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.
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TOXIC RELEASE INVENTORY (TRI)
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.
WHAT THIS COURSE DOES NOT DO
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.
Sections 311 and 312 of EPCRA require businesses to report the locations and quantities of chemicals stored on-site to state and local governments.
Section 313 requires businesses to report the more than 600 designated toxic chemicals released to the environment.
40 CFR 372 Toxic Chemical Release Reporting: Community Right-To-Know
Facility owners/operators that have on their premises chemicals designated under EPCRA as “extremely hazardous substances” must cooperate with state and local planning officials in preparing comprehensive emergency plans (Sections 302 and 303);
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).
Section 313 of EPCRA requires certain businesses to submit reports each year on the amounts of toxic chemicals their facilities release into the environment, either routinely or as a result of accidents.
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.
A plant, factory, or other facility is subject to the provisions of Section 313 if it meets all three of the following criteria:
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 services
2. If it has 10 or more full-time employees (or the equivalent 20,000 hours per year
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 list
Information reported by facilities includes:
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 facility
Maximum amount of chemical present on-site at the facility during the year
Types of activities conducted at the facility involving the toxic chemical, and
Source reduction activities.
Thresholds are specified amounts of toxic chemicals used during the calendar year that trigger reporting requirements.
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.
Manufacture– means to produce, prepare, import, or compound one of the toxic chemicals on the list. For example, if you make a dye for clothing by taking raw materials and reacting them, you are manufacturing the dye. You would also be covered if you were a textile manufacturer who imported a dye on the list for purposes of applying it to fabric produced at your plant.
Process – in general, is the incorporation of a toxic chemical into a product and includes making mixtures, repackaging, or using a chemical as a feed-stock, raw material, or starting material for making another chemical.
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).
Otherwise Use– applies to any use of a toxic chemical at a covered facility that is not covered by the terms “manufacture” or “process” and includes use of a toxic chemical contained in a mixture or trade name product. This includes disposal, stabilization, and treatment for destruction if the facility that conducted these activities received the toxic chemical for purposes of waste management. Examples include:
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.
Facility - all buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites and which are owned or operated by the same person. Warehouses on the same site as covered facilities are covered at the same threshold levels. Stand-alone warehouses that do not support a covered operation are not currently covered.
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.
EPA has compiled a list of more than 650 chemicals.
This list grows each year.
How EPA lists some of the Toxic Release Chemicals:
CAS NumberChemicalDe Minimis %
The top 20 chemicals released in 1998 were:
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.
Section 313 requires reporting on the toxic chemical categories listed on the following slides, in addition to the more than 650 specific toxic chemicals mentioned previously.
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.
Ethylenebisdithiocarbamic acid, salts and esters
Certain Glycol Ethers
Nicotine and salts
Polybrominated Biphenyls (PBBs)
Polycyclic aromatic compounds (PACs)
Strychnine and salts
Warfarin and salts
Qualifers are only reportable if in listed form.
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.
5. Hydrochloric acid - Only if it is an aerosol form.
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.
The qualifier for the following two chemicals is based on the chemical activity rather than the form of the chemical. Both are subject to EPCRA section 313 reporting requirements only when the indicated activity is performed.
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.
Under certain circumstances, some or all of the reporting requirements under Section 313 may not apply to a facility.
The following are the major exemptions:
De minimis concentrations of a toxic chemical in certain mixtures.
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.
Articles. In considering whether a reporting threshold has been exceeded, you are not required to count toxic chemicals present in articles processed or used at your facility. An “article” is a manufactured item:
(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.
Laboratory Activities. In considering whether a reporting threshold has been exceeded, you are not required to count toxic chemicals that are manufactured, processed, or otherwise used for research or quality control in a laboratory at a covered facility under the supervision of a technically qualified individual. This exemption does not apply to production, processing, or the use of toxic chemicals in laboratories for distribution in commerce or in pilot plant scale operations.
Other Exemptions. You are not required to count toxic chemicals that are used at your facility for any of the following purposes:
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.
Owners of Leased Property.
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.
Compare quantities of EPCRA Section 313 chemicals that you manufacture, process, or otherwise use to the respective thresholds for those activities.
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.
EPCRA defines a release as any “spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment.
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.
Air Emissions. Releases to air are reported either as point source or fugitive emissions. Point source emissions, also referred to as stack emissions, occur through confined air streams, such as stacks, vents, ducts, or pipes. Fugitive emissions are all releases to air that are not released through a confined air stream.
Fugitive emissions include equipment leaks, evaporative losses from surface impoundments and spills, and releases from building ventilation systems.
Surface Water Discharges.
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.
Underground Injection. Underground injection is the subsurface emplacement of fluids through wells. TRI chemicals associated with manufacturing, the petroleum industry, mining, commercial and service industries, and federal and municipal government-related activities may be injected into Class I, II, III, IV, or V wells, if they do not endanger underground sources of drinking water (USDW), public health, or the environment.
On-site Land 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.
For any EPCRA Section 313 chemical whose identity is claimed as trade secret, you must submit to EPA two versions of the substantiation form
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.
Businesses must report Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals.
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.
The owner or operator of a covered facility must report annually. Reports must be submitted on or before July 1 and cover activities that occurred at the facility during the previous calendar year.
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.
This is based on an alternate threshold for facilities with low amounts of an EPCRA Section 313 chemical in waste.
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 R consists of two parts that are on 5 pages.
Part 1 asks facility information:
Section 1 – Reporting Year
Section 2 – Claiming a Trade Secret
Section 3 – Certification
Section 4 – Facility Identification
Section 5 – Parent Company Information
Part 2 asks for chemical related information:
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 locations
Part 2 (continued):
Section 7a - On-site waste treatment methods and efficiency
Section 7b – On-site energy recovery processes
Section 7c – On-site recycling processes
Section 8 – Source reduction and recycling activities
The Pollution Prevention Act of 1990 (PPA) requires facilities to report the quantities of TRI chemicals they manage in waste, both on- and off-site. The PPA also requires facilities to provide information about the efforts they have made to reduce or eliminate those quantities.
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 is defined in the Pollution Prevention Act of 1990 as any practice that:
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.
Facilities have found that the following measures help in source reduction and fewer emissions:
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 Modification
The law requires facilities covered by Section 313 to send toxic chemical release reports both to EPA and to the state in which the facility is located. At EPA, the Office of Pollution Prevention and Toxics is responsible for receiving and processing the data. The agency designated to receive reports in your state is listed in the instructions for Form R.
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.
Sound recordkeeping practices are essential for accurate and efficient TRI reporting.
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.
Check that you have 10 or more full-time employees (that is, if the total annual hours worked by all employees is at least 20,000 hours).
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.
Determine whether you manufactured, processed, or otherwise used any toxic chemical on the list in an amount greater than the thresholds.
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.
Maintain a recordkeeping system that will help you estimate releases for future years. You should designate someone at your facility to be responsible for reporting under Section 313. That person should obtain reporting forms and instructions and should be aware of the reporting deadline: July 1 of each year.
To request copies of TRI and EPCRA documents or to obtain further information about the program, contact the toll-free Emergency Planning and Community Right-to-Know Information Hotline at 1-800-424-9346.
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.
TIPS FOR USING CONTRACTORS
ELEMENTS OF A SUCCESSFUL
THE IMPORTANCE OF A
“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