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IV. Pollution Prevention

Source: EPA 1994 Toxics Release Inventory
Public Data Release, Appendix A:
Questions and Answers

Q19 November 1992 is the expiration date listed on Form R. Is the Form R valid for reporting year 1995?

A The Form R was revised in May 1992 to include the Pollution Prevention Act requirements. November 1992 was the expiration date given by the Office of Management and Budget (OMB) when it approved the Form on May 19, 1992. However, the Pollution Prevention Act Implementation Provisions of the 1993 Appropriations Act allows the Agency to continue to use this Form R until regulations are promulgated. Therefore, this Form R is still valid and should be used for all submissions until changes are made to the form.

Q20 Why don't the totals reported for "Source Reduction and Recycling Activities" in Section 8 of the Form R equal the quantities reported for "Transfers of the Toxic Chemical in Wastes to Off-Site Locations" in Section 6 of Form R? Do these represent different quantities? Why are the data reported in two places on the Form R?

A The quantities reported in Sections 6 and 8 may be different if the facility has reported accidental or one-time releases not related to production. Quantities reported in Section 8.1 through 8.7 do not include such quantities, while quantities reported in Section 6 do. If the facility has not reported any non-production related releases, the quantities reported in Section 8 and Section 6 should be the same. Differences in the data are also due to different interpretations made by reporting facilities when completing Sections 6 and 8. EPA is building on the experience gained from the 1991 through 1994 reports to develop final guidance for reporting facilities.

Q21 How does the quantity released, reported in Section 8 of the Form R, Source Reduction and Recycling Activities, differ from the quantities reported in the Section 5, Releases of the Toxic Chemical to the Environment On-Site?

A The quantity reported as released in Section 8.1 can differ from the total of the releases reported in Section 5 in two basic ways. First, the quantity reported in Section 8 includes quantities sent off-site for disposal. This quantity is not reported in Section 5 but is reported in Section 6. Second, the quantity reported in Sections 8.1-8.7 should not include any quantities released to the environment because of catastrophic, remedial, or one-time events that are non-routine (not associated with production operations). Such quantities would be included as part of the total releases reported in Section 5 and Section 8.8.

Q22 Why are the off-site energy recovery, recycling, and treatment data characterized differently from these same activities on-site?

A The difference in how the data are characterized is based on the level of knowledge the facility has. For example, a facility is able to estimate the amount of the toxic chemical recovered by on-site recycling processes because this activity is under its control. The facility is not likely to know the amount recovered through a similar activity occurring off-site because it is not under its control. What the facility should know, however, is the quantity of the chemical sent off-site for the purpose of recycling. This same difference in knowledge applies to on-site and off-site energy recovery and treatment. The facility can estimate amounts combusted for energy and destroyed through their treatment processes, but they may only know the amounts sent offsite for the purpose of energy recovery and treatment.

Q23 Why are the individual quantities reported in Section 8, Source Reduction and Recycling Activities, mutually exclusive?

A These quantities are designed to add up to the total amount of the TRI chemical in waste streams (exclusive of catastrophic, remedial, or one-time non-production related releases). To accomplish this, the individual quantities undergoing each type of waste management activity must be mutually exclusive because any double or multiple counting of an amount of the reported TRI chemical in waste streams will inflate the actual total. By avoiding multiple counting, a more accurate picture of how the toxic chemical in waste streams is managed within the waste management hierarchy can be obtained.

Q24 Why are catastrophic releases reported separately?

A The catastrophic releases are reported separately because they cannot be predicted and generally are not amenable to source reduction efforts.

Q25 Why are the recycling numbers so large?

A The recycling numbers are very large in comparison with the amounts reported as being released to the environment because the nature of recycling is to recover the chemical for further use. Unlike the quantities released, which leave the process, the amounts recycled return to the process again and again.

Q26 How will EPA and others use the "future years" reported estimates? What if actual estimates differ from the projected estimates?

A EPA will use the future estimates data as indicators of possible future trends in waste management. The future year estimates are projections and do not represent a commitment or a quantity that the facility must meet under penalty of enforcement. In addition, this data is useful to city planners in identifying future pollution loads and opportunities for new businesses.

Q27 What is the production index?

A The production index is a ratio of production during the reporting year and production during the prior year. It is intended to allow data users to assess the impact of business changes on changes in total waste generated.

Q28 How is a chemical that is treated on-site and then disposed of reported in Section 8 of the Form R?

A The amount of a chemical destroyed in on-site treatment is the quantity reported as treated on-site. Any amount not destroyed (the balance) is reported as the quantity "released" (including transferred off-site for disposal).

Q29 Does EPA plan to review the quality of the data reported in Section 8 of the Form R?

A EPA has instituted a computerized review of the data, primarily to check potential data discrepancies between Section 8 and Sections 5 and 6 of the form.

Q30 What is the difference between energy recovery and incineration?

A Both incineration and energy recovery involve combustion of a toxic chemical in a waste. However, they have different purposes. Energy recovery is combustion of toxic waste occurring in a boiler, kiln, or industrial furnace in which the heat from the combustion is used to generate steam or to heat other materials in a manufacturing process. Incineration is the combustion of toxic waste in order to destroy the toxic chemical by converting it into one or more other chemicals.

Q31 Over 1 million pounds of various metals and metal compounds have been reported as transferred to energy recovery. Can metal compounds be used for energy recovery?

A No. These reports were made in error. They may represent metal compounds in waste solvents that were sent to an energy recovery unit. EPA's instructions cite metals as an example of the type of chemicals that should not be reported as undergoing energy recovery because they do not contribute to the heating value of the waste stream.

Q32 A large quantity of toluene was reported as burned off-site for energy recovery in 1994. Does any of the toluene get released to the environment as a result of this?

A Energy recovery processes are not 100% efficient. Therefore, some small amount of the toluene is likely to be released, either as un-combusted material or as fugitive releases from the handling of the toluene-containing material prior to combustion.

Q33 How are the data elements in Section 8 of Form R different from those stated in the Pollution Prevention Act?

A Facilities do not report the "quantity entering any waste stream prior to recycling, treatment, or disposal" as stated in the PPA. This number is derived by EPA by adding up the individual quantities that were reported as released, used for energy recovery, treated, and recycled. This total number is available in the public database for each chemical reported by a facility. Energy recovery, which is not discussed in the PPA, has aspects of both recycling and waste treatment and is reported separately from the quantities reported as treated or recycled. Instead of reporting the percent changes of quantities reported in Sections 8.1-8.7 from the prior year and for the next two years, the Form R collects the actual prior year quantity and the estimated two future years' quantities in pounds per year. Quantities treated, recycled, or undergoing energy recovery are reported separately by whether they occur on-site or off-site.

Q34 What is the Office of Pollution Prevention and Toxics (OPPT) doing to reduce environmental releases reportable under EPCRA section 313?

A OPPT is using TRI data to help target activities, chemicals, facilities, and industry categories that are of high concern. The Pollution Prevention Policy Council's initiative, "Source Reduction Review Project," is one example where the TRI data were used as a screening tool to identify a group of industrial categories as long-term targets of opportunity. As a part of this project, OPPT is working with other program offices to incorporate prevention into their programs through regulation, where feasible, and through guidance and voluntary efforts. OPPT is also working with industry (usually through trade associations) to raise awareness of the benefits of pollution prevention. OPPT also conducts training programs that help orient government and industry toward pollution prevention and to incorporate prevention into their regular activities. A state grants program is available to help states develop pollution prevention programs. OPPT and the Office of Research and Development have developed a clearinghouse, the Pollution Prevention Information Clearinghouse (PPIC), that provides information on pollution prevention for industry, government, and public interest groups to use in encouraging and implementing prevention.

Q35 The quantity of certain chemicals released (at a particular facility or nationwide) is decreasing. What does this mean?

A Currently, Form R does not allow for facility- and-chemical specific quantification of source reduction. Also, the TRI database does not include specific explanations of the reasons for changes in quantities reported by facilities. The new TRI data required under the PPA can give some indication of whether changes are due to shifting of chemicals off-site for energy recovery, treatment, or recycling; decrease in economic activity or production levels; or source reduction. Many other factors, however, may also cause changes in reported release quantities, for example, substitution of one chemical for another, changes in accounting or estimation techniques, changes in the design of a product, or regulatory requirements. A study completed by OPPT examined how some of the above factors contributed to changes in releases and transfers between 1989 and 1990. The study found that although source reduction was a significant factor in explaining some of the changes, fluctuations in production were more frequently cited for individual facilities' increases and decreases. This is an important consideration because measuring progress in source reduction must also take into account production changes.

Source reduction is too complex to be captured by only one measure. These data collected on Form R will help EPA better evaluate release trends and will also be critical in developing a comprehensive understanding of the effects of pollution prevention activities. The data provide EPA with a more comprehensive view of waste management practices. They shift the focus from releases to movement up the waste management hierarchy.

Source: USEPA 1994 Toxics Release Inventory Public Data Release (EPA 745-R-96-002, June 1996).

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