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Summary of Listening Session: Steel Industry Representatives

National Dialogue on Access to Environmental Information
Washington, D.C.
May 19, 2008

Quick Summary – Steel Industry
Representatives would like to see the following changes in TRI: 

  • Improved data quality

  • Contextual information accompanying datasets

  • More public outreach and education

  • Improve transparency of EPA models and methodologies

  • Additional TRI release categories and sorting options

  • Linkages to compliance information and other EPA databases

  • Addition of caveats and disclaimers

A key component of the Environmental Protection Agency’s National Dialogue on Access to Environmental Information is a series listening sessions to elicit input on the types of environmental information that EPA’s stakeholders use, how they use it, and their preferred formats, channels, and venues for obtaining this information. This report summarizes inputs from a National Dialogue Listening Session with steel industry representatives. In contrast to the core group sessions, the format of this listening session was less structured and focused primarily on improving the communication of environmental information using the example of EPA’s Toxic Release Inventory (TRI). The Appendix at the end of this document provides information about the participants, including their job titles and affiliations.

Main Concerns

The representatives of the steel industry welcomed the opportunity to discuss with EPA suggestions to improve the accuracy and usefulness of environmental information communicated to the public.  They used examples of Toxic Release Inventory (TRI) information to illustrate methods that EPA could use to better inform the public of pertinent environmental information in their communities. Mostly, they were concerned with making sure that the information which was communicated by the TRI database contained sufficient contextual reference so that the data was meaningful to users.  The participants agreed that a website was the most practical and effective tool to disseminate TRI information on a large scale. They pointed out one potential source of error in the current web presentation. Currently waste material transported off site and placed in a secure landfill is treated the same as any localized emission.  Also materials transported off site for recycle or reuse without any associated emissions are also treated as localized emissions.  The participants suggested that aggregating these activities with actual reported emissions had the potential to misinform the community.  

EPA's role should be in educating the public about the release data contained in the TRI database to help clear up any misconceptions.

The addition of information on which entities and sectors report under TRI and which are exempt, would also show more clearly that some large public sources of emissions within a ZIP code are not reflected in a TRI search. The iron and steel industry has been included since TRI’s inception, and while several sectors have been added to TRI over the years, municipal sources, such as incinerators (large generators of mercury), and wastewater treatment plants (large emitters of nitrates) have not. The public needs to know that the published TRI database results only includes facilities required to report under TRI, and that there are other large emitters that are not required to report. In fact it has been proven that within a particular local area, transportation sources can eclipse the emissions of even a large facility.

The participants also believe that the public should know about a company’s emission control activities and associated expenditures, and be informed about the amount of resulting emissions reductions and improved efficiencies. The industry has made large investments in emission control devices over the years and improved capture efficiencies significantly. State of the art emission control equipment removes regulated substances from the effluent stream and disposes of them safely at secure landfills. However, while removing substances from water and air has resulted in a decreased emission to these media, the amount of these collected substances transported for secure disposal at landfills has increased. The participants pointed out that there has been no effort to explain the reasons behind such trends to the public. While it would probably not be practical for TRI to capture this type of information for each facility, EPA could add a general explanation about pollution reduction efforts and technologies and provide some general trend information.

Other EPA Information Tools

When EPA inquired about other environmental information tools the steel industry uses, the participants mentioned the Risk-Screening Environmental Indicators (RSEI) tool [http://www.epa.gov/oppt/rsei/index.html] and the National-Scale Air Toxics Assessment (NATA) [http://www.epa.gov/ttn/atw/nata/index.html]. One respondent noted that EPA’s models often lack transparency and that the methodologies and underlying assumptions need to be made more transparent.

One of the participants commented that the RSEI analysis tool is too simplified. RSEI allows users to plug TRI data into a risk assessment model. The results then are intended to indicate the level of environmental risk a facility may theoretically pose to a surrounding community. The participant pointed out that the assumptions underlying this analysis are unrealistic because the tool does not apply a toxic weighting factor and risk receptors are not considered. While the model distinguishes between the “relative importance” of different substances, such as, for example, benzene and nitrates, or zinc and lead, risks need to be weighted, defined, and interpreted more clearly in order to convey a meaningful message to the public.

When asked about their experience with NATA, the participants thought that “in theory, the database is educational and useful,” but noted that the risk information presented in NATA may not be “accurate.” The model looks at different emission sources and attempts to communicate to the public, theoretical associated health risks. According to EPA, NATA undergoes a considerable amount of vetting and provides context and background information on health risks. But the participants said that similar to EU’s REACH, which also attempts to quantify the risks associated with specific constituents, the industry is concerned about the procedures used to  develop risk factors without taking into consideration localized attenuation.

Some participants indicated the ECHO [Enforcement and Compliance History Online] database could be improved by adding a true “Compliance History”, reporting not just rare non-compliance events, but actually report the overall percent compliance for a facility.   On the whole steel facilities operate at better than 99% compliance.   The new web tools could easily communicate this to the public and users would be able to discern chronic non-compliant facilities more readily and not just focus on the a few events.

Uses of TRI

According to the steel industry representatives, TRI data is used during public outreach efforts. However, the participants suggested that a lack of contextual information as described above leaves the door open for misinterpretation of the data. As a result, the industry frequently finds itself having to continually explain potential flaws in the data described above. While the industry takes community outreach very seriously and undertakes significant efforts to educate the public about TRI and put the information in proper perspective, it would welcome it if EPA would add more interpretive information to the TRI database and improve its educational qualities. To reiterate the main focus, substances transferred to an engineered Subtitle D landfill or  Subtitle C landfill [authorized under RCRA to accept hazardous waste] do not necessarily constitute emissions to the environment and certainly do not represent localized emissions.  At the very least unlike categories of emissions should not be aggregated.

When asked about the nature of their public outreach activities, one of the steel industry representatives noted that his company engages actively in an ongoing public dialogue with community groups and considers this to be an important aspect of its operation. The participants all have provided communities greater access to facility environmental and operational data – beyond the contents of TRI.  Additionally some companies are providing information on company website. In one representative’s experience, most misunderstandings with the community arise when data are discussed in the absence of proper context. As a result, the industry spends a lot of time clearing misconceptions about their environmental information, especially in terms of the science of any potential exposure and health risks.

Another participant added that his company also maintains ongoing relationships with communities surrounding its facilities. At one facility in particular, outreach staff hold monthly meetings with a local Community Action for a Renewed Environment (CARE) group. He knows that other facilities are engaging in similar outreach activities with groups such as the Sierra Club and River Keepers or are in the process of developing community education programs. The main focus of these meetings is to discuss the actions taken by the companies to reduce their local environmental impact. The participants expressed hope that through enhanced outreach the steel industry clarify the perception of the public.

Channels of Delivery for Environmental and Public Health Information and Preferred Formats

The representatives understood the public’s need for access to accurate informative data, and seemed to favor that data is published in a more synthesized and interpreted format. One of the participants said that he understood that some users, such as environmental advocacy groups, scientists, engineers, and others, would like to have increased access to raw data, but thought that it was important that all incoming data are vetted and not made public without some basic QA/QC. Again, he stressed the importance of proper context to avoid misconstrued conclusions. He said that synthesis reports and trend analyses are very important, and also need to be referenced carefully. If raw data are to be published, it should be accompanied by appropriate caveats and disclaimers.

Appendix
Participant Summary
Steel Industry

The information in the following table is based on information provided by the participants during their introduction and summarizes key data about the participants. As shown, the three steel industry participants are environmental managers in charge of TRI reporting, and work at large U.S. and international corporations.

Summary of Steel Industry Representatives
Company
Job Title
ArcelorMittal Manager, Environmental Information and Reporting
United States Steel Corporation General Manager, Environmental Affairs
Nucor Environmental Manager

Types of Environmental Information

The industry participants provided the following information about the types of environmental information they use:

Uses of Environmental Information

The industry representatives indicated that they use environmental information in the following ways:

 

 


Group I: Industry; Group II: Federal, State, and Local Environmental and Public Health Agencies; Group III: Environmental and Community Groups; Group IV: Media; Group V: Educators, Students, Researchers, and Librarians.


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