^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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