Why start TRI Month talking about waste reporting? Because waste is the most overlooked of all the emissions media. Most EH&S professionals are more worried about their air emissions reporting, then water releases (in that order) – and consequently, waste tracking and credits are where we see the most mistakes being made.
While people tend to overlook waste, it is actually an essential part of proper TRI Air Emission reporting, as you should be claiming waste credits for the chemicals contained and treated as waste against your air emissions. In this way, waste and air emissions are part of the same package and shouldn’t be treated separately.
This short article will provide some essential pointers for making sure you’re handling waste properly in your TRI calculations.
Waste Needs Year-Round Attention
The most common environmental data management mistake that TRI reporters make in regards to waste is managing waste records at fixed times of the year, and always in isolation. For example, many EHS professionals do not review waste records until it is time for annual/biennial waste reporting or TRI, or just a monthly air emission report. But waste is being generated every day on site, and the recordkeeping should be a reflection of this. That doesn’t mean daily data review is required for accurate reports (though if you have the ability to review daily, it will improve your overall waste management), but you shouldn’t postpone waste record management until the end of the business quarter.
What helps most EHS departments reframe waste is to remember that all your monthly air emissions, air permits, and annual emissions inventories can hinge on waste. That means it must be treated with the same respect and eye for details that air emission tracking gets.
Use the Best Available Quantification Methods
One of the top reasons why waste credits get inaccurately calculated is because all those waste drums you send out for treatment can be “black boxes” for information. Most drums of waste are mixed batches of different chemicals, and materials get dumped into these drums without any recordkeeping as to which chemicals are being added.
This results in a number of difficult questions:
- Which TRI chemicals are in your waste?
- How much of those TRI chemicals are in the waste drums?
- What do you do if there is mixed waste in the drums that cannot be used for TRI purposes (i.e. dirty rags)?
Without a good system for waste management in place, it can be impossible to be certain in your waste credit calculations. ERA’s TRI experts have developed a strong set of methodologies you can use for your drums of waste when you don’t have a reliable waste profile or lab analysis– we’ve build a powerful Waste Management Software that does all the calculations for you. ERA software can also be used if you do have a waste profile but need to determine how to speciate emissions without knowing exactly what quantity of TRI chemicals are in the drum.
If you are attempting to do these complex waste calculations by hand, you’ll need:
- Either a lab analysis of a waste drum, from which you can begin allocation calculation;
- Or detailed usage records from the processes contributing to the waste, from which you can derive a reasonable waste profile from the materials added to waste, then distributed according to usage ratio.
- You will also want to know recovery rate of your process.
With this information you can begin to allocate waste by %solids, %VOC, %HAP etc. This information, once determined, can be used to speciate your emissions.
The best practice for waste calculations is to ensure you are taking accurate records whenever possible, and supplementing those records with lab analysis. If you don’t have lab analysis data, you should be taking detailed usage records and know which processes contribute to which waste streams.
Contact ERA Environmental Management Solutions to learn more about our waste calculation methodologies and how you can apply them for your TRI reporting.
Why Waste is Essential
Waste credits are often miscalculated due to gaps in environmental data management and the complexity of waste calculations. However, mismanaging waste credits can have an enormous effect on your final TRI report. If you over-estimate waste credits, you’ll under report on your air emissions, which can result in audits and even fines. Under-estimating waste credits typically results in over-reporting of air emissions, which is a common red flag for EPA auditors. This is why having a robust waste management system and waste reporting tool is vital.
The best practice approach to avoiding waste credit errors and improving overall TRI accuracy, is to implement a system that can calculate waste credits for you (rather than attempting them by hand). This system should be able to:
- Calculate waste credits from drums with unknown waste profiles
- Calculate waste credits based on lab analysis data and sampling
- Calculate waste generation and recovery
- Differentiate between non-waste items (like rags or water) in your waste drums
- Perform all these waste calculations in a fraction of the time it takes you to do manually
The ERA Waste Module was specifically designed by proven environmental engineers to meet all these needs and more.
See the ERA System in action by getting your free, personalized demo today.
This Blog was Co-Authored By:
June 3, 2016