The latest version of the Toxic Release Inventory (TRI) came out on the 19th, with RTK Net's version open a day later. This year, RTK NET's version also supplies RSEI risk screening numbers -- for the first time, an at least partial answer to the question "How important is this particular release of pollution, anyways?"
EPA continued its recent trend of downplaying the data release. I don't think that they announced they'd be releasing it far in advance -- I had to find out about it through the grapevine after it was already up. I didn't see much news about it, and the news there was was unspecific. For instance, the overall release trend was down, but PCB releases jumped 40%. Why? According to this story, for one example, "EPA said that the jump was probably due to disposal of old equipment or clean up at industrial sites." Probably? The vast majority of the increase seems to be due to one site, Chemical Waste Management in Emelle, Alabama. Why not call that facility and get the actual cause for the jump? That's one of the things that would change this from a contextless, uninvestigated number into a story that people could begin to understand.
Showing posts with label toxic pollution. Show all posts
Showing posts with label toxic pollution. Show all posts
Sunday, March 22, 2009
Friday, March 13, 2009
So much for TRI's expanded Form A
As mentioned in an article here, the return of the Toxic Release Inventory's Form A to its older reporting levels -- back to 500 pounds instead of 2000 pounds of releases, if you don't want to get technical about it -- was attached to the spending bill and signed into law. It was pretty much a race between the judicial, legislative, and executive branches to see who would get this one first after Bush left.
If you do want to get technical about it, then this particular Post article, like almost all news articles that I know something about, is misleading. A sentence reads "The legislation restores the standard established by law in 1986, compelling all facilities to inform the public of any chemical releases that total 500 pounds a year or more, lowering the 2,000-pound threshold Bush had adopted." I could see not mentioning that it was actually two thresholds that were affected (one for releases and the other for waste generated). But the standard was never set by law, in 1986 or anytime else. The law leaves it up to EPA to set a reasonable standard. That's why the threshold can change in the first place. The older Form A level, which is what we're returning to, didn't even exist at all within the law as passed in 1986 -- it was added to TRI for 1995.
If you do want to get technical about it, then this particular Post article, like almost all news articles that I know something about, is misleading. A sentence reads "The legislation restores the standard established by law in 1986, compelling all facilities to inform the public of any chemical releases that total 500 pounds a year or more, lowering the 2,000-pound threshold Bush had adopted." I could see not mentioning that it was actually two thresholds that were affected (one for releases and the other for waste generated). But the standard was never set by law, in 1986 or anytime else. The law leaves it up to EPA to set a reasonable standard. That's why the threshold can change in the first place. The older Form A level, which is what we're returning to, didn't even exist at all within the law as passed in 1986 -- it was added to TRI for 1995.
Wednesday, January 21, 2009
An agenda for the Toxic Release Inventory
Today Obama signed a new Executive Order revitalizing FOIA, and spoke about transparency being one of the touchstones of his Presidency. As a sort of minor reciprocal gesture of faith, I've decided to put up an agenda of changes that I think should be made to the Toxic Release Inventory (TRI), one of U.S. EPA's most successful data programs. At any time during the last eight years, I wouldn't have talked about these ideas in any public forum until each piece was ready to be proposed formally, knowing that talking about the agenda beforehand would only give industry a heads-up to prepare to scuttle it. But perhaps being willing to talk about it beforehand will help everything go more smoothly. Needless to say, I'm also eager to hear about other people's ideas.
I have no formal authority to propose these kinds of changes at all, and am not writing this under any organizational affiliation. They are simply my personal ideas. However, I've worked extensively on the Toxic Release Inventory outside EPA since 1990, and I consider myself to be an expert on it. There are a number of organizations which I plan to work with to propose these things formally, in the event that no one else does.
I'll try to provide a little bit of background, in the unlikely event that anyone reads this who doesn't know all about TRI already. If you want to find out basic information about the Toxic Release Inventory, you can go to EPA's Web page on it, but in short it's a database, legislatively mandated to be publicly accessible in electronic form, that requires most kinds of large, fixed polluters to report their releases and transfers of toxic chemicals, as well as the toxic chemicals in waste that they generate. Unlike EPA's hazardous waste databases, it also requires that these reports be of the amount of chemical, not the amount of chemical plus inert filler, and that the reports be in common units. Facilities have to report releases of chemicals to air, land, water, and underground. These characteristics make the database EPA's most useful one for general toxic pollution issues. TRI was the model for many similar databases in other countries; these databases are generally called PRTRs, Pollutant Release and Transfer Registers.
The Toxic Release Inventory has had notable expansions during its now decades-long span -- waste data was added by the Pollution Prevention Act in 1991, Federal facilities added in 1994, hundreds of chemicals added in 1995, new industries outside manufacturing had to report starting in 1998, and data on persistent bioaccumulative chemicals was expanded in 2000. And for the last eight years, that's where it has stood -- other than a disgraceful reduction in TRI data in 2006, when the "Form A" option for facilities to avoid reporting was expanded, despite widespread opposition from the public, lawmakers, and scientists. Suffice it to say that although EPA's civil service employees generally understand the value of TRI, the administration running the agency at that time was actively hostile.
So these ideas have been around, in some cases, for many years, but there was no point in proposing them until the administration changed. Now that it has, here they are:
1. Add chemicals that cause global anthropogenic climate change (global warming)
This would be primarily CO2, methane, and nitrous oxide -- the Montreal Protocol chemicals, which also contribute to global warming, are already in TRI. I'm not a lawyer, but I would think that this would be possible under current legal authority because chemicals can be added to TRI if they cause a sufficient adverse effect on the environment, which GHGs are now known to do. The statute does refer to the adverse effect as being due to toxicity, so this interpretation is not certain. But if new authority is needed, it's going to be gotten anyways -- the Obama administration plans to do something about global warming, and you can hardly do anything about it without tracking emissions.
I can understand that people who want to track GHGs may want a new database designed for that particular purpose. (Currently EPA and DOE have a patchwork of databases, none of which were really designed for that, and which are going to have to be replaced.) TRI has certain limitations as a database tracking GHGs; what, for example, would be done about transportation sources, like fleets of trucks? But it seems to me that these chemicals should be added to TRI in any case, even if another database is created to specifically track them, as a cross-check. The information would also then benefit from TRI's well-developed distribution paths and user base. And TRI would come closer to matching other countries' PRTRs, several of which added GHGs quite a few years ago.
2. Change range reporting and speciation reporting of highly toxic chemicals
Since the beginning of TRI, people have faced the problem that TRI most easily allows comparison of raw pounds of chemicals -- but some chemicals are much more toxic than others, and some releases affect more people than others. These problems are attacked by a (in my opinion) excellent program within EPA called RSEI. But whenever there is a data release using data from RSEI -- most recently, the USA Today report -- the same thing happens, a facility reports a release range of 11-499 pounds of a highly toxic chemical like chromium compounds or diisocyanates, and this rightly is converted by EPA into the midpoint of the range, 250 pounds. (I blogged about a case of this here). 250 pounds is generally a very large release, for these chemicals, and it makes facilities pop up as major polluters and wastes everyone's time as people have to track down what is really going on. Most often, it turns out that the facility either thinks that its releases are towards the bottom of the range, or they don't release the more dangerous form of a chemical with two or more forms -- hexavalent vs trivalent chromium, for instance.
EPA could help both the reporting facilities and the public by changing the reporting rules. First, for those highly toxic chemicals that have more than one common form, EPA could require that each form be reported separately. This is already done for Dioxin. Second, EPA could prevent release and transfer range reporting from being used for these chemicals, or at least warn people who report through the TRI-ME reporting software what they are about to do.
3. Fix the Form A.
I won't write about attempts to roll back Form A reporting to what it used to be; that's already being done by various people. But whether the expanded Form A is rolled back or not, EPA should change the way in which it treats already-reported Form A data. A Form A should be treated as a range report, in the same way as TRI release and transfer ranges are treated. If someone sends in a current Form A for a non-PBT chemical, they are reporting that they release not more than 2000 pounds of the chemical, and generate in waste not more than 5000 pounds. This is not zero pounds. In fact, it's a range: 0-2000 pounds for releases, and EPA should use its well-established procedure for handling release ranges and take the midpoint, converting this to a quantity within the database of 1000 pounds. This would preserve the TRI reporter's ability to not have to take the time to fill out the additional information required for a Form R, but it would also give the public a more accurate estimation, based on best available information, of what is going on. If a TRI reporter didn't want the public to assume that the best guess was 1000 pounds, they always have the option of choosing to fill out a Form R and reporting any number of pounds, including zero.
This procedure is currently used for TRI data provided by RTK NET (described here), so I know that it's both possible and easy to do. The release media (air, land, or water) can't be determined, but a general Form A pseudo-release-medium can be assigned. No change in how facilities report would be required in order to do this; it could be done simply as an internal change in how EPA handles the data.
4. Fix Pollution Prevention Act reporting.
Pollution Prevention Act data were added to TRI in 1991, and they've never been able to be done exactly right. The waste data are currently reported as amounts recycled on and off site, burned for energy recovery on and off site, treated (destroyed) on and off site, and released or disposed of on and off site in various ways. But all of these numbers were supposed to add up to a single number, the quantity of the chemical in waste generated by the facility. That's because reporting these numbers was supposed to encourage source reduction, the practice of changing processes to reduce the amount of waste generated. But the regulation was sabotaged by ideologues at the Office of Management and Budget, and EPA was prevented from defining what a waste was, or something similar. So it could only require that facilities report the components that add up to the overall waste number, without really referring to it in a coherent way.
I don't know whether any actual change in reporting is required for this to happen -- perhaps just better guidance from EPA? Re-opening the issue with a new OMB? Perhaps having facilities total up their Section 8 waste quantities and report the total would help them realize what it's supposed to be for.
5. Re-open cooperation with other countries' PRTRs
I'm not sure where this stands, organizationally, and it's not the kind of thing I'd know about directly. (Although I have worked for the Commission for Environmental Cooperation on putting together a Web site to display combined U.S., Canadian, and Mexican PRTR data.) But it seems to me that EPA could have more of a sense of where chemicals within TRI stand within an international comparison. Just about the entire First World has some sort of PRTR -- does EPA track transfers from one country to another using multiple PRTRs? Could they, perhaps, report on how U.S. emissions of particular chemicals compare to those of other countries? I'd guess that more is being done on this score than I know about, but anything that EPA can do to make this kind of data more truly global would be highly valuable.
(I should probably note that I once tried to put together a proposal to make a free, publicly accessible database-backed Web site that would allow people to search all the PRTRs at once. I couldn't find a funder for it -- most charitable foundations and NGOs that I deal with focus on the U.S. That was a few years back, and I don't know whether anyone is doing that now, but it would still be a good idea.)
That's probably enough for now. I invite anyone who wants to comment on this to feel free to.
...Read more
I have no formal authority to propose these kinds of changes at all, and am not writing this under any organizational affiliation. They are simply my personal ideas. However, I've worked extensively on the Toxic Release Inventory outside EPA since 1990, and I consider myself to be an expert on it. There are a number of organizations which I plan to work with to propose these things formally, in the event that no one else does.
I'll try to provide a little bit of background, in the unlikely event that anyone reads this who doesn't know all about TRI already. If you want to find out basic information about the Toxic Release Inventory, you can go to EPA's Web page on it, but in short it's a database, legislatively mandated to be publicly accessible in electronic form, that requires most kinds of large, fixed polluters to report their releases and transfers of toxic chemicals, as well as the toxic chemicals in waste that they generate. Unlike EPA's hazardous waste databases, it also requires that these reports be of the amount of chemical, not the amount of chemical plus inert filler, and that the reports be in common units. Facilities have to report releases of chemicals to air, land, water, and underground. These characteristics make the database EPA's most useful one for general toxic pollution issues. TRI was the model for many similar databases in other countries; these databases are generally called PRTRs, Pollutant Release and Transfer Registers.
The Toxic Release Inventory has had notable expansions during its now decades-long span -- waste data was added by the Pollution Prevention Act in 1991, Federal facilities added in 1994, hundreds of chemicals added in 1995, new industries outside manufacturing had to report starting in 1998, and data on persistent bioaccumulative chemicals was expanded in 2000. And for the last eight years, that's where it has stood -- other than a disgraceful reduction in TRI data in 2006, when the "Form A" option for facilities to avoid reporting was expanded, despite widespread opposition from the public, lawmakers, and scientists. Suffice it to say that although EPA's civil service employees generally understand the value of TRI, the administration running the agency at that time was actively hostile.
So these ideas have been around, in some cases, for many years, but there was no point in proposing them until the administration changed. Now that it has, here they are:
1. Add chemicals that cause global anthropogenic climate change (global warming)
This would be primarily CO2, methane, and nitrous oxide -- the Montreal Protocol chemicals, which also contribute to global warming, are already in TRI. I'm not a lawyer, but I would think that this would be possible under current legal authority because chemicals can be added to TRI if they cause a sufficient adverse effect on the environment, which GHGs are now known to do. The statute does refer to the adverse effect as being due to toxicity, so this interpretation is not certain. But if new authority is needed, it's going to be gotten anyways -- the Obama administration plans to do something about global warming, and you can hardly do anything about it without tracking emissions.
I can understand that people who want to track GHGs may want a new database designed for that particular purpose. (Currently EPA and DOE have a patchwork of databases, none of which were really designed for that, and which are going to have to be replaced.) TRI has certain limitations as a database tracking GHGs; what, for example, would be done about transportation sources, like fleets of trucks? But it seems to me that these chemicals should be added to TRI in any case, even if another database is created to specifically track them, as a cross-check. The information would also then benefit from TRI's well-developed distribution paths and user base. And TRI would come closer to matching other countries' PRTRs, several of which added GHGs quite a few years ago.
2. Change range reporting and speciation reporting of highly toxic chemicals
Since the beginning of TRI, people have faced the problem that TRI most easily allows comparison of raw pounds of chemicals -- but some chemicals are much more toxic than others, and some releases affect more people than others. These problems are attacked by a (in my opinion) excellent program within EPA called RSEI. But whenever there is a data release using data from RSEI -- most recently, the USA Today report -- the same thing happens, a facility reports a release range of 11-499 pounds of a highly toxic chemical like chromium compounds or diisocyanates, and this rightly is converted by EPA into the midpoint of the range, 250 pounds. (I blogged about a case of this here). 250 pounds is generally a very large release, for these chemicals, and it makes facilities pop up as major polluters and wastes everyone's time as people have to track down what is really going on. Most often, it turns out that the facility either thinks that its releases are towards the bottom of the range, or they don't release the more dangerous form of a chemical with two or more forms -- hexavalent vs trivalent chromium, for instance.
EPA could help both the reporting facilities and the public by changing the reporting rules. First, for those highly toxic chemicals that have more than one common form, EPA could require that each form be reported separately. This is already done for Dioxin. Second, EPA could prevent release and transfer range reporting from being used for these chemicals, or at least warn people who report through the TRI-ME reporting software what they are about to do.
3. Fix the Form A.
I won't write about attempts to roll back Form A reporting to what it used to be; that's already being done by various people. But whether the expanded Form A is rolled back or not, EPA should change the way in which it treats already-reported Form A data. A Form A should be treated as a range report, in the same way as TRI release and transfer ranges are treated. If someone sends in a current Form A for a non-PBT chemical, they are reporting that they release not more than 2000 pounds of the chemical, and generate in waste not more than 5000 pounds. This is not zero pounds. In fact, it's a range: 0-2000 pounds for releases, and EPA should use its well-established procedure for handling release ranges and take the midpoint, converting this to a quantity within the database of 1000 pounds. This would preserve the TRI reporter's ability to not have to take the time to fill out the additional information required for a Form R, but it would also give the public a more accurate estimation, based on best available information, of what is going on. If a TRI reporter didn't want the public to assume that the best guess was 1000 pounds, they always have the option of choosing to fill out a Form R and reporting any number of pounds, including zero.
This procedure is currently used for TRI data provided by RTK NET (described here), so I know that it's both possible and easy to do. The release media (air, land, or water) can't be determined, but a general Form A pseudo-release-medium can be assigned. No change in how facilities report would be required in order to do this; it could be done simply as an internal change in how EPA handles the data.
4. Fix Pollution Prevention Act reporting.
Pollution Prevention Act data were added to TRI in 1991, and they've never been able to be done exactly right. The waste data are currently reported as amounts recycled on and off site, burned for energy recovery on and off site, treated (destroyed) on and off site, and released or disposed of on and off site in various ways. But all of these numbers were supposed to add up to a single number, the quantity of the chemical in waste generated by the facility. That's because reporting these numbers was supposed to encourage source reduction, the practice of changing processes to reduce the amount of waste generated. But the regulation was sabotaged by ideologues at the Office of Management and Budget, and EPA was prevented from defining what a waste was, or something similar. So it could only require that facilities report the components that add up to the overall waste number, without really referring to it in a coherent way.
I don't know whether any actual change in reporting is required for this to happen -- perhaps just better guidance from EPA? Re-opening the issue with a new OMB? Perhaps having facilities total up their Section 8 waste quantities and report the total would help them realize what it's supposed to be for.
5. Re-open cooperation with other countries' PRTRs
I'm not sure where this stands, organizationally, and it's not the kind of thing I'd know about directly. (Although I have worked for the Commission for Environmental Cooperation on putting together a Web site to display combined U.S., Canadian, and Mexican PRTR data.) But it seems to me that EPA could have more of a sense of where chemicals within TRI stand within an international comparison. Just about the entire First World has some sort of PRTR -- does EPA track transfers from one country to another using multiple PRTRs? Could they, perhaps, report on how U.S. emissions of particular chemicals compare to those of other countries? I'd guess that more is being done on this score than I know about, but anything that EPA can do to make this kind of data more truly global would be highly valuable.
(I should probably note that I once tried to put together a proposal to make a free, publicly accessible database-backed Web site that would allow people to search all the PRTRs at once. I couldn't find a funder for it -- most charitable foundations and NGOs that I deal with focus on the U.S. That was a few years back, and I don't know whether anyone is doing that now, but it would still be a good idea.)
That's probably enough for now. I invite anyone who wants to comment on this to feel free to.
...Read more
Thursday, December 11, 2008
Saint-Gobain, Northampton, MA
The fallout from the USA Today report mentioned in the last post is still settling, with politicians and Federal and state regulators promising various responses. I've heard that there's the usual rush of facilities, after a TRI report like this is released, to correct their reporting errors and/or explain their reports. But I'm getting involved with this locally too; a school that I've often biked past, and that some of my friends' kids go to, is listed as the third most potentially polluted from these industrial sources in Massachusetts.
Update: after new information was supplied by the facility, this is probably nothing to worry about: see below.
Looking at the site, 99% of the estimated risk is from a single polluter here, a Saint-Gobain facility. Looking up their TRI data here, as well as their RSEI data, it's clear that the estimated risk is due to their report of an air release of chromium compounds.
I've seen many, many facilities get themselves bad publicity by reporting in the way that this facility did, when they report something like chromium compounds or diisocyanates, something with a high toxicity or carcinogenicity. They reported an air release using a release range: 11-499 pounds. EPA routinely transforms this into the midpoint of the range: 250 pounds. That's a lot of chromium. In addition, EPA doesn't have respondents distinguish between hexavalent chromium, a known human carcinogen (and the chemical that Erin Brockovich campaigned against), and trivalent chromium, which isn't anywhere near as bad.
The facility should clarify this so that everyone can get a better idea of how much concern there should be. I called their TRI public contact on the phone, left a message, and got no response -- that's no surprise; I've been working with TRI data since 1991 and have never, ever gotten a response from a public contact. So I sent the following Email to their technical contact:
I'll see what I response I get. Given that Saint-Gobain is a multinational, I'd guess that my missive may well get passed up quite a chain. But I plan on continuing to pursue this.
My guess is that the range reporting may well have inflated their reported number to be greater than what they actually released. But there's no way to know without asking them.
Update (12/12/2008): The facility says that the level of hexavalent chromium in the chromium they use is very low, so I'd think that this means there's no reason for undue concern. Their reply was:
My reply was:
And that is that. Really what is needed is some way to change TRI reporting to discourage this kind of report from happening -- reporting chromium speciation would be good (people already report dioxin speciation to TRI, so it can be done), and there might be a category of highly toxic chemicals that range reporting is not used for, or at least warned about. I'm going to take this up with EPA once the new administration is in place.
...Read more
Update: after new information was supplied by the facility, this is probably nothing to worry about: see below.
Looking at the site, 99% of the estimated risk is from a single polluter here, a Saint-Gobain facility. Looking up their TRI data here, as well as their RSEI data, it's clear that the estimated risk is due to their report of an air release of chromium compounds.
I've seen many, many facilities get themselves bad publicity by reporting in the way that this facility did, when they report something like chromium compounds or diisocyanates, something with a high toxicity or carcinogenicity. They reported an air release using a release range: 11-499 pounds. EPA routinely transforms this into the midpoint of the range: 250 pounds. That's a lot of chromium. In addition, EPA doesn't have respondents distinguish between hexavalent chromium, a known human carcinogen (and the chemical that Erin Brockovich campaigned against), and trivalent chromium, which isn't anywhere near as bad.
The facility should clarify this so that everyone can get a better idea of how much concern there should be. I called their TRI public contact on the phone, left a message, and got no response -- that's no surprise; I've been working with TRI data since 1991 and have never, ever gotten a response from a public contact. So I sent the following Email to their technical contact:
Dear Mr. (redacted):
I am Emailing you because you are listed as the TRI (Toxic Release Inventory) technical contact for the Saint-Gobain Ceramic Materials facility in Northampton. I am an independent researcher living in Northampton who has worked with TRI data for some time, as well as the RSEI data used to make the USA Today report that references your facility at:
http://content.usatoday.com/news/nation/environment/smokestack/polluter/465
As you can see from this USA Today report, the Saint-Gobain facility causes the Montessori School of Northampton to rank in the top two percentile of schools nationwide in terms of schools whose air is potentially polluted by industrial facilities, as well as potentially affecting other Northampton schools. Looking at your TRI report at:
http://data.rtknet.org/tri/tri.php?facility_id=01060SNTGB175IN&reporting_year=2005&datype=T&reptype=f&detail=4
and at the RSEI data, it is clear that the potential pollution in question is listed in your report as a release range of 11-499 pounds of chromium and chromium compounds to the air in 2005. EPA routinely treats release ranges of this sort as being equivalent to the midpoint of the range: 250 pounds.
I have some questions about your TRI report and the facility's operations:
1. Do you have a better idea of how much chromium and / or chromium in compounds is actually released than 11-499 pounds? Getting a more accurate number could affect the RSEI risk screening calculation quite dramatically.
2. Do you have an idea, through testing or other means, of how much of the chromium is hexavalent chromium -- a known human carcinogen -- vs how much is trivalent [note: I originally wrote this as "chromium trioxide", oops.]? That would also lead to a better understanding of the potential risk involved.
3. Are there any plans possible or underway to reduce use of, or emissions of, chromium? Your 2006 TRI report, the latest publicly available, shows the same chromium release as in 2005.
Thank you for your attention to this request for information. I plan on sharing your reply with other people who may be concerned about the chromium emissions from the Saint-Gobain Ceramic Materials facility. If you wish to contact me, I can be reached through Email, or by phone at xxx-xxx-xxxx.
Best regards,
Rich Puchalsky
cc: (redacted), Montessori School of Northampton
I'll see what I response I get. Given that Saint-Gobain is a multinational, I'd guess that my missive may well get passed up quite a chain. But I plan on continuing to pursue this.
My guess is that the range reporting may well have inflated their reported number to be greater than what they actually released. But there's no way to know without asking them.
Update (12/12/2008): The facility says that the level of hexavalent chromium in the chromium they use is very low, so I'd think that this means there's no reason for undue concern. Their reply was:
We produce various ceramic powders used by our customers in coating applications. One of our products is trivalent chromium oxide used in wear resistance applications. This chromium product contains well over 99% trivalent chromium oxide. We have tested for hexavalent chromium oxide and the concentration tends to be around 50ppm in our product. As stated in the USA Today website that you reference “Chromium 3 (trivalent) is an essential nutrient and helps the body process proteins, sugars, and fats.”
We believe that the emission values that you reference are a conservative estimate and the actual values are likely much less. The trivalenet chromium is present as a small particle like dust. We process our internal process air through “dust collectors” that are designed to remove 99.99% of the dust in the air. This treated air is then vented back into the building. We also utilize a plant wide central vacuum system for cleaning floors and equipment to minimize dust generation during cleaning. Therefore any trivalent chromium emissions are simply any minimal dust that may escape through open doors. As you can imagine the actual number would be difficult to measure, but we feel that the actual number is closer to 11 lbs than to 499 lbs per year.
My reply was:
Thank you for your reply. The RSEI model used to estimate the risk from your facility's chromium emissions assumes that air emissions of chromium are particulates, as is the case for your facility, but it also assumes, based on industry averages, that the percentage of hexavalent chromium in the chromium released would be 34%. An actual hexavalent chromium percentage of 1% (to round up) would then reduce the estimated risk to 1/34 of the original calculation. That would lower the concern about emissions from your facility to the point where the Montessori school, and other schools in Northampton, would no longer score high on a nationwide or statewide comparison of the kind used in the USA Today report.
I should mention, however, that as far as I know, TRI estimates of releases are supposed to be made for the amount leaving the facility, not the amount "released" internally and then recollected before it reaches the outside. It's good to know that you have processes in place to reduce emissions, but the 11-499 pound estimate is presumably your estimate for the amount released to the air after your emission-control equipment has worked, not before.
I encourage you to develop a better estimate of how much chromium is actually released, sufficient for you to report to TRI with your best estimate in pounds rather than as a range. Until that is done, the public can only assume that 250 pounds is the best guess, which leads to more concern about your facility than is warranted if the true number is actually much lower. Hexavalent chromium is by far the primary concern for air emissions, but there are some environmental processes that can change trivalent to hexavalent chromium under some conditions, so it's still of interest to people to know how much is being released.
And that is that. Really what is needed is some way to change TRI reporting to discourage this kind of report from happening -- reporting chromium speciation would be good (people already report dioxin speciation to TRI, so it can be done), and there might be a category of highly toxic chemicals that range reporting is not used for, or at least warned about. I'm going to take this up with EPA once the new administration is in place.
...Read more
Tuesday, December 9, 2008
Toxic air and America's schools
There's an excellent report by USA Today that uses EPA reported pollution data and air modeling to estimate air quality at schools nationwide. It has a good database-backed Web site, too, that lets you look up your school, the schools with the worst air quality from those sources in your state, and so on.
I was involved very tangentially in this project -- I helped to work on data for PERI that USA Today used. I'm impressed by what USA Today did with it; it's better than the usual environmental toxics story. What PERI did was a bit complicated to explain, but I'll make the attempt -- there's a database, TRI, in which large industrial sources report their toxic pollution. A project within EPA, RSEI, takes the reported pounds of air pollution from each facility and runs an air model to see where the chemicals are going, geographically. They can then use Census data to see how many people live in each area affected by the pollution. They add all of this up into an overall risk screening score for each facility. PERI realized that these data could be obtained for each location on the ground, instead of being all added up to a single score for each facility. That lets you find the contribution of each polluter to a particular place where people live. (Or, in this case, where a school is.)
I only wish that I had the resources that USA Today does; their database-backed Web site is significantly more polished and user-friendly than I can generally make mine in the time that I have available to work on them. Learning how to embed databases into Google Maps is something I'm going to have to pick up. But there is one map graphic they created that I particularly wanted to call attention to: this -- or as a screenshot rather than an interactive map, so that I can show it here, the map below.
Compare this with the map of electric power generation by fuel source that I copied from eGRID for this earlier post. Or, for that matter, compare it with Joel Garreau's division of North America into "nine nations":
Industrial pollution near schools seems to be heavily concentrated in the areas of the country that Garreau refers to as Dixie and the Foundry. That's surprising, in some ways. Other places such as California certainly have industrial pollution too, but perhaps it's more spread out, or further away from city centers. Of course, this particular pollution map doesn't include non-point sources such as cars -- Los Angeles' smog problem gives it much worse overall air quality throughout its region than the vast majority of point-source-polluted sites. And this map doesn't include all sorts of other sources. But it's an example of how pollution is largely affected by regional patterns of development. If you were mapping environmental damage from mining waste, you'd get a different region of the U.S. highlighted -- national solutions to these problems often come down to regional politics.
...Read more
I was involved very tangentially in this project -- I helped to work on data for PERI that USA Today used. I'm impressed by what USA Today did with it; it's better than the usual environmental toxics story. What PERI did was a bit complicated to explain, but I'll make the attempt -- there's a database, TRI, in which large industrial sources report their toxic pollution. A project within EPA, RSEI, takes the reported pounds of air pollution from each facility and runs an air model to see where the chemicals are going, geographically. They can then use Census data to see how many people live in each area affected by the pollution. They add all of this up into an overall risk screening score for each facility. PERI realized that these data could be obtained for each location on the ground, instead of being all added up to a single score for each facility. That lets you find the contribution of each polluter to a particular place where people live. (Or, in this case, where a school is.)
I only wish that I had the resources that USA Today does; their database-backed Web site is significantly more polished and user-friendly than I can generally make mine in the time that I have available to work on them. Learning how to embed databases into Google Maps is something I'm going to have to pick up. But there is one map graphic they created that I particularly wanted to call attention to: this -- or as a screenshot rather than an interactive map, so that I can show it here, the map below.
Compare this with the map of electric power generation by fuel source that I copied from eGRID for this earlier post. Or, for that matter, compare it with Joel Garreau's division of North America into "nine nations":
Industrial pollution near schools seems to be heavily concentrated in the areas of the country that Garreau refers to as Dixie and the Foundry. That's surprising, in some ways. Other places such as California certainly have industrial pollution too, but perhaps it's more spread out, or further away from city centers. Of course, this particular pollution map doesn't include non-point sources such as cars -- Los Angeles' smog problem gives it much worse overall air quality throughout its region than the vast majority of point-source-polluted sites. And this map doesn't include all sorts of other sources. But it's an example of how pollution is largely affected by regional patterns of development. If you were mapping environmental damage from mining waste, you'd get a different region of the U.S. highlighted -- national solutions to these problems often come down to regional politics.
...Read more
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