How Consistent Is Your Emissions Data?

This article is available as a podcast episode on ALL4’s Air Quality Insider

With greater frequency lately, many facilities are receiving inquiries from U.S. EPA regarding inconsistencies related to Federal Toxic Release Inventory (TRI) reporting and other regulatory reporting programs.  These inquiries tend to be in the form of an email, which can look something like this:

Dear TRI Facility Technical Contact:

This email message is part of EPA’s annual data quality check. EPA performs many analyses on the TRI data to ensure that the TRI dataset is of the highest quality possible. At this time we are reviewing the data for reporting years 2014-2016. A Form R from your facility’s [reporting year] submission(s) has been identified for follow-up due to the following:

The email then goes on to identify one or more specific discrepancies between emissions data reported to a state/local/tribal government compared to emissions data reported for TRI.  The email concludes with something like the following:

This inquiry does not automatically mean that EPA believes your facility has made an error. EPA would like to provide you with an opportunity to double check your submissions and, if necessary, make corrections. Please let us know if the data is correct as reported, will be revised or withdrawn.  We would appreciate your response back to me no later than [approximately 30 days later].

As U.S. EPA implies, there may be a legitimate reason for a discrepancy.  However, if an error is identified, U.S. EPA directs the recipient to TRI-MEweb, which is used to submit, revise, or withdraw TRI reporting forms.  While this example pertains specifically to TRI, we have seen inquiries across various state and Federal programs, and they appear to be automated due to the availability of electronic data.  We have also seen other similar inquiries before, especially for National Emissions Inventory (NEI) years like 2017  (i.e., every three years).

There are plenty of reasons why your state emissions inventory data may differ from the data reported for TRI purposes.  The TRI program addresses several types of releases from a facility (e.g., air, water, and waste) while state emissions inventory data focuses on air emissions.  Some substances may be reportable under one program and not another.  If there really is an error, a common reason we see is due to discrepancies between an emissions factor or calculation methodology across various programs.  Such discrepancies may occur because each report was prepared by a different individual at the facility, or because an emissions factor was updated for one program and not the other, or just because “it’s always been done that way.”

Emissions factors can change fairly frequently, especially if they are based on site-specific data; but published emissions factors (e.g., from AP-42, WebFIRE, or from trade organizations), may also change as new data becomes available.  How often does your facility review and update emissions factors, and how often are they updated consistently between reporting programs?

If you determine that a discrepancy identified by U.S. EPA requires a revision to the emissions data in the state or TRI report, where else was that emissions data used?  Having a procedure in place to ensure emissions data are representative and consistent across multiple programs becomes more important as electronic reporting and associated “data transparency” becomes more common.  Electronic emissions data are more accessible to regulators and the public for review, comparison, and scrutiny, and therefore facilities need to be confident in their emissions data.  Confidence can come from being proactive with your emissions data rather than reactive to inquiries.

With many different reporting obligations, could your facility use more consistency?  Contact me (610.933.5246 x122 or lkroos@all4inc.com) to discuss how ALL4 can support you.