Toxics Release Inventory (TRI)

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What is TRI?

The Toxics Release Inventory (TRI) was established as a part of the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986. The initial purpose of the program was for chemical manufacturing facilities to report “releases” of certain listed substances to the air, land and/or water on an annual basis to the Environmental Protection Agency (EPA). The annual reporting of releases is accomplished with the submittal of Form R’s to the EPA by those facilities in the TRI program.

In 1997, the EPA expanded the TRI program to cover seven additional industries, including metal and certain coal mining operations. Beginning January 1, 1998, these additional industries started tracking releases of more than 600 designated chemicals and compounds. Releases were reported for calendar year 2005 by July 1, 2006. The information contained in the 2006 Form R reports is similar to that reported in previous years but overall the releases are higher due to improving economic conditions that translated into increased production. Information on prior TRI releases has been made available by the Colorado Mining Association (CMA) and member companies. CMA, along with the coal and metal mines reporting under TRI, have shared information with the public beyond what is provided by EPA because the industry believes communities should better understand the TRI program. As an example of that commitment, the mining industry works closely with local governments by providing them with site maps of facilities, encouraging local governments to visit the sites, and joining with nearby communities to coordinate activities of mutual interest.

Reportable materials from the Colorado mining industry include metals and compounds containing arsenic, barium, chromium, cobalt, copper, cyanide, dioxins, lead, manganese, mercury, lead, nickel, nitrate, selenium, zinc and vanadium. The vast majority (e.g., >99%) of the reported releases for the mining industry are naturally occurring metals in rock, with a minuscule percentage (e.g., dioxins, mercury, etc.) being associated with fuel combustion by-products, volatilization, or other authorized uses of materials containing TRI chemicals or compounds. The naturally occurring substances and the other chemical compounds that are manufactured, processed or otherwise used above established thresholds must be reported under TRI. Under the TRI program, it is assumed that all the naturally occurring chemicals and compounds in rock are released during the year of placement for simplicity. Observation and experience indicate that rock typically requires decades, centuries, or millennia to weather into the elemental constituents that TRI assumes occurs in only a year. The TRI program does not take into consideration the rigorous environmental permitting and management requirements for rock and coal ash. As such, TRI provides no meaningful indication of the risk to human health or environmental exposure to TRI chemicals in naturally occurring rock at mining operations.

Should the information available in these reports be of concern to my community?

No. TRI is merely a reporting program. It is not intended to assess risk of exposure. The EPA simply publishes the TRI data annually by state, company, facility, sector, and chemical without any explanation of risk or exposure. Based on these reports, industry sectors, companies and individual facilities are each ranked solely by the volume of materials reported and not on the risk of public exposure to these chemicals and compounds.

Furthermore, most of the reported materials never leave the controlled environment of the mine site and many of the reported materials remain contained in the minerals or rock matrix in which they occur in nature. EPA and the TRI program do not attempt to make any distinction between substances that are an integral component of the rock versus those that may be more mobile. Based on all of these factors, it is clear that the TRI program does not address the presence or absence of risk to the public for the vast majority of releases reported at mining operations for naturally occurring metals in rock.

Implementing the Community Right-to-Know

Background:

• As of January 1, 1998, metal and certain coal mining operations began tracking the chemicals and compounds to be reported to EPA on an annual basis under the TRI program. On July 1 of each year, the TRI reports are submitted to the EPA for those chemicals and compounds that exceeded established thresholds. The reported “releases” are categorized according to the receptor media - air, water or land.
• Reporting under the TRI program is triggered if more than 25,000 pounds of listed chemicals or compounds are manufactured or processed, with a lower threshold of 10,000 pounds for those that are otherwise used.
• Thresholds for certain persistent bioaccumulative toxic (PBT) chemicals were substantially lowered by EPA for reporting year 2000 and again in 2001. Dioxin was lowered to 0.1 gram, mercury to 10 pounds and lead to 100 pounds. Due to these changes to the reporting thresholds, the TRI releases reported by some facilities increased significantly in 2001.
• Nearly 650 chemicals/compounds are presently on the TRI list.
• Reported releases decreased dramatically for some hard rock mining operations in 2002 due to Federal District Court decisions clarifying the applicability of the program to naturally occurring TRI chemicals in excavated rock. Native rock moved by mining operations with TRI chemical concentrations less than 1% (excepting lead and mercury) are now eligible for the de minimis exemption previously established by EPA.
• The reporting is designed to provide local communities with information about the volume of materials being used and regulated at facilities near them. The reporting regulations now cover more than 23,000 industrial and federal facilities.
• The raw data neither identifies nor accounts for required environmental management controls designed and implemented to reduce health and environmental risks. These environmental management controls, applicable to mining operations through myriad environmental protection statues, use criteria that are based on protecting the health of the environment and the public. The TRI reporting process does not provide public or environmental exposure information or risk assessments, which are essential in helping to inform and educate the public about health and/or environmental risks associated with these materials. The raw data reported to the EPA by the Colorado mining industry describes large volumes of material containing very low concentrations of naturally-occurring minerals that are listed “reportable chemicals” in the rock that is mined - they are often called “trace elements,” for good reason.
  

Colorado Mining Industry Positions:

• The Colorado mining industry takes its many reporting responsibilities seriously. It believes that local residents have a right to know what materials are being managed on site. The industry has a long record of working openly and cooperatively with local communities on environmental issues.
• The Colorado mining industry is committed to safe work environments and safe communities, and has implemented modern, efficient and safe material management practices. The industry has a very good record for safety and compliance with environmental, health and safety requirements. Presidents and governors have acknowledged Colorado mines’ environmental stewardship through numerous reclamation and environmental awards.
• The Colorado mining industry operates safe, environmentally responsible and community-oriented businesses, which are overseen and governed by local, state and federal regulations.
• The Colorado mining industry is fully committed to safe environmental practices. The industry routinely uses environmental protection measures such as sophisticated containment and monitoring systems; detailed engineering designs and controls; best management practices; and water conservation measures involving reuse and recycling.
• The Colorado mining industry manages operations to fully train and protect workers.
• CMA and the Colorado Mining Industry worked closely with the Colorado Department of Public Health and Environment (CDPHE) in developing a Pollution Prevention (P2) Program and acceptable Code of Practices (Code) for the mining industry. The P2 Code has been endorsed by the CDPHE and recognized by the EPA through a 2003 Friend of EPA Award. Several CMA member companies have certified under the P2 Code and received awards with special recognition from CMA along with an endorsement for consideration by the CDPHE in its Environmental Leadership Program.
• Reclamation and closure planning, design, implementation, reporting, and bonding are an integral part of modern mining in Colorado. The creation of stable land forms that are compatible with the surrounding land uses and environmental values are important objectives of the reclamation and closure activities.
• Responsible Colorado mining companies regularly reach out to local communities to address public concerns. The industry routinely provides information and education about mining industry practices; the TRI reporting program is just another way the industry is able to do this.
• Responsible mining provides society with valuable metals and energy fuels necessary for everyday life. For example, coal is used to produce more than 72 per cent of the electricity generated in Colorado, and many precious metals are crucially important in the fields of medicine and health, electronics, communications equipment, safety devices, optics, aviation, security and other modern technologies.

What will be reported?

Colorado is home to mines producing coal, gold, silver and molybdenum. During the mining process, mining operations move hundreds of millions of pounds of rock to access the valuable mineral deposits. The industry must account for the reportable, naturally occurring metals found in the rock as well as other chemicals used in the process of removing the valuable minerals if certain thresholds are triggered.

The chemicals and compounds properly managed and reported by the Colorado mining industry include the following:

The materials containing these chemicals and compounds are all used, controlled and/or managed under federal, state and local permits and regulations designed to protect public health and the environment. Some of the chemicals and compounds occur in very small amounts and are totally (e.g., dioxin) or partially (e.g., mercury) attributable to the combustion of diesel fuel in various types of equipment (e.g., dump trucks, bulldozers, etc).

How are these materials managed?

Reportable TRI “releases” represent emissions, discharges or transfers of materials containing listed chemicals and compounds to the land, water and/or air. It must be noted that while the Colorado mining industry will typically report large volumes, the materials and substances at mines are usually in very low concentrations. As such, there is minimal risk of exposure that would adversely affect human health or the environment. The following explains the ways in which the mining industry manages its reportable releases.

• Air
  Trace amounts of TRI chemicals are created (e.g., dioxin) or liberated (e.g., mercury, lead, etc.) during the combustion of diesel or other fuel sources (e.g., used oil, propane, etc.). If the release exceeds 0.1 gram of dioxin, 10 pounds of mercury, or 100 pounds of lead on an annual basis, the respective thresholds are triggered and reporting is required under TRI. Heavy equipment, furnaces, heaters, boilers, generators and other stationary sources are also potential sources of combustion products that require reporting if TRI thresholds are exceeded. TRI chemicals or compounds in dust produced by a mining operation may also require reporting. The dust particles are controlled with suppressants and other effective measures to remain within safe limits and are monitored. Air emissions are monitored by the mine operators and regulated through permits issued by the Colorado Air Pollution Control Division to protect public health and the environment.
• Water
  The mining industry must meet water quality standards established by the Colorado Water Quality Control Division before water can be released from a mining operation. These standards ensure that the water leaving the mine protects public health and the environment. Varying degrees of treatment and management practices are implemented to reduce constituent concentrations and assure that these levels are within prescribed limits. Many mining operations recycle water used in mineral preparation and processing and direct storm water around the active mine areas.
• Land
  Most of the TRI chemicals and compounds reported by the mining industry originate from the movement of native rock or coal combustion products (coal ash) and remain on the mine site. These materials are safely managed, monitored and if necessary, treated. Carefully planned and executed engineering controls are implemented, including reclamation, to ensure that the public health and the environment are protected under permits issued by the Colorado Division of Minerals and Geology and, if on federal land, agencies such as the Bureau of Land Management and the U.S. Forest Service. Reclamation of disturbed lands is an integral component of modern mining operations.

Questions & Answers

• What is inventory reporting or TRI?
  Congress created inventory reporting as a part of the Emergency Planning and Community Right-to-Know Act of 1986. The reports make up a publicly available database of information on more than 600 materials and substances. The Environmental Protection Agency publishes this information annually by state, facility, sector, and chemical. The EPA notes that reportable materials and substances vary widely in their actual risk to the public health based on volume, degree of toxicity, and type of release. The available data only reflect the volumes of materials released and not their actual or potential impact on public health or the environment.
• What purpose does the reporting serve?
  The reporting is designed to help communities identify the TRI chemicals and compounds “released” to air, water, and/or land at a regulated facility.
• What is a release?
  A “release” is any transfer, emission, or discharge of a listed chemical or compound to air, water, and/or land.
• What types of releases must be reported?
  Facilities are required to report all releases or transfers of listed materials and substances that exceed prescribed thresholds established by the EPA for air, water, and/or land. Under the reporting requirements, land releases include rock or other materials that are moved, deposited, or managed on site once thresholds are triggered.
• Why are there differences in the reported data from individual mines?
  As a result of the nature of mining, different mines will report different numbers. Whether a mining operation is being conducted on the surface or underground, the types of ore bodies being mined, and processing techniques being implemented are all factors that will result in different reported volumes.
• Are all mining operations required to report under the Program?
  No. Depending on the activity at the mine, some mines are not required to report. Inactive mines may not need to report because they do not trigger thresholds for the activities being conducted. Also, coal mines that use coal ash to enhance reclamation efforts are required to provide data on the reportable metals found in the coal ash, while coal mines not using coal ash have certain exemptions and are not required to report. Finally, the number of people employed at a mine, and the concentration levels of reportable substances affect whether or not a mine must report.
• What are the health risks posed to communities as a result of these releases?
  Mining operations are regulated so that both human health and the environment are protected. The reports on released substances do not address risk. Determination of risk depends on release and environmental conditions, which are monitored and managed by the mining industry. By and large, the Colorado mining industry reports large volumes of materials and substances, which are in very low concentrations with minimal, if any, risk to the public health or the environment.
• What does it mean to say that mines “manage” their releases?
  All of Colorado’s mines must obtain permits under federal, state and local laws and conduct their operations in compliance with these permits. Colorado’s mines apply technology effectively to protect human health and the environment and use monitoring systems to ensure that hydrologic and surface conditions are suitable for the safe and effective management of the materials and substances at the mines.
• What are waste rock and tailing?
  The bulk of materials reported are trace metals contained in the waste rock and tailing. Waste rock (also referred separately from the reporting program as “overburden”) is the unmineralized rock surrounding the ore body (which contains valuable minerals). During extraction of the ore body, waste rock is separated from the valuable ore material to be processed, and placed in engineered and managed areas that are reclaimed, often for continued wildlife use, after mining. During operations, tailing is comprised of a rock and water mixture that comes from the mining process that is placed in engineered containment facilities and which are designed and operated to be isolated from the surrounding environment. The tailing deposit is also reclaimed after cessation of mining.
• What are the mines doing with their used materials and substances?
  Colorado mines recycle their waste products to the greatest extent practicable. Materials like used oil and anti-freeze are recycled and most mines have implemented pollution prevention measures to reduce or eliminate hazardous wastes. Waste rock is moved so that the mineralized ore can be placed into engineered facilities that are graded concurrently with the on-going mining as a part of reclamation. Mill tailing is managed on site and monitored to ensure that reportable materials in the crushed rock are properly managed. More concentrated materials are stored in holding ponds, which are lined with clay or synthetic materials, and managed to prevent seepage into ground water. Still other materials used in the mining process are recycled until operations cease. The entire mine site is reclaimed and returned to a productive use after the mine closes.
• Does my community need to be concerned about used materials and substances?
  Everyone in their community should be interested in how used materials and substances are managed and the effective management practices in place at mine sites. All materials are subject to permit requirements set forth by the EPA, the Colorado Department of Public Health and Environment and the Colorado Division of Minerals and Geology. The mines welcome opportunities to answer any questions about their operations.
• Water is a big component of mining operations. Is there any chance that water can become contaminated by these materials?
  Mining operations are required under federal and state laws to obtain water quality permits for discharges. In Colorado, the water quality permit program is administered by the State’s Water Quality Control Division and the Division of Minerals and Geology. Moreover, mines use monitoring wells to ensure compliance and recycling systems to capture, reuse and where necessary, treat water that may be impacted by their operations.
• How do used mining materials and substances affect Colorado wildlife?
  As required by state and federal laws, members of the Colorado mining industry are required to design and implement environmental protection measures that offer protection to fish and other wildlife. Many Colorado mines have returned previously mined land to prime wildlife habitat. Operating mine sites often become wildlife sanctuaries because of the excellent reclaimed habitats created and the protection afforded from hunting.
• Where can I find reliable sources of information on what is being reported?
  Ask the mining operations in your community. They fully disclose the metals and chemicals they report and are happy to answer any questions you may have. Additionally, the Colorado Department of Public Health and Environment and the Colorado Division of Minerals and Geology will also answer questions on reportable materials.
  
• Why is there such a large volume of materials being reported?
  Metal and specific coal mining operations are required to report the materials and substances used in the mining process, as well as, reporting the volume of metals that already exist naturally in rock if thresholds are triggered elsewhere in the operation. Again, the Colorado mining industry is expected to report large volumes of materials that are low in toxicity.
• Mining industry numbers are significant. Does this make the industry the worst “polluter” in the state?
  There is a misperception that those industries reporting the largest numbers are the top “polluters.” It is important to understand that mines move and handle massive volumes of rock and earth that have naturally occurring metal compounds. The materials present little health risk or potential impact on water, air or land.
• Can the mining industry reduce its releases?
  The mining industry has made significant environmental protection advancements over the years. However, advancements in mining technologies have not limited the amount of material that must be moved and handled to access the ore, or the fact that the mineral of value occurs as a very small fraction of the ore. Due to the nature of the mining process, there are fewer and fewer opportunities to reduce the volumes of rock moved by the mining industry. Mining companies have, since the enactment of the Emergency Planning and Community Right-to-Know Act, reduced the use of manufactured materials containing hazardous substances as part of their pollution prevention programs. Colorado’s mining companies will continue to develop and implement similar programs where feasible.

Industry Snapshot

Production:

• Coal - Colorado coal is among the highest quality and cleanest burning in the country due to its low sulfur and high energy content. Given this low sulfur content, Colorado coal is preferred by utility companies because it helps them meet stringent air quality standards. Coal is critical for generating electricity and is used to supply 72 percent of Colorado’s electricity needs. Colorado’s coal mines produced 36 million tons of clean burning coal in 2006.
• Gold - Gold is used in dentistry, medicine and critical medical applications; jewelry and arts; in medallions and coins; sold as ingots for its value; for scientific, and electronic instruments, such as computers and as an electrolyte in the electroplating industry. Gold is also critical in the effective use of automotive airbags and as a radiation shield for the aerospace industry, to protect individuals, such as fire fighters, against heat, and in architecture. The major gold producer in Colorado is the Cripple Creek & Victor Gold Mining Company’s Cresson Mine, which produces nearly 300,000 ounces of gold a year.
• Molybdenum - Molybdenum is used in steel alloys; as a catalyst to remove sulfur from petroleum, a lubricant, as a corrosion inhibitor, as a pigment and as a flame and smoke suppressant. Molybdenum is also critical in the production of automotive airbags. The Henderson Mine near Empire, Colorado is the largest primary producer of molybdenum in the world, producing about 8.9 million tons of molybdenite in 2006.
• Copper - Copper is used in electric cables and wires, switches, plumbing, heating, roofing and building construction; chemical and pharmaceutical machinery, alloys; alloy castings; and electroplated protective coatings and undercoats for nickel, chromium, etc. Copper is not produced in Colorado, but is found naturally in small amounts at many mine sites.
• Lead - Lead is used in lead batteries, fuel tanks, solders, and bearings; electrical and electronic applications; TV tubes and glass, construction, communications and protective coatings; in soundproofing, and ammunition. The United States is the largest producer and consumer of lead metal. No lead mines are producing in Colorado today, but small amounts of lead are found naturally at most all mine sites.
• Zinc - Zinc is used as a protective coating on steel, as a die casting, as an alloying metal with copper to make brass, and as chemical compounds in rubber and paints; as sheet zinc and for galvanizing iron; electroplating; metal spraying; automotive parts; electrical fuses; anodes; dry cell batteries; nutrition; chemicals; roof gutters; engravers’ plates; cable wrappings; organ pipes, and pennies. No zinc is produced in Colorado today, but the metal is found naturally in many of Colorado’s mineralized areas.

Economic Impacts:

Colorado’s modern mining industry extracts a wide variety of minerals from the earth, valued at more than $2.5 billion. As an extension of the significant amount of minerals produced, Colorado also supports a thriving aggregates industry. In its 2006 report on the mineral resource industry, the Colorado Geological Survey reported that the mineraland mineral fuel industries produced materials valued at nearly $3 billion.

When both the direct and indirect contributions of mining are considered, the value of mining’s contribution climbs to nearly $7.7 billion, according to a 1997 study conducted by the Western Economic Analysis Center. Additionally, the industry as a whole offers the highest paid positions of any industrial sector in rural areas.

Unique Facts About Colorado’s Mining Industry:

• Colorado is home to the largest molybdenum mine in the world, which produced 8.9 million tons molybdenite in 2006 with a direct value of more than $900 million.
• Colorado coal producers mined 36 million tons of coal valued at $884 million in 2006. Coal is the fuel used to generate 72 percent of the electricity consumed in Colorado.
• The most productive gold mine in Colorado’s modern history produces nearly 300,000 ounces of gold annually.
• Colorado is home to the only commercial diamond mine to have been located in the United States since the turn of the century.
• The marble used in the construction of the Tomb of the Unknown Soldier came from a quarry in Colorado.
• Colorado’s overall mineral production has a direct value of $2.5 billion.

For more information about Mining in Colorado, click here.

Material Health Risk Profile

The Material Health Risk Profiles are compiled from EPA and industry studies, as well as from information available in EPA chemical databases.

• Read more about material health risks, click here.
  

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