U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF PESTICIDES AND TOXIC SUBSTANCES
401 M STREET S.W.
WASHINGTON, DC 20460
TOXIC CHEMICAL RELEASE INVENTORY (TRI)
STATE DATA ENTRY FEASIBILITY ANALYSIS
FEASIBILITY ANALYSIS
FINAL
CONTRACT #68-W9-0037 DELIVERY ORDER #112
August 5, 1992
BOOZ'ALLEN & HAMILTON Inc.
4330 East West Highway
Bethesda, Maryland 20814-44-55
301/951-2200
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
August 19, 1992 -T.C.D.. ANO TOX.C
Dear Chemical Information Management Project Members:
Enclosed are copies of the Interview Summary and Final
Report for the Toxic Release Inventory State Data Entry
Feasibility Analysis, as promised at the last FOSTTA meeting.
The Report was prepared by the contractor Booz*Allen & Hamilton.
Included in the Interview Summary is a list of those people
who were interviewed for the Report. I would like to thank the
FOSTTA Project for meeting with the contractor during the last
two meetings and especially thank those members of FOSTTA who
agreed to be interviewed.
The Final Report is undergoing Agency review and no
decisions have been made based on the options or recommendations.
If you have any questions about the Report, please contact me at
(202) 260-3757.
Sincerely,
Steven Newburg-Rinn, Chief
Public Data Branch
enclosures
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TABLE OF CONTENTS
EXECUTIVE SUMMARY iii
Chapter 1 INTRODUCTION 1
Background 1
Purpose and Approach 4
Chapter 2 CHARACTERISTICS OF EXISTING DATA BASES USING
STATE DATA ENTRY APPROACH 7
BRS 7
AIRS 11
Conclusions 14
Chapter 3 STATE AND REGIONAL INTERVIEWS 17
State Interviews 17
Regional Interviews 20
Chapter 4 DEFINITION OF CRITERIA FOR FEASIBILITY 23
Legislative Requirements 23
User Requirements 24
Operational Requirements 27
Fatal Criteria 28
Chapter 5 DEFINITION OF ALTERNATIVE APPROACHES 31
Status Quo 31
State-Based 32
State-Entry with Centralized Data Quality/Normalization 33
Hybrid 34
Chapter 6 ANALYSES OF OPTIONS AND RECOMMENDATIONS 37
Criteria Failing to Meet Fatal Factors 37
Analysis of Remaining Options 39
Recommendations 48
Conclusion 51
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Table of Contents
Appendix A INTERVIEWEE LIST 53
Appendix B INTERVIEW GUIDES 57
Appendix C STATE INTERVIEW MATRIX 67
Appendix D COST ANALYSIS ASSUMPTIONS 69
Feasibility Analysis ii
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EXECUTIVE SUMMARY
Background
In 1987 the Toxics Release Inventory (TRI) was established to meet the
public's demand for information about toxic chemicals in their community. The
law requires that EPA make this inventory available and accessible to the public
in various formats, but specifically in the form of a computer data base. Since the
creation of the TRI program, the public has become more aware of the presence
and effects of toxic chemicals, and has effectively used TRI data to promote
emergency planning, pollution prevention, waste minimization, and other
activities. Due to the usefulness of TRI data and the success of the TRI program,
the public's desire to know more about toxic chemicals continually grows. In
response to this demand, TRI has been expanded by EPA and Congress to
incorporate the need for access to additional information.
Purpose and Approach
Because of the increased volume of data to be processed by TRI and the
demands from users to have access to the data more quickly than the current
time frame, EPA is considering alternative data entry and management
approaches. Because several states have indicated interest in performing TRI
data entry at the state level, EPA has requested a study to determine the
feasibility of state data entry for TRI through an examination of:
The benefits, costs, and management issues raised by decentralized
TRI data management approaches
The logistical activities which would need to take place for such an
approach to succeed.
In order to obtain the information necessary to evaluate the feasibility of moving
to a system based solely or partially on entry of data at the state level, a series of
interviews were conducted with:
EPA Headquarters and Regional personnel involved with TRI
State personnel involved with TRI
System managers, state, and Regional personnel involved with two
other EPA data bases using a state data entry approach.
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Executive Summary
This data collection was based on structured interview guides that were
administered through face-to-face and telephone interviews. A list of
interviewees is included in Appendix A of this document and copies of the
interview guides in Appendix B.
BRS and AIRS Summary
The Biennial Reporting System (BRS) and the Aerometric Information
Retrieval System (AIRS), two data bases that rely upon data entry at the state
level, were examined to determine the benefits and problems associated with this
type of data management system. Although these two systems are not identical
to TRI, they do serve as useful tools for evaluating the feasibility of state data
entry for TRI. One important difference between these two systems and TRI is
that these systems support programs that are state delegated, and states are
primary users of the data. TRI, however, is not a state delegated program, and
does not possess the more formal state, Regional, and Headquarters relationships
upon which these two systems depend.
An obvious benefit of state data entry for both BRS and AIRS is that the
states are more knowledgeable about the facilities than EPA staff, and recognize
and resolve problems with the data more quickly. Data entry is also
accomplished more quickly by the individual states if they are active
participants, rather than by a centralized system entering all the data. However,
if a significant number of states do not participate in the data entry process, this
requires additional time and resources for EPA to enter the data for the state.
Coordinating with the states is clearly a challenge with both systems.
Additional time and resources are required in data conversion if states perform
data entry, and do not utilize the appropriate conversion software or experience
other problems with conversion. All states do not always adhere to the coding
conventions and standards for data entry/ and consequently data quality
suffers. Data quality is also affected when states do not have sufficient
resources to adequately perform data quality checks.
As can be seen, there are benefits to performing data entry at the state
level, but there are also significant challenges. Although the problems associated
with this approach may not severely affect the overall performance of these two
systems, it is necessary to evaluate the unique requirements of TRI to determine
the feasibility of this approach for TRI.
State and Regional Interview Summary
Both the states and the Regions saw potential benefits of the state data
entry approach, including higher data accuracy, improved timeliness, and an
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Executive Summary
increased sense of ownership, interest, and usage of TRI data by the states. But
state and Regional interviewees indicated that the extent to which the benefits
would be realized depended upon many factors. One major factor included the
ongoing commitment from states in participating. States currently have a wide
variety of capabilities, interests, and usages of TRI data.1 Therefore, all states
may not be interested in, and committed to, performing data entry for the long
term. Other states may be interested primarily in fulfilling their needs and not
the broader requirements of a national database. State and Regional interviews
indicated that for decentralization to work effectively, state commitment is a
necessity.
Other factors impacting the success of a state data entry approach
included the availability of resources and the resolution of many logistical
activities that must take place. All states have varying levels of capabilities and
available resources, therefore in most cases funds would need to be allocated by
EPA toward ensuring the states have the appropriate hardware, software, and
training to perform data entry. Logistical issues that would need to be resolved
include quality assurance/quality control, data normalization and
standardization, the processing and assignment of document control numbers to
Form Rs, and the revisions to data not only for the current year, but also for
previous years. States and Regions indicated that these factors must be
sufficiently addressed before decentralization is considered feasible. States
strongly emphasized that they would need to participate actively in resolving
these issues to ensure that their needs are met as well as national needs.
Interviewees felt that Regional offices should act primarily in an assistance
role, not an operational role. This could involve acting as a liaison between the
states and Headquarters and acting as the administrator of any grants.
Feasibility Criteria
To assess the feasibility of moving from centralized data entry to a
successful state-based approach, criteria for the assessment were defined. These
criteria were based upon the assessment of the other systems using state data
entry approaches as well as an in-depth understanding of the unique
requirements and needs of the TRI program and of state capabilities and
interests. These criteria fall into three main categories:
Legislative Requirements
Data base is national in scope*
1 A matrix in Appendix C summarizes the capabilities and interests of states interviewed for this
analysis.
* The criteria followed by an asterick are considered to be "fatal" criteria.
v Feasibility Analysis
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Executive Summary
TRI supports legislatively mandated uses*
Publicly accessible on-line*
Required data elements are present in the data base*
User Requirements
Accuracy close to 100% in critical data elements, such as
release fields, and very high in all others
Data sufficiently standardized across the data base to
facilitate searching
Data are available within six months
Both the data and the forms are available on an ongoing
basis
Operational Requirements
Alternative can be implemented within projected resources
All participants in the alternative are committed*
Data ownership issues do not negatively affect the ability to
compile the national data base
Significant increases in reporting requirements can be
handled by the alternative*
There are six criteria considered to be "fatal" criteria. All legislative
requirements are considered to be fatal because failure to meet any of the
requirements would keep EPA from meeting its legal obligations. Participant
interest is considered fatal because if any participant required by an approach is
not committed, then implementation of that approach will not be. feasible. The
ability to expand to handle increased reporting requirements is also considered
fatal because the likelihood that TRI reporting requirements will be expanded
over the next five years is very high. If any of the alternative approaches cannot
be expanded, then this approach will not be feasible over time. Therefore, it is
not efficient to implement a new approach for the very short term.
Alternative Approaches
Four alternative approaches were defined and analyzed against the
criteria. These alternatives include:
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Executive Summary
Centralized (Status Quo) - the current system where EPA receives
forms from industry, enters data, performs all quality assurance
(i.e., identifies both data entry and reporter errors), and makes the
data available to the public. This alternative also assumes the
potential addition, in the short-term, of image processing and/or
optical character recognition (OCR) technologies.
State-Based - all states would be responsible for all activities that
EPA performs in the status quo. The states would then upload the
data to EPA's mainframe; no additional data quality checks would
be done on the national data base
State Entry with Centralized Quality Assurance - all states would
be responsible for entering and verifying data entry accuracy. EPA
would perform additional quality assurance checks on the data to
ensure standardization of the data and to identify reporter errors.
Hybrid - interested states would perform data entry and
verification, and EPA would do data entry and verification for the
remaining states. EPA would also be responsible for all quality
assurance on the national data base as in the previous alternative.
These alternatives were then evaluated relative to the feasibility criteria.
Evaluation
Each alternative was first evaluated relative to the fatal criteria to
determine if the alternative would allow legal requirements to be met and if it
was implementable. At this point in the analysis, no attempt was made to
determine which alternative best satisfied each criterion. Rather, each alternative
was evaluated to see if it satisfied a fatal criterion to any degree. This analysis is
summarized in the graphic on the following page.
vii Feasibility Analysis
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Executive Summary
Exhibit i-1
Status Quo
State-Based
State Entry with
Centralized
Quality
Assurance
Hybrid
- indicates that alternative satisfies fatal criterion
Two alternatives - state-based and state entry with centralized quality
assurance - were eliminated because both of these alternatives do not satisfy
three critical fatal criteria. The two remaining alternatives - status quo and
hybrid - were assessed against the 12 established criteria. These alternatives
received one of three ratings relative to each criterion:
Does not meet the criterion
Moderately satisfies the criterion
Fully satisfies the criterion.
This analysis is summarized in the chart on the following page.
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vin
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Executive Summary
Exhibit i-2
Jj Does not satisfy criterion
Moderately satisfies criterion
Fully satisfies criterion
Because of the ability of the status quo approach to fully satisfy over 80%
of the criteria, it clearly remains a strong approach. The hybrid approach is
almost split evenly between criteria that it fully satisfies and those that it
moderately satisfies.
Recommendations
Both of the two alternatives that satisfied all of the fatal criteria status
quo and the hybrid approach are able to satisfy all legislative requirements.
However, the status quo is able to meet a wider range of user expectations,
including EPA's ongoing need to access the data and forms for enforcement
purposes, industry and environmental groups' needs for accuracy, and other
users demands for sufficient standardization to perform useful searches on the
data base. The hybrid approach offers the potential to meet some of the user
needs, but not to the extent that the status quo does. Additionally, the status quo
better ensures operational success because data ownership issues do not have the
potential to introduce additional delays or problems with producing the national
data base into the process.
Therefore, the status quo is the most feasible means of continuing to
produce the TRI data base, so that it meets all legal and most user requirements.
Additionally, planned technological improvements in the status quo approach
have the potential to strengthen further the current approach's ability to meet all
user requirements.
However, because the states are a critical partner in environmental
protection, and EPA wishes to continue to increase its involvement with the
states, there are opportunities for improving state involvement with TRI. These
ix Feasibility Analysis
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Executive Summary
opportunities range from involving the state more in the current process in roles,
such as quality control, to further investigating the feasibility of involving
committed states in the data entry and verification process. Additional research
into the hybrid approach may reveal that the benefits of state involvement
outweigh any potential difficulties or loss in ability to meet other requirements,
making this a worthwhile approach to pursue. However, if other user
requirements cannot be met in a reasonable manner as is indicated by this
analysis, then the hybrid approach should not be pursued because TRI has an
extensive user base, and each user is a valuable partner in environmental
protection.
Feasibility Analysis
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I. Introduction
This chapter provides background information on the Toxics Release
Inventory, including a summary of reporting requirements and a high-level
description of TRI operations. This chapter also explains the impetus and
purpose of the study, and Booz* Allen & Hamilton Inc.'s approach to performing
the study.
Background
The 1987 Toxics Release Inventory was mandated by the "Emergency
Planning and Community Right-to-Know-Act" (EPCRA) enacted by Congress in
October of 1986. This law, also known as Title III of the Superfund Amendments
and Reauthorization Act (SARA), is based on the premise that citizens have a
"right-to-know" about toxic chemicals in their communities, and has two main
purposes:
To encourage planning for response to chemical accidents
To provide the public and the government with information about
possible chemical hazards in their communities.
The law requires that EPA make this inventory available to the public in a
computer data base. In addition, it requires states to establish State Emergency
Response Commissions and Local Emergency Planning Committees to collect
detailed information on local manufacturers.
Current Legislative Mandate
The original EPCRA law requires all facilities in the manufacturing sector
- Standard Industrial Codes (SIC) 20 through 39 - that have ten or more full-time
employees to report if, during the calendar year, they:
Manufacture, import, or process 25,000 pounds or more of one or
more of over 320 chemicals
Use 10,000 pounds or more of a listed chemical.
These reports must be submitted no later than July 1 of the following calendar
year.
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Introduction
Congress derived the original chemical list from lists of toxic chemicals
developed Tor New Jersey's and Maryland's community right-to-know programs.
Maryland's list included chemicals subject to other federal environmental
programs and chemicals known to be likely carcinogens. New Jersey listed
chemicals that were used or imported into the state and/or the United States in
excess of 10,000 pounds per year and those known to cause cancer and other
adverse health effects.
Facilities that meet these reporting requirements must submit a report for
each chemical. Since reporting is based on chemical production or use, reports
must be submitted even if no releases are estimated or if the emissions level
complies with all federal environmental laws and permits. Information the
facilities must report includes the:
Maximum amount of chemicals on site during the year
Purposes for which the chemical was used
Steps taken to treat the waste.
Additionally, new pollution prevention requirements have increased the number
of data elements. The increase expands the number of data elements required to
be reported by approximately 30. For the RY90 form, approximately 60 data
elements on average were entered into TRI, compared to the RY91 form which
has a total of 90 data elements.
Future Regulations
TRI is the first government program mandated by Congress to make
information available to the public via telecommunications. As a result of this
mandate and the interest in the Form R data, TRI has received extensive attention
from a diverse group of organizations and individuals, including environmental
groups, members of industry, individual citizens, and other government
organizations. This attention is continuing to grow as the public asks for access
to additional environmental data.
This momentum may result in additional reporting requirements for TRI.
For example, EPA is considering requiring additional industries, such as federal
facilities, mining, agriculture, or utility companies to comply with the reporting
regulations of EPCRA, and/or to require the reporting of additional chemicals.
In addition, various versions of the Community-Right-To-Know-More Act are
under consideration, which, if passed, will significantly increase the number of
facilities required to report, the number of chemicals listed, and data elements to
be maintained in TRI. As reporting requirements change and the number of
reporting facilities and chemicals increase, EPA must be capable of responding to
this additional volume and complexity.
Feasibility Analysis 2
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Introduction
Current Process
The process by which data are received and entered into the TRI database is
summarized below and in Exhibit 1-1.
Exhibit 1-1
Required Section 313 Reporting
Industries throughout the U.S.
£«CD«t»
Entry LAW
EPA Processing
NeiiBMl tat* Pmratlne
- . fu. >-| ,
IMVlWQfl
H»««»reh Triwifll* Pmrk,
Annual
tiii
Data to
Public
ot
Date Reconciliation
Resolution of l*sue« ol
noncompliance and technical
errors with Industries
Electronic
Public
Access
The process has five main components:
Industry submits Form Rs, containing the required reporting
information, to the EPCRA Reporting Center (ERC) where they are
processed and entered into a Local Area Network (LAN) data base.
A sample of this data from the LAN data base is then verified
against the original form for accuracy.
Records from the LAN database are periodically uploaded to EPA's
mainframe computer, which is an ADABAS database, located at the
National Data Processing Division in Research Triangle Park (RTP),
N.C.
ERC staff use terminals connected to the mainframe to run data
reconciliation procedures. This involves running data quality
reports that assist with analyzing the data for reporter and data
entry accuracy, correcting records in the database, and
Feasibility Analysis
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Introduction
standardizing data (such as parent company names) across the
database.
Submitting facilities are contacted, when necessary, by EPA and
ERC staff to notify them of noncompliance with the regulation and
to resolve technical errors in the data.
Data are transferred to the National Library of Medicine (NLM) in
segments of approximately 20,000 records each after the data
quality/reconciliation process has been completed for each section.
NLM indexes and loads the data on TOXNET. Data is also
available in Depository Libraries across the country on various
other media such as CD-ROM, diskette, magnetic tape and through
the National Report and other publications. The hard copy forms
for the current year are available for review by the public as soon as
the data is entered into the network.
Responsibility for operation of TRI has been primarily delegated to two divisions
within EPA's Office of Pollution Prevention and Toxics (OPPT), the Information
Management Division (IMD) and the Economics and Technology Division (ETD),
although other divisions also play a role in outreach, analysis, and other areas.
IMD has the responsibility for data management implementation and operations
while ETD is responsible for overall program guidance, regulation development,
and regulatory interpretation.
States also play a role in TRI. Some states currently operate their own
systems, which they use to fulfill public requests for data or to perform data
analysis for their own usage. In addition, EPA often works with states to verify
that the TRI data maintained at Headquarters are the most accurate. Selected
states have received grants from EPA to perform data quality checks on their
state's subset of the national data. At present, however, no states perform data
entry for the national TRI data base.
Purpose and Approach
Because of the increased volume of TRI data to be processed and the
demands from users to have access to the data more quickly, EPA is considering
alternative data entry and management approaches. Because several states have
indicated interest in performing TRI data entry at the state level, EPA has
conducted a study to determine the feasibility of state data entry for TRI through
an examination of:
The benefits, costs, and management issues raised by decentralized
TRI data management approaches
Feasibility Analysis
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Introduction
The logistical activities which would need to take place for such an
approach to succeed.
In order to obtain the information necessary to evaluate the feasibility of moving
to a system based solely or partially on entry of data at the state level, a series of
interviews were conducted with:
EPA Headquarters and Regional personnel involved with TRI
State personnel involved with TRI
System managers, state, and Regional personnel involved with two
other EPA data bases using a state data entry approach.
This data collection was based on structured interview guides that were
administered through face-to-face and telephone interviews. A copy of the
interview guides and a list of interviewees are included in Appendix A and
Appendix B of this document.
The information obtained in these interviews is used in the feasibility
study to address the following issues:
Definition of Agency and other user requirements for performance
of the TRI system
Description of the characteristics of other EPA data bases using
state data entry as an input process
Definition of alternative approaches using decentralized data entry
Definition of criteria to evaluate alternative approaches
High level analyses of each of these alternatives, including the costs
and benefits
Recommendations as to the most appropriate approaches to pursue
and the activities that must be implemented to ensure the
approaches are successful.
By addressing these issues this study will assess the overall feasibility of TRI
being based solely or partially on entry of data at a state level.
Feasibility Analysis
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II. Characteristics of Existing Data Bases
Using State Data Entry Approach
The operations of two existing EPA data bases the Biennial Reporting
System (BRS) and the Aerometric Information Retrieval System (AIRS) that
currently rely on data entry at the state level were examined. Although neither
of these data bases share all of the unique requirements of the TRI program, they
provide a useful point of reference for the implementation and operation of state-
based data entry approaches. The rest of this chapter briefly describes these two
systems, their performance, and any issues relevant to the potential advantages
and disadvantages of a state data entry approach for TRI.
BRS
BRS, which is sponsored by EPA's Office of Solid Waste (OSW), supports
the Resource Conservation and Recovery Act (RCRA) program. A reporting
requirement for hazardous waste generators and waste treatment, storage, and
disposal facilities was included in the May 19,1980, promulgation of RCRA
regulations. In the initial years following the promulgation of these regulations,
the reporting requirements were suspended due to a lack of information
management capabilities at OSW and Office of Management and Budget (OMB)
concerns about RCRA paperwork burdens. OSW initiated a number of mail,
telephone, and site visit surveys during this period designed to help characterize
handlers of hazardous wastes. As a result of discussions with environmental
groups and states, EPA agreed to administer a biennial report for hazardous
waste generators and receivers beginning in 1983.
Purpose
BRS describes the demographics of hazardous waste generation and
management through the tracking of trends in capacity and waste minimization
information. Hazardous waste generators and receivers are required to report on
what wastes they generated and how they disposed of them. Waste generators
also report on pollution prevention activities. The resulting data are intended to
provide an overview of the progress of the RCRA program.
BRS data are primarily used internally by EPA and the states. EPA
Headquarters personnel use the data to support RCRA regulation development.
The 1986 amendments to SARA required states to certify that they have the
capacity to handle the wastes generated within their states, either internally or
through agreements with other states. The BRS data provide key support to
Feasibility Analysis 7
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Data Base Characteristics
these state efforts by quantifying the capacity of waste treatment, storage, and
disposal facilities.
The program does not currently have a strong public access focus. The
public cannot directly access the data base, either in hard copy or electronic form.
Freedom of Information Act (FOIA) requests are currently the only means for the
public to obtain the data, although OSW plans to eventually make the
information available through the National Technical Information Service (NTIS).
Similarities and Differences with TRI
The BRS program has both similarities and differences with the TRI
program. The two programs are approximately comparable in terms of the
number of reporting facilities. There is also some overlap between the two
programs; approximately 10,000 BRS waste generators are also TRI reporters.
Both programs also involve data that are facility-reported, rather than monitored
by the government.
TRI has a standard reporting Form R, whose format must be followed
whether facilities file on hard copy or electronically. For BRS, reporting on the
Federal form is not required, so many different forms and formats are used. The
BRS program defines the data elements, and states collect the data how they
want. About 20 states use the official EPA form.
The BRS program also has more complex reporting requirements,
involving a greater number of data elements and many complex technical issues.
BRS also differs from TRI because the original legislation called for only a few
data elements, which were subsequently deemed to be insufficient for program
management. The data elements were expanded somewhat in the draft rule, but
additional data needs have been identified since that time. However, a final rule
has not been promulgated, leaving EPA with no actual authority to enforce the
submission of data that were not included in the draft rule, such as facility-level
data.
TRI is currently a Federal program. Conversely, BRS is largely a delegated
program, with much of the responsibility in the hands of the states and the
Regions. Approximately 35 to 40 states have RCRA authority delegated to them;
BRS efforts for the remaining states are managed by their Regions.
Process
The regulated community provides their data every two years, to either
the state or the Region, as appropriate. Reporting forms are due to the states and
Regions on March 1 of the reporting years. As noted above, many different
reporting forms and formats are used; some states combine the BRS data
Feasibility Analysis 8
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Data Base Characteristics
collection with other data collection efforts. The states and Regions handle all
data entry.
Prior to 1987, after receiving the individual submissions from each facility,
the states and Regions compiled the results and sent aggregated data to EPA.
Beginning in 1987, a decision was made by OSW to attempt to develop a facility-
level BRS data base, so states and Regions were asked to provide facility-level
data. However, EPA had no authority to enforce this request, since facility-level
data were not included in the draft rule.
Once the states and Regions have prepared the data, they are
electronically uploaded to the Headquarters system. The uploading software
includes data quality checks that allow the exporting of only those records that
have valid entries in each field. Additional data quality checks for consistency
are performed at the Headquarters level.
Performance
With regard to timeliness, BRS has not had strong success. The reports are
due to the states and the Regions on March 1 of each reporting year. The original
plan was for the states and Regions to have the period from March to September
to process the data and to submit it to Headquarters, which would then have the
national data base available by December or January.
This schedule has not yet been met. The 1987 data were released in 1990,
and the 1989 data have not yet been released, partly because some states still
have not submitted their 1989 data to EPA.2
Much of the reason for the delays in releasing the data have been due to
problems with data quality. Headquarters has defined data quality standards for
each individual data element by defining valid entries. As noted above, records
cannot be exported from the states and Regions into the Headquarters files if any
elements fail this data quality check.
However, other significant data quality problems exist, primarily relating
to reporter errors and non-responses. For example, Headquarters had to
abandon its goal of producing a facility-level national data base for the 1987
reporting year due to the failure of many states to provide these non-mandated
data. As documented in the report on the 1987 implementation of the BRS
reporting program, many other problems exist relating to low response rates for
specific data elements, invalid entries, and entries that are logically inconsistent
2 In contrast, the 1989 national data set for TRI, received July 1,1990, was made available to the
public in May, 1991.
9 Feasibility Analysis
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Data Base Characteristics
with other information reported.3 There is a significant amount of confusion
among reporting facilities concerning technical aspects of particular data
elements that results in erroneous entries. As discussed in the 1987 evaluation,
any reporter problems that exist are compounded by the fact that most states
devote few resources to data quality follow-up with facilities.
Perceived Advantages and Disadvantages of State Data Entry Approach
Several difficulties have made the implementation of a state-based data
entry program difficult, as summarized below:
State commitment States have received limited grant money
from EPA Headquarters for BRS programs. This has provided
them with weak incentives to cooperate or to expend efforts on
what is essentially seen as a Headquarters data base. States tend to
focus the resources that they do have on the specific data elements
that they need, such as those relating to capacity certification. This
is a consideration that should be accounted for in any program
involving state data entry. A lack of funding and/or a lack of state-
related incentives for performing the effort will affect the quality of
the program.
Reporting standards Legal reporting requirements for BRS have
been extremely limited, making it difficult for EPA to enforce
reporting standards. The agency, however, is currently taking
steps to address this issue. States have historically used a variety of
reporting cycles and reporting forms. Thus, not all 1989 BRS data
may really be for calendar year 1989, and, as noted, states often
collect their own data elements. In any state-based program, efforts
to enforce data processing and submission of specific data elements
may be difficult.
Management commitment Efforts to implement BRS,
particularly in the early years, were hampered by the lack of a
strong management commitment from Headquarters. This
situation has been reflected in the lack of resources provided, in the
form of insufficient numbers of Headquarters and Regional staff to
manage the reporting program. This situation improved somewhat
after 1987, when a major effort was made to reexamine the role of
BRS and to improve its operations. TRI has had a strong
management commitment at Headquarters since its inception. A
continued commitment would be necessary if a state-based data
entry approach were adopted.
3The 1987 Biennial Report Forms Evaluation. Information Management Staff, Office of Solid
Waste, Environmental Protection Agency, March 20,1989.
Feasibility Analysis 10
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Data Base Characteristics
Some advantages to the state-based approach used by BRS do exist. In
particular, the report evaluating the implementation of the 1987 BRS reporting
process noted that state personnel generally have knowledge of individual
facility operations that allows them to more easily identify errors or omissions in
the reported information (resources permitting) than EPA Headquarters.
AIRS
AIRS, which is sponsored by the Office of Air and Radiation (OAR),
directly supports the air data needs of EPA and state agencies to meet
requirements of Title I, III, V, and VII of the 1990 Clean Air Act. AIRS is EPA's
national repository for ambient air concentration and point-source emission data
within the United States. AIRS stores data from more than 10,000 ambient air
quality monitors and 50,000 plants. Data are collected from all 50 states, and
monitoring is required for the criteria pollutants based on such factors as
population, pollutant sources, and geographic area. Point sources emitting more
than 100 tons per year of any criteria pollutant (except 5 tons per year for lead
and 1,000 tons per year for carbon monoxide) must report actual or estimated
annual emissions data. Emissions data is gathered from the facilities through
surveys that each state (or local agency) develops. AIRS is comprised of four
subsystems:
Air Quality Subsystem (AQS) contains measurements of ambient
concentrations of air pollutants and associated meteorological data.
AQS contains the data from the old SAROAD (Storage and
Retrieval of Aerometric Data) system.
Air Facility Subsystem (AFS) contains aerometric emissions and
regulatory compliance data on air pollution point sources tracked
by the EPA and state and local regulatory agencies. AFS merges
the data from old CDS (Compliance Data System) and NEDS
(National Emissions Data System).
Area/Mobile Source (AMS) Subsystem contains estimates of area-
wide emissions from mobile sources, forest fires, fugitives,
transport, and other large-scale point emissions sources.
Geo-Common Subsystem (GCS) contains reference information
that is used with all of the AIRS subsystems. Reference information
includes codes to identify places, pollutants, and processes.
Since data in TRI are facility based, as are data in AFS, this study focused
particular attention on that subsystem. Although AFS is not exactly identical to
TRI in structure, it does provide the best available means for comparison.
11 Feasibility Analysis
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Data Base Characteristics
Purpose
AFS is used by EPA Headquarters and Regions in various means,
including as a tool to assist in the estimation of total national emissions. State
and local agencies utilize the data as well. States use the data to prepare State
Implementation Plans to comply with regulatory programs. In addition,
industries, public interest groups, and academia request the information in AIRS
via the FOIA process. However, the public does not yet access AIRS on-line.
Standard reports are produced using AFS data. These reports include Plant
Compliance Summary, Emissions by SIC code, and Distribution of Emissions.
These reports, which were developed to respond to recurring FOIA requests for
that type of information, are available on-line or through the FOIA process.
Similarities and Differences with TRI
TRI has both similarities and differences with AIRS. For example, both
systems have automated edit checks used in data quality procedures. In
addition, some AIRS data are facility reported, and some overlap also exists in
terms of the air toxics data maintained in each system. The following are
differences between AIR and TRI:
AIRS is a state delegated program. TRI is not.
AIRS tends to be chemical class specific (e.g., volatile organic
compounds), while TRI focuses on individual chemicals.
Regional offices are active with AIRS, and assist with quality
assurance. TRI has limited Regional involvement.
AIRS does not currently allow direct public access. Public on-line
access drives TRI and is Congressionally mandated.
Data in AIRS do not receive the same level of quality assurance
across all fields as TRI data do. AIRS managers are confident about
the accuracy of data in some fields, but concerned with the data in
others. TRI managers are certain about the data quality levels in all
of their data.
All data in AIRS are not facility reported. Some data are measures
of state activity with respect to inspections and enforcement
actions. Other data supplied by the states are listings of permitted
amounts, not measures of emissions, etc. All TRI data are facility
reported.
Feasibility Analysis 12
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Data Base Characteristics
Some data elements in AIRS allow two entries, one for federal and
one for the state version. TRI stores only one set of data received
from facilities, with certain limited fields for EPA-supplied data.
Process
Emissions data that are gathered from the facilities by state and local
agencies are entered by state or Regional staff. Data entry approaches vary from
state to state depending on the available resources and personnel. For example,
some states do direct on-line entry (approximately 20), while other states use
their own systems to create a tape which is then converted by EPA. Still a limited
number of states submit manual reports to Regional offices where the data are
entered. This occurs if the states are not able to enter the data themselves (i.e.,
insufficient resources) or if they are not interested in doing so. AIRS is then
updated nightly.
While conducting data entry, states and Regions are supposed to adhere
to established coding conventions. States are also required to develop QA/QC
plans for ozone data. In order to ensure that quality control procedures were
followed, AIRS has automated edit checks and verification is performed on
selected data. EPA provides ongoing training to assist states in data entry. In
addition, states are partially funded by EPA grants to perform data entry and
quality control procedures.
Performance
AIRS experiences problems with timeliness of the data for various
reasons, including problems associated with conversion of the data. In addition,
states are often slow in submitting their data to EPA. Because of limited
resources and varying priorities at the state level, AIRS data entry can take a
lower priority for states. In many cases, the latest set of data in AIRS is not from
the most recent year.
AIRS also has difficulty in producing a complete and accurate data set.
There are coordination problems with the states and EPA as to what is required
to be reported, and at what data quality level. Although AIRS managers are
confident about the accuracy of data in the fields that are most frequently used,
they are concerned with the quality of the less frequently used data. States do
not always adhere to coding conventions, and they often lack the appropriate
resources to perform adequate data quality checks and even though there are
edit checks built into the system, they do not check for all types of error. For
example, there are no edits to check data against the previous year's submissions
to detect any inconsistencies with the data that was reported in previous years.
This edit check is the responsibility of the state or appropriate Region. Also,
13 Feasibility Analysis
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Data Base Characteristics
some states submit permit data rather than actual emissions data, and EPA may
not be made aware of this.
Perceived Advantages and Disadvantages of State Data Entry Approach
The following are the benefits of a state-based data entry approach for
AIRS:
Data entry for data sets of states actively participating in AFS is
often accomplished more quickly than by the Regional entry
approach.
This approach encourages states to have a stake in AIRS
States are more knowledgeable about certain facilities than EPA
staff, and facility-level data quality could possibly increase because
of this familiarity.
The following are difficulties that have made the implementation of state-
based data entry for AFS difficult:
EPA has difficulty in obtaining all of the necessary data elements
from the states, and consequently has some incomplete data sets.
Data conversion from state tapes often introduces difficulties that
require additional time and money to resolve.
Some states lack the resources to adequately perform quality
assurance procedures, and consequently data quality suffers in
some instances.
There is no specific time frame during which states must enter and
submit data to EPA. As a result, many states perform data entry
only when they are able. For example, some 1989 data have still
not been submitted to. EPA.
BRS and AIRS Conclusions
Through examining these two data bases that rely on data entry at the
state level, the benefits and problems associated with this type of data
management system can clearly be recognized. Although these two systems are
not identical to TRI, they are similar enough to serve as a useful tool for
evaluating the feasibility of a system based on state data entry for TRI. One
important difference between these two systems and TRI is that these systems
support state-delegated programs where states are primary users of the data.
Feasibility Analysis 5
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Data Base Characteristics
TRI, however, is not a state delegated program, and does not possess the more
formal state, Regional, and Headquarters relationships upon which these two
systems depend. Another major difference is that EPA is required to compile
and make available a national set of data for TRI, whereas AIRS and BRS are not
required to do so.
An obvious benefit of this approach for both BRS and AIRS is that the
states are more knowledgeable about the facilities than EPA staff, and could
recognize and resolve problems with the data submitted by facilities more
quickly. Data entry can also be accomplished more quickly by the individual
states if they are active participants, rather than by a centralized system entering
all the data. However, if a significant number of states do not participate in the
data entry process or submit only selected data elements, this requires additional
time and resources for EPA to enter the data for the state.
Coordinating with the states is clearly a challenge with both systems.
Additional time and resources are required in data conversion if states perform
data entry, and do not utilize the appropriate conversion software or experience
other problems with conversion. States do not always adhere to the coding
conventions and standards for data entry, and consequently data quality suffers.
Data quality is also affected when states do not have sufficient resources to
adequately perform data quality checks. Also, EPA has, at times, not received all
the data that it needs for national purposes because the states are focused on
collecting and entering data that support their own needs.
As can be seen, there are benefits to performing data entry at the state
level, but there are also significant problems. Although the problems associated
with this approach may not severely affect the overall performance of these two
systems, it is necessary to evaluate these problems with respect to the unique
requirements of TRI to determine the feasibility of this approach for TRI.
15 Feasibility Analysis
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IIL State and Regional Interviews
In order to obtain the information necessary to evaluate the feasibility of
moving to a decentralized system of data entry, a series of interviews were
conducted with state and Regional personnel involved with TRI. These
interviews were administered through face-to-face and telephone interviews.
The interview guides and a list of interviewees are included in the appendices of
this document. Also, a matrix summarizing the results of the state interviews is
contained in Appendix C.
This chapter summarizes information obtained during the state
interviews, including the varying capabilities of the different states, and the
ability and interest of the states in performing data entry for TRI. The chapter
also discusses the Regional offices' feedback on the role they should play in this
process.
State Interviews
Face-to-face interviews were conducted with personnel from states that
currently enter a significant number of TRI data elements themselves, as well as
states that do not. These states included:4
Georgia (enters data)
California (enters data)
Texas (does not enter)
North Carolina (does not enter)
Indiana (does not enter).
Interviews were also conducted with personnel from states that
participate in the Forum on State and Tribal Toxics Action (FOSTTA). This
organization is intended to foster an exchange of information on toxics-related
issues between the states, territories, tribes, and EPA. The following states
requested telephone interviews based upon a presentation on this study given at
a FOSTTA meeting:
Kansas
Maryland
Utah
Ohio.
4 OPPT management selected these states based upon results of the FOSTTA survey and
indications of interest from the states.
Feasibility Analysis 27
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State and Regional Interviews
Motivational Factors for States Performing Data Entry
Many factors were identified as providing an incentive for states to
perform data entry. Included in these motivating factors was the desire to have
the data available at an earlier date than is now available through NLM.5 Many
states also believe that NLM is difficult to use, and even when data are made
available to states through NLM, they still require a significant amount of time to
manipulate the data so that they can be used. Although many states voiced a
desire for earlier availability of data, some are not currently performing analysis
or using the data in such a way that necessitates earlier availability of data.
Other states identified the need to have the data earlier to respond to inquiries
from the public about TRI data.
Other states perform, or would like to perform data entry at a state level
because they believe they can obtain higher submitter data accuracy than the
federal system . They believe that they are more familiar with the facilities,
therefore, they would be able to detect problems with the data more easily than
EPA. Most states, however, did not perform data normalization or data
verification checks as thoroughly as is currently done at the federal level. Their
efforts are focused on ensuring the accuracy of data entry.
Still other states perform data entry because they want to have greater
control or ownership of the data, and to be able to incorporate revisions more
easily. States also track administrative information for fee programs and
therefore need to enter the data to track these fees.
States that enter data currently are committed to continuing with state
data entry, and others without systems are already planning to go forward with
developing programs. Many other states that did not have systems indicated
interest, but cited inadequate resources to develop their own system. Some of
the states that rely upon the national database stated that although they are very
interested in TRI data that the data are not currently of sufficiently high priority
within the state to warrant initiating data entry programs.
Data Usage
TRI data are used in various ways by the states, including:
To provide information to the public
To support programs, such as air toxics and pollution prevention.
To develop new management tools, such as emissions inventories
To help identify discrepancies with permits
5 All states currently have access to TRIS as data entry proceeds. In addition, the full data set is
usually available to the states before all data quality activities are finished and before the data set
is made available to NLM.
Feasibility Analysis 18
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State and Regional Interviews
To evaluate health risks
To conduct other analyses.
Usage of TRI data by the states continues to grow and to become more
sophisticated.
Benefits Associated with State Data Entry
The following are what states perceive as being the benefits of state data
entry for the TRI program:
Higher submitter data accuracy because state personnel are more
familiar with their facilities, can recognize errors, and have a vested
interest in correct information
Data available in a more timely manner due to smaller number of
forms
Revisions provided by facilities can be processed and incorporated
more quickly
State entry creates more of a sense of ownership, interest, and usage
by states
State entry reduces duplication of effort and may save resources
States have closer relationships with facilities and could work with
them to reduce reporter errors.
These benefits represent some of the driving forces behind states currently
performing data entry.
Problems Associated with State Data Entry
Although states perceive there to be many benefits associated with state
data entry, they also recognize the challenges to be faced if they are to perform
data entry for TRI. The following are what states perceive as being problems
associated with state data entry:
Limited resources
All states may not buy in
States may have only parochial interests
Compatibility/normalization of data could be challenging
19 Feasibility Analysis
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State and Regional Interviews
States may not be interested in entering all data elements or
conducting extensive quality checks on all elements. States want to
emphasize the elements that they use.
States do not want the data that they enter to be changed at federal
level
Forms are currently being sent to two places; difficult to ensure that
all forms and revisions are entered and to monitor when they are
entered.
It was indicated by states that these problems must be evaluated and resolved
before a decentralized data entry system could function most efficiently.
Regional Interviews
Regional interviews were conducted to correspond with state interviews.
Personnel in the following Regional offices were interviewed to obtain
information on what they perceive as being state data entry issues, benefits, and
problems for TRI:
Region IV
Region V
Region VI
Region IX.
Although Regional staff indicated that they had heard interest from many states
in performing data entry for TRI, they were not certain of the feasibility of
performing this function with the same standards that are currently used at the
federal level.
Benefits
The following are perceived by Regions as being benefits associated with
state data entry for TRI:
States could do data entry more quickly and thus have the data
available to assist with internal programs, such as the 33/50
initiative, air toxics; data would also be available to Regions
quicker
Data quality could improve as states often know their facilities
better than Headquarters.
Feasibility Analysis 20
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State and Regional Interviews
Although Regions recognize the benefits to states performing data entry, they
also recognize the challenges that arise if all states are not committed to
performing data entry.
Problems
Some Regional personnel that were interviewed felt opinion that the
problems associated with state data entry would outweigh the benefits. The
following are perceived by Regions as being problems associated with state data
entry for TRI:
Regions are unsure of the interest, commitment, and capabilities of
all states; all states will not be interested
QA/QC - states do not have as stringent of edit checks as the
national data base
Data normalization - consistency and standardization of data will
be difficult
Funding - almost all states will require funding to do data entry,
which may not be feasible
Community Right-to-Know More requirements could overwhelm
the states if enacted.
Regional Role
The Regional offices felt that they could not play a significant operational
role in a state data entry process because of their lack of access to the forms and
their belief that Headquarters possesses more TRI expertise. However, the
Regions provided the following recommendations with respect to their role:
Involve the Regions in an assistance role when the program is
initiated and as an ongoing liaison
Involve the Regions in administering grants.
Some Regional offices indicated that resources might need to be provided to
Regions to ensure that the right personnel are available to complete these
responsibilities.
21 Feasibility Analysis
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State and Regional Interviews
Conclusion
Both the states and the Regions saw potential benefits of the state data
entry approach, including higher data accuracy, improved timeliness, and an
increased sense of ownership, interest, and usage of TRI data by the states. But
state and Regional interviewees indicated that the extent to which the benefits
would be realized depended upon many factors. One major factor included the
ongoing commitment from states in participating. States currently have a wide
variety of capabilities, interests, and usages of TRI data. Therefore, all states may
not be interested in, and committed to, performing data entry for the long term.
Other states may be interested primarily in fulfilling their needs and not the
broader requirements of a national database. State and Regional interviews
indicated that for decentralization to work effectively, state commitment is a
necessity.
Other factors impacting the success of a state data entry approach
included the availability of resources and the resolution of many logistical
activities that must take place. All states have varying levels of capabilities and
available resources, therefore in most cases funds would need to be allocated
toward ensuring the states have the appropriate hardware, software, and
training to perform data entry. Logistical issues that would need to be resolved
include quality assurance/quality control, data normalization and
standardization, the processing and assignment of document control numbers to
Form Rs, and the revisions to data not only for the current year, but also for
previous years. States and Regions indicated that these factors must be
sufficiently addressed before decentralization is considered feasible. States
strongly emphasized that they needed to participate actively in resolving these
issues to ensure that their needs were met as well as national needs.
Interviewees felt that the Regional offices should participate primarily in
an assistance role, not an operational role. This could involve acting as a liaison
between the states and Headquarters and acting as the administrator of any
grants.
Feasibility Analysis 22
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IV. Definition of Criteria for Feasibility
To evaluate the feasibility of moving from centralized data entry to a
successful decentralized approach for TRI, criteria for the assessment were
defined. These criteria were based upon the assessment of the other systems
using state data entry approaches as well as an in-depth understanding of the
unique requirements and needs of the TRI program and of states capabilities and
interests. These criteria fall into three main categories:
Legislative Requirements
User Requirements
Operational Requirements.
Each of these criteria categories is discussed below.
Legislative Requirements
Section 313 of EPCRA, Title III of the Superfund Amendments and
Reauthorization Act of 1986, defines certain requirements that must be met by
the TRI program. These requirements must be met regardless of the specific
approach that is used for data entry. Each of these requirements is summarized
briefly below:
National data base Section 313 of EPCRA states that, 'The
Administrator shall establish and maintain in a computer data base
a national toxic chemical inventory based on data submitted to the
Administrator under this section." Thus, EPA has a legislatively-
defined responsibility for the development of a national,
computerized TRI data base.
Intended Uses Sections 313(h) of EPCRA states that the TRI data
is "intended to provide information to the Federal, State, and Local
governments and the public, including citizens of communities
surrounding covered facilities." Therefore, EPA must ensure that
the data support these uses.
Publicly accessible on-line Section 313 of EPCRA states that,
"The Administrator shall make these data accessible by computer
telecommunications and other means to any person on a cost
reimbursable basis." Thus, EPA has a legislatively-defined
responsibility for making the TRI data base available on-line and
otherwise accessible.
Feasibility Analysis 23
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Feasibility Criteria
Required data elements Section 313 also requires EPA to
develop a "uniform toxic chemical release form" for facilities
covered by the legislation. The law also identifies certain data
elements that must be reported:
Name, location, and principal business activities of the
facility
An appropriate certification of the accuracy and
completeness of the report, signed by a senior official
Whether each listed toxic chemical present at the facility is
manufactured, processed, or otherwise used, and the general
category or categories of use of the chemical
An estimate of the maximum amounts of each toxic chemical
present at the facility at any time during the year
The annual quantity of each toxic chemical entering each
environmental medium
For each waste stream, the waste treatment or disposal
methods employed, and an estimate of the treatment
efficiency typically achieved by such methods for that waste
stream.
These reporting requirements have since been supplemented by the
Pollution Prevention Act of 1990. Section 313 also defines which
industries are subject to TRI reporting, and the threshold limits for
releases of listed toxic chemicals.
User Requirements
Because TRI user groups utilize the data in many ways they hold varying
expectations with respect to TRI. As these users have begun utilizing TRI data
in more sophisticated analysis, this has increased user requirements in many
areas. These expectations are discussed below in terms of accuracy, timeliness,
ongoing availability of the present and past years' data and forms, and
standardization of the data. As these expectations are interrelated, they are
presented in terms of which criteria a particular group prioritizes and on which
they would like EPA to focus its efforts.
Feasibility Analysis 24
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Feasibility Criteria
Accuracy
The TRI user community, in general, expects the data to be of the highest
quality. Users expect data quality to be near 100% accuracy for certain key data
fields, particularly those fields that characterize chemical releases, and high
accuracy in all other fields as well. A data management process that would
ensure near 100% accuracy in critical fields and high accuracy in others would
satisfy this criterion. The following provides examples of why this level of
accuracy is important to users.
Industries are most interested in the accuracy of TRI data because
incorrect data can have negative impacts on business. For example,
if a release value is either incorrectly reported or entered
inaccurately, a facility can receive negative publicity or even
potentially be subject to litigation.
EPA's enforcement authorities place high emphasis on data quality
for similar reasons. EPA needs high quality data in order to
perform effective enforcement. If they use data that are incorrect,
they could possibly take enforcement action against industries that
are in compliance.
The scientific community uses TRI data to assist with
environmental analyses, so that scientists can understand the
environmental quality of a particular area and identify measures
that can be taken to improve the quality. Therefore, the scientific
community is most interested in high quality data to ensure that
environmental problems can be accurately characterized and
addressed.
Most environmental groups emphasize the importance of retaining
the present high level of data accuracy. However, these groups also
understand that the data are self-reported by facilities and
recognize that regardless of the effort EPA places on ensuring data
entry accuracy, there may be errors in the data resulting from
inaccurate reporting by the facilities.
Ongoing Availability
Expectations of the TRI user community include that the data and the
original Form Rs must be consistently available and accessible over time. TRI
data are often used in trend analysis, so it is crucial that TRI data be available, not
only for the present year, but also for preceding years. Therefore, data and Form
Rs must be available on an ongoing basis in order to satisfy availability
expectations.
25 Feasibility Analysis
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Feasibility Criteria
EPA is concerned with the availability of the data and the Form R for
enforcement and other activities. To support development of a case for legal
action, EPA must have the original Form R that was submitted by the facility. In
addition, EPA must have access to the data and the Form R not only for the
current year, but must also have access for the previous years. Therefore, EPA
enforcement offices place high emphasis on the availability of the data and the
original Form R. Additionally, EPA uses hard copies of forms to verify data base
accuracy when anomalies are found in trends.
Timeliness
The TRI user community emphasizes the need to receive data in a timely
manner. Expectations from the environmental community and other users for
the release of data to the public through the National Library of Medicine (NLM)
range from one to six months after the July 1 reporting deadline with the average
expectation being approximately six months. While other users (including EPA)
would clearly like the data to be available as soon as possible, they find the
current 10 to 11 month delivery cycle to be satisfactory. Therefore, to meet this
criterion to satisfy user timeliness requirements the data ideally would be made
available within six months.
Environmental groups tend to prioritize timeliness. They are very
interested in having access to TRI data as soon after the reporting deadline as
possible. TRI staff indicate that specific expectations they have heard from
environmental groups for the release of data range from one to six months.
Some states maintain data bases of the TRI data for their individual state,
although few states enter all TRI data. Other states do not have TRI data
management programs and, therefore, rely upon EPA to provide the data. As
with environmental groups, state government environmental organizations
prioritize timeliness. They are interested in being able to access the data soon
after the reporting deadline to assist with tracking and regulating toxic chemical
emissions, enforcing environmental programs, and responding to public
requests.
Standardization
The TRI public data base is accessed by various users groups, including
industry, private citizens, media, public interest groups, and the federal
government. These users are highly concerned with standardization of data.
Standardization of data refers to the way in which data are entered into the
system. In order to perform effective searches, the data being entered into the
system (e.g., parent company name or address) must correspond with the name
and address already in the system. For example, the name "Dupont" may be
Feasibility Analysis 26
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Feasibility Criteria
entered on one form, while "Du Pont, Inc." is entered on a second. When a search
is performed on this data, all relevant records may not be retrieved. Therefore, in
order to meet the user requirements for standardization the data must be
compatible throughout the entire system across all states so that users can
successfully search for data, and perform meaningful analysis on a national basis
(i.e., be able to retrieve information on all Du Pont facilities without having to
search using a variety of names).
Operational Requirements
These criteria measure the operational feasibility of the particular
alternative or the ease with which an alternative can be implemented. The four
criteria that fall into this category are discussed below.
Resource Availability
This criterion measures the extent to which implementation of the
particular data entry approach is feasible within projected resources. Resources
include both the personnel that will be needed as well as the funding required
for equipment, training, and any other activities necessary to ensure successful
entry and maintenance of the TRI data. An approach that can be implemented
within the constraints of projected federal and state personnel and funding
availability will be considered to meet this criterion. This will be assessed at a
high level, meaning that options which clearly would require more resources
than are projected to be available will be considered to not satisfy this criterion.
Participant Interest and Commitment
The success of any data entry approach depends on the interest and
commitment of the participants, namely Headquarters, the Regions, and the
states or U.S. territories. Therefore, all alternative approaches will be evaluated
based upon the interest and continued commitment from potential participants.
Commitment will be measured in terms of the interest of the senior management
of the organization in allocating time and resources to accomplishing entry of
TRI data. This interest and commitment will be assessed, to the extent possible,
in an ongoing framework as TRI data must be entered and made available on an
annual basis.
Data Ownership
EPA is legislatively required to make a national data base available to the
public. Therefore, each approach must be assessed with respect to its ability to
promote aggregation of the data into a national set. Data ownership issues have
the potential to constrain compilation and maintenance of this national set if one
27 Feasibility Analysis
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Feasibility Criteria
organization feels strongly that it owns the data and, therefore, its data cannot be
assessed, corrected, or normalized (e.g., the Du Pont example above) at another
level, such as when the data have been aggregated. Each alternative approach is
rated with respect to the extent to which data ownership issues will negatively
impact development of the national data base.
Reporting Requirement Modifications
Congress and EPA are currently considering adding extra reporting
requirements for TRI. These potential modifications include the following:
Chemical list changes (250 or more additional chemicals)
Standard Industrial Classification (SIC) code expansion (10 or more
additional SIC codes)
Materials accounting data.
In each of these cases, either new types of facilities will be required to report or
existing facilities will be required to submit more data. These modifications have
the potential to add significant numbers of new forms and data elements, which
has serious implications for EPA and the states' or territories' abilities to enter
and make accessible the TRI data. This criterion will measure the extent to which
each alternative approach would be negatively affected by the potential increase
in reporting requirements. An approach which is said to meet this criteria fully
would be sufficiently flexible to handle the current projected increases in
reporting requirements and to adapt to changes in the Form R and the
corresponding data elements.
Fatal Criteria
The graphic on the following page summarizes the criteria that will be
used to evaluate the alternative data entry approaches. Several of the criteria
have been designated as "fatal" criteria. These criteria were so designated
because failure to meet any particular criterion will result in the program not
meeting designated legislative requirements or not being feasible with respect to
implementation of operations. Therefore, the alternative is not viable and should
not be pursued. The remaining, non-fatal criteria define the extent to which the
alternative approaches will satisfy various user expectations and the ease with
which they can be implemented.
In the analysis that follows in this paper, special consideration is given to
issues relating to availability of resources. Although this criterion was not
identified as fatal, cost considerations could represent a significant barrier to the
implementation of a new approach.
Feasibility Analysis 28
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Feasibility Criteria
Exhibit IV-1
0,1
£g
31
VI
ll
ifi
National Data Base
Supports Intended Uses
Accessible Online
Required Data Elements
Timely
Accurate
Standardized
Ongoing
Resource Availability
Participant Interest
Data Ownership
Additional Reporting
Requirements
- indicates that alternative is a fatal criterion
All legislative requirements are considered to be fatal because failure to meet any
of the requirements would keep EPA from meeting its legal obligations.
Participant interest is considered fatal because if any participant required by an
approach is not committed, then implementation of that approach will not be
feasible. The ability to expand to handle increased reporting requirements is also
considered fatal because the likelihood that TRI reporting requirements will be
expanded over the next five years is very high. If any of the alternative
approaches cannot be expanded, then this approach will not be feasible over
time. Therefore, it is not efficient to implement a new approach for the very
short term. These fatal criteria along with the remaining non-fatal criteria will be
used as the basis for the evaluation of alternatives in subsequent chapters.
29
Feasibility Analysis
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This chapter defines four alternative approaches to entering, performing
quality assurance activities, aggregating, and making TRI data available to the
public. These alternatives include:
Centralized (Status Quo)
State-Based
State Entry with Centralized Quality Assurance
Hybrid.
Each of these alternatives is defined below. An evaluation of each with respect to
the feasibility criteria will occur in Chapter VI.
Centralized (Status Quo)
Under the current approach, states play no formal role in the processing of
the TRI data to produce the national data base. Although, as required by law, the
reporting Form Rs are sent by facilities to both the states and the EPCRA
Reporting Center operated by Headquarters, all activities relating to entry,
verification, and quality control of the TRI data to produce the national data base
are performed by Headquarters at a single central location in Washington, D.C.
Some states perform their own data entry and create their own state data bases,
but these data are not the basis for the national data base. Some states do assist
in data quality efforts, based on grants provided by EPA.
Facilities
Exhibit V-l
EPA
«?
Toxics Release
Inventory
EPA produces a national data base that is made available to the public and to the
states in a variety of formats, including on-line access through the National
Library of Medicine's TOXNET and on diskettes.
Feasibility Analysis
31
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Alternative Approaches
The TRI data processing effort managed by Headquarters is a Local Area
Network (LAN)-based data entry system, linking multiple individual PC
workstations. Data entry is primarily a manual process with some of the
submissions on magnetic media. Certain elements of the data verification and
data normalization processes are automated, but manual effort is critical at
various stages for tasks such as comparing data base entries to original hard copy
reports. LAN-entered data are uploaded to EPA's mainframe, where anyone
with access can use the data. All other TRI products are generated from the
mainframe version of the data base.
This alternative also includes the assumption that, even in the short-term,
new technologies, such as imaging and/or optical character recognition, will be
incorporated within the basic framework of the existing process to improve its
ability to handle an increased workload, particularly with respect to data entry
and records management.
State-Based
This approach involves the states (or territories) performing the activities
themselves, including data entry and quality control activities (i.e., identifying
both data entry and reporter errors - verification and reconciliation of data).
Once these activities are completed, the data will then be uploaded into the
national data base maintained on EPA's mainframe. No additional quality
assurance activities will be performed on the national data base. If revisions or
new forms are submitted after the upload, the state will be responsible for
updating the national data base. Therefore in this scenario as illustrated below,
the states will be the primary parties responsible for the TRI data base.
Exhibit V-2
Facilities
States
Toxics Release
Inventory
These states will either use EPA-provided data entry software or will use
their own system and provide a magnetic tape or diskette version to EPA. EPA
will be required to provide data entry software or conversion programs, training,
data entry procedures and standards, and ongoing user support to the states.
Additionally, EPA will still be responsible for performing enforcement activities,
using the national data base, as the delegation of this function is not expected to
occur.
Feasibility Analysis
32
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Alternative Approaches
As access to the forms is a requirement for enforcement activities, the
Agency will need to have access to the same sets of forms that the states have.
This could be approached in one of several manners. EPA could reconcile the
forms that it receives at Headquarters with those maintained by the states.
Alternatively, the forms could be sent to just the states, and the states could then
copy the forms and send them to EPA. Logistical issues relating to the assigning
of Document Control Numbers (DCNs) would need to be resolved.
It is assumed that in this state-based approach EPA will need to provide
funding through grants to those states that require additional resources to
operate the program. These grants will define accuracy and timeliness standards
to which the states should adhere. These standards will be determined in
discussions between EPA and the states.6
State-Based with Centralized Quality Assurance
In this approach, states (or territories) will still be responsible for all data
entry as well as some quality control activities, primarily those involved with
identifying data entry errors through data verification steps. The states will
either use EPA data entry software directly or use their own systems and provide
electronic versions of the data to EPA.
Data quality activities will be performed by EPA on the national data set
once states have uploaded their data. These activities will include some
automated edit checks as well as manual checks to ensure high quality data and
to ensure that the data elements are sufficiently standardized to be useful. The
quality assurance at the centralized level will also include attempts to identify
reporter errors similar to the approach used currently by TRI staff. Enforcement
activities will also remain the responsibility of EPA.
Exhibit V-3
Facilities States EpA
6 EPA in this context is referring primarily to Headquarters EPA and not the Regional offices.
Both Headquarters and Regional interviewees indicated that they did not see a direct role for
EPA's Regions in the data entry and quality control process because the Regions do not have
access to the forms and because they do not have the level of expertise with respect to the TRI
data management process that Headquarters possesses.
33 Feasibility Analysis
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Alternative Approaches
To perform these data quality and enforcement activities, EPA will need
access to the forms. This access will be provided as discussed in the state-based
approach either through obtaining a copy of the state forms or reconciling the
forms received at Headquarters with those received in the states.
It is assumed that EPA will provide funding through grants to those states
that require additional resources to operate the program. These grants will
define accuracy and timeliness standards to which the states will be expected to
adhere as a condition of the grant. These standards will be determined in
discussions between EPA and the states. EPA will also be responsible for
providing data entry or conversion software, procedures, training, and other
support as necessary to the states.
Hybrid Approach
The hybrid approach involves a combination of some elements of the
approaches described previously. In this alternative, those states (or territories)
that are interested in and committed to state data entry will enter data for their
state, perform data entry accuracy checks, and upload the data to the national
system.
Exhibit V-4
States
EPA
Facilities
Data entry under the hybrid method would occur using EPA's data entry
software, or conversion software would be provided. For those states that are
not interested in participating, EPA will be responsible for entering and verifying
their data at a central location. In addition, EPA will perform quality assurance
activities on the national data base, focusing on identifying reporter errors and
Feasibility Analysis
34
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Alternative Approaches
ensuring standardization of data.7 EPA will also retain responsibility for
enforcement activities.
Access to forms will be handled as presented in the state-based and state-
based with centralized quality assurance alternatives. It is also assumed that
EPA will be responsible for providing funding via grants to those states that have
chosen to enter data, developing and providing data entry and conversion
software as well as standards and procedures, and providing ongoing user
support.
Each of these alternatives is evaluated relative to the feasibility criteria in
the following chapter.
7 As the previous footnote indicated, these activities are assumed to be performed by
Headquarters EPA, not Regions due to the lack of access to the forms that Regions currently
experience.
35 Feasibility Analysis
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VI. Analyses of Options and Recommendations
This chapter summarizes the analysis of the four alternative approaches
introduced in the last chapter. The first step in this analysis was to evaluate each
approach against the fatal criteria defined in Chapter III. Based on this analysis,
alternatives that did not meet the fatal criteria were immediately eliminated as
these alternatives were not considered to be viable options for TRI. The
remaining alternatives were then evaluated with respect to all criteria and the
primary benefits and problems associated with each were identified. This
chapter presents these analyses and Booz, Allen's recommendations with respect
to the most appropriate alternatives to pursue.
Criteria Failing to Meet Fatal Factors
Six fatal criteria were defined in Chapter IV. Four of these criteria related
to TRI's legislative requirements:
Need to aggregate data into a national data base
Need to support legislatively mandated uses
Need to make data accessible on-line
Need to ensure that legislatively-mandated data elements are
entered into the national data base.
The other two remaining fatal criteria measure the feasibility of making each
alternative operational. These criteria include:
Participants are interested in and committed to the data entry
process
Alternatives are able to expand to handle increased reporting
requirements
The chart on the next page summarizes the evaluation of each of the four
alternatives relative to the six fatal criteria. At this point in the analysis, no
attempt was made to determine which alternative best satisfied each criterion.
Rather, each alternative was evaluated to see if it satisfied a fatal criterion to any
degree.
Feasibility Analysis 37
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Analyses of Options and Recommendations
Exhibit VI-1
Status Quo
State-Based
State Entry with
Centralized
Quality
Assurance
Hybrid
/
/
v
/
y
*, y
4/
/
/
\
^%
^
-------
Analyses of Options and Recommendations
directly. Therefore, these alternatives could not guarantee that EPA would be
able to meet its legislative requirement to enter all data elements reported on the
Form R.
Surveys of state and territorial TRI programs conducted by FOSTTA
indicate that 25 out of 52 respondents or 48% do not currently have automated
TRI data bases. Additionally, these surveys indicate that the funding, emphasis,
and involvement of the states and territories with the TRI data vary greatly.
Based on these surveys as well as the interviews conducted for this project, it can
be concluded that all states and territories will not be willing to commit to talcing
on the responsibility for data entry. Finally, all state interviewees stated that if
reporting requirements increased significantly, such as would occur with passage
of the Community Right-to-Know More Act, they had serious concerns about
their state's ability to handle that volume of data. Therefore, these alternatives
are not operationally feasible if reporting requirements increase significantly.
The remaining two alternatives were then evaluated relative to each of the
criteria to determine how well the approach satisfies the criterion. The results of
this analysis are summarized below.
Analysis of Remaining Options
The two remaining alternatives status quo and hybrid were assessed
against the 11 established criteria. These alternatives received one of three
ratings relative to each criterion:
Does not meet the criterion
Moderately satisfies the criterion
Fully satisfies the criterion.
The results of this analysis are illustrated on the following page.
39 Feasibility Analysis
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Analyses of Options and Recommendations
Exhibit VI-2
j ] Does not satisfy criterion
Moderately satisfies criterion
Fully satisfies criterion
Status Quo
The status quo alternative was found to fully satisfy all but two criteria
timeliness and increased reporting requirements.
Weaknesses
With respect to timeliness, currently EPA makes the data available to the
public between 10 and 11 months after the reporting deadline. States and other
user groups are interested in receiving the data much more quickly, on average
within six months. Therefore, the status quo is not currently meeting the
timeliness expectations of all user groups. One component of the status quo
alternative is the addition of image processing and optical character recognition
(OCR) technologies. Depending upon the success of these technologies, they
could allow the status quo alternative to come closer to user expectations for
timeliness. In addition, EPA is trying to increase submissions on magnetic
media. If this initiative is successful, this could also enable EPA to come closer to
user expectations.
The status quo was also not found to satisfy fully the increased reporting
requirements criterion. However, the planned incorporation of image processing
and OCR technologies in the current process has strong potential for helping
EPA better manage the increased volume of forms and data resulting from new
reporting requirements.
Feasibility Analysis
40
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Analyses of Options and Recommendations
Strengths
The major strengths of this alternative revolve around its ability to meet
all legislative requirements, most user expectations, and its proven operational
feasibility.
The status quo was designed to allow EPA to meet the
requirements of the law. The current system contains all data
elements, produces a national data base, is accessible on-line and
through other means, and supports legislatively-mandated uses.
The status quo alternative has evolved to meet sophisticated user
expectations with respect to overall data accuracy and
standardization. Data entry accuracy of the system exceeds 99%,
and accuracy of critical release value fields is even higher. EPA has
also invested significant resources in standardizing data and in
identifying reporter errors to further improve accuracy. This level
of accuracy supports a wide variety of usages, including EPA's
enforcement activities.
With the status quo, EPA is able to access the original Form Rs
easily, so that enforcement and other activities are supported.
EPA has demonstrated its commitment to continuing to provide
data over the years, so that users' abilities to perform trend and
other types of analysis is enhanced. TRI managers foresee no
change in this commitment.
The status quo is a proven concept in that its operations are
ongoing, and EPA senior management is committed to continuing
to allocate resources to the program.
Because the major party responsible for TRI data entry is the
Agency, data ownership issues with respect to preparing the
national data set are minimized.
Because of this alternative's ability to fully satisfy over 80% of the criteria, the
status quo clearly remains a strong approach.
Hybrid
The hybrid approach was found to satisfy fully six out of the twelve
criteria.
42 Feasibility Analysis
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Analyses of Options and Recommendations
Weaknesses
The six criteria that were not fully satisfied included:
Timeliness
Standardized data
Ongoing availability
Available resources
Data ownership
Increased reporting requirements.
Each of these six is discussed below.
Timeliness
With respect to timeliness, there are many issues that could potentially
hinder the ability of the hybrid approach to meet some users' expectations of
production of a data base within six months.
States or territories may encounter difficulties during data entry or
may have other priorities that take precedence over TRI data entry,
thus introducing delays into the process. Managers from other
EPA systems with state-based approaches indicated that the latter
could be a particular problem with an annual reporting period,
such as required under TRI. Staff hired to work on TRI data entry
would be given other responsibilities to attend to during non-entry
periods. These responsibilities could then interfere with data entry
during peak periods. One potential solution to this problem would
be to hire temporary staff each year. However, this has
implications for training, data quality, and other issues.
If states or territories do not adhere to established procedures or
standards or if conversion software is not effective, EPA could
spend significant amounts of time "cleaning up" the data, so that
they meet the users' accuracy expectations.
The states with high volumes of forms would need to volunteer to
participate in this hybrid approach and do their own data entry to
reduce significantly the current time period in which the data are
available. If EPA still is entering data for the high volume states,
then the majority of the data entry will still be occurring centrally
and significant time savings over the current process will not be
realized. If the high volume states do participate, there is the
potential for the data entry process to be somewhat accelerated.
Feasibility Analysis 42
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Analyses of Options and Recommendations
Overall because of the many potential areas in which the TRI data entry and
verification process may be slowed, the hybrid approach was found to only
moderately satisfy the timeliness requirement
Standardization
Standardization of data so that the national data base can be searched and
analyzed in a meaningful fashion is critical for supporting many uses. If many
different organizations are responsible for entering and checking the accuracy of
data, this has the potential to result in different approaches to entering the same
data. For example, Du Pont could be entered in different ways (e.g., Dupont) by
different organizations making it difficult to search for all records associated with
that company.
Successful implementation of the hybrid approach would require
resolving a number of other issues in order to meet data standardization
requirements. It would be necessary to establish data entry standards for states
and to perform quality assurance on the national data base to address this issue.
The potential for this to be a more challenging process than in the status quo and
to take more time is real, resulting in the moderate rating.
Ongoing Availability
The hybrid ensures the ongoing availability of TRI data because of the
strong role played by EPA in this alternative. If a state that has previously
agreed to participate drops out, the Agency will be in a position to enter that
state's data. The hybrid does not fully satisfy the other component of this
criterion, the ongoing availability of the forms. Access to the form is critical for
performance of enforcement and reconciliation activities. Because data entry is
occurring within different organizations state and federal and because
forms are currently sent to both places, it becomes difficult to ensure that EPA
has the same set of forms that the state performing data entry has in its
possession. EPA and several states have reconciled their forms at various times
in the past and have indicated that the same set of forms and revisions is often
not sent to both the states and EPA. EPA may have forms from facilities that the
state does not have and vice versa.
The following options exist for ensuring appropriate access to the forms
under the hybrid approach:
Reconciliation of forms: Because forms are sent to two places,
EPA would need to give the states a range of document control
numbers (DCNs) which the states would assign to their forms. The
states would then provide EPA with information on what forms,
revisions, etc., that it received and the corresponding DCN that was
assigned. EPA would compare this information against its forms
43 Feasibility Analysis
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Analyses of Options and Recommendations
and assign the same DCN. Any discrepancies between-the two sets
would then be resolved. This approach would have cost
implications because the need to reconcile forms from all states
would require EPA to invest in extra personnel to perform this
function. This could also result in time delays if there are
discrepancies or if states do not quickly submit their forms
information. EPA would not be able to perform any enforcement
or reconciliation activities until the forms were reconciled.
Submission of Forms to States: A decision could'be made to treat
the forms submitted to the participating states as the "official"
Form R submissions for those states, although submission to EPA
would continue as well, as required by law. The participating
states would copy the forms received and forward them to EPA for
use in its activities. This could potentially require additional
investments and personnel and slow the overall process if forms
are not copied promptly. Once again, EPA could not start any of its
enforcement or reconciliation activities until the forms were
received. If EPA required access to an original form, they could
request the original from the state or attempt to locate the original
from among the submissions sent directly to EPA. Either process
could potentially be time-consuming and introduce considerable
delays. Since EPA has legal responsibility for the national data
base, some procedures for ensuring access to the original forms
would be required.
Submission of Forms to EPA: Another alternative is to send the
forms only to EPA. The Agency could then copy the forms and
send them to the participating states. As with the previous option,
this approach would likely involve additional personnel and has
the potential for introducing delays into the data entry process.
The use of image processing technology by EPA to make electronic
images of the forms accessible to the states could be explored, but
the associated communications and hardware costs for transmitting
images would likely eliminate this as an option in the near term.
Because of all the challenges just described, this alternative does not fully
support the ongoing availability of data and forms criterion.
Feasibility Analysis 44
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Analyses of Options and Recommendations
Available Resources
Based on the results of interviews, it can be concluded that EPA will be
required to provide resources to.the majority of the states that agree to perform
data entry. For the purposes of this project, a high level cost analysis has been
performed to estimate the additional cost of this undertaking for EPA. This
analysis does not estimate total costs, but instead the additional resources EPA
would be required to provide as well as the resources the Agency would save by
not entering all forms. This is calculated by estimating personnel and equipment
costs for those activities that would vary most widely between the status quo and
a state data entry approach, including upfront processing, data entry, data
verification, training, user support, management, grant oversight, and forms
reconciliation. Detailed calculations and assumptions are provided in Appendix
D.
Based on the state and Regional interviews and the results of the
FOSTTA survey, it can be concluded that the perception is that
most states would be interested in participating, with some
exceptions. Therefore, for the purposes of this cost analysis, it was
assumed that 70% of the forms would be entered by the states, or
approximately 59,500 forms and 25,500 by EPA.
By averaging the number of forms per state and or territory, 70% of
the forms can be translated into approximately 36 states and /or
territories that would participate.
For each participating state and territory, EPA was assumed to
provide all necessary personnel and equipment. This could cost
the Agency close to an extra $3.6 million each year for personnel
and a one time investment of $657,000 for equipment.
EPA's costs for data entry and verification could be reduced by
about $1.1 million because the Agency is no longer responsible for
entry and verification of 70% of forms.
EPA would need to add resources to its Headquarters staff to
oversee, coordinate, and support the state data entry process. This
would result in the need for close to an additional half million
dollars each year. This estimate can be broken out as follows:
$226,000 per year for user support and training
$190,000 a year for overall management and grant oversight
$49,000 per year for personnel to reconcile forms.
45 Feasibility Analysis
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Analyses of Options and Recommendations
Exhibit VI-3
State Personnel and Equipment $3,598,279
Savings from EPA Data Entry/Verification l >137,459
EPA User Support and Training + 226,400
EPA Management and Grant Oversight + 190,000
EPA Personnel to Reconcile Forms + 49,038
Total $ 2,926,259
Therefore, it can be seen based on these preliminary estimates that with
the hybrid approach, EPA will be investing significantly more dollars each year.
EPA will be responsible for one-time costs of approximately $657,000 and
additional costs of approximately $3 million each year for personnel in the
hybrid approach.
If Community Right-to-Know More or other legislative or regulatory
changes are enacted, EPA would need to provide the states with additional
personnel and equipment to handle the increased volume. This would also
require additional EPA personnel to support the states in terms of training, user
support, grant oversight, and forms reconciliation. In addition, EPA would not
realize as large of savings in its upfront processing, data entry, and verification
budgets because the Agency would be handling a larger volume of data as well.
The net result would be the need for EPA to invest even more resources for the
state data entry approach to be feasible.
Data Ownership
The hybrid alternative was ranked as moderately meeting the data
ownership criteria because most state interviewees indicated that they would not
want their TRI data to be changed by EPA if states were responsible for data
entry. Yet, other interviewees felt that data quality activities must be performed
on the national data set to ensure that it meets users' expectations for accuracy.
Because of these views, EPA would retain its responsibility for overall data
quality and would need to conduct its usual data standardization activities.
However, rather than actually change the data base when errors or
inconsistencies are discovered, EPA would ask the participating states to change
the data and resubmit to EPA. Thus, state insistence on data ownership would
not prevent the development of a standardized national data set, but the
procedures necessary to modify data under this alternative have the potential to
Feasibility Analysis 46
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Analyses of Options and Recommendations
increase the amount of time required to make the data available to the public
beyond the status quo.
Increased Reporting Requirements
Interviewees also expressed concern over the states' abilities to continue to
perform TRI data entry if reporting requirements increase dramatically as would
result from passage of a Community Right-to-Know More Act. This increase in
reporting requirements would definitely necessitate additional resources for the
states. However, some states indicated that this sort of significant increase might
reduce their interest in participating in data entry.
Strengths
The strengths of this alternative were that it satisfies all the legislative
requirements, one user requirement, and one of the operational requirements.
The hybrid approach will still allow the national data base to be
compiled and to be made available on-line.
Only those states and territories that agree to enter all required data
elements will participate. EPA will have responsibility for entry of
all required elements for the remainder of the states, so that
legislative requirement will be met. However, as learned from the
experiences of AIRS and BRS, there is the potential that even those
states which initially agree may not be able to carry out all
responsibilities. So EPA would need to be prepared to assume
those responsibilities for that state.
The hybrid approach will also ensure accurate data. The
participating states will be responsible for verifying their data
according to standards negotiated between EPA and the states.
Because these states will have agreed to meet these standards and
because they are working with a smaller number of forms and are
familiar with their facilities, this should result in high data entry
accuracy (states interviewed indicated that data entry accuracy for
their systems currently ranged from 90 - 99+%). States will need to
be required to submit reports on error rates to EPA to ensure that
data quality is acceptable. EPA can then identify any problems and
take steps to address them.
Also, EPA will be responsible for detecting any additional errors
and standardization problems in the national data set, and for
identifying reporter errors, further strengthening accuracy. This
partnership between EPA and the states has the potential to
improve upon the levels of accuracy obtained with the existing
47 Feasibility Analysis
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Analyses of Options and Recommendations
system because of the combined facility knowledge and efforts of
both parties. The success of these efforts will be dependent on the
ability to reach agreement on how forms and edits will be handled
for those states that will not relinquish ownership of the data, to
ensure that EPA has access to original forms as required for its
work efforts.
Participation should not be an issue with this alternative because
only those states that are interested in participating will be
responsible for data entry. States will not be under any obligation
or commitment to participate and take responsibility for data entry.
If they would prefer not to be involved, EPA will continue to have
responsibility for their forms and data.
The hybrid approach is almost split evenly between criteria that it fully
satisfies and those that it moderately satisfies. However, this analysis is based on
"lessons learned" from other systems as well as opinions of interviewees. If
difficulties encountered by other systems have been identified and planned for,
the potential exists that if actual implementation were pursued, some of the
rankings (e.g., standardization) might improve. However, some (e.g., accuracy)
could also decrease if unexpected problems are encountered during
implementation.
Recommendations
Based strictly upon an evaluation of the alternatives relative to the criteria,
two alternatives are infeasible state-based and state-based with centralized
quality assurance because all states and territories:
Will not be willing or able to participate
Are not interested in entering all the data elements for which EPA
is responsible
Do not feel that they could perform data entry if reporting
requirements increase dramatically.
With respect to the remaining two options, the status quo is the most
feasible approach to entering, quality assuring, and making the data available
to the public as it satisfies ten of the twelve criteria fully and two moderately.
This approach ensures that all legal obligations are met, most user expectations
(with the exception of timeliness), and almost all operational requirements.
(These evaluations assume that the current system is upgraded to incorporate
image processing and OCR technologies.) The hybrid approach also fully
Feasibility Analysis 48
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Analyses of Options and Recommendations
satisfies all legal obligations, but does not provide the same level of satisfaction
with respect to user and operational requirements as the current approach.
However, during this evaluation of feasibility of state data entry benefits
associated with increasing state involvement in the TRI program in some
capacity have been identified. These benefits include potentially the ability to
assist EPA with responding to an increased volume of public queries and
assistance with internal, programmatic activities aimed at improving
environmental quality. Therefore, regardless of whether or not a decentralized
data entry approach is pursued, it is critical that EPA continue to promote the
federal/state approach in the context of the TRI program. Because of the interest
in promoting this partnership, EPA should consider additional mechanisms to
involve states in the current system as well as consider additional research into
the feasibility of the hybrid approach. Recommendations in each of these areas
are provided in the following sections.
Status Quo
EPA should consider additional mechanisms for promoting
communication and involvement with the states in the existing process as well as
for better meeting the needs of the states. Examples of some mechanisms
include:
Investigate the possibility of expanding the number of states that
are given data quality grants to review the TRIS data. This could
also increase the involvement of the Regional offices through the
grant administration process.
Develop a tool for identifying on-line when revisions are entered
into the TRI data base, so that the states are able to use the most up-
to-date versions. This recommendation is already being addressed
for the next reporting cycle (RY91). In this version of the data base,
access to both revised and prior data will be available to the states.
Implement more state outreach projects, like the ongoing
Pennsylvania pilot. This pilot is investigating all potential TRI
users in Pennsylvania and is seeking to build a network of
organizations (e.g., libraries, poison control centers) across the state
that will satisfy the needs of these users.
Provide additional funding to train state TRI program personnel in
the use of TRIS and NLM, to enhance their access to the data.
Implementation of these recommendations would promote further
involvement of the states and territories with TRI data even if decentralized data
entry is not adopted. This would also provide overall benefits for TRI in terms of
49 Feasibility Analysis
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increased usage and access to data at the state ancHocal levels throughout the .3
country and well as the potential for higher quality facility-level data.
Hybrid
The hybrid approach offers more potential for directly involving the states
than the current system does and for allowing TRI data to meet the needs of state
users. But as described earlier, its ability to meet the expectations of all users and
to be operationally feasible is somewhat in question. However, further
development of this alternative and research into its feasibility would allow EPA
to determine the extent to which user expectations would not be met and
operational problems would occur, and whether those potential problems would
be offset by the benefits of increased state involvement.
Some of the specific issues that would need to be addressed if further
development of the hybrid alternative was considered to be worthwhile:
Interest How many states and territories are interested in
becoming involved in data entry and what capabilities do these
states have currently.
Level of resources - What level of resources the states need to
ensure successful data entry and through what source (e.g., fees,
EPA grants).
Appropriate quality and timeliness standards - What standards
should be met regardless of where data entry occurs
Grants tracking - Where are grants going to be tracked, at the
Regions or Headquarters? It may be difficult for the Regional
offices to track the grants and to monitor overall compliance with
data quality and timeliness standards because the Regions do not
currently have access to the forms.
Enforcement - How will enforcement activities be managed? EPA
has currently indicated that it will not delegate enforcement
activities, so the specifics of accessing original forms, certifying
whether or not a facility reported, and other enforcement activities
will need to be worked out if EPA is not responsible for all data
entry.
Data entry approach - Direct, using EPA software or retain use of
state system and convert the data? If conversion software is
necessary, the issue of who should pay for and develop the
software must also be explored.
feasibility Analysis 50
-------
Analyses of Options and Recommendations
Data quality - Negotiate specifically what the responsibilities of the
states will be vs. EPA. The states should maintain responsibility for
verification with EPA the primary responsibility for reconciliation.
Training and ongoing user support - How much should be
provided each year and should this occur through EPA
Headquarters or the Regional offices? This decision is dependent
upon issues such as access to the form, current location of expertise,
and economies of scale.
Access to forms - Should the forms be reconciled and what will this
require in the way of resources? Would EPA give the states a range
of document control numbers to ensure that an individual form can
be tracked? Should forms go only to the state or to EPA and then
be copied for the other party?
In addition to conducting an exploration of these issues, it may also be helpful to
conduct a pilot to test an operational data entry approach, to test resource
estimations, and to identify any additional issues that need to be resolved.
Conclusion
Both of the alternatives that satisfied all of the fatal criteria status quo
and the hybrid approach are able to satisfy all legislative requirements.
However, the status quo is able to meet a wider range of user expectations and
operational requirements, including EPA's ongoing need to access the data and
forms for enforcement purposes, industry and environmental groups needs for
accuracy, and other users demands for sufficient standardization to perform
useful searches on the data base. The hybrid approach offers the potential to
meet some of the user needs, but not to the extent that the status quo does.
Additionally, the status quo better ensures operational success because data
ownership issues do not have the potential to introduce additional delays or
problems with producing the national data base into the process.
Therefore, the status quo is the most feasible means of continuing to
produce the TRI data base, so that it meets all legal and most user requirements.
Additionally, planned technological improvements in the status quo have the
potential to further strengthen the current approach's ability to meet all user
requirements.
However, because the states are a critical partner in environmental protection,
and EPA wishes to continue to increase its involvement with the states, there are
opportunities for improving state involvement with TRI. These opportunities
range from involving the states more in the current process in roles such as
quality control, to further investigating the feasibility of involving committed
51 Feasibility Analysis
-------
Analyses of Options and Recommendations
states in the data entry and verification process. Additional research into the
hybrid approach may reveal that the benefits of state involvement outweigh any
potential difficulties or loss in ability to meet other requirements, making this a
worthwhile approach to pursue. However, if other user requirements cannot be
met in a reasonable manner as is indicated by this analysis, then the hybrid
approach should not be pursued because TRI has an extensive user base, and
each user is a valuable partner in environmental protection.
Feasibility Analysis 52
-------
Appendix A. Interviewee List
The interviewee lists on the following pages are organized as follows:
Headquarters
Regional
State
System Managers.
Headquarters Interviewees:
George Bonina, Office of Pollution Prevention and Toxics, Information
Management Division, Deputy Director
Ruby Boyd, Office of Pollution Prevention and Toxics, Information Management
Division
Sarah Hammond, Office of Pollution Prevention and Toxics, Environmental
Assistance Division, State Liaison
John Harmon, Office of Pollution Prevention and Toxics, Information
Management Division
Bob Janney, Office of Pollution Prevention and Toxics, Environmental Assistance
Division, Regional Liaison
Steve Newburg-Rinn, Office of Pollution Prevention and Toxics, Information
Management Division, Public Data Branch Chief
Janette Peterson, Office of Pollution Prevention and Toxics, Information
Management Division
Doug Sellers, Office of Pollution Prevention and Toxics, Information
Management Division
Sam Sasnett, Office of Pollution Prevention and Toxics, Economics and
Technology Division
Linda Travers, Office of Pollution Prevention and Toxics, Information
Management Division, Director
Mike Walker, Office of Enforcement, Toxic Litigation Division
Mike Wood, Office of Compliance Monitoring, Compliance Division
Janet Bearden, Office of Compliance Monitoring, Policy Division
Bridget Sullivan, Office of Pollution Prevention and Toxics, Office of Compliance
Monitoring, Policy Division
Sylvia Bell, CBSI, TRI contractor
Maxine Romo, CBSI, TRI contractor
David Waggoner, CBSI, TRI contractor
-------
Appendix A
Regional Interviewees:
Helen Burke, Region IX, Pesticides and Toxics Branch
Carlton Hailey, Region IV, 313 Coordinator, Pesticides and Toxics Branch
Dennis Wesolowski, Region V, Pesticides and Toxic Substances Branch
Warren Layne, Region VI, Pesticides and Toxics Branch
Bob Hickland, Region VI, Enforcement
State Interviewees:
Steve Hanna, Chief, Office of Environmental Information, California
Environmental Protection Agency
Ken Rydbrink, Office of Environmental Information, California Environmental
Protection Agency
Fred Alvarez, Indiana Department of Environmental Management, MIS
Robert Bierman, Indiana Department of Environmental Management, Office of
Air Management, Sr. Environmental Manager
Skip Powers, Indiana Department of Environmental Management, Emergency
Response Branch, Staff Director
Barty Titus, Indiana Department of Environmental Management, Office of Air
Management, Director
Bert Langley, Georgia Department of Natural Resources, Environmental
Protection Division, Emergency Response Program Manager
Karl Birrts, Right to Know Program, Kansas Department Health and the
Environment
Cindy Sferra-DeWulf, Division of Air Pollution Control, Ohio EPA
Marcia Mays, Toxic Registries Division, Maryland Department of Environment,
Program Administrator
Emily Kilpatrick, SARA Coordinator, North Carolina Department of Emergency
Management
Becky Kurka, Pollution Prevention and Conservation Division, Texas Water
Commission
Ken Zarker, Pollution Prevention and Conservation Division, Texas Water
Commission
Gena Guo, Pollution Prevention and Conservation Division, Texas Water
Commission
Feasibility Analysis 54
-------
Appendix A
System Manager Interviewees:
BUI Laxton, Technical Support Division, OAQPS
Chuck Isbell, National Air Data Branch, OAQPS
David Misenheimer, Emissions Inventory Branch, OAQPS
David Mobley, Emissions Inventory Branch, OAQPS
Ron Ryan, Emissions Inventory Branch, OAQPS
Howard Wright, National Air Data Branch, OAQPS
Jill Vitas, Alliance Technology, contractor to OAQPS
George Czerniak, Region V, Chief Air Enforcement Branch
Myra Galbreath, Office of Solid Waste, Information Management Branch
Kathy Ferland, Texas Water Commission, BRS
Joan Allen, Texas Water Commission, RCRIS
George Murray, North Carolina
Mary K. Marusak, Region VI
Terri Mikus, Region VI
55 Feasibility Analysis
-------
Appendix B* Interview Guides
Interview Guide
EPA Headquarters and Regional Program Personnel
TRI Performance Requirements
1. What performance requirements must be met by TRI, regardless of who is
responsible for data entry and quality control (i.e., with regard to costs,
accuracy, timeliness, and other factors)? Please define these requirements
as specifically as possible.
2. What is the relative importance of these requirements?
3. What other program objectives are impacted by failure to meet the
performance requirements defined above (e.g., making the data publicly
available, supporting enforcement efforts)?
4. Are there other logistical components of the TRI program that could be
impacted by a change in TRI data entry operations (e.g., EPA's ability to
aggregate the data to build a nationwide data set, linking facility data
across reporting years)? Please define these other elements, and the
potential impacts of changes in TRI data entry procedures, as specifically
as possible.
Potential Advantages/Disadvantages of a State-Based Data Entry Approach
5. What are your perceptions of the possible advantages and/or
disadvantages of a state-based data entry approach for TRI, in terms of the
performance requirements discussed above?
6. Do you feel that such an approach has potential for introducing
improvements relative to any of the performance requirements discussed
above? Why or why not?
7. Do you feel that such an approach has potential for worsening
performance relative to any of the performance requirements discussed
above? Why or why not?
Feasibility Analysis 57
-------
Appendix B
8. Would there be value to a system that involved state-based data entry for
selected states, with the current system being retained for other states?
9. What groups/organizations within EPA are currently supporting the
adoption of a state-based data entry approach? Outside EPA?
Role of Headquarters in a State-Based Data Entry Approach
10. What role do you feel that Headquarters should play in a state-based data
entry approach?
11. What are the roles /responsibilities that you feel Headquarters must retain
under a state-based data entry approach?
12. Should states handle only data entry, or should they also perform some or
all of the data verification and reconciliation steps currently performed at
Headquarters?
13. Should Headquarters perform any data verification/reconciliation efforts
on the information provided by the states?
Role of Regions in a State-Based Data Entry Approach
14. What role should the Regions play in a state-based data entry approach
forTRI?
15. What role should your specific Regional office have?
16. What are your perceptions of the relative advantages and disadvantages
of incorporating Regional involvement into a state-based data entry
approach for TRI?
17. Would your current staff/resources be able to handle these additional
roles/responsibilities? If not, how much would your staff/resources need
to be augmented?
Funding of a State-Based Data Entry Approach
18. What are the options for providing funding for a state-based data entry
approach?
19. Which option do you believe is most feasible for EPA to implement?
Feasibility Analysis 58
-------
Appendix B
20. Do you believe that a state-based data entry approach would be cost-
effective?
59 Feasibility Analysis
-------
Appendix B
Interview Guide
States
Background Information
1. Do you have your TRI data entered into a computer?
2. If you do not have your TRI data in a computer do you plan to enter it into
a computer? Why or why not? If no on question 1, skip to question 28.
3. What motivated your state to set up their own system?
Costs/Funding/Staffing
4. How is it funded? by grants? state funds?
5. Have you ever received a grant from HQ for state data entry? If so, how
was it used?
6. How many staff (full-time and part-time) are working on the TRI
program?
7. What kind of hardware/software do you use?
8. Do you think this hardware/software can adequately grow and handle a
significant increase in data?
9. What was the state's capital investment?
State Data Entry Process
10. Please describe how your state data entry process works?
11. Do you enter all or only part of the data? If only parts, which parts do you
enter?
12. What sort of data quality procedures do you follow?
13. Does the state adhere to data entry and other standards established by
EPA?
Feasibility Analysis 60
-------
Appendix B
14. What level of data accuracy is attained with the system? How is the
accuracy measured?
15. What types of data normalization (i.e., standardization) activities occur?
At what point in the process?
16. At what point are data aggregated or uploaded to the system?
17. Are any data quality or normalization (i.e., standardization of data
elements) activities undertaken on the entire data base?
18. Is there any involvement of Regional offices?
19. If regions were involved do you think this would be one more chance for
error?
20. How many Form Rs do you receive and process?
21. How many data elements are entered on average each year?
22. Approximately how much does it cost on average for states to do data
entry - per data element?
23. How soon after the July 1 reporting deadline is computerized TRI data
available? to staff? to the public?
24. Is this after all data quality/normalization activities have taken place?
25. Do you update your state TRI data base to include revisions? If yes, how
often do you revise the data?
26. Do you reconcile your data with Headquarters TRI data?
27. Do you adjust your data base reports/runs to reflect new chemical listings
or modifications?
28. Pollution Prevention Act data is included on this year's Form R. Do you
plan to include this data in your computerized data base?
29. How much do you think it would cost for your state to enter all TRI/PPA
data, assuring 99.5% data entry accuracy?
Feasibility Analysis
-------
Appendix B
Data Users and Uses
30. How do you use the data?
31. Do you use the data for enforcement action?
32. What difference does it make to you if the data is available in December or
May? What uses necessitate it to be available in December?
33. Who are the users of the data?
34. Does the level of accuracy in your data base meet the needs of the users?
35. Does the timeliness in terms of availability of the data meet the needs of
your users?
36. Do you make the TRI data available to the public? If so, how?
37. Can the public access this TRI computer data base? How? What
methods?
38. Do you create customized reports from your data base?
39. Do you respond to public queries?
40. How many requests for information from the public do you receive?
41. What type of requests do you receive (e.g., written, telephone)?
42. Do you charge for your services? If yes, how much?
43. Do you help the public interpret the data by providing them with health
effects or risk analysis information?
Advantages and Disadvantages of State Data Entry
44. What do you see as the benefits of state data entry?
45. What do you see as the problems with state data entry?
46. How would you improve the state data entry process?
47. How much do you think these suggested improvements would cost?
48. What type of hard ware/software do you use?
Feasibility Analysis 62
-------
Appendix B
Questions for States Without Systems
49. What type of hard ware/software do you use?
50. Do you think that this hard ware/software can be adequately expanded
and grow to handle a significant increase in data?
51. How many staff do you believe would be required to support TRI state
data entry?
52. What do you think would be the state's capital investment to conduct state
data entry, assuring 99.5% data entry accuracy?
63 Feasibility Analysis
-------
Appendix B
Interview Guide
System Managers
Background Information
1. Please describe the basic purpose of your system and the types of
information that it contains.
2. Please categorize the users (e.g., industry, environmental groups) of the
data?
3. Does the public have direct access to the data base or to its data?
4. What types of analyses can the data support?
5. How are the data used? Is a certain level of accuracy necessary for
supporting the various uses?
6, What level of enforcement activities are conducted for this program?
7. What type of entry cycle does the system follow (i.e., continuous, based on
a reporting deadline)?
8. How many forms are submitted? What is the average number of data
elements? Are they formatted or free text?
9. How long does it take to enter a form, all forms?
10. How soon after receipt by the states are data given to Headquarters
(average, worst case scenario)? How soon are data available to the larger
user community?
Feasibility Analysis 64
-------
Appendix B
11. Have the states always been responsible for data entry? If not, why did
the approach change?
Process Discussion
12. Please describe how the state data entry process works.
13. Is data entry conducted on the EPA mainframe or at a remote site? How
is the EPA mainframe updated?
14. At-what point are the data aggregated or uploaded to the national system?
15. Did states develop their own software or did EPA give them the software?
16. Did EPA establish data entry and other standards to which the states must
adhere? Are copies of written standards available?
17. What, if any, is the involvement of the Regional offices?
18. At what point does Headquarters become involved?
19. Who monitors progress, production schedules, etc.?
Data Quality
20. What specific data quality procedures do the states follow?
21. What is the level of data accuracy in the system? What level is
expected/required?
65 Feasibility Analysis
-------
Appendix B
22. What types of data normalization activities occur? At what point in the
process? Who ensures consistency nationwide?
23. Are any data quality or normalization activities undertaken on the entire
data base?
Funding
24. How are the state data entry programs funded?
25. Did the states have to make any significant capital investments to perform
their responsibilities? Where did equipment, software, and staff come
from?
26. Approximately how much does it cost on average for states to perform
data entry - per data element, per form? How does this compare to the
federal cost to perform data entry activities?
Benefits/Problems
27. What do you think are the benefits of state data entry?
28. What do you see as the problems with state data entry?
29. How would you improve the state data entry process?
30. Are there coordination problems with the states?
Feasibility Analysis 66
-------
Appendix B
Questions for Regional Staff Involved with System
1. What is your involvement with the system?
2. Please explain the Regional office's responsibilities with respect to data
entry and /or quality control.
3. In what capacity, does the Regional office interact with the states with
respect to this system?
4. What do you see as the benefits of the Regional office's involvement?
5. What do you see as the problems with Regional involvement?
6. In your opinion, what are the benefits of state data entry?
7. What are the problems with state data entry?
8. How would you improve upon the existing process?
9. Have you encountered data quality problems with the data base? What
are they? How have they affected your use/confidence in the data base?
67 Feasibility Analysis
-------
*§
53'
State
Capabilities
Enters data into a
computer
Plans to enter PPA
data
Number of data
elements entered
Number of
facilities/forms
Date by which data
are entered
Hardware/
software
QA
procedures
Level of accuracy
#ofFTEsfor
TRI-reJated work
Texas
Tracking data
No
Approx. 5
1200/
6000
Sept.
fee data
PC/
Paradox
N/A
N/A
1 full-time +
part-time
California
Yes
No
All but,
chemical use,
waste mlm PPA
1800/
6000
Sept.
PC/ Oracle
Automated
checks &
manual
verification
of CAS and
emissions;
dataentrv '
99+%
1* asst
part-time
1
Indiana
Data from
natl system
No
Subset
only
900/
3300
N/A
Mac/
spread-
sheet
Internal
state review
of data
N/A
1
North
Carolina
Facility
info.
No
Approx.
15
1100/
2500
Sept.
PC/ dBase
100%
verification
of data
elements
N/A
1
Georgia
Yes
Yes
90%
730/
2470
Sept. or
Oct.
PC/QA
software
Automated
checks;
15%
verification;
100% check
over
Imillion Ibs.
90+%
1
Utah
Yes
Yes
All except,
waste min.,
120/450
Sept.
PC/
dBase
100%
verification
of data
elements
100%
2.5
Kansas
Yes
Yes
All
230/900
Sept.
AS400/
Hazox
N/A
unknown
10
Ohio
Yes
Not
certain
All exc. waste
mln., lat/ long,
POT W, stream
1,600/
6500
Sept.
PC
100%
verification
of data
elements
N/A
5
Mary-
land
Yes
Yes
ID Info, and
33 fields for
chemicals
230/800
Sept.
PC/
dBase
100%
verification
of data
elements
90% !
1
-------
-
| State^^
| ^^-""Capabilities
I Data uses
1 Form Rs Hied
i Creates customized
! reports
i Public can access
i system on-line
i Data available to
I public
j Publishes annual
i report
] Funding
Interest in state entry
jRequire funding
JExtra FTEs
i required
Texas
Reports,
toxic
loadings,
air tones,
permits,
public, risk
assessment
Yes
Yes
No
100
requests/yr.
Yes
Fee
Program -
$100,OGO/
year
Yes, grant
application
Yes, will
consider fees
Yes
California
Air toxics,
pollution
prevention,
ozone, public
requests
Yes
Yes
No
1210 requests
over 4 years
No
Funds from
hazardous
waste
program; all
state funds
Yes, consd.
for Region
Yes, will
consider fees
.5-1
Indiana
Air toxics,
health
effects,
inspections
Yes
Yes
No
100
requests/yr.
In 1987
Fed. grant
for data use;
no dedicated
funding
Yes, not top
priority
Yes, will
consider fees
2+
equipment
Carolina
Responds
to public
requests for
Form Rs
Yes
No
No
15-20
requests per
year
No
State
funds
Yes
Yes
4+
equipment
Georgia
Air toxics,
permitting,
compliance,
emergency
response
Yes
Yes
No
Yes
Yes
Fed. grant
for 311, 312,
added 313;
no dedicated
funding
Yes
Yes
3+
equipment
Utah
Air toxics,
and other
environ.
programs,
public
requests
Yes
Yes
No
Yes
Yes
State
funds
Yes, will
consider
Yes
No
Kansas
Reports,
toxic
loadings,
air toxics,
permits,
public, risk
assessment
Yes
Yes
Yes
175
equests/yr.
Yes
State
general
funds,
fees,
grants
Yes
Yes
0-.5
Ohio
Air toxics,
permits,
public,
stream
analysis
Yes
No
No
Yes
Yes
Fees,
grant
Yes
No
No
Mary-
land
Inspections,
permits,
air-mgmt,
33/50
analysis,
briefings j
Yes
Yes
No
;
Yes
i
No
1
State
funds
i
Yes I
Yes
Yes
a
a,
n
-------
Appendix D. Cost Analysis Assumptions
Cost Analysis Assumptions
1. Because this is a high level analysis intended to give EPA an estimate of
additional costs involved with or saved as a result of state data entry, only
personnel and equipment costs for the components that would vary most
widely between the status quo and state data entry were estimated. These
included upfront processing, data entry, verification, training, user
support, management, grant oversight, and forms reconciliation.
2. State personnel are assumed to be able to perform upfront processing
(e.g., opening, date stamping) at the same per hour rate as the current EPA
contractor personnel.
3. Peak period for upfront processing for states was assumed to be 1 month
on average with 3 months on average for data entry and data verification.
These time frames are necessary to ensure that along with EPA quality
assurance activities the data can be available within the 6 month target.
4. Peak period for the current system for upfront processing is 3 months and
6 months for data entry and verification.
5. All salary estimates are based upon Labor Rate Surveys and the GS
schedule.
6. It was assumed that EPA would fund all personnel involved with entering
and/or verifying TRI data for all states as well as most equipment.
7. Each state participating in data entry was assumed to require a LAN
which EPA would fully fund. If states plan to use their own systems, then
they would receive funding in the same amount as the equipment to
develop conversion software or to enhance the existing system to meet
performance expectations.
8. In addition to the personnel necessary for data entry and verification, each
state was assumed to need one manager - the equivalent of a GS-12 to
oversee the state operations.
9. It was assumed that in the status quo approach one manager can
supervise 15 personnel (workyears).
Feasibility Analysis 71
-------
Appendix D
10. It was assumed that EPA would need to hire additional personnel to
perform coordination and oversight functions.
11. EPA will need to train all states approximately once a year to ensure that
they are familiar with any changes to software. This number was derived
from discussions with other EPA system managers involved with state
data entry. EPA employees will visit each individual state to assist with
installing new software, training, and overseeing data entry functions.
Each trip was assumed to cost $1000.
12. User support in the form of a hotline will also be provided at EPA.
13. Additional personnel will be required to oversee the grants and to ensure
that data entry and verification efforts are coordinated across states and
between EPA and the states.
14. For the purposes of this cost analysis, it is assumed that EPA will be
responsible for reconciling its forms against those held by the states. This
will involve EPA providing document control number ranges to the states
and then matching its forms against those in the state data base.
Additional personnel are required for this function.
Feasibility Analysis 72
-------
Appendix D
PERSONNEL RESOURCES NEEDED BY STATES and EPA
Assume 70%
of forms entered by states
Forms entered by EPA
Total Forms
Forms/hour for upfront processing
Hours per 1 month peak period - state upfront processing
Forms/hour for TTS keying (first component of data entry}
Forms/hour for TRIS keying (second component of data ent
Hours per 3 month peak period; state data entry and verifi
Forms/hour for verification
Hours per 3 month peak period - current upfront processing
Hours per 6 month peak period - current data entry and ve
Number of Managers Needed/State
Number of Managers Needed by EPA for each 15 Workvears
state Estimates for 70% of Data Entry, Verification
Hours Required for State Upjront Processing
Workyears for
State Upfront Processing
Hours Required for State TTS Keying/Year
Workyears for
State TTS Keying
Hours Required for State TRIS Keying/Year
Workyears for
State TRIS Keying
Hours Required for Verfication
Workyears Required for Verification
Total Workyears Required for States
Average Workyear/State
Total Number of Managers Required for States
EPA Savings
Hours Required for EPA Upfront Processing
Workyears for
EPA Upfront Processing
Hours Required for EPA TTS Keying/year
Workyears for
EPA TTS Keying
Hours Required for EPA TRIS Keying/Year
Workyears for EPA TRIS Keying
Hours Required for Verfication
Workyears Required for Verification
Total Workyears Required for EPA
Managers Rec
Cost/Year for
uired for Supervision
Upfront Processing Personnel
59500
25500
85000
12
160
10
*
480
7
480
960
1
1
4822
30
6128
13
23611
49
9070
19
111
3
36
4822
10
6128
6
23611
25
9070
9
50
3
$19,500
73
Feasibility Analysis
-------
Appendix D
Cost/Year for Data Entry Personnel
Cost/Year for Verification Personnel
Cost/Year for Managers (equivalent to a GS-12)
Total State Cost for Personnel to Process, Enter, Verify 70'
Total Cost for State Managers
Total Cost for State Personnel
Total EPA Savings
EQUIPMENT COSTS - Non-recurring
Average Number of Forms/State
Total Number of States Participating
Equipment Necessary Per State for Data Entn
File Server Cost
Cost for Two Workstations/State
Printer Cost
Total Cost for File Servers
Total Cost Workstations
Total Cost Software
Total Cost Printers
Total Equipment Cost
I
$20,000
$20,550
$38,000
$2,215,079
$1,383,200
$3,598,279
$1,137,459
1635
36
$8,000
$8,000
$2,000
$291,200
$291,200
$2,000
$72,800
$657,200
ADDITIONAL RECURRING RESOURCE REQUIREMENTS FOR EPA
Training and User Support Workyears Required
5
(based on each state being trained each year and telephone support)
Cost per Workyear (equivalent to a GS-12)
Total Cost for Additional Training
Cost for Travel per Trip
Total Cost for Travel/Year
MANAGEMENT AND GRANT OVERSIGHT WORKYEARS
Management and Grant Oversight Workyears Required
Cost per Workyear (equivalent to a GS-12)
Total Cost for Management and Grant Oversight
I
$38,000
$190,000
$1,000
$36,400
5
$38,000
$190,000
Feasibility Analysis
74
-------
Appendix D
FORMS RECONCILIATION COST
Reconciliation Rate/Hour
Reconciliation Workyears Required
Cost /Workyearfor Forms Reconciliation
Total Cost for Forms Reconciliation Workyears
Total Recurring Costs for State Personnel
Total Additional Recurring Costs for EPA
EPA Savings from Not Performing Activit
ADDITIONAL EPA COST/YEAR
ADDITIONAL EQUIPMENT COSTS
20
2
$24.000
$49,038
$3,598,279
$465,438
$1,137,459
$2,926.259
$657,200
75
Feasibility Analysis
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EPA
U.S. ENVIRONMENTAL PROTECTION AGENCY
Washington, DC 20460
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Interview Summary
August 3,1992
This document was prepared by Booz-Allen & Hamilton Inc., under Delivery Order 112 of EPA/OARM Contract #68-W9-0037.
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Interviews were conducted to collect the information
necessary to evaluate the feasibility of state data entry for
TRI data. Interviews were conducted with the following
personnel:
EPA Headquarters personnel
EPA Regional program personnel
State personnel
Managers of other EPA systems with state-based data entry
approaches as well as Regional and state personnel
involved with these systems.
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Personnel in the following offices were interviewed to obtain information
on what EPA Headquarters offices perceived as being state data entry
issues, benefits, and problems for TRI:
Information Management Division in the Office of Pollution
Prevention and Toxics (OPPT)
Environmental Assistance Division in OPPT
Economics and Technology Division in OPPT
Office of Compliance Monitoring
Office of Enforcement.
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EPA Headquarters personnel indicated that if states were to perform data entry
for TRI they would need to meet the following performance requirements to
ensure that legislative requirements and user expectations were satisfied:
Data accuracy standards
99.5% data accuracy for data entry
Near 100% accuracy in critical data fields (e.g., release amounts
over 50,000 Ibs)
95% accuracy for all other values
Data of sufficient consistency to facilitate searching
Timeliness - have the data ready for release to the public nine months
after the filing deadline
Cost - must work within budget constraints
Availability - must make the data available through many sources and
accessible in various formats; data must be available in a national data
base i
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EPA Headquarters personnel also discussed the following specific internal
uses for the TRI data, which will need to be supported regardless of who has
primary responsibility for TRI data entry:
Producing the national report
Targeting inspection and enforcement efforts and identifying potential
nonreporters and submitters of false data
Negotiating pollution prevention settlements
Responding to requests for information regarding specific
enforcement cases
Performing economic analyses of impact of changes in reporting
requirements, such as listing/delisting of chemicals or midifying the
reporting thresholds.
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The following are perceived as being benefits of state data entry:
State data entry promotes buy-in from the states
Some states collect additional information now, and EPA could
possibly use this information
States are more familiar with the facilities in their own state,
and could recognize errors in data submitted more easily
Potential for improved access to information at local level.
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The following are problems that Headquarters personnel perceive as being
associated with the states performing TRI data entry and meeting TRI
performance requirements:
Legal and Regulatory Issues
The law requires that there be a national data base for which EPA is
responsible
Trade secrecy is not delegated to the states
Enforcement responsibilities will be maintained at the federal level
Notices of noncompliance and technical error are presently done at the
federal level
For compliance purposes, it may be difficult to get states to perform current
Headquarters role of certifying that a given facility did not report, which
sometimes requires witnesses to testify in court.
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Form R Issues
Form R processing and retrieval could be difficult since states do not
assign document control numbers
Access to the "official" copy of the Form R could be a problem if it is
kept in the state. Reconciling the national set of forms to the state set
could also be challenging.
If a cutoff date is established for new forms and revisions, it would be
difficult to coordinate with all states.
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Resources
Even if resources were available for new technologies, the benefits
associated with economies of scale for new technologies would not likely
be attainable due to smaller universe of forms being processed by a given
state. States could not do the same work for the same amount of money.
Concern about lack of sufficient funding to support the program.
For states that currently perform no entry of the TRI data, significant
resources would be required for training and for establishing a program.
If grants are selected as the primary funding source for a state data entry
program, consideration must be given of the resources required for grant
oversight.
State data entry program has potential for increasing burden on Regional
resources, which is where most compliance resources are located.
Cost savings are likely to be limited because much of Headquarters
overhead would not go away (e.g., all forms would still need to be stored);
possible cost savings would be further limited if Headquarters still had to
enter data for some states.
10
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TRI Data Management Issues
Requirement for meaningful use of a national data base means that
Headquarters would still need to perform data reconciliation activities to
ensure consistency of data
Since Headquarters needs to perform data reconciliation activites, data
ownership could not be given to the states
It may be difficult to know which version of the data is available if states
submit by batch files
If states input and interpret data and send them to EPA it is risky because data
do not come from the facility, but rather from the state. Also, each state may
interpret data differently
There is concern that the data quality checks may not be as stringent at the
state level as those currently in place
Data normalization so that data are accessible for searches may be difficult if
states do entry (e.g., facility and chemical name)
If states are unwilling to allow EPA to modify data in any way, it may be
difficult to ensure data quality. n
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State Commitment and Participation Issues
Not all states will be able or interested in doing data entry, so Headquarters
might still have to perform some data entry.
States must remain committed to the program to ensure that data are
available over the years.
There is currently no means to ensure state compliance with policies and
procedures; Headquarters resources would need to be committed to these
efforts.
States are likely to lack the incentive to enter every TRI data element
because they do not use all elements.
Possible that states' closer relationships with industry could result in
pressure to present data more favorably.
12
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The following are recommendations received from Headquarters personnel
about how to approach state data entry if such an approach is decided upon:
Make certain levels of accuracy and time frames in which entry
is to be completed requirements of any grants
Provide states with entry software, including NAM/ADD file,
and guidance for submissions of tapes/diskettes
Provide states with a range of document control numbers for
their facilities
Continue at least limited data reconciliation and QA on the
national data base
Perform random QA checks the first year to ensure appropriate
level of accuracy
^ Do not involve Regional offices in data entry
Provide sufficient funding to support the program adequately.
13
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Personnel in the following Regional offices were interviewed to obtain
information on what they perceive as being state data entry issues,
benefits, and problems for TRI:
Region IV
Region V
Region VI
Region IX.
15
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The following are perceived by Regions as being benefits associated with
state data entry:
States could do data entry quicker and thus have the data available to
assist with internal programs, such as the 33/50 initiative, air toxics; data
would also be available to Regions quicker
Data quality could improve as states often know their facilities better
than Headquarters.
16
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|| The following are perceived by Regions as being problems associated with state
|| data entry:
Regions are not sure of the interest, commitment, and capabilities of all
states; all states will not be interested
QA/QC - states do not have as stringent of edit checks as the national
data base, and data quality could suffer
Data normalization - consistency and standardization of data will be
difficult
Funding - almost all states will require funding to do data entry, which
may not be feasible
Community Right-to-Know More requirements could overwhelm the
states if enacted.
17
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EPA Regional personnel provided the following recommendations for a
state-based data entry approach:
Planning and Organization
Invest in initial training and development of procedures for the states and
provide ongoing support
Ensure that state organization most interested in using the data is
responsible for the entry
Procedural Recommendations
Negotiate with states to determine appropriate procedures and standards
Stipulate requirements in grants for accuracy and time
Ensure that Headquarters still performs some quality assurance on the
national data base
Target 6 months to make data available if entry is moved to states.
18
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Regional Role Recommendations
Involve the Regions in an assistance role when the program is
initiated and as an ongoing liaison
Involve Regions in administering grants. One Region indicated
that resources would need to be provided to Region to ensure the
right personnel are available to administer grants
Investigate regional data entry approach where one state enters
data for all states in the Region. California has considered doing
this for Region IX.
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Interviews were conducted with personnel from
states with active TRI data management
programs. These states include:
California
Georgia
Interviews were also conducted with personnel from states with
less-developed TRI data management programs. These states include:
Texas
North Carolina
Indiana.
21
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Interviews were also conducted with personnel
from states that have members on the Forum on
State and Tribal Toxics Action (FOSTTA). The
following states requested interviews based upon
a presentation on this study given at a FOSTTA
meeting:
Kansas
Maryland
Utah
Ohio.
22
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The following were identified by states as being motivational factors for
performing data entry at the state level:
Earlier availability of data
Higher data accuracy
Greater control over data
NLM is not easy to use
Need to track administrative information for fee programs
Problems with incorporating revisions.
States that enter data currently are committed to continuing with state data entry.
States that did not have systems cited inadequate resources and insufficient usage
of TRI data to justify developing then* own system. Some of these states that rely
upon the national database indicated that TRI data are not of sufficiently high
priority within the state currently to warrant initiating data entry programs; others
are already planning to go forward with their own data entry.
23
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The following were identified as being the largest current uses of the data:
To provide information to the public
To support programs, i.e. air toxics, pollution prevention
Other current uses of the data include:
To develop new management tools, i.e., emissions inventory,
help identify discrepancies with permits
To evaluate health risks, i.e., those associated with construction
applications and various permits
To conduct analyses, e.g., toxic loadings.
24
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I The following are what states perceive as being the benefits of state data entry:
Higher data accuracy because state personnel are more familiar with their
facilities, can recognize errors, and have a vested interest in correct
information
Data available in a more timely manner due to smaller number of forms
Revisions provided by facilities can be processed and incorporated more
quickly
State entry creates more of a sense of ownership, interest, and usage by
states
State entry reduces duplication of effort and may save resources
States have closer relationships with facilities and could work with them to
reduce reporter errors.
25
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The following are what states perceive as being problems associated with state
data entry:
Limited resources
All states may not buy in
States may have only parochial interests
Compatibility/normalization of data could be challenging
States may not be interested in entering all data elements or
conducting extensive quality checks on all elements. States want to
emphasize the elements that they use.
States do not want the data that they enter to be changed at the
federal level
Forms are currently being sent to two places; it will be difficult to
ensure that all forms and revisions are entered and to monitor when
they are entered.
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The following are recommendations made by the states with respect to jj
their data entry: jj
Data Elements: I
Consider utilizing only data elements currently entered, enter j
remaining at federal level I
Consider entering critical data (e.g., releases) first and making ||
available immediately 1
Allow states the flexibility to request additional information from jj
facilities on the reporting form and to maintain this data to support j
their work* I
Data Changes/Revisions: 1
Allow only the states to make changes to data ||
Limit the number of revisions that can be submitted each year |
Develop a tool for identifying when revisions or updates have been made ||
I Under the law states can now request supplemental information from facilities.
27
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Management and Financial Assistance:
Provide recommendations to states on how to organize and staff this
function
Provide the states with software.
Provide conditions in grants to encourage receipt of quality, timely data
Provide states with appropriate equipment.
State and Federal Communication:
Have forms submitted only to states; copies made for EPA
Develop communication mechanisms to ensure coordination between
states, Regions, and Headquarters
Establish standards initially and provide them to the states on issues, such
as facility name and other QA measures; work with states to develop these
standards.
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29
State
Capabilities
Enters data into a
computer
Plans to enter PPA
data
Number of data
elements entered
Number of
facilities/forms
Date by which data
are entered
Hardware/
software
QA
procedures
Level of accuracy
ftofFTEsfor
TRI-related work
Texas
Tracking data
No
Approx. 5
1200/
6000
Sept.
fee data
PC/
Paradox
N/A
N/A
1 full-time +
part-time
California
Yes
No
All but,
chemical use,
waste mln., PPA
1800/
6000
Sept.
PC/ Oracle
Automated
checks &
manual
verification
of CAS and
emissions;
data entrv
99+%
1+ asst.
part-time
Indiana
Data from
natl system
No
Subset
only
900/
3300
N/A
Mac/
spread-
sheet
Internal
state review
of data
N/A
1
North
Carolina
Facility
info.
No
Approx.
15
1100/
2500
Sept.
PC/ dBase
100%
verification
of data
elements
N/A
1
Georgia
Yes
Yes
90%
730/
2470
Sept. or
Oct.
PC/QA
software
Automated
checks;
15%
verification;
100% check
over
Imillion Ibs.
90+%
1
Utah
Yes
Yes
All except,
waste min.,
120/450
Sept.
PC/
dBase
100%
verification
of data
elements
100%
2.5
Kansas
Yes
Yes
All
230/900
Sept.
AS400/
Hazox
N/A
unknown
10
Ohio
Yes
Not
certain
All exc. waste
mln., lat/ long,
POTW, stream
1,600/
6500
Sept.
PC
100%
verification
of data
elements
N/A
5
Mary-
land
Yes
Yes i
i
i
ID info, and
33 fields for
chemicals i
230/800
Sept.
j
j
PC/
dBase
100%
verification
of data
elements
90%
1
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30
| state^^^
I ^^''Capabilities
! Data uses
j Form Rs filed
i Creates customized
; reports
I Public can access
i system on-line
i Data available to
j public
i Publishes annual
j report
1 Funding
Interest in state entry
jRequire funding
Extra FTEs
i required
Texas
Reports,
tOXK
loadings,
air tones,
permits,
public, risk
assessment
Yes
Yes
No
100
requests/yr.
Yes
Fee
Program -
$100,000/
year
Yes, grant
application
Yes, will
consider Tees
Yes
California
Air toxics,
pollution
prevention,
ozone, public
requests
Yes
Yes
No
1210 requests
over 4 years
No
Funds from
hazardous
waste
program; all
state funds
Yes, consd.
for Region
Yes, will
consider fees
.5-1
Indiana
Air toxics,
health
effects,
inspections
Yes
Yes
No
100
requests/yr.
In 1987
Fed. grant
for data use;
no dedicated
funding
Yes, not top
priority
Yes, will
consider fees
2+
equipment
North
Carolina
Responds
to public
requests for
Form Rs
Yes
No
No
15-20
requests per
year
No
State
funds
Yes
Yes
4+
equipment
Georgia
Air toxics,
permitting,
compliance,
emergency
response
Yes
Yes
No
Yes
Yes
Fed. grant
for 311, 312,
added 313;
no dedicated
funding
Yes
Yes
3+
equipment
Utah
Air toxics,
and other
environ.
programs,
public
requests
Yes
Yes
No
Yes
Yes
State
funds
Yes, will
consider
Yes
No
Kansas
Reports,
toxic
loadings,
air toxics,
permits,
public, risk
assessment
Yes
Yes
Yes
175
equests/yr.
Yes
State
general
funds,
fees,
grants
Yes
Yes
0-.5
Ohio
Air toxics,
permits,
public,
stream
analysis
Yes
No
No
Yes
Yes
Fees,
grant
Yes
No
No
Mary-
land
Inspections,
permits,
air-mgmL,
33/50
analysis,
briefings
Yes
Yes
No
Yes
No
State
funds
Yes
Yes
Yes
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Interviews were conducted with personnel in the following
offices:
BRS
- Office of Solid Waste
- Regional and state BRS contacts
AIRS
- Office of Air Quality Planning and Standards
- Regional and state AIRS contacts
This section outlines the results of those interviews, including
recommendations to be taken into consideration if TRI adopts a
state-based approach.
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Purpose/Description
BRS, which is sponsored by the Office of Solid Waste, supports the
Resource Conservation and Recovery Act program.
Waste generators and waste treatment, storage, and disposal facilities must
report every two years on what hazardous wastes they generated and how
the wastes were managed.
Handlers provide data to states or Regions, depending on how authority is
delegated; all data entry is performed by the states and Regions.
Public access to the BRS data is currently available through FOIA requests,
and on NTIS tape.
The data are used primarily by states to support their SARA Capacity Plans
and by EPA to develop RCRA regulations and monitor the progress of the
RCRA program.
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BRS Similarities to TRI:
Generators are required to report what they have done in terms
of pollution prevention
Approximately the same number of reporting entities
Some overlap between reporters; about 7,000 - 8,000 BRS
handlers are also TRI reporters.
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Differences from TRI:
RCRA is a state delegated program
Data users are primarily internal to EPA and the states
Original BRS legislation does not encompass all BRS data elements,
including facility level data, and EPA has no actual authority to enforce
submission of data not included in the draft rule. A final rule, however,
is currently being promulgated.
Data base cannot be accessed by the public on-line, and a national data
base is not required by law
Handlers report every two years, not every year
In the past, there has been varying levels of management commitment to
this program
Data are electronically reported to the Regions from the states, and the
data must pass basic quality edits to enable extraction of data oy Regions.
Software for the states has non-mandatory edits for the states to perform.
EPA performs Regional and Headquarters data quality checks once data
are received.
34
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Difficulties Associated with Direct State Data Entry as Experienced by BRS:
States and regional offices receive limited funding, so there is marginal
incentive for states to participate
States collect data for their own use, and therefore focus primarily on their
own interests. States often collect and submit only data they use or data
required by law.
In the past, the data base was perceived as being a Headquarters data base
and some Regions believed it is not of much use to them
Data quality and consistency standards of state data are not at standards that
are acceptable to Headquarters, and will require additional funding to
improve.
Significant resources are required to ensure acceptable data quality, but
many states do not have enough resources
Timeliness of data submission is a concern because data is often not
submitted in a timely manner.
35
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Benefits Associated with Direct State Data Entry (vs. centralized) as
Experienced by BRS:
Data entry at the state level is accomplished quicker than at a Regional
level if there is adequate funding
This approach encourages states to have a stake in BRS. It improves a
state's understanding of its hazardous waste material, and this
understanding can be used in other program activities.
States are more knowledgeable about certain facilities than EPA staff.
36
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Purpose/ Description
AIRS is the national repository for information about airborne pollution in
the U.S. It has four subsystems: Air Quality Subsystem (AQS); Air
Facility Subsystem (AFS); Geo-Common Subsystem (GCS); and the
Area/Mobile Source Subsystem (AMS)
Interviews for this task focused on AFS because it was determined to be
most relevant for TRI's purposes. AFS tracks emissions and compliance
data from industrial plants.
Emissions data is gathered from the facilities through surveys that each
state (or local organization) develops
Data entry approach differs by state; some states do direct online entry
(approximately 20); others use their own systems to create a tape which is
then converted; others submit manual reports to the Regional offices
where the data are entered (limited); AIRS is updated nightly.
37
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Purpose/Description
Coding conventions were established in the user's manual.
States had to develop QA/QC plans for ozone data and have them
approved by the Regional office.
AIRS has automated edit checks and verification is performed on some
data.
Ongoing training is provided for Regions and states
All states are funded to some extent by EPA grants (105 grants)
EPA's National Computing Center provides connectivity to all states and
free time share
38
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AIRS Similarities to TRI:
AIRS has automated edit checks
Some overlap exists in terms of air toxics.
39
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AIRS Differences to TRI:
Air is a state-delegated program
Regional offices are active with AIRS, assisting with quality assurance
AIRS does not currently allow direct public access
Data does not receive the same level of quality assurance as TRI data
across all fields. Managers are extremely confident of the accuracy of
some data and concerned about the accuracy of others.
All data are not facility reported. Some data are measures of state activity
with respect to inspections, enforcement actions, and therefore the states
report the data themselves. States also estimate facility emissions and
report the data.
Some grant awards are based upon the level of activity that the states
report to AIRS, so states have an incentive to participate
Some data elements allow two entries, one for the federal and one for the
state.
40
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Benefits Associated with Direct State Data Entry (vs. centralized) as
Experienced by AIRS:
Data entry at the state level is accomplished quicker than it was with
the Regional approach
Fewer people handle the data creating less opportunities for error
This approach encourages states to have a stake in AIRS
States are more knowledgeable about certain facilities than EPA
staff.
41
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Difficulties Associated with Direct State Data Entry as Experienced by AIRS:
Difficulty in obtaining all necessary data elements
Data conversion from tapes often introduces difficulties that require
additional time to resolve
Some states lack the resources to perform appropriate levels of QA
Timeframe for entering data is not definitive; many states perform
emissions data inventory entry as they are able.
42
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Recommendations:
Must convince states that they have a vested interest in using the
system; make system sufficiently flexible to serve state needs
Demonstrate use of the state's data so that they will recognize the
need for accurate, timely data
Provide sufficient resources for personnel and equipment
Need to consider the potential for integration between AIRS and
TRI data and the implications of this
Establish a state workgroup to negotiate approaches to state data
entry
43
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The interviewee lists on the following pages are organized as
follows:
Headquarters
Regional
State
System Managers.
44
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George Bonina, Office of Pollution Prevention and Toxics, Information
Management Division, Deputy Director
Ruby Boyd, Office of Pollution Prevention and Toxics, Information
Management Division
Sarah Hammond, Office of Pollution Prevention and Toxics, Environmental
Assistance Division, State Liaison
John Harmon, Office of Pollution Prevention and Toxics, Information
Management Division
Bob Janney, Office of Pollution Prevention and Toxics, Environmental
Assistance Division, Regional Liaison
Steve Newburg-Rinn, Office of Pollution Prevention and Toxics,
Information Management Division, Public Data Branch Chief
Janette Peterson, Office of Pollution Prevention and Toxics, Information
Management Division
45
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Doug Sellers, Office of Pollution Prevention and Toxics, Information
Management Division
Sam Sasnett, Office of Pollution Prevention and Toxics, Economics and
Technology Division
Linda Travers, Office of Pollution Prevention and Toxics, Information
Management Division Director
Mike Walker, Office of Enforcement, Toxic Litigation Division
Mike Wood, Office of Compliance Monitoring, Compliance Division
Janet Bearden, Office of Compliance Monitoring, Policy Division
Bridget Sullivan, Office of Compliance Monitoring, Policy Division
46
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Sylvia Bell, CBSI, TRI contractor
Maxine Romo, CBSI, TRI contractor
David Waggoner, CBSI, TRI contractor
47
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Helen Burke, Region IX, Pesticides and Toxics Branch
Carlton Hailey, Region IV, 313 Coordinator, Pesticides and Toxics
Branch
Dennis Wesolowski, Region V, Pesticides and Toxic Substances
Branch
Warren Layne, Region VI, Pesticides and Toxics Branch
Bob Hickland, Region VI, Enforcement
-------
Steve Hanna, Chief, Office of Environmental Information, California
Environmental Protection Agency
Ken Rydbrink, Office of Environmental Information, California
Environmental Protection Agency
Fred Alvarez, Indiana Department of Environmental Management,
MIS
Robert Bierman, Indiana Department of Environmental Management,
Office of Air Management, Sr. Environmental Manager
Skip Powers, Indiana Department of Environmental Management,
Emergency Response Branch, Staff Director
Barty Titus, Indiana Department of Environmental Management,
Office of Air Management, Director
Bert Langley, Georgia Department of Natural Resources,
Environmental Protection Division, Emergency Response Program
Manager
49
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Carl Birns, Kansas Department of Health and Environment
Cindy Sferra-DeWulf, Division of Air Pollution Control, Ohio EPA
Marcia Mays, Toxic Registries Division, Maryland Department of
Environment, Program Administrator
Emily Kilpatrick, SARA Coordinator, North Carolina Department
of Emergency Management
Becky Kurka, Pollution Prevention and Conservation Division,
Texas Water Commission
Ken Zarker, Pollution Prevention and Conservation Division, Texas
Water Commission
Gena Guo, Pollution Prevention and Conservation Division, Texas
Water Commission
50
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Bill Laxton, Technical Support Division, OAQPS
Chuck Isbell, National Air Data Branch, OAQPS
David Misenheimer, Emissions Inventory Branch, OAQPS
David Mobley, Emissions Inventory Branch, OAQPS
Ron Ryan, Emissions Inventory Branch, OAQPS
Howard Wright, National Air Data Branch, OAQPS
Jill Vitas, Alliance Technology, contractor to OAQPS
George Czerniak, Region V, Chief Air Enforcement Branch
Kathy Ferland, Texas Water Commission, BRS
Joan Allen, Texas Water Commission, RCRIS
George Murray, North Carolina
51
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I WASHINGTON, D.C. ZQ46D
or
FCITIC1DCI ANO TOXIC SUBSTANCE
SEP 22 1988
Re: Revised Policy for Acute Toxicity Testing
Appended is a revised policy for evaluating the acute
toxicity of chemical exposures under the Federal Insecticide,
Fungicide and Rodenticide Act and the Toxic Substances Control
Act. This action builds upon a previous revision of. the acute
toxicity testing strategy to reduce the use of experimental
animals while providing adequate information about chemical
safety.
The Environmental Protection Agency is disseminating this
notice to industry, governmental bodies, scientific societies,
animal welfare groups and interested parties to apprise them of
our new position. The Agency's acute toxicity testing guidelines
are being revised to reflect the positions.articulated in this
policy.
Victor
Acting Assistant; Administrator
for Pesticides
and Toxic Substances
Enclosure
-------
Alternative Methodology for Acute Toxicity Testing
The Environmental Protection Agency announces a revision to
its approach to acute toxicity testing in fulfillment of actions
under the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) and the Toxic Substances Control Act (TSCA). This
revision reflects the Agency's concern about animal welfare and
its continued efforts to reduce the impacts on animals of EPA's
testing requirementsx While maintaining the tiered approach
adopted in 1984, the Agency now recommends (when appropriate) the
use of abbreviated test methods and consideration of using only
one sex, as a means of reducing the numbers of animals in
deriving important information on acute toxicity.
Background
EPA considers the evaluation of toxicity following short-
term exposure to a chemical (i.e., acute toxicity) to be a
limited but integral step in the assessment of the toxic
potential of a chemical substance under the regulatory framework
of its pesticide and toxic substances programs. The Agency also
supports measures dedicated to reduce the use of animals in
toxicity testing and conducts research on test methods which can
lead to further reduction or elimination of animal usage and
suffering. Through the careful selection of test methodology and
maximization of the data obtained from acute studies, EPA strives
to achieve a balance between the welfare of animals and the need
to utilize animals in evaluating chemical safety.
The approach to acute toxicity testing previously giver.
in EPA's Test Guidelines (U.S. Env. Prot. Agency, 1978; 1979)
emphasized the determination of the median lethal dose (LD50)
with a 95% confidence interval. A 1984 update of the guidelines,
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