Reduction In Tri Reporting Facilities - Andy Opperman

ACADEMIC COMMUNITY

EMERGENCY COMMUNITY RIGHT-TO-KNOW ACT Section 313 Toxic Release Inventory

2007 TRI Data Reporting Issues • For Reporting Year 2007 it was the first year – No reporting package was mailed out to facilities and – No CDX software was mailed to facilities

• Facilities were e-mailed and mailed information on how to download the reporting information • After reporting deadline we saw a reduction on the number of reporting facilities in Region 2 NJ 9%

NY 7%

PR 13%

• We decided to further look into this issue

Facilities Contacted - 169 Facility Closed 3% 4%

23%

Below Thresholds TRI MEWEB issues

25%

Forgot to Report 14%

31%

Disk or paper problems Unresolved

REGION 2 - FINDINGS 50 45 40 35 30 25 20 15 10 5 0

Facility Closed

Did not meet thresholds

TRI M EWEB certification issues Forgot to Report Late Reporter

22

66

81

169

Puerto New New Total Rico Jersey York

Submitted on time by diskette or paper and had problems Unresolved

Analysis for NJ • Total on and offsite waste management 2006 - 21.8 million pounds 2007 - 20.6 million pounds • Total Production related waste 2006 - 294.2 million pounds 2007- 257.7 million pounds If all facilities (66 facilities) that reported in 2006 and did not in 2007 had maintained their same levels of usage or emissions in 2007 they would have accounted for: – 164,625 pounds On and Offsite releases or 13% of the reduction – 5.5 million pounds of Total Production Related Waste or around 15% of the reduction

Analysis of NJ continued.. • After contacting the 66 facilities what we found was that: – 22 facilities were non-reporters – 5 facilities had problems with their TRI-Me Web submissions

• If these facilities (26 facilities) that reported in 2006 and did not in 2007 had maintained their same levels of usage or emissions in 2007 they would have accounted for only: – 12,206 pounds of On and Offsite releases or 1% of the reduction shown in NJ for 2007 – 1.3 million pounds of Total Production Related Waste or around 3.5 % of the reduction

Analysis of NJ continued.. • Based on the information we gathered we believe – Approximately 99% of the On and Offsite Transfers was captured in the 2007 PDR – Approximately 96% of the Total Production Waste was captured in the 2007 PDR.

• We continue to work with NJ to address – TRI and RPPR confusion – of the 22 facilities that did not report 18 had submitted to NJ RPPR so they thought that by submitting it they had complied with TRI

• There are still some facilities that are unresolved and we will continue to clarify distinction among the two programs

TRI-MeWeb Issues • Validate vs. Certify

→

CONFUSION

– Facilities think that when they “validate” they have submitted and do not continue with the certification process • This issue was the same with the software

• Certifier does not Certify – Technical contact did not get e-mail notification that the certifier had not certified • This has been corrected in new version

– Certifier did submit ESA (and in the preparer screen it shows that he is ready to certify) but on the certifier screen the facility does not show up in their screen – E mail being used in other CDX registrations might cancel out registration

Challenges • TRI State Data Exchange Region 2 Participants – New Jersey is the only state participating in TRI MeWeb – New York in the process of submitting their MOU – Puerto Rico and Virgin Islands do not have the capacity for the application

• TRI MeWeb rates by facility in Region 2 are: NJ 42% PR 20%

NY 30% VI 50%

• These means that over 814 facilities will require assistance in Region 2 in the next two years