Pulse Point Newsletter for September 30, 2000
Published by Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
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MEXICO REPORTS RELEASES AND TRANSFERS OF POLLUTANTS FOR THE FIRST TIME

By Enrique Medina, MS, CIH

Need to find out how much hazardous waste is generated in Mexico or the type of industry located in a particular municipality? Now there is a source for this information available to the public. It is called the Pollution Release and Transfer Registry (PRTR).  Here are examples of some facts:

Mexico's Secretariat of Environment, Natural Resources and Fisheries (SEMARNAP for its Spanish acronym) issued its first National Report of Pollution Release and Transfer Registry (PRTR) for the 1997-1998 period.

The PRTR is part of the National Environmental Information System established as part of the Right-to-Know  clause in the 1996 reforms to the General Law of Ecological Equilibrium and Environmental Protection (LGEEPA). SEMARNAP was mandated to issue an annual environmental report to the nation. The PRTR also addresses a number of international commitments made by Mexico, including the 1992 Rio Accord, Agenda XXI, NAFTA's Border XXI and obligations to the Organization for Economic Cooperation and Development.

The PRTR (known in Spanish as RETC) is Mexico's version of the Toxic Release Inventory (TRI) program developed in the United States, and the Canadian National Pollutant Release Inventory (NPRI). It is designed to provide the public with information on generation, emissions and discharges of listed contaminants into the air, water, and as hazardous waste. It works by compiling information supplied by generators as part of the Unified Environmental License and the annual Operating Permit (COA). These are required of all industry, hazardous waste treatment and disposal facilities, water supply and wastewater treatment plants, and other federally regulated activities.

A list of 178 pollutant substances was developed from an initial grouping of 409 substances found in a number of domestic regulations and international programs (including the TRI and NPRI), substances listed in various Official Mexican Norms (NOMs), the highly hazardous activities list, as well as the list of regulated pesticides.

The information used to develop the PRTR comes from a number of sources. Regulated facilities have been submitting environmental license applications and annual permits for several years. The annual permit application was due each February and included an emissions inventory as well as concentrations of wastewater discharge streams. Generators also file reports on hazardous waste shipped for treatment of disposal on a semi-annual basis, and facilities discharging into federal bodies of water submit periodic test results of wastewater discharge quality to the National Water Commission, which provided them for this report.

Integrating this information to ensure an acceptable level of quality and integrity was a major obstacle. A total of 2653 individual facilities from all over Mexico submitted reports, of which only 1129 or 42% were included in the PRTR database, after reviewing them for completeness, format compatibility and other criteria. The selection process is explained in the SEMARNAP report.

One significant omission involves state-regulated facilities, which represent a large percentage of all sources, especially in northern border states. These are mostly absent in the PRTR for a number of reasons, including incompatibility between federal and the state reporting forms, as well as lack of resources in some states to compile the data and submit it to SEMARNAP in a timely manner.

Unlike the TRI and NPRI, Mexico's PRTR does not report pollutant data by facility. Instead, SEMARNAP developed statistics for municipalities, states and regions, further skewing the results in favor of states with a large percentage of reporting federal sources, or those with better established state reporting mechanisms, such as the Mexico City Metropolitan Area, the states of Nuevo León, Jalisco, and tiny Tabasco, which reported a large number of Pemex oil and petrochemical facilities.

The PRTR data was used to generate 32 maps of Mexico, which graphically illustrate the results. One map shows the states that reported COA that were included in the database. Eleven maps show the location by state of federal sources by industrial sector, and 11 others by municipality. There are 7 air emission maps covering the 5 metropolitan air districts in Mexico with emissions data by total emissions, type of source (industry, services and transportation), and one each for emissions of particulates, sulfur dioxide, carbon monoxide, nitrogen oxides and hydrocarbons. The final two maps show wastewater discharge volumes by state, and hazardous waste generation by state, using data from a 1994 report on hazardous waste minimization and management. The report lists the sources included in the report by industry type, municipality and state.

Some of the major facilities not included in the list of reporting sources include:

Certain types of information available in other reports, such as the TRI are not found in the PRTR. Most notably, there is no data on the amount of any one of the listed contaminants released into the air, water or as hazardous waste, or an inventory of releases and transfers by facility, municipality, state or region.

Notwithstanding the large gaps in reporting and the consolidation of facility data into geographical and sector information, the PRTR report does contain some interesting estimates, such as:

This first PRTR report is long on explanations and short on factual data. However, it marks a major milestone in terms of providing environmental information to the public. The National Institute of Ecology (INE), the agency responsible for producing this report, is providing technical support grants to states to assist in developing their own PRTRs with the goal of having a compatible data gathering and reporting system. This effort and other outreach activities targeted to employer groups and industry is designed to improve the quality of the PRTR to make it an effective public policy and planning tool in the future.

The PRTR report, contaminant lists and maps can be viewed and downloaded from the INE web site of at: www.ine.gob.mx/dggia/retc/index.html.

If you have questions about how the new environmental impact regulations may affect your current or future projects, please contact us at (619) 297-1469 or send us an email at emedina@pulse-point.com.

PP

Alliance Consulting International
Partners in Environmental and Occupational Health and Safety
3361 28th St.
San Diego, California 92104
(619)297-1469
(fax (619)297-1023
emedina@pulse-point.com
www.pulse-point.com/alliance

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