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What is the Toxics Release Inventory (TRI)?
What is the Toxics Release Inventory?
The Toxics Release Inventory (TRI)
is a publicly available database of information on the release
and transfer of nearly 650 chemicals by private companies and
government facilities. Congress created TRI under the Emergency
Planning and Community Right-To-Know Act of 1986 (EPCRA). The
U.S. Environmental Protection Agency (EPA) administers the TRI
program, receiving the data collected by reporting entities and
making it available to the public. EPA previously required reporting
for manufacturing entities in Standard Industrial Classification
20-39 to file annual TRI reports. However, in May 1997, EPA expanded
TRI reporting requirements to include seven new industry groups;
key among them are mining and electric utilities.
The TRI program is popular among
regulators, legislators, environmental groups, the media, and
the general public. This paper answers basic questions about TRI
and what it means for the mining industry.
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Who must file TRI reports?
Under TRI, an individual facility
reports to EPA and their respective State if it meets the following
criteria:
- It has a facility within certain
designated Standard Industrial Classification (SIC) codes
- It employs the equivalent of
at least 10 full-time workers.
- It "manufactures"
or "processes" 25,000 pounds of a listed chemical or…
- It "otherwise uses"
exceeding the threshold level of 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 will file TRI reports for the first time
in 1999.
For mining, the rule covers metal
mining and beneficiation (iron ore is exempt) and non-extractive
activities at coal facilities (coal extraction is exempt). Beneficiation
is the removal of undesired minerals associated with ore.
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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 on-site 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
contact persons both technical and community.
TRI covers nearly 650 individual
chemicals and chemical substances. Many mining facilities probably
will meet or exceed the threshold levels for "manufacturing,"
"processing," or "otherwise using" approximately
20 of those chemicals as a result of the materials we manage.
In the case of certain naturally
occurring chemical substances that are present in rock and processed
rock managed on site at the mine, the quantities reported will
be significantly higher as compared to other reporting industrial
categories.
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What does TRI do?
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 concerns with the program is that
TRI data cannot be used to determine actual toxicity, exposure,
or risk to the public associated with the releases that are reported.
TRI gives the public direct access
to information about the use and ultimate fate (storage, disposal
or release) of the listed chemical substances at facilities covered
by the program.
TRI only provides information
about the amount of substances reported by covered operations.
It is very important to note
that the program does not provide information on the potential
risk associated with the "release" of substances reported
under the program.
In fact, many of the substances
listed in TRI are not inherently unsafe. Some occur naturally
in soils and plants, and these substances only cause concern
when concentrations are high enough and exposure is sufficient.
TRI does not provide any information on these important factors
and should not be relied upon to assess or to speculate upon
potential impact to health or the environment.
It is important to keep in mind
that the reports from metals mining operations will be unlike
those files by other industries. That’s because the reports
from mining facilities will include the amount of naturally occurring
listed substances that remain in unneeded rock and processed
rock that is contained in managed facilities at the mine site.
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Where will 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 compile a TRI report for
each chemical that exceeds the threshold.
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Where will TRI reports go?
Facilities reporting under TRI
will submit their reports to the EPA and the state where each
reporting facility is located. Many cities also require companies
participating in the TRI program to submit reports to them.
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When must mine operators report under TRI?
Companies report TRI data to
EPA once a year. Beginning July 1, 1999, coal and metal mining
facilities will submit data for their mines. EPA will analyze
the data and compile its 1998 Public Data Release for
distribution by the end of 1999 or in the first quarter of 2000.
The numbers are reported on a site-by-site basis, as well as
listings for each company and overall industry.
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Why do companies report TRI data?
TRI reports are addressed by
a federal law, the Emergency Planning and Community Right-To-Know
Act of 1986 (EPCRA).
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Why do mine operators 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 to include electric utilities, coal and metal mining,
commercial hazardous waste treatment, petroleum bulk terminals
and plants, chemical and allied products wholesale, and solvent
recovery services. This action expanded by more than 6,000 the
total number of facilities reporting under TRI.
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How will mine operators report TRI data?
Each facility reporting under
TRI uses a document known as Form R, provided by EPA. A separate
Form R is filed for each TRI chemical the facility has "manufactured,"
"processed," or "otherwise used" in amounts
exceeding threshold levels during the reporting year.
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How will TRI data be used?
TRI is intended to provide local
communities with information about operations in their area.
In addition, EPA analyzes TRI data from all reporting facilities
¾ about 30,000 individual plants and facilities ¾
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 5" or "Top 10" chemical
releases, and "Top 5" or "Top 10" OSHA carcinogen
releases. And, it makes comparisons with previous years’
reports.
In addition, mining companies
and state, regional and national mining associations and related
organizations will have TRI information on their web sites along
with links to other web sites containing useful information on
the mining industry, TRI and the Right-to-Know program.
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