57
TRI Program Impacts on Reducing Toxic Chemical Releases
reduce or eliminate reporting requirements for this chemical. It has been our experience that regulated facilities will select products that do not contain TRI chemicals if
an alternative is available, even if the alternate is more costly. For example, a recent
client, a federal facility for which we are upgrading their treatment plant, is subject to
TRI reporting. In municipal treatment plants, those not subject to TRI reporting, we
typically provide methanol as the treatment chemical for removing nutrients. At the
federal facility, the client chose to use acetic acid, even though it was twice the cost
of methanol, to avoid the requirement of reporting methanol releases under TRI.
In performing pollution prevention opportunity assessments at a series of military
installations, one of the goals was to reduce the use of TRI chemicals below the
reporting threshold.
A number of other factors not directly related to TRI may also have had an effect
on release reductions (Stephan, Kraft, and Abel 2005). For example, facilities may
choose to reduce releases to forestall mandatory regulations. The same reductions
could also be implemented in anticipation of upcoming pollution reduction legislation.
Another mechanism by which companies could be inspired to reduce releases is
through cost reduction. Through internal studies, mandatory reporting under TRI,
or voluntary or mandatory pollution prevention planning, companies have found in
a number of instances that projects that result in emission reductions may also lead
to cost reductions through reduced energy use, reduced water use, reduced cost or
quantity of chemicals used, or eliminated hazardous waste-related costs. This is
discussed in more detail in Chapter 13.
In one survey, users of the TRI program were surveyed to determine the impacts
of the program on environmental performance (Stephan, Kraft, and Abel 2009). In
this survey, 74 percent of the respondents either agreed or were neutral to the assertion that the program helped identify needs and opportunities for source reduction at
the facility level. Furthermore, 73 percent of the respondents agreed or were neutral
to the assertion that the TRI program allowed facilities to set goals or demonstrate
commitment to emission reductions. The results of this survey point to factors that
can contribute to emission reductions.
According to a study conducted in 2005 that assessed trends in releases and estimated toxic risk from individual facilities between 1991 and 2002, a small group
of large facilities contributed significantly to the national trend in toxic emission
reductions. In 1999, in fact, 31 percent of the emission reductions came from 50 of
the 21,000 facilities reporting under the program. The study also determined that,
of the facilities reporting under the program, 43 percent of the facilities nationwide
reduced both releases and public health risk between 1995 and 2000. Over the same
time period, the study determined that 48 percent of facilities increased releases and
public health risk (Stephan, Kraft, and Abel 2005). Although the national trends
for toxic chemical release reduction would suggest that the TRI program has been
effective in reducing the total amount of releases nationwide, the program is not
uniform in its success. Many facilities do not seem to be affected in the same way
by the program.