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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
Data Used for Annual Toxics
Release Inventory National
Analysis Are 99 Percent
Complete, but EPA Could
Improve Certain Data Controls
Report No. 20-P-0337
September 30, 2020
Average of
17,574,755
lbs
Average of
3,774,441,032
lbs

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Report Contributors:
Christina Lovingood
Dwayne Crawford
Ben Beeson
Alana Morrell
Steve Hanna
Abbreviations
EPA	U.S. Environmental Protection Agency
POTW Publicly Owned Treatment Works
TRI	Toxics Release Inventory
Cover Photo: Data used for the annual Toxics Release Inventory Analysis are 99 percent
complete. (EPA OIG image)
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^tD sr^	U.S. Environmental Protection Agency	20-P-0337
^	\ Office of Inspector General	September 30,2020

At a Glance
Why We Did This Project
We conducted this audit to
determine the extent to which
late reporting of Toxics Release
Inventory data impacts the
annual TRI National Analysis.
In 1986, Congress passed the
Emergency Planning and
Community Right-to-Know Act
to provide the public with
information about toxic
chemical releases and support
emergency planning. Facility
owners or operators report to
the U.S. Environmental
Protection Agency by July 1
each year on each toxic
chemical that they used in
quantities exceeding the
established toxic chemical
threshold for the preceding
calendar year. The chemical
information collected and
reported through the TRI
provides citizens with the
means to better understand
pollution sources in their
communities.
This report addresses the
following:
•	Operating efficiently and
effectively.
This report addresses a top EPA
management challenge:
•	Complying with internal control
(data quality).
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Data Used for Annual Toxics Release Inventory
National Analysis Are 99 Percent Complete,
but EPA Could Improve Certain Data Controls
The EPA's efforts to
follow up with late
reporters prior to
"freezing" the data
contributed to more
complete data.
What We Found
TRI release data that were reported late to the EPA
accounted for an average of less than one-half of
1 percent, or 70.3 million of the 15.2 billion total pounds
reported in the TRI annual reporting analysis from 2013
through 2016. The EPA publishes the annual TRI
National Analysis to summarize the submitted TRI data,
trends in the data, and findings from the perspective of
human health and environmental protection. Although the official deadline for
facilities to report data is July 1, the EPA accepts data submissions until it "freezes"
the dataset in mid-October. For the purposes of this report, we considered data late
if they are reported after the Agency freezes the dataset. The annual reports from
2013 through 2016 are based on a dataset that has more than 99 percent of the
data.
Communities located near the facilities that reported late may not have access to
current TRI data to make informed decisions. To improve data collection, the EPA
prompts the facilities that missed the July 1 deadline to comply with TRI reporting
requirements. Since this good practice is not documented as a standard operating
procedure, the EPA runs the risk of not replicating this practice yearly.
We also identified control weaknesses concerning the reporting of the final
disposition of chemicals that facilities transferred to a publicly owned treatment
works, or POTW. Reporting facilities can edit the default "POTWdistribution
percentages" that the EPA uses to estimate the final disposition of chemical
quantities transferred to a POTW. The EPA, however, cannot verify the validity of
the data since the reporting facility is not required to provide evidence to the Agency
supporting the edit. Current practices do not provide adequate controls to ensure
the validity and accuracy of TRI data for chemicals transferred to POTWs,
especially since facilities could alter the distribution percentages to report fewer
chemicals released into the environment. Facilities' edits of certain TRI transfer data
from 2014 through 2017 reduced the net pounds reported released by
3,354,235 pounds, or approximately 19 percent.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA continue to follow up with facilities that have not
reported their data before the freeze date, analyze the impact of late-reported data,
and establish controls over POTW distribution percentage edits to validate the
accuracy of the data. In its response and subsequent communications, the Agency
agreed with the recommendations and provided estimated milestone dates for its
planned corrective actions. All recommendations are resolved.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 30, 2020
MEMORANDUM
SUBJECT: Data Used for Annual Toxics Release Inventory National Analysis Are 99 Percent
Complete, but EPA Could Improve Certain Data Controls
Report No. 20-P-0337
This is a report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit was OA&E-FY18-0002. This
report contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. Final determinations on matters in this report will be made by EPA managers in accordance
with established audit resolution procedures.
The Office of Chemical Safety and Pollution Prevention and the Office of Water were responsible for the
issues discussed in this report.
Your offices provided acceptable corrective actions and estimated milestone dates in response to OIG
recommendations. All recommendations are resolved, and no final response to this report is required.
However, if you submit a response, it will be posted on the OIG's website, along with our memorandum
commenting on your response. Your response should be provided as an Adobe PDF file that complies
with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The
final response should not contain data that you do not want to be released to the public; if your response
contains such data, you should identify the data for redaction or removal along with corresponding
justification.
FROM: Sean W. O'Donnell
TO:
Alexandra Dapolito Dunn, Assistant Administrator
Office of Chemical Safety and Pollution Prevention
David P. Ross, Assistant Administrator
Office of Water
We will post this report to our website at www.epa.gov/oig.

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Data Used for Annual Toxics Release Inventory
National Analysis Are 99 Percent Complete,
but EPA Could Improve Certain Data Controls
20-P-0337
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		4
Scope and Methodology		5
Prior Reports		5
2	EPA Could Improve Controls Over Certain TRI Data		7
EPA's Robust but Undocumented Practice Encouraged Reporting
and Minimized Late-Reported Data		7
EPA Did Not Determine Whether Late-Reported Data
Impacted the Annual Analysis		9
EPA Fixed Errors Identified in OIG Management Alert		9
Insufficient Controls Over Modifications to POTW Distribution
Percentages in TRI Reports Can Change the Validity
of Reported Chemical Release Quantities		10
Conclusions		13
Recommendations		13
Agency Response and OIG Assessment		14
Status of Recommendations and Potential Monetary Benefits		15
Appendices
A TRI Reporting Analysis of Late-Reported Data	 16
B Agency Response to Draft Report	 17
C Distribution	 21

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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection
Agency's Office of Inspector General
conducted this audit to determine the
extent to which late reporting of Toxics
Release Inventory data impacts the
annual TRI National Analysis.
This report addresses, in part, the
discrepancies we found in Report
No. 19-N-0115. Management Alert: Certain Toxic Release Inventory Data
Disclosed to the Public Are Inaccurate, issued on April 8, 2019, concerning TRI
chemical transfers to publicly owned treatment works, or POTWs. POTWs are
sewage treatment plants that are typically owned by a state or municipality.
Background
Congress created the TRI program following a series of toxic chemical releases
from industrial facilities, which raised public concern about local readiness for
chemical emergencies and the availability of information regarding hazardous
substances. According to the EPA:
On December 4, 1984, a cloud of extremely toxic methyl
isocyanate gas escaped from a Union Carbide Chemical plant in
Bhopal, India. Thousands of people died that night in what is
widely considered to be the worst industrial disaster in history.
Thousands more died later as a result of their exposure, and
survivors continue to suffer with permanent disabilities. In 1985, a
serious chemical release occurred at a similar chemical plant in
West Virginia.
In 1986, Congress passed the Emergency Planning and
Community Right-to-Know Act (EPCRA) to support and promote
emergency planning and to provide the public with information
about releases of toxic chemicals in their community. Section 313
of EPCRA established the Toxics Release Inventory.
Since 1988, 42 U.S.C. §11023 has required facility owners or operators to report
each TRI4isted chemical that was manufactured, processed, or otherwise used in
quantities exceeding the established toxic chemical threshold during the preceding
Top Management Challenge
This audit addresses the following top
management challenge for the Agency, as
identified in OIG Report No. 20-N-0231,
EPA's FYs 2020-2021 Top Management
Challenges, issued July 21, 2020:
• Complying with internal control
(data quality).
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calendar year by July 1 of each year. The TRI National Analysis includes industry
data submitted up through mid-October before the EPA freezes the data.1
The TRI National Analysis is the Agency's annual publication that summarizes
TRI data submitted for the most recent reporting year, identifies and characterizes
trends in the data, and presents the Agency's interpretation of the data. The
chemical information collected and reported through the TRI allows the public to
better understand pollution sources in its communities. For example, lead is of
special concern because acute or chronic exposure is particularly dangerous to
fetuses, infants, and children, as their central nervous systems are more sensitive
to the damaging effects of lead. The EPA typically publishes its TRI National
Analysis in the January-March time frame of the second year following the
reporting year. For example, the national analysis for the 2017 reporting year was
published in March 2019 (Figure l).2
Figure 1: Timeline for TRI data collection, follow-up, and annual TRI National Analysis
EPA follows up to	Annual TRI
get late-reported National
data for annual TRI Analysis
National Analysis	published for
i	i
reporting year
i
f+
¦TRI reporting year-
Jul;
Deadline for
reporting	2nd week
of October
Data freeze
Source: OIG analysis. (EPA OIG image)
Subsequent to the annual national analysis, the Agency performs a follow-up data
quality review every spring that includes any data reported after the freeze date in
mid-October. The EPA then publishes those data in Envirofacts. a data system
available to the public to access information on TRI-reported releases.
TRI Reporting for Transfers to POTWs
The TRI includes the quantities of toxic chemicals released into the air, water, and
land. One of the specific reporting requirements is that facilities report the
quantity of TRI chemical wastes sent to off-site facilities for disposal, treatment,
energy recovery, or recycling. These wastes include wastewaters containing TRI
1	EPA website. "What is the Toxics Release Inventory?," last updated July 28, 2020.
2	The TRI National Analysis for the 2018 reporting year was published in February 2020.
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reportable chemicals that are sent to POTWs.3 TRI chemical wastes that facilities
transfer to POTWs subject to the TRI reporting requirements are reportable by the
facilities themselves. The POTWs that receive and treat the wastes are not
required to report to the TRI. This reporting of chemical transfers to POTWs is
complex and elevates the need for strong controls.
Since the discrepancies that we identified in Report No. 19-N-0115 all concerned
TRI chemical transfers to POTWs, we followed up on those issues in this report.
TRI reports that disclose transfers to a POTW should include the quantity of the
toxic chemical transferred as well as the final disposition of the toxic chemical.
To calculate the final disposition when a facility lacks specific data on the
ultimate disposition of chemical quantities transferred to a POTW, the EPA
provides suggested or default POTW removal and treatment rates for certain
chemicals to assist facilities in completing TRI reports. Facilities can apply the
default distribution treatment, removal, and release percentages to chemical
quantities transferred to a POTW.
If facilities have more accurate information on the final disposition of chemicals
based on factors such as continuous monitoring or random sampling, facilities
should use that information instead in their reports. For example, if a facility
transfers 1,000 pounds of chemical X to a POTW, the facility can apply the
default distribution percentages provided by the EPA to calculate the final
disposition of the chemical. If the default distribution percentages for chemical X
are that 40 percent of the chemical is treated, 40 percent of the chemical is
disposed of in a landfill or an injection well, and 20 percent of the chemical is
released, that would mean 400 pounds of the chemical transferred will be treated,
400 pounds of the chemical will be disposed of in a landfill or an injection well,
and the remaining 200 pounds will be released (Figure 2).
3 POTWs are treatment works facilities owned by a state or municipality, as defined by the Clean Water Act. "This
definition includes any devices or systems used in the storage, treatment, recycling, and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes sewers, pipes, or other conveyances only if they
convey wastewater to a POTW treatment plant. The term also means the municipality [as defined in [Clean Water
Act] section 502(4)] that has jurisdiction over the indirect discharges to and the discharges from such a treatment
works," according to Introduction to the National Pretreatment Program, dated June 2011.
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Figure 2: Example of POTW distribution percentage
f	POTW process-
I
Chemical
transfer to
POTW
S
Facilities
S i«"
Wastewater

processing

rTreated at i

^POTW 1
m
Facilities reporting transfers to POTWs
can edit these distribution percentages.
The EPA does not verify edits for
validity, which may impact data quality.
4 W
Disposed in an
injection well _
or landfill
^Released
W M
^off-site

Source: EPA OIG image.
Responsible Offices
Multiple offices within the EPA perform TRI-related tasks:
•	The Office of Chemical Safety and Pollution Prevention's mission is to
protect public health and the environment from risks from pesticides and
toxic chemicals. Its Office of Pollution Prevention and Toxics manages
the TRI program.
•	The Office of Information Management within the Office of Mission
Support serves as the Agency lead for collecting information, managing,
and reporting on programs, and developing and overseeing related Agency
policy and web services. Two such search tool services are the
Multisystem Search and the TRI Search, both found in Envirofacts.
•	The Office of Enforcement and Compliance Assurance, in partnership
with states, is responsible for enforcing environmental laws, including the
Emergency Planning and Community Right-to-Know Act and TRI
reporting requirements.
•	The Office of Water provides guidance; specifies scientific methods and
data collection requirements; and performs oversight and facilitates
communication, including for POTWs that receive TRI chemical transfers.
Its Office of Wastewater Management oversees a range of programs
contributing to the well-being of the nation's waters and watersheds. The
collection and treatment of domestic sewage and wastewater is vital to
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public health and clean water and can include TRI chemical quantities
transferred to a POTW.
Scope and Methodology
We conducted our audit from October 2018 through August 2020 in accordance
with generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our
objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objective.
To address our audit objective, we obtained and analyzed TRI data and
corresponding annual TRI National Analysis reports for the 2013-2017 reporting
years to understand the total number of TRI reporting facilities that may have
filed their TRI reports too late to include in the TRI National Analysis for a given
reporting year.
We interviewed management and staff from the Office of Enforcement and
Compliance Assurance, the Office of Information Management within the Office
of Mission Support, the Office of Water, and the Office of Chemical Safety and
Pollution Prevention to determine the extent that late reporting impacts the
respective TRI National Analysis and to assess other issues we identified with
TRI data quality. Although the statutory deadline for facilities to report their data
is July 1, the EPA includes data submissions up until it freezes the dataset in
mid-October. For the purposes of this report, we considered data reported after the
Agency freezes the data in mid-October as late.
The scope for our audit did not include determining whether facilities met all
reporting requirements. It also did not include determining the effects of
unreported data on the TRI National Analysis.
Prior Reports
In OIG Report No. 19-N-0115. the OIG found that two total release calculation
queries provided in Envirofacts did not include the correct POTW release
amounts. Individuals querying the system, including residents in communities
near POTWs or researchers worldwide, did not always have accurate or consistent
information regarding releases of toxic chemicals from POTWs. This may have
impacted human health and the environment. The EPA stated that the error in the
total release calculations in the two Envirofacts queries has been corrected. As
part of the EPA's corrective action, the Agency said that it was going to check all
its other calculations in the TRI database for similar errors.
In OIG Report No. 20-P-0200, EPA Needs to Address Internal Control
Deficiencies in the Agencywide Quality System, issued on June 22, 2020, the OIG
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found that the Office of Mission Support had not fully implemented internal
controls for the mandatory agencywide Quality System or reviewed policies,
procedures, and guidance within required time frames. The EPA uses its Quality
System to manage the quality of its environmental data generation, collection, and
use. The Quality System also determines hazardous or toxic wastes in the
environment and establishes health-risk levels, supports enforcement monitoring
efforts, and maps human health risk data. The OIG reported that poor data quality
negatively impacts the EPA's effectiveness in monitoring programs that directly
impact public health and could also subject the EPA to significant financial and
legal risks. The report also stated that the EPA and the public rely upon the
quality of the Agency's data, which helps the Agency make reliable, cost-
effective, and defensible decisions. The Agency concurred with most of the
recommendations and provided corrective actions. As of August 2020, two
recommendations were not resolved.
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Chapter 2
EPA Could Improve Controls Over Certain TRI Data
Late-reported data accounted for a small portion of reported TRI release data, but
improved internal controls can improve data accuracy. The EPA requires facilities
to report TRI data by July 1 of the following year and freezes the data for
reporting in mid-October. The EPA has a robust but nonetheless undocumented
approach for encouraging and improving timeliness for data submissions. The
EPA allows reporting facilities to modify some factors for calculating chemical
releases due to transfers to a POTW but does not verify whether the modifications
to those factors are valid. By improving internal controls over reporting and
POTW calculations, the EPA can improve TRI data accuracy and provide
improved information to the public on toxic releases in its communities.
EPA's Robust but Undocumented Practice Encouraged Reporting and
Minimized Late-Reported Data
Data that were reported after the Agency froze the data in mid-October accounted
for an average of less than one-half of 1 percent of the releases reported in the
TRI analyses in the data we reviewed. One reason for the low percentage is that
between the reporting deadline on July 1 and when the EPA froze the data in mid-
October, the Agency followed up with prior year reporters who had not yet
reported in the current year to minimize the impact of late-reported data for the
TRI National Analysis.
However, the EPA's good practice of following up with facilities after the July 1
deadline to obtain data not yet reported is not documented as a standard operating
procedure. Therefore, the EPA runs the risk of not replicating this good practice
successfully every year. According to the TRI Program management, the Office
of Pollution Prevention and Toxics has not developed a standard operating
procedure for following up with facilities that have not filed their TRI reports by
the statutory July 1 deadline. The TRI Program stated that it has several practices
in place that are routinely used to obtain data. These include:
•	Sending "reminder" e-mails in late January and early February, as well as
approximately 60 days, 30 days, 15 days, and seven days prior to July 1.
After the July 1 deadline, emails are sent to facilities that have not certified
their reports of releases.
•	Contacting facilities that submitted TRI data in the previous reporting year
but not in the current reporting year either to prompt them to submit TRI
reporting forms or to verify that facilities have valid reasons for not
reporting.
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•	Conducting extensive quality analysis and refreshing the dataset to
incorporate any revisions or late submissions.
•	Creating a list of facilities that reported relatively large waste management
quantities for the prior year and referring them to the EPA regions to
follow-up for compliance assistance purposes.
We quantified the effects of the EPA's efforts to follow up with facilities that
reported in the prior year but not in the current year. During the time between the
July 1 deadline for reporting and when EPA froze the data in mid-October for the
reporting years we reviewed, approximately 800-2,000 facilities submitted about
2,500-9,000 TRI reports between the 2013-2017 reporting years.4 Some facilities
submitted more than one report. These reports comprise about 5 percent of the
total amount of chemicals reported released to the TRI for years we reviewed, as
well as approximately 7 percent of the facilities filing reports and approximately 8
percent of the number of reports filed. These reports further represent 70.3 million
total pounds of an approximate 15.2 billion pounds of chemicals reported released
during the 2013-2016 reporting years.5 See Table 1 and Appendix A.
Table 1: Summary of TRI data reported
Reporting
year
Total releases reported
by all facilities (pounds)
by October freeze date
July-October
reported releases
(pounds)
Percent releases
for July-October
reported data
2013
4,188,229,223
197,560,786.20
4.72
2014
3,999,521,569
222,995,422.28
5.58
2015
3,467,130,719
254,220,628.44
7.33
2016
3,513,181,638
51,591,030.24
1.47
2017
3,955,859,224
212,951,113.37
5.38
Average
4.90
Source: OIG analysis of EPA TRI data. (EPA OIG table)
Late reports represented 0.35 to 0.77 percent of the total TRI reportable chemicals
reported released (about 12-27 million pounds) during the period we reviewed. A
summary by reporting year showing an analysis of how many facilities reported
and the total amounts of chemicals released as reported to the EPA is in
Appendix A.
By freezing the dataset in October rather than in July, the EPA improved data
completeness for the period we reviewed by approximately 5 percent. Data not
included by the mid-October freeze date account for less than one-half of
1 percent of total pounds of chemicals that would be reported to the TRI (Figure 3
and Table 1).
4	Late-reported data for the 2017 reporting year were not available in Envirofacts when we reviewed the data in
April 2019.
5	See Footnote 4.
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Figure 3: Average TRI percent releases by time reported, 2013-2017

4.90
0.47%
Reported July- Reported after October
October (2013- cutoff (2013-2016)
Source: OIG analysis of EPA TRI data. (EPA OIG graphic)
EPA Did Not Determine Whether Late-Reported Data Impacted the
Annual Analysis
Although we found that the amount of data reported after the EPA annually froze
the data in mid-October accounted for an average of less than one-half of
1 percent of releases reported to the TRI National Analysis, the EPA did not track
the effect that late-reported data may have had on the TRI National Analysis.
When we asked the EPA about that, managers and staff stated that they had not
looked at the data from that perspective. The EPA freezes the TRI dataset in mid-
October and uses that data for the TRI National Analysis. Any data that arrived
after the mid-October freeze date, along with any revisions to previously
submitted data, would be included in the next update of the TRI dataset and in the
following year's TRI National Analysis.
While the EPA does compare prior year releases with the most current reported
releases, the Agency does not revise prior years' analyses to include data that
arrived after the mid-October freeze date. The EPA can improve the annual TRI
National Analysis by describing the impact of any data that arrived after the mid-
October freeze date from prior years that are missing from the current year's
annual TRI National Analysis. Disclosing the late-reporting rate would help
explain the impact on the dataset and the completeness of the data. Not doing so
limits the public's ability to effectively participate in managing human health and
environmental risks and places the burden on the public to search for late-reported
data to assess any relevant effects.
EPA Fixed Errors Identified in OIG Management Alert
We reported two discrepancies in the publicly available TRI data in OIG Report
No. 19-N-0115. Specifically, two Envirofacts queries did not correctly calculate
the amount of chemicals released from POTWs:
• The total pounds of chemicals released to the environment as reported in
the publicly available TRI data for reporting years 2013-2017.
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• The information that the EPA provided to us separately on the total
pounds of chemicals released.
since reporting year 2014 but it corrected the
errors in March 2019. The OIG verified the
correction on a sample of data obtained from
Envirofacts.
The EPA stated that the issue has existed
EPA public website
Inaccurate offsite
releases data for
TRI chemicals fixed
Insufficient Controls Over Modifications to
POTW Distribution Percentages in TRI Reports Can Change the
Validity of Reported Chemical Release Quantities
The EPA lacks adequate controls over data elements used to calculate releases
into the environment for chemicals transferred to a POTW. According to the EPA,
facilities are expected to use the best available information when reporting, are
required to keep documentation on certain information used for compliance
determinations and submissions,6 and are expected to present such documentation
in the event that the EPA conducts an inspection or requests such information.
Reporting facilities can accept the EPA's default POTW distribution percentages,
or they can modify those percentages if they have better information. Neither the
POTW nor the EPA can easily verify the validity of the data concerning
distribution percentages since a reporting facility is not required to provide
evidence supporting its modifications of the data.
Facilities can raise or lower the calculated quantities of chemicals reported as
released from a POTW into the environment. It could appear in the TRI as if
fewer chemical quantities were released than were actually reported released,
thereby misleading the public. For the approximately 35 percent of the reports of
chemicals transferred to POTWs, facilities' edits to the EPA's distribution
percentage values resulted in fewer net pounds of toxic chemicals reported
released into the environment from 2014 through 2017. These edits reduced
reported releases by 3,354,235 pounds or approximately 19 percent. The EPA,
however, does not verify that the edits to the distribution percentage data are
correct.
6 40 C.F.R. § 372.10.
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For the 2014-2017 reporting years, we calculate that approximately 35 percent of
reported chemical transfers greater than zero to POTWs differed from the default
percentages.7 Since reporting facilities are not required to provide evidence to
support edits to the POTW distribution percentages, the EPA cannot verify the
validity of the data.8
According to the EPA, reporting facilities may also choose not to disclose to the
public the POTW distribution percentages they use. When reporting facilities edit
the POTW distribution percentages without providing documentation supporting
changes, and the EPA does not provide appropriate oversight or inspect the
records supporting the change:
•	The EPA and the public have no way to determine whether the amount
reported released is correct or to determine the eventual destination of the
chemicals after they are transferred or released.
•	Facilities could misrepresent the final disposition of chemicals reported as
transferred to POTWs in the TRI data.
•	The EPA and the public may be deprived of useful information to improve
the default values used in the TRI dataset or identify new technologies that
could benefit others, if the change in the distribution percentage is valid.
For example, distribution percentages provided by one facility conflicted with
distribution percentages provided by other facilities transferring the same
chemical to the same POTW (Figure 4). For example, two reporting facilities
transferred lead to the same POTW. One reporting facility indicated that the
POTW only released 37 percent of the lead into the environment, while the other
facility indicated that the same POTW released 100 percent. In other words, one
facility reported that the same POTW released fewer pounds of lead into the
environment. In the 2017 data, there were over 800 instances where facilities
transferred the same chemical to the same POTW but used different POTW
distribution percentages.
7	The average is calculated from the percentage of nondefault value POTW transfers, where the POTW transferred
pounds reported was greater than zero pounds for each year from 2014 through 2017. The averages per year are as
follows: 46.3 percent in 2014, 34.6 percent in 2015, 31.1 percent in 2016, and 28.7 percent in 2017. The average from
2014 through 2017 is approximately 35.2 percent. The data for 2013 were excluded due to too many blank values.
8	Facilities filed 2,927 reports that used nondefault values within the 10,461 transfers to POTWs that were reported as
greater than zero pounds in the 2017 dataset.
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Figure 4: Transferring the same chemical to the same POTW
Facility A
Two facilities transferring the same chemical to the same
POTW will undergo the same treatment process.
Transfer
Chemical X

Same POTW
Facility B
Transfer
Chemical X
Source: EPA OIG-generated picture. (EPA OIG image)
r	H
Wastewater
Processing
k of Chemical i
According to the Agency, a facility may have more accurate information
regarding the final disposition of the TRI chemical transferred to a POTW. But if
two facilities report transferring the same chemical to the same POTW, each
facility should report the same distribution percentages on that chemical since the
POTW conducts the same treatment process no matter the source. The current
reporting process does not provide a way to distinguish between which facility
had access to more accurate data, used a different set of assumptions, or might
have misrepresented the data.
Without specific internal controls on data quality to enforce consistency among
facilities reporting the same chemical to the same POTW, reporting facilities
could alter the distribution percentages to allow them to report fewer pounds of
chemicals released to the environment.
We met with the Agency regarding the insufficient controls over edits and how
the Agency can improve the validity of reported chemical release quantities to
TRI reports. Managers and staff in the Office of Chemical Safety and Pollution
Prevention told us that they are taking action to improve the reporting process and
that the following updates to the reporting forms and instructions are underway:
•	Updated user interface to align better with real-life reporting practices.
•	New waste management codes to help categorize the type of POTW
disposal and treatment processes.
•	New validation alerts to warn reporters that an entry may be problematic.
Although these efforts represent progress toward improving the reporting process
for TRI data, they do not address the data quality problem we identified. Our
analysis of the updated form controls as described by the EPA showed that the
revised reporting system does not require facilities that report transferring the
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same chemical to the same POTW to use consistent distribution percentages in
their reports.
Conclusions
The EPA's practice of following up with late-reporting facilities is effective and
increases the completeness of the TRI dataset. The data reported after the mid-
October freeze date represent an average of less than one-half of 1 percent of the
total pounds of chemicals reported in the TRI National Analysis. This practice,
however, is not documented as a standard operating procedure. The EPA should
set and document standard controls over these efforts to ensure that data are
reported on time so that the releases are included in the annual TRI analysis.
The EPA also lacks controls over the validity of POTW distribution percentage
edits in the information processing system. While new technologies may justify
editing the POTW distribution percentages, this practice does not provide
adequate controls to ensure the validity and accuracy of TRI data, especially since
facilities could be motivated to alter the distribution percentages to allow them to
report fewer chemicals released to the environment. This can lead to
misrepresentation in the TRI data for chemicals that were reported transferred to
POTWs. The EPA should improve these controls to bolster the credibility of TRI
reported data. The public relies on the TRI dataset to obtain important information
concerning the presence of toxic chemicals in its communities.
Recommendations
We recommend that the assistant administrator for Chemical Safety and Pollution
Prevention:
1.	Develop and implement standard operating procedures to:
a.	Follow up on high-value late reporters so that their data is included
in the annual Toxics Release Inventory National Analysis.
b.	Minimize the effect any late reporting may have on the Toxics
Release Inventory National Analysis.
2.	Conduct and publish results of an annual analysis on late-reported Toxics
Release Inventory data to determine the overall impact on the accuracy of
the annual Toxics Release Inventory National Analysis reports.
We recommend that the assistant administrator for Chemical Safety and Pollution
Prevention, in coordination with the assistant administrator for Water:
3.	Revise the Toxics Release Inventory reporting instructions by removing
the option for reporting facilities to not disclose the publicly owned
treatment works distribution percentages used in their reports.
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4. Develop and implement procedures to:
a.	Annually review Toxics Release Inventory reports where publicly
owned treatment works distribution percentages differ from the
default values, especially when publicly owned treatment works
distribution percentages do not align with other facilities reporting
transfers of the same chemical to the same publicly owned
treatment works, and require corrections as appropriate.
b.	Annually review whether default values for the publicly owned
treatment works distribution percentages need to be updated.
Agency Response and OIG Assessment
On September 24, 2020, the assistant administrator for Chemical Safety and
Pollution Prevention provided a formal response to our draft report (Appendix B).
The Agency also provided informal technical comments, and we made changes
where appropriate. The Agency provided acceptable corrective actions and
estimated milestone dates in response to our recommendations. All
recommendations are resolved.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
13 Develop and implement standard operating procedures to:
a.	Follow up on high-value late reporters so that their data is
included in the annual Toxics Release Inventory National
Analysis.
b.	Minimize the effect any late reporting may have on the
Toxics Release Inventory National Analysis.
13 Conduct and publish results of an annual analysis on late-
reported Toxics Release Inventory data to determine the overall
impact on the accuracy of the annual Toxics Release Inventory
National Analysis reports.
13	In coordination with the assistant administrator for Water, revise
the Toxics Release Inventory reporting instructions by removing
the option for reporting facilities to not disclose the publicly
owned treatment works distribution percentages used in their
reports.
14	In coordination with the assistant administrator for Water,
develop and implement procedures to:
a.	Annually review Toxics Release Inventory reports where
publicly owned treatment works distribution percentages
differ from the default values, especially when publicly
owned treatment works distribution percentages do not
align with other facilities reporting transfers of the same
chemical to the same publicly owned treatment works, and
require corrections as appropriate.
b.	Annually review whether default values for thepublicly
owned treatment works distribution percentages need to
be updated.
Potential
Monetary
Benefits
(in $000s)
Assistant Administrator for 12/20/20
Chemical Safety and
Pollution Prevention
Assistant Administrator for 2/28/21
Chemical Safety and
Pollution Prevention
Assistant Administrator for 4/30/21
Chemical Safety and
Pollution Prevention
Assistant Administrator for 7/31/21
Chemical Safety and
Pollution Prevention
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
TRI Reporting Analysis of Late-Reported Data
Reporting
year
Total
Facilities filing at
least one
late report after the
October freeze date
Number of chemicals
reported late to TRI


Total number of pounds of chemical releases
reported
Facilities
reporting
Reports
filed
Number
Percent
Number
Percent
July-October
reported releases
(lbs)
Percent releases
for July-October
reported data
Total
Late (received
after October
freeze date)
Percent late
2013
22,264
83,151
1,192
5.35
2,241
2.70
197,560,786.20
4.72
4,188,229,223
15,708,358
0.38
2014
22,305
83,130
988
4.43
1,803
2.17
222,995,422.28
5.58
3,999,521,569
15,509,968
0.39
2015
22,220
82,038
674
3.03
1,230
1.50
254,220,628.44
7.33
3,467,130,719
26,805,717
0.77
2016
21,881
80,236
443
2.02
817
1.02
51,591,030.24
1.47
3,513,181,638
12,274,979
0.35
2017
21,456
79,435
*
*
*
*
212,951,113.37
5.38
3,955,859,224
*
*






Total

4.90
19,123,922,373
70,299,022
0.47
Source: EPA OIG analysis of EPA data. (EPA OIG table)
Note: Data as of April 2, 2019 (within the scope of the report).
* Late-reported data for 2017 were not available when we accessed the data.
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Appendix B
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC. 20460
September 24. 2020
OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION
MEMORANDUM
SUBJECT: Response to Draft Report entitled "Data Used for Annual Toxics Release
Inventory National Analysis is 99 Percent Complete, but EPA Could Improve
Certain TRI Data Controls."
FROM: Alexandra Dapolito Dunn
Assistant Administrator
ALEXANDRA
DAPOLITO DUNN
Digitally signed by
ALEXANDRA DAPOLITO DUNN
Date: 2020.09.24 16:57:15
-04'00'
TO:
Sean W. O'Domiell
Inspector General
This memorandum responds to the OIG's Draft Report entitled "Data Used for Annual Toxics
Release Inventory National Analysis is 99 Percent Complete, but EPA Could Improve Certain
TRI Data Controls," Project No. OA&E-FY18-0002, dated August 27, 2020.
The Office of Chemical Safety and Pollution Prevention (OCSPP) appreciates the OIG's effort in
evaluating the following:
•	The extent to which late reporting of Toxics Release Inventory data impacts the annual
TRI National Analysis;
•	Calculation of TRI chemical release quantities from publicly owned treatment works
(POTW) facilities following transfers of TRI chemical wastes from TRI reporting
facilities to POTWs.
II. OCSPP's Response to the Recommendations:
Recommendation 1: Develop and implement standard operating procedures to:
a) Follow-up on high-value late reporters so that their data is included in the annual Toxics
Release Inventory National Analysis, and
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I. General Comments

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b) Minimize the effect any late reporting may have on the Toxics Release Inventory
National Analysis.
•	Response and Background: It is OCSPP/OPPT's annual practice to email reminders to
TRI facilities in advance of the July 1 TRI reporting deadline. In addition, it is also
OCSPP/OPPT's annual practice to expressly notify via email TRI facilities which had
submitted TRI forms for the prior year that disclosed large release quantities but failed to
submit TRI forms by the July 1 deadline for the current year. These practices are
documented via an internal EPA milestones document, and each year the TRI program
reviews these milestones to ensure that they are met.
•	Proposed Corrective Action 1: To satisfy Recommendation 1, for OCSPP to "develop
and implement standard operating procedures," the TRI Program will formalize these
reminder and notification practices by establishing an internal Standard Operating
Procedure that describes these processes to minimize the effect any late reporting may
have on the TRI National Analysis.
•	Target Completion Date: December 2020.
Recommendation 2: Conduct and publish results of an annual analysis on late-reported Toxics
Release Inventory data to determine the overall impact on the accuracy of the annual Toxics
Release Inventory National Analysis reports.
•	Response and Background: To address the OIG's recommendation, and make
transparent how late TRI reports affected the quantities reported in the prior year's TRI
National Analysis, OCSPP/OPPT will include in the TRI Data Considerations section of
the TRI National Analysis a discussion on reports received too late for incorporation in
the previous year's National Analysis.
•	Proposed Corrective Action 2: In the publication of the TRI National Analysis for
RY2019, OCSPP will include language that summarizes how late reports and revised
reports have changed the dataset that was used to develop the previous year's National
Analysis.
•	Target Completion Date: February 2021.
Recommendation 3: Revise its Toxics Release Inventory reporting instructions by removing the
option for reporting facilities to not disclose the publicly owned treatment works distribution
percentages used in their reports.
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•	Response and Background: Starting with Reporting Year 2018, it is straightforward to
calculate these percentages.
•	Proposed Correction Action 3: To further clarify this information for TRI data users,
OCSPP will provide these percentages in the TRI data presentation tools.
•	Target Completion Date: April 2021.
Recommendation 4: Develop and implement procedures to:
a)	Annually review TRI reports where publicly owned treatment works distribution
percentages differ from the default values, especially when publicly owned treatment
works distribution percentages do not align with other facilities reporting transfers of the
same chemical to the same POTW and require corrections as appropriate.
b)	Annually review whether default values for the POTW distribution percentages need to
be updated.
•	Recommendation 4a Response and Background: Each year, OCSPP reviews submitted
TRI data to look for outliers and to validate the reported data across a wide range of
metrics. For past years, OCSPP has conducted data quality processes in regard to
reported transfers to POTWs. Such processes led to the creation of default distribution
percentages that vary on a chemical-by-chemical basis.
Note that facilities contacted by the TRI Program regarding their reporting, whether it
pertains to transfers to POTWs or any other TRI data element, need to determine whether
they complied with the reporting requirements or should submit a revision. Ultimately,
such corrections, if needed, are performed by the facilities who must certify to the
completeness and accuracy of their reporting forms and are subject to potential
enforcement should they have failed to adhere to the reporting requirements.
•	Proposed Corrective Action 4a: Going forward, OCSPP will review submitted data to
look for situations where a facility reported a transfer to a POTW such that the transfer
reported provides a markedly different outcome than the default distribution percentages
would have produced as well as review situations where such reporting differs from
transfers reported by similarly situated facilities.
•	Target Completion Date: July 2021.
•	Recommendation 4b Response and Background: OCSPP agrees to annually review
these percentages and will incorporate more accurate default POTW distribution
percentages and assumptions when it learns of more accurate data and information.
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•	Proposed Corrective Action 4b: OCSPP's TRI Program will provide updated default
POTW percentages for certain chemicals (e.g., nonylphenol ethoxylates) and develop a
standard operating procedure to describe how these default distribution percentages are
determined.
•	Target Completion Date: July 2021 (for Reporting Year 2021).
cc: All OCSPP DAAs
OW AA and DAAs
OECA AA and DAAs
OPPT OD, DODs
TRI Program Managers
Kathlene Butler, OIG
Christina Lovingood, OIG
Dwayne Crawford, OIG
Janet L. Weiner, OCSPP Audit Liaison
John Latham, OPPT
Gwendolyn Spriggs, OECA Audit Liaison
Tiffany Crawford, OW Audit Liaison
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Appendix C
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Chief Financial Officer
Assistant Administrator for Chemical Safety and Pollution Prevention
Assistant Administrator for Water
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Deputy Chief Financial Officer
Principal Deputy Assistant Administrator for Chemical Safety and Pollution Prevention
Principal Deputy Assistant Administrator for Water
Deputy Assistant Administrator for Chemical Safety and Pollution Prevention
Deputy Assistant Administrators for Water
Director, Office of Pollution Prevention and Toxics, Office of Chemical Safety and Pollution
Prevention
Director, Office of Continuous Improvement, Office of the Administrator
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention
Audit Follow-Up Coordinator, Office of Water
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