TRI DATA ARE FROM COMPANY SELF-REPORTS
Companies are responsible for the accuracy of the TRI data they submit to EPA. Unfortunately, little or no enforcement has taken place to date challenging inaccurate reporting by facilities.
CHEMICAL RELEASES ARE USUALLY ESTIMATED AND NOT MEASURED
TRI facilities usually estimate their releases and waste generation, rather than actually measure the amounts of toxic chemicals they emit or create. TRI does not require any specific monitoring of emissions. Estimating releases (using emissions factors developed for various production processes or using process modeling) is considerably cheaper than monitoring releases, but clearly introduces significant uncertainties into company-reported data.
HOW ACCURATE ARE TRI DATA?
A recent study by the Environmental Integrity Project (EIP), Who's Counting?, estimates that companies may be failing to report 15% of their total toxic air emissions to TRI. EIP used data compiled by the Texas Commission on Environmental Quality that quantifies the extent to which refineries and chemical plants in Texas underreport certain toxic emissions. The EIP report applies the Texas findings nationwide and reveals that emissions of specific toxic chemicals, including recognized carcinogens such as benzene and butadiene, may be four to five times higher than is reported to TRI.
The Environmental Integrity Project identified two primary explanations for this underreporting:
1) The root problem is the lack of adequate emissions monitoring. Instead of actually monitoring many air emissions, industry uses unreliable calculation methods for estimating emissions. A 2001 General Accounting Office study documented that only four percent of all emissions reporting used direct monitoring or testing. The other 96 percent were based on estimates calculated using emissions factors. Emissions factors were developed by EPA as a means of estimating the long-term average emissions for all facilities in a particular source category. These factors do not reflect the variations within a source category due to different processes, controls or operating systems at individual facilities. The factors, therefore, are often not accurate for calculating a particular facilitys emissions.
2) EPA has failed to improve monitoring and reporting of toxic air pollution. In fact, EPA has moved in the opposite direction and has weakened some federal monitoring requirements. Efforts to standardize the methods used to calculate emissions have been defunded and abandoned. In 2004, EPA actually adopted new rules that weaken air emission reporting requirements. Because EPA continues to knowingly allow industrial facilities to underreport toxic emissions, the public remains in the dark about the true extent of their exposure.
Note that it is not possible to predict the level of under-reporting at specific TRI facilities and incorporate these projections into Scorcard reports. The findings of the EIP study indicate the potential size and nature of a systematic problem with reporting, but cannot be directly translated into accurate emissions estimates for specific facilities. Some plants may use accurate emissions factors, or actual monitoring, and have fewer problems with underreporting.
WHAT CHANGES HAS ENVIRONMENTAL DEFENSE MADE TO 2002 TRI DATA?
Environmental Defense has identified a variety of errors in company TRI reports, particularly in regard to geographic location. Companies have submitted reports with latitude and longitude data that locate their facility in the ocean, with zip codes that are in the wrong state, etc. Environmental Defense has attempted to correct easily verifiable locational errors when possible.
Environmental Defense has modified the 2002 public data release by removing all records involving isopropyl alcohol (strong acid process) after determining that company reports involving this TRI chemical were in error. Companies using isopropyl alcohol were incorrectly reporting release and waste management data for this chemical, even though it is not covered by TRI reporting requirements. The strong acid manufacturing process for producing isopropyl alcohol is not in use anywhere in the United States.
In reporting releases or waste management practices involving dioxin compounds or dioxin congeners, Scorecard presents the gram values that facilities submitted to TRI to four significant figures.