TOXIC RELEASE INVENTORY (TRI). CUSTOMIZED ENVIRONMENTAL TRAINING. WELCOME. INSTRUCTOR. Insert Instructor Name Here. OBJECTIVES. Discuss Who Must Report Toxic Chemical Releases. Discuss What Must Be Reported. Discuss the Types of Chemicals That Are to be Reported.
Insert Instructor Name Here
The goal of this course is to provide supervisors with the tools needed to prepare a Toxic Chemical Release Inventory (TRI). It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you in preparing this annual requirement and help your facility personnel better understand the EPCRA 313 process.
The course is not intended to provide every answer to TRI reporting. This course provides only the framework for TRI. This course does provide sources of additional help at the end of the course. For complex questions beyond the scope of this course, it is recommended that additional training or outside assistance be solicited.
Section 313 requires businesses to report the more than 600 designated toxic chemicals released to the environment.EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
Facility owners/operators must report accidental releases of, “extremely hazardous substances” and CERCLA “hazardous substances” to state and local response officials (Section 304); and
Facility owners/operators must make Material Safety Data Sheets (MSDSs) available to officials and must also report, to local and state officials, inventories (including locations) of chemicals on their premises for which MSDSs exist (Sections 311 and 312).SOME OF THE RESPONSIBILITIES UNDER EPCRA
The purpose of this reporting requirement is to inform government officials and the public about releases of toxic chemicals into the environment.
Section 313 requires facilities to report releases to air, water, and land. The reports must be sent to the U. S. EPA and to designated state agencies. Reports are due by July 1 each year.
Those who fail to report as required are subject to civil penalties of up to $27,500 a day.SECTION313
1. It is included in a covered Standard Industrial Classification (SIC) code A facility must report to TRI if it conducts manufacturing operations within SIC codes 20 through 39 and or if it is in one of the following industries: metal mining, coal mining, electrical utilities, RCRA Subtitle C hazardous waste treatment and disposal facilities, chemical distributors, petroleum terminals, and solvent recovery servicesWHO MUST REPORT
3. It manufactures, imports, processes, or otherwise uses any of the toxic chemicals listed by EPA in amounts greater than the “threshold” quantities specified below. At present, there are more than 650 chemicals and chemical categories are covered. The list is subject to change by the EPA Administrator who can add or delete chemicals from the listWHO MUST REPORT
Basic information identifying the facility
Name and telephone number of a contact person
Environmental permits held
Amounts of each listed chemical released to the environment at the facility
Amounts of each chemical sent from the facility to other locations for recycling, energy recovery, treatment, or disposal
Amounts of each chemical recycled, burned for energy recovery, or treated at the facilityWHAT MUST BE REPORTED TO TRI
Types of activities conducted at the facility involving the toxic chemical, and
Source reduction activities.WHAT MUST BE REPORTED TO TRI
If you manufacture or import any of the listed toxic chemicals, the threshold quantity will be:
25,000 pounds over the calendar year.
If you process any of the listed toxic chemicals, the threshold quantity will be:
25,000 pounds over the calendar year.
If you otherwise use any of the listed toxic chemicals (without incorporating it into any product or producing it at the facility), the threshold quantity is:
10,000 pounds over the calendar year.THRESHOLDS
Examples of processing include:
– Adding a solvent to dilute when making a paint, coating, or other mixture;
– Using a chemical as reactant in the manufacture of a
pesticide (e.g., using chemical A to make chemical B).PROCESS
Using a metal cutting fluid that contains diethanolamine;
Using a heat transfer fluid containing biphenyl;
Using trichloroethylene to degrease tools;
Using chlorine in waste water treatment;
Using Freon 113 as a refrigerant to cool process streams.OTHERWISE USE
The reporting thresholds apply to toxic chemicals known by the owner or operator to be used in amounts above the thresholds. Section 313 requires suppliers of mixtures and trade name products to notify customers of the presence of Section 313 listed toxic chemicals in their products above certain de minimis concentrations.FACILITY
This list grows each year.
How EPA lists some of the Toxic Release Chemicals:
CAS Number Chemical De Minimis %
7664-41-7 Ammonia 1.0
7440-38-2 Arsenic .1
7440-39-3 Barium 1.0
7440-47-3 Chromium 1.0
7440-48-4 Cobalt .1
7440-50-8 Copper 1.0CHEMICALS
Zinc compounds Styrene
Nitrate compounds Hydrochloric acid
Methanol Phosphoric acid
Ammonia Methyl ethyl ketone
Manganese compounds Chromium compounds
Toluene Carbon disulfide
Xylene (mixed isomers) Dichloromethane
n-Hexane Glycol ethers
Copper compounds Lead compounds
These chemicals accounted for 2.376 billion pounds.CHEMICALS
The metal compounds listed unless otherwise specified, are defined as including any unique chemical substance that contains the named metal (e.g., antimony, nickel, etc.) as part of that chemical\'s structure.
Toxic chemical categories are subject to the 1 percent de minimis concentration unless the substance involved meets the definition of an OSHA carcinogen in which case the 0.1 percent de minimis concentration applies.CHEMICAL CATEGORIES
1. Aluminum (fume or dust) - Only if in a fume or dust.
2. Aluminum oxide (fibrous forms) - Only if in a fibrous form.
3. Ammonia – Only 10 percent of aqueous forms. 100 Percent of anhydous forms.
4. Asbestos (friable) - Only if it is a friable form.CHEMICAL QUALIFIERS
6. Phosphorus (yellow or white) - Only if it is a yellow or white.
7. Sulfuric acid (acid aerosols) - Only if it is an aerosol form as defined.
8. Vanadium (fume or dust) - Only if it is in a fume or dust form.
9. Zinc (fume or dust) - Only if it is in a fume or dust form.CHEMICAL QUALIFIERS
1. Isopropyl alcohol (manufacturing - strong acid process, no supplier notification.)
The qualifier is “Only if it is being manufactured by the strong acid process.”
2. Saccharin (manufacturing, no supplier notification)
The qualifier is “Only if it is being manufactured.”
Manufactures of these chemicals do not need to notify their customers that these are reportable EPCRA section 313 chemicals.CHEMICAL QUALIFIERS
The following are the major exemptions:
In determining whether the amount of a toxic chemical used at your facility exceeds the EPA reporting threshold, you are not required to count the amount of chemical present in a mixture if
its concentration is less than 1 percent of the mixture, or
its concentration is less than 0.1 percent of the mixture when the chemical is defined by the Occupational Safety and Health Administration (OSHA) as carcinogenic.DE MINIMIS
(1) which is formed to a specific shape or design during manufacture;
(2) which has end use functions dependent in whole or in part upon its shape or design during end use; and
(3) which does not release a toxic chemical under normal conditions of processing or use of that item at the facility or establishments.ARTICLE
As a structural component of the facility;
In routine janitorial or facility grounds maintenance;
In foods, drugs, cosmetics, or other items for personal use, including supplies of such items (for example, in a facility-operated cafeteria);
In motor vehicle maintenance (including motor fuel);
In process water and non-contact cooling water as drawn from the environment or from municipal sources, or in air used either as compressed air or as part of combustion.OTHER EXEMPTIONS
The owner of a covered facility is not subject to reporting under Section 313 if the owner’s only interest in the facility is ownership of the real estate upon which the facility is operated. However, the operator of the facility must report if the criteria are met.OWNERS OF LEASED PROPERTY
EPA has worksheets, or you can make up your own similar to the ones on the following slides that will assist you in determining whether your facility has exceeded any of the reporting thresholds.
Worksheets are not required and the completed worksheet(s) should not accompany Form R reports submitted to EPA and the State.DETERMINING THRESHOLDS
Under Section 313, covered facilities are required to take into account in their reports all toxic chemicals entering each environmental medium (e.g., “routine” and “accidental” releases.)
Reporting under Section 313 includes the total amount of the toxic chemicals, both routine, operational and accidental releases.RELEASES
Fugitive emissions include equipment leaks, evaporative losses from surface impoundments and spills, and releases from building ventilation systems.RELEASES
Releases to water include discharges to streams, rivers, lakes, oceans, and other bodies of water. This includes releases from contained sources, such as industrial process outflow pipes or open trenches. Releases due to runoff, including stormwater runoff, are also reportable to TRI.RELEASES
On-site releases to land occur within the boundaries of the reporting facility.
Releases to land include disposal of toxic chemicals in landfills, land treatment/application farming, surface impoundments, and other land disposal methods or releases to land.
Facilities separately report amounts released to RCRA subtitle C landfills from amounts released to other on-site landfills.RELEASES
One set of reports, the "unsanitized" version, should provide the actual identity of the EPCRA Section 313 chemical.
The other set of reports the "sanitized" version, should provide only a generic identity of the EPCRA Section 313 chemical. If EPA deems the trade secret substantiation form valid, only the sanitized set of forms will be made available to the public.TRADE SECRETS
Required to Report if:
Facility manufactures 100 pounds of that PBT chemical during the calendar year.
Facility processes 100 pounds of that PBT chemical during the calendar year.
Facility otherwise uses 100 pounds of that PBT chemical during the calendar year.PBT REPORTING
EPA will provide a reporting form (EPA Form A or Form R) with instructions and technical guidance on how to calculate toxic chemical releases or emissions from your facility.
You are not required to measure or monitor releases for purposes of Section 313 reporting. You may use readily available data to report the quantities of chemicals that you use and the amounts released into the environment.HOW TO REPORT
The Form A serves as an alternate to Form R, such that completion of the Form A is in lieu of Form R. The Form A consists of two parts, but only consists of a total of two pages.
Part I, Facility Identification Information, which also includes the "certification" regarding the eligibility to use the Form A; and
Part II, Chemical Identification The Form A may be used to report multiple chemicals.
A complete report for Form A consists of at least two pages for each submission.FORM A
Section 1 – Toxic Chemical Identity
Section 2 – Mixture Component Identity
Section 3 – Activities and uses of the toxic chemical at the facility
Section 4 – Maximum amount of the toxic chemical onsite at any time during the calendar year.
Section 5 – Quantity of the toxic chemical entering each environmental medium (e.g. water, air, land) onsite.
Section 6 – Transfers of the toxic chemical in wastes to off-site locationsFORM R
Through source reduction, risks to people and the environment can be reduced, financial and natural resources can be saved that would otherwise have to be expended on environmental clean-up or pollution control, and industrial processes can become more efficient.SOURCE REDUCTION
reduces the amount of any hazardous substance, pollutant, or contaminant entering any wastestream or otherwise released into the environment (including fugitive emissions); and
reduces the hazards to public health and the environment associated with the release of such sub-stances, pollutants, or contaminants.SOURCE REDUCTION
Good Operating Practices
Tighter Inventory Control
Better Spill and Leak Prevention
Raw Material Modifications
Improved Process Modifications
Cleaning and Degreasing
Better Surface Preparation/Finishing
Better Product ModificationSOURCE REDUCTION
EPA is required by law to make the data in the reports available to the public through a computer database. (You can claim the toxic chemical identity to be a trade secret, but you must justify the claim to EPA.)
The database is intended to help answer citizens’ questions about toxic chemical releases in their community.PUBLIC ACCESS TO REPORTS
Facilities must keep a copy of each report filed for at least three years from the date of submission. These reports will be of use when completing future reports.
Facilities must also maintain those documents, calculations, worksheets, and other forms upon which they relied to gather information for prior reports.
In the event of a problem with data elements on a facility’s Form R or Form A report, EPA may request documentation from the facility that supports the information reported.RECORDKEEPING
Check the SIC code list to determine whether your facility is covered.
Check the list of toxic chemicals covered by Section 313 to see if any are manufactured, imported, processed, or otherwise used by your facility. Your chemical supplier is required to inform you if any of the Section 313 toxic chemicals are contained in mixtures sold to you. Also, the EPA document “Common Synonyms for Section 313 Chemicals” can assist you in identifying toxic chemicals.WHAT YOU CAN DO
If you meet the criteria, request copies of the reporting form, instructions, and any of the appropriate guidance documents from EPA.
Begin to develop the appropriate information to report your releases and your source reduction and recycling activities.WHAT YOU CAN DO
TRI information is also available on the TRI Web site at www.epa.gov/tri.
Other potential sources of TRI information include the state EPCRA section 313 contact, or your EPA Regional Office.ADDITIONAL TRI INFORMATION
“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”
Carol Browner Former EPA Administrator