Sara 313 Reporting: The Impact of Changing Emission Estimates, 1999 Environmental Conferenc Proceedings

Arun V. Someshwar & Ashok K. Jain

National Council of the Paper Industry for Air & Stream Improvement

Southern Regional Center

Ever since the first reporting year, 1987, NCASI has been assisting its member companies in filling out Form Rs by issuing annual updates to its Handbook for SARA Section 313 Form R Reporting. Over the years, pulp and paper mills have relied heavily on the use of industry-wide average estimates provided in this Handbook. The task of generating mill-specific estimates for most chemicals is generally quite cumbersome. Unfortunately, however, these estimates change from year to year. There are several reasons for these changes, mostly related to periodic generation of new data and to clarified or uncertain interpretations by both EPA and the regulated community of the reporting requirements. Thus, trends in annual releases reported by a particular mill may have little to do with any real changes in process or production-related activities and more to do with the use of changing average estimates published in the Handbook. Using three model mills, one unbleached kraft and two bleached kraft, the predicted trends in air, water and land releases of several 313 chemicals are plotted for the period between 1987 and 1996, assuming the example mills strictly use the estimates provided in the Handbook. For comparison purposes, actual average releases reported in EPA’s TRI database for chemical pulp mills are also plotted for several of these chemicals. The results of this exercise show that in spite of no changes occurring within the model mills, theoretical annual reported releases go through significant fluctuations. Indeed, quite often, industry-wide average releases reported in EPA’s TRI database appear to track the changing average estimates in the Handbook quite well, underscoring the role played by these estimates, as well as by modified or clarified EPA interpretations on the reporting requirements for some chemicals.