Connecting Stovepipes: The Toxics Release Inventory (TRI) Experience

1. For Conference Purposes Only Connecting Stovepipes:The Toxics Release Inventory (TRI) Experience February 13, 2008 Larry Reisman

2. For Conference Purposes Only Connecting Stovepipes: The TRI Experience Panelists: Larry Reisman OEI, Office of Information Analysis and Access (OIAA) Pat Garvey OEI, Office of Information Collection (OIC) Mike Barrette OECA, Office of Compliance (OC) Steve Wurtz Region 7, Air and Waste Management Division (AWMD)

3. For Conference Purposes Only Connecting Stovepipes: The TRI Experience • What do we mean when we say “Connecting Stovepipes: The TRI Experience”? • Comparing Toxics Release Inventory (TRI) data to other EPA media-specific (i.e., air, land, and water) data to determine consistency and completeness of filings across programs. • The purposes of “connecting stovepipes” are to enhance data quality, strengthen data integration, and support compliance/enforcement efforts.

4. For Conference Purposes Only Connecting Stovepipes: The TRI Experience • What is TRI? • The Toxics Release Inventory (TRI) is a publicly available EPA database that contains information on toxic chemical releases and other waste management activities reported annually by certain covered industry groups as well as federal facilities. • This inventory was established under the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 and expanded by the Pollution Prevention Act (PPA) of 1990. • Because TRI is multi-media in scope it is well-suited as a data source for comparing and drawing connections between the Agency’s media-specific data.

5. For Conference Purposes Only Connecting Stovepipes: The TRI Experience

6. For Conference Purposes Only Connecting Stovepipes: The TRI Experience • An example of one comparison analysis aimed at identifying potential inconsistencies between Clean Air Act (CAA) permit requirements and TRI reported releases of hazardous air pollutants (HAPs): • A stationary source that emits or has the potential to emit 10 tons per year or more of a single HAP constitutes a major source under the CAA and this status should be reflected in AFS. • A TRI data run identified TRI reports with >10 tons of air releases of a single HAP and no matching AFS ID as reflected in the Facility Registry System (FRS). For TRI facilities with >10 tons of air releases of a single HAP one would expect an AFS ID indicating major source status.

7. For Conference Purposes Only Connecting Stovepipes: The TRI Experience • Example (cont.): • OIC’s evaluation of the initial list of 200+ TRI reports with >10 tons of air releases of a single HAP and no corresponding AFS ID resulted in facility linkage improvements in FRS and a refined list of 40 TRI facilities with >10 tons and no AFS ID. OECA evaluated this list of 40 TRI facilities. • Presently, the regions/states, in coordination with OECA’s Air Enforcement Division (AED), have assessed penalties on two CAA enforcement targets located in Region 10 and work is continuing on 16 remaining facilities identified by comparing TRI data to AFS data.

8. For Conference Purposes Only Connecting Stovepipes: The TRI Experience • Next Steps: • Continuing work on air permit (TRI / AFS), air release (TRI / NEI) and water permit (TRI / NPDES) comparisons and beginning work on land disposal comparisons (TRI / RCRAInfo). • Working with OECA to capture the investigative approach and integrate search algorithms into OECA’s Online Tracking Information System (OTIS), a web-based interface to the Integrated Data for Enforcement Analysis (IDEA) mainframe. • The following slide illustrates a potential tool for TRI comparative analyses with the Agency’s media-specific data.

9. For Conference Purposes Only Connecting Stovepipes: The TRI Experience