Toxic Release Inventory (TRI) Reporting is Due!

The July 1st deadline is fast approaching for facilities meeting the TRI reporting requirements. There are a few basics every facility should be aware of when it comes to TRI reporting. Below, we have three questions that will help you get on the right track to navigate your RY2019 TRI report.

Am I required to file a report?

Not everyone is required to file a TRI report, but it is important to know if you are subject and, in the event you do not meet the requirements, able to demonstrate why you are not subject. These requirements are:

  1. Your facility falls under a covered NAICS code;
  2. Your facility employees 10 or more full-time equivalent employees; and
  3. Manufactures, processes, or otherwise uses a TRI-listed chemical in quantities above the provided thresholds.

Your facility must meet all three of these criteria to trigger the reporting requirements. EPA provides a basic tool to help determine if you are required to file a TRI report.

It is important to keep records of calculations used to make the determination whether or not a report is required.

Where do I file my report?

Once a facility meets all three criteria they must complete a Form R using the EPA’s TRI-ME web reporting tool through the Central Data Exchange (CDX). A facility will complete a Form R for each qualifying chemical.

It is worth noting that some facilities may be able to file a Form A in lieu of a Form R. Form A is a simplified report that does not require detailed release information or waste management practices. This is determined on a chemical by chemical basis. Criteria for a Form A are:

  1. The chemical is not listed as a Persistent, Bioaccumulative, /or Toxic (PBT);
  2. The chemical has not be manufactured, processed, or otherwise used in excess of 1,000,000 lbs; and
  3. The total waste management during the reporting year for the chemical does not exceed 500 pounds.

A facility has to meet all three requirements for the chemical to be eligible for a Form A report. If reporting a Form A it is important to keep records of calculations used to make the determination.

What do I need to consider when determining what quantities to report?

For each chemical you have to report, you will need to determine how and in what quantity a chemical leaves your site. This includes on-site releases to air/water/land, transfer of chemicals to off-site locations, and other waste management practices such as recycling/treatment/energy recovery.

On-Site releases to air includes fugitive and point-source emissions. Typically, an up-to-date air emission inventory is a quick go-to for this data. For facilities reporting annual emissions under Title V of the Clean Air Act it is important to make sure your TRI emissions and annual inventory agree with each other.

On-Site releases to water include all discharges (including stormwater) to bodies of water and to water treatment facilities. It is important to review discharge monitoring reports and the associated analytical data to determine the quantity of a chemical released. If the analytical shows “non-detect” it is a common practice to use the detection limit when determining the loading.

On-Site releases to land include all waste that contain a TRI chemical disposed by means of landfill, underground injection, surface impoundments, engineered piles, or applied as a fertilizer. Information in most cases will come from a waste profile or by means of mass balance combined with various assumptions based on engineering judgement. In the case of using engineering judgement you should be able to support your assumptions based on conservative principles.

For some facilities, maybe you just have no idea where to start or how to go about calculating your releases. For others, it could simply be a lack of resources to ensure you meet the deadline with accurate information. Lastly, maybe you have been doing the same report, year after year, and you just need someone to take a look at your reporting to give you peace of mind

PPM has the resources and expertise to provide you with TRI services ranging from guidance and quality assurance of your current reporting all the way to a complete evaluation of TRI chemicals at your facility with full calculation and reporting services. We commit to make sure that each customer understands the why’s and how’s for each chemical being reported. Please call Paul Hansen, P.E. or Zane Hood, P.E (205-836-5650); or email here) to find out more about how we can simplify this complex task for you and your business.