1. Effective Uses of TRI Information The Pollution Prevention Act at 18 2008 Toxic Release Inventory National Training Conference Arlington, VA February 12 – 14, 2008

2. The Pollution Prevention Act A State Perspective of TRI Form R Section 8 Source Reduction Data and A Comparison of Form R Section 8 Data with Pollution Prevention Data collected by NJDEP

3. The PPA Requirements Section 6607 of the Pollution Prevention Act of 1990 (PPA) requires certain information. Section 8 of the Form R includes data elements mandated by the PPA that provide information about source reduction activities and quantities for TRI chemicals managed as waste.

4. Form R Section 8 Data Quality EPA: Do you look at Section 8 data? States: Do you look at Section 8 data? Industry: Do you look at Section 8 data? I have to believe that it’s presence alone will make technical staff / consultants take note of quantities being reported.

5. Releases or Disposals Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Total other on-site disposal or other releases Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills Total other off-site disposal or other releases Form R Section 8 Data Elements

6. Form R Section 8 Data Elements (continued) Other Waste Management Activities Quantity used for energy recovery onsite Quantity used for energy recovery offsite Quantity recycled onsite Quantity recycled offsite Quantity treated onsite Quantity treated offsite

7. Going Beyond TRI NJ Release and Pollution Prevention Report (RPPR) Materials Accounting / Mass Balance (“Chemical Use”) balance within  5% margin of error Account for the fate of all chemical use for the reporting year

8. Track the use and fate of toxic chemicals Balance of Inputs & Outputs Calculate NonProduct Output (NPO) aka production-related waste Calculate Chemical “Use” Shipped as (or in) Product + Consumed + NPO NPO per Use is a Measure of Efficiency! RPPR Purpose & Goal

9. RPPR Data & P2 Trend (production-adjusted)

10. RPPR Off-Site Transfers Trend (all substances reported)

11. RPPR Off-Site Transfers Trend (supporting data table)

12. RPPR Off-Site Recycling Trend (all substances reported) 20,000,000 25,000,000 30,000,000 35,000,000 40,000,000 45,000,000 50,000,000 1997199819992000200120022003200420052006 Pounds

13. RPPR Off-Site Recycling Trend (all substances vs. metals only)

14. RPPR Off-Site Recycling Trend (supporting data table)

15. Confusion & Controversy (just maybe, ya think?!) TRI = RY 2004 Section 8.5 Quantity recycled offsite RPPR = actual annual quantity reported (TRI source: EnviroFacts EZ Query, Source Reduction & Recycling Quantities)

16. Some Thoughts / Comments Solvents data were looked at - nothing unusual or noteworthy jumped out as with metals! So, what does NJDEP do different that might add to the discussion? The next few pages demonstrate the Pollution Prevention Process-Level Data Worksheet (P2-115) that is part of the P2 planning process and the RPPR submission.

17. RPPR P2-115 P2-115 = Pollution Prevention Process-Level Data Worksheet

18. RPPR P2-115 P2-115 = Pollution Prevention Process-Level Data Worksheet

19. RPPR P2-115 P2-115 = Pollution Prevention Process-Level Data Worksheet

20. A Few Chemical Use, Recycling & Reporting Issues Electric Arc Furnaces, Alloying, Metal Fabricators, etc. Manufacturer of Stainless Steel Pipe & Tube: rolling, welding & pickling; metals in filter cakes & sludge were not reported until DEP audit Manufacturer of Super Alloys: melting Co, Cr & Ni into alloys of tight specs; selling scraps (at a price for the Ni content) for metals recovery but reporting as “Shipped in Product”

21. Questions For You Do your conversations with Industry include any such discussions? Do you have P2 (or Source Reduction) Requirements? How are they met? Do you look for Efficiency in Chemical Use? Do you care about Off-Site Recycling? If so, what you get might not tell the whole story.

22. More Questions For You Do you know that TRI exempts some Recycling? Do you care? Do you use TRI Section 8, Source Reduction & Recycling Activities Data (8.10, 8.11)? EPA’s P2 Requirements? Have you looked at the Q&A doc on these? Do you see a need for more/better guidance? It looks like I have more work to do!

23. Contact Info: Andy Opperman NJDEP andy.opperman@dep.state.nj.us 609-633-1154 http://www.state.nj.us/dep/opppc/ Want to Talk More on the Subject?