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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
18-P-0001
October 5, 2017
Why We Did This Review
We conducted this review to
determine how the
U.S. Environmental Protection
Agency (EPA) uses Toxics
Release Inventory (TRI) data
to identify potentially
noncompiiant facilities in its
major regulatory programs.
Businesses that manufacture,
process or otherwise use
large volumes of listed
chemicals and meet other
conditions file TRI reports with
the EPA. TRI reports include
the quantitative releases of
chemicals to air, water and
land. The TRI also reports
the maximum amount of
chemicals on-site at any one
time during the calendar year.
Analysis of TRI data can be
used to identify potentially
noncompiiant facilities (non-
filers) in other EPA regulatory
programs, such as the Risk
Management Program (RMP),
and surface water dischargers
regulated under the National
Pollutant Discharge
Elimination System (NPDES).
This report addresses the
following:
•	Ensuring the safety of
chemicals.
•	Compliance with the law.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.aov/oia.
List of OIG reports.
Analysis of Toxics Release Inventory Data
Identifies Few Noncompiiant Facilities
What We Found
While using data analytics can be resource-
intensive when comparing data on facilities across
different EPA programs, this approach can
enhance environmental protection by identifying
facilities that are potentially noncompiiant with EPA
reporting requirements. We reviewed data from
three EPA programs and identified potentially
noncompiiant facilities by analyzing cross-program
data, as follows:
Noncompliance among
facilities that must comply
with multiple
environmental laws or
programs can be reduced
by making minimal
enhancements to EPA
reporting software.
•	RMP—We identified potential RMP non-filers based on TRI chemical and
volume data. During the course of our review, the EPA implemented its 3-year
review of non-filers, which identified potential non-filers for follow-up by EPA
regions. So far, EPA regions have found very few actual non-filers.
•	TRI—-We identified some potential non-filers from the chemical manufacturing
industry based on RMP chemical and volume data. The EPA recently
completed a review of 2011-2015 data to identify TRI non-filers from RMP
data and found only 4 percent to be actual non-filers.
• NPDES—We obtained potential NPDES non-filers from the EPA Discharge
Monitoring Report (DMR) Pollutant Loading Tool. We reviewed the largest
dischargers, accounting for 99 percent of the non-filer discharges. We found
NPDES permits for some but were unable to complete a review of all due to a
lack of specific discharger address information.
Based on the OIG's work during this review, TRI program staff implemented
enhancements to the TRI reporting software. This enhancement informs potential
non-filers about their potential RMP requirements if they file TRI reports over the
threshold of an RMP chemical. Further, TRI program staff also modified the
software to notify dischargers to surface water of the need for an NPDES permit.
EPA RMP program staff have committed to making similar enhancements to RMP
filing software to inform RMP filers of their potential TRI reporting requirements.
Recommendations and Planned Agency Corrective Actions
We recommend that EPA (1) clarify limitations to public NPDES data in the DMR
Pollutant Loading Tool, and (2) after the implementation of mandatory electronic
DMRs, review the usefulness of the data in the DMR Comparison Dashboard for
identifying possible unpermitted surface water dischargers using TRI data, and
modify as appropriate. The recommendations are resolved with agreed-to actions
pending.

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