The Emergency Planning and Community Right to Know Act, Section 313 reporting, commonly referred to as Toxic Release Inventory (TRI) reporting, is due July 1, 2015. TRI reports must be submitted using EPA’s TRI-MEweb software, accessed through EPA’s Central Data Exchange (CDX). TRI reporting is required for facilities that have 10 or more full-time employees (20,000 hours or greater), are covered under an applicable NAICS code, and that manufacture, process, or otherwise use TRI reportable chemicals above established thresholds. The applicability analysis can be challenging for small facilities as contractors and corporate staff must be added to the site employee total, and for multi-establishment sites.
Persistently Bioaccumulative Toxic (PBT) chemicals (e.g., lead, mercury, etc.) have especially low reporting thresholds, and are commonly overlooked as suppliers are not required to list PBT chemicals in SDSs if present below certain concentrations, even though PBT chemicals do not have a de miminis concentration exemption. Other challenges include correct use of the article and specified use exemptions, correctly accounting for chemicals in storage in threshold determinations, making threshold determinations for every TRI chemical present no matter how small (including those associated with onsite fuel combustion), selecting the proper basis of estimate code, accounting for storm water discharges, correct use of sampling data in release calculations, and inclusion of contractor chemicals.
Discharge calculations (air, water, and solid waste) must utilize the best information available (e.g., monitoring data, engineering estimates, etc.), identify all release routes a TRI molecule can take, and should be consistent with other environmental reports submitted for CY2014 (e.g., emissions inventories, discharge monitoring reports, etc.). Reporters should also be cautious about reporting release data using too many significant figures. For assistance with TRI reporting, contact your local Trinity office at (800) 229-6655.