The National Nitrate
Compliance Initiative
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Notice
The U.S. Environmental Protection Agency (EPA) produced this document. Mention of reports,
web sites, products, or other reference materials does not constitute EPA's endorsement or
recommendation for use.
United States Office of Enforcement EPA 300-R-02-003
Environmental Protection and Compliance
Agency Assurance (2248A) April 2002
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
CONTENTS
Section Page
EXECUTIVE SUMMARY 1
EPA's Results in Brief 1
The Toxics Release Inventory in Brief 1
The Nitrate Initiative in Brief 2
Achieving Compliance Today, Maintaining Compliance Tomorrow 2
BACKGROUND: THE TOXICS RELEASE INVENTORY 3
Introduction 3
Creation of the Toxics Release Inventory 3
The Basic Reporting Requirement and Enforcement 4
BACKGROUND: THE NATIONAL NITRATE COMPLIANCE INITIATIVE 5
Introduction 5
Water-Dissociable Nitrate Compounds 5
Why Nitrates? 5
Structuring a National Response 6
PERFORMANCE MEASURES 9
Introduction 9
Goal 1: Increasing Reporting of Nitrates to the TRI 9
Goal 2: Substantially Raising Awareness of Coincidental Manufacturing 14
Goal 3: Deterring Future Violations 14
Goal 4: Conserving Resources 15
POLLUTION PREVENTION STRATEGIES 17
Case Study: Nitrates and the Dairy Industry 17
MATERIAL SUBSTITUTION 17
NITRATE TREATMENT TECHNOLOGY 18
Case Study: Nitrates and the Metal Finishing Industry 19
MATERIAL SUBSTITUTION 19
NITRIC ACID RECYCLING 20
DRAGOUT REDUCTION 21
MAINTAINING COMPLIANCE: RESOURCES FOR ASSISTANCE 23
Figures
1 Non-Nitrate Reporting Forms Submitted 14
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Tables
1 Number of Reporting Forms for Nitrates 11
2 Pounds of Released Nitrates Reported 11
3 Pounds of Transferred Nitrates Reported 12
4 Percent Changes in Reported Released, Treated, and Transferred
Nitrates 12
5 Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases
and Transfers of Nitrates 13
6 Changes in Release and Transfer Data for Non-nitrate Compounds 14
Appendices
1 NATIONAL AND REGIONAL ANALYSES OF THE IMPACT OF THE NITRATE
INITIATIVE ON THE TOXICS RELEASE INVENTORY
2 NATIONAL AND REGIONAL FACT SHEETS ON THE IMPACT OF THE NITRATE
INITIATIVE ON THE TOXICS RELEASE INVENTORY
3 NITRATE INITIATIVE: ESTIMATED INSPECTION AND ENFORCEMENT COSTS
SAVED
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
EXECUTIVE SUMMARY
The National Nitrate Compliance Initiative
achieved results through voluntary and
negotiated compliance that reduced the
cost and time associated with traditional
enforcement actions.
EPA's Results in Brief
Through the National Nitrate Compliance
Initiative, the U.S. Environmental Protection
Agency (EPA) implemented a variety of
compliance and enforcement tools to improve
rates of compliance for known reporters: this
initiative increased reporting of nitrate from 60
percent to 98 percent. EPA achieved this
result at a fraction of the time and cost
associated with traditional inspections and
enforcement actions for both EPA and the
regulated community. Specifically, nearly 600
companies agreed to audit more than 1,000
facilities for EPCRA Section 313 regulatory
obligations and to pay administrative
penalties totaling more than $1.4 million. As
a result, EPA, the public, and our state
partners received more than 7,000 revised or
original TRI reporting forms that documented
the release, transfer, and other waste
management of 420 million pounds of nitrates
that previously had been unreported.
Of particular note, the Nitrate Initiative
resulted in the reporting of an additional 250
million pounds of previously unreported
nitrates that were transferred off site to
publicly owned treatment works-a
correction to the TRI of almost 90 percent.
This information improved the compliance of
various TRI reporting elements for nitrates
and other toxic chemicals. For example, the
Nitrate Initiative led to a correction to the TRI
for on-site and off-site releases of nitrates by
an additional 20 percent, of on-site treatment
of nitrates by an additional 94 percent, and of
total transfers off site for further waste
management by an additional 84 percent. Of
particular note, the Nitrate Initiative prompted
facilities to report an additional 250 million
pounds of previously unreported nitrates that
were transferred off site to publicly owned
treatment works (POTW)-a correction to the
TRI by nearly an additional 90 percent. The
reduced use of traditional inspections,
investigations, and litigation allowed agency
resources to be focused on other activities.
More than 600 regulated entities also
benefitted because they were allowed to
reserve more resources for auditing and
compliance rather than paying penalties.
Because more than 1,000 facilities agreed to
conduct comprehensive audits of all TRI
regulatory obligations, participants in the
Nitrate Initiative also properly reported
approximately 100 toxic chemicals other than
nitrates to the TRI for the first time.
Cumulatively, facility audits conducted
through the initiative documented an
additional 106 million pounds of toxic
chemical releases and 33 million pounds of
transfers for further waste management.
The Toxics Release Inventory in Brief
The TRI is a publicly available database that
contains information on specific toxic
chemical releases and waste management
from industrial facilities in the United States,
including federally owned facilities. Some
consider the Emergency Planning and
Community Right-to-Know Act (EPCRA), as
implemented through the TRI, one of the
most powerful forces in empowering the
federal government, state governments,
industry, environmental groups, and the
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
general public for full participation in an
informed dialogue about the environmental
and human health impacts of toxic chemical
manufacture and use in the United States.
Combined with information on hazard and
exposure, the TRI has proven a valuable tool
for identification of risk.
The Nitrate Initiative in Brief
In late 1999, an EPA analysis found reason to
believe that as many as 600 facilities failed to
report to the TRI nitrate compounds that were
coincidentally manufactured during the
treatment of nitric acid. Coincidentally
manufactured chemicals have been
reportable since the very first TRI rulemaking
in 1988. Since 1988, EPA has consistently
provided compliance assistance and outreach
directed toward coincidentally manufactured
chemicals such as nitrate compounds.
Despite chemical- and industry-specific
guidance documents, free national
workshops, and nitrate-specific examples in
the reporting instructions, EPA's analysis of
the data showed that the rate of compliance
remained at approximately 60 percent.
Through this initiative, EPA improved this
rate of compliance through publicized
opportunities to voluntarily disclose
noncompliance and opportunities to conduct
voluntary compliance audits negotiated in
exchange for significantly reduced
administrative penalties.
Achieving Compliance Today, Maintaining
Compliance Tomorrow
The Nitrate Initiative generated attention not
only from the 1,000 facilities that chose to
participate, but also from trade organizations
that represented several industry sectors and
from a variety of environmental news media.
This broad exposure raised awareness of the
basic concept of coincidental manufacturing,
not only for nitrate compounds, but for other
chemicals that are reportable under TRI as
well. This report will be distributed to all
participants in the initiative. It will include
information on compliance assistance and
pollution prevention strategies that can help
to reduce the amount of nitrates that facilities
must manage and to help avoid
noncompliance.
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BACKGROUND: THE TOXICS RELEASE INVENTORY
EPCRA Section 313 charges EPA with
collecting and disseminating information on
chemical releases and other waste
management data, so governments,
industry, and communities can estimate
local exposure and local risks. EPCRA is
intended to provide basic information on
releases that will allow communities and
states to make informed decisions on the
management of toxic chemicals. This
basic empowerment is a cornerstone of the
right to know.
Introduction
Congress enacted the Emergency Planning &
Community Right-To-Know Act (EPCRA) in
1986. Originally a part of the Superfund law,
EPCRA recognizes the unique role
communities play in ensuring environmental
protection at the local level. Just before
EPCRA was enacted, releases of methyl
isocyanate from a chemical manufacturing
facility in Bhopal, India, caused widespread
fatalities and emphasized the need to
develop and share emergency planning and
routine release information with the public. A
similar incident in Institute, West Virginia,
sharpened understanding of this need.
Because the chemicals involved in the
Bhopal disaster are used at facilities located
in the United States, lawmakers recognized
the potential for similar accidents to occur
domestically as well as the dangers posed by
routine releases of toxic chemicals. These
routine, annual releases, if assessed at all,
were known only to the facilities themselves.
Communities were unaware of the magnitude
and potential consequences these releases
posed.
Creation of the Toxics Release Inventory
EPCRA Section 313 created the Toxics
Release Inventory (TRI). The TRI is a
publicly available database that provides
quantitative information about releases of
toxic chemicals and certain other waste
management operations at domestic facilities
that are covered under the law. The TRI is
populated with data through timely and
accurate submission of Toxic Chemical
Release forms from these covered facilities to
the U.S. Environmental Protection Agency
(EPA). This information was collected for the
first time for the 1987 reporting year, creating
the ability for the public, the government, and
the regulated community to understand the
magnitude of chemical releases in the United
States; to compare chemical releases among
facilities and transfers of chemical wastes
among states, industries, facilities, and
environmental media; and, perhaps most
importantly, to assess the need to reduce
and, where possible, eliminate these releases
and transfers. The TRI enables all parties
interested in environmental progress to
establish credible baselines, to set realistic
goals, and to measure progress in meeting
these goals over time.
Before EPCRA was enacted, the kind of
information now contained in the TRI was
generally nonexistent or unavailable to the
federal government, state governments,
emergency preparedness teams, or the
general public. If this information was
disclosed, it usually was made available only
after major impacts to human health and the
environment were evident. This "after-the-
fact" disclosure of information did little to help
plan for or prevent serious damage to human
health or the environment or to manage
cumulative releases. EPCRA Section 313
allows communities to estimate local
exposure and local risks, which can be
significantly different than are assessed at
the national level. These data can also be
used to draw a national picture of releases
and discern waste management trends over
time. The intent of EPCRA Section 313 is to
move the determination of risks that are
acceptable from EPA to communities and the
states where the releases occur. This basic
empowerment is a cornerstone of the right to
know.
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
The Basic Reporting Requirement and
Enforcement
EPCRA Section 313 requires certain
manufacturers, processors, and users of
more than 650 listed toxic chemicals and
chemical compounds1 to report annually on
the quantity of toxic chemicals that enters
each environmental medium. The Pollution
Prevention Act (PPA) of 1990 requires
additional data and information to be included
annually on "Form R" reports, including
strategies for pollution prevention that focus
on source reduction as the primary means of
achieving and maintaining compliance.
Facilities must now report the quantities for
each toxic chemical released on site to air,
water, and land (including underground
injection), or transferred off site for disposal.
They also must report quantities that are
otherwise managed as waste (treated on site
or off -site), combusted for energy recovery
on site or off site, and recycled on site and off
site. These reports must be sent to EPA and
the state or tribal agencies by July 1 of each
year for the prior year ending December 31.
EPA is responsible for implementing and
enforcing EPCRA Section 313, the PPA, and
any rules promulgated pursuant to EPCRA
and the PPA.
EPCRA Section 325(c) authorizes EPA to
assess civil administrative penalties for
violations of Section 313. Any owner or
operator of a facility who violates any
requirement of Section 313 is liable for a civil
administrative penalty of up to$27,5002 for
each violation. Federal agencies are not
subject to the reporting requirements based
on Standard Industrial Classification (SIC)
codes; however, Executive Order (EO) 13148
requires federal agencies to comply with
EPCRA and the PPA of 1990. Each day a
violation continues may constitute a separate
violation. The EPA administrator may assess
civil penalties after an administrative hearing
or may bring actions to assess and collect
penalties in the U.S. District Court.
1 See generally Title 40 Code of Federal Regulations
(CFR) 372 fora description of the requirements of
EPCRA Section 313 . See also 40 CFR 372.65 for the
current list of toxic chemicals regulated under EPCRA
Section 313.
" Pursuant to the Debt Collection Improvement Act,
violations occurring after January 30, 1997, are subject
to a maximum penalty of $27,500.
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
BACKGROUND: THE NATIONAL NITRATE COMPLIANCE INITIATIVE
EPA discovered significant noncompliance
rates with a critical element of TRI
reportingcoincidental manufacturing of
nitrate compoundsand employed a
variety of regulatory tools to achieve and
preserve improved rates of compliance.
Introduction
Early in fiscal year 2000, EPA analyzed
reporting patterns and discovered potential
widespread noncompliance with the EPCRA
Section 313 reporting obligations for nitrates.
EPA determined that many facilities submitted
"Form R" for nitric acid but failed to report
coincidentally manufactured nitrate
compounds, which typically result from the
neutralization of nitric acid. Facilities that
coincidentally produce nitrate compounds at
quantities that exceed the manufacturing
threshold and that otherwise satisfy the
elements of EPCRA Section 313 and 40 CFR
Part 372 are required to submit a Form R or a
Form A. EPA began investigating facilities
that failed to submit a Form R or Form A for
nitrate but appeared to coincidentally
manufacture nitrate in amounts that exceeded
the manufacturing threshold.
Water-Dissociable Nitrate Compounds
All water-dissociable nitrate chemicals have
been subject to the requirements of EPCRA
Section 313 as a category since 1995 (reports
were due July 1, 1996). As stated in the
directions that accompany the 1998 Form R
and Form A: "manufacturing . . . EPCRA
Section 313 chemicals during waste
treatment is commonly overlooked. For
example, the treatment of nitric acid may
result in the coincidental manufacturing of a
reportable chemical (nitrate compounds)."
Toxic CHEMICAL RELEASE INVENTORY
REPORTING FORMS AND INSTRUCTIONS,
Appendix C, page 2 ("Common Errors
Completing Form R Reports") (February
1999). The partial or complete neutralization
of nitric acid creates nitrate compounds (such
as sodium nitrate and potassium nitrate),
which requires annual Form R or Form A
reports if they were manufactured in excess
of 25,000 pounds and if all other EPCRA
reporting criteria are satisfied. At a pH of 6,
EPA considers the waste acid to be 100
percent treated. Consistent with the EPA
guidance document, "Toxics Release
Inventory. List of Toxic Chemicals within the
Water, Dissociable Nitrate, Compounds
Category and Guidance for Reporting" (June
1999) ("Nitrate Guidance") (originally
published in 1995), a facility that treats or
neutralizes 18,000 pounds or more of nitric
acid on site with sodium hydroxide to a pH
above 6 will likely manufacture 25,000
pounds of sodium nitrate, and therefore will
be required to submit a Form R or Form A for
nitrates. The use of other neutralizing
compounds for example, potassium
hydroxide will result in a greater weight of
nitrate compounds for the same amount of
acid neutralized.
Why Nitrates?
Nitrates are toxic chemicals that can pose
serious risks to human health and the
environment. Exposure to high levels of
nitrates may cause serious illness or death,
as well as significant environmental damage
to streams, lakes, and rivers. Infants and
children are especially sensitive to elevated
levels of nitrate, which cause
methemoglobinemia, or "blue-baby
syndrome." When too much nitrate is
ingested, it reduces the capacity of blood to
carry oxygen, turning the skin blue, causing
shortness of breath, and depriving the brain of
oxygen. These effects in turn, increase the
risk of brain damage. Other long-term effects
include dieresis, increased starchy deposits,
and hemorrhaging of the spleen.
Under the authority of the Safe Drinking
Water Act (1974) EPA has set a maximum
contaminant level (MCL) for public water
supplies of 10 milligrams per liter (mg/L),
which is equal to 10 parts per million (ppm)
for nitrogen in the nitrate form. This level
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
provides a margin of safety against a
significant risk to human health. EPA
believes water that contains nitrogen in the
nitrate form at or below this level is
acceptable for daily drinking over a lifetime
and does not pose a health risk of
methemoglobinemia for infants or adults.
Catastrophic releases and their adverse
health effects have prompted EPA to take
emergency action. On June 7, 2000, EPA's
Region III (in the mid-Atlantic area) issued an
emergency order under the Safe Drinking
Water Act to AK Steel Corporation to provide
bottled water to more than 4,000 people in
Zelienople, Pennsylvania, because AK Steel
contaminated local drinking water and more
than 21 miles of the Connoquenessing Creek
with dangerous levels of nitrates.
Elevated levels of nitrate may damage
surface water and ground water with excess
nutrients and can cause algae blooms in
coastal waters, which can remove oxygen
from the water and result in fish kills. Nitrate
contamination is a real and widespread
environmental problem. The National
Academy of Sciences recently reported that
pollution by nitrogen and phosphorous were
causing damage in most of the nation's
coastal inlet, with severe problems identified
in 44 of the 139 coastal areas examined.
The discussion shows that discharges of
nitrate-contaminated water to surface water or
groundwater could affect drinking water
supplies. EPA has promulgated regulations
that directly or indirectly limit discharges of
pollutants such as nitrate to surface water and
groundwater. For example, in 1972,
Congress enacted the Clean Water Act
(CWA) to restore and maintain the integrity of
the nation's waters. EPA's National Pollutant
Discharge Elimination System (NPDES)
Permitting Program represents one of the key
components established to accomplish this
task.
The NPDES program requires that all point-
source discharges to waters of the United
States be permitted. The permits regulate
point sources such as industries and
concentrated animal feeding operations that
discharge directly into receiving waters.
Permits include site-specific limits and
standards and site-specific compliance
monitoring and reporting requirements. The
permit writer develops site-specific conditions
for the permit based either on national
standards or on more stringent local water
quality standards. The permit conditions may
involve conventional pollutants, toxic
pollutants, or nonconventional pollutants such
as nitrates.
The combination of human health and
environmental risks posed by nitrates
emphasizes the need to provide communities
with reliable data about releases of nitrate by
neighboring facilities.
Structuring a National Response
In light of the human health and
environmental risk posed by nitrates and the
noncompliance rate, which suggests that
communities were denied access to valuable
information, EPA concluded that it was
appropriate to adopt a nationally consistent
enforcement response. EPA named this
response "The National Nitrate Compliance
Initiative".
EPA designed the Nitrate Initiative to draw on
multiple tools to achieve compliance. First,
EPA sought to raise awareness to achieve
voluntary compliance. EPA began the Nitrate
Initiative on March 1, 2000, when the agency
issued an "Enforcement Alert" that described
the lack of compliance with the reporting
required for coincidentally manufactured
nitrate and urged facilities to self-disclose
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violations under EPA's Audit and Small
Business Policies. Many facilities took this
opportunity.
Nevertheless, many facilities did not respond
and remained out of compliance.
After voluntary disclosure, EPA's next tool
was the use of broad, industry-wide
settlements. On April 28, 2000, EPA issued
"Notice of Opportunity to Show Cause" letters
(Show Cause Letters) to facilities that had not
disclosed violations but appeared out of
compliance (as described above). Show
Cause Letters offered facilities the opportunity
to demonstrate the violations EPA alleged
had not occurred or to accept a settlement by
signing and returning a National Nitrate
Compliance Agreement (Option I Agreement),
which recited the proposed primary terms and
conditions of a settlement and was enclosed
with each Show Cause Letter. These
proposed terms included a drastically reduced
penalty of $5,000 per year of violation at each
facility that was not in compliance, and proper
reporting of nitrates in the future. EPA
regions were responsible for developing and
implementing procedures to verify statements
made in the Show Cause Letters.
EPA concluded that there was an opportunity
to achieve greater compliance. Therefore, on
or about June 23, 2000, EPA issued follow-up
correspondence with facilities that received
the Show Cause Letter that described an
alternative settlement and included a National
Nitrate Compliance Option II Agreement.
Under the Option II Agreement, EPA
proposed to settle confirmed violations of the
reporting requirements for nitrate for $5,000
per company or $1,000 per company for
businesses with fewer than 100 employees,
regardless of the number of facilities or years
of violation. In exchange for the flat penalty,
Option II required participants to undertake a
compliance audit of all obligations under
EPCRA Section 313 , emphasizing the
coincidental production of all listed toxic
chemicals at all facilities that received the
Show Cause Letter. The compliance audit
under the Option II Agreement must have
been completed and submitted by October
27, along with an audit report, which
described the audit procedures, any violations
discovered, and steps taken to prevent future
violations.3 The majority of companies that
participated in the Nitrate Initiative agreed to
settle under the terms of Option II. Ultimately,
Option II allowed EPA to achieve far greater
compliance and enabled the regulated
community to focus resources on compliance
rather than on paying penalties.
" Consistent with the general Statute of Limitations on
administrative actions, EPA will not seek stipulated
penalties for violations it may discover that are over 5
years beyond the date the violation occurred.
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PERFORMANCE MEASURES
The principal objective of the EPCRA
Section 313 Enforcement Program is to
promote the community's right to know
by monitoring the accuracy and
completeness of the TRI database. The
Nitrate Compliance Initiative
(1) substantially increased nitrate
reporting to the TRI, (2) substantially
raised awareness of reporting
responsibilities for nitrate compounds
that are coincidentally manufactured, (3)
deterred future violations, and (4)
conserved resources for EPA and the
regulated community.
Introduction
The National Nitrate Compliance Initiative
also provided a unique opportunity to
measure the effect and effectiveness of an
industry-wide, project that used multiple tools
to restore an industry sector to compliance.
The large number of regulated entities
participating in the Nitrate Initiative allowed
EPA to analyze changes in behavior both
quantitatively and qualitatively . EPA selected
four performance measures for the Nitrate
Initiative: the amount of nitrates reported to
the TRI; the awareness in the regulated
community of reporting requirements for
coincidentally manufactured compounds;
deterrence of future violations; and the cost
savings of the initiative for EPA and the
regulated community.
The most meaningful measure is the change
in nitrate reporting. The results are striking.
The number of reports increased 63 percent.
The reported pounds released increased 20
percent. The reported pounds transferred
increased 84 percent. Overall, an additional
580 million pounds of nitrates were reported
to the TRI, an increase of 47 percent.
Goal 1: Increasing Reporting of Nitrates to
the TRI
NUMBER OF REPORTS
Participants in the Nitrate Initiative submitted
an additional 2,452 reporting forms. These
reports represented a 63 percent increase
over the baseline. Of these reporting forms,
2,206 were submitted for the first time and
246 were submitted as revisions to reports
that had been filed previously. Table 1 details
the number of new and revised nitrate
submissions for each reporting year covered
by the initiative (1995 through 1998)
compared with the number of baseline
reports. Baseline reports are reporting forms
that were submitted to the TRI before the
Nitrate Initiative began.
POUNDS OF NITRATES RELEASED
These new and revised reports added more
than 155 million pounds of nitrate releases to
the TRI that previously had been unreported
.4 These releases marked a 20 percent
increase over the baseline. Based on an
analysis before the Nitrate Initiative began,
EPA expected to claim an additional 50 to
100 million pounds of nitrate releases.
Therefore, EPA's actual results for Goal One
exceeded the most optimistic expectations by
more than 50 percent. Table 2 details the
amount of new and revised nitrate releases
captured by the initiative by year, and the
overall change to the TRI compared with
baseline reports. The baseline quantity
represents the cumulative release totals from
all nitrate reporting forms submitted before
the Nitrate Initiative began.
POUNDS OF NITRATES TRANSFERRED
Cumulatively, participants disclosed an
additional 267 million pounds of nitrate
transfers that had previously been
As defined in the TRI, release numbers represent both
on-site and off-site releases.
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unreported5, further exceeding EPA's
projected results. These transfers
represented a 84 percent increase over the
report baseline. Table 3 details corrected
transfers of nitrate for further waste
management by reporting year.
OVERALL CHANGES FROM THE BASELINE
The most dramatic performance measures
are the overall correction rates to the TRI for
various nitrate reporting elements. Total on-
and off-site releases of nitrates have been
corrected by 20 percent. The largest
correction of nitrate releases 49 percent
represented releases to land. Total transfers
off site for further waste management
underwent an even more dramatic
correction84 percent. Notably, the Nitrate
Initiative corrected known transfers of nitrates
to publicly owned treatment works (POTW) by
89 percent.
Table 4 provides greater detail about overall
corrections to the TRI for nitrates. The five
facilities that reported the greatest releases
and transfers of nitrate captured by the
initiative appear in Table 5.
For further information about how the TRI
changed with the new data, refer to Appendix
1, National and Regional Analysis of the
Nitrate Initiative's Impact on the TRI, and
Appendix 2, National and Regional
Factsheets on the Nitrate Initiative's impact
on the TRI.
These transfers include transfers to POTWs and other
off-site transfers for further waste management.
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Table 1
Number of Reporting Forms for Nitrates
Number of Reports
Reporting Year
1995
1996
1997
1998
1995-1998
Baseline
Reports
831
920
993
1,138
3,882
Revised
Reports
Submitted
28
40
53
125
246
New
Reports
Submitted
539
555
558
554
2,206
Total
Reports
1,370
1,475
1,551
1,692
6,088
Change in
Reports
567
595
611
679
2,452
Table 2
Pounds of Released Nitrates Reported
Release Quantities Reported (pounds)
Reporting Year
1995
1996
1997
1998
1995-1998
Quantity
from
Baseline
Reports
142,025,029
176,789,334
201,999,901
239,107,562
759,921 ,826
Changes
from
Revised
Reports
3,463,387
1 ,526,322
1 ,235,063
8,984,704
15,209,476
Increases
from New
Reports
32,336,622
38,178,768
33,943,735
35,948,722
140,407,847
Updated
Database
Quantity
177,825,038
216,494,424
237,178,699
284,040,988
915,539,149
Change in
Pounds
35,800,009
39,705,090
35,178,798
44,933,426
155,617,323
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Table 3
Pounds of Transferred Nitrates Reported
Transfer Quantities Reported (pounds)
Reporting Year
1995
1996
1997
1998
1 995-1 998
Quantity
from
Baseline
Reports
66,915,608
77,190,990
84,192,722
88,898,236
317,197,556
Changes
from
Revised
Reports
564,374
-1,008,027
691 ,303
923,671
1,171,321
Increases
from New
Reports
62,803,621
62,764,358
70,300,688
69,735,794
265,604,461
Updated
Database
Quantity
130,283,603
138,947,321
155,619,729
159,122,595
583,973,248
Change in
Pounds
63,367,995
61 ,756,331
70,991 ,991
70,659,465
266,775,782
Table 4
Percent Changes in Nitrates Reported Released, Treated, and Transferred
(Reporting Years 1995 through 1998)
Type of Release or
Transfer
On-Site Releases
Surface Water
Discharges
Underground
Injection
On-site Land
Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to POTWs
Other Off-site Transfers
Total Transfers Off-site
for Further Waste
Management/Disposal
Total of All Releases, On-
Site Treatment, and
Transfers Off-Site
Baseline Data1
(pounds)
741 ,868,493
584,802,309
135,524,966
21,541,218
18,053,333
759,921 ,826
168,711,455
288,575,876
28,621 ,680
317,197,556
1 ,245,830,837
Changes from
Revised
Reports
(pounds)
15,260,506
19,882,241
-4,608,780
-12,955
-51 ,030
15,209,476
7,406,317
3,110,154
-1,938,833
1,171,321
23,787,114
Increases from
New Reports 2
(pounds)
137,813,893
127,037,228
306,967
10,469,698
2,593,954
140,407,847
151,063,582
254,804,991
10,799,380
265,604,371
557,075,800
Net Change
from All
Reports
(pounds)
153,074,399
146,919,469
-4,301,813
10,456,743
2,542,924
155,617,323
158,469,899
257,915,145
8,860,547
266,775,692
580,862,914
Percent
Change to
Baseline Data
21%
25%
-3%
49%
14%
20%
94%
89%
31%
84%
47%
(1) The baseline information reflects Toxic Release Inventory data as of December 31,
(2) "New reports" are reports submitted for the first time after January 1, 2000.
1999.
12
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Table 5
Releases and Transfers of Nitrates for Top Five Facilities Ranked on Total Changes in Releases
and Transfers(Reporting Years 1995 through 1998)
Facility, City, State
Hercules Inc. Parlin Plant,
Parlin, NJ
Siid-Chemie Inc., West Plant,
Louisville, KY
First Chemical Corporation,
Pascagoula, MS
Anheuser-Busch Inc.,
Baldwinsville, PA
Osram Sylvania Products Inc.,
Towanda, PA
Responded to
Enforcement
Alert?1
No
No
No
No
No
First Time
Reporter?
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
0 00
0 0 24
0 00
10,240,413 0 0
8,109,372 0 0
Total
Changes
in On-site
Releases
(pounds)
0
24
0
10,240,413
8,109,372
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes in
Transfers to
POTWs
(pounds)
61 ,576,521
16,100,000
10,484,000
0
0
Total
Changes in
Other
Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1. 2000.
13
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Goal 2: Substantially Raising Awareness
of Coincidental Manufacturing
All participants in the Nitrate Initiative that
chose to settle under Option II were required
to conduct a comprehensive environmental
audit of all regulatory obligations under
EPCRA Section 313. The audit required
specific attention to any additional unreported
chemicals that may have been generated as a
result of coincidental manufacture. In total,
1,050 facilities agreed to these audits under
the Option II settlement. As a result, EPA
reached a sizable number of facilities from a
variety of industries and substantially
increased understanding of and compliance
with reporting obligations for coincidental
manufacturing of nitrate compounds. Figure 1
details the forms submitted as a result of the
Nitrate Initiative that reported compounds
other than nitrate. Although these forms are
not entirely attributable to coincidental
manufacturing, the Nitrate Initiative was
responsible for a significant correction to
information on releases, transfers, and other
waste management for chemicals other than
nitrate as well. Table 6 describes these
changes by media.
These results also exceeded EPA's initial
expectations.
FIGURE 1
NON-NITRATE REPORTING FORMS
Ol IDMITTCn
1600
1400
| 1200
0 1000
LI-
'S
o>
.a
E
800
600
400
200
0
1995 1996 1997
Reporting Year
New n Revised All
1998
TABLE 6
Changes in Release and Transfer Data for
Non-nitrate Compounds
(Reporting Years 1995 Through 1998)
Type of Release or Transfer
On-site Releases
Air Releases
Surface Water Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site Releases
Transfers to POTWs
Other Off-site Transfers
Total Transfers Off-site for Further
Waste Management/Disposal
Total of All Releases and Transfers
Off-site
-3,679,740
37,170,093
33,490,353
139,604,777
Net Change from
All Reports
(pounds)
57,126,724
11,750,723
4,665,516
16,504,379
24,206,106
48,987,700
106,114,424
Goal 3: Deterring Future Violations
In spite of the substantially reduced penalties
each regulated entity paid in the Nitrate
Initiative, EPA still assessed approximately
$1.5 million in administrative penalties against
participants in the Nitrate Initiative. In
addition, nitrate settlements required
participants to agree to pay stipulated
penalties should EPA discover any additional
violations of EPCRA Section 313 that were
not reported in the required audit unless they
were self-disclosed by the violator. This
settlement structure provides further
incentives to maintain compliance with
EPCRA Section 313. Trade press and other
media coverage likely raised awareness with
facilities that had not specifically been
targeted by EPA.
EPA's emphasis on reporting by-product
formation has also raised the level of
awareness for reporting Persistent,
Bioaccumulative, and Toxic (PBT) chemicals
under EPCRA Section 313. PBT chemicals
were first required to be reported to the TRI
14
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
starting in 2000. Many PBT chemicals are
coincidentally manufactured as a by-product
or impurity from combustion operations and
could easily be overlooked in the same
fashion as were nitrates. Reporting
thresholds for PBT chemicals, which can be
as low as 0.1 gram for dioxin and dioxin-like
compounds, are significantly lower than the
25,000 pound annual threshold value for
nitrates.
These PBT chemical reports will provide data
on releases, transfers, and other waste
management operations for calendar year
2000. PBT chemicals are of particular
concern not only because they are toxic, but
also because they remain in the environment
for long periods, are not readily destroyed,
and build up or accumulate in body tissue.
Relatively small releases of PBT chemicals
can pose threats to human health and the
environment. Consequently, releases of
these chemicals warrant recognition by
communities.
Goal 4: Conserving Resources for EPA
and Regulated Community
EPA and the regulated community expended
substantially fewer resources to return many
entities to compliance. Traditional
enforcement, including investigations,
inspections, and litigation would have cost all
parties significantly more in time and money.
For every dollar spent, approximately $6 were
saved. Assuming a 25 percent
noncompliance rate with EPCRA Section 313
reporting, EPA would have traditionally spent
approximately $2.75 million in enforcement
resources to manage and settle the same
number of cases.
EPA was able to increase compliance as well
as improve the accuracy of the TRI database
by effectively using resources and directly
engaging the facilities with suspected
violations of the reporting requirements for
nitrate. Through this innovative approach,
EPA saved approximately $2.35 million in
capital resources and required an additional
1,000 facilities to review and correct any
compliance issues under EPCRA Section
313. Refer to Appendix 1, EPA's estimate of
inspection and enforcement costs that would
have been incurred to achieve results similar
to this initiative.
The regulated community also saved
resources compared with typical expenses
during traditional enforcement litigation.
Instead, resources were directly spent on
returning facilities to compliance.
15
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
POLLUTION PREVENTION (P2) STRATEGIES
Pollution Prevention strategies can enable
facilities to limit the amount of nitrates
managed, ultimately reducing releases,
transfers, and other waste management,
saving money, and reducing human health
and environmental impacts without
government intervention.
Case Study: Nitrates and the Dairy
Industry
MATERIAL SUBSTITUTION
Dairy processing facilities use nitric acid
during the equipment cleaning process
(process lines, weigh jars, vessels, and other
equipment). Much of the equipment is
cleaned using the clean-in-place (CIP)
procedure, which involves the following steps:
1. Pre-rinse
2. Wash (usually with an alkaline cleaner to
emulsify fats)
3. Rinse
4. Nitric acid post-rinse
5. Drain
6. Sanitize
Nitric acid is used in the post-rinse step to
limit (1) the buildup of milkstone (mineral salts
derived from water supply and milk), and (2)
bacterial growth. It also helps to eliminate
spotting and streaking and neutralizes
alkaline residues from the washing step.
Pollution Prevention (P2) strategies for nitric
acid in the dairy industry involve material
substitution technologies. In addition, nitric
acid can be treated in the wastewater.
Material substitution alternatives and
treatment of wastewater contaminated with
nitric acid are discussed below.
Alternatives to nitric acid that are less
hazardous have not been widely available as
a result of performance and cost issues.
Specifically, with respect to performance,
public health issues are of concern, and
cleaning solutions must disinfect to reduce
the potential for contaminated milk and milk
products. Some vendors are marketing
alternatives to nitric acid to replace or reduce
use of nitric acid. These alternatives are
discussed briefly below.
Several chemical vendors for the dairy
industry are beginning to market alternatives
to nitric acid in the United States; examples
from Kern Tech, Bio/Chem Research, Inc.,
Ecolab, Inc., and DuPontare provided below.
None of these vendors mentioned the
companies using its products or the specific
purpose, but they all indicated that the
products can be used as alternatives to nitric
acid in the dairy industry, and most of them
stated that dairies are purchasing these
products.
Dairy Processing
Kern Tech offers a line of cleaning products
(SAFE-AR) that can be used in place of nitric
acid or a nitric and phosphoric acid
combination to remove milkstone, calcium,
and lime deposits. The SAFE-AR line is a
non-corrosive, biodegradable, low-pH,
organic salt solution that works like an acid.
Companies that have used SAFE-AR
reported that it cleans as well as nitric acid,
does not smell bad (unlike nitric acid), does
not burn workers' skin, and saves money
because it does not damage parts, such as
gaskets, that nitric acid destroys.
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Bio/Chem Research, Inc., offers a product
called CITRICIDAL that is made from
grapefruit extractives and glycerin. According
to the manufacturer, the product is nontoxic,
noncorrosive, and biodegradable that does
not contaminate milk. It can be used to
eliminate the crusts of cream and other
particles in milk storage tanks after they have
been washed with water and a neutral
detergent.
Ecolab, Inc., offers an
equipment-washing
detergent called
Mandate LT, which is
a combination of
phosphoric acid,
propionic acid, organic
acids, and anionic
surfactants, for use in
place of nitric acid.
Milk Solids Processing
Equipment
DuPont offers a line of glycolic acid products
that can be used in place of nitric acid.
DuPont conducted a series of tests on acids
(glycolic, sulfamic, phosphoric, and sodium
bisulfate) as post-rinse cleaners for dairy
equipment. Glycolic acid and sulfamic acids
were found to be the most effective
compounds tested. Glycolic acid is also the
mildest of the acids tested and the most
effective at removing milkstone deposits at
varying levels of pH. According to DuPont,
glycolic acid has been used for many years
as a cleaner for dairy equipment and is a
readily biodegradable, nonvolatile,
phosphate- and chloride-free, nontoxic, non-
fuming, and low-corrosive cleaner.
Note: EPA does not endorse or sponsor any
of the entities mentioned in this report, or any
specific technology. The names of the
entities and technologies are provided as
examples only.
NITRATE TREATMENT TECHNOLOGY
Dairy processes that use nitric acid in
cleaning operations generate wastewater that
contains nitric acid, which is neutralized into
nitrates during the wastewater treatment
process. Nitrates can be separated from
wastewater using reverse osmosis, ion
exchange, electrodialysis, and evaporation;
however, these methods do not destroy
nitrates and are often energy-intensive and
expensive to purchase and operate. The
Los Alamos Environmental Science and
Waste Technologies group developed a
nonthermal, nonbiological technology
(ChemDen) that uses a mixture of metal
and acid to strip oxygen atoms from nitrates
and reduces the nitrates to water and nitrogen
gas that can be safely released into the
atmosphere. The process is less expensive
and more efficient than other methods used to
destroy or remove nitrate wastes. The
process has been tested on a pilot scale and
is awaiting full-scale commercialization. The
pilot equipment can eliminate about 2.5
pounds of nitrates from wastewater per hour,
from a waste stream that contains up to 500
grams per liter of nitrates. For further
information, contact Jacek Dziewinski
(505) 667-9792, jacek@lanl.gov.
Biological treatment systems can also convert
nitrates to nitrogen gas in a properly designed
and operated wastewater treatment plant.
This process is known as denitrification.
More information on denitrification and other
wastewater treatment processes can be
obtained from EPA's Office of Water, Office of
Wastewater Management, at
http://www.epa.gov/owm/mtbfact.html.
18
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Case Study: Nitrates and the Metal
Finishing Industry
All metal finishing (electroplating and
anodizing) processes involve a series of tanks
that contain chemical solutions. Parts are
sequentially immersed to achieve the desired
decorative or functional surface finish.
Between chemical tanks is at least one tank
that holds clean water used to rinse the film of
the chemical solution that remains on the part
after it is removed from the chemical tank
(this film is known as dragout). Generically,
there are three stages in most metal finishing
processes: surface preparation, surface
finishing, and post-finishing.
Metal finishers use nitric acid for various
reasons, depending on the type of metal
processed; however, nitric acid is used for
two general purposes: surface preparation
and stripping. Surface preparation removes
oxides, scale, and other contaminants from
the surface of the part to achieve a quality
finish. Specifically, nitric acid is commonly
used (1) for descaling or passivating
(removing free iron and iron oxide) stainless
steel; (2) as an ingredient in several bright
dips, which are mixtures of nitric, sulfuric, and
phosphoric acid; and (3) in combination with
hydrofluoric acid to remove heat scale.
Stripping is used on "reject" parts (plated
parts with quality defects) to remove plated
metal so the parts can be processed again.
Stripping also removes metal buildup on
racks used to move parts through the metal
finishing process.
Material Flows for Metal Finishing
Evaporation
Loss
Evaporation
Loss
(and Dragin)
Process
Chemicals
Parts and Dragout
kAi/OS^.
PROCESS BATH
Dragout
Parts and Dragout
RINSE TANK
Wastewater
For more than 10 years, EPA, states, and
local governments have initiated P2 outreach
to the metal finishing sector. Much of this
work has culminated in the National Metal
Finishing Strategic Goals Program (SGP).
The SGP was established on the foundation
of work and relationships built under EPA's
Common Sense Initiative. The SGP is a
unique, collaborative effort to define new,
performance-based approaches to
compliance and proactive environmental
management in the metal finishing sector.
Information about the SGP can be found at its
website: www.strategicgoals.org.
Specific P2 strategies for nitric acid can be
organized in three categories: material
substitution, recovery and recycling
technology, and reduction in dragout; each of
these categories is discussed below.
MATERIAL SUBSTITUTION
Alternatives to nitric acid that are less
hazardous have not been widely available as
a result of performance, cost, and customer
specification issues. However, recent
changes in passivating standards for stainless
steel allow citric acid to be substituted for
nitric acid, and some vendors are marketing
proprietary formulations to replace or reduce
nitric acid. These alternatives are discussed
briefly below.
Spent Baths
Freshwater
19
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Citric Acid Passivation
Government standard QQP3C established
widely used parameters for stainless steel
passivation using nitric acid (typically 20 to
50 percent by volume). However, the
American Society for Testing and Materials
(ASTM) established, in ASTM A967, a new
passivation standard that allows citric acid
passivation; this standard has replaced
QQP3C. Citric acid (4 to 10 percent by
weight) is an effective passivating agent that
typically operates faster than nitric acid,
thereby improving throughput. Nitric acid
passivation baths are often heated
(sometimes up to 160 «F), whereas citric acid
baths can be operated at room temperature.
From a quality perspective, citric acid meets
or exceeds nitric acid in various performance
tests for corrosion resistance. Citric acid may
cost up to 20 percent more than nitric acid;
however, the higher purchase price is offset
by lower waste treatment costs. According to
manufacturers and metal finishing facilities,
wastewater from citric acid passivation can be
sent directly to the sewer, sometimes without
requiring pH adjustment. In addition,
processing at room temperature reduces
heating costs.
Unlike nitric acid, citric acid does not emit
smog-producing nitrous oxide (NOx) vapors,
does not require special handling, and does
not corrode other equipment. Moreover, citric
acid passivates without removing significant
amounts of nickel, chromium, and other
metals from the part, which reduces
hazardous constituents in dragout and spent
baths.
Alternatives to Proprietary Chemicals or
Additives
Several vendors for metal finishing chemicals
are beginning to market alternatives and
additives for surface preparation and stripping
baths that use nitric acid; examples from
Atotech and McDermott are provided below.
Atotech offers two proprietary solutions that
substitute for conventional nitric acid
processes. MTJ Rackstrip is an electrolytic
rack stripper that removes plated copper,
nickel, and chromium from stainless steel
rack tips. MTJ Rackstrip replaces nitric acid
stripping baths (typically 50 to 100 percent by
volume), contains proprietary, nonhazardous
chemicals, and operates at a pH range of 6.3
to 6.8. Alumetch NN is a nitric acid-free
deoxidizing solution for aluminum anodizing
processes. Alumetch NN can replace
conventional deoxidizing solutions (typically
50 percent nitric acid); it operates at ambient
temperature and causes less pitting than nitric
acid solutions.
McDermott offers a proprietary material
(Clepostrip 569NA and 569ND ) that
(1) reduces the concentration of nitric acid
required in stripping and aluminum bright dip
baths, and (2) oxidizes NOx emissions to
nitrogen gas, thereby significantly reducing
toxic air emissions. One medium-size
company involved in decorative metal
finishing reported that the concentration of
nitric acid in a stripping bath could be reduced
from 100 to 30 percent with measurable
reductions in emissions; however, this facility
also noted that the new process required
twice as much time and careful supervision to
prevent attack on the base metal.
NITRIC ACID RECYCLING
Although it is not common,
the National Center for
Manufacturing Sciences
cites metal finishing facilities
that have attempted to recycle
(purify), rather than neutralize, spent acids
using acid sorption technology. Acid sorption
technology relies on specialized anion
exchange resins to separate metal
contaminants from the acid. Acid sorption is
primarily applicable to sulfuric and
hydrochloric acid solutions; however, the
National Center for Manufacturing Sciences
report refers to case studies from EcoTec, a
technology vendor, where acid sorption was
applied to a nitric acid stripping bath and an
20
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
aluminum bright dip bath that contained nitric
acid. Acid sorption cannot be applied to
solutions with a concentration of nitric acid
that exceeds 35 percent, which, together with
the "exotic" nature of the technology, explains
its limited use in the metal finishing industry.
DRAGOUT REDUCTION
Formation of nitrate during on-site wastewater
treatment is proportional to the amount of
nitric acid introduced to the treatment system
from rinse tanks, which, in turn, is proportional
to the volume of dragout from the nitric acid
process bath. Numerous P2 techniques exist
to reduce dragout, including over-tank spray
systems, slower withdrawal rate, longer hang
time, rack tilt pads, and many more. These
P2 techniques are often not rigorously
implemented because they require changes
in worker practice or modifications to the
process line that facilities hesitate to
implement based on time constraints or
quality concerns, or because they have
insufficient data to quantify operational and
environmental benefits. Nevertheless,
fundamental practices that reduce dragout,
when implemented regularly, can result in
significant source reductions and associated
material use and treatment costs. The
following chart illustrates the percent
reduction associated with four dragout
reduction techniques measured at 10 metal
finishing facilities.
Operator Techniques
Parts Racking
Drain Time
(2-5 icctuch)
Spray Rtnsing
C2-S Mc'mek)
Till and Drain
(1-3 Me/rack)
28.8%
| Average Reduction
Individual Experiments
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Percent Dragout Reduction
21
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THE NATIONAL NITRATE COMPLIANCE INITIATIVE
MAINTAINING COMPLIANCE: RESOURCES FOR ASSISTANCE
The following compliance assistance
references provide opportunities to obtain
further information on the Toxics Release
Inventory and reporting obligations:.
EPA compiles data contained in facility
reports on release and other waste
management operations that involve toxic
chemicals in the TRI, an on-line, publicly
accessible, national computerized database.
The TRI helps communicate information to
communities on releases (that is, toxic
chemicals that are released into the
environment) and other waste management
activities (that is, toxic chemicals that may not
be released but are managed by on- or off-
site waste management facilities) of
manufacturing facilities and certain other
industry sectors. TRI data, in conjunction with
other information, can be used as a starting
point in evaluating exposures that may result
from releases and other waste management
operations that involve toxic chemicals. The
estimate of potential risk depends on many
factors, including the toxicity of the chemical,
the fate of the chemical after it is released,
the locality of the release, and the populations
that are exposed to the chemical after it is
released. EPA communicates this
information to the public so it can be used in
several ways. For example, TRI data provide
citizens with an opportunity to become active
in emergency planning and prevention
activities in the community.
In addition, the TRI website provides valuable
information to the regulated community on the
regulations and policies that govern reporting
requirements, chemical- and industry-specific
guidance documents, question and answer
documents, and access to the required
reporting forms and instructions. Useful
resources for TRI information includes:
EPA's TRI Homepage:
http://epa.gov/tri/
TRI Reporting Forms and Instructions:
http://www.epa.gov/tri/report.htm
Guidance Documents:
http://www.epa.gov/tri/guidance.htm
Other TRI Policy Documents,
Regulations, and Statutes:
http://www.epa.gov/tri/trirules.htm
EPA also maintains a Hotline telephone
number and website, which can be accessed
at:
EPCRA Hotline: 1-800-424-9346
EPCRATDD: 1-800-553-7672
www.epa.gov/epaoswer/hotline
The following are EPA Compliance and
Enforcement Resources:
Office of Regulatory Enforcement:
http://www.epa.gov/oeca/ore
Toxic & Pesticide Enforcement Division:
http://www.epa.gov/oeca/ore/tped
"Incentives for Self-Policing: Discovery,
Disclosure, Correction and Prevention of
Violations" (Audit Policy):
http://www.epa.gov/oeca/auditpol.html
Small Business Policy:
http://www.epa.gov/oeca/smbusi.html
Protocol for conducting environmental
compliance audits under EPCRA:
http://es.epa.gov/oeca/ccsmd/epcra.pdf
TRI Explorer:
http://www.epa.gov/triexplorer
23
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APPENDIX 1
NATIONAL AND REGIONAL ANALYSES OF THE
NITRATE INITIATIVE'S IMPACT ON THE TOXICS RELEASE INVENTORY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
ALL EPA REGIONS
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; groups and organizations; and the
public in dialogues about environmental and human health impacts from the manufacture and
use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 3,882 nitrate reporting forms for
reporting years 1995 to 1998. Figure 1 shows the number of nitrate reporting forms submitted
to the TRI for each reporting year. The data is shown by submittal year, as reporting forms are
due July 1 of the year after the reporting year. Most forms were submitted on time. The year-
by-year number of submittals typically dropped significantly each year after the due date.
EPA REGION 1 THROUGH 10 SUMMARY
-------
FIGURE 1
NUMBER OF REPORTING FORMS FOR NITRATES
SUBMITTED IN CALENDAR YEARS 1996 THROUGH 2000
FOR REPORTING YEARS (RY) 1995 THROUGH 1998
RY1998
RY1997
RY1996
RY1995
1996 1997 1998 1999 2000
Year Submitted
In calendar year 2000, the effect of the Nitrate Initiative is shown in the substantial increases in
the number of submittals for reporting years 1995 through 1997. For reporting year 1998, the
Nitrate Initiative resulted in a substantially diminished decrease in the number submittals
between calendar years 1999 to 2000, especially as compared to the prior years, 1995 to 1997.
During the Nitrate Initiative, about 800 facilities submitted a total of 2,452 reports for nitrates.
One hundred fifty-seven of these facilities submitted reporting forms in response to the
enforcement alert. As shown in Table 1, the majority of these forms are "new reports," which
are reports that were submitted for the first time during the Nitrate Initiative. These new reports
increased by over 50 percent the number of nitrate reporting forms in the TRI database from
facilities. Fewer than 250
reports were submitted as TABLE 1
revisions to nitrate reports
filed prior to the Nitrate
Initiative.
NUMBER OF NITRATE REPORTING FORMS
The number of reporting
forms increased across the 4
reporting years covered by
the Nitrate Initiative. TRI
Form A reporting forms
represented only 31 of the
2,452 forms submitted. The
Reporting
Year
1995
1996
1997
1998
1995-1998
Number of Reports
Baseline
Reports
831
920
993
1,138
3,882
Revised
Reports
Submitted
28
40
53
125
246
New
Reports
Submitted
539
555
558
554
2,206
Total
Nitrate
Reports
1,370
1,475
1,551
1,692
6,088
Changes in
Reports
567
595
611
679
2,542
EPA REGION 1 THROUGH 10 SUMMARY
-------
remaining 2,421 Form R reporting forms resulted in a 20 percent increase in reported on-site
and off-site releases of nitrates and a 84 percent increase in reported transfers off-site of
nitrates for further waste management. As shown on Figures 2 and 3 below, food and chemical
industries were responsible for most of the increases in releases and transfers, respectively.
Nitrate Initiative participants paid about $1.5 million in penalties under consent agreements with
EPA, including $356,000 assessed by EPA's Office of Enforcement and Compliance Assistance
and more than $1.1 assessed by EPA's ten regional offices..
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 147 million pounds of nitrates were reported as
released to surface water from 1995 through 1998. This represents a correction of 25 percent
to the baseline data. About 2.5 million pounds of nitrates were added to the quantity released
off-site, a correction of 14 percent. Over 10 million pounds of nitrates were added to the
quantity released to land on-site, a correction of 49 percent. Changes in nitrate releases
through underground injection were minimal.
Most dramatic was the 255 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 89 percent to the
TRI database. An additional 8.9 million pounds of nitrates were reported as transferred off-site
to other types of facilities for further waste management. This quantity represents a correction
of 31 percent to the TRI database. The quantity of nitrates reported as treated on-site
increased by about 160 million pounds, a correction of 94 percent.
Table 2 lists the top fifty facilities that responded to the initiative, ranked on total changes in
FIGURE 2 FIGURE 3
PERCENT CHANGES IN PERCENT CHANGES IN
NITRATE RELEASES NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR REPORTED BY INDUSTRY SECTOR
Other
Secondary 14%
Metals tftfH Electrical _^^ |^^ Chemicals
7% L^Sw Vfe. Food Equipment jf ^ 43%
AOO/ 10%
Primary |^ »^^^
Metals
13%
Chemicals Secondary
Metals
15%
18o/o Metals
releases. Table 3 lists the top fifty facilities ranked on total changes in transfers. Table 4 lists
the top five-parent corporations based on the total changes in releases and transfers of nitrates
reported by facilities owned by that corporation.
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP 50 FACILITIES
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Anheuser-Busch Inc.
Baldwinsville, NY
Osram Sylvania Products
Inc., Towanda, PA
Rohm & Haas Texas Inc.
Deer Park, TX
Protein Technologies
International Inc.
Pryor, OK
Farmland Foods Inc.
Crete, NE
Perdue Farms Inc.
Accomac Processing
Plant, Accomac, VA
Simmons Foods Inc.
South West City, MO
IBP Inc., Lexington, NE
MEMC Electronic
Materials Inc., Moore, SC
Ensign-Bickford
Company, Graham, KY
Solutia Inc., Decatur, AL
Piper Impact Inc.
New Albany, MS
DuPont Repauno Plant
Gibbstown, NJ
Excel Corporation
Fort Morgan, CO
Lewiston Processing
Plant, Lewiston-
Woodville, NC
Excel Corporation
Schuyler, NE
Gulf Chemicals
Metallurgical Corporation
Freeport, TX
Wausau-Mosinee Paper
Corporation Brokaw Mill
Brokaw, Wl
Central Industries Inc.
Forest, MS
Responded to
Enforcement
Alert?1
No
No
No
No
No
Yes
No
No
No
No
Yes
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
10,240,413 0 0
8,109,372 0 0
7,092,909 0 0
6,091,690 0 160,250
6,009,972 0 0
5,660,000 0 1,110
5,260,431 0 0
5,100,000 0 0
4,235,000 0 0
0 0 4,048,238
4,000,000 0 0
3,761,200 0 0
3,666,204 0 0
3,596,262 0 0
2,941 ,627 0 877
2,822,967 0 0
2,646,605 0 0
2,447,991 0 4,159
2,377,336 0 0
Total
Changes in
On-site
Releases
(pounds)
10,240,413
8,109,372
7,092,909
6,251 ,940
6,009,972
5,661,110
5,260,431
5,100,000
4,235,000
4,048,238
4,000,000
3,761 ,200
3,666,204
3,596,262
2,942,504
2,822,967
2,646,605
2,452,150
2,377,336
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
0
0
0
4,266
0
0
0
0
0
0
0
0
363
0
44
0
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP 50 FACILITIES
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
(Continued)
Facility, City, State
Amphenol Corporation
Sidney, NY
Modine Manufacturing
Company, Knoxville, TN
American Cyanamid
Company Hannibal Plant
Palmyra, MO
Crucible Materials
Corporation Trent Tube
Plants 1, 2&3
East Troy, Wl
Leaf River Forest
Products
New Augusta, MS
Biokyowa Inc.
Cape Girardeau, MO
Georgetown Processing
Plant Facility #17
Georgetown, DE
William L. Bonnell
Company Inc.
Newnan, GA
Du Pont Victoria Plant
Victoria, TX
Gold Kist Live Oak
Processing Plant
Live Oak, FL
Lion Oil Company
El Dorado, AR
Hilmar Cheese Company
Inc., Hilmar, CA
Excel Corporation
Beardstown, IL
Gold Kist Trussville
Processing Plant
Trussville, AL
Nielsen & Bainbridge
LLC, Gainesboro, TN
Dairy Farmers of America
Inc., New Wilmington, PA
Spectratech International
Inc., Kearneysville, WV
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
Yes
No
First Time
Reporter?2
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
2,018,847 0 0
1 ,969,828 0 0
1 ,877,000 0 0
1 ,844,200 0 0
1 ,806,369 0 0
1 ,626,000 0 0
1 ,563,000 0 640
1 ,550,000 0 0
6,145,040 -4,608,780 0
1,420,000 0 14,900
1 ,395,394 0 0
0 0 1,387,105
316,907 0 1,040,741
1 ,340,000 0 0
1,277,108 0 0
1 ,276,565 0 0
1,187,000 0 0
Total
Changes in
On-site
Releases
(pounds)
2,018,847
1 ,969,828
1 ,877,000
1 ,844,200
1 ,806,369
1 ,626,000
1 ,563,640
1 ,550,000
1 ,536,260
1 ,434,900
1 ,395,394
1,387,105
1 ,357,648
1 ,340,000
1,277,108
1 ,276,565
1,187,000
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
2,260
5,610
5,600
0
6,680
0
0
0
0
0
0
791
-30,946
0
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP 50 FACILITIES
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
(Continued)
Facility, City, State
BWX Technologies Inc.
Lynchburg, VA
F & A Dairy of California
Inc., Newman, CA
U.S. TVA Paradise Fossil
Plant, Drakesboro, KY
Wah Chang Oremet
Facility, Albany, OR
Koch Petroleum Group
LP, Rosemount, MN
Excel Corporation
Plainview, TX
Wah Chang, Albany OR
Excel Corporation
Dodge City, KS
Maytag Appliances NLP
2, Newton, IA
Defuniak Springs
Complex Facility #87
Defuniak Springs, FL
Georgia Tubing
Corporation
Cedar Springs, GA
U.S. TVA Cumberland
Fossil Plant
Cumberland City, TN
Summit Corporation of
America, Thomaston, CT
Cook Family Foods
Grayson, KY
Responded to
Enforcement
Alert?1
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
No
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
1,183,100 0 0
0 0 1,162,765
1,100,000 0 0
1 ,095,000 0 0
1 ,080,000 0 0
0 0 1,054,919
1 ,022,000 0 0
0 0 958,662
918,000 0 0
871 ,000 0 3,300
867,376 0 0
860,000 0 0
856,147 0 0
845,755 0 7
Total
Changes in
On-site
Releases
(pounds)
1,183,100
1,162,765
1,100,000
1 ,095,000
1 ,080,000
1,054,919
1 ,022,000
958,662
918,000
874,300
867,376
860,000
856,147
845,762
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
0
0
0
0
0
0
0
2,201
0
0
8
Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP 50 FACILITIES
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Hercules, Inc., Parlin Plant, Parlin, NJ
S- d-Chemie, Inc., West Plant, Louisville, KY
First Chemical Corporation, Pascagoula, MS
Bristol-Myers Squibb Company, East Syracuse, NY
MEMC Electronic Materials, Inc., St. Peters Plant
O'Fallon, MO
Corning, Inc., Danville, VA
Farmland Foods, Inc., Denison, IA
Ruetgers Organics Corporation, State College, PA
Miller Plating & Metal Finishing, Evansville, IN
Harshaw Chemical Company, Louisville, KY
Procter & Gamble Manufacturing Company, Greenville, SC
Excel Corporation, Marshall, MO
Dairy Farmers of America, Inc., Corona, CA
Gerber Products, Fort Smith, AR
Aluminum Coil Anodizing Corporation, Streamwood, IL
Zenith Electronics Corporation, Rauland Division
Melrose Park, IL
Land O'Lakes, Inc., Tulare, CA
Indalex West, Watsonville, CA
First District Association, Litchfield, MN
George Industries, Los Angeles, CA
UCAR Graph-Tech, Inc., Lakewood, OH
Hemlock Semiconductor Corporation, Hemlock, Ml
Anomatic Corporation, Newark, OH
Boeing BCAG Fabrication Division-Auburn, Auburn, WA
Thomson Consumer Electronics, Marion, IN
Delphi Delco Electronics Systems Plant 1 , Kokomo, IN
United Dairymen of Arizona, Tempe, AZ
Precision Lithograining Corporation, South Hadley, MA
ITT Industries Cannon, Santa Ana, CA
Avesta Sheffield East, Inc., Baltimore, MD
American Racing Custom Wheels, Gardena, CA
Talley Metals Technology, Hartsville, SC
Responded to
Enforcement
Alert?1
No
No
No
No
No
Yes
No
No
No
No
No
No
Yes
No
Yes
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
Yes
No
Yes
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Total Changes
in Transfers to
POTWs
(pounds)
61,576,521
16,100,000
10,484,000
8,050,000
4,155,000
3,555,000
3,518,000
0
3,220,000
3,120,000
2,898,608
2,828,594
2,813,050
2,572,558
2,534,684
2,485,347
2,373,763
2,293,788
2,053,446
1,885,541
1 ,846,700
0
1,726,413
1 ,560,000
1 ,406,405
1 ,376,000
1 ,375,997
1 ,371 ,355
1,319,724
1 ,277,956
1,214,659
0
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
0
3,415,138
0
0
0
0
0
0
0
0
0
0
0
0
0
1 ,832,278
0
0
0
0
0
0
0
0
0
1,187,392
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP 50 FACILITIES
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
(Continued)
Facility, City, State
Blue Grass Chemical Specialties LP, New Albany, IN
Plating Technologies, Inc., Dayton, OH
Webco Industries, Inc., Sand Springs, OK
Curtis Metal Finishing Company, Sterling Heights, Ml
Crucible Materials Corporation Trent Tube Division
Carrollton, GA
Solutia, Inc., Sauget, IL
National Metal Finishing Corporation, Springfield, MA
Rohm & Haas Company, Bayport Plant, LaPorte, TX
Komag, Inc., Building 6, San Jose, CA
Easton Technical Products, Salt Lake City, UT
Western Lithotech, Jacksonville, TX
Haynes International, Inc., Arcadia, LA
Mueller Brass Company, Port Huron, Ml
Jan-Eze Plating, Inc., Nashville, AR
Gene's Plating Works, Los Angeles, CA
Northrop Grumman Corporation, Dallas, TX
PQ Corporation, Augusta, GA
US Chrome Corp. of Wisconsin, Fond du Lac, Wl
Easton Sports, Inc., Van Nuys, CA
Responded to
Enforcement
Alert?1
No
No
No
No
No
Yes
No
No
No
Yes
No
No
No
No
No
Yes
No
No
Yes
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Total Changes
in Transfers to
POTWs
(pounds)
1,187,221
1,187,000
1,181,092
1,142,350
1,117,755
1,112,684
1,101,410
1 ,075,729
1 ,070,000
1 ,066,856
1 ,060,824
1 ,007,507
988,602
988,323
785,299
959,000
955,675
955,449
923,000
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
14,762
18,815
0
0
0
0
0
0
0
0
0
198,190
0
0
0
0
Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS OF NITRATES
FOR TOP FIVE-PARENT CORPORATIONS BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
Parent Company
Hercules Inc.
S- d Chemie Inc.
Cargill Inc.
Perdue Farms Inc.
El du Pont de Nemours and Company Inc.
Changes in Reported
Releases (pounds)
0
24
9,992,393
11,777,791
10,747,770
Changes in Reported
Transfers (pounds)
61,576,521
16,100,000
2,828,594
43,000
553,209
Total Changes
(pounds)
61,576,521
16,100,000
10,484,000
12,820,987
11,820,791
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATES
As a result of the initiative, 508 facilities submitted 5,794 reporting forms for chemicals other
than nitrates. The distribution of these reporting forms across the 4 reporting years is shown on
Figure 4. Only 1,813 of the reporting forms were first-time submittals, consisting of 361 Form
As and 1,452 Form Rs. Data from the new reports addressed 100 chemicals.
The other 3,981 reporting forms were revisions to previous submittals to the TRI. These revised
reporting forms addressed a total of 140 chemicals. A summary of the changes in transfer and
release quantities from all non-nitrate reports is shown in Table 5. The largest change to the
TRI from these reports was an additional 11 million pounds of manganese compounds reported
as disposed of off-site by one facility for reporting years 1995 through 1998.
FIGURE 4
NON-NITRATE REPORTING FORMS SUBMITTED
16001
1400
1200
LL.
6
800
600
400
200
0
1995 1996 1997
Reporting Year
New o Revised All
1998
EPA REGION 1 THROUGH 10 SUMMARY
-------
TABLE 5
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7664-38-2
7440-50-8
Total
Chemical
Zinc compounds
Phosphoric acid
Manganese compounds
Copper
Chromium compounds
All other chemicals
Changes in
Reported Releases
(pounds)
37,594,151
-318,108
24,884,427
831 ,060
2,439,220
40,683,674
106,114,424
Changes in
Reported
Transfers
(pounds)
-1 ,506,664
35,138,498
2,540,505
16,033,244
9,387,769
-28,102,999
33,490,353
Total Changes
(pounds)
36,087,487
34,820,390
27,424,932
16,864,304
1 1 ,826,989
12,580,675
139,604,777
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI is presented in the
Nitrate Initiative Fact Sheet for all EPA regions. The fact sheet also identifies an EPA contact
that can be reached for further information.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview. html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by facilities in certain
covered industry groups as well as federal facilities. Reporting year 1999 is the most recent TRI
data available. Please access the EPA Envirofacts database for the most recent TRI data.
10
EPA REGION 1 THROUGH 10 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 1
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 1.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 216 nitrate reporting forms from
facilities in EPA Region 1. About 60 facilities in EPA Region 1 submitted a total of 192 reports
for nitrates during the Nitrate Initiative. Twenty-one of these facilities submitted reporting forms
in response to the enforcement alert.
EPA REGION 1 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports almost doubled the number of
nitrate reporting forms in the TRI
database from facilities in EPA Region 1.
Fewer than 10 reports were submitted as
revisions to nitrate reports filed prior to the
Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. TRI
Form A reporting forms represented only
3 of the 192 forms submitted. The
remaining 189 Form R reporting forms resulted in a 39 percent increase in reported on-site and
off-site releases of nitrates and a 74 percent increase in reported transfers off-site of nitrates for
further waste management. As shown on Figures 1 and 2 below, industries that perform
secondary smelting and refining of metals were responsible for most of the increases in EPA
Region 1.
Reporting
Year
1995
1996
1997
1998
1995-1998
Number of Reports
Baseline
Reports
52
56
59
49
216
Revised
Reports
Submitted
1
2
2
2
7
New
Reports
Submitted
44
45
46
50
185
Total
Nitrate
Reports
96
101
105
99
401
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
Primary
Metals
11%
Other
2%
Secondary
Metals
66%
Printing and
Publishing
14%
Secondary
Metals
46%
Electrical
Equipment
15%
No penalties were assessed by EPA Region 1 under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 1.7 million pounds of nitrates were reported as
released to surface water in EPA Region 1 from 1995 through 1998. This represents a
correction of 39 percent to the baseline data. Over 0.5 million pounds of nitrates were added to
the quantity released off-site, a correction of 41 percent. Changes in nitrate releases to land or
through underground injection were minimal or nonexistent.
EPA REGION 1 SUMMARY
-------
Most dramatic was the 10.6 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 76 percent to the
TRI database. An additional 650,000 pounds of nitrates were reported as transferred off-site to
other types of facilities for further waste management. This quantity represents a correction of
50 percent to the TRI database. The quantity of nitrates reported as treated on-site increased
by about 2 million pounds, a correction of 31 percent.
Table 2 lists the top ten facilities in EPA Region 1 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 1
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Summit Corporation of
America, Thomaston, CT
Vermont Whey Co.,
Georgia, VT
Philson Inc.,
Watertown, CT
Wyeth Nutritionals Inc.,
Georgia, VT
Whyco Technologies Inc.,
Thomaston, CT
Harrow Products Inc.,
New Haven, CT
Texas Instruments Inc.,
Attleboro, MA
National Starch &
Chemical Company,
Island Falls, ME
Duralectra Inc.,
Natick, MA
Osram Sylvania Inc.,
Waldoboro, ME
Responded to
Enforcement
Alert?1
No
Yes
No
Yes
Yes
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
856,147 0 0
4,175 0 0
277,000 0 0
2,550 0 0
235,158 0 0
127,000 0 0
82,000 0 0
55,552 0 40
31,975 0 0
14,082 0 0
Total
Changes in
On-site
Releases
(pounds)
856,147
4,175
277,000
2,550
235,158
127,000
82,000
55,592
31 ,975
14,082
Total
Changes
in Off-site
Releases
(pounds)
0
290,643
0
252,510
0
0
30,900
0
0
0
Facilities that submitted nitrate reports after December 31, 1999. but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1.
2000.
EPA REGION 1 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 1
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Precision Lithograining Corporation, South Hadley, MA
National Metal Finishing Corporation, Springfield, MA
Kodak Polychrome Graphics LLC, Holyoke, MA
Cabot/Agri-Mark Inc., Middlebury, VT
Echo Manufacturing Company, Inc., Waterbury, CT
FMC Biopolymer, Rockland, ME
Kodak Polychrome Graphics LLC., Holyoke, MA
Reflek Corporation, Fall River, MA
Osram Sylvania Inc., Waldoboro, ME
Westfield Electroplating Company, Westfield, MA
Responded to
Enforcement
Alert?1
Yes
No
Yes
Yes
No
No
Yes
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
1 ,371 ,355
1,101,410
719,710
632,321
610,980
571 ,400
529,334
516,807
0
413,781
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
0
0
431 ,074
319
(1) Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1.
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATES
As a result of the initiative, 18 facilities in EPA Region 1 submitted 117 reporting forms for
chemicals other than nitrates. The distribution of these reporting forms across the 4 reporting
years is shown on Figure 3. Only 16 of the reporting forms were first-time submittals, consisting
mainly of Form As.
The other 101 reporting forms were revisions to previous submittals to the TRI. These revised
reporting forms addressed a total of 18
chemicals. A summary of the changes in
waste management and release quantities
from the revised non-nitrate reports is shown
in Table 4. The most significant change to
the TRI from these reports was a reduction of
almost 1 million pounds of phosphoric acid
previously reported as transferred off-site by
one facility for reporting years 1995 and
FIGURES
NON-NITRATE REPORTING FORMS SUBMITTED
35
30
25
20
15
10
5
0
1996.
1995 1996 1997
Reporting Year
New n Revised All
1998
EPA REGION 1 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS IN REVISED REPORTS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7440-50-8
7697-37-2
Total
Chemical
Copper
Cyanide compounds
Nitric acid
Chromium compounds
Nickel compounds
All other chemicals
Changes in Reported
Releases (pounds)
3,644
-209
18,251
7,757
540
76,736
106,719
Changes in Reported
Transfers (pounds)
51 4,947
13,845
-5,464
-7,372
-1 ,343
-1,316,958
-802,345
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 1 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 1 contact that can be reached for further information and state
contacts for EPA Region 1 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa. gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 1 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 2
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 2.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 252 nitrate reporting forms from
facilities in EPA Region 2. About 50 facilities in EPA Region 2 submitted a total of 150 reports
for nitrates during the Nitrate Initiative. Twelve of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 2 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by about 50 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 2. Fewer than 20 reports were
submitted as revisions to nitrate reports
that were filed prior to the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. None of
the reporting forms submitted were TRI
Form A. The 150 Form R reporting forms
resulted in a 51 percent increase in reported on-site and off-site releases of nitrates and a 540
percent increase in reported transfers off-site of nitrates for further waste management. As
shown on Figures 1 and 2 below, food and chemical industries were responsible for most of the
increases in EPA Region 2.
Reporting
Year
1995
1996
1997
1998
1995-1998
Number of Reports
Baseline
Reports
57
65
64
66
252
Revised
Reports
Submitted
3
2
2
7
14
New
Reports
Submitted
31
34
38
33
136
Total
Nitrate
Reports
88
99
102
99
388
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
Electrical
Equipment Other
13% 2%
Chemicals
21%
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Chemicals
94%
EPA Region 2 assessed $57,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 18.3 million pounds of nitrates were reported as
released to surface water in EPA Region 2 from 1995 through 1998. This represents a
correction of 52 percent to the baseline data. Over 190,000 pounds of nitrates were added to
the quantity released off-site, a correction of 21 percent. Changes in nitrate releases to land or
through underground injection were non-existent.
EPA REGION 2 SUMMARY
-------
Most dramatic was the 74 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of over 600 percent to
the TRI database. An additional 470,000 pounds of nitrates were reported as transferred off-
site to other types of facilities for further waste management. This quantity represents a
correction of 24 percent to the TRI database. The quantity of nitrates reported as treated on-
site increased by about 2.6 million pounds, a correction of 16 percent.
Table 2 lists the top ten facilities in EPA Region 2 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 2
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Anheuser-Busch Inc.
Baldwinsville, NY
Du Pont Repauno Plant
Gibbstown, NJ
Amphenol Corporation
Sidney, NY
Great Lakes Cheese of
New York Inc.
Adams, NY
Kraft Foods Inc.
Campbell, NY
Empire Cheese Inc.
Cuba, NY
Colorite Specialty
Resins Burlington, NJ
Crucible Specialty
Metals Division, Solvay,
NY
Toshiba Display Devices
Inc., Horsehead, NY
Viasystems Puerto Rico
Inc., San German, PR
Responded to
Enforcement
Alert?1
No
No
No
Yes
Yes
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
10,240,413 0 0
3,666,204 0 0
2,018,847 0 0
517,858 0 0
500,000 0 0
418,000 0 0
276,165 0 0
266,470 0 0
232,749 0 0
0 00
Total
Changes in
On-site
Releases
(pounds)
10,240,413
3,666,204
2,018,847
517,858
500,000
418,000
276,165
266,470
232,749
0
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
0
0
0
0
0
0
164,408
Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 2 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 1
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Hercules Inc. Parlin Plant, Parlin, NJ
Bristol-Myers Squibb Company, East Syracuse, NY
Anoplate Corporation, Syracuse, NY
Du Pont Repauno Plant, Gibbstown, NJ
H.P. Hood, Oneida, NY
Mccadam Cheese Co. Inc., Chateaugay, NY
Foremost Manufacturing Company Inc., Union, NY
Carborundum, Niagra Falls, NY
Keystone Corporation Key Tech Finishing, Buffalo, NY
O-At-Ka Milk Products Co-op Inc., Batavia, NY
Responded to
Enforcement
Alert?1
No
No
Yes
No
Yes
Yes
No
No
No
Yes
First Time
Reporter?2
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
61 ,576,521
8,050,000
499,250
0
448,560
421 ,298
378,786
319,000
317,712
283,000
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
3,400
464,123
0
0
0
0
0
0
Facilities that submitted nitrate reports after December 31. 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 35 facilities in EPA Region 2 submitted 303 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the 4
reporting years is shown on Figure 3. About 150 of the reporting forms were first-time
submittals, over half of which are Form A.
FIGURES
NON-NITRATE REPORTING FORMS SUBMITTED
1995 1996 1997
Reporting Year
New n Revised All
1998
The other reporting forms were revisions to
previous submittals to the TRI. These revised
reporting forms addressed a total of 29
chemicals. A summary of the changes in
transfer and release quantities from all non-
nitrate reports is shown in Table 4. The most
significant change to the TRI from these
reports was a reduction of over 4 million
pounds of ethylene glycol, previously reported
as transferred off-site by one facility for
reporting years 1995 through 1998.
TABLE 4
CHANGES IN RELEASES AND WASTE
MANAGEMENT TRANSFERS REPORTED FOR TOP
FIVE CHEMICALS BASED ON TOTAL CHANGES IN
RELEASES AND TRANSFERS
EPA REGION 2 SUMMARY
-------
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7440-02-0
7632-00-0
100-41-4
Total
Chemical
Nickel compounds
Nickel
Sodium nitrite
Ethylbenzene
Copper compounds
All other chemicals
Changes in Reported
Releases (pounds)
468,421
6,604
378,876
97,793
239,050
86,188
1 ,276,932
Changes in Reported
Transfers (pounds)
41 1 ,687
762,657
0
228,430
67,230
-4,039,109
-2,569,105
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 2 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 2 contact that can be reached for further information and state
contacts for EPA Region 2 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 2 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 3
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 3.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 336 nitrate reporting forms from
facilities in EPA Region 3. About 55 facilities in EPA Region 3 submitted a total of 163 reports
for nitrates during the Nitrate Initiative. Eleven of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 3 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by almost 40 percent
the number of nitrate reporting forms in
the TRI database from facilities in EPA
Region 3. Fewer than 20 reports were
submitted as revisions to nitrate reports
that were filed prior to the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. No TRI
Form A reporting forms for nitrates were
submitted. The 163 Form R reporting forms resulted in an 11 percent increase in reported on-
site and off-site releases of nitrates and a 38 percent increase in reported transfers off-site of
nitrates for further waste management. As shown on Figure 1 below, food and chemical
industries were responsible for most of the increases in reported releases in EPA Region 3.
Figure 2 shows that chemical industries and industries that manufacture stone, clay, glass and
concrete products were responsible for most of the increases in reported transfers in EPA
Region 3.
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
70
78
85
103
336
Revised
Reports
Submitted
0
2
5
12
19
New
Reports
Submitted
40
37
38
29
144
Total
Nitrate
Reports
110
115
123
132
480
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Electrical Other
Equipment 8%
7%
Chemicals
42%
Food
43%
Electrical
Equipment
9%
Secondary
Metals
12%
Primary
Metals
16%
Other
6%
Chemicals
30%
Stone, Clay,
Glass, and
Concrete
27%
EPA Region 3 assessed $96,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 19.5 million pounds of nitrate compounds was
reported as released to surface water in EPA Region 3 from 1995 through 1998. This
EPA REGION 3 SUMMARY
-------
represents a correction of 11 percent to the baseline data. Over 19,000 pounds of nitrates were
added to the quantity released off-site, a correction of 3 percent. Changes in nitrate releases to
land or through underground injection were minimal or nonexistent.
Most dramatic was the 9.5 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This contributed to a correction of 28 percent to
the TRI database. An additional 3.9 million pounds of nitrates were reported as transferred off-
site to other types of facilities for further waste management. This quantity represents a
correction of 450 percent to the TRI database. The quantity of nitrates reported as treated on-
site increased by about 1.8 million pounds, a correction of 13 percent.
Table 2 lists the top ten facilities in EPA Region 3 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 3
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Osram Sylvania Products,
Inc., Towanda, PA
Perdue Farms, Inc.,
Accomac Processing
Plant, Accomac, VA
Georgetown Processing
Plant Facility #17
Georgetown, DE
Dairy Farmers of America,
Inc., New Wilmington, PA
Spectratech International,
Inc., Kearneysville, WV
BWX Technologies, Inc.
Lynchburg, VA
Welland Chemical
Company, Inc., Newell
Works, Newell, PA
Lucent Technologies
Reading, PA
Showell Processing Plant
Showell, MD
P. H. Glatfelter Company
Spring Grove, PA
Responded to
Enforcement
Alert?1
No
No
No
Yes
No
Yes
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
8,109,372 0 0
5,660,000 0 1,110
1 ,563,000 0 640
1 ,276,565 0 0
1,187,000 0 0
1,183,100 0 0
324,000 0 0
248,000 0 0
125,313 0 924
113,680 0 49
Total
Changes in
On-site
Releases
(pounds)
8,109,372
5,661,110
1 ,563,640
1 ,276,565
1,187,000
1,183,100
324,000
248,000
1 26,237
113,729
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
-30,946
0
0
0
0
0
0
Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 3
EPA REGION 3 SUMMARY
-------
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Corning, Inc., Danville, VA
Ruetgers Organics Corporation, State College, PA
Avesta Sheffield East, Inc., Baltimore, MD
Cerro Metal Products Company, Weyers Cave, VA
Barker Microfarads, Inc., Hillsville, VA
Honeywell International, Inc., Hopewell Plant
Hopewell, VA
Republic Technologies International, Baltimore S&S
Baltimore, MD
Cerro Metal Products Company, Shenandoah, VA
Thomson Consumer Electronics, Dunmore, PA
Rohm & Haas Company, Philadelphia, PA
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Total Changes
in Transfers to
POTWs
(pounds)
3,555,000
0
1 ,277,956
683,467
666,700
410,050
408,580
382,751
358,702
283,008
Total
Changes in
Other Off-site
Transfers
(pounds)
0
3,415,138
0
0
0
0
0
0
0
0
Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 42 facilities in EPA Region 3 submitted 519 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the 4
reporting years is shown on Figure 3. Only 182 of the reporting forms were first-time submittals,
consisting of 7 Form As and 175 Form Rs. Data from the new reports addressed 36 chemicals.
The other 337 reporting forms were revisions to previous submittals to the TRI. These revised
reporting forms addressed a total of 54 chemicals. A summary of the changes in transfer and
release quantities from all non-nitrate reports is shown in Table 4. The most significant change
to the TRI from these reports was an increase of over 11 million pounds of manganese
FIGURE 3 compounds reported as disposed of off-site
by one facility for reporting years 1995
through 1998.
NON-NITRATE REPORTING FORMS SUBMITTED
140
120
100
80
60
40
20
0
1995 1996 1997
Reporting Year
New D Revised All
1998
EPA REGION 3 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
1 330-20-7
Total
Chemical
Manganese compounds
Copper compounds
Zinc compounds
Barium compounds
Xylene (mixed isomers)
All other chemicals
Changes in Reported
Releases (pounds)
1 1 ,339,640
128,570
1,868,084
814,411
803,853
3,101,179
18,055,737
Changes in Reported
Transfers (pounds)
-13,926
2,135,281
-91,813
364,866
117,170
-1,024,150
1 ,487,428
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 3 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 3 contact that can be reached for further information and state
contacts for EPA Region 3 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa. gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 3 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 4
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 4.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 680 nitrate reporting forms from
facilities in EPA Region 4. About 135 facilities in EPA Region 4 submitted a total of 402 reports
for nitrates during the Nitrate Initiative. Eight of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 4 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by over 50 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 4. Fewer than 50 reports were
submitted as revisions to nitrate reports
filed prior to the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. TRI
Form A reporting forms represented only 6 of the 402 forms submitted. The remaining 396
Form R reporting forms resulted in a 26 percent increase in reported on-site and off-site
releases of nitrates and a 183 percent increase in reported transfers off-site of nitrates for
further waste management. As shown on Figures 1 and 2 below, food and chemical industries
were responsible for most of the increases in EPA Region 4.
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
149
157
177
197
680
Revised
Reports
Submitted
5
8
9
23
45
New
Reports
Submitted
87
94
87
89
357
Total
Nitrate
Reports
236
251
264
286
1,037
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Electrical
Equipment
12%
Secondary
Metals
17%
Food
30%
Other
Primary 12%
Metals
13%
^sjj
Chemicals
25%
Chemicals
75%
EPA Region 4 assessed $168,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 38 million pounds of nitrates were reported as
released to surface water in EPA Region 4 from 1995 through 1998. This represents a
correction of 36 percent to the baseline data. Over 4.1 million pounds of nitrates were added to
the quantity released to land on-site, a correction of 235 percent. Changes in nitrate releases
through underground injection or to off-site locations were minimal.
EPA REGION 4 SUMMARY
-------
Most dramatic was the 43 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 257 percent to the
TRI database. An additional 2.7 million pounds of nitrates were reported as transferred off-site
to other types of facilities for further waste management. This quantity represents a correction
of 32 percent to the TRI database. The quantity of nitrates reported as treated on-site
increased by about 27 million pounds, a correction of 60 percent.
Table 2 lists the top ten facilities in EPA Region 4 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 4
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
MEMO Electronic
Materials, Inc., Moore, SC
Ensign-Bickford
Company, Graham, KY
Solutia, Inc., Decatur, AL
Piper Impact, Inc.
New Albany, MS
Lewiston Processing
Plant
Lewiston Woodville, NC
Central Industries, Inc.
Forest, MS
Modine Manufacturing
Company, Knoxville, TN
Leaf River Forest
Products
New Augusta, MS
William L Bonnell
Company, Inc.
Newnan, GA
Gold Kist, Live Oak
Processing Plant
Live Oak, FL
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
4,235,000 0 0
0 0 4,048,238
4,000,000 0 0
3,761,200 0 0
2,941 ,627 0 877
2,377,336 0 0
1 ,969,828 0 0
1 ,806,369 0 0
1 ,550,000 0 0
1,420,000 0 14,900
Total
Changes in
On-site
Releases
(pounds)
4,235,000
4,048,238
4,000,000
3,761 ,200
2,942,504
2,377,336
1 ,969,828
1 ,806,369
1 ,550,000
1 ,434,900
Total
Changes
in Off-site
Releases
(pounds)
0
0
0
0
0
0
0
5,610
6,680
0
Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 4 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 4
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
S-d-Chemie, Inc., West Plant, Louisville, KY
First Chemical Corporation, Pascagoula, MS
Harshaw Chemical Company, Louisville, KY
Procter & Gamble Manufacturing Company, Greenville, SC
Talley Metals Technology, Hartsville, SC
Crucible Materials Corporation, Trent Tube Division,
Carrollton, GA
PQ Corporation, Augusta, GA
Loxcreen Company, Roxboro, NC
Greenwood Fabricating & Plating, Inc., Greenwood, SC
Fleischmann's Yeast, Inc., Gastonia, NC
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Total Changes
in Transfers to
POTWs
(pounds)
16,100,000
10,484,000
3,120,000
2,898,608
0
1,117,755
0
792,700
626,360
470,412
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
1,187,392
18,815
956,675
0
0
0
Facilities that submitted nitrate reports after December 31. 1999, but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1.
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 96 facilities in EPA Region 4 submitted 1,245 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the
four reporting years is shown on Figure 3. About one-third of the reporting forms were first-time
submittals, including 80 Form As and 375 Form Rs. Data from the new reports addressed 53
chemicals.
FIGURES
NON-NITRATE REPORTING FORMS SUBMITTED
350
300
fi
£ 250
i 2°°
o> 150
.a
I 100
Z
50
0
1995 1996 1997
Reporting Year
New DRevised BAH
1998
The other 790 reporting forms were revisions
to previous submittals to the TRI. These
revised reporting forms addressed a total of
68 chemicals. A summary of the changes in
transfer and release quantities from all non-
nitrate reports is shown in Table 4. The
most significant change to the TRI from
these reports was an additional 18 million
pounds of copper reported as transferred
off-site by one facility for reporting years
1995 through 1998.
TABLE 4
EPA REGION 4 SUMMARY
-------
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7440-50-8
Total
Chemical
Copper
Manganese compounds
Chromium compounds
Nickel compounds
Copper compounds
All other chemicals
Changes in Reported
Releases (pounds)
-118,309
13,556,371
1 ,243,038
506,068
1 ,478,448
12,672,703
29,338,319
Changes in Reported
Transfers (pounds)
18,480,535
3,826,449
9,324,648
5,539,184
1 ,378,272
7,437,753
45,986,841
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 4 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 4 contact that can be reached for further information and state
contacts for EPA Region 4 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 4 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 5
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31,1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 5.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 1,043 nitrate reporting forms from
facilities in EPA Region 5. About 220 facilities in EPA Region 5 submitted a total of 684 reports
for nitrates during the Nitrate Initiative. Forty-two of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 5 SUMMARY
-------
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these TABLE 1
forms are "new reports," which are
reports that were submitted for the first
time during the Nitrate Initiative. These
new reports increased by almost 50
percent the number of nitrate reporting
forms in the TRI database from facilities in
EPA Region 5. Fewer than 80 reports
were submitted as revisions to nitrate
reports filed prior to the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. TRI Form
A reporting forms represented only 12 of
the 684 forms submitted. The remaining 672 Form R reporting forms resulted in a 20 percent
increase in reported on-site and off-site releases of nitrates and a 65 percent increase in
reported transfers off-site of nitrates for further waste management. As shown on Figure 1
below, food industries and industries that perform primary smelting and refining of metals and
industries were responsible for most of the increases in releases in EPA Region 5. A variety of
industries were responsible for most of the increases in transfers, as shown in Figure 2.
Reporting
Year
1995
1996
1997
1998
1995-1998
Number of Reports
Baseline
Reports
225
245
272
301
1,043
Revised
Reports
Submitted
7
12
20
37
76
New
Reports
Submitted
156
153
152
147
608
Total
Nitrate
Reports
381
398
424
448
1,651
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Petroleum
Refining
S% ,*4t
/
Primary
Metals
34%
Primary
Metals
9%
Chemicals
10%
Secondary
Metals
37%
Electrical
Equipment
17%
EPA Region 5 assessed $385,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 12 million pounds of nitrates were reported as
released to surface water in EPA Region 5 from 1995 through 1998. This represents a
correction of 20 percent to the baseline data. Over 1 million pounds of nitrates were added to
the quantity released to land on-site, a correction of 52 percent. Changes in nitrate releases
EPA REGION 5 SUMMARY
-------
through underground injection were minimal. An additional 930,000 pounds of nitrates were
reported as released off-site, a correction of 39 percent.
Most dramatic was the 50 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 63 percent to the
TRI database. An additional 2.3 million pounds of nitrates were reported as transferred off-site to
other types of facilities for further waste management. This quantity represents a correction of
174 percent to the TRI database. The quantity of nitrates reported as treated on-site increased
by about 21 million pounds, a correction of 92 percent.
Table 2 lists the top ten facilities in EPA Region 5 that responded to the initiative, ranked on total
changes in releases. Table 3 lists the top ten facilities ranked on total changes in transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 5
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Wausau-Mosinee Paper
Corporation, Brokaw Mill,
Brokaw, Wl
Crucible Materials Corp.,
Trent Tube Plants 1, 2 & 3
East Troy, Wl
Excel Corporation,
Beardstown, IL
Koch Petroleum Group, L.P.,
Rosemount, MN
Associated Milk Producers,
Dawson Div., Dawson, MN
Rhinelander Paper Company
Rhinelander, Wl
National-Standard Company,
Lake Street Plant, Niles, Ml
Granite City Steel Granite
City, IL
LTV Steel Company, Inc. -
Cleveland Works Cleveland,
OH
Capitol Products Corporation
Kentland, IN
Responded
to
Enforcement
Alert?1
First Time
Reporter?2
Changes
Surface
Water
Discharges
No Yes 2,447,991
No
Yes
1,844,200
No Yes 316,907
No
Yes
1,080,000
Yes Yes 723,626
No
Yes
657,367
No Yes 577,229
No
Yes
554,126
No Yes 430,500
No
Yes
407,000
in On-site Releases
(pounds)
Underground Land
Injection Disposal
Total
Changes
in On-site
Releases
(pounds)
0 4,159 2,452,150
0 0
1,844,200
0 1,040,741 1,357,648
0 0
1,080,000
0 1,000 724,626
0 0
657,367
0 0 577,229
0 0
554,126
0 0 430,500
0 0
407,000
Total
Changes
in Off-site
Releases
(pounds)
44
2,260
0
0
7,045
4,171
0
0
0
2,910
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000. are
considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to
January 1. 2000.
EPA REGION 5 SUMMARY
-------
TABLES
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 5
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Miller Plating & Metal Finishing, Evansville, IN
Aluminum Coil Anodizing Corporation, Streamwood, IL
Zenith Electronics Corporation, Rauland Division
Melrose Park, IL
First District Association, Litchfield, MN
Ucar Graph-Tech, Inc., Lakewood, OH
Hemlock Semiconductor Corporation, Hemlock, Ml
Anomatic Corporation, Newark, OH
Thomson Consumer Electronics, Marion, IN
Delphi Delco Electronics Systems Plant 1, Kokomo, IN
Blue Grass Chemical Specialities, New Albany, IN
Responded
to
Enforcement
Alert?1
No
Yes
First Time
Reporter?2
Yes
Yes
No Yes
No
Yes
No Yes
No
No
No
No
No
Yes
Yes
Yes
No
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
3,220,000
2,534,684
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
2,485,347 0
2,053,446
0
1,846,700 0
0
1,726,413
1,406,405
1,376,000
1,187,471
1,832,278
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000. ar,
considered to have responded to the enforcement alert.
(2)
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to
January 1. 2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 155 facilities in EPA Region 5 submitted 2,038 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the
4 reporting years is shown on Figure 3. About one-fourth of the reporting forms were first-time
FIGURE 3 submittals, consisting of 98 Form As and
379 Form Rs. Data from the new reports
NON-NITRATE REPORTING FORMS SUBMITTED addressed 61 chemicals.
600
400
300
200
100
0
1935 1996 1997 1998
Reporting 'tear
New n Revised Ai
The other 1,561 reporting forms were
revisions to previous submittals to the TRI.
These revised reporting forms addressed a
total of 88 chemicals. A summary of the
changes in transfer and release quantities
from all non-nitrate reports is shown in
Table 4. The most significant change to the
TRI from these reports was a reduction of
about 48 million pounds of copper
compounds previously reported as
transferred off-site by one facility for
reporting years 1995 through 1998.
EPA REGION 5 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS BASED
ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7664-38-2
Chemical
Zinc compounds
Phosphoric acid
Changes in Reported
Releases (pounds)
32,953,361
-338,060
Changes in Reported
Transfers (pounds)
1,860,290
32,371,155
7697-37-2 Nitric acid 1,361,946 1,262,445
108-95-2
Total
Phenol
Barium compounds
All other chemicals
1,358,163
1,298,978
4,861,469
40,196,879
6,914
2,826
-53,079,181
-17,575,551
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 5 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 5 contact that can be reached for further information and state
contacts for EPA Region 5 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 5 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 6
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 6.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 458 nitrate reporting forms from
facilities in EPA Region 6. About 80 facilities in EPA Region 6 submitted a total of 259 reports
for nitrates during the Nitrate Initiative. Thirteen of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 6 SUMMARY
-------
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by over 50 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 6. Fewer than 25 reports were
submitted as revisions to nitrate reports
filed prior to the Nitrate Initiative.
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
95
112
114
137
458
Revised
Reports
Submitted
3
3
4
13
23
New
Reports
Submitted
58
60
61
57
236
Total
Nitrate
Reports
153
172
175
194
694
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. No TRI
Form A reporting forms were submitted. The 259 Form R reporting forms resulted in a 13
percent increase in reported on-site and off-site releases of nitrates and a 22 percent increase
in reported transfers off-site of nitrates for further waste management. As shown on Figure 1
below, chemical and food industries were responsible for most of the increases in releases in
EPA Region 6. A variety of industries were responsible for most of the increases in transfers,
as shown in Figure 2.
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
Petroleum
Refining Other
Primary 6% J*"1 Chemicals
Metals ^o*C?\l P""1^. 45%
11%
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Chemicals
11%
Transportation
Equipment
15%
Electrical
Equipment
11%
Secondary
Metals
13%
Primary
Metals
14%
EPA Region 6 assessed $80,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 27 million pounds of nitrates were reported as
released to surface water in EPA Region 6 from 1995 through 1998. This represents a
correction of 22 percent to the baseline data. Over 2 million pounds of nitrates were added to
the quantity released to land on-site, a correction of 60 percent. Changes in nitrate releases
through underground injection were minimal. An additional 126,000 pounds of nitrates were
reported as released off-site, a correction of 231 percent.
EPA REGION 6 SUMMARY
-------
Nearly 16 million pounds of nitrates that were reported for the first time as released to publicly
owned treatment works. This resulted in a correction of 23 percent to the TRI database. An
additional 42,000 pounds of nitrates were reported as transferred off-site to other types of
facilities for further waste management. This quantity represents a correction of 3 percent to
the TRI database. The quantity of nitrates reported as treated on-site increased by about 55
million pounds, a correction of 114 percent.
Table 2 lists the top ten facilities in EPA Region 6 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 6
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Rohm & Haas Texas,
Inc., Deer Park, TX
Protein Technologies
International, Inc.
Pryor, OK
Gulf Chemicals.
Metallurgical
Corporation
Freeport, TX
Du Pont, Victoria Plant
Victoria, TX
Lion Oil Company
El Dorado, AR
Excel Corporation
Plainview, TX
Union Carbide
Corporation, Taft/Star
Complex, Taft, LA
Solvay Interox
Deer Park, TX
Ticona Polymers, Inc.
Bishop, TX
Union Carbide
Corporation, Seadrift
Plant, Seadrift, TX
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
7,092,909 0 0
6,091,690 0 160,250
2,646,605 0 0
6,145,040 -4,608,780 0
1 ,395,394 0 0
0 0 1,054,919
628,460 0 0
589,174 0 0
550,530 0 0
503,400 0 0
Total
Changes in
On-site
Releases
(pounds)
7,092,909
6,251 ,940
2,646,605
1 ,536,260
1 ,395,394
1,054,919
628,460
589,174
550,530
503,400
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
0
744
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 6 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 6
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Gerber Products, Fort Smith, AR
Webco Industries, Inc., SWT Division, Sand Springs, OK
Rohm & Haas Company, Bayport Plant, La Porte, TX
Western Lithotech, Jacksonville, TX
Haynes International, Inc., Arcadia, LA
Jan-Eze Plating, Inc., Nashville, AR
Northrop Grumman Corporation, Dallas, TX
Chem-Fab Corporation, Hot Springs, AR
St. Microelectronics, Inc., Carrollton, TX
Huck International, Inc., Waco, TX
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
Yes
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
2,572,558
1,181,092
1 ,075,729
1 ,060,824
1 ,007,507
988,323
959,000
900,506
546,028
467,600
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1 ,
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 62 facilities in EPA Region 6 submitted 908 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the 4-
reporting years is shown on Figure 3. About one-third of the reporting forms were first-time
submittals, consisting of 57 Form As and 278 Form Rs. Data from the new reports addressed
60 chemicals.
The other 573 reporting forms were revisions to previous submittals to the TRI. These revised
reporting forms addressed a total of 78
chemicals. A summary of the changes in
transfer and release quantities from all non-
nitrate reports is shown in Table 4. The
most significant change to the TRI from
these reports was
an additional 2.6 million pounds of
phosphoric acid reported as transferred off-
site by one facility for reporting years 1995
through 1998.
FIGURE 3
NON-NITRATE REPORTING FORMS SUBMITTED
250
200
150
100
50
1995 1996 1997
Reporting Year
New n Revised All
1998
EPA REGION 6 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7664-38-2
67-56-1
7697-37-2
79-1 0-7
Total
Chemical
Phosphoric Acid
Methanol
Nitric acid
Barium compounds
Acrylic Acid
All other chemicals
Changes in Reported
Releases (pounds)
-3,149
345,833
1,448,128
1 ,384,862
29,629
10,069,980
13,275,283
Changes in Reported
Transfers (pounds)
2,629,367
1,185,692
-57,528
0
1,317,354
216,412
5,291,297
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 6 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 6 contact that can be reached for further information and state
contacts for EPA Region 6 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa. gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 6 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 7
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 7.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 222 nitrate reporting forms from
facilities in EPA Region 7. About 50 facilities in EPA Region 7 submitted a total of 157 reports
for nitrates during the Nitrate Initiative. Fourteen of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 7 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by over 60 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 7. Only 14 reports were submitted
as revisions to nitrate reports filed prior to
the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. TRI
Form A reporting forms represented only
5 of the 157 forms submitted. The remaining 152 Form R reporting forms resulted in a 86
percent increase in reported on-site and off-site releases of nitrates and a 78 percent increase
in reported transfers off-site of nitrates for further waste management. As shown on Figures 1
and 2 below, food industries were responsible for most of the increases in EPA Region 7.
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
50
55
58
59
222
Revised
Reports
Submitted
2
2
2
8
14
New
Reports
Submitted
33
36
34
40
143
Total
Nitrate
Reports
83
91
92
99
365
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
Other
Chemicals
8%
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Secondary
Metals
Transportation 5%
Equipment
Electrical
Equipment
30%
Other
2%
EPA Region 7 assessed $71,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 25 million pounds of nitrates were reported as
released to surface water in EPA Region 7 from 1995 through 1998. This represents a
correction of 98 percent to the baseline data. Almost 1 million pounds of nitrates were added to
the quantity released to land on-site, a correction of 1,435 percent. Changes in nitrate releases
through underground injection or releases off-site were minimal or nonexistent.
EPA REGION 7 SUMMARY
-------
Nearly 15 million pounds of nitrates were reported for the first time as released to publicly
owned treatment works. This resulted in a correction of 263 percent to the TRI database. The
amount of nitrates reported as transferred off-site to other types of facilities for further waste
management was reduced by about 2.3 million pounds. This quantity represents a correction of
20 percent to the TRI database. The quantity of nitrates reported as treated on-site increased
by about 37 million pounds, a correction of over 2,000 percent.
Table 2 lists the top ten facilities in EPA Region 7 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 7
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Farmland Foods, Inc.
Crete, NE
Simmons Foods, Inc.
South West City, MO
IBP, Inc., Lexington,
NE
Excel Corporation
Schuyler, NE
America Cynamid
Company, Hannibal
Plant, Palmyra, MO
Biokyowa, Inc.
Cape Girardeau, MO
Excel Corporation
Dodge City, KS
Maytag Appliances
NLP 2, Newton, IA
Farmland Industries,
Inc., Coffeyville, KS
IBP, Inc.
West Point, NE
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
6,009,972 0 0
5,260,431 0 0
5,100,000 0 0
2,822,967 0 0
1 ,877,000 0 0
1 ,626,000 0 0
0 0 958,662
918,000 0 0
580,700 0 0
260,000 0 0
Total
Changes in
On-site
Releases
(pounds)
6,009,972
5,260,431
5,100,000
2,822,967
1 ,877,000
1 ,626,000
958,662
918,000
580,700
260,000
Total
Changes in
Off-site
Releases
(pounds)
0
4,266
0
363
0
5,600
0
0
0
1,000
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1 ,
2000.
EPA REGION 7 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 7
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
MEMC Electronic Materials, Inc., St. Peters Plant
O'Fallon, MO
Farmland Foods, Inc., Denison, IA
Excel Corporation, Marshall, MO
National Starch & Chemical Company, North Kansas City, MO
Midland Brake, Inc., lola, KS
Dairy Farmers of America, Inc., Cabool, MO
Air Capitol Plating, Inc., Wichita, KS
Anodizing, Inc. - Extrusions, Inc., Fort Scott, KS
Boeing Company, Saint Louis, MO
TFS Commercial Solutions Group-Decorah Ops., Decorah, IA
Responded to
Enforcement
Alert?1
No
No
No
No
No
Yes
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Total
Changes in
Transfers to
POTWs
(pounds)
4,155,000
3,518,000
2,828,594
913,961
389,800
339,068
231,014
224,682
179,000
216,000
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
0
0
40,424
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1 ,
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 26 facilities in EPA Region 7 submitted 143 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the
4 reporting years is shown on Figure 3. Approximately one-fourth of the reporting forms were
first-time submittals, consisting of 3 Form As and 33 Form Rs. Data from the new reports
addressed 15 chemicals.
FIGURE 3
NON-NITRATE REPORTING FORMS SUBMITTED
45
40
35
30
20
15
10
5
0
/
The other 107 reporting forms were
revisions to previous submittals to the TRI.
These revised reporting forms addressed a
total of 19 chemicals. A summary of the
changes in transfer and release quantities
from all non-nitrate reports is shown in
Table 4. The most significant change to the
TRI from these reports was an additional
680,000 pounds of sodium nitrite reported
as released to surface water by one facility
for reporting years 1995 through 1998.
1995 1996 1997
Reporting Year
New D Revised All
1998
EPA REGION 7 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7632-00-0
7440-50-8
1 08-88-3
Total
Chemical
Sodium nitrite
Copper
Copper compounds
Chromium compounds
Toluene
All other chemicals
Changes in Reported
Releases (pounds)
678,128
4,624
2,118
34,979
34,897
80,266
835,012
Changes in Reported
Transfers (pounds)
0
249,112
102,220
33,833
25,104
-232,197
178,072
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 7 is presented in the Nitrate Initiative Fact Sheet for this region. The factsheet also
identifies the EPA Region 7 contact that can be reached for further information and state
contacts for EPA Region 7 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain, covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 7 SUMMARY
-------
NITRATE INITIATIVE
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 8
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 8.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 154 nitrate reporting forms from
facilities in EPA Region 8. About 20 facilities in EPA Region 8 submitted a total of 45 reports for
nitrates during the Nitrate Initiative. Seven of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 8 SUMMARY
-------
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by 25 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 8. Fewer than 10 reports were
submitted as revisions to nitrate reports
filed prior to the Nitrate Initiative.
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
36
38
36
44
154
Revised
Reports
Submitted
1
1
1
4
7
New
Reports
Submitted
7
9
11
11
38
Total
Nitrate
Reports
43
47
47
55
192
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. No TRI
Form A reporting forms were submitted. The 45 Form R reporting forms resulted in a 10
percent increase in reported on-site and off-site releases of nitrates and a 36 percent increase
in reported transfers off-site of nitrates for further waste management. As shown on Figure 1
below, food industries were responsible for most of the increases in releases in EPA Region 8.
Miscellaneous manufacturing and food industries were responsible for the majority of the
increases in transfers, as shown in Figure 2.
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
Metal Mining
Instruments 5%
8%
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
Electrical
Equipment
23%
Other
3%
Miscellaneous
Manufacturing
43%
EPA Region 8 assessed $11,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 3.9 million pounds of nitrates were reported as
released to surface water in EPA Region 8 from 1995 through 1998. This represents a
correction of 25 percent to the baseline data. Over 329,000 pounds of nitrates were added to
the quantity released to land on-site, a correction of 6 percent. Changes in nitrate releases to
land or through underground injection were nonexistent.
EPA REGION 8 SUMMARY
-------
About 2.4 million pounds of nitrates that were reported for the first time as released to publicly
owned treatment works. This resulted in a correction of 37 percent to the TRI database. An
additional 98,000 pounds of nitrates were reported as transferred off-site to other types of
facilities for further waste management. This quantity represents a correction of 22 percent to
the TRI database. The quantity of nitrates reported as treated on-site increased by about 8.6
million pounds, a correction of 106 percent.
Table 2 lists the facilities in EPA Region 8 that responded to the initiative and reported changes
in releases of nitrates. Table 3 lists the top ten facilities in EPA Region 8 that responded to the
initiative, ranked on total changes in transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR FACILITIES IN EPA REGION 8
RANKED ON TOTAL CHANGES IN RELEASES
I
Facility, City, State
Excel Corporation
Fort Morgan, CO
Kodak, Colorado
Division, Windsor,
CO
Wharf Resources
(U.S.A.), Inc., Lead,
SD
Saputo Cheese
USA, Inc., Big Stone
City, SD
Easton Technical
Products
Salt Lake City, UT
Responded to
Enforcement
Alert?1
No
No
No
Yes
Yes
REPORTING YEARS 1995 THROUGH 1998)
First Time
Reporter?2
Yes
Yes
No
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
3,596,262 0 0
335,000 0 -15
4,150 0 229,000
0 0 99,705
0 0 1 ,000
Total
Changes in
On-site
Releases
(pounds)
3,596,262
334,985
233,150
99,705
1,000
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000. are considered to
have responded to the enforcement alert.
A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 8 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 8
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Easton Technical Products, Salt Lake City, UT
Dairy Farmers of America, Inc., Amalga, UT
Meadow Gold Dairies, Englewood, CO
Viktron Utah, Salt Lake City, UT
Compeq International, Salt Lake City, UT
LSI Logic, Inc., Colorado Springs, CO
Anheuser-Busch, Inc., Fort Collins, CO
Front Range Investors, Inc., Front Range Plating
Englewood, CO
Conexant Systems, Inc., Colorado Springs, CO
Merix Corporation, Loveland, CO
Responded to
Enforcement
Alert?1
Yes
Yes
Yes
Yes
No
No
No
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
1 ,066,856
381 ,769
262,027
168,000
156,374
109,998
0
78,257
61 ,024
42,000
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
98,711
0
0
0
Facilities that submitted nitrate reports after
have responded to the enforcement alert.
A facility is identified as a first time reporter
2000.
December 31. 1999. but before the enforcement mailing in April 2000. are considered to
if the facility did not submit nitrate reports for these reporting years prior to January 1,
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 6 facilities in EPA Region 8 submitted 28 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the
4 reporting years is shown on Figure 3. Over half of the reporting forms were first-time
submittals, consisting of one Form A and 14 Form Rs. Data from the new reports addressed 6
chemicals.
FIGURES
NON-NITRATE REPORTING FORMS SUBMITTED
8
7
I 6
1995 1996 1997
Reporting Year
New Q Revised All
1998
The other 13 reporting forms were revisions
to previous submittals to the TRI. These
revised reporting forms addressed a total of 4
chemicals. A summary of the changes in
transfer and release quantities from all non-
nitrate reports is shown in Table 4. The most
significant change to the TRI from these
reports was an additional 600,000 pounds of
ethylene glycol reported as transferred
off-site by one facility for reporting years
1995 through 1998.
TABLE 4
EPA REGION 8 SUMMARY
-------
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
107-21-1
7697-37-2
7439-96-5
7440-02-0
7440-47-3
Total
Chemical
Ethylene glycol
Nitric acid
Manganese
Nickel
Chromium
All other chemicals
Changes in Reported
Releases (pounds)
-6,923
93,583
18,001
12,234
3,091
419
120,405
Changes in Reported
Transfers (pounds)
600,000
-750
4,120
1,482
8,257
5,825
618,934
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 8 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 8 contact that can be reached for further information and state
contacts for EPA Region 8 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa.gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 8 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 9
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally-manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 9.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 286 nitrate reporting forms from
facilities in EPA Region 9. About 100 facilities in EPA Region 9 submitted a total of 310 reports
for nitrates during the Nitrate Initiative. Twenty-three of these facilities submitted reporting
forms in response to the enforcement alert.
EPA REGION 9 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports more than doubled the number of
nitrate reporting forms in the TRI
database from facilities in EPA Region 9.
Fewer than 20 reports were submitted as
revisions to nitrate reports filed prior to the
Nitrate Initiative.
The number of reporting forms increased
across the 4 reporting years covered by
the Nitrate Initiative, with a large increase
in submittals for reporting year 1998. TRI
Form A reporting forms represented only 3 of the 310 forms submitted. The remaining 307
Form R reporting forms resulted in a 17 percent increase in reported on-site and off-site
releases of nitrates and a 126 percent increase in reported transfers off-site of nitrates for
further waste management. As shown on Figure 1 below, food industries were responsible for
most of the increases in EPA Region 9. Figure 2 shows that food industries and industries that
manufacture electronic and electrical equipment and components were responsible for most of
the increases in transfers for waste management.
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
49
58
67
112
286
Revised
Reports
Submitted
2
3
3
8
16
New
Reports
Submitted
67
73
73
81
294
Total
Nitrate
Reports
116
131
140
193
580
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Primary
Metals
10%
Secondary
Metals
8%
Transportation
Equipment
7%
Secondary
Metals
23%
Primary
Metals
Electrical
Equipment
27%
PA Region 9 assessed $190,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 196,000 pounds of nitrates were reported as
released to surface water in EPA Region 9 from 1995 through 1998. This represents a
correction of 2 percent to the baseline data. Over 1.9 million pounds of nitrates were added to
the quantity released to land on-site, a correction of 32 percent. Changes in nitrate releases
EPA REGION 9 SUMMARY
-------
through underground injection were non-existent. An additional 446,000 pounds of nitrates
were reported released off-site, a correction of 291 percent.
Most dramatic was the 31 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 127 percent to the
TRI database. An additional 776,000 pounds of nitrates were reported as transferred off-site to
other types of facilities for further waste management. This quantity represents a correction of
89 percent to the TRI database. The quantity of nitrates reported as treated on-site increased
by about 3.3 million pounds, a correction of 703 percent.
Table 2 lists the top ten facilities in EPA Region 9 that responded to the initiative, ranked on
total changes in releases. Table 3 lists the top ten facilities ranked on total changes in
transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 9
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Hilmar Cheese
Company, Inc. Hilmar,
CA
F & A Dairy of California,
Inc., Newman, CA
Luxfer Gas Cylinders
Riverside, CA
Alloys Cleaning, Inc.
Los Angeles, CA
C & H Sugar Company
Inc., Crockett, CA
Recot, Inc.
Bakersfield, CA
Barrick Goldstrike Mine
Elko, NV
DK Environmental, Inc.
Vernon, CA
Kaiser Aluminum &
Chemical Corporation
Oxnard, CA
Safety-Kleen, Inc.
San Jose, CA
Responded to
Enforcement
Alert?1
Yes
Yes
No
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
0 0 1,387,105
0 0 1,162,765
0 0 143,809
0 00
195,558 0 0
0 0 101,000
0 0 24,300
0 00
0 00
0 00
Total
Changes in
On-site
Releases
(pounds)
1,387,105
1,162,765
143,809
0
195,558
101,000
24,300
0
0
0
Total
Changes in
Off-site
Releases
(pounds)
0
0
196,629
273,538
0
0
0
23,768
6,742
1,380
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 9 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 9
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Dairy Farmers of America, Inc., Corona, CA
Land O'Lakes, Inc., Tulare, CA
Indalex West, Watsonville, CA
George Industries, Los Angeles, CA
United Dairymen of Arizona, Tempe, AZ
ITT Industrial Cannon, Santa Ana, CA
American Racing Custom Wheels, Gardena, CA
Komag, Inc., Building 6, San Jose, CA
Gene's Plating Works, Los Angeles, CA
Easton Sports, Inc., Van Nuys, CA
Responded to
Enforcement
Alert?1
Yes
Yes
No
No
No
No
No
No
No
Yes
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
2,813,050
2,373,763
2,293,788
1,885,541
1 ,375,997
1,319,724
1,214,659
1 ,070,000
785,299
923,000
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
0
0
0
198,190
0
(1) Facilities that submitted nitrate reports after
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter
2000.
December 31. 1999, but before the enforcement mailing in April 2000, are considered to
if the facility did not submit nitrate reports for these reporting years prior to January 1,
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 48 facilities in EPA Region 9 submitted 335 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the 4-
reporting years is shown on Figure 3. About one-fourth of the reporting forms were first-time
submittals, consisting of 15 Form As and 79 Form Rs. Data from the new reports addressed 23
chemicals.
0)
.a
FIGURES
NON-NITRATE REPORTING FORMS SUBMITTED
1995
1996
1997
1998
Reporting Year
I New n Revised All
The other 241 reporting forms were revisions
to previous submittals to the TRI. These
revised reporting forms addressed a total of
26 chemicals. A summary of the changes in
transfer and release quantities from all non-
nitrate reports is shown in Table 4. The most
significant change to the TRI from these
reports was a reduction of almost 3 million
pounds of zinc compounds previously
reported as transferred off-site by one facility
for reporting years 1995 through 1998.
EPA REGION 9 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
7440-50-8
7664-41-7
7697-37-2
Total
Chemical
Copper compounds
Copper
Ammonia
Lead compounds
Nitric acid
All other chemicals
Changes in Reported
Releases (pounds)
10,936
910,151
1,037
104
62,708
-41 8,461
566,475
Changes in Reported
Transfers (pounds)
1 ,452,302
439,825
645,661
182,900
80,914
-3,769,315
-967,713
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 9 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 9 contact that can be reached for further information and state
contacts for EPA Region 9 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa. gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 9 SUMMARY
-------
NITRATE INITIATIVE:
CHANGES TO THE TOXIC RELEASE INVENTORY
EPA REGION 10
BACKGROUND
Through its National Nitrate Compliance Initiative (Nitrate Initiative), the U.S. Environmental
Protection Agency (EPA) has achieved significantly improved compliance rates for nitrate
reporting to the Toxic Release Inventory (TRI). The TRI is a database of specific toxic chemical
releases and other waste management activities in the United States. The TRI was created
through the Emergency Planning and Community Right-to-Know Act (EPCRA). EPCRA
empowers national, state, and local governments; industry; public-interest and environmental
groups and organizations; and the public in dialogues about environmental and human health
impacts from the manufacture and use of toxic chemicals in the United States.
Facilities submit one of two types of reporting forms to EPA for the TRI: Form R and Form A.
Form R is an extensive report that provides information on releases, transfers, and other waste
management activities of a toxic chemical. The Form A can be used by a facility when it uses
less than 1 million pounds of a chemical and releases or otherwise manages less than 500
pounds of that chemical; it certifies that the facility is not subject to the more extensive reporting
requirements on the Form R.
The Nitrate Initiative used various compliance and enforcement tools to improve known
compliance rates by facilities for the period of 1995 through 1998 for water-dissociable nitrate
compounds. Nitrate reporting is important because nitrates are toxic chemicals that at sufficient
doses can cause serious risks or death to humans and significant damage to the environment.
The Nitrate Initiative began on March 1, 2000; it combined the use of an enforcement alert and
show cause letters. The enforcement alert described the lack of compliance with nitrate
reporting for coincidentally manufactured nitrate compounds and urged facilities to self-disclose
violations. The show cause letters offered facilities the opportunity to demonstrate that there
were no violations as alleged or to negotiate a settlement with a greatly reduced penalty.
Although the enforcement alert for the Nitrate Initiative was published in March 2000, some
facilities became aware of the enforcement effort before its publication and submitted nitrate
reporting forms to the TRI after December 31, 1999, under EPA's audit policy. Therefore, the
TRI data as of December 31, 1999, is designated as baseline data and is used to evaluate the
effect of the Nitrate Initiative on the TRI database. This document summarizes the impact of the
Nitrate Initiative for nitrate reporting to the TRI in EPA Region 10.
PARTICIPATION
Prior to the Nitrate Initiative, the TRI contained data from 235 nitrate reporting forms from
facilities in EPA Region 10. About 30 facilities in EPA Region 10 submitted a total of 90 reports
for nitrates during the Nitrate Initiative. Six of these facilities submitted reporting forms in
response to the enforcement alert.
EPA REGION 10 SUMMARY
-------
TABLE 1
NUMBER OF NITRATE REPORTING FORMS
As shown in Table 1, the majority of these
forms are "new reports," which are reports
that were submitted for the first time
during the Nitrate Initiative. These new
reports increased by over 25 percent the
number of nitrate reporting forms in the
TRI database from facilities in EPA
Region 10. Fewer than 30 reports were
submitted as revisions to nitrate reports
filed prior to the Nitrate Initiative.
The reporting forms were fairly evenly
distributed across the 4 reporting years
covered by the Nitrate Initiative. TRI
Form A reporting forms represented only
2 of the 90 forms submitted. The remaining 88 Form R reporting forms resulted in a 2 percent
increase in reported on-site and off-site releases of nitrates and a 14 percent increase in
reported transfers off-site of nitrates for further waste management. As shown on Figure 1
below, industries that perform primary smelting and refining of metals were responsible for most
of the increases in releases in EPA Region 10. Figure 2 shows industries that manufacture
transportation equipment were responsible for most of the increases in transfers.
Reporting
Year
1995
1996
1997
1998
1 995-1 998
Number of Reports
Baseline
Reports
48
56
61
70
235
Revised
Reports
Submitted
4
5
5
11
25
New
Reports
Submitted
16
14
18
17
65
Total
Nitrate
Reports
64
70
79
87
300
FIGURE 1
PERCENT CHANGES IN
NITRATE RELEASES
REPORTED BY INDUSTRY SECTOR
Other
FIGURE 2
PERCENT CHANGES IN
NITRATE WASTE MANAGEMENT TRANSFERS
REPORTED BY INDUSTRY SECTOR
Primary
Metals
17%
Chemicals
10%
Primary
Metals
99%
Secondary
Metals
23%
Transportation
Equipment
50%
EPA Region 10 assessed $66,000 in penalties under the Nitrate Initiative.
CHANGES IN NITRATE RELEASE AND TRANSFER DATA BY MEDIA
As a result of the Nitrate Initiative, an additional 475,000 pounds of nitrates were reported as
released to surface water in EPA Region 10 from 1995 through 1998. This represents a
correction of 2 percent to the baseline data. Changes in nitrate releases to land or to off-site
locations or through underground injection were minimal or nonexistent.
EPA REGION 10 SUMMARY
-------
Most dramatic was the 2.7 million pounds of nitrates that were reported for the first time as
released to publicly owned treatment works. This resulted in a correction of 13 percent to the
TRI database. An additional 305,000 pounds of nitrates were reported as transferred off-site to
other types of facilities for further waste management. This quantity represents a correction of
64 percent to the TRI database. The quantity of nitrates reported as treated on-site increased
by about 1.1 million pounds, a correction of 16 percent.
Table 2 lists the facilities in EPA Region 10 that responded to the initiative and reported
changes in releases of nitrates. Table 3 lists the top ten facilities in EPA Region 10 that
responded to the initiative, ranked on total changes in transfers.
TABLE 2
CHANGES IN RELEASES OF NITRATES FOR FACILITIES IN EPA REGION 10
RANKED ON TOTAL CHANGES IN RELEASES
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Wah Chang-Oremet
Facility, Albany, OR
Wah Chang Albany
Albany, OR
Simpson Tacoma
Kraft Company
Tacoma, WA
Weyerhaeuser Pulp
Mill, Cosmopolis, WA
Fort James Camas,
LLC, Camas, WA
Blount, Inc., CCI
Operation
Lewiston, ID
Hytek Finishes
Company, Kent, WA
Responded to
Enforcement
Alert?1
No
No
No
No
No
No
No
First Time
Reporter?2
Yes
No
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface
Water Underground Land
Discharges Injection Disposal
1 ,095,000 0 0
1 ,022,000 0 0
155,400 0 0
98,000 0 0
92,400 0 250
755 0 0
0 00
Total
Changes in
On-site
Releases
(pounds)
1 ,095,000
1 ,022,000
155,400
98,000
92,650
755
0
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
1,000
0
0
91
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1,
2000.
EPA REGION 10 SUMMARY
-------
TABLE 3
CHANGES IN TRANSFERS OF NITRATES FOR TOP TEN FACILITIES IN EPA REGION 10
RANKED ON TOTAL CHANGES IN TRANSFERS FOR WASTE MANAGEMENT
(REPORTING YEARS 1995 THROUGH 1998)
Facility, City, State
Boeing BCAG Fabrication Division-Auburn, Auburn, WA
Timet Castings Corporation, Albany, OR
Anodizing Inc., Parts Division, Portland, OR
Solvay Interox, Inc., Longview, WA
Advanced Silicon Materials Inc., Moses Lake, WA
Western Pneumatic Tube Company, Kirkland, WA
Hytek Finishes Company, Kent, WA
Boeing Commercial Airplane Group - Everett, Everett, WA
Boeing Company of Portland, Portland, OR
Merix Corp., Forest Grove, OR
Responded to
Enforcement
Alert?1
Yes
Yes
No
No
No
No
No
Yes
Yes
No
First Time
Reporter?2
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Total
Changes in
Transfers to
POTWs
(pounds)
1 ,560,000
428,000
367,712
0
152,299
141,157
113,649
138,000
38,450
23,400
Total
Changes in
Other Off-site
Transfers
(pounds)
0
0
0
340,174
0
0
355
-35,478
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to
have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1 ,
2000.
CHANGES IN TRI DATA FOR CHEMICALS OTHER THAN NITRATE COMPOUNDS
As a result of the initiative, 20 facilities in EPA Region 10 submitted 158 reporting forms for
chemicals other than nitrate compounds. The distribution of these reporting forms across the
4 reporting years is shown on Figure 3. About one-third of the reporting forms were first-time
submittals, consisting of 9 Form As and 46
FIGURE 3 Form Rs. Data from the new reports
NON-NITRATE REPORTING FORMS SUBMITTED addreSSed 15 Chemicals.
The other 103 reporting forms were revisions to previous submittals to the TRI. These revised
reporting forms addressed a total of 19
chemicals. A summary of the changes in
501 . transfer and release quantities from all non-
nitrate reports is shown in Table 4. The
most significant change to the TRI from
these reports was an additional 1.3 million
pounds of copper compounds reported as
transferred off-site by one facility for
reporting years 1995 through 1998.
45
40
35
30-(
25
20
15
10-)
5
0
1995
1996
1997
1998
Reporting Year
I New n Revised All
EPA REGION 10 SUMMARY
-------
TABLE 4
CHANGES IN RELEASES AND WASTE MANAGEMENT TRANSFERS REPORTED FOR TOP FIVE CHEMICALS
BASED ON TOTAL CHANGES IN RELEASES AND TRANSFERS
(REPORTING YEARS 1995 THROUGH 1998)
CAS Number
1 08-1 0-1
7632-00-0
7664-41-7
Total
Chemical
Copper compounds
Lead compounds
Methyl Isobutyl Ketone
Sodium nitrite
Ammonia
All other chemicals
Changes in Reported
Releases (pounds)
67,574
87,875
362,660
321,791
127,580
74,180
1 ,041 ,660
Changes in Reported
Transfers (pounds)
1 ,296,887
523,784
0
0
89,740
1 8,272
1 ,928,683
ADDITIONAL INFORMATION
Additional information on nitrate releases and transfers reported to TRI from facilities in EPA
Region 10 is presented in the Nitrate Initiative Fact Sheet for this region. The fact sheet also
identifies the EPA Region 10 contact that can be reached for further information and state
contacts for EPA Region 10 that can provide further information about individual state TRI
programs.
For further information on chemical releases and transfers reported to TRI, access the TRI
Explorer and Envirofacts databases through the following EPA websites:
http://www.epa.gov/triexplorer
http://www.epa. gov/enviro/html/ef_overview.html
The TRI Explorer database will generate reports based on facilities, chemicals, geographic
areas, or industry type (SIC code) at the county, state, and national levels. The Envirofacts
database provides environmental information from other EPA databases on air, chemicals,
facility information, grants and funding, hazardous waste, risk management plans, Superfund,
TRI, and other EPA databases.
These databases are publicly available and contain information on specific toxic chemical
releases and other waste management activities reported annually by certain covered industry
groups as well as federal facilities. Reporting year 1999 is the most recent TRI data available.
Please access the EPA Envirofacts database for the most recent TRI data.
EPA REGION 10 SUMMARY
-------
APPENDIX 2
NATIONAL AND REGIONAL FACT SHEETS ON THE
NITRATE INITIATIVE'S IMPACT ON THE TOXICS RELEASE INVENTORY
-------
&EPA Nitrate Initiative: Changes to the Toxic Release Inventory
ALL EPA REGIONS
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground
Injection
On-site Land
Releases
Off-site Releases
Total On- and Off-site
Releases
Baseline Data
1 (pounds)
741,868,493
584,802,309
135,524,966
21,541,218
18,053,333
759,921,826
Changes
from
Revised
Reports
(pounds)
15,260,506
19,882,241
-4,608,780
-12,955
-51,030
15,209,476
Increases
from New
Reports2
(pounds)
137,813,893
127,037,228
306,967
10,469,698
2,593,954
140.407,847
Net Change
from All
Reports
(pounds)
153,074,399
146,919,469
-4,301,813
10,456,743
2,542,924
155.617,323
Percent
Change to
Baseline
Data
219/o
25%
-3%
49%
14%
20%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
iTransfers of Nitrate
Compounds to Publicly
Owned Treatment Works
Treated On-site
168,711.455
7.406.317
151,063,582
158.469.899
94%
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site
Transfers
288,575,876
28,621,680
3.110,154
-1.938.833
254.804,991
10,799,380
257.915,145
8.860,547
89%
31%
Total Transfers Off-site
for Further Waste
Management
317,197,556
1,171,321
265,604,371
266,775,692
84%
National Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Form Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Form As Submitted
Number of Revised Form Rs Submitted
714
29
2,177
140
2
244
(1) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January 1, 2000.
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
831
920
993
1,138
Revised
Reports
Submitted
28
40
53
125
New
Reports
Submitted
539
555
558
554
Total
Reports
1,370
1,475
1,551
1,692
Release Quantities Reported ' (pounds)
Quantity from
Baseline
Reports
142,025,029
176,789,334
201,999,901
239,107,562
Changes from
Revised Reports
3,463,387
1,526,322
1,235,063
8.984,704
Increases from
New Reports
32,336,622
38,178,768
33,943,735
35,948,722
Updated
Database
Quantity
177,825,038
216,494,424
237,178,699
284,040,988
Transfer Quantities Reported 2 (pounds)
Quantity from
Baseline Reports
66,915,608
77,190,990
84,192,722
88,898.236
Changes from
Revised Reports
564,374
-1,008,027
691,303
923.671
Increases from
New Reports
62,803,621
62,764,358
70,735,704
69,300.688
Updated
Database
Quantity
130,283,603
138,947,321
155,619,729
159,122,595
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
ALL EPA REGIONS
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
FacUity, City, State
Hercules Inc. Parlin Plant, Parlin, NJ
Sud-Chemie Inc., West Plant, Louisville, KY
First Chemical Corporation, Pascagoula, MS
Anheuser-Busch Inc., Baldwinsville, PA
Osram Sylvania Products Inc., Towanda, PA
Responded to
Enforcement
Alert? 1
No
No
No
No
No
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
0 00
0 0 24
0 00
10,240,413 0 0
8,109,372 0 0
Total
Changes in
On-site
Releases
(pounds)
0
24
0
10,240,413
8,109,372
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total Changes
in Transfers to
POTWs
(pounds)
61,576,521
16,100.000
10,484,000
0
0
Total Changes
in Other
Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1. 2000.
Changes in Toxic Releases Inventory Data for Chemicals Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers
(Reporting Years 1995 through 1998)
CAS
Number
7440-50-8
Chemical
Manganese compounds
Copper
Copper compounds
Chromium compounds
Nickel compounds
All other chemicals
Newly Reported Releases
(pounds)
25,403,001
54,165
2,428,124
2,344,864
1,665,772
34,559,632
Newly Reported
Transfers (pounds)
3,892,033
17,961,666
10,514,538
9,636,066
6,101,252
11,779,256
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers
(Reporting Years 1995 through 1998)
CAS Number
7664-38-2
67-56-1
108-88-3
Chemical
Phosphoric acid
Zinc compounds
Methanol
Barium compounds
Toluene
All other chemicals
Changes hi Reported
Releases (pounds)
-319,396
31,294,804
978,993
2,946,000
531,045
4.227,420
Changes in Reported
Transfers (pounds)
35,135,362
-2,123,043
1,077,183
-939,685
1,418,172
-60,962,447
For More Information....
National Nitrate Initiative Coordinator
1200 Pennsylvania Avenue
Mail Code 2245A
Washington, D.C, 20460-0001
Fax: (202)401-2347
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax: (202) 401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 1
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data
1 (pounds)
4.407,930
4,407,930
0
0
1,437,114
5,845,044
6,404,978
13,577,736
1,308,565
14,886,301
Changes
from
Revised
Reports
(pounds)
0
0
0
0
0
0
1,720,000
-250,000
48,304
-201,696
Increases
from New
Reports 2
(pounds)
1,697,687
1,697,647
0
40
585,753
2,283,440
297,374
10,614,478
601,570
11,216,048
Net Change
from All
Reports
(pounds)
1,697,687
1,697,647
0
40
585,753
2,283.440
2,017,374
10,364,478
649,874
10.858.519
Percent
Change to
Baseline Data
39%
39%
0%
-
41%
39%
31%
76%
50%
74%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
* *Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(1) The baseline information reflects Toxic Release Inventory: data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January 1. 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Form Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Form As Submitted
Number of Revised Form Rs Submitted
57
3
182
3
0
7
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Numher of Reports
Baseline
Reports
52
56
59
49
Revised
Reports
Submitted
1
2
2
2
New
Reports
Submitted
44
45
46
50
Total
Reports
96
101
105
99
Release Quantities Reported * (pounds)
Quantity from
Baseline
Reports
1,867,496
1,299,317
1,441,269
1,236,962
Changes from
Revised Reports
0
0
0
0
Increases
from New
Reports
547,561
609,953
590,828
535,098
Updated
Database
Quantity
2,415,057
1,909,270
2,032,097
1,772,060
Transfer Quantities Reported 2 (pounds)
Quantity from
Baseline
Reports
3,569,628
3,756,375
3,600,117
3,960,181
Changes from
Revised Reports
4,480
9,782
14,376
-230,334
Increases from
New Reports
2,531,716
2,848,813
2,917,814
2,917,705
Updated
Database
Quantity
6,105,824
6,614,970
6,532,307
6,647,552
(]) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 1
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Precision Lithograining Corporation, South Hadley, MA
National Metal Finishing Corporation, Springfield, MA
Summit Corporation of America, Thomaston, CT
Kodak Polychrome Graphics LLC, Holyoke, MA
Cabot/ Agri-Mark Inc., Middlebury, VT
Responded to
Enforcement
Alert? '
Yes
No
No
Yes
Yes
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
0 00
0 00
856,147 0 0
0 00
0 00
Total
Changes in
On-site
Releases
(pounds)
0
0
856,147
0
0
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
1,371,355
1.101,410
0
719,710
632,321
Total Changes
in Other Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time
(Reporting Years 1995 through 1998)
CAS Number
7647-01-0
Chemical
Hydrochloric acid (1995 and after, acid
aerosols only)
Newly Reported
Releases (pounds)
2,115
Newly Reported Transfers
(pounds)
0
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7440-50-8
7697-37-2
Chemical
Copper
Cyanide compounds
Nitric acid
Chromium compounds
Nickel compounds
All other chemicals
Changes in Reported
Releases (pounds)
3,644
-209
18,251
7,757
540
76,736
Changes in Reported
Transfers (pounds)
514,947
13,845
-5,464
-7,372
-1,343
-1,316,958
For More Information....
State Contacts:
Connecticut
Joseph Pulaski
(860) 424-3373
Fax: (860) 424-4059
Maine
Robert Gardner
(207) 626-4503
Fax: (207) 626-4499
Email: joseph.pulaski@po.state.ct.us
Email: robert.s.gardner@state.me.us
Massachusetts
Walter Hope
(617)292-5982
Fax:(617)292-5858
Email: walter.hope@state.ma.us
Rhode Island
Karen Slattery
(401)222-2808, ext. 7030
Fax:(401)222-2017
New Hampshire
Leland Kimball
(603)271-2231
Fax: (603)225-7341
Email: leek@nhoem.state.nh.us
Vermont
Paul Van Hollebeke
(802) 241-3629
Fax: (802) 241-3273
Email: kslatter@dem.state.ri.us Email: paulv@dec.anr.state.vt.us
EPA Regional Contact:
Dwight Peavey
(617)918-1829
Fax:(617)918-1810
Email: peavey.dwight@epa.gov
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax: (202) 401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 2
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated Ou-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data '
(pounds)
35,250.479
35,140,557
0
109,922
927,224
36,177,703
16,083,011
11,866,884
1,986,971
13,853.855
Changes from
Revised
Reports
(pounds)
500,000
500,000
0
0
70
500,070
-500,000
243,717
920
244,637
Increases
from New
Reports 2
(pounds)
17.846,903
17,846,903
0
0
190,400
18,037,303
3,076,893
74,108,908
467,315
74,576,223
Net Change
from All
Reports
(pounds)
18,346,903
18,346,903
0
0
190,470
18,531,373
2,576,893
74,352.625
468,235
74,820,860
Percent
Change to
Baseline
Data
52%
52%
0%
0%
21%
51%
16%
627%
24%
540%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
« ^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(1) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January 1, 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Fonii Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Fonii As Submitted
Number of Revised Form Rs Submitted
43
0
136
0
14
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
57
65
64
66
Revised
Reports
Submitted
3
2
2
7
New Reports
Submitted
31
34
38
33
Total
Reports
88
99
102
99
Release Quantities Reported ' (pounds)
Quantity from
Baseline
Reports
7,065,831
7,546,044
8,664,532
12,901,296
Changes from
Revised Reports
290,027
210,015
9
19
Increases from
New Reports
4,862,313
4,419,825
4,663,009
4,092,156
Updated
Database
Quantity
12,218,171
12,175,884
13,327,550
16,993,471
Transfer Quantities Reported ~ (pounds)
Quantity from
Baseline
Reports
3,214,297
3,674,907
3,705,384
3,259,267
Changes from
Revised Reports
0
0
0
244.637
Increases from
New Reports
18,365,507
15,347.428
20,637,337
20,225.951
Updated
Database
Quantity
21,579,804
19,022,335
24,342,721
23,729,855
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 2
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Hercules Inc., Parlin Plant, Parlin, NJ
Anheuser-Busch Inc., Baldwinsville, NY
Bristol-Myers Squibb Company (Technical Operations), East
Syracuse, NY
Du Pont, Repauno Plant, Gibbstown, NJ
Arnphenol Corporation, Sidney, NY
Responded to
Enforcement
Alert?1
No
No
No
No
No
First Time
Reporter? *
Yes
Yes
Yes
Yes
Yes
Changes in On-slte Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
0 00
10,240,413 0 0
0 00
3,666,204 0 0
2,018,847 0 0
Total
Changes in
On site
Releases
(pounds)
0
10,240,413
0
3,666,204
2,018,847
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
61,576,521
0
8,050,000
0
0
Total Changes
in Other Off-site
Transfers
(pounds)
0
0
0
464,123
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7632-00-0
100-41-4
Chemical
Nickel compounds
Sodium nitrite
Ethylbenzene
Copper compounds
Certain glycol ethers
All other chemicals
Newly Reported
Releases (pounds)
468,324
378,786
97,793
239,180
228
100,971
Newly Reported Transfers
(pounds)
411,777
0
228,430
67,092
240,160
328,852
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7440-02-0
7440-48-4
7440-47-3
7439.96-5
7647-01-0
Chemical
Nickel
Cobalt
Chromium
Manganese
Hydrochloric acid (1995 and after, acid
aerosols only)
All other chemicals
Changes in Reported
Releases (pounds)
6,604
8,999
13,075
1,806
14,845
-53,769
Changes in Reported
Transfers (pounds)
762,657
291,364
172,318
34,956
-3,971
-5,188,928
For More Information....
State Contacts:
New Jersey
Andrew Opperman
(609) 292-6714
Fax: (609) 633-7031
Email: aopperma@dep.state.nj.us
Puerto Rico
Genaro Torres
(787) 766-2823
Fax:(787)766-0150
Email: jcaemer@prtc.net
EPA Regional Contact:
Nora Lopez
(732) 906- 6890
Fax:(732)321-6788
Email: lopez.nora@epa.gov
New York
Sitansu Ghosh
(518)485-8472
Fax:(518)457-2570
Email: sbghosh@gw.dec.state.ny.us
Virgin Islands
HollisL. Griffin
(340) 773-0565 (St. Croix)
Fax:(340)773-9310
(340) 777-4577 (St. Thomas)
Fax: (340) 774-5416 (St. Thomas)
Email: hlgrifl2@viaccess.net
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
o -p. Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 3
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data '
(pounds)
180,163,290
179,132,374
0
1,030,916
718,968
180,882,258
14,065,544
35,753,776
871,836
36,625,612
Changes from
Revised
Reports
(pounds)
-393,995
-393,995
0
0
-29,346
-423,341
-1,788,172
507,191
123,900
631,091
Increases
from New
Reports 2
(pounds)
19,925,211
19,922,488
0
2,723
49,072
19,974,283
3,553,902
9,510.439
3,802,065
13,312,504
Net Change
from All
Reports
(pounds)
19,531,216
19,528,493
0
2,723
19,726
19,550,942
1,765,730
10,017,630
3,925,965
13,943,595
Percent
Change to
Baseline
Data
11%
11%
0%
<1%
3%
11%
13%
_-- ~"\
X\ - """ * -Ar^
\ "n \ Locations of Top Ten
\ (^ Facilities Based On Total
9 "v Changes Reported for the
\ *M following:
A A __//
]l ^ "IT/A * Releases of Nitrate
/ \^_ T~~7"^ ^ ^v' \ V. Compounds to Surface
1 H / ^ V. *l
_J j i Ln. X/ t i »Transfers of Nitrate
( f^"^r^ ^^^> ~5T Compounds to Publicly
f/ 1 £ Owned Treatment Works
\ / ^ ^ ^
^X^-^ * _- ^
/ +^~^~~~^~~
t£d~~~f'
Regional IN it rate Submission Data
New Nitrate Reports
28% Number of Facilities Submitting New Reports 49
Number of New Form As Submitted 0
Number of New Form Rs Submitted 144
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports 1 3
38°'° Number of Re vised Form As Submitted 0
(J) The baseline information reflects Toxic Release Inventory data as of December 31. 1999.
(2) "New reports" are reports submitted for the first time after January 1. 2000.
Number of Revised Fonn Rs Submitted
19
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
70
78
85
103
Revised
Reports
Submitted
0
2
5
12
New
Reports
Submitted
40
37
38
29
Total
Reports
110
115
123
132
Release Quantities Reported ' (pounds)
Quantity from
Baseline
Reports
35,514,604
36,333,531
50,503,725
58,530,398
Changes from
Revised Reports
0
0
-800,000
376,659
Increases from
New Reports
5,619,495
5,302,198
5,123,336
3,929,254
Updated
Database
Quantity
41,134,099
41,635,729
54,827,061
62,836,311
Transfer Quantities Reported 2 (pounds)
Quantity from
Baseline
Reports
6,641,607
9,947,360
11,903,505
8,133,140
Changes from
Revised Reports
0
24,655
83,571
522,865
Increases from
New Reports
3,284,868
3,599,006
3,124,393
3,304,237
Updated
Database
Quantity
9,926,475
13,571,021
15,111,469
11,960,242
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
e -p. Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 3
Releases and Transfers tor 1 op Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Osrarn Sylvania Products Inc., Towanda, PA
Perdue Farms Inc., Accomac Processing Plant, Accomac. VA
Coming Inc., Danville, VA
Ruetgers Organics Corporation, State College, PA
Georgetown Processing Plant Facility #17, Georgetown, DE
Responded to
Enforcement
Alert?1
No
No
No
No
No
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes hi On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
8,109,372 0 0
5,660,000 0 1.110
0 00
0 00
1,563,000 0 640
Total
Changes hi
On-site
Releases
(pounds)
8,109,372
5,661,110
0
0
1,563,640
Total
Changes hi
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
0
0
3,555,000
0
0
Total Changes
hi Other Off-site
Transfers
(pounds)
0
0
0
3,415,138
0
(1) Facilities that submitted nitrate reports after December 31, 1999. but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January J. 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
1330-20-7
Chemical
Manganese compounds
Copper compounds
Zinc compounds
Barium compounds
Xylene (mixed isomers)
All other chemicals
Newly Reported
Releases (pounds)
11,312,625
181,859
1,845,639
807,882
803,853
3,668,062
Newly Reported
Transfers (pounds)
0
2,123,000
16,557
372,186
117,170
398,712
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7697-37-2
7440-02-0
7440-47-3
Chemical
Nitric acid
Nickel
Manganese compounds
Chromium
Nickel compounds
All other chemicals
Changes hi Reported
Releases (pounds)
71,062
3,119
27,015
1,424
10,515
-677.318
Changes in Reported
Transfers (pounds)
5,473
24,798
-13,926
8,028
-4,517
-1,560,053
For More Information....
State Contacts:
Delaware
David Fees
(302) 739-4791
Fax:(302)739-3106
District of Columbia
Miehele Penick
(202)673-2101,ext.3159
Fax: (202)673-2290
Email: dfees@dnrec.state.de.us Email: mpenick-oep@dcgov.org
Maryland
Patricia Williams
(410)631-3800
Fax:(410)631-3873
Pennsylvania
Shirley Miller
(717) 787-2450
Fax:(717)783-5099
Email: pwilliams@mde.state.md.us
Email: smiller@dli.state.pa.us
Virginia West Virginia
Dona Huang Stephen Kappa
(804) 698-4489 (304) 558-5380
Fax: (804) 698-4264 Fax: (304) 344-4538
Email: drhuang@deq.state.va.us Email: skappal@wvoes.state.wv.us
EPA Regional Contact:
William Reilly
(215) 814- 2072
Fax: (215) 814-3114
Email: reilly.william@epa.gov
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax: (202) 401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 4
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data '
(pounds)
159,378,190
104,585,967
53,018,570
1.773,653
5.625,438
165,003,628
45,059,289
16,816,580
8,254,336
25,070,916
Changes from
Revised
Reports
(pounds)
165,002
166,176
0
-1,174
-9,933
155,069
4,392,961
-105,462
232,702
127,240
Increases
from New
Reports 2
(pounds)
42,072.639
37,861,083
50,300
4.161,256
167,645
42,240,284
22,485,053
43,350,804
2,419,743
45,770,547
Net Change
from All
Reports
(pounds)
42,237,641
38,027,259
50,300
4,160.082
157.712
42.395,353
26,878,014
43,245,342
2,652,445
45.897,787
Percent
Change to
Baseline
Data
27%
36%
<1%
235%
3%
26%
60%
257%
32%
183%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(I) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports" are reports submitted for the first time after January 1. 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Fonii Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Fonii As Submitted
Number of Revised Form Rs Submitted
117
5
352
23
1
44
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
149
157
177
197
Revised
Reports
Submitted
5
8
9
23
New
Reports
Submitted
87
94
87
89
Total
Reports
236
251
264
286
Release Quantities Reported l (pounds)
Quantity from
Baseline
Reports
25,432,599
41,425,114
49,668,349
48,477,566
Changes from
Revised
Reports
19,294
39.982
16,990
78.803
Increases
from New
Reports
10,458,512
11,358.614
9,455,519
10,967.639
Updated
Database
Quantity
35,910,405
52,823,710
59,140,858
59,524,008
Transfer Quantities Reported ~ (pounds)
Quantity from
Baseline
Reports
5,954,706
5,335.060
5,946,620
7,834.530
Changes from
Revised
Reports
-443
111,397
1 49, 442
-133,156
Increases
from New
Reports
10,035,900
10,881,320
13,104,343
11,748,984
Updated
Database
Quantity
15,900,163
16.327,777
19,200,405
19.450,358
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 4
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Siid-Chemie Inc., West Plant (Formerly United Catalysts Inc.),
Louisville, KY
First Chemical Corporation, Pascagoula, MS
MEMC Electronic Materials Inc.. Moore, SC
Ensign-Bickford Company. Graham, KY
Solutia Inc., Decatur, AL
Responded to
Enforcement
Alert? '
No
No
No
No
Yes
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground
Discharges Injection Laud Disposal
000
000
4,235,000 0 0
0 0 4,048,238
4,000,000 0 0
Total
Changes in
On-site
Releases
(pounds)
0
0
4,235,000
4,048,238
4,000,000
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes in
Transfers to
POTWs
(pounds)
16,100,000
10,484.000
0
0
0
Total Changes in
Other Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7440-50-8
Chemical
Copper
Manganese compounds
Chromium compounds
Nickel compounds
Copper compounds
All other chemicals
Newly Reported
Releases (pounds)
15,371
13,509,341
1,267,464
484,123
1,230,064
9,568,478
Newly Reported Transfers
(pounds)
17,561,693
3,826,449
9,324,648
5,612,135
1,609,618
4,710,369
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
108-88-3
7664-38-2
7664-41-7
7440-50-8
Chemical
Toluene
Barium compounds
Phosphoric acid
Ammonia
Copper
AH other chemicals
Changes in Reported
Releases (pounds)
445,055
2,195,311
-2,364
775,269
-133,680
-16,113
Changes in Reported
Transfers (pounds)
1,310,639
-932,351
1,196,375
103,636
918,842
744,788
For More Information..
State Contacts:
Alabama
Kirk Chandler
(334)2(50-2717
Fax:(334)272-8131
Email: KFC@adem.state.al.us
Georgia
Dr. Bert K. Langley
(404) 656-6905
Fax: (404) 657-7893
Email: bert_langley@mail.dnr.state.ga.us
Florida
Sam Bracket!
(850) 413-9970
Fax:(850)488-1739
Email: sam.brackett@dca.state.il.us
Kentucky
Alex Barber
(502)564-2150
Fax: (502) 5644245
Email: barber@nrpath.state.ky.us
Mississippi
John David Burns
(601)961-5005
Fax:(601)961-5660
North Carolina
(No Coordinator at this time)
(919)733-1361
Fax:(919)733-2860
Email: john_burns@deq.state.ms.us Email: nc-sara@ncem.org
South Carolina
Michael Juras
(803) 898-4385
Fax: (803) 8984487
Email: jurasms@columb31. dhec.state.sc.us
Tennessee
Betty Eaves
(615)741-2986
Fax:(615)242-9635
Email: beavesfS),tnema.org
EPA Regional Contact:
Ezequiel Velez
(404)562-9191
Fax:(404)562-9163
Email: velezezequiel@epa.gov
To obtain TR1 data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax: (202) 401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 5
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment
Works (POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data '
(pounds)
69,312,218
61,632,244
5,699,000
1,980,974
2,401,174
71,713,392
22,319,618
82,314,828
1,310,449
83,625,277
Changes from
Revised
Reports
(pounds)
-340,562
43,398
0
-383,960
46,325
-294.237
155.606
1,624.827
66,616
1,691,443
Increases
from New
Reports 2
(pounds)
13,756,501
12.223,454
126,157
1,406,890
887,547
14,644,048
20,426,245
50,263,817
2,219,501
52.483,318
Net Change
from All
Reports
(pounds)
13,415,939
12,266,852
126,157
1.022,930
933,872
14.349,811
20.581,851
51.888,644
2,286,117
54,174,761
Percent
Change to
Baseline Data
19%
20%
<1%
52%
39%
20%
92%
63%
174%
65%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(1) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January 1, 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Fonii Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Fonii As Submitted
Number of Revised Form Rs Submitted
204
11
597
45
1
75
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
225
245
272
301
Revised
Reports
Submitted
7
12
20
37
New
Reports
Submitted
156
153
152
147
Total
Reports
381
398
424
448
Release Quantities Reported ' (pounds)
Quantity
from
Baseline
17,889,140
15,362,129
15,518,394
22,943,729
Changes from
Revised
Reports
-13,187
-20,143
11,892
-272.799
Increases
from New
Reports
2,765,582
4,095,800
3,805,836
3,976.830
Updated
Database
Quantity
20,641,535
19,437,786
19,336,122
26,647,760
Transfer Quantities Reported ~ (pounds)
Quantity from
Baseline
Reports
17,493,410
18,899,636
21,740,631
25,491.600
Changes from
Revised
Reports
437,923
387,209
128,759
737,552
Increases
from New
Reports
12,647,525
12,372,087
13,953,296
13,510,410
Updated
Database
Quantity
30,578,858
31,658,932
35,822,686
39.739,562
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 5
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Miller Plating and Metal Finishing, Evansville, IN
Aluminum Coil Anodizing Corporation, Streamwood. IL
Zenith Electronics Corporation - Rauland Division,
Melrose Park, IL
Wausau-Mosinee Paper Coiporation - Brokaw Mill, Brokaw,
WI
First District Association. Litchfield, MN
Responded to
Enforcement
Alert? '
No
Yes
No
No
No
First Time
Reporter?2
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground
Discharges Injection Land Disposal
000
000
000
2,447,991 0 4,159
000
Total
Changes hi
On site
Releases
(pounds)
0
0
0
2,452,150
0
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
44
0
Total
Changes in
Transfers to
POTWs
(pounds)
3,220,000
2,534,684
2,485,347
0
2,053,446
Total Changes
in Other
Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1. 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
108-95-2
7697-37-2
Chemical
Copper compounds
Zinc compounds
Phenol
Nitric acid
Barium compounds
All other chemicals
Newly Reported
Releases (pounds)
116,010
1,454,011
1,339,751
1,327,843
1,298,964
5,034,747
Newly Reported
Transfers (pounds)
3,551,534
507,774
6,914
5,535
2,840
2,773,118
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7664-38-2
7697-37-2
100-41-4
78-93-3
Chemical
Zinc compounds
Phosphoric acid
Nitric acid
Ethylbenzene
Methyl ethyl ketone
All other chemicals
Changes in Reported
Releases (pounds)
31,499,350
-338,060
34,103
10,530
-7,420
-273,972
Changes hi Reported
Transfers (pounds)
1,352,516
32,368,025
1,256,910
504,668
413,333
-60,318,718
For More Information....
State Contacts:
Illinois
Stan Ostrem
(217)785-3557
Fax:(217)782-1312
Indiana
Derek Eisman
(317)232-5433
Fax:(317)233-5627
Email: epa8579@epa.state.il.us Email: deisman@,dem.state.in.us
Minnesota
Michigan
Robert Jackson
(517)373-2731
Fax:(517)241-7966
Email: jacksorc@state.mi.us
Ohio
Cindy DeWulf
(614)644-3606
Fax: (614) 644-3681
Steve Tomlyanovich
(651)282-5396
Fax:(651)296-0459
Email: steve.tomlyanovich@state.mn.us
Wisconsin
Tara L. Edblom
(608) 264-6043
Fax: (608) 267-2531
Email: cindy. dewulf@epa.state, oh.us
Email: edblot@mail01.dnr.state.wi.us
EPA Regional Contact:
Thelma Codina
(312)886-6219
Fax:(312)353-4788
Email: codina.thehna@epa.gov
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 6
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline
Data1
(pounds)
184,001.208
123,700,064
56,940,946
3,360,198
54,881
184,056,089
47.883,922
71,076,429
1,348.432
72.424,861
Changes
from
Revised
Reports
(pounds)
8,740,804
13,238,512
-4,608,780
111,072
0
8,740,804
2,120,022
171,243
0
171,243
Increases
from New
Reports 2
(pounds)
15,846,462
13,813,657
130,510
1,902,295
126,549
15,973,011
52,642,242
15,911,357
41.649
15,953,006
Net Change
from Ah1
Reports
(pounds)
24.587,266
27,052,169
-4,478,270
2,013,367
126,549
24,713,815
54,762,264
16,082,600
41,649
16,124,249
Percent
Change
to
Baseline
Data
13%
22%
-8%
60%
231%
13%
1 14%
23%
3%
22%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(I) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January 1, 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Form Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Form As Submitted
Number of Revised Form Rs Submitted
69
0
236
13
0
23
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
95
112
114
137
Revised
Reports
Submitted
3
3
4
13
New
Reports
Submitted
58
60
61
57
Total
Reports
153
172
175
194
Release Quantities Reported ' (pounds)
Quantity
from
Baseline
Reports
31,995,906
48,238,013
47,220,726
56,601,444
Changes from
Revised
Reports
2,952,253
1.133,795
1,754,503
2.900,253
Increases
from New
Reports
3,621,585
3,725,783
4,384,875
4,240,768
Updated
Database
Quantity
38,569,744
53,097,591
53,360,104
63,742,465
Transfer Quantities Reported ~ (pounds)
Quantity from
Baseline
Reports
16,560,397
17,700,890
17,183,587
20,979,987
Changes from
Revised
Reports
0
6,272
0
164,971
Increases
from New
Reports
3,411,435
3,954,505
4,285,722
4,301,344
Updated
Database
Quantity
19,971,832
21,661,667
21,469,309
25,446,302
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 6
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Rohm & Haas Texas Inc., Deer Park, TX
Protein Technologies International Inc., Pryor, OK
Gulf Chemical & Metallurgical Corporation, Freeport, TX
Gerber Products, Fort Smith, AR
Du Pont - Victoria Plant, Victoria, TX
Responded to
Enforcement
Alert?1
No
No
No
No
No
First Time
Reporter? 2
No
Yes
Yes
Yes
No
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
7,092,909 0 0
6,091.690 0 160,250
2,646,605 0 0
0 00
6,145,040 -4,608,780 0
Total
Changes
in On-site
Releases
(pounds)
7,092,909
6.251,940
2,646,605
0
1,536,260
Total
Changes
hi Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes in
Transfers to
POTWs
(pounds)
0
0
0
2,572,558
0
Total Changes
hi Other
Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
108-95-2
7697-37-2
Chemical
Phenol
Zinc compounds
Nitric acid
Barium compounds
Copper compounds
All other chemicals
Newly Reported
Releases (pounds)
1,243,706
1,107,822
642,137
640,716
580,176
3,579,147
Newly Reported
Transfers (pounds)
0
1,160
316
0
29,316
1,686,924
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7664-38-2
79-10-7
67-56-1
1330-20-7
Chemical
Phosphoric acid
Acrylic acid
Methanol
Xylene (mixed isomers)
Manganese compounds
All other chemicals
Changes hi Reported
Releases (pounds)
-3,271
29,629
125,636
720,934
748,743
3,859,908
Changes in Reported
Transfers (pounds)
2,629,361
1,317,354
1,069,070
99,074
0
-1,541,278
For More Information....
State Contacts:
Arkansas
Robert (Bob) Johns
(501)730-9790
Fax:(501)703-9754
Louisiana
Linda Brown
(225) 765-0305
Fax:(225)765-0617
Email: robert.johnson@adeq.state.ar.us Email: lindab@deq.state.la.us
New Mexico
Max Johnson
(505) 476-9620
Fax: (505) 476-9695
Oklahoma
Monty Elder
(405) 702-1017 or (800) 869-1400
Fax:(405)702-1001
Email: Mjohnson@DPS.state.nm.us
Texas
Kenneth Kidd
(512)239-4TRI(4874)
Fax:(512)239-1515
Email: toxic@.tnrcc.state.tx.us
Email: monty.elder@deq.state.ok,us
EPA Regional Contact:
Warren Layne
(214)665-8013
Fax:(214)665-6762
Email: layne.warren@epa.gov
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 7
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated Ou-site
Transfers to Publicly
Owned Treatment
Works (POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline
Data1
(pounds)
25,979.660
25,910,365
2.500
66.795
4,902,809
30.882,469
1,773,916
6,254,116
11,756,563
18,010,679
Changes
from
Revised
Reports
(pounds)
6,977,000
6,977,000
0
0
0
6,977,000
282.000
1,871,780
-2,382,209
-510,429
Increases
from New
Reports 2
(pounds)
19,375,013
18,416,351
0
958,662
81,134
19,456,147
36,643,713
14,584,191
48,751
14,632,942
Net Change
from All
Reports
(pounds)
26,352,013
25,393,351
0
958,662
81,134
26.433.147
36,925,713
16,455,971
-2,333,458
14,122,513
Percent
Change
to
Baseline
Data
101%
98%
0%
1,435%
2%
86%
2,082%
t
V
*\
it}
\ Locations ol Top Ten
s. Facilities Based On Total
^ Changes Reported for the
* j/ following:
c
S J * * Releases of Nitrate
^
** 1
^
Regional
Y Compounds to Surface
V. Water
" jfs ^Transfers of Nitrate
/ Compounds to Publicly
^v Owned Treatment Works
* *J
^J
titrate Submission Data
New Nitrate Reports
° Number of Facilities Submitting New Reports 44
Number of New Form As Submitted 5
-20% Number of New FonnRs Submitted 138
Number of Facilities Submitting Revised Reports 8
780/o Number of Revised Form As Submitted 0
(1) The baseline information
(2) "New reports " are repor
reflects Toxic Release Inventory data as ofDecember 31. 1999.
ts submitted for the first time after January 1. 2000.
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
50
55
58
59
Revised
Reports
Submitted
2
2
2
8
New
Reports
Submitted
33
36
34
40
Total
Reports
83
91
92
99
Release Quantities Reported ' (pounds)
Quantity from
Baseline
Reports
9,631,178
6.785,376
6,552,502
7.913,413
Changes from
Revised
Reports
438,000
384,000
513,000
5,642,000
Increases
from New
Reports
3,099,239
5,982,064
4,080,248
6,294,596
Updated
Database
Quantity
13,168,417
13,151,440
11,145,750
19,850,009
Transfer Quantities Reported 2 (pounds)
Quantity from
Baseline
Reports
3,204,657
7,292,820
5,229,839
2,283,363
Changes from
Revised
Reports
105,443
-1.190,114
451,919
122,323
Increases
from New
Reports
3,798,759
3,817,839
3,407,452
3,608,892
Updated
Database
Quantity
7,108,859
9,920.545
9,089,210
6,014.578
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 7
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Farmland Foods Inc., Crete, NE
Simmons Foods Inc., South West City, MO
IBP Inc., Lexington, NE
MEMC Electronic Materials Inc. - St. Peters Plant,
OTallon, MO
Farmland Foods Inc., Denison, IA
Responded to
Enforcement
Alert? '
No
No
No
No
No
First Time
Reporter? 2
Yes
Yes
No
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
6,009,972 0 0
5,260,431 0 0
5,100,000 0 0
0 00
0 00
Total
Changes hi
On site
Releases
(pounds)
6,009,972
5,260,431
5,100,000
0
0
Total
Changes hi
Off-site
Releases
(pounds)
0
4,266
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
0
0
0
4,155,000
3,518,000
Total Changes hi
Other Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventor,' Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7632-00-0
7440-50-8
7664-93-9
Chemical
Sodium nitrite
Copper
Copper compounds
Zinc compounds
Sulfiiric acid (1994 and after, acid
aerosols only)
All other chemicals
Newly Reported
Releases (pounds)
678,128
4.657
2,096
44,124
43,800
36,868
Newly Reported
Transfers (pounds)
0
249,112
102,225
0
0
47,460
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
108-88-3
75-56-9
100-41-4
Chemical
Toluene
Chromium compounds
Propylene oxide
Manganese compounds
Ethylbenzene
All other chemicals
Changes hi Reported
Releases (pounds)
34,897
25,279
1,447
1,339
9,139
-46,762
Changes in Reported
Transfers (pounds)
25,104
33,833
0
62
-8,268
-271,456
For More Information....
State Contacts:
Iowa
Stuart Schmitz
(515)242-5241
Fax:(515)281-8895
Kansas
Scott Bangert
(785)296-1689
Fax:(785)296-1545
Email: stuart.schmitz@dnr.state.ia.us Email: sbangert@kdhe.state.ks.us
Missouri
Gene Nickel
(573) 526-6627
Fax: (573) 526-5808
Email: nrnicke@dur.state.mo.us
EPA Regional Contact:
Eddie McGlasson
(913)551-7756
Fax:(913)551-7065
Email: wnrtz.stephen@epa.gov
Nebraska
Donnie Zach
(402)471-4251
Fax:(402)471-2909
Email: donnie.zach@ndeq.state.ne.us
To obtain TRI data use assistance, call
TRIUser Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 8
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total Oil- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment
Works (POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline
Data1
(pounds)
41,279,454
15,976,064
19,862,000
5,441,390
7,762
41,287,216
8.066,425
6.393,451
441,666
6,835,117
Changes
from
Re\ised
Reports
(pounds)
568,135
339,150
0
228,985
0
568.135
1,009,000
0
-95
-95
Increases
from New
Reports 2
(pounds)
3.696,967
3,596,262
0
100,705
0
3.696,967
7,543,433
2,395,646
98,711
2,494,357
Net Change
from All
Reports
(pounds)
4,265.102
3,935,412
0
329,690
0
4,265,102
8,552,433
2,395,646
98,616
2.494.262
Percent
Change to
Baseline
Data
10%
25%
0%
6%
0%
10%
106%
37%
22%
36%
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
(I) The baseline information reflects Toxic Release Inventory data as of December 31. 1999.
(2) "New reports" are reports submitted for the first time after January 1. 2000.
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Form Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Form As Submitted
Number of Revised Form Rs Submitted
14
0
38
4
0
7
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995 through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
36
38
36
44
Revised
Reports
Submitted
1
1
1
4
New
Reports
Submitted
7
9
11
11
Total
Reports
43
47
47
55
Release Quantities Reported ' (pounds)
Quantity from
Baseline
Reports
5,427,915
11,856,786
12,070,404
11,932,111
Changes from
Revised
Reports
257,000
-4
-8
311.147
Increases
from New
Reports
99,955
1,111.885
1,229,205
1,255.922
Updated
Database
Quantity
5,784,870
12,968,667
13,299,601
13,499,180
Transfer Quantities Reported2 (pounds)
Quantity from
Baseline
Reports
1,217,065
1,447.859
2,103,222
2,066.971
Changes from
Revised
Reports
-41
-54
0
0
Increases
from New
Reports
552,015
566,133
718,468
657,741
Updated
Database
Quantity
1,769,039
2.013,938
2,821,690
2.724,712
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 8
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Excel Coiporation, Fort Morgan, CO
Easton Technical Products, Salt Lake City, LIT
Dairy Farmers of America Inc., Amalga, UT
Kodak - Colorado Division, Windsor, CO
Meadow Gold Dairies, Englewood, CO
Responded to
Enforcement
Alert?1
No
Yes
Yes
No
Yes
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
3,596,262 0 0
0 0 1,000
0 00
335,000 0 -15
0 00
Total
Changes hi
On-site
Releases
(pounds)
3,596,262
1,000
0
334,985
0
Total
Changes hi
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
0
1,066,856
381,769
0
262,027
Total Changes hi
Other Off-site
Transfers
(pounds)
0
0
0
-95
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter if the facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time
(Reporting Years 1995 through 1998)
CAS
Number
7439.96-5
7440-02-0
7440-47-3
7440-50-8
50-00-0
Chemical
Manganese
Nickel
Chromium
Copper
Formaldehyde
Newly Reported
Releases (pounds)
18,001
12,234
3,091
164
255
Newly Reported Transfers
(pounds)
4,120
1.482
8,257
5,575
250
Changes in Transfer and Release Quantities Previously Reported
(Reporting Years 1995 through 1998)
CAS
Number
107-21-1
7697-37-2
Chemical
Ethylene Glycol
Nitric Acid
Changes hi Reported
Releases (pounds)
-6,923
93,583
Changes hi Reported
Transfers (pounds)
600,000
-750
For More Information....
State Contacts:
Colorado
Kirk Mills
(303) 692-2977
Fax: (303) 782-4969
Email: kirk.mills@state.co.us
North Dakota
Ray DeBoer
(701)328-2111
Fax:(701)328-2119
Email: rdeboer@state.nd.us
Montana
Tom Ellerhoff
(406) 444-5263
Fax: (406) 444-4386
Email: tellerhofK8state.mt.us
South Dakota
Lee Ann Smith
(605) 773-3296
Fax: (605) 773-6035
Email: leeann.smiths
Jstate.sd.us
Utah Wyoming
Neil Taylor Bobbi Tenborg
(801)536-4102 (307)777-4910
Fax: (801) 536-4242 Fax: (307) 635-6017
Email: ntaylor@deq.state.utus Email: btenbo@state.wy.us
EPA Regional Contact:
Joyel Dhieux
(303)312-6447
Fax: (303)312-6044
Email: dhieux.joyel@epa.gov
To obtain TRI data use assistance, call
TRI User Support Service (TRI-US):
(202)260-1531
Fax: (202) 401-2347
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 9
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment Works
(POTW)
Other Off-site Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline
Data1
(pounds)
15,326,579
9,102,494
1,200
6,222,885
153,455
15,480,034
473,212
24,061,377
865,442
24,926,819
Changes
from
Revised
Reports
(pounds)
32,122
0
0
32,122
-58,146
-26,024
0
-858,023
7,266
-850,757
Increases
from New
Reports 2
(pounds)
2,132,705
195,828
0
1,936,877
504,763
2.637,468
3,326,135
31,395,568
758,752
32.154,320
Net Change
from All
Reports
(pounds)
2,164,827
195,828
0
1,968,999
446,617
2,611,444
3,326,135
30,537,545
766,018
31,303,563
Pel-cent
Change
to
Baseline
Data
14%
2%
0%
32%
291%
17%
703%
127%
89%
126%
(1) The baseline information reflects Toxic Release Inventory data as of December 31, 1999.
(2) "New reports " are reports submitted for the first time after January? 1, 2000.
Locations of Top Ten
Facilities Based On Total
Changes Reported for the
following:
Releases of Nitrate
Compounds to Surface
Water
^Transfers of Nitrate
Compounds to Publicly
Owned Treatment Works
Regional Nitrate Submission Data
New Nitrate Reports
Number of Facilities Submitting New Reports
Number of New Form As Submitted
Number of New Fonn Rs Submitted
Revised Nitrate Reports
Number of Facilities Submitting Revised Reports
Number of Revised Form As Submitted
Number of Revised Form Rs Submitted
95
3
291
10
0
16
Changes in Release and Transfer Data for Nitrate Compounds by Reporting Year (1995
through 1998)
Reporting
Year
1995
1996
1997
1998
Number of Reports
Baseline
Reports
49
58
67
112
Revised
Reports
Submitted
2
3
3
8
New
Reports
Submitted
67
73
73
81
Total
Reports
116
131
140
193
Release Quantities Reported ' (pounds)
Quantity front
Baseline
Reports
2,591,094
2,692,843
2,516,611
7,679,486
Changes from
Revised
Reports
0
268,677
268,677
-563,378
Increases
from New
Reports
1,058,480
541.991
532,279
504,718
Updated
Database
Quantity
3,649,574
3,503,511
3,317,567
7,620,826
Transfer Quantities Reported 2 (pounds)
Quantity from
Baseline
Reports
5,204,576
5,299,450
6,974,808
7,447,985
Changes from
Revised
Reports
23,562
-247,029
-332,299
-294,991
Increases
from New
Reports
7,680,069
8,530,795
7,865,236
8,078,220
Updated
Database
Quantity
12,908,207
13,583,216
14,507,745
15,231,214
(1) The release quantities shown above include on-site and off-site releases.
(2) The transfer quantities shown above include transfers to publicly owned treatment works and other off-site transfers for further waste management.
-------
«>EPA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 9
Releases and Transfers for Top Five Facilities Ranked on Total Changes in Releases and Transfers of Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Dairy Farmers of America Inc., Corona, CA
Land O'Lakes Inc., Tulare, CA
Indalex West, Watsouville, CA
George Industries, Los .Angeles. CA
Hilmar Cheese Company Inc., Hilmar, CA
Responded to
Enforcement
Alert?1
Yes
Yes
No
No
Yes
First Time
Reporter? 2
Yes
Yes
Yes
Yes
Yes
Changes in Oil-site Releases (pounds)
Surface Water Underground
Discharges Injection Land Disposal
000
000
000
000
0 0 1,387,105
Total
Changes hi
On-site
Releases
(pounds)
0
0
0
0
1,387,105
Total
Changes hi
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes hi
Transfers to
POTWs
(pounds)
2,813,050
2,373,763
2,293,788
1,885,541
0
Total Changes hi
Other Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31, 1999, but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter ifthe facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7632-00-0
120-80-9
Chemical
Copper compounds
Lead compounds
Sodium nitrite
Zinc compounds
Catechol
All other chemicals
Newly Reported Releases
(pounds)
11,165
104
98,518
82,198
3,521
126,626
Newly Reported Transfers
(pounds)
1,734,866
182,900
0
0
39,637
44,628
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7440-50-8
7664-41-7
7697-37-2
128-04-1
Chemical
Copper
Ammonia
Nitric acid
Nickel compounds
Sodium dimethyldithiocarbamate
All other chemicals
Changes hi Reported
Releases (pounds)
910,151
1.037
61,692
42,939
60,740
-832,216
Changes hi Reported
Transfers (pounds)
439,825
645,661
80,914
-119
53,063
-4,082,962
For More Information.
State Contacts:
American Samoa
Pati Faiai
(684) 633-2304
Fax:(684)633-5801
Email: asepa@samoatelco.com
California
California Environmental Protection Agency
(916)323-3421
Fax:(916)323-1788
Email: n/a
Hawaii
Marsha Graf
(808) 586-4249
Fax:(808)586-7537
Email: heer@eha.health.state.hi. us
Commonwealth of Northern Mariana Islands
Ignacio V. Cabrera
International: (670)664-8500
Fax: (670) 664-8540
Email: deq.director@saipan.com
EPA Regional Contact:
Adam Browning
(415)744-1121
Fax:(415)744-1073
Email: browning.adam@epa.gov
Arizona
Daniel Roe
(602)231-6346
Fax:(602)392-7519
Email: roed@dem.state.az.us
Guam
Conchita S. N. Taitano
International (671) 646-8863
Fax: (671) 477-9402
Email: taitano@kuentos.guam.net
Nevada
Alene Coulson
(775) 687-4670, ext. 3006
Fax: (775) 687-6396
Email: acoulson@govmail.nv.us
To obtain TRI data use assistance, can
TRI User Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
- CDA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 10
Percent Changes in Release, Treatment, and Transfer Baseline Data
for Nitrate Compounds
(Reporting Years 1995 through 1998)
On-Site Releases
Surface Water
Discharges
Underground Injection
On-site Land Releases
Off-site Releases
Total On- and Off-site
Releases
Treated On-site
Transfers to Publicly
Owned Treatment
Works (POTW)
Other Off-site
Transfers
Total Transfers Off-site
for Further Waste
Management
Baseline Data '
(pounds)
26,769,485
25,214,250
750
1,554,485
1,824,508
28,593,993
6,581,540
20,460.699
477,420
20,938,119
Changes
from
Revised
Reports
(pounds)
-988,000
-988,000
0
0
0
-988,000
14,900
-95,119
-36,237
-131,356
Increases
from New
Reports 2
(pounds)
1,463,805
1,463,555
0
250
1,091
1,464,896
1,068.592
2,669,783
341,323
3,011.106
Net Change
from All
Reports
(pounds)
475,805
475,555
0
250
1,091
476,896
1.083,492
2,574,664
305,086
2.879,750
Percent
Change to
Baseline
Data
2%
2%
0%
<1%
-------
- CDA Nitrate Initiative: Changes to the Toxic Release Inventory
EPA REGION 10
Releases and Transfers tor lop Mve Facilities KanUed on Total Changes in Releases and I ransters ot Nitrates
(Reporting Years 1995 through 1998)
Facility, City, State
Boeing BCAG Fabrication Division - Auburn, Auburn,
WA
Wah Chang-Oremet Facility, Albany, OR
Wan Chang Albany, Albany, OR
Timet Castings Corporation, Albany, OR
Anodizing Inc. Parts Division, Portland, OR
Responded to
Enforcement
Alert?1
Yes
No
No
Yes
No
First Time
Reporter? 2
Y'es
Yes
No
No
Yes
Changes in On-site Releases (pounds)
Surface Water Underground Land
Discharges Injection Disposal
0 00
1,095,000 0 0
1,022,000 0 0
0 00
0 00
Total
Changes in
On site
Releases
(pounds)
0
1,095,000
1,022,000
0
0
Total
Changes in
Off-site
Releases
(pounds)
0
0
0
0
0
Total
Changes in
Transfers to
POTWs
(pounds)
1,560,000
0
0
428,000
367,712
Total Changes
hi Other
Off-site
Transfers
(pounds)
0
0
0
0
0
(1) Facilities that submitted nitrate reports after December 31. 1999. but before the enforcement mailing in April 2000, are considered to have responded to the enforcement alert.
(2) A facility is identified as a first time reporter ifthe facility did not submit nitrate reports for these reporting years prior to January 1, 2000.
Changes in Toxic Releases Inventory Data for Chemicals
Other than Nitrate Compounds
Transfer and Release Quantities Reported for the First Time for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
108-10-1
7632-00-0
Chemical
Copper compounds
Lead compounds
Methyl isobutyl ketone
Sodium nitrite
Zinc compounds
All other chemicals
Newly Reported Releases
(pounds)
67,574
55,969
362,660
321,791
573
134,253
Newly Reported Transfers
(pounds)
1,296,887
555,674
0
0
83,188
14,271
Changes in Transfer and Release Quantities Previously Reported for Top 5 Chemicals
Based on Total Changes in Releases and Transfers (Reporting Years 1995 through 1998)
CAS Number
7664-41-7
7440-50-8
108-88-3
7697-37-2
67-56-1
Chemical
Ammonia
Copper
Toluene
Nitric acid
Methanol
All other chemicals
Changes hi Reported
Releases (pounds)
102,735
509
-3,695
11,718
21,447
-33,874
Changes in Reported
Transfers (pounds)
89,740
133,599
123,495
0
10,682
-357,489
For More Information....
State Contacts:
Alaska
Camille Stephens
(907) 465-5220
Fax: (907) 465-5244
Idaho
Bill Bishop
(208) 422-5725
Fax:(208)422-4485
Email: cstephen@envircon. state.ak.us Email: bbishop@bds. state.id.us
Oregon
Bob Albers
(503) 378-3473, ext. 262
Fax: (503) 373-1825
Email: Bob.ALBERS@state.or.us
EPA Regional Contact:
Christina Colt
(206)553-4016
Fax: (206) 553-8509
Email: colt.christina@epa.gov
Washington
Idell Hansen
(360) 407-6727 or (800) 633-7585
Fax:(360)407-6715
Email: ihan461@ecy.wa.gov
To obtain TRI data use assistance, call
TRIUser Support Service (TRI-US):
(202)260-1531
Fax:(202)401-2347
-------
APPENDIX 3
NITRATE INITIATIVE: ESTIMATED INSPECTION AND ENFORCEMENT COSTS SAVED
-------
THE NATIONAL NITRATE COMPLIANCE INITIATIVE
NITRATE INITIATIVE: ESTIMATED INSPECTION AND NITRATE-
ENFORCEMENT COSTS SAVED
AVOIDED COSTS
Based on an analysis of reporting data under the National Nitrate Compliance Initiative (Nitrate
Initiative), 670 facilities were discovered to be potentially in violation of reporting requirements
for nitrate. The noncompliance rate for nitrate reporting to the Toxic Release Inventory (TRI)
was expected to be about 25 percent. Therefore, to identify the same number of potential
violators without analyzing any data, the U.S. Environmental Protection Agency (EPA) would
have had to conduct 2,680 inspections and review the results of the inspections. For facilities
found to be in noncompliance, EPA would have to expend additional costs for case review
officers and attorneys to implement traditional enforcement methods.
EPA's costs for conducting these inspections and enforcement follow-up were estimated
assuming the following:
Senior employees (SEE) would conduct 80 percent of the inspections.
EPA employees, referred to as full-time equivalents (FTE), would conduct 20 percent of
the inspections.
The hourly cost for an SEE employee is $15.
The hourly cost for an FTE for inspection activity is $25, for case review is $27, and for
attorney fees is $35.
Overnight travel would be required for 80 percent of the inspections.
For the 25 percent or 670 facilities that would be in noncompliance, the cost estimate assumes
that only three inspections would be completed in 1 week. For the 75 percent or 2,010 facilities
that would be found in compliance, the cost estimate assumes that an average of 4.25
inspection would be completed in a week.
Using traditional inspection and enforcement methods, an estimated $1.7 million would be
incurred for facilities that would be found in noncompliance. An estimated $1.1 million would be
incurred for inspecting facilities that would be found in compliance. See Table 1 for a
breakdown of the cost estimate. The total estimated costs for achieving the results of the
Nitrate Initiative using traditional inspection and enforcement methods would be about $2.8
million. Assuming a 10 percent variability in this cost estimate, the avoided costs are estimated
to range between $2.5 million and $3.1 million.
INCURRED COSTS
The Nitrate Initiative started in March 2000, when the enforcement alert was issued. Activity
continued in April 2000 when Show Cause letters were mailed. EPA regional and headquarters
employees were actively involved in the Nitrate Initiative through October 2000. Therefore, the
estimate for incurred costs is based on an implementation period of 9 months. EPA regional
and headquarters employee time expended in support of the Nitrate Initiative was estimated in
terms of FTE, or the fraction of a year. One FTE is equivalent to 2,000 hours. EPA's cost for
implementing the Nitrate Initiative was developed assuming (1) an hourly cost of $30 for
employees in regional TRI programs and headquarters employees in the Toxics, Pesticides,
and Enforcement Division, and (2) an hourly cost of $35 for EPA regional employees in the
Office of Regional Counsel.
APPENDIX 3-1
-------
THE NATIONAL NITRATE COMPLIANCE INITIATIVE
Based on these assumptions, EPA estimates that about $496,000 was expended to support the
Nitrate Initiative. See Table 2 for a breakdown of this cost estimate. Assuming a 10 percent
variability in this cost estimate, the costs incurred are estimated to range between $545,600 and
$446,400.
TABLE 1
ESTIMATED COSTS FOR TRADITIONAL INSPECTION AND ENFORCEMENT METHODS
Activity
Number of
Inspections
Cost Factors
Cost
Facilities in Noncompliance: 670
Inspection Travel
Inspection by SEE
Inspection by FTE
Report Writing by SEE
Report Writing by FTE
Case Review by Case Review
Officer FTE
Enforcement Support by
Attorney FTE
Postage and other Materials
536 (80%)
536 (80%)
134(20%)
536 (80%)
134(20%)
670(100%)
670(100%)
NA
(1 week/3 inspections) x ($400/week)
(1 week/3 inspections) x (40 hours/week) x
($15/hour)
(1 week/3 inspections) x (40 hours/week) x
($25/hour)
(32 hours/inspection) x ($15/hour)
(32 hours/inspection) x ($25/hour)
(30 hours/inspection) x ($27/hour)
(25 hours/inspection) x ($35/hour)
NA
Total Estimated Inspection and Enforcement Costs for Facilities in Noncompliance
$71,467
$107,200
$44,667
$257,280
$107,200
$542,700
$586,250
$10,000
$1,726,763
Facilities in Compliance: 2,010
Inspection Travel
Inspection by SEE
Inspection by FTE
Report Writing by SEE
Report Writing by FTE
Review by Case Review
Officer FTE
Postage and other Materials
1 ,608 (80%)
1 ,608 (80%)
402 (20%)
1 ,608 (80%)
402 (20%)
2,010(100%)
NA
(1 week/4.25 inspections) x ($400/week)
(1 week/4.25 inspections) x (40 hours/week) x
($15/hour)
(1 week/4.25 inspections) x (40 hours/week) x
($25/hour)
(7 hours/inspection) x ($15/hour)
(7 hours/inspection) x ($25/hour)
(4 hours/inspection) x ($27/hour)
NA
Total Estimated Inspection and Enforcement Costs for Facilities in Compliance
$214,400
$321,600
$134,000
$168,840
$70,350
$217,080
$5,000
$1,131,270
APPENDIX 3-2
-------
THE NATIONAL NITRATE COMPLIANCE INITIATIVE
ESTIMATED COSTS SAVED
The difference between the avoided costs and the incurred costs ranges between $2 million and
$2.7 million, or about $2.35 million. The ratio of avoided costs to incurred costs is calculated as
follows:
($2.8 million avoided costs) / ($496,000 incurred costs) = $5.65
Therefore, for every dollar spent in support of the Nitrate Initiative, about $6 was saved.
TABLE 2
ESTIMATED COSTS INCURRED
EPA Program
Headquarters TPED and TRI
Region 1 TRI
Region 1 ORC
Region 2 TRI
Region 2 ORC
Region 3 TRI
Region 3 ORC
Region 4 TRI
Region 4 ORC
Region 5 TRI
Region 5 ORC
Region 6 TRI
Region 6 ORC
Region 7 TRI
Region 7 ORC
Region 8 TRI
Region 8 ORC
Region 9 TRI
Region 9 ORC
Region 10 TRI
Region 10 ORC
FTEs Spent
1
0.2
0.1
0.3
0.2
0.3
0.2
0.4
0.3
0.6
0.4
0.3
0.2
0.7
0.2
0.1
0.1
0.6
0.4
0.2
0.1
Cost Factors
(2000 hours/FTE) * ($30/hour)
(2000 hours/FTE) * ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
(2000 hours/FTE) x ($30/hour)
(2000 hours/FTE) x ($35/hour)
Consultant Costs
Estimated Total Costs Incurred
Cost
$60,000
$12,000
$7,000
$18,000
$14,000
$18,000
$14,000
$24,000
$21,000
$36,000
$28,000
$18,000
$14,000
$42,000
$14,000
$6,000
$7,000
$36,000
$28,000
$12,000
$7,000
$60,000
$496,000
Notes:
FTE Full-time Equivalent
ORC Office of Regional Counsel
TPED Toxics and Pesticides Enforcement Division
TRI Toxic Release Inventory
APPENDIX 3-3
------- |