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Re: EPCRA compliance

I do a lot of benchmarking and inventory work using publicly available
waste data bases and I've known the TRI since it was a baby.  I've found
that there are a lot of simple flags for finding certain types of
misreporting.  In fact, in emissions inventory work I wind up having to
make corrections to reported data because total reported emissions, for
example, are lower than the sum of the reported emissions to individual
media.  So one type of reporting error is data that is inconsistent.  It's
a lot harder to tell if a company should be reporting a chemical and
isn't, but data from several companies with similar product slates can
identify where this type of misreporting occurs.  And there are cases, of
course, where a facility simply doesn't report at all when they clearly
fall under the requirements for reporting.  I can send you a draft of an
article on organochlorine emissions in the Great Lakes basin that explains
my corrections methodology and would be happy to talk to you about other
red flags in TRI reporting, if you're interested. 

 Kirsten Sinclair Rosselot, P.E.                   Process Profiles 
                                                      P.O. Box 8264 
 1-818-878-0454                            Calabasas, CA 91372-8264
 rosselot@netcom.com                                         U.S.A.

> Hello-
> We are doing a compliance study for EPA's Office of Enforcement and 
> Compliance Assurance.  Part of this study concerns compliance with EPCRA 
> sections 302 emergency plan notification, 304 emergency release 
> notification, 311/312 community right-to-know and 313 toxic release 
> inventory.  We need to get a realistic picture of the state of compliance 
> with each of these sections (ie. are facilities reporting/notifying and is 
> this reported info accurate).  This could include local, regional or 
> national studies or reports on the state of compliance.  We are also 
> interested in any general information on the success of EPCRA.  If you have 
> any relevant information or contacts, please let us know.
> Thanks very much for your help,
> Eric Voogt
> Kerr & Associates
> kerrasoc@ix.netcom.com
> (703)715-3030