Toxics Release Inventory (TRI) reporting is the most difficult time of the year for EHS professionals: it’s an annual compendium of your air, water, and waste emissions that forces you to take a closer look at your facility’s records. Because the scope of TRI Reporting is so broad—both in the quantity of data and the time it takes to compile and submit it to the EPA—it is shockingly easy to make a major mistake that results in an eagle-eyed environmental auditor knocking on your door.
These auditors adhere to a specific procedure when hunting down red flags in your TRI report. Luckily, some of the steps they follow are available to the public, which means you can spot and correct red flags in your TRI data before they cost you.
We teamed up with a recently retired high-level TRI coordinator to learn exactly how auditors decide which facilities to target for an investigation. More specifically, we will go over the process of studying the data you submitted in your last National Emissions Inventory (NEI) Report and making sure it aligns with the picture you are painting this TRI season.
We also offer a full guide to TRI reporting outside of this auditing topic, in case you're looking for a more comprehensive analysis of TRI data.
How EPA Auditors Use NEI Data to Check your TRI Report for Accuracy
Both reports ask you to quantify the annual air emissions your production sources release into the atmosphere. Therefore, there is significant overlap between the two programs; in fact, TRI covers as many as 96% of the Hazardous Air Pollutants included in NEI reporting.
This overlap grants you an opportunity to double-check whether your emissions ‘story’ is cohesive. TRI, however, collects both stack and fugitive emissions, so expect the emission sums reported under TRI to be higher than the NEI equivalents for the same chemical.
As far as gathering NEI data goes, your best bet is to look at your previous records. Assuming your site has been operating according to regulation, you’ll have multiple years’ worth of accurate data to use as points of reference for both individual values and overall air pollutant emission trends. If this year’s numbers are within the acceptable parameters, then the EPA should find no fault with your submission. (And if you don’t keep track of records internally or you have trouble locating them, think of this exercise as a good wake-up call when it comes to investing in a centralized reports library).
If you are new to your site or are otherwise unfamiliar with your NEI records, you can always resort to the EPA’s national emissions inventory database for your state or industry, which is precisely what auditors will be investigating. Simply access the ECHO website and search for your facility. For more tips on navigating this database, refer to our TRI Red Flags eBook (see below).
Once you’ve compiled whatever data you could find, it’s time to set it beside this year’s numbers and put your auditor cap on.
Comparing NEI and TRI Reporting Figures to Find Discrepancies in Your Data
EPA auditors have been trained to spot specific red flags. By knowing what they are looking for, you’ll be able to direct your attention to the inconsistencies most likely to get you fined.
For starters, you should only focus on high-emission, TRI-reportable chemicals. You could have a 500% difference in emission levels from one year to the next, but no auditor will bat an eye if the jump is from 0.5 to 3.0 tons of ammonia or any other criteria pollutant (lead aside). And of course, if the chemical in your emissions inventory report is not included in your TRI submission, you won’t have data to compare in the first place. That said, make sure not to omit any TRI chemical categories when narrowing down your list; this is a common EPA TRI reporting mistake that might misrepresent your numbers.
You should have a vetted inventory of the most conspicuous TRI chemicals at your facility, as made publicly available on the NEI database, against which to cross-reference your current TRI report. Your goal is to find differences between NEI and TRI values greater than 20% (if any exist), since anything below that mark is generally caused by the inclusion of fugitive emissions and seldom reviewed by auditors.
These discrepancies usually come in one of four kinds. We’ve listed them below, along with potential software fixes for them.
Missing TRI-listed Chemicals
One of the most frequent discrepancies, and by the far the easiest to iron out, occurs when TRI-reportable chemicals are present in your emissions inventory but missing in your TRI report. As a matter of fact, the same applies to last year’s TRI submission. Auditors expect continuity year-over-year, so if you discover that a chemical has been purposefully omitted, rather than accidentally forgotten, you better know why that was.
The Software Solution: A single platform that tracks every incoming chemical and the quantities of product used or processed acts as a toxic release inventory database and guarantees every reportable chemical is accounted for.
Small Discrepancies for a Few TRI Pollutants
While deviations from the rolling average at or below 20% rarely earn you a spot on the EPA watchlist for future audits, they might point to an excluded source or an inconsistent estimation methodology and are therefore worth reviewing in their own right. You’d be surprised just how mismanaged records can be when independent EHS professionals draw on siloed spreadsheets and expose their data to varying calculation rules and procedures.
The Software Solution: Invest in a centralized data management and modeling software built to provide you with extremely robust and precise environmental calculations.
Major Discrepancies Between Emission Inventory Releases
Unless your facility’s industrial operations have radically changed or the use of some of the main TRI-reportable chemicals was discontinued, a sudden jump or drop in emission levels is a telltale sign that there’s something amiss about your standards for communicating environmental data. Whatever the case, prepare for a follow-up phone call or an in-person audit by compiling your chemical inventory data and emission records for the year in question. Auditors will want to study every data point in your system to justify your TRI narrative.
The Software Solution: There are several potential reasons behind a deviation of that magnitude, from a shift in industrial priorities to negligent recordkeeping. More efficient data management cannot single-handedly resolve these issues, but having access to a consolidated data bank and processing engine does make it easier to legitimize the blips in your compliance timeline.
Multiple Discrepancies Across a Specific Release Type
Whenever you notice a repeating pattern of inconsistencies for a specific chemical type, emissions media (e.g. air, waste, or water), or source, you’re probably feeling the effects of a breakdown in communication between EHS teams at your facility. The groups may not be sharing records with each other or even agreeing on the approach for performing calculations, leading to disjointed recordkeeping.
Here's a real-world example that the ex-TRI coordinator who helped us prepare this article experienced firsthand:
A company tasked with reporting mercury releases set up a task force specifically for this purpose. Naturally, they strove to use the most stringent monitoring procedures to track, and ultimately minimize, these releases. However, the team in charge of TRI reporting was based at a different site; not only did they never consult the task force, but they also used a much more general estimation methodology and came up with vastly different numbers. When the EPA compared the two reports, it concluded the company was inconsistent with its reporting process and called for an audit, even though the company did the right thing by creating the task force in the first place.
The Software Solution: This division is effortlessly resolved by using a collaborative EHS platform to standardize and automate your data management. As long as everyone pulls from the same data and follows the same reporting best practices, your report should be free of this discrepancy.
Overall, having a tool that systematically gathers and sorts your records, flags these discrepancies, and provides an explanation for a chemical’s absence or anomalous values obviates the need to check for these discrepancies.
Free Downloads: Toxics Release Inventory Reporting eBooks
ERA offers a plethora of free, on-demand, and comprehensive resources on everything reporters need to know to file an environmental report, be it TRI, Tier II, NPRI, and so on. Among them you’ll find the TRI Reporters Guide to Catching and Fixing Red Flags, a more detailed analysis of the overlap between NEI and TRI and how to leverage it to avoid fines and penalties. You can download your free copy by clicking on the button below.
We’ve also created an all-encompassing Survival Guide for both new and experienced reporters looking for useful insights, TRI reporting instructions and best practices, and tips for keeping your reports up to date.
And, as always, feel free to schedule a meeting with one of our Project Analysts. This is a perfect opportunity for you to shore up your TRI approach if you spotted one or several of the aforementioned discrepancies in your draft report. You’ll be amazed at how easy it is to streamline your EH&S methodology and reap the benefits of automated inventory management and report generation.
An older version of this article was written by Alex Chamberlain and posted on June of 2016.