'ASSESSMENT,' OF
DATA QUALITY IN THE' 1987
TOXIC RELEASE INVENTORY:
SITE VISIT PROGRAM
March 27, 1990
Prepared for:
Mr. Larry Longanecker
U.S. Environmental Protection Agency
Office of Toxic Substances 5(TS-779)
401 M Street, S.W.
Washington, D.C. 204,60
Prepared by:
Radian Corporation
2455 Horsepen Road, Suite 250
Herndon, Virginia 22071
DRAFT FINAL REPORT
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ASSESSMENT OF
DATA QUALITY IN THE 1987
TOXIC RELEASE INVENTORY:
SITE VISIT PROGRAM
March 27, 1990
Prepared for:
Mr. Larry Longanecker
U.S. Environmental Protection Agency
Office, of Toxic Substances (TS-779)
401 M Street, S.W.
Washington, D.C. 20460
Prepared by:
Radian Corporation
2455 Horsepen Road, Suite 250
Herndon, Virginia 22071
FINAL REPORT
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TABLE OF CONTENTS
EXECUTIVE SUMMARY vi
1.0 INTRODUCTION 1-1
1.1 EPA's Overall Quality Assurance Program 1-1
1.2 EPA's Site Visit Program 1-2
1.3 EPA's Pilot Survey 1-3
1.3.1 Methodology 1-4
1.3.2 Results 1-4
2.0 APPROACH 2-1
2.1 Survey Instrument 2-1
2.2 Sample Selection 2-3
2.3 Training 2-4
2.4 Arranging Site Visits 2-7
2.5 Site Visit Methodology 2-8
2.6 Data Collection and Calculations 2-9
2.6.1 General Information 2-12
2.6.2 Threshold Determinations 2-15
2.6.3 Release Estimates 2-18
2.7 Data Management and Data Quality . . . . 2-19
2.7.1 Data Management System 2-19
2.7.2 Data Weighting 2-20
2.7.3 Survey Bias 2-22
2.8 Wrap-up Meeting 2-25
3.0 RESULTS 3-1
3.1 Threshold Determination Results 3-2
3.1.1 Frequency of Errors in Threshold Determinations . . . 3-3
3.1.2 Sources of Errors in Threshold Determinations .... 3-5
3.1.3 Summary 3-11
3.2 Release Estimation Results 3-11
3.2.1 Accuracy of Release Estimation 3-12
3.2.2 Sources of Errors in Release Estimates 3-18
3.2.3 Release Estimation Techniques 3-23
3.2.4 Summary 3-24
3.3 Domains of Interest 3-24
4.0 CONCLUSIONS 4-1
5.0 RECOMMENDATIONS
5.1 Additional Reporting Guidance
5.2 Additional Areas of Study
APPENDIX A. SURVEY INSTRUMENT
APPENDIX B.-SAMPLE SELECTION PROCESS (ABT ASSOCIATES)
APPENDIX C. TRAINING MEETING AGENDA
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TABLE OF CONTENTS (Continued)
Page
APPENDIX D. SITE VISIT REQUEST INTRODUCTION LETTER D-l
APPENDIX E. REFERENCES USED BY FACILITIES E-l
APPENDIX F. WRAP-UP MEETING AGENDA AND SUMMARY OF ISSUES F-l
APPENDIX G. SURVEY DATA - G-l
APPENDIX H. SUMMARY OF PREFERRED ALTERNATIVE APPROACHES H-l
APPENDIX I. SUMMARY OF THE TOP TWELVE RELEASE ESTIMATE ERRORS FOR
EACH RELEASE MEDIUM 1-1
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LIST OF TABLES
Page
2-1 TARGET DISTRIBUTION OF FACILITIES AMONG THE FOUR DOMAINS
IN THE SITE VISIT PROGRAM 2-5
2-2 TARGET AND ACTUAL DISTRIBUTION OF FACILITIES AMONG THE FOUR
DOMAINS IN THE SITE VISIT PROGRAM 2-10
2-3 DISTRIBUTION OF FACILITIES AMONG SIC CODES 20-39 2.11
2-4 TYPES OF FACILITY PERSONNEL PRIMARILY RESPONSIBLE FOR
PREPARING FORM R REPORTS AT THE SURVEYED FACILITIES .... 2-13
2-5 REFERENCES COMMONLY USED BY SURVEYED FACILITIES TO ESTIMATE
RELEASES AND CONTROL EFFICIENCIES 2-14
2-6 APPROACHES COMMONLY USED BY FACILITY PERSONNEL TO MAKE
THRESHOLD DETERMINATIONS 2-17
2-7 TARGET UNIVERSE FOR THE SITE VISIT PROGRAM 2-21
2-8 EXPECTED PRECISION OF THE SAMPLE SELECTION PROCESS FOR THE
FOUR DOMAINS OF INTEREST 2-23
3-1 SUMMARY OF TOXIC CHEMICAL RELEASE QUANTITIES 3-13
3-2 FREQUENCY OF ERRORS IN NON-ZERO RELEASE ESTIMATES FOR EACH
RELEASE MEDIUM 3-16
3-3 FREQUENCY OF ERRORS IN ZERO RELEASE ESTIMATES FOR EACH
RELEASE MEDIUM 3-17
3-4 TYPES OF ERRORS MADE FOR THE TWELVE LARGEST-QUANTITY ERRORS
IN EACH RELEASE MEDIUM 3-22
3-5 THRESHOLD DETERMINATION ERROR RATES WITHIN THE FOUR DOMAINS
OF INTEREST 3-25
3-6 RELEASE ESTIMATE ERROR RATES WITHIN THE FOUR DOMAINS OF
INTEREST 3-26
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LIST OF FIGURES
Page
2-1 APPROACH USED TO PERFORM THE SARA TITLE III, SECTION 313
SITE VISIT PROGRAM 2-2
3-1 THRESHOLD DETERMINATION RESULTS: CHEMICAL COVERED UNDER
SARA TITLE III, SECTION 313 3-4
3-2 REASONS FOR INCORRECTLY INCLUDING CHEMICALS 3-6
3-3 REASONS FOR INCORRECTLY OMITTING CHEMICALS 3-10
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EXECUTIVE SUMMARY
As part of a continuing program to assess and improve the quality
of the data contained in the Toxic Release Inventory (TRI) database, the U.S.
Environmental Protection Agency (EPA) conducted a site visit program during
the summer of 1989. The goals for this program were to identify areas in the
SARA Title III, Section 313 data collection process that could be improved and
to provide a quantitative assessment of the accuracy of the data collected for
calendar year 1987. The program described in this report was developed
jointly by EPA and its contractors, Abt Associates and Radian Corporation.
The procedures used during the program were tested and refined during a pilot-
scale (25-site) program performed by Radian in the fall of 1988.
Recognition of a fundamental limitation of the Section 313 report-
ing process is crucial to both the understanding of and the use of the results
and conclusions of the site visit program. SARA Title III, Section 313
requires facilities to report releases of listed toxic chemicals into the
environment; however, the act does not require the facility to carry out new
monitoring and measuring to make estimates of these releases. Thus, specific
release estimates calculated by facility personnel may differ a great deal (or
very little) from actual release quantities. Whether any difference exists
depends on several factors, including the amount and quality of monitoring and
measurement data already available to the facility, the type of estimate
necessary if no monitoring data exist, and the nature of the process involved.
The objectives of this program must be viewed in light of this fundamental
limitation of the release estimation process. Also, the Form R chemical
report errors discussed in this report should be recognized as differences
from "better" estimates using available data rather than as differences from
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actual release quantities. Likewise, recommendations cited in this report are
oriented toward making better use -of available data and toward improving EPA's
understanding of what data sources may be useful. However, the quality of
release estimates contained in the TRI database will be limited by the quality
and the amount of data available to the reporting facility personnel.
To collect information for the 1987 TRI data quality assessment,
Radian engineers and scientists visited 158 industrial facilities, who sub-
mitted a total of 728 Form R chemical reports for 1987. Participation in this
program by these industrial facilities was voluntary, and they were assured of
anonymity. These facilities were randomly selected to represent the.entire
population of facilities submitting Form R chemical reports for calendar year
1987.
The site visits included conducting plant tours and interviewing
facility representatives. Site surveyors carefully reviewed all documentation
supporting the Form R reports and searched for errors in the threshold deter-
minations and release estimates made by facility personnel. Radian personnel
examined estimation techniques, checked calculations, and noted the types of
guidance materials used by the facilities. This information was recorded on a
survey instrument developed specifically for this program. Radian used a
detailed survey instrument and a surveyor training course to achieve
facility-to-facility consistency among the survey teams involved in the
program. The information from each survey instrument was reviewed to assure
quality and consistency and was then compiled in a computerized database.
As a result of this site visit program, the Agency now has a
database containing information on the quality of 1987 Form R report data.
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Because the sample population was carefully drawn to provide a valid
representation of most of the population of reporting facilities, this data-
base can be used for a variety of analyses, such as analysis of data quality
and error rates by SIC code, facility size, and release medium. However, the
current study was confined to performing an overall assessment of the 1987 TRI
data quality and then making recommendations for reducing error frequency in
future reporting years.
The most significant finding of the program was that the overall
quality of the TRI database is good. The data obtained from the site visits,
when compiled and generalized to the TRI database in general, revealed a
slight overall under-reporting of releases and transfers off-site of the total
national release quantity contained in the 1987 TRI data (based only on
reporting facilities). The most important limitation associated with this
finding was that it applies to aggregate data only, that is, some of the
apparent data accuracy comes from the cancellation effects of under- and over-
reporting of releases. When the total quantity of under-reported releases is
added to the total quantity of over-reported releases, the combined differen-
tial is less than 20% of the total national release quantity. This figure
provides a better sense of the accuracy of smaller segments of the TRI data-
base and is also a better indicator of the accuracy of the individual Form R
chemical reports.
The largest error source, both in frequency and in total impact on
the quantitative release estimate total, was not found in faulty calculations
or in poor estimation techniques, but in the misunderstanding and misinterpre-
tation of instructions and definitions associated with the Form R process.
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Data obtained during the site survey program indicated that about one-tenth of
the release quantities contained in the TRI database would have been omitted
had facility personnel correctly applied threshold determinations, activity
categories, and exemptions. Similarly, the number of missing release
estimates was approximately one-tenth of the total number of release estimates
in the TRI database. Better and more detailed instructions should reduce
these types of errors in the future. This project report provides details on
the specific types of mistakes most frequently made on the Form R chemical
reports and provides recommendations for specific areas of the instructions
that warrant revision. Additional guidance is also recommended for particular
steps in the reporting process.
The data quality assessment identified five major types of errors
in the Form R data reported by facilities for calendar year 1987:
Chemicals reported that need not have been reported
(incorrectly-included chemicals);
Chemicals that were not reported but should have been
reported (incorrectly-omitted chemicals);
Chemical releases that need not have been reported;
Chemical releases not reported that should have been
reported; and
Chemical releases reported that should have been reported as
a quantity greater than one order-of-magnitude different
than the reported quantity.
The limited testing and environmental monitoring performed by the
facilities made it difficult to assess the quality of the estimation tech-
niques used by these facilities in completing to the Form R chemical report.
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According to the survey, 'the vast majority of facilities estimated releases
using a combination of engineering judgment and material balance calculations,
Radian's site surveyors identified preferred alternative approaches for
estimating releases at less than 10% of the visited facilities.
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1.0 INTRODUCTION
Section 313 of Title III of the Superfund Amendment and Reauthori-
zation Act of 1987 (SARA) requires the U.S. Environmental Protection Agency
(EPA) to collect information concerning releases of chemicals to the environ-
ment from manufacturers, processors, and users of listed toxic chemicals. The
information collected under SARA Title III. Section 313 is useful for many
purposes, but primarily for informing the general public and the communities
surrounding affected facilities of releases of toxic chemicals, assisting in
focusing the Agency's research into the effects and control of toxic
substances, and aiding in the development of regulations, guidelines, and
standards. At the time the current study was initiated, approximately 68,500
first-year (1987) Form R chemical reports had been submitted to EPA by more
than 18.000 industrial facilities. When completed. 74,152 chemical reports
had been submitted by 19,278 facilities, and compiled in EPA's Toxic Release
Inventory (TRI) database.
1.1 EPA's Overall Quality Assurance Program
EPA needed to gain a sense of the accuracy of the TRI database
because of its wide audience and many intended uses. For this reason, EPA
designed and implemented a program to assess the quality of the data collected
under Section 313 and to identify areas where improved guidance would be
useful for improving the accuracy of future reported data. In addition to the
site visit program described in this report, EPA sponsored a telephone contact
survey program in which computer algorithms were used to screen for
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technically questionable data. EPA also conducted a confidential telephone
survey of facilities that may be subject to the requirements of Section 313,
but did not file any reports (the "nonresponders" survey).
1.2 EPA's Site Visit Program
EPA's site visit program was designed to provide a quantitative
assessment of the accuracy of the data collected for calendar year 1987 by
identifying both the frequency and the magnitude of errors in the Form R data
and the reasons these.errors occurred. The on-site review of industrial
processes, pollution control technologies, and documentation supporting the
Form R reports was designed to reveal:
Overlooked chemicals and releases that were not likely to be
identified in the telephone surveys;
Errors in the Form R reports submitted to EPA; and
Whether more reasonable release estimation techniques could
have been used, based on information available to the
facilities.
The results from this program can now be used to improve the Form R reporting
instructions, and thus improve the quality of information in the TR1 database
in future years. The quantitative assessment of the TRI database also pro-
vides a baseline for measuring the extent of data-quality improvement as
guidance changes are implemented.
Users of the results of the site visit program, as well as the TRI
database itself, should be aware of a basic limitation of the Section 313
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reporting process. Under SARA Title III, Section 313, facilities are not
required to perform any additional monitoring or measurement of the quantity
of toxic chemicals released to the environment to calculate Form R release
estimates. Therefore, the techniques' selected by facilities to estimate
releases depend on the nature of the data available to facility personnel, and
the quality of these release estimates in turn depends on both the proper
application of the estimation techniques and on the quality of available data.
At facilities where supporting data were available, surveyors carefully
examined the estimation calculations and data sources and then recalculated
the estimates. In many instances, the site surveyors were able to identify
data sources overlooked by facility personnel, and these new data were used to
recalculate release estimates during the site visits. Radian's site surveyors
also assessed the quality of the estimation techniques by recalculating
releases using alternative approaches where more accurate estimation tech-
niques were appropriate and where available data warranted.
1.3 EPA's Pilot Survey
Before conducting the full-scale site visit program, Radian
performed a limited, nonstatistical pilot survey program in the fall of 1988.
The purpose of this pilot survey was to confirm that the approach of perform-
ing site visits would add valuable information for assessing data quality and
would provide feedback that could be used to improve the Form R report. the
reporting instructions, and other guidance materials. The pilot survey also
provided information about the survey instruments used to collect the quality
assurance program data. The experience gained in the pilot survey also proved
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useful in planning, scheduling, and costing the full-scale site visit quality
assurance program conducted in the summer of 1989.
1.3.1 Methodology
For the pilot survey, Radian engineers and scientists visited 25
of the facilities described in the TRI database. At each facility, site
surveyors toured the industrial processing operations and storage and waste
treatment areas, reviewed supporting documentation, and interviewed facility
personnel. A detailed survey instrument was completed at each facility during
the site visit. The survey instrument was developed specifically for this
program to ensure consistency in survey procedures and documentation
materials. Surveyors assessed whether the facility personnel had reported the
correct chemicals, whether they had overlooked any uses of the chemical or
release media, whether they had used the best release estimation techniques
available, and whether they had accurately estimated releases.
1.3.2 Results
During the pilot survey, Radian visited 25 facilities representing
18 of the 20 Standard Industrial Classification (SIC) codes covered by SARA
Title III, Section 313 requirements. These facilities encompassed a wide
variety of process types, chemicals, waste streams and calculation methods,
and varying levels of technical skill among facility personnel who prepared
the Form R reports. A detailed account of the results of this pilot survey
are provided in a Radian report entitled Final Summary Report: Toxic Release
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Inventory Data Quality Assurance Site Visits (March 1989). Briefly, this
report concluded that the approach of performing site visits was an extremely
effective way to assess data quality, and that facility tours would provide an
environment for addressing items unlikely to be discussed in a telephone or
paper survey. The survey instrument was useful for conducting site visits,
although some revisions were recommended and implemented for the full-scale
site visit program. Also, various errors made by facility personnel in each
section of the Form R report as well as comments regarding data availability,
test and monitoring data, and documentation were summarized in the report.
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2.0 APPROACH
The approach for performing the site visit program, shown schema-
tically in Figure 2-1, consisted of the following steps:
(1) Developing a Survey Instrument:
(2) Selecting facilities to be visited (Sample Selection);
(3) Training site surveyors (Training);
(4) Arranging Site Visits:
(5) Performing site visits (Site Visit Methodology);
(6) Completing survey instrument for each site (Data Collection
and Calculations);
(7) Summarizing, generalizing, and reporting quantitative
results (Data Management and Data Quality); and
(8) Reviewing qualitative results (Wrap-up Meeting).
Each of these steps is discussed in the following subsections.
2.1 Survey Instrument
The survey instrument, shown in Appendix A, was designed to
facilitate Radian's review of threshold determinations and release estimates.
Each section of the survey instrument focused on identifying specific types of
errors made by facility personnel on their Form R submittals. The Radian
engineers and scientists who performed the site visits used the survey instru-
ment as a detailed checklist to ensure that all pertinent items were reviewed,
and also as a consistent format for recording both the data collected during
site visits and the errors made by facility personnel on their Form R reports.
In addition to its primary focus on chemical-specific information, 'the survey
instrument contained questions regarding the usefulness of the reporting
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Develop the
Survey Instrument
Develop a
Computerized
Data Management
System
Define the Goals
for the Sample
Selection Process
Select a Random
Group of Facilities
for the Sample
Obtain Facility's
Voluntary Participation
and Arrange Site Visits
Perform the Site
Visits and Complete
the Survey Instrument
for each Site
Internally Check the
Consistency of the
Completed Survey
Instruments
Enter and Verify
the Data in the
Data Management
System
Develop a
Training Manual
Train Site
Surveyors
Prepare for
each Site Visit
Hold an Informal
Wrap-up Meeting
to Discuss
Qualitative items
Summarize the
Results of the
Mrap-up Meeting
in a Memorandum
Generalize the Results
using Facility Heights
I
REPORT RESULTS
Figure 2-1. Approach used to Perform the SARA
Title III, Section 313 Site Visit Program
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instructions, the Title III telephone hotline, and the other published
guidance materials.
2 . 2 Sample Selection
Radian's goal in the sample selection activity was to select a
random group of facilities that vould represent the entire population of
facilities included in the TRI database. Observations made during the pilot
survey indicated that chemical industry facilities (Primary SIC Code 28) used
more complicated estimation techniques than did nonchemical industry facili-
ties, and that facilities reporting large-quantity emissions for chemicals had
different types of problems in estimating releases than did facilities report-
ing smaller quantities of emissions. Due to these differences, four domains
of interest (chemical industry facilities, nonchemical industry facilities,
large-quantity emitters, and small-quantity emitters) were created to assess
trends among these major categories. Radian elected to over-sample chemical
industry facilities and large-quantity emitters because of their relatively
large contribution to the overall emission quantities for the entire TRI
database.
A target of 150 facilities was selected as the number of facili-
ties needed to ensure the statistical validity of the data collected during
the site visit program. Appendix B provides a detailed discussion of the
procedure used by Abt Associates to select the sample jjroup of facilities, and
also provides a description of the weighting system (i.e., the number of
facilities in the TRI database represented by each sample point). Briefly,
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facilities submitting 151 or fewer Form R reports were divided into geographic
clusters on the basis of the first three digits in their zip codes. This
clustering approach was used to minimize costs by reducing travel costs and
travel time for site survey teams. A stratified sample of facilities was
drawn randomly from each of the sampled geographic clusters, based on the
desired number of site visits for the two stratifiers (chemical industry
facilities versus nonchemical industry facilities; large-quantity emitters
versus small-quantity emitters) discussed earlier. Table 2-1 shows the target
distribution among the four domains of facilities in the site visit program.
2.3 Training
Radian's goal in the training program was to ensure consistency
and high-quality work among all site surveyors. The first step in this
training program involved compiling a comprehensive training manual that would
be helpful both during and after the training session. The manual also was
designed as a reference document that would be useful when questions arose
during site visits. The manual included a copy of the survey instrument and
instructions for its completion, a copy of the pilot survey report, a discus-
sion of the surveyor's responsibilities on the project, a review of preferred
alternative approaches for completing release estimate calculations, and
'A site visit at a facility submitting 16 or more forms would have required
considerable time to complete. Limiting the visits to facilities with 15 or
fewer forms eliminated only about 2% of the facilities and 22% of the Form R
reports from the population sampled, thus including in the survey the maximum
number of facilities within available resources. Since a major element of the
study was to determine error sources, the larger number of facilities surveyed
gave a greater range of information on how facility personnel dealt with the
Form R reporting process and the information available to them.
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TABLE 2-1
TARGET DISTRIBUTION OF .FACILITIES AMONG THE FOUR DOMAINS
IN THE SITE VISIT PROGRAK
TARGET: 150 completed site visits
40 chemical industry facilities*
110 nonchemical industry facilities
75 large-quantity emitters8
75 small-quantity emitters8
*Chemical facilities were defined as facilities with Primary SIC Code" 28.
BA facility was defined as a large-quantity emitter when its reported release
to any medium for calendar year 1987 was greater than the 90th percentile for
that medium. Facilities without such releases were defined as small-quantity
emitters.
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copies of all guidance documents EPA had published concerning accurate com-
pliance with the Form R report instructions.
The second step in the training program involved holding a series
of training sessions to familiarize project personnel with program require-
ments. To minimize travel costs on the site visit program, Radian used
personnel from several of its offices across the country to conduct the site
visits. Personnel from the following Radian offices were used to arrange and
conduct the site visits: Austin, Texas; Herndon, Virginia; Los Angeles,
California; Milwaukee, Wisconsin; Research Triangle Park, North Carolina; and
Sacramento, California. In each of these offices, one person, the office
coordinator, took the lead role in managing the activities from that office,
including selecting site surveyors, training survey teams, scheduling site
visits, supervising site surveying activities, and performing quality
assurance review of survey instruments.
Radian central project staff trained office coordinators at a one-
day training session held in Radian's Herndon, Virginia office (the agenda for
this meeting is provided in Appendix C). The purposes of this session were to
train the office coordinators in their project duties and to prepare the
office coordinators to train the site surveyors. Each office coordinator then
trained the survey teams at his/her respective office. The final step in the.
training program consisted of each office coordinator thoroughly reviewing the
completed survey instruments with his/her site surveyors. This quality
assurance review allowed the office coordinator to identify and correct any
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problems as the program progressed and Co maintain consistency of approach
among the surveyors.
2.4 Arranging Site Visits
The program goal in arranging the site visits was to provide each
facility in the sample with an equal chance to participate in the site visit
program, thus ensuring the statistical validity of the program. Participation
in the site visit program was voluntary; the facilities were not legally
required to participate. A key factor encouraging voluntary participation was
the assurance of anonymity to the facilities. Names, locations, and all other
facility identification data were shielded from the Agency throughout the site
visit program.
As a first step, introduction letters (copies of these letters are
provided in Appendix D) were sent to each facility's technical contact, and
where appropriate, to each facility's senior management official. These
letters explained the purpose of the quality assessment program and the
anticipated burden on and benefits to the facility, and assured the facility
that all facility-specific data would be treated as confidential. Radian
followed these letters with telephone calls to the technical contacts at the
facilities to solicit their participation, and for those facilities agreeing
to participate in the program, to arrange a date for the site visit.
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2.5 Site Visit Methodology
The goal of the sice visit methodology was to collect all the
information needed to complete the survey instrument accurately, while mini-
mizing burdens on facility staff. To complete the site visit program as
efficiently as possible, the engineers and scientists staffing the program
were selected on the basis of their experience in performing environmental
audits of industrial processing facilities, and were required to have a
thorough understanding of chemistry, technical calculations, multimedia
environmental concerns, and pollution control technologies.
Thorough preparation for each site visit was crucial to meeting
the overall goals for the site visits. This preparation included gaining a
detailed familiarity with the reports submitted by facilities, the properties
(such as volatility or solubility) and uses of the chemicals to be reviewed,
the types of industrial processing operations to be reviewed, and the expected
efficiencies of the pollution control technologies employed at the facilities.
On-site survey activities included tours of the facilities, which
focused on material storage areas, industrial processing operations, and
pollution control equipment; careful review of all readily available documen-
tation; and interviews with appropriate facility employees regarding documen-
tation materials. The site visits were designed to reveal:
Overlooked chemicals and releases that were not likely to be
identified in the telephone surveys;
Errors in the Form R reports submitted to EPA; and
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Whether more reasonable release estimation techniques could
have been used, based on information available to the
facilities.
Site surveyors recorded these results on the survey instruments and reviewed
them with facility personnel before leaving the sites. After each site visit,
the appropriate office coordinator reviewed the completed survey instrument
for completeness and technical accuracy. Where necessary, follow-up phone
calls were made to facility personnel to clarify specific data.
2.6 Data Collection and Calculations
To obtain the EPA target of 150 facility site visits with the
distribution shown in Table 2-1, and based on the acceptance rates experienced
during the pilot survey, Abt randomly selected 280 facilities from the 1987
TRI database. Radian contacted the 280 selected facilities to request their
participation. The overall response rate was higher than expected, and a
total of 188 facilities agreed to participate in the site visit program. Of
these 188 facilities, 158 sites, distributed among the four domains of
interest as shown in Table 2-2, were visited. Table 2-3 shows the distribu-
tion among SIC codes of the 156 facilities having usable data.2 Surveyors
visited 26 facilities in the 10-49 employee range; 97 facilities in the 50-499
employee range; and 33 facilities with 500 or more employees.
2Two of the 158 sites visited had fewer than 10 employees and therefore
were not required to submit Form R reports. -These sites were deleted'from this
study as being nonrepresentative of the population under consideration.
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TABLE 2-2
TARGET AND ACTUAL DISTRIBUTION OF FACILITIES AMONG THE FOUR DOMAINS
IN THE SITE VISIT PROGRAM
TARGET: ISO completed site visits
40 chemical industry facilities*
110 nonchemical industry facilities
75 large-quantity emitters8
75 small-quantity emitters8
ACTUAL: 156 completed site visits0
44 chemical industry facilities*'
112 nonchemical industry facilities
78 large-quantity emitters8
78 small-quantity emitters8
AChemical facilities were defined as facilities with Primary SIC Code 28.
facilities were defined as large-quantity emitters when their reported
release to any medium was greater than the 90th percentile for that medium
reported for calendar year 1987. Facilities without such releases were
defined as small-quantity emitters. See page B-3 of Appendix B.
cln addition to the 156 site visits shown, site surveyors visited two other
chemical facilities that reported small-quantity emissions. These two
facilities had fewer than 10 employees and were deleted from the survey
program results.
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TABLE 2-3
DISTRIBUTION OF FACILITIES AMONG SIC CODES 20-39
Number of
SIC Code Description Facilities Visited
20 Food and kindred products 16
21 Tobacco products 0A
22 Textile mill* products 5
23 Apparel and other finished products
made from fabrics and other similar
materials 1
24 Lumber and wood products, except
furniture 2
25 Furniture and fixtures 2
26 Paper and allied products 14
27 Printing, publishing, and allied
industries 3
28 Chemicals and allied products 44
29 Petroleum refining and related
industries 0A
30 Rubber and miscellaneous plastic
products 7
31 Leather and leather products 0A
32 Stone, clay, glass, and concrete
products 2
33 Primary metal industries 16
34 Fabricated metal products, except
machinery and transportation
equipment 16
35 Industrial and commercial machinery
and computer equipment 5
36 Electronic and other electrical
equipment and components, except
computer equipment 11
37 Transportation equipment 7
38 Measuring, analyzing, and
controlling instruments;
photographic, medical and
optical goods; watches and
clocks 2
39 Miscellaneous manufacturing
industries 3
TOTAL 156B
ANo facilities in SIC Codes 21, 29, or 31 were visited for this program; each
of these SIC codes had fewer than 2% of the reporting facilities in the 1987
TRI data.
"Radian visited two additional chemical facilities, but they had fewer than 10
employees, and were deleted from the survey program results.
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At the 156 surveyed facilities having usable data, site surveyors
reviewed general information pertaining to the Form R report, as well as
specific information related to threshold determinations and release
estimates. Site surveyors reviewed 728 Form R chemical reports at these 156
facilities. The following subsections describe the information collected at
these facilities.
2.6.1 General Information
To identify trends among the surveyed facilities, site surveyors
reviewed general information on the type of personnel primarily responsible
for preparing the Form R reports and on the types of references used by these
personnel. Table 2-4 lists the six types of facility personnel identified as
primarily responsible for preparing the Form R reports at the surveyed facili-
ties. Facility staff, both nonenvironmental (47%) and environmental (29%),
were most frequently tasked with preparing Form R reports. Corporate environ-
mental personnel and outside consultants or contractors accounted for about
10% and 11% of cases, respectively.
Table 2-5 lists the types of references most commonly used by
personnel at the surveyed facilities to estimate releases and control
efficiencies. This table provides a summary of the information contained in
Appendix E, which contains details on the number of personnel using specific
references. The most frequently used references were those published specifi-
cally to support the Section 313 program. Further, certain industries
frequently used trade association data for reference; for example, the pulp
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TABLE 2-4
TYPES OF FACILITY PERSONNEL PRIMARILY RESPONSIBLE FOR
PREPARING FORM R REPORTS AT THE SURVEYED FACILITIES
Number of Facilities
Report Preparer Preparing Reports
Facility Staff 73
Facility Environmental Staff 45
Consultants or Contractors 17
Corporate Environmental Staff 16
Company President 3
Corporate Safety Department Staff 2
TOTAL 156
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TABLE 2-5
REFERENCES COMMONLY USED-BY SURVEYED FACILITIES TO ESTIMATE
RELEASES AND CONTROL EFFICIENCIES
Number of Facilities
Reference Using Reference
TRI Reporting Form R and Instructions 141
EPA 560/4-88-005
The Emergency Planning and Community Right-to Know 40
Act, Section 313 (40 CFR 372)
EPA 560/4-88-001
Estimating Releases and Waste Treatment 38
Efficiencies for the TRI
EPA 560/4-88-002
Title III Section 313 Release Reporting Guidance, 23
EPA 560/4-88-004 a through q, Estimating Chemical
Releases
Compilation of Air Pollution Emission Factors, 17
AP-42
Toxic Chemical Release Reporting Proposed Rule, 52 16
FR 21152, June 4, 1987
Industry Trade Association Materials 15
Privately Sponsored Seminar Materials 14
2-14
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and paper industry frequently used NCASI (National Council of the Paper
Industry for Air and Stream Improvements) emission factor data (9 of 14
facilities in the survey). By contrast, the chemical industry rarely used
trade association data (6 of 44 facilities in the survey).
2.6.2 Threshold Determinations
Threshold determinations and release estimates were reviewed
separately to identify the frequency, magnitude, and sources of errors in
these two areas. Site surveyors followed the stepwise approach described in
the Section 313 procedures for completing threshold determinations and release
estimates. In following the Form R reporting instructions, facilities must
first assess which chemicals are manufactured, processed, or otherwise used in
excess of appropriate thresholds. Facilities must then estimate and report
all releases of these chemicals exceeding a threshold to the environment, and
all off-site transfers of these chemicals in wastes to other locations.
To identify errors in the threshold determinations, site surveyors
looked for problems in a facility's documentation and, on the plant tour, site
surveyors looked for evidence of chemicals that were reported but need not
have been reported, and for evidence of chemicals that were not reported but
should have been reported. Each facility's documentation was reviewed to
track the decision process used to determine whether a chemical should have
been reported. Furthermore, site surveyors used all available documentation
to recalculate threshold estimates for reported chemicals and for chemicals
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present but not reported to verify the accuracy of facility personnel
calculations.
As part of the process of collecting data on threshold determina-
tions, site surveyors assessed the approaches commonly used by facility
personnel to make threshold determinations. Table 2-6 lists the eight
approaches most commonly identified as the mechanism by which facility person-
nel made their threshold determinations. The most common approach, the
purchase and inventory approach, involves calculating the total amount of a
chemical purchased during the calendar year, taking into account changes in
inventory levels. This approach usually includes using Material Safety Data
Sheets (MSDS) and other data to determine the concentration of chemicals in
the raw material.
In general, the other seven approaches, all of which are based on
engineering calculations, were used less frequently than the purchase and
inventory approach. However, there were certain situations in which these
other seven approaches typically were used. For example, the emission factor
approach was used frequently by facilities in the pulp and paper industry to
determine the quantity of certain volatile chemicals that are emitted to the
atmosphere immediately upon manufacture. Also, facilities commonly used the
mass balance approach to determine the quantity of sodium sulfate manufactured
as a by-product in wastewater treatment systems.
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TABLE 2-6
APPROACHES COMMONLY USED BY FACILITY
PERSONNEL TO MAKE THRESHOLD DETERMINATIONS*
Approaches
Purchase and inventory records
Engineering calculations based on:
Emission factors
Mass balance
Process recipes
Monitoring data
Production data
Hazardous waste manifests
Assumptions
*Table G-2 in Appendix G provides tables which define these approaches and
show their frequency of use among the surveyed facilities.
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2.6.3 Release Estimates
To identify errors in the release estimates, site surveyors
recalculated the releases during the site visits using the best data avail-
able. Site surveyors always recalculated releases using the same general
approach as the facility used. (Guidance materials for Section 313 identify
four approaches for estimating releases: use of monitoring data, emission
factors, mass balance, and engineering calculations.) Whenever the site
surveyor's experience and training indicated that a calculation approach
different than that used by the facility personnel was appropriate, the
surveyor attempted to obtain the data needed to calculate releases using the
more appropriate approach. In many such instances, data were not readily
available during the site visit to recalculate releases using the alternative
approach. In the few cases where site surveyors were able to recalculate
releases using alternative approaches, the site surveyors were able to assess
the reasonableness of the estimation techniques used by facility personnel.
Throughout the site survey program, site surveyors only reviewed release
estimates for those chemicals and media where it was appropriate to do so.
The surveyors quantified all numerical differences between the
facility's release estimates and the recalculated values, even in instances
where surveyors identified only small differences. As discussed later, these
numerical differences were used to quantitatively assess the accuracy of the
total aggregate releases contained in the 1987 TR1 database.
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To gain a sense of how frequently facilities made release estimate
errors, site surveyors examined release estimates using an order-of-magnitude
screen (i.e., the percentage of release estimates in which facilities under-
estimated or overestimated releases by more than a factor of ten). This broad
range (one order-of-magnitude) of difference was selected to identify error
frequency in the first-year Form R reports because the limitations on
available data and the variety of permissible estimation techniques suggest
that facility release calculations are of limited accuracy. Reduction in the
frequency of order-of-magnitude release errors in future reporting data should
provide a good indication of both greater understanding of revised guidance
materials and improved estimation techniques.
2.7 Data Management and Data Quality
2.7.1 Data Management System
To manage the sizable volume of data generated by the site survey
effort, Radian used PC-based SAS™ software as a database management tool
because of its powerful statistical capabilities.
Since this database has many intended uses, Radian took several
steps to ensure its high quality. As discussed earlier, the first quality
assurance step was to thoroughly and consistently train the site surveyors
before any site visits were performed. After each site visit was completed,
the office coordinator performed a quality assurance review of the survey
instrument before submitting the completed forms to the quality assurance (QA)
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team. The QA team performed a second review to assure consistency in .the work
performed by the various site survey teams. The twice-reviewed survey instru-
ment data then were entered into the database. The final step in the database
QA process was to verify the accuracy of the data entry effort. Project staff
randomly selected 40 of the 156 survey instruments (25%) for a data entry
verification test. The results from this test showed an error rate of less
than 0.4%.
2.7.2 Data Weighting
To allow EPA to assess the impact of the site visit program
results on the TRI database, weighting factors were applied to the site visit
data. These factors or "weights" represent the number of facilities in the
TRI database corresponding to each of the surveyed facilities. The weights
compensate for the sample selection probabilities introduced by the sample
selection process, in which chemical industry facilities and large-quantity
emitters were purposely over-sampled.
As discussed previously, Abt used a two-stage sample selection
procedure, involving geographic clusters and four domains of interest, to
select facilities for the site visit program. Table 2-7 shows the target
universe for the site visit program distributed among the four domains. The
universe represents 17,622 of the 18,000 facilities in the TRI database (98%),
corresponding to 53,385 of the 68,500 chemical reports in the TRI database
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TABLE 2-7
TARGET UNIVERSE FOR THE SITE VISIT PROGRAM*
Domain Number of Facilities
Chemical Industry Facility 3,610
Nonchemical Industry Facility 14.012
TOTAL 17,622
Large-Quantity Emitter 2,206
Small-Quantity Emitter 15.416
TOTAL 17,622
AThis universe is further "discussed in Appendix B.
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(78%).3 Inferences can be applied with a known degree of sampling error to
this universe. The potential error associated with applying the site visit
program results to the remaining 2% of facilities in the TRI database,
representing 22% of chemicals in the TRI database, cannot be- quantified from
the data generated by this study.
2.7.3 Survey Bias
To place boundaries on the accuracy of data collected and analyzed
during the site visit program, project staff analysts reviewed the sources of
bias in the program approach and assessed their implications. The following
three primary areas in the program approach were identified as producers of
bias:
Sample selection;
Surveying; and
Data reduction and analysis.
A sampling bias was introduced to the program results because the
sample for this program was limited to approximately 150 facilities.
Table 2-8 presents the expected precision of results at the 90% confidence
level for the total sample and for the four domains of interest. As an
example, with 90% confidence, the actual population percentage for large-
quantity emitters is expected to be between 40.3% and 59.7% when the sample
3At the time the current study was initiated, approximately 68,500 chemical
reports had been submitted to EPA by approximately 18,000 industrial facilities.
These data were entered in the 1987 TRI database. Subsequent to this study, EPA
completed the TRI database, which now includes data from approximately 70,000
chemical reports from approximately 19,000 facilities.
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TABLE 2-8
EXPECTED PRECISION OF THE SAMPLE SELECTION PROCESS
FOR THE FOUR DOMAINS OF INTEREST*
Domain
Chemical Industry Facilities
Nonchemical Industry Facilities
Large-Quantity Emitters
Small-Quantity Emitters
TOTAL SAMPLE
Expected Usable Level of Precision
± 13.3%
± 8.0%
± 9.7%
± 9.7%
± 6.9%
ADesign precision is discussed further in Appendix B. The precision levels
shown are at the 90% confidence level.
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percentage equals 50%. Thus, if 50% of large-quantity emitters report using a
specific calculation approach (such as mass balance), the odds are 90 in 100
that the population percentage value will be between 40.3% and 59.7%. Sample
selection precision levels are discussed further in Appendix B.
A surveying bias was introduced to the program results because
approximately 40 surveyors were used to conduct the site visits. However,
Radian took several steps to minimize the impact of personal bias in the
surveying process, including using a standardized survey instrument, thorough-
ly and consistently training each site surveyor, and carefully checking the
completed survey instruments before data entry.
A data reduction and analysis bias also was introduced to the
program results due to the use of four assumptions intended to simplify survey
data reduction and analysis:
Incorrectly-omitted releases were quantified using the
lowest range suggested by the reporting instructions (1-499
pounds) unless sufficient data were available to calculate a
larger release;
Review of the 22% of the Form R chemical reports (those from
facilities submitting more than 15 reports) included in the
TRI database, but not addressed by this program, would
produce results similar to those documented by the site
survey program;
A quantitative assessment of the impact of nonresponding
facilities on the TRI database would not change the site
survey program's conclusions; and
The total aggregate releases from incorrectly-included
chemicals were equal to those from incorrectly-omitted
chemicals.
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This latter assumption, concerning aggregate releases for chemical
reports that were not submitted by facility personnel, likely underestimates
total release quantities, because release quantities associated with incor-
rectly included chemicals tend to be small, while release quantities
associated with omitted chemicals could be higher.
In general, these program biases likely do not introduce suffi-
cient bias to substantially change the conclusions discussed later in this
report. However, a limited analysis of the quantitative impact of these
biases on the program's conclusions should verify whether there is any impact.
2.8 Wrap-up Meeting
After the site visits were completed, Radian held a debriefing
wrap-up meeting with all office coordinators at its Herndon, Virginia office.
Each office coordinator previously had conducted a debriefing meeting with
his/her site surveyors. During the wrap-up meeting, attended by representa-
tives from Abt and EPA's Office of Toxic Substances, office coordinators
discussed the qualitative observations from the site visits and provided input
for improving future efforts. The agenda for the wrap-up meeting, and a
memorandum summarizing the items discussed, are provided in Appendix F. The
two key qualitative observations discussed were that:
(1) Radian's site visits relied heavily on documentation and
insight provided by facility personnel (the one- or two-day
site visits provided only enough time to briefly tour
facilities and to review readily available records); and
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(2) The threshold determination and release estimate results
were limited by the quality and the amount of information
facility personnel had readily available for review.
Overall, the facilities' documentation was often found to be poor, which made
the task of assessing the quality of the reported release quantities more
difficult.
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3.0 RESULTS
This section presents the site visit program results and their
implications to the Toxic Release Inventory (TRI) database. The analysis of
the results focuses on errors in threshold determinations and release
estimates to allow EPA to assess data quality and determine where improved
reporting guidance would be most effective. This section provides a summary
of the results with regard to the following questions:
(1) Threshold Determinations. Did facilities include the
Section 313 chemicals they were required to report? If
facilities made errors in threshold determinations, what
were the reasons for the errors?
(2) Release Estimates. For chemicals that were correctly
included, what is the impact on the TRI database of the
errors facilities made in their release and off-site trans-
fer estimates? If facilities made errors in their release
and off-site transfer estimates, what were the reasons for
the errors? Given the data readily available for making
release estimates, did facilities use reasonable release
estimation techniques?
(3) Domains of Interest. Did the Form R chemical reports
submitted by chemical industry facilities contain fewer
errors than those submitted by nonchemical industry facili-
ties? Did the Form R chemical reports submitted by facili-
ties where large-quantity emissions were reported contain
fewer errors than those submitted where small-quantity
emissions were reported?
Because Form R preparers went through two major steps, threshold
determination and release estimates, the analysis of error in Form R chemical
reports for these two areas were reviewed separately. Four domains of
interest (chemical industry facilities, nonchemical industry facilities,
large-quantity emitters, and small-quantity emitters) were selected to help
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EPA determine where to focus future resources for improving the TRI database.
The survey data upon which these summary results are based are shown on tables
in Appendix G.
3.1 Threshold Determination Results
Section 313 requires facilities to determine which of their
chemicals are manufactured, processed, or otherwise used in excess of
.appropriate thresholds. These chemicals must be reported to the Agency using
a Form R chemical report. The threshold determination actually consists of
three steps:
(1) Assessing which activities are appropriate for each
chemical;
(2) Computing the amount of chemical manufactured, processed, or
otherwise used during the calendar year; and
(3) Determining if this quantity exceeds the applicable
threshold.
A further complexity of Section 313 is that facility personnel may exclude
some or all of a chemical's activity if it meets one of several exemptions.
(The exemptions include de minimis concentrations, laboratory activities,
processing and use of articles and certain use provisions.) Each of these
exemptions may be incorrectly applied by facility personnel, and may cause
them to either incorrectly include or incorrectly omit a chemical from its
proper reporting. Tables G-l through G-4 in Appendix G contain the threshold
determination survey results, which are summarized and discussed in the
following section.
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3.1.1 Frequency of Errors in Threshold Determinations
Radian examined threshold determinations made by the surveyed
facilities to determine whether the facilities reported the Section 313
chemicals they were required to report. This examination resulted in four
threshold determination categories: two that represent correct threshold
determinations and two that represent incorrect threshold determinations.
These four threshold determination categories are:
Chemical was reported and should have been reported
(correctly included);
Chemical was reported but need not have been reported
(incorrectly included);
Chemical was not reported and should not have been reported
(correctly omitted); and
Chemical was not reported but should have been reported
(incorrectly omitted).
Facilities generally included the Section 313 chemicals they were
required to report and omitted the chemicals they should not have reported.
However, error rates observed in the survey results, when applied to all
reporting facilities, suggest that approximately 6,000 chemical reports were
incorrectly omitted and that approximately 8,000 chemical reports were
incorrectly included in the 1987 TR1 database.4 These overall findings are
displayed graphically in Figure 3-1. As shown in Figure 3-1, less than 40%
of the cases where SARA 313 chemicals were manufactured, processed, or
4This finding is exclusive of the Form R reports that should have been
submitted by nonresponding facilities.
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Incorrectly-Omitted
Chemical Reports
3%
Corrnctly-Omitted
Chemical Reports
59%
Correctly-Included
Chemical Reports
34%
Incorrectly-Included
Chemical Reports
4%
Note:
The survey identified
approximately 60. 000
correctly-included
chemicals in the
1987 TRI database
Figure 3-1. Threshold Determination Results:
Chemicals Covered Under SARA Title III. Section 313
-------
otherwise used by facilities submitting Form R reports to EPA were required to
be reported under Section 313. The remaining 60% of the cases were excluded
through the threshold and exemption process described earlier.
The survey results also indicate that 94% of the facilities in the
TRI database were correct in submitting at least one of the Form R reports
they submitted. Five percent of the facilities that did submit at least one
Form R report need not have reported at all under Section 313. A small group
(1%) need not have reported any of the chemicals they did report, but should
have reported other chemicals they did not report.
3.1.2 Sources of Errors in Threshold Determinations
The sources for the two types of threshold determination errors
are described below.
Incorrectly-Included Chemical Reports
The reasons for facilities incorrectly including chemicals on the
Form R reports are listed in Figure 3-2. The most common reason for incor-
rectly-included chemicals resulted from facility personnel reporting a chemi-
cal despite having calculated a quantity below, an applicable threshold.
Facility personnel probably erred by failing to understand the concept of the
threshold determination for this program, or perhaps by wanting to be
conservative (i.e., reporting a chemical because the calculated quantity was
near the applicable threshold).
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Incorrectly-Omitted
Chemical Reports
3X
Correctly-Omitted
Chemical Reports
59X
Correctly-Included
Chemical Reports
34X
Incorrectly-Included
Chemical Reports
4X
REASONS FOR INCORRECTLY INCLUDING CHEMICALS
• Facility personnel reported chemical despite
calculating a quantity below applicable threshold
• Facility personnel misinterpreted a chemical qualifier
• Facility personnel miscalculated a chemical quantity
• Facility personnel misinterpreted an exemption clause
• Facility personnel misinterpreted the list of chemicals
covered by Section 313
• Facility personnel misclassified a chemical activity
• Facility personnel incorrectly assumed thresholds
were exceeded, without supporting documentation
Figure 3-2
3-6
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Another common error involved misinterpreting chemical qualifiers.
For example, isopropyl alcohol was. frequently reported as an "otherwise used"
chemical although reporting is required for isopropyl alcohol only when it is
manufactured by the strong acid process. Other instances of misinterpreted
qualifiers involved metals (aluminum, vanadium, and zinc), where reporting is
required only when the metals are used in a fume or dust form. Numerous
facilities reported use of such metals but did not handle the material as fume
or dust. Strengthening the presentation of these qualifiers in the Form R
instructions and guidance documents should help eliminate this problem
Another frequent type of error facilities made in threshold
determinations was in miscalculating quantities. This type of error typically
resulted from several sources:
Estimating the amount of a constituent chemical in a raw
material instead of using composition data available in the
Material Safety Data Sheet;
Overlooking one area of chemical activity at a facility;
Assuming that a chemical was a by-product of processing or
an impurity in the raw material without supporting documen-
tation; or
Calculating threshold amounts based on amounts of chemicals
circulated in closed-loop systems instead of only the
amounts of makeup chemicals added to the systems during the
year.
The other types of errors listed in Figure 3-2 occurred less
frequently than those discussed above. Generally, these errors involved
facility personnel misinterpreting a specific item in the reporting
instructions. such as an exemption clause, misreading the list of chemicals
3-7
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reportable under Section 313, or not understanding the definitions of the
activity classifications. Although activity classifications5-were frequently
misinterpreted (approximately 20% of the activity classifications were
reported incorrectly, especially the manufacturing and processing classifica-
tions) , this error rarely led to a chemical being incorrectly included in the
TRI database (or omitted from the TRI), since the quantity involved usually
exceeded (or was below) the thresholds for both the correct and incorrect
activity classifications.
In a few instances, facility personnel assumed thresholds were
exceeded and made no calculations. Some of these chemicals need not .have been
reported. In these cases, the preparer's assumption regarding the chemical
quantity was simply incorrect. This was the least common type of error
identified.
Incorrectly-Omitted Chemical Reports
Application of the site survey results to the TRI database indr-
cated that approximately 6,000 chemical reports were incorrectly omitted from
the TRI database (i.e., chemicals that were not reported-but were manu-
factured, processed, or otherwise used above an applicable threshold). These
'Facility personnel were required to classify each reported chemical
activity as manufactured, processed, and/or otherwise used depending on its
specific application or applications at the facility.
3-8
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chemical reports were incorrectly omitted by 3,000 facilities in the TRI
database.6 The reasons for these omissions are shown in Figure 3-3.
The most common reason for incorrectly omitting chemicals was
facility personnel overlooking a chemical activity. The following chemical
activities were overlooked:
Manufac tur ing by-produc ts;
Wastewater treatment by-products;
Wastewater treatment chemicals;
Cleaning chemicals; and
Miscellaneous chemicals.
Approximately 75% of the incorrectly-omitted chemical reports were omitted
because one or more of these activities was overlooked.
Other reasons for incorrectly-omitted chemical reports include
miscalculating threshold quantities, misclassifving use activities, and
misinterpreting specific reporting instructions. Also, about 10% of the
exemptions claimed by industry were found to be incorrect. Most of these
exemption errors occurred in the "article" and "certain uses"7 category. The
"de minimis" and "laboratory" exemptions were generally applied correctly in
calculating thresholds.
6This finding does not include nonresponding facilities.
7The "certain uses" exemption includes use as a structural component of the
facility; use in routine janitorial or facility grounds maintenance; personal
use by employees or other persons; use of products containing toxic chemicals
for the purpose of maintaining motor vehicles operated by the facility; or use
of toxic chemicals contained in intake water (used for processing or noncontact
cooling) or in intake air (used either as compressed air or for combustion).
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Incorrectly-Omitted
Chemical Reports
3%
Correctly-Omitted
Chemical Reports
59X
Correctly-Included
Chemical Reports
34X
Incorrectly-Included
Chemical Reports
4X
REASONS FOR INCORRECTLY OMITTING CHEMICALS
• Facility personnel overlooked a chemical activity
• Facility personnel miscalculated a chemical quantity
• Facility personnel misclassified a chemical activity
• Facility personnel misinterpreted an exemption clause
Figure 3-3
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3.1.3 Summary
The results of the site survey program indicated that industry
reported most of the chemicals they were required to report. For chemical
reports incorrectly omitted, the most common reason was facility personnel
overlooking a chemical activity. For chemical reports incorrectly included,
the most common reason was facility personnel reporting a chemical despite
calculating a quantity below an applicable threshold. Finally, for the most
part, facilities accurately omitted a large number of Section 313 chemical
reports that need not have been reported (due to thresholds and exemptions).
3.2 Release Estimation Results
Section 313 requires facility personnel to report the total
quantity of each reportable chemical released to the environment and trans-
ferred in wastes off-site during the calendar year. Releases to the environ-
ment include emissions to the air, discharges to surface waters, and releases
to land and underground injection wells. Off-site transfers include chemicals
sent to publicly-owned treatment works (POTW) and other locations, such as
off-site landfills. Section 313 requires facility personnel to use all
readily available data to estimate release quantities as accurately as
possible.
Site surveyors assessed release estimates by recalculating the
releases using the same approach the facility personnel used, and by using
alternative approaches if they were available. The database compiled during
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the site visit program contains data for instances where the site surveyor
calculated a release estimate different than the estimate the facility
reported. 'These differences were used to assess the overall TRI database
release accuracy.
The following subsections focus on the overall accuracy of the TRI
database and on the sources of errors made by facilities in their release
estimates. Also, the quality of the release estimation techniques used by the
facilities is assessed. Tables G-5 through G-8 in Appendix G contain the
release estimate survey results, which are summarized and discussed below.
3.2.1 Accuracy of Release Estimation
The site visit program data showed that the aggregate 1987 TRI
database release estimates reported by industry generally were accurate, but
were slightly underestimated. Table 3-1 provides a summary of toxic chemical
release quantities by release medium. This table includes release quantities
as reported in the 1987 TRI and quantities that have been corrected based on
results from the site visit program.
The data also showed that some release estimates of sizable
quantities were over-reported or under-reported. .As a result, the accuracy of
the aggregate TRI release estimates is, to some extent, only "apparent"
accuracy caused by the cancellation effects of summing the overestimated and
underestimated quantities. The data showed that the total quantity over-
reported and under-reported were less than 10% of the total release quantity,
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TABLE 3-1
SUMMARY OF TOXIC CHEMICAL RELEASE QUANTITIES
Release Medium
Fugitive Air
Stack Air
Discharges' to Water
Underground Injection
On-site to Land
POTW
Other Off-site Transfers
TOTAL
Quantity of Chemical
Quantity of Chemical
Released, Adjusted by
Released, as Reported the Results of the Site
in the 1987 TRI
(billion pounds)
0.8
1.8
9.6
3.2
2.4
2.2
22.5*
Visit Program
(billion pounds)
0.8
1.9
9.9
3.2
2.7
2.0
2J.
23.0*
Quantities shown do not sum to total due to rounding effects.
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and that there were slightly more under-reported release quantities than over-
reported release quantities.
The site survey program data analysis included a separate assess-
ment of the frequency of errors for zero and non-zero release estimates for
the 62,000 correctly-included chemical reports in the 1987 TRI (i.e., chemi-
cals that were reported and should have been reported). Non-zero release
estimates are examined separately from zero release estimates because non-zero
release estimate errors give a better indication of the type of estimation
errors made by facility personnel. In contrast, facility personnel who
incorrectly omitted a release quantity either overlooked a specific type of
release or misinterpreted a specific instruction, rather than estimating a
quantity incorrectly.
Table 3-2 shows the number and percent of non-zero chemical
release estimates (by release medium) in the 1987 TRI that had what is called
a "large magnitude" release estimate error.8 Overall, roughly 84% of the non-
zero release estimates in the 1987 TRI were small magnitude errors correct
within an order-of-magnitude. Reducing the screening threshold to a factor of
two only decreased this value from 84% to 77%. For the chemical releases in
error by greater than one order of magnitude, Table 3-2 shows higher error
rates for discharges to water, on-site releases to land, and off-site
'Reference to the frequency of release estimate errors in this report
includes only large magnitude errors. Large magnitude release errors were
defined as non-zero release quantities more than one order-of-magnitude different
than the site surveyor's estimated value, or release quantities that should not
have been reported. The large magnitude error screen was used to assess the
general accuracy of non-zero releases since release calculations usually were
based on limited data that did not lend itself to very precise estimates.
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transfers to POTV than for air releases, discharges to underground injection
wells, or other off-site transfers.. Most of these errors were due to
incorrectly-reported releases, i.e., those that should not have been reported.
Further analysis of the site survey data showed that almost half
of the facilities represented in the 1987 TRI made at least one large mag-
nitude error in calculating non-zero chemical release estimates. Acids,
bases, and volatile organic compounds were the chemical groups most frequently
containing such release estimate errors. The previous finding that most non-
zero release estimates were correct within an order-of-magnitude seems to
contradict this finding concerning number of facilities. However, the data
showed that facilities reporting multiple chemical releases made only these
large magnitude errors in a small number of their release estimates.
The finding that almost half of the facilities made at least one
large magnitude error in calculating non-zero chemical release estimates seems
at first to be an apparent discrepancy with the overall finding that the
aggregate 1987 TRI database release estimates reported by industry generally
were accurate. However, a detailed review of these instances of error
revealed that these large magnitude errors usually involved small quantities
of chemical releases.
Table 3-3 shows the number and percent of chemical releases (by
release medium) in the 1987 TRI that should have been reported as a non-zero
3-15
-------
TABLE 3-2
FREQUENCY OF ERRORS IN NON-ZERO RELEASE ESTIMATES FOR EACH RELEASE MEDIUM
Release Medium
Number of Non-Zero
Chemical Releases in
1987 TRI
Number of Non-Zero
Chemical''Releases With a
Large Magnitude Error*
Fugitive Air
Stack Air
Discharges to Water
Underground Injection
Ons ite to Land
POTW
Other Off -site Transfers
TOTAL
29,000
33.000
3,500
450
2,200
13,000
22.000
103,000
3
2
1
*
3
16
,800 (13%)
,200 (7%)
,300 (37%)
66 (15%)
790 (36%)
,300 (33%)
.700 ^17%}
,000 (16%)
ALarge magnitude release estimate errors were defined as non-zero release
quantities more than one order-of-magnitude different than the site surveyor's
estimated value, or release quantities that were reported but should not have
been reported.
3-16
-------
TABLE 3-3
FREQUENCY OF ERRORS IN ZERO RELEASE ESTIMATES FOR EACH RELEASE MEDIUM*
Release Medium
Number of Chemical
Releases Omitted
From 1987 TRI
Number of
Chemical Releases
Erroneously Omitted
From 1987 TRI
Fugitive Air
Stack Air
Discharges to Water
Underground Injection
Ons ite to Land
POTW
Other Off-site Transfers
TOTAL
30,000
25,000
58,000
62,000
60,000
47,000
35.000
317,000
4,200 (14%)
3,900 (16%)
400 (<1%)
0 (0%)
300 (<1%)
1,600 (3%)
4.000 m%>
14,400 (5%)
"Number of zero chemical releases was based on 60,000 correctly-included
chemical reports in the 1987 TRI.
3-17
-------
value but were erroneously omitted from the TRI.8 Overall, approximately 95%
of the chemical releases omitted from the TRI for correctly-included chemicals
were correctly omitted. Most of the 5% of the erroneously-omitted chemical
releases pertained to air releases and off-site transfers to POTW and other
locations as seen in Table 3-3.
As stated above, most release estimate errors were due to incor-
rectly-reported and incorrectly-omitted releases, and resulted from facilities
misinterpreting instructions or overlooking chemical releases. Most estimates
not affected by these errors were accurate to within one order-of-magnitude,
and most were within a factor of two of the site surveyors' best estimates.
This finding confirms the previous finding that the aggregate 1987 TRI data-
base release estimates generally were accurate.
3.2.2 Sources of Errors in Release Estimates
Four general types of errors in the release estimates were iden-
tified in the survey data:
• Misinterpretation of reporting instructions;
• Use of incomplete information;
• Insufficient documentation to support release estimates; and
• Calculation and transcription errors.
Misinterpretation of reporting instructions and use of incomplete information
were the most common errors. Table G-6 in Appendix G provides a summary of
"These zero chemical releases include all release media reported as zero or
not applicable (N/A).
3-18
-------
Che frequency of each type of error at the surveyed facilities. The data
showed that facilities in the following SIC codes had the largest error rates
for release estimates:
20-Food and kindred products;
22-Textile mill products; and
34-Fabricated metal products.
Misinterpretation of Reporting Instructions
Where misinterpretation of reporting instructions occurred, it
usually concerned errors related to acid/base neutralization, recycle/reuse of
chemicals transferred off-site, metal compound releases, or the appropriate
use of the de minimis exemption. The acid/base neutralization error occurred
when facilities neglected to include the 100% treatment efficiency for an acid
or base in their release estimates. This error resulted in over-reporting of
acid/base releases (470 million pounds/year). If the pH of a liquid release
is maintained between 6 and 9 standard pH units, the reporting instructions
specify that ionic acids and bases (HC1, HN03, H2S04, and NaOH) are completely
(i.e., 100%) neutralized and should be reported as a zero release.
The recycle/reuse off-site error occurred when 'the surveyed
facilities reported a release for a chemical that was transferred off-site for
recycling or reuse as a fuel. This error also resulted in over-reporting of
releases (180 million pounds/year). The reporting instructions specify that
chemicals transferred off-site for recycle or reuse should be reported as a
zero release.
3-19
-------
The other cases of misinterpretation occurred only rarely.
Facilities misinterpreting the metal compound instructions erred by reporting
the release of a metal compound rather than the parent metal in the
compound(s). The reporting instructions specify that facilities should
include releases of parent metals only when considering releases for metal
compounds. This error also resulted in over-reporting of releases (60,000
pounds per year). Facilities incorrectly interpreting the de minimis
exemption applied this exemption to their waste streams, contrary to the
reporting instructions. The de minimis exemption states that if a listed
toxic chemical is present in a mixture, excluding waste streams, at a
concentration below a specified de minimis level, the chemical in that mixture
does not have to be factored into threshold and release determinations. This
error resulted in under-reporting of releases (28 million pounds per year).
Use of Incomplete Information
In cases where facility personnel erred in estimating releases,
they typically overlooked three sources of information: facility data,
chemical property data, and emission factor data. Facility data often over-
looked included waste manifests, process information, and monitoring data.
Where errors were found, facility personnel also frequently overlooked chemi-
cal property data, such as the volatility, solubility, and fate of chemicals
in certain media. Only rarely did facilities overlook published emission
factors for a process or treatment technology. These errors resulted in
under-reporting of releases (220 million pounds per year).
3-20
-------
Other Errors
In cases where the facility had insufficient documentation to
support a release estimate, surveyors typically could not readily locate
sufficient data to quantify a different release estimate. However, where
surveyors attempted alternative estimates based on engineering judgment, these
errors were estimated to result in under-reporting of releases (20 million
pounds per year). The survey also revealed arithmetic calculation errors. and
transcription errors (facility personnel incorrectly recording release
estimates on the Form R reports). Overall, arithmetic errors resulted in
under-reporting of releases (832 million pounds per year), while transcription
errors resulted in over-reporting of releases (76 million pounds per year).
To assess whether certain errors were typical for a release
medium, the types of errors made for the 12 largest-quantity errors in each
release medium were examined. The results of this review are presented in
Table 3-4. As this table shows, most air release and on-site land release
errors were due to facility personnel overlooking some type of information,
while water release errors (on site and to POTW) usually were due to facility
personnel misinterpreting acid/base neutralization or the manufacture of
sodium sulfate. Most other off-site transfer errors were due to facility
personnel misinterpreting items in the reporting instructions or making
transcription errors.
3-21
-------
TABLE 3-4
TYPES OF ERRORS MADE FOR THE
TWELVE LARGEST-QUANTITY ERRORS IN EACH RELEASE MEDIUM*
Misinter-
preted the
Release Reporting
Medium Instructions
Fugitive Air
Stack Air
Discharge to
Water
Underground
Injection
Ons ite to
Land
POTW
Other Off-
0
0
5
2
0
9
4
Used
Incomplete
Information
9
9
1
1
6
2
3
Made
Calculation
Errors
2
2
2
1
3
1
0
Made
Transcription
Errors
1
1
4
1
3
0
5
site Transfer
AAppendix I provides detailed information on the magnitude of the individual
errors summarized in this table.
3-22
-------
3.2.3 Release Estimation Techniques
To assess the quality of the release estimation techniques used by
facilities, instances where more accurate release estimation techniques were
identified by Radian surveyors were examined. As discussed earlier, the four
release estimation techniques outlined under Section 313 are:
(1) Monitoring data;
(2) Emission factors;
(3) Mass balance; and
(4) Engineering calculations.
Appendix H lists the few cases (less than 10% of facilities) in which alterna-
tive estimation techniques were identified among the surveyed facilities.
In most cases, the release estimation techniques used by industry
were reasonable. A few clear examples of more accurate techniques were found;
however, even using these techniques, the magnitude of error was not substan-
tially different than that experienced for the entire TRI database. These few
cases showed that the engineering judgment technique may lead to under-
estimated releases and that the emission factor technique may be a more
reasonable estimation approach for these situations.
As discussed earlier, the site visits were conducted in one or two
days, thus limiting Radian's ability to obtain the additional data necessary
to compute release quantities using alternative estimation techniques. A more
exhaustive audit, possibly combined with the ability to take some simple
measurements, would likely increase the possibility of locating sufficient
3-23
-------
information to calculate releases using alternative estimation techniques.
However, with the SARA Title III, -Section 313 condition that additional
measurements and monitoring are not required to prepare Form R reports, the
cases in which a preferred alternative estimation method is available may not
be numerous, even with a more extensive survey or audit.
3.2 .'4 Summary
Overall, facilities estimated total release quantities with
reasonable accuracy; however, there were numerous areas where better guidance
would improve data quality. Alternative release estimation techniques were
difficult to apply given the limited amount of readily available information.
3.3 Domains of Interest
One of the goals for the site survey program was to assess whether
there were trends in data quality based on the type of industry (chemical
versus nonchemical) or the reported size of the emitter (large versus small-
quantity). To perform this assessment, the chemical-specific error rates for
threshold determinations and release estimates were compared for the four
domains of interest. The data for this assessment are presented in Tables 3-5
and 3-6.
As shown in these tables, facilities'in the chemical industry
(primary SIC Code 28), and facilities that reported large-quantity emissions
(large-quantity emitters) consistently made fewer errors than did nonchemical
3-24
-------
TABLE 3-5
THRESHOLD DETERMINATION ERROR RATES
WITHIN THE FOUR DOMAINS OF INTEREST
Threshold
Determination
Domain*-8 Error Rate0
Chemical Industry Facilities 5.1%
Nonchemical Industry Facilities 8.4%
Large-Quantity Emitters 7-1%
Small-Quantity Emitters 7.7%
*Chemical industry facilities were defined by Primary SIC Code 28.
BLarge- and small-quantity emitters were differentiated by the quantity of
emissions reported on the Form R report by the facility. Large-quantity
emitters reported a release above the 90th percentile for a particular release
medium. (See page B-3 in Appendix B.)
^Threshold determination errors were defined as incorrectly-included chemicals
and incorrectly-omitted chemicals.
3-25
-------
TABLE 3-6
RELEASE ESTIMATE ERROR RATES
WITHIN THE FOUR DOMAINS OF INTEREST
Release
Estimate
Domain*-8 Error Ratec
Chemical Industry Facilities 23.0%
Nonchemical Industry Facilities 27.4%
Large-Quantity Emitters 19.5%
Small-Quantity Emitters 29.3%
AChemical industry facilities were defined by Primary SIC Code 28.
BLarge- and small-quantity emitters were differentiated by the quantity of
emissions reported on the Form R report by the facility. Large-quantity
emitters reported a release above the 90th percentile for a particular release
medium. (See page B-3 in Appendix B.)
GRelease estimate errors were defined as release quantities more than one
order-of-magnitude different than the Radian QA reviewer's estimated value.
3-26
-------
SIC codes and small-quantity emitters, respectively. This finding was true
for both threshold determinations .and release estimates.
The better performance by the "large emitter" domain may, to some
extent, be an artifact of the approach taken to the site survey program. The
use of an order-of-magnitude screen to identify errors means that extremely
large release numbers would have to pass through whatever review process was
employed by facility personnel, before being included in the completed Form R
report. It seems probable that very large release numbers would be subjected
to more scrutiny, and therefore fewer instances of erroneous reporting would
result.
As stated above, chemical industry facilities made relatively
fewer errors than nonchemical industry facilities. However, these relatively
fewer errors made by the chemical industry accounted for a relatively larger
quantity of release errors than the nonchemical industry, because of the
relatively larger release quantities involved. Further, the data show that
the chemical industry tended to under-report release quantities (especially to
receiving streams), while the nonchemical industry tended to over-report
release quantities.
With respect to the other two domains (large- versus small-
quantity emitters) the survey data showed that large-quantity emitters
accounted for relatively fewer errors, but a relatively larger quantity of
release errors than small-quantity emitters. Again, this result is due to the
relatively larger release quantities involved. Also, large-quantity emitters
3-27
-------
tended to under-report release quantities, while small-quantity emitters
tended to over-report release quantities. These trends are likely due to the
relatively larger quantities of releases associated with chemical industry
facilities and large-quantity emitters.
3-28
-------
4.0 CONCLUSIONS
The site visit program results revealed that most facilities
included in the 1987 Toxic Release Inventory (TRI) did a good job in perform-
ing threshold determinations and in estimating release quantities. The 1987
TRI database contains approximately 70,000 Form R chemical reports from
approximately 19,000 facilities, showing a total aggregate release of 22.5
billion pounds of toxic chemicals. The site visit program results revealed
that approximately 68,000 Form R chemical reports should have been reported by
18,000 facilities, with a total aggregate release of 23.0 billion pounds of
toxic chemicals. Thus, while the TRI database contains roughly 3% more Form R
chemical reports than it should, and roughly 5% more facilities than it
should, total aggregate releases were slightly under-reported. These numeri-
cal findings should be considered in light of the various limitations of the
site survey program, described earlier in this report.
The survey data revealed that facilities incorrectly included and
incorrectly omitted numerous chemicals with respect to threshold determina-
tions. These problems surfaced in cases where facility personnel misunder-
stood the threshold determination requirements, or where they overlooked
various chemical activities.
The survey data also revealed that facilities accurately estimated
total releases across the TRI with respect to release estimates, but that they
made 'numerous errors in individual release estimates. The data showed that
roughly 84% of all release estimates were accurate within one
4-1
-------
order-of-magnitude, given the constraints of the program. Data analysis
revealed that errors primarily resulted from facility personnel misinterpret-
ing reporting instructions, overlooking releases, using incomplete informa-
tion, poorly documenting release estimates, or making calculation and tran-
scription errors. Furthermore, the survey data showed that alternative
release estimation techniques were difficult to apply given the limited amount
of readily available data.
The survey data also revealed that chemical industry facilities
and facilities reporting large-quantity emissions consistently made fewer
errors (relative to the number of chances for making errors) than did non-
chemical industry facilities or small-quantity emitters, respectively. On the
other hand, the survey results showed that these relatively fewer number of
errors resulted in relatively larger quantities of release errors for both the
chemical industry facilities and the large-quantity emitters. These trends
probably result from the relatively larger quantities of releases associated
with chemical industry facilities and large-quantity emitters.
The data indicated that EPA guidance materials specific to the
SARA Title III, Section 313 program, especially the reporting instructions,
were the reference materials most commonly used by facility personnel in
completing Form R chemical reports. Many types of errors could be eliminated
through additional guidance. Because they are used so frequently, EPA docu-
ments would be a good vehicle for providing improved guidance. In some
industries (e.g., pulp and paper), trade association data was used heavily; in
4-2
-------
these cases, trade associations would be a good vehicle for improving
guidance.
4-3
-------
5.0 RECOMMENDATIONS
This section presents several recommendations for the SARA
Title III, Section 313 program based on the results and conclusions of the
quality assessment site-visit program. By implementing these specific recom-
mendations concerning additional reporting guidance and additional areas of
study, the quality of the data contained in future years' Toxic Release
Inventory (TRI) databases would be improved substantially. The scope of the
site visit program included categorizing reporting errors into discrete types
of errors and misinterpretations to allow EPA to focus improvement efforts on
the areas of highest potential yield.
Radian's site surveyors identified several specific reasons that
facility personnel made errors in their threshold determinations and release
estimates. In addition, the survey data revealed that certain facility
characteristics (e.g., chemical versus nonchemical industry facilities, large-
versus small-quantity emitters) and certain release media had distinct types
of errors. The recommendations presented below result from these findings.
5.1 Additional Reporting Guidance
(1) Additional guidance is needed concerning .what constitutes
"documentation." Section 372.10 (recordkeeping) of the
regulation cites the need for frequent documentation. New
guidance materials may include a specific definition and/or
a number of examples of what constitutes "acceptable"
5-1
-------
documentation. Surveyors found poor documentation in both
threshold determinations and release estimates at most of
the surveyed facilities; this generic problem led in turn to
errors in both threshold determinations and release
estimates.
(2) Additional guidance is needed concerning threshold deter-
minations. The survey results indicated that approximately
8,000 chemical reports are incorrectly included in the TRI
database, mostly because facility personnel did not under-
stand the concept of making threshold determinations. The
results also indicated that approximately 6,000 chemical
reports are incorrectly omitted from the TRI database,
mostly because facility personnel overlooked chemical
activities at their site. In making both types of threshold
determination errors, many facility personnel misinterpreted
specific instructions provided under Section 313. Addi-
tional clarifying guidance should be provided in the
instructions for the following areas in which particular
problems were identified with making threshold determination
calculations:
Threshold determinations;
Exemptions;
Activity classifications;
Calculations; and
Chemical qualifiers.
5-2
-------
(3) Additional guidance is needed concerning release estimates.
The survey resuLts showed that approximately 14% of the
release estimates in the TRI database are more than one
order-of-magnitude different than the Radian surveyor's
recalculated value. One of the primary reasons-for making
release estimate errors was that facility personnel mis-
interpreted the following items pertaining to release
estimates in the reporting instructions:
Acid/base neutralization;
Off-site recycle and reuse;
Metal compounds;
De minimis exemptions; and
Fugitive air emissions.
Additional clarifying guidance should be provided for these
areas.
Other reasons for release estimate errors occurred where
facility personnel used incomplete information or less-than-
preferred estimation techniques for computing release
quantities. Additional guidance should be provided on the
types of information and approaches preferred by EPA in
given situations.
5-3
-------
5.2 Additional Areas of Study
(1) The data reduction and analysis simplifying assumptions used
in this program should be quantified with respect to their
impacts on the program's conclusions. These assumptions
concern:
Incorrectly-omitted releases;
Incorrectly-omitted chemicals;
Form R chemical reports not addressed by this program;
and
Facilities not included in the TRI database (i.e.,
nonresponders).
(2) A comparative evaluation of data quality in the 1988 Toxic
Release Inventory should be performed to assess the effec-
tiveness of additional guidance materials and other outreach
programs targeted to the regulated community. While the
current study showed that chemical industry facilities and
large-quantity emitters did a better job than nonchemical
industry facilities and small-quantity emitters, respec-
tively, Radian believes that an across-the-board comparison
of data quality between the 1987 and 1988 TRI databases
would be beneficial.
(3) Further study is necessary to identify situations in which
the mass balance approach would be reasonable for estimating
releases. The survey showed that facility personnel
frequently used the mass balance approach to estimate
5-4
-------
releases (sometimes in combination with engineering calcula-
tions) when monitoring data were not available. Correlating
the release quantities with the throughput quantities for
each SIC code and other groupings that are appropriate given
the limited size of the database would allow EPA to assess
the usefulness of the mass balance approach.
5-5
-------
APPENDIX A
SURVEY INSTRUMENT
-------
Facility ID-
SECTION 313 REPORTING
QUALITY ASSURANCE SURVEY INSTRUMENT
A-l
-------
FaciLicy ID
DATE OF VISIT:
FACILITY OR ESTABLISHMENT NAME:
STREET ADDRESS-
CITY.
STATE:
TELEPHONE NUMBER:
CONTACT:
Radian office performing sice survey:
REVIEWERS: OFFICE COORDINATOR:
CODES FOR REPORTED CHEMICALS
Reported Chemical
Chemical(s) CAS » Code
B
H
LIST SECTION 313 CHEMICALS NOT REPORTED BUT EXPECTED TO BE USED BY THIS
INDUSTRY AS IDENTIFIED IN EPA PUBLICATIONS EPA 560/4-88-00&A THROUGH
EPA 560/4-88-004Q AND A REVIEV OF OTHER REPORTS IF THEY ARE AVAILABLE.
Chemical (listed prior to site visit)
o o
o o
o o
o o
o o
o o
o o
cml.103
A-2
-------
Facilicy ID.
SECTION 1.0
REPORT PREPARATION
1.1 Who prepared your reports--in particular, the release estimates?
(Check all that apply)
[ ] Facility Environmental Staff
[ ] Company Environmental Staff
[ ] Facility Staff
[ ] Consultant/Contractor
[ ] Other, specify
1.2 List all EPA documents and other references used to estimate -releases and
control efficiencies. If no references were used, check here [ ] and
continue to question 1.3. (Use 2-page list of codes.)
Reference Used
o o
o o
o o
1.3 If the reporting guideline document was not used, why not?
Reporting Guidance document was used. [ ]
Didn't know it was available. [ ]
Other, specify [ ]
1.4 Did you find the revised 1988 reporting guideline document more useful
than the previous version?
N/A - have not done comparison [ ]
Yes [ ]
No [ 1
cml.103
A-3
-------
FacilUy ID
1.5 Did you feel any section of the instructions.provided with the Form R vere
unclear? yes [ ] no [ ] If yes, check the appropriate section below arc.
briefly explain the difficulty encountered.
[ ] Part I. Facility Identification Information
[ ] Part II. Off-site Locations to which Toxic Chemicals are transferred
in waste
[ ] Part III Chemical specific information
1.6 Is the facility aware that chemical/material suppliers are required co
notify customers of all Section 313 chemicals in their products effective
in 1989? yes [ ] no [ ]
1.7 Did you call the Emergency Planning and Community Right- to-Know Hotline"1
yes [ ] no [ ]. If yes, did you find the operator's response helpful?
yes [ ] no [ J.
1.8 How many full-time employees does the facility have?
cml.103
A-4
-------
Section 2.0
All Chemicals Reported by the Facility
Facility I 0
Chemicals
Reported on
Form R(s)
A
B
C
D
E
F
G
H
1
J
K
L
M
N
0
Reported use
or Activity A
of Chemico™
•
Briefly Describe the Activities in
which the Chemical is Manufactured.
Processed, or Otherwise Used
(NA - Not a Section 313 Chemical)
Was (he Chemical '
Use or Activity
Cuneclly Determined'''
(Yes/No/NAjB
©M - Manufactured ffl
P - Processed II No. document on the following Section 20 worksheet
U - Otherwise. Used
6925E2R
- Not applicable (Reported chemical is not a listed Section 313 Chemical)
-------
Chemical Code:
Facility ID
SECTION 2.0 WORKSHEET
Chemical Code:
Chemical Code:
Chemical Code: D
Chemical Code:
Chemical Code:
Chemical Code:
Chemical Code:
cml.110
A-6
-------
Faci.li.cy ID
SECTION 2.0 WORKSHEET (continued)
Chemical Code:
Chemical Code:
Chemical Code: K
Chemical Code:
Chemical Code: M
Chemical Code: N
Chemical Code: 0
cml.110
A-7
-------
D
Section 3.0
Section 313 Chemicals used but not Reported Because Below
an Applicable Threshold Umft®
Cl»«fc>«r» It d»imrt i r«t ••€!!•• 313 CMBy««toiM»« but »»lf
FaeWly LO.
D
IBM 10. wtal WM th* UM i
10.
CliMntofll
1
a
3
4
O
0
T
•
•
10
^_ w^^^^ ^^^B ^^^^^^ta^^^B
•MdbvttoPMMMy
Wtal TVM of Aettlvllf
OMHMFaeMly
»p»ripttoU l«r Ikto/^
C^^^te^V IM P IL MAT
*^^^^M^V ^^^ »-f 1^ ••Mf
WMOM
A-iiilullu
CWTMll®
(VM/lto/WA)
WtalwMlMFMMly
••ttMl* •! OM
AMOIM!
MMMfaoturtt^L
Pr«o*>M4 «r
OUM*wto*lto*«T
C»/yr>
toOuppMilM
AModte^A&9
(VM/lto)®
CalculallMM
Waslh*
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•toll*
»»port
C«rr*«IT
(V*a/Ne)
>
oo
70.000 OM
70.000k*
IkJCtf 10.000 OM
®MA-»MOJIyOM>*l
M late. p^f^p^O^^B^O^ A^M ft
(•)•-•••
3.O wwkatect.
313<
•rt»»p»HiO>ii«M
r*vt*w «•>(•• 10 «
VDM-
• -
o-
NA-ri
•••MM 3.0 wwkvlM*!.
wotorti
r r*w4ta. stel*
» •! Ik* r*vl*w*r'a i
i
-------
Faci.li.cy ID
SECTION 3.0 WORKSHEET
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
cml.110
A-9
-------
Sectional
Section 313 Chemicals used but not reported because
they were overlooked ©
Faculty ID.
D
Ckirti h*r* M Ml
Ckeek k*r* M Ik* MM*** *l •«eUe« 313 CkMBtute •*<
> Uwy w*r* *«wto«li*tf to •reel** tta*. 1O. H tr**l«r
i 10. wfcal w*.*lk*l*MM«k*r**lr*p«rl*«*
nMMno*tfe*y
thMlO.wfc.
•••MM 319®'
•MA A^^^^vft^^
i
•
3
4
8
•
?
•
•
1*
towMehthtaClmriMlto
MM0 Wjf HM ™ ttfl^Ry
What Tya* •! AeMtvMy to
Appropriate Iw IM>^N
CtMododT (fiL p* IU ' ^'^
WlMltotMNcvtoww
ICttMl* •! Ik*
MMMlMtwa<
•»«O««»< «f fi)
(k/yr)
Mould Ihli
ClMMUcal haw*
b*MiH*pOfUd?
(V««/Ne)
3L*.
3131
>1*i
«i Ik* t»iiwto< SMlto* &• w*rk*lM*l.
i
-------
Facilicy ID
SECTION 3.1 WORKSHEET
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
cml.110
A-ll
-------
Section 4.0
Facility ID
Section 313 Chemicals used but not Reported Due to an Exemption Clause
a
Check here If not Applicable
Check hero If the number ol Section 313 Chemicals exempted is
greater than 10. If greater than 10 Section 313 Chemicals
exempted, what was the total number ol Section 313 Chemicals exempted?
Section 313 Chemical
nol Reported
1
2
3
4
5
6
7
8
9
10
Briefly Describe the Activities in which
this Chemical is used by ttie Facility
©
What was the Exemption Basis?
Was the Bosib lor (his Exemption
Correct (Yes/No)®
N)
© This section does not apply lo those chemicals used but nol
reported because below an applicable threshold llmH.
0 If mar* than 10 Section 313 chemicals were not reported due to
exemption, list the 10 with the greatest amount of use.
© 0 - Oe-Mlnlmls. Listed chemical Is present In a mixture below 1
percent, or 0.1 percent In the cose ol carlnogens.
A - Article, manufactured Items formed lo a specific shape during
manufacture, which has end use functions dependent on that shape.
and which does not release toxic chemical under normal conditions
of processing or uee at the facility
U - Uses, used as a structural component, routine janitorial or
facility groundkeoplng. maintenance, personal use by employees.
maintenance of motor vehicles, or use of toxic chemicals present In
process water and non- contact cooling water drawn from the
environment or from municipal sources, or air used as
compressed air or as part of combustion
L - Activities In Laboratories, used In a laboratory under a
the supervision of a technically qualified Individual.
S
0
If no. document on the following Section 4 0 worksheet.
-------
Facility ID'
SECTION 4.0 WORKSHEET
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
Chemical:
cml.110
A-13
-------
Section 5.0
Facility ID
Threshold Determinations for Reported Section 313 Chemicals
Section 313
Chemical
Reported
A
B
C
D
E
F
G
H
1
J
K
L
M
N
O
Is Supporting
Doc umentalion
Available?^
(Yes/No)®
What was the Estimate of
(he Amount Manufactured.
Processed, or Otherwise Used?
(lb/yr)P
Reviewer's
Use
Estimate®
Was the Chemical Amount
Used by the Facility
Above the Applicable
Threshold Limit?
(res/No£>
What Approach
Did the Facility
Use to Determine .-.
Threshold Ouanlily'P
i
H—
*-
© II No. document on the following Section S.O work sheet.
© On the following Section 5 0 worksheet, present a •ummary al the threshold
calculations ol both the reviewer and facllHy.
A - Proem recipes
8 - Purchata and Inventory Records
C - Cnalnearlng Judgement
0 - Other (specify In Section S 0 worksheet)
an
o>
CN
a>
to
-------
Chemical Code:
Faci.Li.cy ID
SECTION 5.0 WORKSHEET
Chemical Code:
Chemical Code: C
Chemical Code: D
Chemical Code: E
Chemical Code:
Chemical Code: G
Chemical Code: H
cml.110
A-15
-------
Facilicy ID
SECTION-5.0 WORKSHEET (continued)
Chemical Code.
Chemical Code:
Chemical Code: K
Chemical Code:
Chemical Code: M
Chemical Code: N .
Chemical Code: 0
cml.110
A-16
-------
FceWly I.D.
Section 6.0 Reviewer Checklist
Reported Section 313 Chemical
F /Q
to LflBtf CMI dto)
to fOTW
WMteTn
It ««y •»«• w«r« «««Uf«f ••yjirtittiithj •••^•••••rtMfcX 0 m to •vary MM* fw Mckia»wl«« •
-------
Facility I.O.
Section 6.0 Reviewer Checklist
3
4
5
6
0
10
Ararat*
•MtoTCyM/M)'
Pwi
lMtMltf>U.V*lto
Kt *) (g)
Boto? tbo f o0CNv*0 bttflto •€
rapwtetf •• HM P«m II U* C. «, O) 0
Ar* OMf • Mqr <
iMffw*
•r
Mrf»K>TW)T
W«r« n» §•!••••• If•• wa>U
ilrallHM*!
aia
lpnri«
Reported Section 313 Chemical
iMlltoMtoWkVlMllMir*
1
-------
Chemical Code:
Facility ID
SECTION 6.0 WORKSHEET
Chemical Code:
Chemical Code:
Chemical Code: D
Chemical Code: E
Chemical Code: F
Chemical Code: G
Chemical Code: H
cml.110
A-19
-------
Facilicy ID
SECTION -6.0 WORKSHEET (continued)
Chemical Code:
Chemical Code:
Chemical Code: K
Chemical Code:
Chemical Code: M
Chemical Code: N
Chemical Code: 0
cml.110 A_2Q
-------
Facility I D.
Section 7.0
Results of Detailed Calculation Review
(To be completed for each Reported Section 313 Chemical)
Chemical Code 10:
Release/®
Transfer
Fugitive Air
.Stack Air
Roc. Stream
Land On-site
Underground
Injection
POTW
Other Off-site
Max. On-site
Form
Entry
Pounds
Calculated*
by Same
Method
Reviewer Release®
Estimate
Ratio of "Form®
Entry to Reviewers
Approach"
'//////,
Q
9
For multiple entries (2 receiving streams), use total amount for that
medium.
Calculated using same approach/data used by facility.
estimate based on reviewer's judgment of a superior estimation method
given tho data available to the facility .and reviewer. State method on attached
calculation sheets.
A - facility underestimated by a factor of 1000 or more.
• - facility underestimated by factor of 100 to 999.
C - facility underestimated by a factor of 10 to 99.
0 - less than factor of 10 difference.
I - facility overestimated by factor of 10 to 99.
F - facility overestimated by factor 100 to 999.
6 - facility overestimated by a factor of over 1000.
H - facility Incorrectly omitted release quantity (I.e.. rotlo*0)
I - facility reported a releaase quantity that it should not have.
(I.e., ratlo»lnflnlty)
A-21
-------
Facility ID-
SECTION 7.0 WORKSHEET
Reviewer Release Estimates of Reported Section 313 Chemicals
Chemical Code: A
Chemical Code:
Chemical Code:
Chemical Code: D
Chemical Code:
cml.110
A-22
-------
Faci.li.cy ID.
SECTION 7.0 WORKSHEET (continued)
Chemical Code: F
Chemical Code:
Chemical Code:
Chemical Code:
Chemical Coda:
cml.110 A_23
-------
Faci.li.cy ID:
SECTION 7.0 WORKSHEET (continued)
Chemical Code:
Chemical Code:
Chemical Code:
Chemical Code: N
Chemical Code: 0
onl.110 A_24
-------
APPENDIX B
SAMPLE SELECTION PROCESS
(ABT ASSOCIATES)
-------
Saaple Selection Process
The pocencial respondent universe for the Evaluation of the Quality
and Accuracy of the Data Submitted by the Eligible Facilities in Compliance
with Section 313 Requirements consisted of approximately 18,000 responding
facilities. The 18,000 facilities submitted roughly 68,500 forms (i.e.,
chemical reports) in total, for an average of 3.8 forms per facility. The
distribution of facilities by number of forms submitted is shown below.
No. of Forms Percent
1
2
3
4
5
5-10
11-15
16*
Facilities submitting 15 or fewer forms account for 97.8 percent of the total
responding facilities. Because facilities with 16 or more forms are so few
and would have required a time consuming site visit, they were removed from
the sampling frame. So, too, were facilities in Alaska and Hawaii where it
would have been costly to conduct site visits due to the travel costs
involved.
The resulting sampling frame of responding facilities was divided into
geographic clusters. The clusters were formed on the basis of three-digit zip
code sectional centers. The distribution of facilities by these section
centers was examined and there were many that contained only a small number
(less than 25) of facilities. It was therefore necessary to combine adjacent
sectional centers to build up the clusters to a minimum size of 25 facili-
ties. It vas also necessary to remove remote sectional centers, with five or
fewer facilities, that could not be grouped in a consistent fashion with other
sectional centers.
The final respondent universe consisted of roughly 17,600 facilities
and about 53,400 chemical report forms. The final respondent universe
contains 97.8Z of facilities, and 78.02 of forms. It is to this universe that
inferences can be made with a known degree of sampling error.
B-l
-------
A two-stage sampling procedure was used to draw the sample of facili-
ties. At the first stage of sampling 54 zip code sectional centers or
sectional center groups were drawn with probability proportional to size (PPS)
sampling, .the measure of size being the count of facilities in the cluster.
At the second stage of sampling a stratified sample of facilities was drawn
from each of the 54 sample clusters. Two facility stratifiers were used.
Each defines key analytic domains of interest to the evaluation of data
quality and accuracy. By using these two variables of interest as
stratifiers, the sample size of site visits could be controlled and as dis-
cussed below, the desired level of precision for each analytic domain could be
met. The first was a two-category Standard Industrial Classification (SIC)
code variable:
• Primary SIC code equals 2800 to 2899. This covers
chemical manufacturing.
• Primary SIC code does not equal 2800 to 2899, but the
primary, secondary, or tertiary SIC code is in the 2000
to 3999 range. This covers all other manufacturing
facilities.
The population size and the desired number of facilities with completed site
visits at the time the sample.was drawn in April 1989 is shown below:
Approximate Desired
Population Number of
SIC CODE GROUP Size of Facilities Site Visits
Chemical Manufacturing 3,610 40
Other Manufacturing 14,012 110
17,622 150
The main objective of this stratifier is to allow for the comparison of
chemical manufacturing facilities with'all other manufacturing facilities.
The second stratifier categorized facilities into large versus small
emitters of chemicals to the environment. To create this stratifier it was
B-2
-------
necessary to first examine Che distribution of facilities by the number of
pounds of chemicals released to each of six media:
1. Fugitive or non-point air emissions and stack or point
air emissions,
2. Releases to receiving streams,
3. POTW,
4. All other off-site transfer,
5. On-site land disposal* and,
6. Deep-well injection on-site.
A threshold for defining a large emitter was set for each of the six media
using the 90th percentile of each individual facility distribution among
facilities with non-zero emission to that medium. The 90th percentile was
selected so that only the largest emitters would fall into the large emitter
stratification category. A facility was classified as a large emitter if it
fell in the large emitter end of the distribution for any of the six media.
If it did not cross the threshold for any of the six media then it was
classified as a non-large emitter. The threshold values for defining a large
emitter by mediums are shown below:
Threshold
Release to! (Ibs/year)
Water* > 100,000
POTWs* > 200,000
Air > 300,000
Off-Site Locations
Other than POTWs > 300,000
Land > 500,000
Underground Injection > 25,000,000
*Excludes releases of Sodium Sulfate
B-3
-------
The desired sampLe size of facilities in each of these two categories
is shown below. The population size of facilities in each stratum, at the
time the sample was drawn, is also shown:
Approximate Desired
Type of Population Size Number of
Emitter of Facilities Site Visits
Large 2,206 75
Non-Large 15.416 75
17,622 ISO
The main objective of this stratifier is to allow for the comparison of large
versus non-large emitters.
Other potential stratifiers such as number of forms submitted, number
of employees, total release amount, type of emission, type of chemical, and
presence of basic data errors in the forms submitted were also given con-
sideration in the design. The two selected stratifiers discussed above were
ranked highest (given a total sample size of 150 facilities) based on the
analytic needs of the study.
After consideration of the cost of conducting a single site visit, the
cost of travel to a zip code sectional center, and the expected low degree of
homogeneity of facilities within section centers, it was determined that a
reasonable initial sample size of facilities per section center was around
eight. With an expected response rate of around 60 percent, the typical
sectional center would yield about 4.8 completed site visits, and therefore, a
total of approximately 32 out of the 54 sample sectional centers would have to
be travelled to attain roughly 150 total site visits. The procedure of
selecting approximately 32 out of 54 zip code sectional centers is discussed
below.
It was very important to come as close as possible to the target of
ISO completed site visits, because of the considerable cost per site visit
compared to the typical cost per interview in a household survey. Although a
target response rate of 60 percent had been set, the actual response rate
might have turned out somewhat higher or lower than this, and furthermore, the
response rate might also vary across the four strata formed by the two
category SIC code variable and the two-category level of emissions
B-4
-------
scratifier. Keeping in mind the need to have a national probability sample of
facilities, a first-stage sample of 54 zip code sectional centers was drawn.
Before any facility sampling occurred, the sectional centers were sorted into
zip code order, a proxy for geographic ordering, and randomly subsampled into
nine replicates, each containing six zip code sectional centers. In the first
five replicates, containing 30 sample sectional centers in total, the
selection of a stratified sample of eight facilities per sectional center was
carried out.
The section of sample facilities involved three steps. First, the
desired marginal sample sizes were input into an iterative proportional
fitting algorithm along with the following population table:
Non-Large
Large
3,093
12,323
517
1,689
Chemical
Other
A set of expected cell frequencies was then derived under the constraint that
the cell frequencies satisfied the desired marginal sample sizes. The desired
cell (stratum) sample sizes are shown below:
Non-Large
Large
Chemical
Other
18
57
22
53
75 75
40
110
150
These stratum sample sizes were next allocated to the sample zip code
sectional centers with the objective of having a roughly self-weighting sample
of facilities for each of the four strata. The sample sizes actually
allocated to the zip code sectional centers were inflated to allow for an
expected 60Z response rate. The third step involved drawing a stratified
random sample of facilities without replacement from each sample zip code
sectional center.
The sample facilities in the 30 zip code sectional centers were then
contacted for participation in the site visits. The results of the first five
B-5
-------
replicates were used Co judge Che. overall response race (with a factor for
subsequent cancellations built in), and Che response rates in the four
strata. It turned out noc to be necessary co sample facilities in any
additional replicates beyond Che fifth.
Because site visits are expensive co conduce, Che minimum sample size
needed Co meet Che analytic and estimation needs of the study was determined
Co be around ISO. As noted above, estimates of percent of facilities with
various types of data' errors was to be computed for Che encire sample and for
Che four domains of interest. The sample was therefore allocated so that the
separate domain escimates chat are derived will all have a useable Level of
precision at the 90 percent confidence level as indicated below.1
Total Sample (n » 150) ±6.91
Chemical Manufacturers (n » 40) i 13.3Z
Other Manufacturers (n = 110.) i 8.0Z
Large Emitters (n = 75) i 9.7Z
Small Emitters (n = 75) i 9.7Z
The sample size allocated to chemical manufacturers is the smallest of the
domain sample sizes. One hundred ten of Che 150 facilities were allocated to
Che non-chemical manufacturing domain* because Che general expectation was
chat chemical manufacturers made fewer reporting errors than other types of
manufacturers.
The actual number of completed sice visits is very close to the
desired CargeC sample size as shown below:
Non-Large Large
Chemical
Other
19
59
25
53
78 78
44
112
156
A cocal of 156 useable sice visits were completed.
1 The calculation uses P » SOS sine* the variance (P(IOO-P) is largest for this value.
The 90 percent confidence lleits equal / 1.04 / 1.65 / 50(100-50)/n, where the design effect
due to clustering is assuned to be 1.04
B-6
-------
1C is necessary co use weighcs when drawing inferences to each of the
four domains, Che entire target universe, or other subclasses of interest.
The weighcs compensate for the unequal selection probabilities arising from
Che disproportionate allocation of the sample to the four strata.
The weighting methodology involved several steps. First, the
reciprocal of Che selection probability of each of Che 30 sample zip code
sectional centers in the first five replicates was computed. This was divided
by 5/9 to reflect the fact that only 5 out of Che 9 replicates were used.
This resulting zip code weight was multiplied times Che reciprocal of
che wichin zip code sectional center selection probability of each facility
where a site visit was completed. This quantity equalled Nnj/nhl» wnere Nhi
is the population count of facilities in che h-th stratum for che i-th zip
code sectional center and n^j is the corresponding count of sample facilities
where a sice visit was conducted. The produce equals Che facility weight.
The distribution of the 156 facility weights was examined, and values
above the 90th percencile of che discribucion were Cruneated Co che weight
value at the 90th percentile. The truncation procedure reduces increases in
sampling variance from unequal weighting. All facilities with a truncated
weight value are in che Other/Non-Large Emitter stratum, which was
undersampled.
The weights after truncation were then ratio-adjusted so that the
weighted discribucion by che four strata equalled the target universe
discribucion shown below.
Chemical/Non-Large
Chemical/Large
Ocher/Non-Large
Ocher/Large
The total weighted counc of reported chemicals equals 53,393,
B-7
-------
APPENDIX C
TRAINING MEETING AGENDA
-------
AGENDA FOR MAY 15, 1989 OFFICE COORDINATOR TRAINING
1. Opening Remarks TM
2. Introduce Training Program RW
3. Overview of SARA Title III, and Purpose of the Quality Assurance
Program TM
4. Results of the Pilot Survey KB
5 Office Coordinator Responsibilities RW
LUNCH BREAK
6. The Survey Instrument and Instructions GO
7. Helpful Hints in Conducting Surveys KB
8. Preferred Alternative Approaches GO
9 Case Studies RW
10. Wrap-up TM
C-l
-------
APPENDIX D
SITE VISIT REQUEST INTRODUCTION LETTER
-------
2O
*
Anniversary
1359S Dulles Technology Or.
eo mmom mi o M Herndon. VA 22071
(703)834-1500
April 28, 1989
Dear
Your facility has been randomly selected by the U.S. Environmental Protection
Agency (EPA) to participate in a quality assurance survey of facilities that
submitted first year reports (Form R) for the Toxic Chemical Release Inventory
(TRI) under Section 313 of SARA Title III. The purpose of the survey is to
evaluate the quality of the data submitted in the Form R's and to provide
feedback to EPA that can be used to improve the reporting instructions,
guidance, or the reporting form for the future. EPA has contracted with
Radian Corporation to perform the survey by conducting visits to some
150 facilities selected from the TRI database.
Participation in this program will assist you in determining reporting
thresholds and release estimates for your facility. This should be valuable
information for completion of future Form R's.
As the contractor for EPA on this effort, we will visit your facility sometime
in May, June, or July 1989. The visit will last 1 to 2 days depending on che
number of Form R's you submitted. We will spend the majority of that time
reviewing the calculations and data used to determine reporting thresholds and
release estimates. During the site visit, we will need your assistance to
tour the plant extensively enough to allow us to understand your overall
process and identify potential release points. Your assistance will also be
needed in filling out a questionnaire, which is designed to address areas
where we believe data quality problems are most likely to occur. We will make
every effort to minimize disruptions to your schedule while we are on site.
tfe will contact you by telephone within the next week to arrange a date for
the site visit. I would like to emphasize that the name and location of your
facility will not be released to EPA in order to ensure confidentiality of
your facility's information. The EPA Project Officer for this program is
Larry Longanecker of the Office of Toxic Substances. Enclosed is a letter
from him requesting your participation.
Thank you for your cooperation. If you have any questions, please feel free
to call Glenn Osmond at (919) 541-9100 or me at (703) 834-1500.
Sincerely,
Tim McAdams
Project Director
Enclosure
D-l
-------
2O
*
Anniversary
13595 Dulles Technology Dr.
Herndon. VA 22071
(7031834-1500
April 28, 1989
id \
Dear
Your facilicy has bean randomly selected by tha U.S. Bnvlrotinancal Protection
Agancy (EPA) Co participate in a quality aaauranca aurvay of facilities that
submitted first year reports (Font R) for the Toxic Chemical Release
Inventory (TRI) under Section 313 of SARA Title III. The purpose of the
survey is to evaluate the quality of the data submitted in the Form R's and
to provide feedback to EPA that can be used to improve the reporting
instructions, guidance, or the reporting fora for the future. EPA has
contracted with Radian Corporation to perform the survey by conducting visits
to some 150 facilities selected from the TRI database.
Participation in this program will assist you in determining reporting
thresholds and release estimates for your facility. This should be valuable
information for completion of future Form R's.
A letter detailing what to expect during the site visit, which will occur
sometime in Hay, June, or July 1989, has been sent to Karen Jandar, who was
given as the technical contact on your Form R(s). We will contact Ms. Jander
by telephone within the next week to arrange a date for the site visit.
I would like to emphasize that the name and location of your facility will
not be released to EPA in order to ensure confidentiality of your facility's
information.
The EPA Project Officer for this program is Larry Longanecker of the Office
of Toxic Substances. Enclosed is a letter from him requesting your
participation.
Thank you for your cooperation. If you have any questions, please feel free
to call Glenn Osmond at (919) 541-9100 or me at (703) 834-1500.
Sincerely,
Tim McAdams
Project Director
Enclosure
cc: Karen Jander
D-2
-------
APPENDIX E
REFERENCES USED BY FACILITIES
-------
TABLE E-l
REFERENCES COMMONLY USED.BY SURVEYED FACILITIES TO ESTIMATE
RELEASES AND CONTROL EFFICIENCIES
Number of Facilities
Reference Using Reference
TRI Reporting Form R and Instructions
EPA 560/4-88-005
The Emergency Planning and Community Right-to Know
Act, Section 313 (40 CFR 372)
EPA 560/4-88-001
Estimating Releases and Waste Treatment
Efficiencies for the TRI
EPA 560/4-88-002
Title III Section 313 Release Reporting Guidance,
EPA 560/4-88-004 a through q, Estimating Chemical
Releases:
a. Monofilament fiber manufacturing
b. Printing operations
c. Electrodeposition of organic coatings
d. Spray application of organic coatings
f. Formulating aqueous solutions
g. Electroplating operations
h. Textile dyeing operation
i. Press wood and laminated wood products
manufacturing
j. Roller, knife, and gravure coating
operations
k. Paper and paperboard products
q. Rubber production and compounding
Compilation of Air Pollution Emission Factors,
AP-42
Toxic Chemical Release Reporting Proposed Rule, 52
IE 21152, June 4, 1987
Privately Sponsored Seminar Materials
Government Sponsored Seminar Materials
National Council of the Paper Industry for Air and
Stream Improvements (NCASI) Memorandum
CMA Guidance for Estimating Fugitive Emissions
1
1
1
3
1
7
3
1
2
1
141
40
38
23
17
16
14
9
9
E-l
-------
TABLE E-l (Continued)
REFERENCES USED BY SURVEYED FACILITIES TO ESTIMATE
RELEASES AND CONTROL EFFICIENCIES
Number of Facilities
Reference Using Reference
Toxic Chemical Release Inventory Questions and 6
Answers
EPA 560/4-89-002
Vendor Brochures 4
Common Synonyms for Section 313 Chemicals 4
OTS-ETD-001
Corporate Guidance Manual 4
Comprehensive List of Chemicals Subject to 3
Reporting Under the Act (Title III List of Lists)
EPA 560/4-88-003
Understanding the Small Quantity Generator 2
Hazardous Waste Rules: A Handbook for Small
Business
EPA 530/SW-86-019
Chemical Hazard Communication Guidebook 2
"313 Advisor" Computer Program, duPont 2
Assessment of Atmospheric Emission from Petroleum 2
Refining, EPA 600/2-80-075 C
Fugitive Emission Sources of Organic Compounds - 2
Additional Information on Emissions, Emission
Reductions, and Costs
EPA 450/3-82-010
Draft Protocols for Generating Unit Specific 2
Emission Estimates for Equipment Leaks of VOC and
VHAP, EPA, April 1987
"Fugitive Emissions Calculation Guidelines," J.W. 2
Davenport and L. J. McGregor, Paper presented at
80th Annual Meeting of APCA
"Community Right-to-Know Manual," Thompson 1
Publishing Group
E-2
-------
TABLE E-l .(Continued)
REFERENCES USED BY SURVEYED FACILITIES TO ESTIMATE
RELEASES AND CONTROL EFFICIENCIES
Number of Facilities
Reference Using Reference
Locating and Estimating Air Emissions From 1
Sources of Manganese
EPA 450/4-84-007h
Electric Arc Furnace Dust Disposal, Recycle and 1
Recovery, Center for Metals Production
Chemical.Engineers Handbook, Perry and Chilton, 1
McGraw-Hill
TOTAL REFERENCES USED 352
E-3
-------
APPENDIX F
WRAP-UP MEETING AGENDA AND
SUMMARY OF ISSUES
-------
AGENDA FOR SARA 313 SITE VISIT PROGRAM WRAP-UP MEETING
SEPTEMBER 7, 1989; HERNDON, VIRGINIA
ATTENDEES
Larry Longanecker, U.S. EPA, Office of Toxic Substances
Kathy Franklin, U.S. EPA, Office of Toxic Substances
Richard Wells, Abt Associates
Roger Christman, Radian Corporation, Program Manager
Tim McAdams, Radian Corporation, Project Director
Kevin Fisher, Radian Corporation, Office Coordinator
Glenn Osmond, Radian Corporation, Office Coordinator
Tim Rimpo, Radian Corporation, Office Coordinator
Larry Sontoski, Radian Corporation, Office Coordinator
Richard Weisman, Radian Corporation, Office Coordinator
Vic Yamada, Radian Corporation, Office Coordinator
Deb Matthews, Radian Corporation, Site Surveyor
Sandy Howard, Radian Corporation, Research Assistant
DISCUSSION ITEMS
1. Overall Impressions
How do you feel about the information obtained?
How do you feel about the effort put forth by industry?
2. Survey Instrument
What specific questions in the survey instrument should be changed, and
how should they be changed?
Please comment on each section of the survey instrument. Are there
poorly phrased questions? Are you not sure of a question's intent?
3. Site Selection
Did you encounter any problems in the site selection process (e.g., plant
locations vor groupings)?
4. Arrange Site Visits
How could the process used to contact facilities and arrange site visits
be improved?
How could the training for the telephone callers be improved?
NRJ-50
0821-03.nrj.2
F-l
-------
What problems did you encounter when either rescheduling or cancelling
site visits?
Surveyor Training
How could the training for the site surveyors be improved? What elements
could be added or improved? What are the elements of a reasonable model
training program?
Were the training materials useful? Which were most useful? Which were
least useful?
Was the training budget adequate? What would be adequate?
Surveyor Qualifications
What qualifications (education and experience) are necessary for a person
to successfully perform a quality assurance site visit?
Site Visit Preparation
How much preparation is needed for a site visit? What preparation do you
think is necessary before making a site visit? What about the facility
and the industry should be reviewed prior to visiting a site?
Facility Tour
How is a facility tour a useful component of a quality assurance site
visit?
How detailed should the facility tour be to obtain information needed to
complete the site visit?
Did the facility personnel appear to be candid during the tour?
Do you think the operational status of the facility affected the quality
of the information you obtained?
Did you tour any facilities that were not in operation?
For those facilities toured, did you see things that were overlooked?
For those non-operating facilities toured, do you think you missed
anything? For non-operating facilities who did not use a mass-balance
approach, how can you tell if you missed anything?
Documentation
How much confidence should be placed on the documentation facilities
offered for review?
NRJ- 50
0821-03.nrj.3
F-2
-------
Did Che facility personnel appear to be candid in providing documentation
for review and when answering questions about the documentation?
10. Facility Concerns
Did the facility personnel express concern about public perceptions of
the release estimates they reported?
Did the facilities take steps to improve their release estimates or to
reduce their releases of Section 313 chemicals?
11. Range Reporting
Did the facility personnel find the range reporting option useful?
12. Causes of Release Estimate Errors
For situations where the facility personnel estimated releases higher
than we calculated, what are the primary reasons why the facility's
release estimates were over reported?
For situations where the facility personnel estimated releases lower than
we calculated, what are the primary reasons why the facility's release
estimates were under reported?
13. Hotline
Did you find the EPA/EPCRA Hotline helpful? Did the facility personnel
find the Hotline helpful?
What problems with the Hotline were encountered?
Did the Hotline provide accurate, consistent answers to specific ques-
tions?
14. "Toxic Chemical Release Inventory Reporting Form R and Instructions"
What specific items in the instructions did you find unclear?
What specific items in the instructions did the facility personnel find
unclear?
How could these items be improved?
15. Survey Instrument Quality Assurance
How could the survey instrument quality assurance (both in-office and
inter-office) be improved?
NRJ-50
0821-03.nrj.4
F-3
-------
16. Future Activities
Future activities planned for the EPA quality assurance program are an
audit manual, an examination of large emitters, and an assessment of
companies with large changes from year-to-year. What are your thoughts
on these activities? What other activities would you suggest?
NRJ-50
0821-03.nrj.5
F-4
-------
CORPORATION
MEMORANDUM
2455 Horsepen Road, Suite 250
Herndon, VA 22071
(703)834-1500
TO: Larry Longanecker and Kathy Franklin,
U.S. EPA, Office of Toxic Substances
FROM: Tim McAdams and Richard Weisman,
Radian Corporation
DATE: 24 October 1989
SUBJECT: Summary of Issues Discussed at Wrap-up Meeting
This memorandum briefly summarizes the issues discussed during the SARA Title
III, Section 313 Site Visit Program wrap-up meeting held in our office on
September 7, 1989. This memorandum includes the comments and recommendations
made by the meeting attendees on each of the discussion items on the agenda (a
copy of the agenda is appended to this memorandum), as well as on the three
additional discussion items raised by Richard Wells.
DISCUSSION ITEMS
1. Overall Impressions
There were limited data available for industry to make threshold determi-
nations and to estimate releases.
Calculations usually went beyond data obtained/maintained to satisfy
permit requirements.
Smaller companies need more help than larger companies.
The electroplating and furniture industries had more trouble than others
with reporting.
Electroplaters had problems with chemistry-oriented issues.
Facilities had difficulty incorporating existing computer programs for
inventory tracking with SARA Title III, Section 313 reporting require-
ments .
Facilities with environmental staffs generally did a better job of
reporting than facilities without environmental staff.
NRJ-50
0922-07.bjg.l
F-5
-------
RADIAN
CORPORATION
Tim McAdams and Richard Weisman
24 October 1989
Page 2
Richard Wells' Discussion Items
The supplier notification was not very helpful to industry because of the
large number of MSDSs received by industry and the irregular systems used
for tracking toxic chemicals.
Additional technical guidance documents would be helpful to industry -
especially for electroplaters and furniture makers.
The current series of industry-specific guidance documents were found to
be overly simplistic and, as a result, of limited usefulness
Site Selection
Problems were encountered with facilities entered in the TRI database
incorrectly.
The computer printout occasionally missed reported chemicals, especially
when amended Form R's were submitted after July 1, 1988.
Is the facility name and address typed in once or separately with each
chemical entered?
Arrange Site Visits
We could have been better prepared to respond where facilities requested
confidentiality agreements.
Surveyor Training
More detailed and realistic guidance documents, including an expanded
question and answer document, would aid surveyors in determining how the
Form R's should be completed where industries and chemicals are complex.
An entire day is needed to allow the surveyors to read all the training
materials that were provided.
Surveyor Qualifications
Qualified surveyors need to have an understanding of chemistry, indus-
trial processing operations, SARA Title III, Section 313 regulations, and
people management skills.
Site Visit Preparation
Obtain detailed information over the phone on what major processes each
facility operates.
NRJ-50
0922-07.bjg.2
F-6
-------
Tim McAdams and-Richard Weisman
24 October 1989
Page 3
Cross-reference 3-digit SIC codes with reported chemicals to help prepare
for visits.
8. Facility Tour
Tours were found to have many advantages - they provide a -direct mecha-
nism to address facility contact's concerns, let you view storage and
waste treatment areas, and provide a clear way to ask meaningful ques-
tions .
'Tours were not as useful for facilities where a mass balance approach was
used to estimate releases.
9. Documentation
The quality of documentation reviewed varied significantly, and sugges-
tions were made that EPA should publish guidance on what is good.documen-
tation.
10. Facility Concerns
Facilities -generally had limited feedback from the public on reported
releases.
Since July 1988, many facilities have taken steps to improve reporting
.accuracy and reduce their releases.
11. Range Reporting
EPA should add a lower range, for example, 1-10 pounds per year.
12. Causes of Release Estimate Errors
Facilities frequently wanted to report, "just to be complete", even if
they were below applicable thresholds.
Other errors were due to reporting releases of metal compounds, reporting
releases of all material purchased, without considering inventory
changes, on-site treatment, or incorporation into products, failing to
consider recycle/reuse practices, fraction of.a compound in a material,
neutralization of acids and bases, and volatile releases of nonvolatile
compounds.
Facilities were found to have performed limited QA on their release
calculations, and to sometimes have poor internal communication at large
facilities with multiple groups using the same chemical.
NRJ-50
0922-07.bjg.3
F-7
-------
CORPORAT
Tim McAdams and Richard Weisman
24 October 1989
Page 4
13. Hotline
The hotline was usually a good information source for our surveyors when
visiting facilities.
The hotline sometimes gave contradictory answers to questions asked by
different people.
The hotline often could not cite the written source for an answer.
14. Reporting Instructions
Several items in the Revised '88 Instructions were found to be unclear:
the definition of an "article," de minimus concentrations, and metal
fumes or dust; how to address chemicals that are manufactured, processed,
and used in the same operation; when to consider metals different than
metal compounds; how to determine waste treatment efficiencies; and how
to consider materials brought to a facility for reclamation purposes.
15. Survey Instrument Quality Assurance
The QA protocol should be published at the beginning of the program
Internal QA should be performed on a more rapid basis.
16. Future Activities
A manual on how to perform QA surveys would be very helpful.
A detailed checklist, with questions similar to the survey instrument,
should be included in the manual.
NRJ- 50
0922-07.bjg.4
F-8
-------
APPENDIX G
SURVEY DATA
-------
TABLE G-l
THRESHOLD DETERMINATION SURVEY RESULTS
Category
Correctly-Included
Chemical Reports
Incorrectly-Included
Chemical Reports
Correctly-Omitted
Chemical Reports
Incorrectly-Omitted
Chemical Reports
Category
Correctly-Included
Chemical Reports
Incorrectly-Included
Chemical Reports
Correctly-Omitted
Chemical Reports
Incorrectly-Omitted
Chemical Reports
UNWEIGHTED RESULTS
Number of Chemicals
657
71
746
48
WEIGHTED RESULTS
Number of Chemicals
62,000
8,000
110,000
6,000
Number of Facilities
149
46
135
33
Number of Facilities
17,000
4,000
15,000
3,000
G-l
-------
TABLE G-2
THRESHOLD DETERMINATION APPROACHES USED BY SURVEYED
FACILITIES TO DETERMINE AMOUNT OF CORRECTLY-INCLUDED CHEMICALS
MANUFACTURED, PROCESSED, OR OTHERWISE USED
Threshold Determination Approach
Percent of Chemical Reports
Correctly Included by the
Surveyed Facilities
Purchase/Inventory Records
Emission Factors*
Mass Balance8
Facility Assumed Threshold Exceeded0
Process Recipes0
Monitoring DataE
Production DataF
Hazardous Waste Manifests0
TOTAL
85.3
3.7
3.2
2.4
2.7
1.4
1.1
0^2
100.0
AEmission factors published by industry trade associations were used to
compute quantities of chemicals manufactured.
BMass balance calculations were based on the quantity of chemical in raw
materials, products, and wastes, and included complex calculations involving
chemical reactions and stoichiometry.
cFacility personnel assumed thresholds were exceeded for a chemical based on
knowledge of facility operations, usually without support documentation.
°Process recipes were used to calculate the quantity of chemical manufactured
or processed based on the quantity of raw material purchased.
EData characterizing wastewater discharges and solid waste materials were used
to compute the quantity of disposed chemical. The quantity of chemical used
was assumed to be equal to or greater than the quantity of disposed chemical.
FThe quantity of product manufactured multiplied by the concentration of the
chemical in that product was used to determine the quantity of chemical
manufactured.
°Waste quantity data from hazardous waste manifests and corresponding
characterization data were used to compute the quantity of disposed chemical.
The quantity of chemical used was assumed to be equal to or greater than the
quantity of disposed chemical.
G-2
-------
TABLE G-3
REASONS CHEMICAL REPORTS WERE INCORRECTLY INCLUDED
IN THRESHOLD DETERMINATION RESULTS
Reason
Percent of Chemical Reports
Incorrectly Included
Among Surveyed Facilities
Qualifier Misinterpreted
Quantity Less Than Threshold Limit
Facility Assumptions Not Supported
by Records
Activity Misclassified
Quantity Miscalculated
Chemical Subject to Exemption
Not a Section 313 Listed Chemical
TOTAL
19.7
45.1
5.6
1.4
15.5
8.5
100.0
G-3
-------
i-A
TABLE G-4
REASONS CHEMICAL REPORTS WERE INCORRECTLY OMITTED
IN THRESHOLD DETERMINATION RESULTS
Number of Facilities
Incorrectly Omitting
Number of Chemical Reports At Least One
Reason Incorrectly Omitted* Chemical Report*
Overlooked Chemical 36 26
Activity
- Manufacturing By- 4
Products
- Wastewater Treatment 11
By-Products
- Wastewater Treatment 7
Chemicals
- Cleaning Chemicals 4
- Miscellaneous
Process or Otherwise 10
Used Chemicals
Misclassified Activity8 5 4
Miscalculated Quantity0 4 4
Other0 3
TOTAL 48 33E
*The number of chemical reports and facilities presented are based on data
collected at 156 surveyed facilities.
BThese errors occurred when facilities used more than 10 ,'000 Ibs/yr of a
chemical, but less than 75,000 Ibs/yr, and misclassified the activity as
manufacturing or processing. Radian surveyors found the correct activity for
these chemicals to be "otherwise used."
cRadian's surveyors recalculated the quantity of chemical manufactured,
processed, or otherwise used, and determined a quantity greater than the
applicable threshold.
°0ne facility incorrectly interpreted requirements to mean that repackaging
did not need to'be reported. One facility followed a manufacturer's advice
that a chemical did not need to be reported. One facility incorrectly
calculated the quantity of pure metal used instead of the metal compound.
ESome of the 32 facilities incorrectly omitting chemicals did so for more than
one reason. Therefore, the total number (32) does not equal the sum of the
reason-specific numbers.
G-4
-------
TABLE G-5
FREQUENCY OF ERROR IN RELEASE ESTIMATES*
AT THE SURVEYED FACILITIES:
UNWEIGHTED DATA
Magnitude of Facility's Error
Percent of Release Estimates
Applicable to a Release Medium
Incorrectly-Omitted Release Quantity
Underestimated by three or more
orders-of-magnitude
Underestimated by two orders-of-
magnitude
Underestimated by one order-of-
magnitude
Not an error--within one order-of-
magnitude
Overestimated by one order-of-
magnitude
Overestimated by two orders-of-
magnitude
Overestimated by three or more
orders-of-magnitude
Incorrectly-Reported Release
Quantity
TOTAL
8.7
0
0.5
1.4
77.9
1.4
0.5
0.1
100.0
ARelease estimate errors were defined as release quantities more than one
order-of-magnitude different than the Radian QA reviewer's estimated value.
G-5
-------
TABLE G-6
SOURCES OF ERROR IN RELEASES ESTIMATES*.
AT THE SURVEYED FACILITIES:
UNWEIGHTED DATA
Type of Error
Number of Instances
Error was Made
Number of
Facilities
1. Misinterpreted the reporting
instructions:
Acid/Base Neutralization 49
Recycle/Reuse Off-Site 24
Metal Compound Reported 2
De Minimus Exemption 6
2. Used incomplete information:
Overlooked facility data 70
Overlooked chemical properties 48
Overlooked emission factors 15
3. Documentation did not support release 51
estimates
4. Other errors made by facility:
Calculation errors 11
Transcription errors 33
23
15
1
1
26
25
9
26
8
14
AThis table summarizes instances where the QA reviewer's release estimate
differed from the amount reported by the facility by more than one order-of-
magnitude.
G-6
-------
TABLE G-7 FREQUENCY OF ERRORS (3) IN RELEASE ESTIMATES-
UNWEIGHTED SURVEY DATA
Type of
Industry (1)
Chemical
Non- Chemical
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
165
215
380
A
0
0
0
B
0
1
1
C
5
4
9
Fugiti
D
127
173
300
ve Ai
E
6
2
8
r
F
1
0
1
G
0
0
0
H
11
24
35
I
15
11
26
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
295
85
380
Fugitive Air
A
0
0
0
B
1
0
1
C
5
4
9
D
239
61
300
E
7
1
8
F
1
0
1
G
0
0
0
H
22
13
35
I
20
6
26
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28,
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or more
B = Facility underestimated by a factor of 100 to 999
C •= Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H = Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-7
-------
TABLE G-7 FREQUENCY OF ERfcORS(3) IN RELEASE ESTIMATES -
UNWEIGHTED SURVEY DATA
Total Number
Of Releases
Estimates
Type of Applicable to
Indus try (1) Medium (4)
Chemical
Non- Chemical
Total
163
225
388
A
0
0
0
B
1
1
2
C
1
3
4
Stack Air
D
137
202
339
E
6
1
7
F
1
0
1
G
0
0
0
H
9
14
23
I
8
4
12
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
285
103
388
A
0
0
0
B
2
0
2
C
3
1
4
Stack
D
255
84
339
Air
E
4
3
7
F
1
0
1
G
0
0
0
H
11
12
23
I
9
3
12
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999."
C = Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H = Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not,have.
4 - Analysis applicable only for chemical reports correctly
included.
G-8
-------
TABLE G-7 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES-
UNWEIGHTED SURVEY DATA
Type of
Indus try (1)
Chemical
Non- Chemical
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
36
63
99
A
0
0
0
B
0
0
0
I
C
1
1
2
)ischa
D
28
35
63
rge t
E
0
1
1
o Wat
F
0
0
0
er
G
0
0
0
H
0
6
6
I
7
20
27
Reported
Size of
Emitter (2)
Large
Small
Total
Total Number
Of Releases
Estimates
Discharge to Water
Applicable to
Medium (4)
93
6
99
A
0
0
0
B
0
0
0
C
2
0
2
D
61
2
63
E
1
0
1
F
0
0
0
G
0
0
0
H
5
1
6
I
24
3
27
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order, of magnitude different
than the site surveyor's recalculated value.
A " Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C - Facility underestimated by a factor of 10 to 99.
D = Not an error; within one order of magnitude.
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H = Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-9
-------
TABLE G-7 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES-
UNWEIGHTED SURVEY DATA
Type of
Industry(l)
Chemical
Non- Chemical
Total
Total Number
Of* Releases
Estimates
Applicable to
Medium (4)
20
34
54
On-Site Release
A
0
0
0
B
0
0
0
C
0
2
2
D
15
24
39
E
0
0
0
to Land
F
0
0
0
G
0
0
0
H
1
4
5
I
4
4
8
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
49
5
54
On-Site Release
A
0
0
0
B
0
0
0
C
2
0
2
D
38
1
39
E
0
0
0
to Land
F
0
0
0
G
0
0
0
H
4
1
5
I
5
3
8
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.'
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H « Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-10
-------
TABLE G-7 FREQUENCY OF EKRORS(3) IN RELEASE ESTIMATES-
UNWEIGHTED SURVEY DATA
Total Number
Of Releases
Estimates
Type of Applicable to
Indus try (1) Medium (4)
Chemical
Non- Chemical
Total
20
1
21
A
0
0
0
B
0
0
0
Underground
C D E
0
0
0
18
0
18
0
0
0
Injection
F G
0
0
0
0
0
0
H
0
0
0
I
2
1
3
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
21
0
21
Underground
A
0
0
0
B
0
0
0
C
0
0
0
D
18
0
18
E
0
0
0
Injection
F
0
0
0
G
0
0
0
H
0
0
0
I
3
0
3
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more .than one order of magnitude different
than the site surveyor's recalculated value.
A - Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10'to 99.
D = Not an error; within one order"of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H = Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-ll
-------
TABLE G-7 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES-
UNWEIGHTED SURVEY DATA
Type of
Industry (1)
Chemical
Non- Chemical
Total
Total Number
Of Releases
Estimates
Discharge to POTW
Applicable to
Medium (4)
62
103
165
A
0
0
0
B
0
3
3
C
0
0
0
D
44
65
109
E
0
0
0
F
1
1
2
G
0
0
0
H
13
7
20
I
4
27
31
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
132
33
165
Discharge to POTW
A
0
0
0
B
1
2
3
C
0
0
0
D
93
16
109
E
0
0
0
F
1
1
2
G
0
0
0
H
17
3
20
I
20
11
31
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28,
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A - Facility underestimated by a factor of 1000 or more.
B = Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10 to 99.
D = Not an error; within one order of magnitude.
E « Facility overestimated by a factor of 10 to 99.
F = Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-12
-------
TABLE G-7 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES -
UNWEIGHTED SURVEY DATA
Type of
Indus try (1)
Chemical
Non-Chemical
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
124
172
296
Other
A
0
0
0
B
1
0
1
C
0
2
2
Off-Site Transfer
D
104
122
226
E
2
1
3
F
1
2
3
G
1
1
2
H
10
23
33
I
5
21
26
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
228
68
296
Other
A
0
0
0
B
1
0
1
C
2
0
2
Off-Site Transfer
D
181
45
226
E
2
I
3
F
2
1
3
G
2
0
2
H
21
12
33
I
17
9
26
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A — Facility underestimated by a factor of 1000 or more
B = Facility underestimated by a factor of 100 to 999
C = Facility underestimated by a factor of 10 to 99.
D = Not an error; within one order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F = Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-13
-------
TABLE G-8 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES-
WEIGHTED SURVEY DATA
Type of
Industry(1)
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
Fugitive Air
B C D E F
0 444 6944 213 35
24 217 11698 255 0
24 661 18642 468 35
G H I
0 713 938
0 2465 762
0 3178 1700
Chemical
Non-Chemical
Total
9287 0
15421 0
24708 0
Reported
Size of
Emitter(2)
Total Number
Of Releases
Estimates
Applicable to
Medium (4) A
Fugitive Air
B C D E F
24 189 6556 243 35
0 472 12087 224 0
24 661 18643 467 35
G H I
0 667 572
0 2511 1127
0 3178 1699
Large
Small
Total
8286 0
16421 0
24707 0
Notes: 1 • Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities, more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility .underestimated by a factor of 1000 or more.
B » Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a. factor of 10 to .99.
D - Not an error; within one order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F = Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H = Facility"incorrectly omitted release quantity.
I = Facility reported a release quantity..that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-14
-------
TABLE G-8 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES -
WEIGHTED SURVEY DATA
Type of
Industry(1)
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
Stack Air
B C D E F
22 71 7902 378 22
31 227 15638 173 0
53 298 23540 551 22
G H I
0 980 234
0 1979 551
0 2959 785
Chemical
Non-Chemical
Total
9609 0
18599 0
28208 0
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
8460
19748
28208
A
0
0
0
B
53
0
53
C
124
173
297
Stack
D
7568
15972
23540
Air
E
129
423
552
F
22
0
22
G
0
0
0
H
274
2685
2959
I
290
495
785
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A - Facility underestimated by a factor of 1000 or more
B = Facility underestimated by a factor of 100 to 999.
C - Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-15
-------
TABLE G-8 FREQUENCY OF ERRORS(3) IN RELEASE ESTIMATES -
WEIGHTED SURVEY DATA
Type of
Total Number
Of Releases
Estimates
Applicable to
Discharge to Water
Industry (1)
Chemical
Non-Chemical
Total
Medium (4)
846
2114
2960
A
0
0
0
B
0
0
0
C
11
27
38
D
536
1124
1660
E
0
23
23
F
0
0
0
G
0
0
0
H
0
289
289
I
299
651
950
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
2210
751
2961
A
0
0
0
B
0
0
0
C
38
0
38
Dischc
D
1537
124
1661
irge t
E
23
0
23
o Wat
F
0
0
0
er
G
0
0
0
H
116
173
289
I
496
454
950
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or more.
B = Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H = Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-16
-------
TABLE G-8 FREQUENCY OF ERRORS IN RELEASE ESTIMATES -
WEIGHTED SURVEY DATA
Total Number
Of Releases
Estimates
Type of Applicable to
Indus try(l) Medium (4)
Chemical
Non- Chemical
Total
974
920
1894
A
0
0
0
On- Site Release
B
0
0
0
C
0
55
55
D
418
651
1069
E
0
0
0
to Land
F
0
0
0
G
0
0
0
H
108
120
228
I
448
94
542
Reported
Size of
Emitter(2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
1128
767
1895
A,
0
0
0
On- Site Release
B C D E
0
0
0
55 842
0 227
55 1069
0
0
0
to Land
F G
0
0
0
0
0
0
H
120
108
228
I
111
432
543
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are -defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or' more.
B = Facility underestimated by a factor of 100 to 999.
C - Facility,underestimated by a factor of 10 to 99.
D - Not an error; within one'order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F = Facility overestimated by a factor of 100 to 999.
G = Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-17
-------
TABLE G-8 FREQUENCY OF ERfcORS(3) IN RELEASE ESTIMATES-
WEIGHTED SURVEY DATA
Total Number
Of Releases
Estimates
Type of Applicable to
Industry (1) Medium (4)
Chemical
Non- Chemical
Total
386
8
394
A
0
0
0
Underground Injection
B C D E F G
0
0
0
0
0
0
341
0
341
0
0
0
0
0
0
0
0
0
H
0
0
0
I
45
8
53
Reported
Size of
Emitter (2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
394
0
394
Underground
A
0
0
0
B
0
0
0
C
0
0
0
D
341
0
341
Injection
E
0
0
0
F
0
0
0
G
0
0
0
H
0
0
0
I
53
0
53
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A *• Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G - Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-18
-------
TABLE G-8 FREQUENCY OF'ERRORS(3) IN RELEASE ESTIMATES -
WEIGHTED SURVEY DATA
Type of
Indus try (1)
Total Number
Of Releases
Estimates
Applicable to
Medium (4) A
B
2867 0 0
8430 0 390
11297 0 390
Discharge to POTW
C D E F G
H
Chemical
Non-Chemical
Total
0 2374
0 4377
0 6751
0 8
0 150
0 158
0 428 57
0 785 2728
0 1213 2785
Reported
Size of
Emitter (2)
Large
Small
Total
Total Number
Of Releases
Estimates
Discharge
to POTW
Applicable to
Medium (4)
4280
7016
11296
A
0
0
0
B
56
334
390
C
0
0
0
D
3197
3554
6751
E
0
0
0
F
8
150
158
G
0
0
0
H
476
737
1213
I
543
2241
2784
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on- the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A = Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C - Facility underestimated by a factor of 10 to 99.
D - Not ah error; within one-order of magnitude.
E - Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of .100 to 999.
G - Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I - Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-19
-------
TABLE G-8 FREQUENCY OF ERR'ORS(3) IN RELEASE ESTIMATES-
WEIGHTED SURVEY DATA
Type of
Industry(1)
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
B
71
0
71
Other Off-Site Transfer
C D E F G H
Chemical
Non-Chemical
Total
7066 0
13266 0
20332 0
0 5373 212 190 22 943 255
61 9164 8 46 24 2085 1878
61 14537 220 236 46 3028 2133
Reported
Size of
Emitter (2)
Large
Small
Total
Total Number
Of Releases
Estimates
Applicable to
Medium (4)
6739
13593
20332
A
0
0
0
B
71
0
71
C
61
0
61
Other
D
5305
9232
14537
Off-Site
E
30
190
220
Transfer
F G
46
190
236
46
0
46
H
551
2477
3028
I
629
1504
2133
Notes: 1 - Chemical industry is defined here by Primary SIC Code 28.
2 - Large and small emitters are differentiated by the
quantity of releases reported on the Form R.
3 - Release estimate errors are defined here as reported
quantities more than one order of magnitude different
than the site surveyor's recalculated value.
A - Facility underestimated by a factor of 1000 or more.
B - Facility underestimated by a factor of 100 to 999.
C = Facility underestimated by a factor of 10 to 99.
D - Not an error; within one order of magnitude.
E = Facility overestimated by a factor of 10 to 99.
F - Facility overestimated by a factor of 100 to 999.
G « Facility overestimated by a factor of over 1000.
H - Facility incorrectly omitted release quantity.
I = Facility reported a release quantity that it
should not have.
4 - Analysis applicable only for chemical reports correctly
included.
G-20
-------
APPENDIX H
SUMMARY OF PREFERRED ALTERNATIVE APPROACHES
-------
TABLE H-l
SUMMARY OF RELEASES AND CALCULATION APPROACHES FOR- CHEMICALS AT
SURVEYED FACILITIES WHERE RADIAN IDENTIFIED A PREFERRED ALTERNATIVE APPROACH
Facility
1
1
2
2
3
3
A
5
5
5
5
5
6
7
8
9
10
10
10
10
10
10
10
10
10
11
12
Chemical
Code
A
B
A
B
A
B
A
A
B
C
D
E
A
A
A
A
A
B
C
D
E
F
G
H
I
A
A
Facility's
Estimation
Approach*
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
M
M
M
M
M
M
M
0
0
Facility's
Reported
Release
Estimate
(lbs/yr)B
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
10,000-20,000
10,000-20,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
0-1,000
10,000-30,000
10,000-30,000
10,000-30,000
10,000-30,000
10,000-30,000
1,000-10,000
1,000-10,000
1,000-10,000
0-1,000
Radian's
Preferred
Approach*
E
E
C
C
E
E
M
E
E
E
M
M
E
C
E
E
E
E
E
E
E
E
E
E
E
M
E
Radian's
Release
Estimate
(Ibs/yr)
50,000
50,000
80,000
40 , 000
. 3,000
800,000
100
10,000
2,000
1,000
0
0
100
80 , 000
20,000
0
100
100
2,000
2,000
500
500
100
500
100
0
3,000
C «= Mass Balance
E = Emission factors
M - Monitoring data
0 = Engineering judgment
Facility releases were reported as ranges to protect confidentiality.
H-l
-------
APPENDIX I
SUMMARY OF THE TOP TWELVE RELEASE ESTIMATE ERRORS
FOR EACH RELEASE MEDIUM
-------
Facility Release
TABLE 1-1
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
Fugitive Air
Radian QA Reviewer's
Release Estimate
Estimate (Ibs/yr)*-9
700,000
40 , 000
300,000
300,000
10,000
2,000
0
200,000
0-1,000
0-1,000
0-1,000
(Ibs/yr)*-8
10,000
200,000°
200,000
200,000
100,000
90,000
80 , 000C
100,000
50,000C
50 . 000C
40 , 000C
Source of Error8
Transcription error
Overlooked emission factors
Overlooked % of chemical
Overlooked % of chemical
Overlooked emission factors
Overlooked air releases from
treatment lagoons
Overlooked chemical properties
(volatility)
Miscalculated release estimate
Overlooked emission factors
Overlooked emission factors
Overlooked chemical properties
100,000
100,000
(volatility)
Calculation error
ARelease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates.
BThe errors summarized in this table were made by 39 facilities.
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-1
-------
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
Stack Air
Facility Release
Estimate (lbs/yr)*iB
Radian QA Reviewer's
Release Estimate
(Ibs/yr)*-9
Source of Error8
100,000
3,000
80,000
3,000
0-1,000
0
6,000
20,000
10,000
60,000
200,000
800,000
400,000
200,000
80,000
60,000
60,000
50,000
40,000C
50,000
40,000
40,000
200.000
Overlooked emission factors
Overlooked air releases from
process vents and stacks
Overlooked air release from one
process unit
Miscalculated release estimate
Overlooked air releases from
process vents
Overlooked air releases
completely
Overlooked emission factors
Overlooked facility data
Incorrectly split air emission
between fugitive and stack
Overlooked air release from
process source
Transcription error
Calculation error
ARelease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates.
BThe errors summarized in this table were made by 39 facilities.
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-2
-------
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE-
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
Discharge to Water
Facility Release
Estimate (lbs/yr)*-B
Radian QA Reviewer's
Release Estimate
(lbs/yr)*-B
Source of Error8
3,000,000
6,000,000
1,000,000
1,000,000
500,000
2,000,000
400,000
200,000
100 , 000
100,000
100,000
100 , 000
40,000,000
0
0
0
0
3,000,000
0
0
0
0
0
2,000
Miscalculated sodium sulfate
production
Transcription error
Transcription error
Transcription error
Misinterpreted acid/base
neutralization instructions
Miscalculated sodium sulfate
production
Transcription error
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Overlooked chemical properties
AR.elease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates.
BThe errors summarized in this table were made by 39 facilities.
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-3
-------
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
Underground Injection
Facility Release
Estimate (lbs/yr)AlB
Radian QA Reviewer's
Release Estimate
(Ibs/yr)*-8
Source of Error8
50,000
30,000
0-1,000
0-1,000
0-1,000
40,000
40,000
0
0
Double-counted,a process source
Incorrectly classed one source
of release as an air emission
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Transcription error
ARelease estimates reported by facilities on the Form- R chemical reports 'are
shown with only one significant figure for confidentiality reasons.. Therefore,
some values shown here may not appear to be errors in release estimates.
BThe errors summarized in this table were made by 39 facilities..
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-4
-------
Facility Release
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
On-Site to Land
Radian QA Reviewer's
Release Estimate
Estimate (Ibs/yr)*-8
400,000
0-1,000
200,000
7,000
6,000
5,000
2,000
0-1,000
2,000
0-1,000
0
0
(Ibs/yr)*-8
1,000,000°
300,000
0
70,000
50,000
0
0
2,000
3,000C
0-1,000
0-1,000
0-1,000
Source of Error8
Overlooked monitoring data
Miscalculated release estimate
Overlooked chemical properties
Miscalculated release estimate
Miscalculated release estimate
Incorrectly reported spill which
was neutralized/transcription
error
Transcription error
Overlooked additional source of
release
Overlooked emission factors
Overlooked facility data
Transcription error
Overlooked release from
treatment system
'ARelease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates.
8The errors summarized in his table were made by 39 facilities.
GA'preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-5
-------
Facility Release
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
Other Off-Site Transfer
Radian QA Reviewer's
Release Estimate
Estimate (Ibs/yr)*-8
0
0
1,000,000
10,000
800.000
0
400,000
0
0
400 , 000
0
300,000
(Ibs/yr)*-8
5,000,000
2,000,000
200,000
800 , 000C
70,000
500,000
0
400,000
400 , 000
0-1,000
300,000
0-1,000
Source of Error8
Transcription error
Transcription error
Misinterpreted recycle/reuse
instructions
Overlooked emission factors
Overlooked % of chemical in
release estimate
Misinterpreted de minimus rule
Misinterpreted acid/base
neutralization instructions
Overlooked chemical properties
Transcription error
Transcription error
Transcription error
Misinterpreted recycle/reuse
instructions
ARelease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates.
errors summarized in this table were made by 39 facilities.
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach .
1-6
-------
TABLE 1-1 (Continued)
SUMMARY OF THE TOP TWELVE RELEASE
ESTIMATE ERRORS FOR EACH RELEASE MEDIUM
POTW
Facility Release
Estimate (Ibs/yr)*8
Radian QA Reviewer's
Release Estimate
(Ibs/yr )*•"
100,000
100,000
Source of Error8
2,000,000
500,000
500,000
400,000
400,000
200,000
200,000
400,000
0-1,000
100,000
3,000,000
0
0
0
0
0
0
600,000
200,000
0
Overlooked amount of chemical
purchased and released
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Miscalculated amount of chemical
in solution
Overlooked chemical properties
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
Misinterpreted acid/base
neutralization instructions
ARelease estimates reported by facilities on the Form R chemical reports are
shown with only one significant figure for confidentiality reasons. Therefore,
some values shown here may not appear to be errors in release estimates
^The errors summarized in this table were made by 39 facilities.
CA preferred alternative method was identified and used to calculate this release
estimate. Otherwise, Radian's estimate was computed using the facility's
approach.
1-7
------- |