Frequently Asked Questions &
Their Answers
Who must file
TRI reports?
Under TRI, an individual facility
reports to EPA if it meets the following criteria:
- It employs the equivalent of at least 10
full-time workers.
- It "manufactures" or
"processes" at least 25,000 pounds of a listed chemical or
it "otherwise uses" at least 10,000 pounds of a listed
chemical.
According to EPA, approximately
30,000 facilities must file reports. Of that total, more than 6,000 new
facilities, including utilities that burn coal or oil to generate
electricity, are required to file TRI reports for the first time in 1999.
What are
facilities required to report under TRI?
For each listed chemical
"manufactured," "processed," or "otherwise
used" in an amount exceeding the threshold level, a facility must
report the following:
- Amount released to the air, water, and land.
- Amount shipped from the facility to other
locations for recycling, energy recovery, treatment, or disposal.
- Amount recycled, burned for energy recovery, or
treated at the facility.
- Maximum amount present on-site at the facility
during the year.
- Types of activities conducted at the facility
involving the chemical.
- Source reduction activities.
- Environmental permits held.
- Name and telephone number of a contact person.
TRI covers nearly 667 individual
chemicals and chemical categories. Utilities probably will meet or exceed
the threshold levels of "manufacturing,"
"processing," or "otherwise using" for 10 to 20 of
those chemicals. In the case of certain chemicals, such as
hydrochloric and sulfuric acids and hydrogen fluoride the
volumes reported will be very high. In some instances, a utility will rank
first or second in its state in terms of total TRI emissions.
What are the
limitations of the TRI data?
According to EPA, the TRI program has
given the public "unprecedented direct access to toxic chemical
release and transfer data at the local, state, regional, and national
level." But one of the criticisms of the program is that TRI data
cannot be used to determine actual toxicity, exposure, or risk associated
with the releases that are reported.
EPA, state agencies, and the media
compile TRI data into "Top 10" lists of companies, facilities,
industries, and states with the largest release volumes. In many cases,
utilities may rank in the "Top 10." However, these lists are
often misleading.
For example, if one company acquires
another, it must aggregate data on the releases of both companies in its
next TRI report. As a result, it may then appear that the acquiring
company experienced a significant increase in its TRI releases for that
year when, in fact, the totals for both companies may have stayed the same
or even decreased.
"Top 10" lists are also
misleading because they report only total volumes of releases and ignore
toxicity and other measures of risk. Thus, EPA might place a facility that
released a larger volume of a low-toxicity chemical higher on its list
(giving the public the impression that the facility poses a more serious
risk) than another facility that released a smaller volume of a much more
toxic chemical.
Where will
utilities' TRI reports originate?
The TRI program collects release
information at the facility level. Each facility with the equivalent of 10
or more full-time employees and meeting the TRI threshold criteria for
"manufacturing," "processing," or "otherwise
using" will be required to compile a TRI report for each chemical
that exceeds the threshold.
Where will
utilities' TRI reports go?
Utilities reporting under TRI will
submit their reports to the U.S. Environmental Protection Agency and the
state where each reporting facility is located. Many cities also require
companies participating in the TRI program to submit reports to them.
When must
utilities report under TRI?
Companies are required to report TRI
data to EPA once each year. Beginning in July 1999, electric utilities
will for the first time submit their data. EPA
will analyze the data and compile its 1998 Public Data Release for
distribution in the spring of 2000. The numbers are reported on a
plant-by-plant basis, as well as listings for each company and overall
industry.
Like other TRI reporters, utilities
will compile and submit reports to EPA each year according to the same
schedule.
Why do
companies report TRI data?
TRI reports are mandated by the
Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA).
Congress passed the law in the wake of the chemical disaster in Bhopal,
India, and intended it as a tool to help communities avoid similar
accidents.
According to EPA, TRI reports give
the public information about toxic chemicals present in their communities.
EPA says citizens can use this information "to identify potential
environmental concerns, gain better understanding of potential risks, and
work with industry and government in addressing concerns and risks.".
Why do
utilities report TRI data?
Originally, only manufacturing
industries (those with Standard Industrial Classification Codes of 20 to
39) reported under TRI. In 1997, EPA expanded the list of industries
required to report to include electric utilities, coal and metal mining,
commercial hazardous waste treatment, petroleum bulk terminals, chemical
wholesalers, and solvent recovery services. This action expanded by more
than 6,000 the total number of facilities required to report under TRI.
How will
utilities report TRI data?
Each facility reporting under TRI
uses a document known as Form R, provided by EPA. A separate Form R must
be filed on each TRI chemical the facility has "manufactured,"
"processed," or "otherwise used" in amounts exceeding
threshold levels during the reporting year.
How will TRI
data be used?
EPA analyzes TRI data from all
reporting facilities - about 30,000 individual plants and
facilities - and prepares an annual Public Data Release.
This report, which is published and
made available via the Internet, summarizes all of the data submitted by
chemical, state, federal facilities, and industry. It also summarizes
releases by type and environmental medium, and provides lists and tables
of such things as total releases, total transfers, "Top 10"
chemical releases, and "Top 10" OSHA carcinogen releases. And,
it makes comparisons with previous years' reports.
The information submitted to EPA is
available to the public via the Internet at these sites:
- The Right-To-Know Net (http://www.rtk.net)
provides public access to TRI and related environmental databases to
community groups concerned about toxics. For more information, call
(202) 797-7200 or (202) 234-8494.
- The National Library of Medicine (http://www.toxnet.nlm.nih.gov)
makes it possible to search the entire TRI database. This site has an
hourly use charge and requires a password. For more information, call
(301) 496-6531.
- EPA (http://www.epa.gov/tri)
makes various reports, data files, and TRI information available. For
more information, call (202) 260-1531.
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