ESTIMATION METHODS USED FOR TRI REPORTING
Laury E. Saligman and Maria I. Menor
Office of Cooperative Environmental Management
U.S. Environmental Protection Agency,
1992-1993 NNEMS Fellowship Program
August 9, 1993
-------
Disclaimer
This report was written under the auspices of the National Network
for Environmental Management Studies fellowship (NNEMS) to support
the activities of the National Advisory Council for Environmental
Policy and Technology (NACEPT). NACEPT is a public advisory
committee established to inform and advise the Administrator and
other officials of the Environmental Protection Agency (EPA) on
policy related issues. This report has been reviewed for approval
by neither NACEPT nor the EPA and, hence,, the contents of this
report and recommendations do not necessarily represent the views
of either organization.
-------
Acknowledgment: s
The authors would like to thank the following people for their
assistance with this project: David Graham, Office of Cooperative
Environmental Management; Edward Weiler, Pollution Prevention
Division, Office of Pollution Prevention and Toxics (OPPT); Lisa
Capozzoli, TRI Librarian, OPPT Library.
In addition, the authors would like to thank Anning Smith, Kathy
Franklin, and John Harman of OPPT for their time and energy spent
reviewing and commenting on the draft version of this report.
-------
TAR1.E OF CONTENTS
I. Introduction 1
I.I Background on TRI 1
1.2 Report Background 4
II. Origins of Basis of Estimate Data Element 8
III The Study: General Tracking 13
of Basis of Estimate Reporting on Form R
III. 1 Purpose of Research 13
III.2 Procedure 14
III.2.1 Charts for Each Medium 15
III.2.2 Graphs 15
IH.2.3 Charts for Each Estimation Method 16
III.3 Data and Results 16
Table A: Charts on Number of Estimates
Table B: Graphs on Number of Estimates
III.3.1 Fugitive Air Releases 19
III.3.2 Point Source Air Releases 21
ffl.3.3 Chemical Injected Underground And Released
To Water and Land 22
III.3.4 Transfers to POTWs and Other Off-Site Locations 23
III.4 Charts for Each Estimation Method 24
III.4.1 Other 25
III.4.2 No Basis Reported 26
III.4.3 Measurements 28
III.4.4 Calculations 29
III.4.5 Emission Factors 30
III.5 Discussion on Data Analysis 31
IV. EPA's Data Quality and Enforcement Activities 32
V. Conclusion and Recommendations 37
VI. Bibliography 41
VII. Appendix 43
Table: Number of Pounds Released
Graph: Number of Pounds Released
-------
I. INTRODUCTION
I . 1 BACKGROUND ON TRI
In 1986, Congress enacted the Emergency Planning and Community
Right-to-Know Act, which has two main purposes: to encourage and
support emergency planning for responding-to chemical accidents;
and to provide local governments and the public with information
about possible chemical hazards in their communities. One of the
major provisions of this law is toxic chemical release reporting,
which is covered under Section 313 of EPCRA. Certain businesses
are required to submit reports each year on the amounts of toxic
chemicals their facilities release into the environment, either
routinely or as a result of accidents. The purpose of this
reporting is to inform government officials and the public of
releases of over 300 toxic chemicals and 20 chemical categories.
These data are maintained and publicly disseminated as the Toxics
Release Inventory (TRI). TRI regulations require facilities to
report chemical releases and transfers to the extent that data
are available and reasonably ascertainable, and to indicate how
they arrived at the reported amounts.
A facility is subject to the reporting requirements if all of
the following apply:
• It has 10 or more full-time employees.
• It conducts manufacturing operations (that is, if the
facility is included in Standard Industrial Classification
Codes 20 through 39).
-------
• It manufactures, processes, or in any other way uses any of
the listed toxic chemicals in amounts greater than the
threshold quantities.
The threshold quantities for manufacturers and processors are as
follows:
• 75,000 pounds during the 1987 calendar year
• 50,000 pounds during the 1988 calendar year
• 25,000 pounds during the 1989 calendar year and in
subsequent years
• 10,000 pounds otherwise used.1
Each-facility must complete and file the Toxic Chemical Release
Inventory Reporting Form (hereafter "Form R") for each listed
chemical or "listed chemical category for which the facility meets
or exceeds the- thresholds above.
Items 5 and 6 in Part III of the 1990 Form R require the
following releases and transfers of the chemical be reported (in
pounds per year):
Section 5
• To air from fugitive or non-point sources
• To air from stack or point sources
• To water directly discharged to a receiving stream
• In wastes that are injected underground
Section 6
• To water discharged to a- publicly owned treatment works
(POTW)
•^•Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, EPA 560/4-88-002 (Washington, DC: U.S. Environmental
Protection Agency, December 1987), p. 1-1.
-------
In other wastes transferred off-site for treatment or
disposal.*
After release points have been identified, facilities must
estimate the amount of toxic chemical released. Estimates are
based upon monitoring data, mass balance, emission factors, or
other approaches such as engineering calculations and/or judgment
(or some combination of these methods). The technique used must
be reported on Form R, and is referred to as the Basis of Estimate
for each amount released to air, water, or land. This reporting
of Basis of Estimate is tied to each type of release or transfer
for each chemical. It is this data element that our study focuses
upon.
Section 313 provides four categories on Form R that submitters
must choose from to report how they estimate their toxic chemical
releases, and facilities must enter a letter code that identifies
the method that applies to the largest portion of the total
estimated release quantity. The codes are as follows:
M- Estimate is based on monitoring data or measurements for
the toxic chemical transferred to an off-site facility.
C- Estimate is based on mass-balance around entire processes
or pieces of process equipment. The amount of a chemical
leaving a vessel equals the amount entering.
Therefore, if input and output or "product" streams are
known (based on measured values), a waste stream can be
calculated as the difference between input and product (any
accumulation/depletion of the chemical in the equipment,
e.g., by reaction, must also be accounted for).
^Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, EPA 560/4-88-002 (Washington, DC: U.S. Environmental
Protection Agency, December 1987), p. 2-1.
-------
E- Estimate is based on published emission factors that are
related to the type of process or equipment that the
facility is using. Such emission factors are those relating
release quantity to throughput or equipment type (air
emission factors are an example). Emission factors are
based on the average measured emissions at several
facilities in the same industry.
O- Estimate is based on other methods such as engineering
calculations (for example, estimating volatilization using
published mathematical formulas), non-chemical-specific
emission factors,or best engineering judgment.!
I.2 REPORT BACKGROUND
As the law's title reveals, a main purpose of the Emergency
Planning and Community Right-to-Know Act is to provide local
governments and the public with information about possible
chemical hazards in their communities. Citizens have the right to
make their own informed decisions about whether the toxic
chemicals in their communities are a threat to their health and
their environment. The Toxics Release Inventory was designed to
help citizens make these decisions, and the intent of the Basis of
Estimate data element was to provide users with the necessary
information on the origin and quality of the data. What is argued
here is that without a clear understanding of how TRI release
figures were derived, the decisions that members of the public
make based on these figures is that much less informed. This study
will evaluate the validity and utility of the "Basis of Estimate"
data element and discuss methods to increase its usefulness. The
following sections will analyze the effectiveness of the Basis of
^•Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, EPA 560/4-88-002 (Washington, DC: U.S. Environmental
Protection Agency, December 1987), p. 2-6.
-------
Estimate data element, determine the usefulness of the information
provided, and explore the future of this data element on
subsequent versions of Form R.
The need for analysis of Form R's Basis of Estimate was sparked
by observations by the Office of Pollution Prevention & Toxics'
Pollution Prevention Division staff (PPD).1 In the research of
issues dealing with the Toxics Release Inventory, PPD had observed
that submitters listed "Other" as their Basis of Estimate with a
much higher frequency than the remaining estimation categories.
Toxics in the Community: National and Local Perspectives The 1989
Toxics Release Inventory National Report lists "Other" to be the
Basis of Estimate" between 17 and 50 percent of the time,
depending on the medium.2 This raises concern since submitters are
not required to specify the technique they used when they list
"Other." For this reason, the authors were encouraged to embark
on conducting more detailed analysis into the use of all four
Basis of Estimate categories, focusing on the frequency of
"Other."
A project recently conducted by the Research Triangle
Institute for PPD was another factor that led to this study.
Titled "Assessment of Changes in Reported TRI Releases Between
1 Ed Weiler of the PPD noticed the preponderance of the use of "Other" in TRI
reporting and suggested that the authors investigated the extent of this
situation.
^ Toxics in the Community: National and Local Perspectives The 1989 Toxics
Release Inventory National Report, Hampshire Research Associates, Inc.p.128.
This study provides a chart containing the number of pounds released and the
percentage of the total which they represent. The data analysis in the
present study differs form that in the National report because it examines the
number of estimates made by facilities as opposed to tonnage and provides a
longitudinal comparison over the last for years for number of estimates made
in for releases made to each reporting media.
-------
1989 and 1990," the purpose of the project was "to assess the
comparative impact of real versus paper changes on TRI
submissions. In particular, the study focuses on the extent to
which three factors—changes in measurement techniques,
production fluctuations, and source reduction activities—affect
changes in reported TRI releases."^
Changes in measurement technique had the smallest impact of the
three factors contributing to changes in TRI release figures. 24
percent of all facilities surveyed claimed a reporting change due
to changes in their measurement or estimation method. In terms of
quantity of pounds released, changes in measurement or estimation
method resulted in an increase of 82 million pounds and a decrease
of 104 million pounds of toxic chemicals reported under TRI
legislation. The impact of these changes were considered small
relative to source reduction and production changes, however, the
authors believe that existence of such paper change makes the area
worthy of investigation.
This study will lend further insight to RTI's project and to
EPA's research into the improvement of Form R. Part II of this
study will examine the legislative history of the Toxic Release
Inventory in order to shed light on the decision to include the
Basis of Estimate data element on Form R. Issues to be discussed
in this section include the initial the reasons for including the
Basis of Estimate data element and some of its fundamental
1"Assessment of Changes in Reported TRI Releases Between 1989 and 1990",
Research Triangle Institute. Prepared for U.S. Environmental Protection
Agency, Office of Pollution Prevention & Toxics, Pollution Prevention
Division, Washington, DC. EPA Contract No. CR8818760-01-0 p. 1-1.
-------
limitations. Part III of the study will analyze what reporting
facilities are doing to ensure that the purpose of this data
element is fulfilled. This section provides information about the
number of instances that each Basis of Estimate is listed for the
release amount of a specific chemical to each release medium.
This analysis is unique in that it compares the first four years
of TRI reporting in terms of estimation technique. Particular
attention was paid to the "Other" category.
The data collected here may further supplement the RTI study
which analyzed the results from a sample of reporting facilities
and may lead to further study on the reconfiguration or
elimination of the data element from Form R. Part IV of this
study focuses on what EPA is doing to ensure that the purpose of
the Basis of Estimate data element is fulfilled. Here, the issues
of compliance and enforcement of TRI's policy regarding the Basis
of Estimate data element are examined.
-------
II. ORIGINS OF BASIS OF ESTIMATE DATA ELEMENT
This section will discuss the development of the Basis of
Estimate data element and the decision to include it on Form R.
The research conducted in this respect included analysis of
relevant rule-making materials and discussions with members of EPA
who were involved in creating Form R.1
The designers of Form R decided that users of TRI data should
have an idea how the release figures for each environmental medium
were derived; subsequently, the four categories that comprise the
Basis of Estimate data element were created. According to OPPT's
Environmental Assistance Division (EAD), the designers of Form R
did not try to generate a finite number of methodologies that
could be used to estimate release quantities; rather, they devised
estimation categories based on the kind of data reporting
facilities would have readily available to them. Therefore, when
TRI was introduced in the Federal Register as a proposed rule in
June 1987, it was stated that EPA proposed to require a data
element that would indicate whether the quantity of toxic chemical
reported was derived primarily based on monitoring data for the
wastes leading to release, mass balance calculations of streams
entering and leaving process equipment, emissions factors, or
^ Interviews with Larry Longanecker, U.S. Environmental Protection Agency,
Office of Pollution Prevention and Toxics, Economics, Exposure and Technology
Division, Chemical Engineering Branch, Deputy Director; and
Kathy Franklin, U.S. Environmental Protection Agency, Office of Pollution
Prevention and Toxics, Environmental Assistance Division, Toxics Release
Inventory Branch, Chemical Engineer.
8
-------
other approaches, such as best engineering judgment.2
Additionally, the designers of the data element hoped that this
data element would be useful for identifying situations in which
monitoring data might be obtained as part of follow-up activities
by EPA or states.
By December of the same year, the Information Collection
Request for the Toxic Release Inventory Reporting Form was sent to
the Office of Management & Budget, wherein the purpose for the
Basis of Estimate data element read as follows: "... (to) provide
users of the data with a relative indication of the quality of
the data and how it was developed."^ According to EAD, the
emphasis above should be placed on the term "relative" since the
Basis of Estimate was never meant to be more than a "rough
indicator" of data quality and how the release figures were
developed.2
Furthermore, EAD emphasizes that it would be difficult for the
data element to give a a rough indication of data quality. Data
quality is a complex issue, being examined by several offices
within the agency. Currently, there is no definition of "data
quality" relating to the Basis of Estimate data element. Even if
quality could be defined, users of the data have no indication of
^•Federal Register/Vol. 52, No. 107/ Thursday, June 4, 1987/ Proposed Rules, p.
21161.
1 From Supporting Statement to Request for OMB Review of Toxic Chemical
Release Inventory Reporting Form - Title III. Prepared for Office of Toxic
Substances, December 1987, p. 10.
^ Discussions with Larry Longanecker and Kathy Franklin.
-------
the percentage error associated with each estimation category
because it would be too difficult to calculate.
The Basis of Estimate data element is fundamentally limited in
its ability to provide information regarding the quality of the
release estimates for several other reasons. Data quality is
linked to accuracy which depends on the difference between the
actual quantity of chemicals released and the estimated value.
First/ it is impossible to certain of the actual release value.
Second estimated values depend on several factors including:
• amount and quantity of available monitoring/measurement
data
• the type of estimate necessary if no monitoring data
exists
• the expertise of the staff completing the report
• the nature of the process involved.1
One conclusion of the site visit program study, then, and a caveat
for the research presented here is that the "quality" of release
i
estimates in the TRI database will continue to be limited by the
quality and the amount of data available to the individual
reporting facility personnel.
The Basis of Estimate, when entered properly, is more useful
in providing an indication of how the release estimates were
developed than in providing an indication of the estimates'
quality. This paper will not address issues of data quality
1 Radian Corporation, "Site Visit Program to Assess 1988 Toxic Release
Inventory Data Quality" July 1991, p.3-28.
10
-------
involved with TRI estimates. First the research presented in this
report will address the extent to which the basis of estimate data
element provides information on how the data was developed.
Without users knowing the how release figures were derived, they
cannot know the quality of the specific measurement or estimate.
The focus of this study will therefore be on the second purpose of
the data element, to inform users of the method used to develop
the data.
One factor that limits the ability of the data element to
reveal the estimation used in a release figure is the fact that a
single release estimate often involves the use of more than one of
the four estimation techniques from which submitters were required
to choose. For example, if 40 percent of stack emissions of the
reported toxic chemical were derived using monitoring data, 30
percent by mass balance, and 30 percent by emission factors, the
reporting facility would have to enter the letter code "M" for
monitoring. This letter code does not represent the other two
methods used to find the release estimate and, therefore, does not
give the full story on how the facility estimated its stack
emissions of that particular chemical.
EPA allows each facility to decide which estimation method will
provide the most accurate release figure. To assist facilities,
EPA provides general guidance in choosing an estimation method.
(This guidance will be discussed in detail in the next section).
1 1
-------
BAD emphasizes that the Basis of Estimate data e'lement was not
meant to dictate a preferred hierarchy of estimation methods.
There does seem to be an implied preference for the use of
monitoring data based on the assumption, that generally it is more
accurate than other estimation methods. For example, the guidance
manual,Estimating Releases and Waste Treatment Efficiencies For
the Toxic Chemical Release Inventory Form: Section 313 Emergency
Planning and Community Right-to Know Act of 1986 states "Although
no monitoring is required to comply with the reporting
requirements, facilities are urged to use (readily available)
monitoring data.ul
Lastly, it is important to point out that throughout the rule-
making process, it was emphasized that reporting this data element
was never meant to create an additional reporting burden on
facilities. The Code of Federal Regulations that implements EPCRA
states:
"No additional monitoring or measurement 'of the quantities or
concentrations of any toxic chemical released into the
environment, or of the frequency of such releases, is required
for the purpose of completing this form, beyond that which is
required under other provisions of law or regulation as part of
routine plant operations."4
1 Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form: Section 313 Emergency Planning and Community Right-to
Know Act of 1986. p. 1-2
4 40 CFR Ch. 1 (7-1-89 Edition), p. 286.
12
-------
III. THE STODY: GENERAL TRACKING OF
BASIS OF ESTIMATE REPORTING ON FORM R
III.I PURPOSE OF RESEARCH
The purpose of the following data analysis is to evaluate if
the Basis of Estimate data element has successfully fulfilled one
of its original goals; to provide TRI users with information on
how the data was developed. A rigorous and thorough analysis of
facilities' responses will make it possible to evaluate if the
Basis of Estimate data element provides sufficient information on
how the release figures were derived.1
This study aims at understanding industry's responses to the
Bases of Estimate. Although analyzing the tonnage of chemical
released leads to important insights on how the environment and
public are affected, facilities' behavior is best understood by
analyzing the number of times each estimation technique was used.
The data analysis therefore focuses on the number of estimates
made by facilities as opposed to the number of pounds released
into the environment. Information pertaining to pounds released
is available in the appendix.
The data presented in this section provides information on
general patterns of estimation techniques reported from the years
^•As discussed in section II, Origins of Basis of Estimate, the first goal of
the Basis of Estimate data element as stated on the ICR is to provide users
with a relative indication of the data quality of release figures. Data
quality of TRI estimates is too nebulous to be captured by the Basis of
Estimate codes given on Form R. For this reason the data analysis section of
the study will focus solely on the second purpose of the data element; to
provide information on how data was developed.
13
-------
1987 to 1990. Analysis over a four year period yields information
on the distribution of estimation methods reported. These
responses are intended to "inform persons about releases of toxic
chemicals to the environment; to assist governmental agencies,
researchers, and other persons in the conduct of research and data
gathering; to aid in the development of appropriate regulations,
guidelines, and standards; and for other similar purposes."1 The
usefulness of the Basis of Estimate question for TRI users with
respect to the preceding goals will be the unifying thread
throughout the analysis.
Special attention will be placed on the "Other" category.
This category, which is inherently vague, can potentially create
confusion in the interpretation of TRI data and impede' users
understanding of the numbers. The "Other" category will
therefore be rigorously analyzed to help policy makers transform
the category into one which better fulfills the intentions of TRI
and the Basis of Estimate question.
III.2 PROCEDURE
Data was collected using the TRI component file of -the TOXNET
system, an on-line system which accesses the main database-of
filed TRI reports in the National Library of Medicine in Bethesda,
Maryland. The number of estimates made and the number of pounds
released or transfered were found for each for the seven -listed
media: non-point air , point air releases, water, underground
1TRI Activities Under Section 313 of EPCRA Renewal of Information Collection
Request, EPA #1363.05, p.2-3
14
-------
injection, land, transfers to publicly owned treatment works, and
transfers to other off-site locations.
III.2.1 CHARTS FOR EACH MEDIUM
Charts were created for each release media and contain the
numbers retrieved from the TRIS system for all four estimation
codes as well as for forms missing a Basis of Estimate code.
These numbers were summed and the percentage of total estimates or
pounds which each estimation technique represents was then
calculated. These values will be referred to as "percentage
values." Comparing these percentage values across the four year
period, 1987 through 1990, allows the observance of any changes
that might be occurring over time. That is, a relative decline
in the use of one method or increase in another becomes clear with
the data displayed in this format.
Coefficients of variation were calculated for the percentage
values in order to assess their degree of variability over the
four year period. In order to compare two or more distributions
in terms of their degree of variability, the most meaningful
measure is one that captures relative variability. Defined as the
standard deviation divided by the mean, the coefficient of
variation measures relative variability, whereas the standard
deviation measures absolute variability.
III.2.2 GRAPHS
Graphs were created to provide a visual representation of
the relative use of one estimation method versus another. Two
sets of graphs were developed; one set to show the actual number
of estimates made and the second set to show the percentage of
15
-------
total estimates which each estimation method represents. The
first set of graphs plots the estimation technique on the
horizontal axis and the the number of estimates (or number of
pounds released) on the vertical axis. For each estimation
method listed on the horizontal axis there are four vertical
columns corresponding to the four reporting years. Such a
graphical representation reveals any increase or decrease in a
given estimation method over time.
The second set of graphs plot the percentage of total
estimates made by each technique against the reporting year. Each
of the four columns is broken into different color segments which
correspond to the Basis of Estimate code. This type of
representation.allows comparison of industry's use of the
different estimation codes relative to one another.
III.2.3 CHARTS FOR EACH ESTIMATION METHOD
In order to provide a better understanding of the relative
use of each estimation technique for each medium, charts were
created to display the average percentage value for the four year
period and the associated coefficient of variation. For each1 of
the four estimation techniques, the media were listed in
descending order, beginning with the medium which the designated
estimation method was most frequently used to determine TRI
releases.
111.3 DATA AND RESULTS
In order to make the data analysis treatable, information is
presented in four sections, each pertaining one of the following
16
-------
release media : Section III.3.1 fugitive air, Section III.3.2
point source air, Section III.3.3. underground injections, land,
and water, and (4) transfers to publicly owned treatment works,
and other off-site locations. These charts show the percentage
of estimates made by each given estimation technique for the
reporting years 1987 through 1990 inclusive.
For each medium or group of media the charts are arranged as
follows. The left hand column identifies the estimation Basis of
Estimate code indicated by facilities on Form R. The four
estimation codes provided by Form R (i.e. Measurements,
Calculations, Emission Factors, and "Other") as well as two
additional categories were incorporated into the chart. A "No
Basis Reported" category was included because in some instances no
code was entered. A "Multiple Categories" variable was added
because releases to 1) water, and 2) land, as well as transfers
to both 1) POTWS and 2) other off-site locations are divided into
several subcategories of release media. Part III, Section 5.3 of
the 1990 Form R requires separate responses for estimates of
discharges to each distinct receiving stream or body of water;
Part III, Section 5.5 requires facilities to list separately
releases to on-site landfills, land treatment/ application
farming, surface impoundment, and other disposal; and Part III,
Section 6 requires facilities to report transfers to each POTW and
other off-site location separately. Estimates made for more than
one subcategory under these media are grouped together under
"multiple subcategories reported". The set-up of TRIS makes
pooling the numbers together the most useful and efficient means
17
-------
of data analysis. Furthermore, the number of "Multiple
Categories" entries represent a very small percentage of total
records (between 0% and 4% for percentage of estimates) and are
therefore not expected to have a significant effect on the study's
results.
18
-------
Number of Estimates Made
Fugitive Air Releases
40.000TT
35,000
30,000
25,0001-
Stack Air Releases
Releases to Water
10,000-
6,000
6,000
Releases Injected Underground
-------
7,000
6,000-
5.ooo-f
4.000-f
1
3,000-f
2,000-f
i,ooo4
o4
Releases to Land
fflte™
i
B
•
•
P
.
*> 0 « ^ "
I | 1 i I i
= •= f
-------
Percentage of Estimates Recorded with Each Basis of Estimate Code
Fugitive Air Releases
/Vps
/A
iwK^mlm
90%
80%
70%-
60%-
50%-
40%-
30%-
20%-
10%
0%
1987
1088 1989
1990
Stack Air Releases
D No Basis
Reported
(13 Otter
1987
1988 1989
1990
Releases to Water
100%
80%
60% 1
40%
20%i
1987 1988 1989 1990
Releases Injected Underground
100%
80%
60%
40%
20%-
1987 1888 1989 1990
-------
Releases to Land
1087 1088 1088 1080
Transfers to Off-Site Locations
1087
1088
1080
1800
Transfers to Publicly Ownec
Works
No Basis Reported
Other
Emissions Factor
Calculations
LJ Measurements
1087 1088 1080
1000
-------
III.3.1
FUGITIVE AIR RELEASES
Fugitive Air Releases
Percentage of
Measurements
Percentage of Mass
Balance Calculations
Percentage of
Emission Factors
Percentage of "Other"
Percentage of No
Basis Reported
1987
4
13
15
62
6
1988
4
14
13
63
6
1989
4
14
13
63
6
1990
4
13
13
63
6
Average
4
14
14
63
6
CV
0.02
0.02
0.06
0.01
0.02
Generally, engineering estimates and other approaches are
the most applicable methods to estimate fugitive air emissions.1
These estimates are recorded in the "Other" category. Fugitive
emissions are usually diffuse and therefore difficult to directly
measure.^ Similarly, mass balance calculations tend not to be
the most applicable estimation method because the release from a
leaking source is small relative to the total quantity of
chemicals and therefore can be easily masked by inaccuracies in
input and output values. ^
The "Other" category encompasses several different yet
frequently used estimation methods for fugitive emissions. For
example, in certain cases emission factors are the most applicable
estimation method, however many available emission factors are not
IA slide from EPA's Form R Training Course Environmental Assistance Division
of OPPTS
o
EstJ.matj.ng Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, EPA 560/4-88-002 (Washington, DC: U.S. Environmental
Protection Agency, December 1987), p.3-17
3 Ibid, 2-8
19
-------
chemical specific but for VOCs or pariculates which then require
adjustments. Such estimates are coded in the "Other" category and
not in the "Emission Factors" category.1
In addition, computer modeling programs are sometimes used in
determining chemical releases from volatilization of on-site
treatment of aqueous or solid wastes. Knowledge of the major
pathways for the chemical, type of waste site, and set of
meteorological conditions must be accounted for in the estimate.
EPA has created computer models for estimating secondary releases
from nonaerated impoundments, aerated impoundments, disposal
impoundments, land treatment, and landfills. Estimates made using
these models are also reported with the Basis of Estimate code
marked as."Other."2
•'•Kathy Franklin, Comments on Draft Report, 6/7/93.
^Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, -EPA 560/4-88-002 (Washington, DC: U.S. Environmental
.Protection Agency, December 1987), p.3-r20
20
-------
The overwhelming majority (i.e. 63 percent) of estimates are
recorded in the "Other" category. When TRI users review the
database, it is impossible for them to know if the majority of
the estimates of fugitive release figures were developed from
engineering estimates, non-chemical specific emission factors,
EPA modeling.programs, or other methods entirely. The release
figures derived from all these different methods are coded in the
"Other" category.
III.3.2
POINT SOURCE AIR RELEASES
Percentage of
Measurements
Percentage of Mass
Balance Calculations
Percentage of
Emission Factors
Percentage of Other
Percentage of No
Basis Reported
1987
7
13
9
50
22
1988
8
15
10
61
6
1989
8
15
10
61
6
1990
8
15
10
61
6
i
Average
8
15
10
58
10
cv
0.08
0.08
0.06
0.10
0.82
"A relatively greater percentage of point source air emission
estimates than fugitive air emissions were measured directly (8%
for the former as compared to 4% for the latter). However, 91% of
the point source releases are not monitored directly revealing
that facilities rely upon mass balance calculations, emissions
factors', and other techniques to estimate point source releases.
Data show mass balance calculations to be a major method of
estimating point source air releases (15% of total estimates on
21
-------
the average for the four year period), then followed by emission
factors (10% ) and then measurements (8%). Again, the "Other"
category dominates the field, representing 58% of the point source
estimates made during the four year period.
III.4.3 CHEMICALS INJECTED UNDERGROUND AND RELEASED TO
WATER AND LAND
Underground
Injections
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Releases to Water
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Percentage Multiples
Releases to Land
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Percentage Multiples
1987
11
8
2
76
3
1987
28
6
2
51
12
1
1987
11
8
2
65
12
2
1988
16
6
2
76
1
1988
34
4
2
55
3
1
1988
13
7
3
71
5
2
1989
18
7
2
71
1
1989
36
4
3
54
2
1
1989
12
7
3
72
4
1
1990
18
7
2
63
9
1990
36
4
2
53
3
1
1990
12
6
3
70
7
1
Average
16
7
2
71
3
Average
33
5
2
53
5
1
Average
12
7
3
70
7
2
CV
0.20
0.15
0.07
0.09
1.14
CV
0.12
0.24
0.15
0.03
0.89
0.01
CV
0.06
0.09
0.12
0.05
0.54
0.15
It is interesting to point out the consistency of choice of
estimation technique used for estimates to these media. As seen
by a low coefficient of variation, the percentage of estimates
made using each estimation technique remained nearly constant.
However, for all three media the percentage of forms submitted
22
-------
without a Basis of Estimate dropped slightly from the first
reporting year to the second as the percentage of estimates
placed in the "Other" category increased. This phenomena will be
discussed in the section III.5, Data Arranged by Estimation
Method: No Basis Reported.
III.3.4
TRANSFERS TO POTWS AND OTHER OFF-SITE LOCATIONS
Transfers to POTWs
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Percentage of Multiples
Transfers to Other Off-
Site Locations
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Percentage of Multiples
1987
26
11
1
44
18
0
1987
22
14
1
38
22
3
1988
33
12
1
51
3
0
1988
25
17
1
50
4
3
1989
36
10
1
50
2
0
1989
24
17
1
51
3
4
1990
39
9
1
48
3
0
1990
24
16
1
52
3
1 4
Average
34
10
1
48
7
0
Average
24
16
1
47
8
4
CV
0.17
0.10
0.10
0.06
1.11
0.68
CV
0.06
0.09
0.13
0.14
1.18
0.06
Transfers, both to publicly owned treatment works and other
off-site locations, were reported under measurements more than any
of the other media. Off-site transfers (other than POTWs) tend to
be weighed for total amount of waste due to shipping and RCRA
manifesting policies. POTWs usually require facilities to monitor
wastewater. Furthermore, these discharges often have permitting
requirements.1
l-Kathy Franklin. Comments on Draft Report. 6-7-93
23
-------
During the four year period at least 34% of transfers to
POTWs and 25% of transfers to other off-site locations were
directly measured. These figures far exceed the number of
estimates made by the methods of mass balance calculations (17%)
and emission factors (1%). Similar to point source emissions, and
releases to water and land, the number of forms submitted without
a Basis of Estimate code decreased from 1987 to 1988, and then
remained fairly constant. However, the drop was much more
pronounced for transfers which plummeted from 18% in 1987 to 3% in
1988 for transfers to POTWs, and fell from 22% to 4% for transfers
to other off-site locations.
III.4 CHARTS FOR EACH ESTIMATION METHOD
For each estimation method, the data was organized by Basis
of Estimate to gain a better understanding of facilities' tendency
to employ each estimation technique. Five charts were produced
which correspond to the four estimation codes (Measurements, Mass
Balance Calculations, Emission Factors, and Other) as well as the
no basis reported category. The release media were listed in
descending order, beginning with the medium which the designated
estimation method was most frequently used to determine TRI
releases.
24
-------
III.4.1 OTHER
Percentage of Estimates Coded as "Other"
Releases
Underground Injection
Land
Fugitive Air
Point Source Air
Water
1987
76
65
62
50
51
1988
76
71
63
61
55
1989
71
72
63
61
54
1990
63
70
63
61
53
Average
72
70
63
58
53
Coefficien't
of
Variation
0.09
0.04
0.01
0.09
0.03
Transfers
Other Locations
P.O.T.W.s
38
44
50
51
51
50
52
48
48
48
0.14
0.06
The overwhelming tendency for facilities to report TRI
releases in the other category is clearly displayed in the
preceding chart. Depending on the medium, the average number of
estimates recorded in the "other category" was between 48% and
72%. Around seven out of ten estimates made for underground
injection and releases to land were coded as "Other". Six out of
ten estimates to air (i.e. fugitive and point source) were coded
as "Other". Transfers, to POTWs and to other off-site locations,
represented the smallest percentage of use of the other category
which in both cases was around 48%.
The broadness of the "Other" category impedes user's
understanding of the how the data element was developed and
therefore prevents the Basis of Estimate data element from
fulfilling its original purpose. Rather than providing users
25
-------
information on how the data was developed, it conceals from them
the origins of the TRI release figures. The "Other" category
includes estimates made by engineering judgments, non-chemical
specific engineering calculations, computer modeling programs, and
unpublished emission factors. It is therefore impossible for
users to know how the majority of TRI estimates were made.
Furthermore, because of the "Other" category, users are
unaware of not only which estimation technique was employed, but
if facilities were switching from one method to another within the
"Other" category during the four year period. Perhaps one year a
facility used best engineering judgment and the following year
SOCMI emission factors. Using only publicly available data, users
would be totally unaware of this change.
III.4.2 No Basis Reported
Percentage of No Basis Reported
KsDeasffiS
Point Source Air
Land
Fugitive Air
Water
Underground Injection
1987
22
12
6
12
3
1988
6
5
6
3
1
1989
6
4
6
2
1
1990
6
7
6
1
9
Average
10
7
6
5
4
Coefficient
of
Variation
0.80
0.51
0.00
1.13
1.08
Trams IF® ITS
Other Locations
P.O.T.W.s
22
18
4
3
3
2
3
3
8
7
1.18
1.12
26
-------
For all media except fugitive air and underground injections,
the number of forms submitted without a Basis of Estimate code
dropped significantly between the first reporting year,,1987, and
subsequent years. One explanation for this drop is that EPA
detected the missing information and notified facilities to
correct the forms. x It is also important to point out that
following this initial drop, the percentage of forms without a
corresponding Basis of Element remained fairly constant. Users
therefore did not gain more knowledge of the derivation of data
over time.
Furthermore, the decrease in the numbers of forms submitted
without a Basis of Estimate code did not necessarily improve
users understanding of how the data was developed. For most
media, a decrease in "No Basis Reported" from 1987 to 1988
coincided with an increase of estimates coded as "Other."
Although the instant drop in forms lacking a Basis of Estimate
code showed that facilities gained a better understanding of Form
R and TRI reporting procedures, TRI users did not benefit from
this learning process. They remained unaware of how the release
figures were derived.
^Kathy Franklin. Comments on Draft Report. 6-7-93
27
-------
111.4.3 MEASUREMENTS
Percentage of Estimates made by Measurements
EffiDefflSffiS
Water
Underground Injection
Land
Point Source Air
Fugitive Air
1987
28
11
11
7
4
1988
34
16
13
8
4
1989
36
18
12
8
4
1990
36
18
12
8
4
Average
34
16
12
8
4
Coefficient
of
Variation
0.12
0.20
0.06
0.08
0.02
Trannsffffirs
P.O.T.W.s
Other Locations
26
22
33
25
36
24
39
24
34
24
0.17
0.06
For most of the media the percentage of estimates made by
direct measurements increased 1987 to 1988 and then stabilized. A
greater percentage of point source release estimates were made
using direct measurements than for fugitive air emissions. Point-
source air emissions are confined and therefore more likely to
have been measured than random and diffuse fugitive emissions.^
^Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form, EPA 560/4-88-002 (Washington, DC: U.S. Environmental
Protection Agency, December 1987), p. 2-8
28
-------
Percentage of Estimates made by Mass Balance
Calculations
K
-------
III.4.5 EMISSION FACTORS
Percentage of Estimates Made Using Emission Factors
K©D©ffl§®§
Fugitive Air
Point Source
Land
Water
Underground Injection
TT[rsinn§ff(er§
P.O.T.W.
Other Locations
1987
15
9
2
2
2
1
1
1988
13
10
3
2
2
1
1
1989
13
10
3
2
2
1990
- 13
10
3
3
2
Average
14
10
3
2
2
Coefficient
of
Variation
0.06
0.06
0.02
0.15
0.07
1
1
1
1
1
1
0.10
0.11
Chemical specific emission factors remained a consistently
small percentage of total estimates. This technique was employed
most frequently for releases to air(14% for fugitive and 10% for
stack emissions). For all other media the use of chemical
specific emission factors was almost negligible (1% to 3%). These
figures remained consistently low for all four reporting years.
30
-------
III. 5 DISCUSSION ON DATA ANALYSIS
This analysis used information on the public database to show
that the Basis of Estimate data element does not adequately
fulfill its original goal of informing users about the derivation
of reported release figures. Using only publicly available
information, it is impossible for users to have a clear
understanding of how TRI data was developed. If the Agency still
believes" this goal to be important, the data element must be
restructured.
The greatest obstacle to user's understanding of the derivation
of release figures is the magnitude and broadness of the "Other"
category. The majority of estimates for all releases and
transfers were reported with Basis of Estimate marked as "Other".
The broadness of this conceals from users any indication of how
the data was developed and thus prevents the data element from
fulfilling its original purpose.
31
-------
IV. EPA'S DATA QUALITY AND ENFORCEMENT ACTIVITIES
It is EPA's responsibility to guarantee that the information
provided through the Basis of Estimates is conveyed to the public
as completely as possible. This section will discuss what EPA is
doing to guarantee that TRI users have a relative indication of
the quality of the data and how it was developed. From the data
generated for this study, it appears that the Basis of Estimate
data element is not adequately tracked through TRI's data quality
process, since a percentage of submitters fails to comply with
this reporting requirement every year. This question can be best
answered by detailing the data management procedure. After
industry submits Form Rs to EPA's EPCRA Reporting Center, these
forms are processed, entered into a Local Area Network (LAN)
database and a sample is verified for data accuracy. Records
from the LAN database are periodically uploaded to EPA's mainframe
computer. EPCRA Reporting Center staff, with the assistance of
EPA personnel, use terminals connected to the mainframe to run
data quality reports, analyze the data for accuracy, and
standardize data (such as parent company names) across the
database.1
Submitting facilities are contacted, when necessary, to
notify them of noncompliance with the regulation and to resolve
data quality errors. Notices of Noncompliance (NONs) are sent to
•'•Toxic Release Inventory Productivity Review, Office of Toxic Substances, U.S.
Environmental Protection Agency, July, 1990, p. 8.
32
-------
facilities that have failed to provide or meet a critical
requirement such as the reporting year or signature. Such errors
impede data input to the mainframe base; failure to report a Basis
of Estimate, therefore, would not result in a NON.1 Failure to
comply with this reporting requirement, however, may result in the
mailing of a Notices of Technical Error (NOTE), which identifies
erroneous or inconsistent data submitted to EPA and states.2
NOTEs_are generated using the mainframe database and are triggered
by three types of technical errors: Categories I, II, and III.
Category I is comprised of the technical errors that are
considered the most serious; Category II errors are considered
major, and Category III errors are considered minor by
comparison.* One Category I error or two Category II errors on
one Form-R triggers the NOTE process (i.e. sending a NOTE to a
facility, which is described below.
Before they are mailed to facilities, NOTES are reviewed, first
by a.team of technical experts who are contractors such as the
Science Applications International Corporation; this team
determines whether the error conditions identified in the NOTEs
are valid or whether corrections can be made, with the submitter's
approval, by the contractor. NOTEs contain two parts: 1) the
p. 54.
^Discussion with Kim Orr, Office of Pollution Prevention and Toxic Substances,
Office of Pollution Prevention and Toxics, TRI Information Management Branch,
Information Management Division, TRI Data Administration Section.
* April 23, 1993 discussion with Kathy Franklin, U.S. Environmental Protection
Agency,.Office of Pollution Prevention and Toxics, Environmental Assistance
Division, Toxics Release Inventory Branch, Chemical Engineer.
33
-------
"Notice," which is a standard letter explaining what the NOTE is
and the requirements for responding to it, and 2) an error report
that is specific to the section of the form in which errors are
identified, explaining to the submitter how to correct the
error(s). Failure by a submitter to include a Basis of Estimate
is a Category II error; therefore, this and another Category II
error would result in the submitter receiving a NOTE.
Unfortunately, budget limitations have prohibited the enforcement
of this process; therefore, EPA has relied on a policy of
voluntary response on the part of submitters receiving NOTEs.**
Permeating TRI's data management procedure is an overall data
quality program that has the following objectives: "1) : identify
and assist reporting facilities so that the data submitted will
be of the highest quality; 2) insure high quality data entry; 3)
correct and normalize as much of the data as possible in order to
maximize the utility of the data; and 4) accurately assess the
relative validity of release estimates and other data."1 While
the first three objectives are not directly relevant to the Basis
of Estimate's original intent to provide information regarding the
relative quality (as well as derivation) of release estimates, the
fourth objective speaks directly to this purpose. Folded into
this objective is the goal to continue conducting site visits to
evaluate the accuracy of emissions estimates. EPA last
** ibid.
1-1990 Toxics Release Inventory Public Data Release, Office of Pollution
Prevention and Toxics, EPA 700-S-92-002 (Washington, DC: U.S. Environmental
Protection Agency, May 1992), pp. 198-199.
34
-------
contracted Radian to conduct site visits in order to determine how
well facilities used available data to estimate 1987 and 1988
releases.
The four categories that make up the Basis of Estimate data
element have never been reviewed by EPA. As mentioned earlier in
this report, it is difficult to use the Basis of Estimate as a
relative indicator of the quality of the release estimate because
it is difficult to pinpoint the accuracy of each estimation method
as they relate to the release figure. The site visits were
designed to reveal, among other things, whether more accurate
release estimation methods could have been used, based on
available information to the facilities. It turns out that the
site surveyors agreed with the calculation method used by the
facility for approximately 84% of release estimates.1 What is
more significant for discussion is the two-pronged approach site
surveyors used for identifying errors in release estimates.
First, the surveyors always recalculated releases using the
same technical approach used by the facility: Second, whenever
the-surveyors' experience and training indicated that a
calculation approach different from 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 fact, in the site visit report, accuracy was
measured by how closely facility estimates compared to the site
surveyors' estimates.) Further, though the four release
l"Site Visit Program to Assess 1988 Toxic Release Inventory Data Quality" July
1991, p.3-28.
35
-------
estimation techniques described in Section 313 and currently
available to reporting facilities are monitoring data, mass
balance, emission factors, and other (engineering calculations),
surveyors used what they considered to be a "more detailed
approach" in reviewing release estimation techniques which
considered the following:
1) Monitoring data or direct measurements;
2) Published emission factors;
3) Information from hazardous waste manifests;
4) Mass balance calculations;
5) Engineering calculations;
6) Engineering judgment; and
7) Other techniques including facility -derived emission
factors.x
In addition to continuing its site visit programs, EPA
intends to continue accuracy evaluations of TRI data by making
phone calls to facilities that fail certain edit checks for
quality of the technical data submitted on TRI's Form R. EPA has
also developed a guidance manual for EPA Regional inspectors on
what to look for when auditing an EPCRA reporting facility. The
manual provides inspectors with detailed guidance on "how to
determine if a facility has identified all reportable chemicals
and calculated thresholds properly and if the releases seem
reasonable."2
Toxics Release Inventory Public Data Release, Office of Pollution
Prevention and Toxics, EPA 700-S-92-002 (Washington, DC: U.S. Environmental
Protection Agency, May 1992), p. 199.
36
-------
VI CONCLUSION AND RECOMMENDATIONS
This report has shown that the Basis of Estimate data element
in its current form does not successfully provide TRI users with
knowledge of (1) the release figures' data quality and (2) how
the data was developed. This is due mainly to the
disproportionately large size of the "Other" category and the
fundamental limitations of the data element. Furthermore,
although TRI has a process that helps guarantee that information
submitted on Form R is complete, budget constraints have
prohibited EPA from providing adequate enforcement measures. In
spite of these limitations, EPA can improve the usefulness of the
information provided by TRI through the following recommendations.
The authors offer recommendations (1) and (2) as a two-
step process to help EPA determine the future of the data
element:
(1) EPA should conduct outreach efforts to discover the extent to
which users are interested in the data quality and derivation of
TRI release figures.
If such a study reveals that users do not find this
information useful the Basis of Estimate is needlessly burdensome
and should be deleted. In specific, industry wastes time in
answering the question, and EPA wastes time and valuable computer
space by entering the responses into TRIS.
(2.1) If users require information on how release figures are
derived, the Basis of Estimate must be redesigned to fulfill this
need.
37
-------
• Additional Basis of Estimate Codes should be given to
common estimation techniques.
The research undertaken by Radian Corporation during the 1990
and 1991 site visit programs demonstrate that it is possible to
create estimation categories that are more detailed than those
which exist today. The first step in reconfiguring this data
element should be to determine the various estimation methods
which facilities have coded in the the "Other" category. If there
are only one or two different techniques, then these techniques
should be given their own codes. If several methods, or
combination of methods comprise this data element, then EPA must
develop a means of representing these different estimation
techniques-'-.
Furthermore users should be aware of the cases in which
several estimation techniques are used for one reported release.
This objective could be obtained by (1) reporting all the relevant
estimation codes or (2) placing a secondary code next to the Basis
of Estimate code which notifies users that several estimation
techniques were used for a single estimate.
• Require submitters to specify estimation method when
listing "Other" as Basis of Estimate.
1 For example, engineering calculations and best engineering judgment are
acknowledged and discussed in the ICR and the TRI reporting package
instructions. If these types of estimates are so prevalent and considered
equally acceptable as mass balance calculations and emission factors, then the
agency should identify them to TRI users by coding them on the TRI data base.
Clearly engineering calculations and best engineering judgment are very vague
terms, but by incorporating them into Form R and then the TRI data base, users
would have a better indication of how the data was developed.
38
-------
It there are a multitude of different estimation techniques
which comprise the "Other" category, it may be too difficult to
represent all estimation methods by additional codes. Although
this information will not be available on on-line, it could made
publicly available through contacting the EPCRA reporting center.
However, the first alternative is preferable because the
information would be more accessible from the on-line database and
therefore is more in keeping with the spirit of EPCRA.
(2.2) Should users value having an indication of release figures'
data quality, a means of obtaining this information must be
developed.
The concept of data quality of estimates is too complicated
to be captured through a self-reported Basis of Estimate data
responses. EPA has not and cannot attach accuracy ratings to each
estimation method. An alternative method to asses data quality
must be developed, implemented, and conveyed to TRI users. One
possibility to determine the data quality is 'to conduct facility
audits similar to those originally intended by TRI's data quality
program.
4) EPA should provide increased guidance to submitters who fail
to comply with the Basis of Estimate reporting requirement.
An analysis of EPA's data management procedure for TRI data
shows that the failure to report a Basis of Estimate for a release
figure can trigger sending a NOTE to a facility. Unfortunately,
budget constraints have limited EPA in its efforts to follow up on
the NOTEs process with adequate enforcement. EPA has reported
39
-------
some success with the current policy of voluntary response.
However, the Agency must decide how important it is for submitters
of the data to comply with all reporting requirements of TRI and
should increase guidance,to improve compliance.
40
-------
VI. SOURCES
Booz, Allen & Hamilton. 1990. Toxic Release Inventory Productivity
Review, prepared for Office of Toxic Substances, U.S.
Environmental Protection Agency, Washington,.DC.
Environmental Protection Agency. 1989. 40 Code of Federal
Regulations, Part 372-Toxic Chemical Release Reporting: Community
Right-To-Know. (7-1-89 Edition).
Federal Register/ Vol. 52, No. 107/ Thursday, June 4, 1987/
Proposed Rules.
Franklin, Kathy. U.S. Environmental Protection Agency, Office of
Pollution Prevention and Toxics, Environmental -Assistance
Division, Toxics Release Inventory Branch, Chemical Engineer.
Hampshire Research Associates, Inc. 1991. Toxics In The
Community: National and Local Perspectives. Prepared for U.S.
Environmental Protection Agency,Office of Toxic Substances,
Economics and Technology Division, Washington, D.C.
Longanecker, Larry. U.S. Environmental Protection Agency, Office
of Pollution Prevention and Toxics, Economics, Exposure and
Technology Division, Chemical Engineering Branch, Deputy Director.
April 23, 1993 discussion.
Office of Pesticides and Toxics. 1987. Estimating Releases and
Waste Treatment Efficiencies For the Toxic Chemical Release
Inventory Form, Washington, DC: U.S. Environmental Protection
Agency, December 1987. EPA 560/4-88-002
Office of Prevention, Pesticides and Toxic Substances,Office of Pollution
Prevention and Toxics. 1992. 1950 Toxics Release Inventory Public
Data Release, Washington, DC: U.S. Environmental Protection
Agency. May 1992. EPA 700-S-92-002
Office of Toxic Substances. "Supporting Statement to Request for
OMB Review of Toxic Chemical Release Inventory Reporting Form -
Title III." Prepared for Office of Toxic Substances, Washington,
DC. December 1987.
Office of Toxic Substances. 1991. Toxic Chemical Release
Inventory Reporting Package for 1990, EPA 560-4-91-001
(Washington, DC: U.S. Environmental Protection Agency).
Orr, Kim. Office of Prevention, Pesticides and Toxic Substances,
Office of Pollution Prevention and Toxic Substances, Office of
Pollution Prevention and Toxics, TRI Information Management
Branch, Information Management Division, TRI Data Administration
Section.
41
-------
Radian Cooperation. 1991. "Site Visit Program to Assess 1988 Toxic
Release Inventory Data Quality," Radian Corporation. Prepared
for U.S. Environmental Protection Agency, Office of Toxic
Substances, Washington, DC. July 1991.
Research Triangle Institute. 1993. "Assessment of Changes in
Reported TRI Releases Between 1989 and 1990". Prepared for U.S.
Environmental Protection Agency, Office of Prevention, Pesticides
and Toxic Substances, Office of Pollution Prevention & Toxics,
Pollution Prevention Division, Washington, DC. EPA Contract No.
CR8818760-01-0.
Weiler, Edward, Office of Prevention, Pesticides and Toxic
Substances, Office of Pollution Prevention & Toxics, Pollution
Prevention Division, Washington, DC
42
-------
VIZ APPENDIX
The charts and graphs contained in this section refer to tonnage
of TRI chemicals released to the environment. Table VILA
displays the number of pounds released to each media as recorded
under each estimation technique for all four reporting years. The
chart is divided into seven subsections which correspond to the
seven media. Each subsection contains the number of total pounds
recorded by each estimation technique for all reporting facilities
from 1987 to 1990 inclusive. The left hand column identifies the
the bases of estimate which facilities can indicate on form R.
Measurements, calculations, emission factors, and "Other" are the
categories provided by form R.
Graph VILA is a set of seven graphs which show the actual
number of pounds released into the environment for each medium.
These graphs reveal an increase or decrease in the actual amount
of chemicals released into the environment. Graph VII.B shows the
percentage of pounds released as determined by each estimation
technique. These charts indicate a rise and-fall in the in the
relative use of one estimation technique as compared to another as
marked by a change in tonnage.
43
-------
Table VII. A: Pounds Released to Each Medium
F. for
Measurements
Calculations
| 1987 | 1988 | 1969 | 1990
33.068.263 31.746.369 28.737.948 26.603.654
268.730.978 268.106.143 264.532.951 220.063.321
Emission Factors 119.632.010 120.943.198 93.SS0.975 89.062.831
Other
372.523.171 378.813.168 35S.998.1S4 324.969.221
No Basis Reported . ^ ,^- ;. •Ł. -Ł&A*™ijiZjZ..-^^.'; %^J^ .. s^ ,-, •> '. -'~
246.325,782 297.SS8.70S 282.363.923 274.372.337
601.539.217 606.535.442 581.385.856 530.714.538
Emission Factors 131.S99.73S 136.473.236 116.775.989 107.347.720
Other
639.680.142 763.215.289 707.987.428 602.665.247
No Basis Reported (NBR) 298.S63.O68 77.317.843 64.539.894 43.029.556
Total
1.917.707.944 1.681.100.521 1.753.053.092 1.556.129.398
Percentage of M 13 16 16 18
Percentage of C 31 32 33 34
Percentage of E 7 7 7 7
Percentage of 0 33 41 40 39
Percentage of NBR 16 4 4 3
Ircentage 100 1OO 1OO 1OO
Measurements
Calculations
*"" "*" 1.279J61SJ652 "l 5?'. 187.1567' 100.548.658 151.368.120
4.639.737.417 46.118.073 24.15S.1S9 10.434.839
Emission Factors 130.389.641 7.324.407 1.679.647 1.617.427
Other
2.493.421.910 52.040.200 56.862.530 31.732.142
NO Basis Reported 677.199.237 68.778.202 2.649.160 1.422.165
Multiple Categories 51.670.478 3.875.092 2.659.699 776.496
Total
Percentage of M
Percentage of C
Percentage of E
Percentage of O
9.272.034.335 335.323.541 188.755.053 197.351.189
14 47 S3 77
50 14 13 S
1211
27 16 30 16
Percentage of NBR 7 21 2 1
Percentage Multiples 1110
Total Percentage 100 100 100 1OO
Flje.CfwTOBgg^giig ^j
Measurements
Calculations
729.803.992 672.773.853 352.116.234 297.724.691
1.679.650.736 94.547.349 34.284.720 36.323.101
Emission Factors 470.760 601.273 825.575 1.466.572
Other
499.695.001 596.653.998 778.150.477 387.082.916
No Basis Reported 172,273.084 530.439 2.897.577 15.779.967
Total
P mage of M
ige of C
jge of E
PelCKitage of O
3.081.893.595 1.365.106.912 1.168.276.583 738.379.247
24 49 30 40
55 7 3 5
O 0 0 O
16 44 67 52
Percentage of NBR 6 O 0 2
Total Percentage 100 100 100 100
Ave. (or Gil
four years
4
33
14
46
•
,
Ave. for all
lour years
16
33
7
38
7
Ave. lor an
lour years
48
20
1
22
6
Ave. for an
our years
36
17
0
45
2
Coefficient of
Variation
O.O4
O.03
0.10
O.02
0.43
Coefficient of
Variation
O.I3
0.04
O.04
O.O9
0.93
Coefficient of
Variation
0.54
0.98
0.48
0.34
1.22
Coefficient of
Variation
0.31
1.43
O.S9
0.47
1.26
Pagel
-------
Land
Measurements
Calculations
Emission Factors
Other
No Basis Reported (NBR)
Multiple Categories
Total
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage NBR
Percentage of Multiples
Total Percentage
Patwt
Measurements
Calculations
Emission Factors
Other
No Basis Reported
Multiple Categories
Total
Percentage of M
Percentage of C
Percentage of E
Percentage of O
Percentage of NBR
Multiple Categories
Total Percentage
Olfc?«te ./Transfers^..,.....
Measurements
Calculations
Emission Factors
Other
No Basis Reported
Multiple Categories
Total
Percentage of M
Percentage of C
Percentage of E
'ercentage of O
Percentage of NBR
Percentage of Multiples
Total Percentage
| 1987 |
SS2.438.119
794.494.116
9.393.258
683.123.700
286.606.412
37.030.867
2.363.086.472
23
34
0
29
12
2
100
336>86.423
407.61 7.753
86.561.817
659.956.272
404.640.374
0
1.895.562.639
18
22
5
35
21
0
100
577.065.914
354.434.723
10.457.044
661.879.423
395.258.325
92.771.084
2.091.866.513
28
17
0
32
19
4
100
1988 |
311.570.410
308.586.847
12.001.431
418.179.891
33.292.860
75.889.058
1.159.520.497
27
27
1
36
3
7
100
166.426.787
252.637.729
21.482.130
262.809.299
26.739.740
80.571
730.176.256
23
35
3
36
4
0
100
654.053.377
455.320.519
9.025.115
714.647.871
51.018.279
79.701.404
1.963. 766.565
33
23
0
36
3
4
100
1989 |
141.502.341
36.934.332
4.133.731
175.494.996
21.690.083
91.710.547
471.466.030
30
8
1
37
5
19
100
141.581.346
185.170.757
29.038.579
189.826.059
8.140.001
4.248
553.760.990
26
33
5
34
1
0
100
361. 760.430""
168.882.058
9.307.951
318.258.518
20.140.919
55.282.184
933.632.060
39
16
1
34
2
6
100
1990
216.057.982
21.983.410
1.302.941
156.104.083
25.336.858
28.271.093
449.056.367
48
<
0
35
6
6
100
113.429.652
139.549.641
32.316.316
161.209.640
2.837.550
523.624
449.866.423
25
31
7
36
1
0
100
•w
364.219.624
128.608.779
13.335.450
265.214.395
11.902.636
38.982.275
822.263.159
44
16
2
32
1
5
100
Ave for all
four years
32
18
1
34
6
8
Ave. for all
four years
23
30
5
35
7
0
i
Ave. for all
four years
36
18
1
34
6
5
Coefficient of
Variation
0.34
0.77
0.56
0.11
0.64
0.91
Coefficient of
Variation
0.16
0.20
0.35
0.02
1.45
1.76
Coefficient of
Variation
0.20
0.18
0.61
0.06
1.34
0.17
Page 2
-------
Table VII. A
Number of Pounds Released to the Environment
Fugitive Air Releases
400,000.000-
350.000.000^
300,000.000-"
250.000,000-
200,000.000-
150,000,000-
100.000,000
50.000,000^
0
Stack Air Releases
800,000.000
700,000.000
600.000.000
500,000.000-
400.000.000
300,000.000
200,000.000
100.000.000-
0
Releases to Water
5,000.000.000
4.500.000,000-
4,000,000,000-
3.500,000,000^
3,000,000,000-
2,500.000,000
2,000,000,000 '
1,500,000,000-;
1,000,000.000-1
500,000,000-'
0
Releases Injected Underground
1,800.000,000-
1,800,000,000-
1.400,000,000 -
1,200,000,000
1,000,000,000-
800.000.000-
600,000,000
400.000.000
200.000.000
0
-------
Releases to Land
800,000,000-
700,000,000-
600,000.000-
500.000,000^
400,000,000
300,000,000-^
200,000.000-r
100.000.000
0
Transfers to Off-Site Locations
800.000.000
700,000,000-
600,000.000
500.000,000
400.000,000-"
300,000,000-
200.000.000
100.000.000
0
Transfers to Public Owned
Treatment Works
700,000.000^
600,000.000
500,000,000-^
400,000.000-
300.000.000^
200,000.000
100.000,000
.•o
-------
Graph VII.B
Percentage of Release* Determined By Each Estimation Method
Fugitive Air Releases
1987 1988 1989 1990
Stack Air Releases
Calculations
Measurements
Releases to Water
100%^'
80% -t
60%
40%
20%
1987 1988 1989 1990
Releases Injected Underground
100%^
80%
1987 1988 1989 1990
-------
Releases to Land
1987 1988 1989 1890
Transfers to Publicly Ownec ® N° Baste Reported
Works
100%-
Qther
Emission Factors
Calculations
O Measurements
Transfers to Off-Site Locations
1987
1988 1989
1990
------- |