Toxics Release Inventory (TRI)/Emergency Planning And Community Right-To-Know Act (EPCRA)

TRI was established under the Emergency Planning and Community Right to Know (EPCRA) Act of 1986. EPCRA came into law in part as a result of a 1984 chemical accident in Bhopal India, when an accidental release of fumes from a pesticide manufacturing plant resulted in a large number of deaths and injuries from a nearby community. The intent of TRI is to better inform the general public of potential hazards in their community and to assist emergency response organizations in their preparations for potential emergencies.

In the U.S. manufacturing industries began to report TRI releases in 1987. Initially 300 chemicals were listed in the inventory. This has since expanded to 667 chemicals and chemical categories. One of the goals of the Clinton Administration was to continue expanding the TRI program. Most recently, certain persistent bioaccumulative toxics (PBTs) were added to the reporting program. At the same time, the reporting threshold for mercury was lowered to 10 pounds and the reporting threshold for dioxin and dioxin-like compounds was set at 0.1 grams. The new reporting levels were used for TRI reports beginning in July 2001.

In May of 1997 the EPA added electric utilities (along with five other categories: coal and metal mining, commercial hazardous waste treatment, petroleum bulk terminals, chemical wholesalers, and solvent recovery services), to the list of affected industries having to report under TRI. This action expands the list by more than 7,000 facilities required to report under TRI, an increase of 30%, from 21,000 to 28,000 reporting facilities. TRI “data” is published annually in a publicly accessible database (http:/www.epa.gov/tri/tridata).

EPA requires only coal and oil-fired utilities to report under TRI. Natural gas fired generation is exempt. Actually reporting is triggered when thresholds are exceeded for manufacturing, processing or using a TRI chemical. EPA changed the definition/interpretation of “manufactured” which now incorporates coincidental manufacturing. Once a threshold is exceeded all releases of that chemical at that facility are to be reported. Thus, if you release a chemical through the combustion process and you otherwise use that same chemical at the facility, you are required to report those incidental releases as well.

On July 1, 1999, electric generating stations burning coal or oil submitted to the EPA for the first time chemical release data under the Toxics Release Inventory (TRI). The data was compiled, aggregated, and reported to the public by EPA (www.epa.gov/tri/tridata/tri99/index.htm).

HOOSIER ENERGY BACKGROUND

Utility coal and oil fired boilers are expected to release millions of pounds of TRI chemicals. This is because, during the combustion process, acid aerosols are created (i.e. coincidentally manufactured). Acids not removed by pollution control devises are released from the stack. Non combustible material such as metals are transformed to metallic oxides contained in the ash (bottom ash and fly ash) and disposed of on site in landfills or ash ponds. Trace elements in coal represent a minute percentage of coal composition; however, we burn over six billion pounds of coal at Merom. The reportable TRI releases from ash represent less than 0.2% of the total ash generated.

As a result of EPA expanding manufacturing categories subject to submit reports under TRI, large coal-fired utility plants in Indiana are among the top TRI reporting entities in the state. This is due to the large amount of coal burned 24 hours a day year round.

Merom released approximately 3 million pounds of TRI chemicals in 2006. About 1.6 million pounds were released up the stack to the atmosphere in the form of acid aerosols. Barium was the highest quantity metal to be reported. Other metals above the threshold include arsenic, beryllium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium, vanadium and zinc. Most of the metals were released to the land via the onsite landfill.

Ratts released approximately 2.0 million pounds of TRI chemicals in 2006. About 1.4 million of those released pounds went up the stack to the atmosphere in the form of acid aerosols. Zinc was the highest quantity metal to be reported. Other metals above the threshold include barium, chromium, copper, lead, manganese, mercury, nickel, and vanadium. Most of the metals were released to the land via the onsite ash ponds.  The reason Ratts emits as many acid aerosols as Merom is because Merom’s Flue Gas Desulfurization system removes acids from the stack gases.

Collectively in 2006, Hoosier burned approximately 3.77 million tons of coal which resulted in the release of 4.63 million pounds of TRI reportable chemicals, a 1.12 pound of TRI emissions per ton of coal burned ratio.

IMPORTANT RISK INFORMATION

Electric Edison Institute

The Electric Edison Institute Board of Directors approved a policy on community right-to-know in 1994. EEI believes the public has a right to accurate, meaningful information about the chemicals that pose risks to the local community. EEI also maintains that reporting of hazardous substances should be based on risk to human health. Information about those substances should be presented in a clearly understandable manner, and include the risks associated with the releases being reported.

In 1997, the Edison Electric Institute inaugurated a program to assist both members and non-members with a wide range of technical and communications information. This is important because the fact that these "emissions" are being reported, in no way equates to any risk factors associated with them. The EEI program is designed to keep utilities in touch with all aspects of TRI reporting, and to educate about technical, communications and community outreach issues. The materials listed below will assist individuals in understanding this complex issue, as well as to give detailed information on the extremely low risk involved in power plant emissions reported under the Toxic Release Inventory.

These materials are available by downloading the Acrobat files from this page or may be obtained from EEI's communications department by contacting Dan Riedinger at driedinger@eei.org:

• Policy Position on Community Right-To-Know - This one page sheet recaps the EEI Board-approved (March 1993) policy position on community right-to-know issues

• EEI's Environmental Overview Brochure - This four-color brochure highlights our industry's efforts and accomplishments in protecting our nation's air, water, and land resources. The brochure conveys a positive message that the electric utility industry values a healthy environment.

• Environmental Excellence Principles - This one page sheet lists the EEI Board- approved (September 1994) Environmental Excellence Principles
   

Solutions

The materials listed below will assist individuals in understanding this complex issue, as well as to give detailed information on the extremely low risk involved in power plant emissions reported under the Toxic Release Inventory.

• Electric Power Generation and TRI Flowchart - This diagram, prepared by Dr. J. Winston Porter, president of Waste Policy Center, illustrates the operation of a "typical" large coal-fired electric power plant. It notes those chemicals that may be reported for such a facility under the TRI program.

• "Guidance on Toxic Release Inventory: Reporting Under Section 313 of the Emergency Planning and Community Right-to-Know Act", 1998. - This volume is available only to electric utilities that must file TRI reports. It is available from EEI for $65 (EEI members); $160 (not an EEI member). The guidance provides information on assessing and calculating releases, on filling out the Form R, and on numerous utility-specific reporting issues.

• Utilities & TRI: A Primer - Written by Dr. J. Winston Porter, President of the Waste Policy Center in Leesburg, VA, this primer uses a typical coal-fired power plant to illustrate how such plant operations result in releases of reportable substances under the TRI program. The author also places utility releases in perspective by offering tips to the public on how to interpret right-to-know reports.

• Excerpts from EPA's Report to Congress - This paper summarizes the methodology and findings of EPA's report to Congress on air emissions from electric utilities. The results of the agency's investigation indicate that utility air emissions pose extremely low risks to human health.

• Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units - The Executive Summary of EPA's February 1998 report to Congress explains the agency's study and its regulatory determinations on HAP emissions from coal-, oil-, and natural gas-fired utilities.

• TRI Questions and Answers - This fundamental fact sheet poses and answers the "who, what, where, when, why, and how" of TRI reporting and what TRI means for utilities.

• Chemical Profiles: Frequently Asked Questions - These eleven fact sheets address basic questions about arsenic, barium, chromium, dioxin, hydrogen chloride, hydrogen fluoride, lead, manganese, mercury, sulfuric acid, and nickel. These chemicals are all released, in varying degrees, by electric utilities into the environment.