Toxic Release Inventory (TRI) Due July 1st: Does your Facility need to Report?

Toxic Release Inventory (TRI) is a resource for learning about toxic chemical releases and pollution prevention activities reported by industrial and federal facilities. TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) created the TRI program. As per this program, U.S facilities in different industrial sectors must report the quantity of each chemical that is released into the environment. In addition, they must also report any applicable strategies adopted to minimize chemicals’ release, such as recycling, energy recovery and treatment. A chemical release is considered to be the emission of any chemical to the air or water, or placed in some type of land disposal. The information submitted by facilities is compiled in the inventory.

What are TRI Toxic Chemicals?

Chemicals covered by the TRI program have one or more of the following impacts:

  • Cancer or other chronic human health effects
  • Significant adverse human health effects
  • Significant adverse environmental impacts

There are currently 770 individually listed chemicals and 33 chemical categories covered by the TRI Program.

Salient elements of the TRI Program were previously covered in Walden’s blog “Toxic Release Inventory Program, what is it and how does it affect my businessin March 2020.

Why is TRI Important?

TRI is a means to ensure that industries improve their environmental performance. By making information about industrial management of toxic chemicals public, TRI provides a strong stimulus for industries to mitigate the release of toxic chemicals. Having open access to information on management of toxic chemicals enables facilities to develop comprehensive emergency preparedness plans. Further, looking at production-related waste managed over time helps facilities in incorporating waste management practices that are preferable to direct disposal/release of waste into the environment.

A comparison of TRI data with data from other EPA regulatory programs helps identify facilities that are potentially out of compliance with certain regulations or operating permits, as well as aids in developing new regulations and policies that facilitate better use and management of toxic chemicals.

Pollution Prevention and Waste Management

EPA encourages facilities to reduce or eliminate the use of TRI-listed chemicals as a first step towards prevention of chemicals’ release and lowering the generation of chemical waste. Additionally, the following source reduction activities are highly recommended:

  • Material substitutions
  • Process modifications
  • Implementation of energy-efficient operating practices
  • Design of  chemical products and processes with a low level of toxicity

For waste that is generated, the most preferred management method is recycling, followed by waste combustion for energy recovery and waste treatment. The least preferred method is the disposal/release of chemical waste into the environment in a safe manner.          

TRI Reporting Requirements for Facilities

If a facility meets all of the criteria listed below, it must submit annual reporting forms for every chemical in the facility whose quantities are above established baseline levels in a given year:

  • Facility is in a covered industry sector (e.g., manufacturing, metal mining, electric power generation, hazardous waste treatment etc.).
  • Facility employs 10 or more full-time equivalent employees.
  • Facility manufactures, processes, or otherwise uses a TRI-listed chemical.

All facilities that meet TRI reporting criteria must submit TRI data to EPA and the relevant state by July 1 of each year.

EPA investigates cases of EPCRA non-compliance and may issue civil penalties, including monetary fines, and may also require correction of the violation, if a TRI is not submitted by the deadline. To support compliance with EPCRA Section 313, EPA has inspectors and attorneys in each of its 10 regional offices and at EPA headquarters.

Walden’s team of engineers can assist organizations with TRI report filing by performing the following activities:

  • Conducting a chemical-by-chemical threshold determination to confirm reporting applicability
  • Assembling the required information to develop media-by-media release, storage, treatment, and transfer estimates for each chemical by considering the variables unique to each site/chemical combination
  • Leveraging custom chemical release tracking and reporting tools consistent with the complexity of the site and the client’s budget
  • Auditing previous reports for accuracy and correcting them as needed
  • Completing EPA’s process for reporting past violations
  • Performing risk assessment modeling of the releases
  • Assisting with the implementation of pollution prevention practices
  • Reviewing the liability from vendors that treat or recycle waste streams

Contact Walden Environmental Engineering at 516-588-6859 to learn more about how we can help you comply with your facility’s TRI report filing requirements.

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