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Reporting Year 2011 %
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Emergency Planning + Community RIGHT-TO-KNOW Act (EPCRA) Section 313
n=,epa i
Toxics Release Inventory
Reporting	Require
Basic Concepts
Do I Need to Report to TRI and
How Do I Report
Note: This program includes audio narration.
Use speakers or headphones for audio. Click Notes button for captions.

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TRI REPORTING REQUIREMENTS
TRI Training Module Agendas
Basic Concepts Module
1.	Introduction
2.	Covered Sectors
3.	Thresholds (PBT and Non-PBT)
4.	Reporting Exemptions
5.	Threshold Determinations
6.	Overview of Form R
7.	Alternate Threshold Rule (Form A)
Advanced Concepts Module
1.	Recent TRI Program Changes
2.	Advanced Reporting Guidance
3.	Detailed PBT Guidance
4.	Tools and Assistance
5.	TRI-MEweb Updates
3/14/2012
2

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What is EPCRA Section 313 & TRI?
•	Section 313 of EPCRA requires facilities to file a TRI report
annually for each Section 313 chemical exceeding an activity
threshold (manufacturing, processing or otherwise using)
¦	Section 313 chemical list contains over 600 chemicals and
chemical categories
•	Facilities exceeding an activity threshold must report f they are:
¦	In a "covered sector" (defined by NAICS codes); and
¦	Have 10 or more employees
•	Submit TRI reports to U.S. EPA, and either
¦	designated state officials, or
¦	designated tribal office
	by July 1st following the calendar year's activities (aka
Reporting Year (RY))
[e.g. July 1, 2012 deadline for RY 2011 (January 1 - December 31,
2011) activities]
3/14/2012
4

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TRI Process - 2 Part Process
Applicability &
Threshold Determinations
Identify Section
313 chemicals
manufactured,
processed, or
otherwise used at
the site
Determine
quantities of
Section 313
chemicals and
whether they are
manufactured,
processed, or
otherwise used
on-site for the
reporting year
I
If a Threshold is
Exceeded...
Release/Waste Mgmt. Reporting
Identify total
releases and
off-site transfers
Use TRI-MEweb to
Complete
Form R or Form A
Identify other waste
management
practices
Identify pollution
prevention
activities
4
Complete
Final QA/QC
I
Submit to
EPA & State
3/14/2012

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TRI Reporting Process
Covered Primary
NAICS Code(s) or
Federal facility?
NO
YES
Ten Employees?
(20,000 hours/year)
YES
MPOU*
Section 313
Chemicals?
NO
NO
(/>
o
-o
YES
MPOU*
Thresholds
Exceeded?
NO
''MPOU: Manufacture (including import), process, or otherwise use
3/14/2012

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Section I: «
Covered Sectors

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TR! REPORTING REQUIREMENTS
Industrial Sectors Covered
Industrial Sector
Notes
Manufacturing
Facilities engaged in the mechanical or chemical transformation of
materials or substances into new products
Metal mining
Not including metal mining services, and uranium, radium, and
vanadium ores
Coal mining
Not including coal mining services
Electrical utilities
Limited to facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce
Treatment, Storage, and
Disposal facilities
Limited to facilities regulated under the Resource Conservation
and Recovery Act, Subtitle C, 42 U.S.C. Section 6921 et seq.
Solvent recovery services
Limited to facilities primarily engaged in solvent recovery services
on a contract or fee basis
Chemical distributors
Facilities engaged in the wholesale distribution of chemicals and
allied products
Petroleum bulk terminals
Facilities engaged in the wholesale distribution of crude petroleum
and petroleum products from bulk liquid storage facilities
8

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TR! REPORTING REQUIREMENTS
Covered NAICS Codes
•	2007 North American Industry Classification System (NAICS) codes
are used for TRI reporting.
•	To determine whether your facility's primary NAICS code is covered
by TRI regulations, see:
www.epa.gov/tri/lawsandreqs/naic/ncodes.htm
I	i_	-i_r

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TRI REPORTING REQUIREMENTS
Federal Facilities
Federal facilities (covered by Executive Order
13423 and its implementing instructions)
¦	Owned or operated by Executive Branch
agencies
•	No restrictions based on NAICS code
•	Includes federal prisons, national parks,
federal hospitals
¦	With 10 or more full-time employees
(equivalent of 20,000 hours per year)
¦	That exceed manufacture, and/or process,
and/or otherwise use thresholds of a listed
chemical
¦	Government unit responsible for reporting on
activities conducted at Federal facilities
¦	Does not change existing requirements of
private contractors of government owned
contractor operated (GOCO) facility to report.
3/14/2012
10

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Definition of "Fac lity"
•	"Facilities" determine whether or not TRI reporting is required
¦	Primary NAICS code determination at facility level
¦	Employee threshold determination at facility level
¦	Chemical threshold determinations made at facility level
•	"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 (or by any person which controls, is controlled
by, or under common control with, such person)."
(EPCRA § 329 (41)

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Example of a Multi-Establishment Fac lity
• Three separate establishments located on contiguous/ adjacent
property owned by same person(s), is one facility under EPCRA
(40 CFR §§ 372.22(b) and 372.3))
¦ Establishment - unique and separate economic unit of a facility (See 40 CFR § 372.3)
Gen. Prod. Warehouse
(NAICS 49312)
Generic Products Food
Processing
(NAICS 311421)
Generic Products Farm
(NAICS 111219)
3/14/2012
12

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TRI REPORTING REQUIREMENTS
Multi-Establishment Facility
• Three separate establishments located on contiguous/ adjacent
property owned by same person(s), is one facility under EPCRA
(40 CFR §§ 372.22(b) and 372.3))
NAICS
determination by:
Majority
>50% of value
added
20%
Gen. Prod. Warehouse
(NAICS 49312)
Generic Products Food
Processing
(NAICS 311421) 60%
Generic Products Farm
(NAICS 111219)
20%
3/14/2012
Value added of food processing establishment = value of final food products - value of
warehousing - value of farm products.
13


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TRI REPORTING REQUIREMENTS
Multi-Establishment Facility
• Three separate establishments located on contiguous/ adjacent
property owned by same person(s), is one facility under EPCRA
(40 CFR §§ 372.22(b) and 372.3))
NAICS
determination by:
Plurality
Greatest % of
value added
30%
Gen. Prod. Warehouse
(NAICS 49312)
Generic Products Food
Processing
(NAICS 311421) 40%
Generic Products Farm
(NAICS 111219)
30%
3/14/2012
Value added of food processing establishment = value of final food products - value of
warehousing - value of farm products.
14

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TRI REPORTING REQUIREMENTS
Multi-Establishment Facility
• Determining how facilities report
¦	Federal facilities and government-owned, contractor-operated
facilities (GOCOs)
¦	See Appendix A of Reporting Forms and Instructions for
guidance specific to federal facilities
I
Dept. of Homeland
Security
Coast Guard




HUD


Ex. 1: Two separate reporting facilities
(HUD and DHS including Coast Guard)

**
*
Contractor 1
~
*
DOE
I
I
! Contractor
> 2
I
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Ex. 2: One reporting facility
(DOE)

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Employee Threshold
• 10 or more full-time employee equivalents (i.e., 20,000 hours)
(40 CFR §§ 372.3 and 372.22(a))
¦	Worked for the facility
¦	Includes operational staff, administrative staff, contractors,
dedicated sales staff, company drivers, off-site direct corporate
support
¦	Does NOT include contract drivers or contractors performing
intermittent service functions such as janitorial services (1998 Q&A
#21, #29 and #38)
¦	Add all hours from part-time and full-time employees
• Determinations based on available time management systems/data

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TR! REPORTING REQUIREMENTS
Quiz #1 Question 1
1. Would the facility described below be covered by Section
313 of EPCRA (TRI) and, therefore, need to consider its
toxic chemical use for possible reporting? Select Yes or No.
A manufacturing facility in a TRI-covered NAICS code,
owned by ABC Corporation, with 100 full-time employees
YES
NO

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TR! REPORTING REQUIREMENTS
Quiz #1 Question 2
2. Would the facility described below be covered by Section
313 of EPCRA (TRI) and, therefore, need to consider its
toxic chemical use for possible reporting?
Select Yes or No.
A maintenance and warehouse facility, owned by ABC
Corporation, with 5 full-time employees, a few blocks away
from the manufacturing facility described in Question 1.
YES
NO

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TR! REPORTING REQUIREMENTS
Quiz #1 Question 3
3. Would the facility described below be covered by Section
313 of EPCRA (TRI) and, therefore, need to consider its
toxic chemical use for possible reporting? Select Yes or No.
A maintenance and warehouse facility, owned by ABC
Corporation, with only 5 full-time employees, next door to
the manufacturing facility described in Question 1
YES
NO

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Section II:
Thresholds (PBT and Non-PBT)

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Thresholds (PBT and Non-PBT)
•	Threshold calculations for each activity are based on cumulative
quantities of each Section 313 chemical over the reporting year for
the whole facility
•	Toxic chemical activity thresholds are treated separately
¦	Classify each chemical activity into manufacture, process, or
otherwise use
¦	Compare amounts in each activity to the toxic chemical's
applicable threshold
If any threshold is exceeded, a TRI Report must be
prepared and submitted for that chemical

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TR! REPORTING REQUIREMENTS
Section 313 Chemicals (Non-PBT) and Thresholds
A facility meeting all three applicable criteria must file a TRI
Report for a non-PBT Section 313 chemical if the facility:
•	Manufactured (including imported) more than 25,000
pounds of the chemical in the reporting year, or
•	Processed more than 25,000 pounds of the chemical in
the reporting year, or
•	Otherwise Used more than 10,000 pounds of the
chemical in the reporting year

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Listed PBT* TRI Chemicals
•	Within the list of 600+ chemicals and chemical categories, there is
a subset designated as being of special concern and commonly
referred to as PBT chemicals (40 CFR § 372.28)
•	PBT chemicals have lower thresholds and different reporting
requirements than the other TRI chemicals
¦ Special rules often apply to PBT chemicals
•	20 chemicals and chemical compound categories are classified as
PBTs and have lower reporting thresholds
*PBT = Persistent, Bioaccumulative, Toxic

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TRI REPORTING REQUIREMENTS
PBT Chemicals and Thresholds
• PBT chemicals are subject to separate arid lower thresholds (See 40
CFR § 372.28)

~o
o
¦ 100 Ibs./yr (manufactured, processed, or otherwise used)
•	Aldrin ' Pendimethalin
•	Lead* ' Po^cycilc Aromatic Cmpds.
, , „ , • Tetrabromobisphenol A
•	Lead Cmpds. ^..
• Trifluralin
•	Methoxychlor


w
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i_
H
m
G_
¦ 10 Ibs./yr (manufactured, processed, or otherwise used)
•	Chlordane • Benzo(g, h, i)perylene
•	Heptachlor • Hexachlorobenzene
•	Mercury • Mercury compounds
•	Toxaphene • Octachlorostyrene
•	Isodrin • Pentachlorobenzene



• PCBs




¦ 0.1 g/yr (manufactured, processed, or otherwise used)
• Dioxin and dioxin-like compounds

«« • Excluding lead in stainless steel, brass, or bronze alloys
3/14/2012 * y
24
TRI

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Section 313 Chemicals and Chemical Categories
•	Current list contains over 600 individual chemicals and chemical
categories (See Table II of the EPA's TRI Reporting Forms and
Instructions document (RFI)). There are 4 parts to the chemical
list:
¦	Individual chemicals alphabetically by name
¦	Individual chemicals by CAS #
¦	Chemicals with qualifiers
¦	Chemical categories
•	The list can change - check every year. Changes listed in the
front of the RFI, on the TRI website, and in TRI-MEweb.

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TR! REPORTING REQUIREMENTS
Chemical List Changes for RY2011
A rule was published in 2010 adding 16 new chemicals to the TRI
chemical list.
Individual chemicals:
CAS#
1-Amino-2,4-dibromoanthraquinone
81-49-2
2,2-bis(Bromomethyl)-1,3-propanediol
3296-90-0
Furan
110-00-9
Glycidol
556-52-5
Isoprene
78-79-5
Methyleugenol
93-15-2
o-Nitroanisole
91-23-6
Nitromethane
75-52-5
Phenolphthalein
77-09-8
Tetrafluoroethylene
116-14-3
Tetranitromethane
509-14-8
Vinyl Fluoride
75-02-5
Chemicals Added to the Polycyclic Aromatic Compounds
1,6-Dinitropyrene
42397-64-8
1,8-Dinitropyrene
42397-65-9
6-Nitrochrysene
7496-02-8
4-Nitropyrene
57835-92-4
• Reporting for these chemicals is required beginning Reporting Year 2011
(reports due July 1, 2012) if all other TRI threshold criteria are met.
3/14/2012
26

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TR! REPORTING REQUIREMENTS
Section 313 Chemicals With Qualifiers
Qualifiers - Listed chemicals with parenthetic qualifiers subject to TRI
reporting only if manufactured, processed, or otherwise used in specified
form (40 CFR § 372.25(g)). Below are some examples (see Table II of
EPA's TRI Reporting Forms and Instructions document):
Chemical
CAS#
Qualifier
Aluminum
7429-90-5
Fume or dust
Aluminum Oxide
1344-28-1
Fibrous forms
Asbestos
1332-21-4
Friable forms
Isopropyl alcohol
67-63-0
Only manufacturers using
strong acid process
Phosphorus (not phosphate)
7723-14-0
Yellow or white
Saccharin
81-07-2
Manufacture only
Hydrochloric acid
7647-01-0
Acid aerosols
Sulfuric acid
7664-93-9
Acid aerosols
Vanadium
7440-62-2
Except when contained in alloy
3/14/2012	27

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TR! REPORTING REQUIREMENTS
TRI Chemical Categories
• Metal compound chemical categories
-	Antimony Compounds
-	Arsenic Compounds
-	Barium Compounds
-	Beryllium Compounds
-	Cadmium Compounds
-	Chromium Compounds **
-	Cobalt Compounds
-	Copper Compounds ***


For all categories: Includes any unique chemical substance that contains
the element or compound as part of that chemical's infrastructure




* Does not include Barium Sulfate CAS 7727-43-7




** Except chromite ore and un reacted ore component of processing residue
(see RFI for further information)




*** Does not include copper Phthalocyanine compounds that are substituted
with only hydrogen, and/or chlorine and/or bromine


3/14/2012
Note: Elemental metals and metal compounds are separately listed chemicals under Section 313.
28
TRI
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Vanadium Compounds
Zinc Compounds

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TR! REPORTING REQUIREMENTS
EPCRA TRI Chemical Categories

OH
I
Chlorophenols
(Cefc;ax
H(5-X) ;X= 1 to 5
Cyanide Compounds
XCN where X=H or any other group where a formal dissociation may
occur. For example, KCN or Ca(CN)2
Diisocyanates
20 individual compounds cited in Category
Dioxin and Dioxin-Like Compounds:
17 individual compounds cited in Category
Ethylenebisdithiocarbamic acid, salts and
esters (EBDCs)
Includes a substance that may contain EBDC or EBDC salt or ester as
part of its infrastructure
Certain Glycol Ethers
Complex definition
Nicotine and salts
Includes a substance that may contain it or salt as part of its infrastructure
Nitrate compounds
Water dissociable, reportable only when in aqueous solution
Polybrominated Biphenyls (PBBs)
(o^@^BrX
H(10-X) ;X= 1 to 10
3/14/2012
29

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Manufacturing Activities
• Manufacturing (EPCRA § 313(b)(1 )(C)(i) and 40 CFR § 372.3) -
generating a Section 313 chemical
¦	Intentionally producing chemicals for:
•	Sale
•	Distribution
•	On-site use or processing (e.g., intermediates)
¦	Coincidentally producing chemicals as impurities* or by-
products**:
•	At any point at the facility, including waste treatment (#152 of
1998 Q&A) and fuel combustion (#252 and #254 of 1998 Q&A)
¦	Importing
•	"Cause" to be imported
*lmpurity=TRI chemical that still remains with the final facility product as it is distributed into
commerce (#151 and #319 of 1998 Q&A)
**By-product= TRI chemical that is separated out from the process mixture before it becomes
the final product
3/14/2012	30


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Processing Activities
• Processing (EPCRA § 313(b)(1 )(C)(ii)
and 40 CFR § 372.3) - preparation of a
Section 313 chemical, after its
manufacture, for distribution in
commerce:
¦	Use as a reactant to manufacture
another substance or product
¦	Add as a formulation component
¦	Incorporate as an article component
¦	Repackage for distribution
¦	Quantities sent off-site for recycling
¦	Incidentally include as an impurity
3/14/2012
31

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Repackaging as a Processing Activity
Repackaging a Section 313 chemical for
distribution in commerce is considered
processing
¦	Repackaging includes:
•	From container to tanker
truck and vice versa
•	Between similar size containers
Via pipeline to/from a tank
¦	Repackaging does not include:
•	Sampling without repackaging
•	Re-labeling
Repackaging without distribution into commerce
is not processing
Transfer to a storage tank for mere storage is
not processing
3/14/2012
32

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TR! REPORTING REQUIREMENTS
Otherwise Use Activities
Otherwise Use (40 CFR § 372.3) -
includes most activities that are NOT
manufacturing or processing.
Examples
¦	Chemical processing aid (e.g.,
solvents)
¦	Manufacturing aid (e.g., lubricants,
refrigerants)
¦	Ancillary activities (e.g., chemicals
used to remediate wastes)
•	Fabrication and/or use of tools in
your process
•	Installation of piping and process-
related equipment, e.g., constructing
storage tanks
3/14/2012
33


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Otherwise Use Activities (continued)
Managing wastes received from off-site also counts as "Otherwise Use"
¦	Disposal, treatment for destruction on-site, or stabilization that does
not result in further distribution in commerce are considered
otherwise use f:
•	Section 313 chemical was received from off-site for the purposes of
further waste management, or
•	Section 313 chemical was manufactured as a result of waste
management activities on materials received from off-site for the
purpose of further waste management.
¦	Waste management activities, including on-site recycling, combustion
for energy recovery, treatment for destruction, waste stabilization and
release/disposal), on Section 313 chemicals in wastes generated on-
site are not threshold activities.
3/14/2012
34

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Ca culating Activity Thresholds
The threshold quantity is the total amount manufactured,
processed, or otherwise used, NOT the amount released.
Calculate the total amount of Section 313 chemical used for a
specific threshold activity
For threshold determinations, Section 313 chemicals recycled
from spent or contaminated materials or Section 313 chemicals
directly reused:
Count original amount used only once
If the materials remain in use from previous years, count only
the quantity added during current reporting year
Calculations for reporting waste management may be different
from threshold quantities.

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TR! REPORTING REQUIREMENTS
Threshold Determination for Compound Categories
Count together all compounds that fall within a category for each
activity, even if different compounds within a category are used
in separate operations
Consider the entire weight of the compounds in the category
when determining thresholds
Note: calculations for release and other waste management
estimates of metal compounds based on the parent metal weight
only; and for nitrate compounds are based on weight of nitrate
ion only

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TRI REPORTING REQUIREMENTS
Activities That Are Not TRI Threshold Activities
• Activities that, alone, do NOT constitute a threshold activity
¦	Storage
¦	Remediation of on-site contamination (assuming no listed
chemicals are manufactured during remediation)
¦	Re-labeling without repackaging
¦	Direct reuse onsite
¦	On-site recycling (not including wastes received from off-site)
¦	Transfers sent off-site for further waste management (not
including recycling)
Note: While these activities are not included in the threshold
determination, releases and wastes from these activities are not
exempt from reporting if threshold is exceeded through other
activities (unless specifically eligible for one of the reporting
exemptions).
3/14/2012	37

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Quiz #2 Question 1
1. A plant uses benzene as a raw material to manufacture
liquid industrial adhesive for sale. The plant adds 27,000
lbs. of benzene to its liquid adhesive-making operation
during the reporting year, but 3,000 lbs. are volatilized
during the operation. How much of the benzene should be
applied toward the processing activity threshold? Select
your choice.
A.	27,000 lbs.
B.	24,000 lbs.
C.	3,000 lbs.

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TR! REPORTING REQUIREMENTS
Quiz #2 Question 2
2. If a facility processes 20,000 lbs. of 2-Butoxyethariol in one
operation and 10,000 lbs. of 2-(2-Butoxyethoxy)ethanol in
another operation during the reporting year, what should it
apply towards t's processing threshold for glycol ethers?
Select your choice.
A.
10,000
lbs
B.
20,000
lbs
C.
30,000
lbs

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Quiz #2 Question 3
3. A facility processes 18,000 lbs. copper sulfate, 10,000 lbs.
of cuprous oxide, and otherwise uses 12,000 lbs. of
aqueous sulfuric acid solution. For which TRI chemicals or
chemical categories would the facility need to submit a TRI
form? Select your choice.
A.	copper compounds and sulfuric acid
B.	only copper compounds
C.	only sulfuric acid

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Section lll:- j '
Reporting Exemptions

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TRI REPORTING REQUIREMENTS
Reporting Exemptions
If an exemption applies, then the amount of Section
313 chemical subject to the exemption does NOT
have to be included in:
¦	Threshold determinations
¦	Release reporting
Recognize that exemptions only apply to certain
limited circumstances

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TRI REPORTING REQUIREMENTS
Reporting Exemptions
Types of exemptions (40 CFR § 372.38)
» De minimis
¦	Article
¦	Laboratory activities
- NAICS code specific
•	Coal mining extraction activities
•	Metal mining overburden
¦	"Otherwise use" exemptions
•	Motor vehicle maintenance
•	Routine janitorial or facility
grounds maintenance
•	Structural components
•	Personal use
•	Intake water and air
3/14/2012	43

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De Minimis Exemption
The quantity of a non-PBT Section 313 chemical in a mixture or
other trade name product is eligible for the de minimis
exemption (40 CFR § 372.38(a)) if the chemical is:
¦ An OSHA-defined carcinogen present at a concentration of less
than 0.1% (See 29 CFR § 1910.1200(d)(4))
OR
¦ Any other non-PBT TRI chemical present at a concentration of
less than 1%
The TRI de minimis level appears next to each chemical on the
chemical list in Table II of the TRI Reporting Forms and
Instructions (1.0, 0.1 or * for PBT chemicals where de minimis is
not allowed (See 40 CFR § 372.38(a)))

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De Minimis Exemption
HOW IT WORKS...
De minimis exemption generally applies to non-PBT chemicals:
¦	In mixtures or trade name products received from off-site,
including imported
¦	Coincidentally manufactured as impurities that remain in
products distributed in commerce
De minimis exemption does not apply to:
¦	Manufactured chemicals (in most cases): this includes by-
products produced from manufacturing, processing, otherwise
use, or any waste management
¦	Wastes received from off-site
¦	PBT chemicals (except for supplier notification)

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TR! REPORTING REQUIREMENTS
PBT Chemicals and the De	Exemption
The de minimis exemption cannot be applied
to PBT chemicals.
¦	For supplier notification
requirements, suppliers of mixtures
containing PBT chemicals at de
minimis concentrations do not need
to supply notification
¦	Even though it may not receive a
supplier notification, a facility that
receives a mixture and knows that
PBT chemicals are present must
consider the PBT chemical in
threshold and release calculations
No other EPCRA section 313 exemptions
were modified by the PBT rule.
3/14/2012
46

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—H-m-rn—it—
TRI REPORTING REQUIREMENTS
De Minimis Exemption: How It Works...
Processing a non-PBT Section 313 chemical in a mixture to below
the de minimis concentration does NOT exempt the chemical from
threshold determinations and release calculations
Acme Industries
Raw Material
Primer Mixture
Products
(90% Toluene)
1%
Toluene > 1%
m\
H
K
3
La

EEB


c



~
¦ ¦ i

i .

Paint
(<1% Toluene)
Toluene <1%
De minimis exemption does NOT apply
Threshold determination required
Release calculations required
De minimis exemption does NOT apply
Threshold determination required
Release calculations still required
3/14/2012

47

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TRI REPORTING REQUIREMENTS
De Minimis Exemption: How It Works...
Processing a non-PBT Section 313 chemical in a mixture to above
the de minimis concentration triggers threshold determinations and, if
thresholds are met, release calculation requirements
Solvent Raw Material
containing trace
amounts of toluene
containing
Paint Stripper
rrpi n j i i i i
»Ed r 1 mm
Acme industries
Toluene > 1%
Toluene < 1%
De minimis exemption DOES apply
Threshold determination not required
Release calculations not required
Concentrated
Toluene > 1%
De minimis exemption does NOT apply
Threshold determination required
Release calculations still required
3/14/2012
48

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TRI REPORTING REQUIREMENTS
Article Exemption Applicability
To qualify for the article exemption, the
article must meet 3 criteria (40 CFR §
372.3):
1.	Is formed into a specific shape or
design during manufacture; and
2.	Has end-use functions dependent
in whole or in part on its shape or
design during end-use; and
3.	Does NOT release a Section 313
chemical under normal processing
or use conditions at a facility

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—H-m-rn—it—
TRI REPORTING REQUIREMENTS
Article Exemption: How it Works
Releases of a Section 313 chemical from an article may negate the
exemption. To maintain the article status, total releases from all like
items must be:
¦	In a form having a specific shape or design; or
¦	Recycled, directly reused; or
¦	0.5 pound or less released per year (may be rounded down to zero)
If more than 0.5 pound per year of a Section 313 chemical is
released from all like items in a form not having a specific shape or
design and is not recycled or directly reused, none of the items
meet the articles exemption
End use must be dependent upon the item's initial shape or design
(For example, sheet metal must maintain ts nitial thickness, and
wire and pipe must maintain their initial diameter.)
See TRI Reporting Forms and Instructions for more on the article
exemption

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TRI REPORTING REQUIREMENTS
Article Exemption: Examples
Wire is cut to specified lengths. Wastes include off-spec cuts and
dust.
¦	Generation of off-spec cuts that are recognizable as articles will
not, by themselves, negate the article status
¦	Dust and off-spec cuts not recognizable as articles, with greater
than 0.5 pound of ANY Section 313 chemical released annually,
and not recycled or directly reused, negate the article status
Fluorescent light bulbs are installed containing mercury. The
used bulbs are crushed for recycling.
¦ Crushing bulbs for disposal is not considered release during
normal use; exemption is not negated

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TRI REPORTING REQUIREMENTS
Article Exemption
Article Exemption is often



inappropriately used!


K
¦ In many instances when metals are
A *W
""
P
machined, cut, or ground, in any
mW ,


manner, the article exemption may


not be applicable.
% A, '


Generally, the articles exemption does
"r


not apply to the actual manufacturing -

—

of articles.



3/14/2012

52
TRI

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Laboratory Activity Exemptions
HOW IT WORKS...

• Section 313 chemicals used in
• Section 313 chemicals used in
these laboratory activities
these laboratory activities are
under the direct supervision of
NOT exempt:
a technically qualified
¦ Specialty chemical production
individual ARE exempt from
¦ Pilot-scale plant operations
threshold and release (40 CFR
¦ Activities not conducted in lab
§ 372.38(d) and 1998 Q&A
¦ Support services
#311):
• Photo processing
¦ Sampling and analysis
• Equipment
¦ Research and development
maintenance/cleaning
¦ Quality assurance

¦ Quality control

3/14/2012
53
TRI

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TRI REPORTING REQUIREMENTS
Motor Vehicle Maintenance Exemption
•	Motor vehicles include cars, trucks,
missiles, spacecraft, tanks, and forklifts
•	Motor vehicle maintenance includes:
¦	Body repairs
¦	Parts washing
¦	Fueling and adding other fluids (e.g., ethylene glycol)
Note: This exemption does NOT apply to "manufacture" of Section 313 chemicals from
combustion of fuels.
• Section 313 chemicals used to maintain vehicles operated by the
facility are eligible for the exemption from threshold
determinations (40 CFR § 372.38(c)(4))
¦ "Otherwise use" exemption
3/14/2012
54

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Routine Janitorial or Facility Grounds Maintenance Exemption
•	Section 313 chemicals contained in products used for non-process
related routine janitorial or facility grounds maintenance ARE
eligible for exemption (40 CFR § 372.38(c)(2)):
¦	Phenol in bathroom disinfectants
¦	Pesticides or fertilizers used on lawns
¦	"Otherwise use" exemption
•	Section 313 chemicals used in the following activities are NOT
exempt
¦	Faci iity equipment maintenance
¦	Cleaning or maintenance activities that are directly associated
with or ntegral to the production process at the facility
Note: Chemicals otherwise used in janitorial or grounds maintenance
activities may not be exempt if part of your facility's "process" is to provide
these services (e.g., federal hospitals, prisons, parks). Also, chemicals
manufactured during routine janitorial or facility ground maintenance are not
exempt.
3/14/2012
55

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Structural Component Exemption
•	Section 313 chemicals used as structural components are eligible
for exemption (See 40 CFR § 372.38(c)(1)) if they:
1.	Are part of the facility structure; and
2.	Are NOT process related.
•	Non-process-related structural items eligible for the exemption:
Potable water pipes and other non-process-related pipes and
structures
•	Processed-related items/uses NOT eligible for the exemption:
Refractory brick, boiler tubes, process-related pipes, anodes
used in electroplating, grinding wheels, & metal working tools
Structural components that are integral to a non-industrial
facility's "process" (e.g., federal prisons, hospitals, parks)

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Other Section 313 "Otherwise Use" Exemptions
•	Section 313 chemicals contained in non-process related items for
employee personal use (40 CFR § 372.38(c)(3))
Non-federal Facilities:
HCFC 22 in air conditioners used solely for employee comfort
(exemption does NOT cover process cooling using chemical-
based cooling systems)
Chlorine used to treat on-site potable water
Phenol used in a facility medical dispensary
Federal Facilities:
Does not include TRI chemicals used for providing services to
non-employees (e.g., patients in federal hospitals, prisoners,
park visitors)
•	Section 313 chemicals found in intake water and air
3/14/2012
57

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Sector Specific Exemptions
Coal mining extraction activities are exempt from threshold
determinations and release reporting (40 CFR § 372.38(g))
(applies to NAICS Codes 212111-212113):
¦	Coal extraction: physical removal or exposure of ore, coal,
minerals, waste rock, or overburden prior to beneficiation, and
encompasses all extraction-related activities prior to
beneficiation (40 CFR § 372.3)
Chemicals in metal mining overburden that are processed or
otherwise used are specifically exempt from TRI reporting (40
CFR § 372.38(h)) (applies to NAICS Codes 212221, 212222,
212231, 212234, 212299):
¦	Overburden: unconsolidated material that overlies a deposit of
useful materials or ores (40 CFR § 372.3)

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Section IV:
Threshold Determination

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Chemical Information Management
Consider all activities and sources
Tracking chemicals entering facility
¦	Purchasing/Inventory
¦	Contractors
¦	Capital purchases (e.g., chillers, process equipment)
¦	Direct purchases (credit card or other emergency purchases)
¦	Direct and indirect materials
¦	Manufacturing byproducts/intermediates generated
Need cooperation and support from all functional groups
Be comprehensive!

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Threshold Determinations
• identify Chemicals and
• Collect Data to Calculate
Concentrations:
Thresholds:
¦
MSDS
¦
Inventory or Purchase Records
¦
Product or Specifications
¦
Throughput/Production Data
¦
Available Supplier/Vendor

Integrated Supplier Records

Product QA/QC data
¦
EPCRA or Other Env. Reports
¦
Industry Standards (API,
¦
Air Permits I MACT or Similar

ASTM, etc.)

Standards I Emission Inventories
¦
Waste Profiles
r .
Water Permits / DMR's /
¦
Process Knowledge

Discharge Reports
¦
Other References (AP-42,
¦
Annual/Biennial Waste Reports

WebFIRE, Merck Index)
¦
User Records
¦
Supplier Notification
¦
Other Vendor Records (can call



vendor)
3/14/2012


61
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Determining Concentrations in Mixtures or Other Trade Name Products
Determine whether thresholds were exceeded for listed
chemicals in a mixture if you know (40 CFR § 372.30(b)(3)):
¦	Exact concentration - use concentration provided:
•	MSDS = 25%	Use 25%
¦	Upper bound - use upper limit
•	MSDS < 25%	Use 25%
¦	Range - use the midpoint of the range
•	MSDS: 30 - 50%	Use 40%
¦	Lower bound - subtract out other known constituents, create a

range, and use the midpoint of range



• MSDS: >75% toxic chemical
Use 87.5% (top of



range = 100%)


• MSDS: >75% toxic chemical
Use 80% (range =


15% water
75% - 85%)

3/14/2012


62
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TRI Chemicals Contained in Mixtures
For the threshold quantity, only include the portion of the TRI
chemical in the mixture, not the weight of the entire mixture.
The de minimis exemption (40 CFR § 372.38(a)) applies to non-
PBT chemicals contained in mixtures at less than 1.0% or 0.1%
(for carcinogens).
¦ The de minimis exemption is related to the concentration of the
chemical in a mixture, NOT the quantity of the mixture used.
A metal alloy can be thought of as solid solution. To determine
threshold quantity, multiply the concentration of the TRI chemical
in the alloy by the total weight of alloy processed or otherwise
used.

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Determining Concentrations in Wastes
•	If concentration is exact, upper bound, range, or lower bound, use
the guidance for mixtures and other trade name products
discussed earlier
•	If concentration is below detection limit, use engineering
judgment:
¦	If the Section 313 chemical IS expected to be present, assume 1/2
of full detection limit
¦	If the Section 313 chemical is NOT expected to be present,
assume 0

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Supplier Notification
Supplier notification - requires suppliers of mixtures or trade
name products to covered facilities (See 40 CFR § 372.45(a)) to:
¦	Identify Section 313 chemical(s) by name and CAS number
¦	Identify Section 313 chemical(s) as being subject to Section 313
requirements
¦	Provide concentration (or range) of Section 313 chemicals n
mixtures and other trade name products (not wastes)
¦	Provide notification at least annually in writing or attached to
the MSDS
¦	Update notification when changes occur
The Regulatory Information section of the MSDS should identify
any chemicals that are subject to TRI reporting

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TR! REPORTING REQUIREMENTS
Watch for Double Counting
•	For threshold determinations, Section 313 chemicals recycled
from spent or contaminated materials or Section 313 chemicals
directly reused:
¦	Count original amount used only once
¦	Materials in use from previous years, count only the quantity
added during current reporting year
•	Section 313 chemicals stockpiled or n inventory but not
manufactured, processed, or otherwise used during reporting year
are NOT counted for threshold determinations
Chemicals sent off-site for recycling and
returned to the facility are considered new
materials and counted for threshold
determinations
3/14/2012
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Watch for Double Counting Within the Same Activity 1 hreshold!
Example: If a chemical is blended into a product mixture, and
then this mixture is packaged for sale into 55 gallon drums, these
are both processing activities, the chemical is "processed" twice.
Only count this quantity once towards the processing threshold.
¦	During Reporting Year, 20,000 lbs. of toluene were blended with
other chemicals to create a paint product.
¦	The paint product (containing the 20,000 lbs. of toluene) was
then packaged nto 55 gallons drums for sale.
¦	The processing threshold quantity for this facility for Reporting
Year = 20,000 lbs.

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Multi-Establishment Facility
Reporting as multi-establishment facility (40 CFR § 372.30(c))
- Apply threshold determinations on aggregate amount of
chemicals used at facility
¦	Able to file separate Form R reports for each part of the facility
(e.g., establishment or grouping of establishments) and the
Form Rs must be designated as "part of a facility" in Part I,
Section 4.2
¦	Report all non-exempt releases and other waste management
activities of reportable Section 313 chemicals for all parts of a
facility
¦	Avoid double-counting at the facility of chemicals involved in
intra-facility transfers

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—H-m-rn—it—
TRI REPORTING REQUIREMENTS
Example: EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet
Facility Name: OMNT CHEMICAL
3/1 4/201 Z
Toxic Chemical or Chemical Category': Toluene
Reporting Year: 	
Date Worksheet Prepared:
Prepared Bv: J.S.P.	
Step 1. Identify amounts of the toxic chemical manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
hi formation
Source
Percent
by Weight
Total Weight
(in lbs)
Amount of the Listed Toxic Chemical by Activity (in lbs):
Manufactured
Processed
Otherwise Used
1. Joe's Deoreaser
Purchasina
50
10,000


5000
2. Bathroom Paint
Vendor
5
30,000


1.500
3. Parts Washer Fluid
Purchasina
40
10.000


4.000
4.






5.













7.






Subtotal:



(A) lbs.
(B) lbs.
(C) 10,500 lbs.
Step 2. Identify exempt forms of the toxic chemical that have been included in Step 1.
Mixture Name as Listed Above
Applicable
Exemption
Note Fraction or Percent
Exempt (if Applicable)
Exempt Amount of the Toxic Chemical from Above (in lbs):
Manufactured
Processed
Otherwise Used
1. Bathroom Paint
Struct. Comp.
100


1.500
2.





3.





4





5





e.





i





Subtotal:


(A,) lbs.
(B,) lbs.
(Cj) 1,500 lbs.
Step 3. Calculate the amount subject to threshold:
Compare to thresholds for section 313 reporting.
(A-Aj)	lbs. (B -B,)	lbs. (( -( ,)	9.000 lbs.
25,000 lbs.	25.000 lbs.	10,000 lbs.
If any threshold is met, reporting is required for all activities. Do not submit this worksheet with Form R. Retain for your records.

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Lessons Learned
Begin early
Implement a program to gather "real-time" data on usage
Searches for historical information can be difficult
Team approach
Include all relevant personnel (e.g., engineering, purchasing,
environmental, waste management, operations)
Recordkeeping & Documentation
Keep good records and document all work

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Well-labeled calculations and engineering
assumptions serve as standard operating 	
procedures (SOPs) for future years
Ensures consistency from year to year, especially if personnel
responsible for reporting change
EPA Requirements
Records used to complete Form R must be kept for three years
from the time the report was submitted (40 CFR § 372.10)
EPA may review records during a data quality audit
TR! REPORTING REQUIREMENTS
Record Keeping and Documentation
Importance of good record keeping
Detailed records improve reporting
accuracy and data quality
Reduces replication of effort from year
to year

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TRI Process - 2 Part Process
Applicability &
Threshold Determinations
Identify Section
313 chemicals
manufactured,
processed, or
otherwise used at
the site
Determine
quantities of
Section 313
chemicals and
whether they are
manufactured,
processed, or
otherwise used
on-site for the
reporting year
I
If a Threshold is
Exceeded...
Release/Waste Mgmt. Reporting
Identify total
releases and
off-site transfers
Use TRI-MEweb to
Complete
Form R or Form A
Identify other waste
management
practices
Identify pollution
prevention
activities
4
Complete
Final QA/QC
I
Submit to
EPA & State
(only EPA if part of
State Data Exchange)
3/14/2012	72

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Section V:
Overview of Form R

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TR! REPORTING REQUIREMENTS
Overview of Form R
Two principal types of information required
¦	Facility-specific
¦	Chemical-specific
One form submitted to EPA and to the State/Tribe for each
Section 313 chemical or chemical category exceeding applicable
thresholds
"Old Days" - Paper Form
"Now" - Electronic Filing (TRI-MEweb)

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TR! REPORTING REQUIREMENTS
Form R Content
Part I
Section 1:
Reporting Year
Section 2:
Trade Secret Information
Section 3:
Certification
Section 4:
Facility Identification
Section 5:
Parent Company Info
Part II
Section 1:
Toxic Chemical ID
Section 2:
Mixture Component ID
Section 3:
Activities & Uses
Section 4:
Max Amt on site for CY
Section 5:
On-site Releases
Section 6:
Off-site Transfers
Section 7:
On-site Waste Treatment, Energy Recovery, Recycling Processes
Section 8:
Source Reduction and Recycling Activities
3/14/2012
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Facility Identification
Select a Facility (TRI-MEweb)
TRI-MEweb preloads facility information
• To view or make changes, select "Edit" after selecting facility
¦ Select "entire facility" or "part of a facility"
Facility Name and Address (Section 4.1)
Mailing address required if different from street address
¦ TRI facility identification number (if a form was filed in a previous
reporting year) or "New Facility" (if reporting for the first time)
Even if establishments in one facility are reporting separately, all

should use the same TRI facility identification number
¦	Federal facilities
• Enter name of Federal department or agency standard acronym
followed by the site name
¦	Standard facility names are available through the Facility Registry
Svstem (www.eDa.aov/enviro/html/fii/ez.html)

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76
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TRI REPORTING REQUIREMENTS
Facility Identification
Select Facility Type (Sections 4.2)
¦	Select Federal facility or "GOCO" or neither
Enter Parent Company Name and Dun and Bradstreet Number (Section 5)
¦	Parent company standardized names:
•	TRI-MEweb is pre-loaded with standardized Parent Company names. (Can
change pre-loaded Parent Company names, if necessary)
•	For new TRI reporters, the TRI-MEweb software has a list of standardized Parent
Company names. If reporters cannot find correct name from the provided list,
enter a new name.
•	Paper filers should refer to www, eoa. gov/tri/report/index, htm for a list of parent
company names.
•	Section 5.1: "NA" box has been replaced with "No U.S. Parent Company (for TRI
Reporting purposes)."
¦	To verify the accuracy of facility and parent company D & B number and name,
go to: https://www.dnb.com/product/alw/form cc4.htm or call 1-888-814-1435.
•	Private-sector and GOCO facilities: enter complete name and Dun & Bradstreet
number of parent company
•	Federal facilities: enter the complete name of department or agency for parent
company (e.g., U.S. Department of Interior)
•	Check "NA" for Dun & Bradstreet number of parent company
3/14/2012	77

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Facility Identification
Facility Dun and Bradstreet Numbers (Section 4.6)
¦ To verify the accuracy of facility and parent company D & B
number and name, go to:
httDs://www.dnb.com/Droduct/dlw/form cc4.htm
or call 1-888-814-1435.
Primary and Secondary NAICS codes (Section 4.5)
¦	Enter primary 6-digit NAICS code
¦	Enter other covered NAICS codes in decreasing order of
significance
¦	www.naics,com/search,htrn

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Part II - Chem cal-Specific information
TRI-MEweb preloads previous year's
chemicals
To select new chemical (Part II
Sections 1.1-1.3, 2.1)
¦	Select CAS number or category code
and name of chemical or chemical
category - except on trade secret
"sanitized" form; or
¦	Enter generic name only if claiming
chemical name as a trade secret (40
CFR 350); or
¦	Report generic name provide by
supplier, if supplier claims trade secret
Contact information (Part I, Section 4.3 and 4.4)
¦	List name, phone number, and email
•	Technical contact - should be able to explain data to EPA
•	Facilities are encouraged to provide an email address for the technical contact
•	Public contact - should be able to represent the facility's data to the public.
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TR! REPORTING REQUIREMENTS
Activities and Uses
Specify use(s) of the Section 313 chemical (Section 3)
(e.g., manufacture, process, or otherwise use)
¦	Report only activities taking place at reporting facility
¦	Check all applicable boxes
& Manufacture
Process
Otherwise Use
[""j Produce |~ For on-site use/processing
f As a reactant
Asa chemical processing aid
I- Import I- For sale distribution
As a formulation component
f* Asa manufacturing aid
I- As a byproduct
As an Article Component
Ancillary or other use
J~~ As an impurity
Repackaging


J- As an Impurity

3/14/2012	80

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TR! REPORTING REQUIREMENTS
Tools and Data Sources for Release Calculations
Previous year Form R reports and documentation (if available)
Process flow diagrams
Environmental monitoring data
Permit applications
EPCRA, CERCLA, RCRA, NPDES, CAA and other env. reports
Waste management manifests, invoices, and waste profiles
Engineering calculations and other notes
• EPA guidance (AP-42, WebFIRE, TANKS, WATER9)

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TR! REPORTING REQUIREMENTS
Estimating Quantities Released
Consider all sources (routine and non-routine)
Reasonable estimates are required by law
Best approach by facility may need to be determined
Data and approach must be documented, and should
be consistent!

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Data Precision
Values for non-PBT Section 313 chemicals must be entered in
whole numbers
¦	EPA allows using two significant figures when reporting releases
and other waste management estimates
•	The number of significant figures is typically the number of non-
zero digits
¦	If estimate is more precise, additional significant figures may be
used based on precision of data used to calculate estimate
¦	For estimates of non-PBT Section 313 chemicals under 1,000
pounds, a range code can be used:
•	A= 1-10 pounds; B = 11-499 pounds; C = 500-999 pounds
3/14/2012
83

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TRI REPORTING REQUIREMENTS
Data Precision
For PBT chemicals, report releases and other waste
management quantities at a level of precision supported by the
data and estimation techniques used
For PBT chemicals, 0.1 pound (100 micrograms for dioxins) is
the smallest amount required to be reported
¦ Estimates < 0.05 pounds (< 50 micrograms for dioxins) can be
rounded down to zero pounds
TRI-MEweb will allow for decimal reporting for PBT chemicals
(e.g., 9.3 pounds)

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"NA" vs, "0"
All data elements in Sections 5 and 6 must be completed. If you
determine that there was no release or transfer quantity:
¦	Use "NA" (not applicable) when no possibi lity of the Section
313 chemical being released to or otherwise managed as waste
in that media (e.g., facility has no on-site landfill)
OR
¦	Use "0" when no release occurs or < 0.5 pound of a non-PBT
Section 313 chemical from a waste stream is directed towards
that medium
•	Example: Discharge to water is zero; however, release possible
if control equipment fails
•	Must indicate a Basis of Estimate code (i.e., M1, M2, C, E1, E2,
O) for all numerical estimates, including "0"
3/14/2012
85

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TR! REPORTING REQUIREMENTS
Maximum On-Site Amount
Select appropriate code indicating the maximum quantity on-site
during the reporting year (Section 4).
1# Range Code: |


[ -- Select a Range Code --
-- Select a Range Code --


1 0 - 99 lbs


2 100 - 999 lbs


3 1000 - 9999 lbs


4 10,000-99,999 lbs


5 100,000-999,999 lbs


6 1,000,000 - 9,999,999 lbs


7 10,000,000- 49,999,999 lbs


8 50,000,000- 99,999,999 lbs


9 100,000,000 - 499,999,999 lbs


10 500,000,000 - 999,999,999 lbs


11 greater than 1 billion lbs


Use maximum total (non-exempt) amount present at one time
during reporting year, even if the Section 313 chemical is present at
more than one location at the facility
¦	Based on amount in storage, process, and wastes
¦	May not be the same as Tier II maximum amount on site
•	Tier II is usually by mixtures, Form R is chemical-specific
•	Tier II excludes hazardous wastes, Form R does not
3/14/2012	86


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TR! REPORTING REQUIREMENTS
Quantity Entering Each Medium
Report total releases of the Section 313 chemical to each
environmental medium on-site - air, water, land (Section 5).
Enter Total Release, report total quantity
¦ Range codes can be used in Sections 5 and 6 for non-PBT
Section 313 chemical quantities less than 1,000 pounds*
•	A = 1 - 10 pounds
•	B = 11 - 499 pounds
•	C = 500 - 999 pounds
* Note that similar quantities reported in Section 8 of Form R must be actual values and not ranges. The
Section 8 Calculator in TRI-MEweb will assume the midpoint of any ranges reported in Sections 5 and 6
when calculating quantities for Section 8.
3/14/2012
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Basis of Estimate Codes
One of the following "Basis of Estimate" codes must be listed on
the Form R for each release and waste management quantity
reported:
¦	Continuous monitoring (M1)
¦	Periodic or random monitoring (M2)
¦	Mass balance calculation (C)
¦	Published emissions factors (E1)
¦	Site-specific emissions factors (E2)
¦	Engineering calculations (O)
•	Everything NOT M1, M2, C, E1 or E2 above, such as:
•	Best engineering judgment
•	Estimated removal efficiencies
•	Non-chemical-specific and non-published emission factors
¦	Use the code on the Form R for the method used to estimate
the largest portion of the release
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Fugitive or Non-Point Air Emissions
Enter total fugitive releases of the Section 313 chemical,
including leaks, evaporative losses, building ventilation, or other
non-point air emissions (Section 5.1)
Example Using a Mass Balance Basis of Estimate (C):
¦ 5,000 lbs of a volatile solvent are added during the year as part
of the manufacture of a liquid adhesive. 4,950 lbs of the solvent
are contained in the final liquid adhesive product.
• Input (5,000 lbs) = Output (4,950 lbs) + Air Loss (50 lbs)

• Fugitive air emissions from this process = 50 lbs


Law of Mass Balance:


What Goes In = What Comes Out

3/14/2012

89
TRI

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TRI REPORTING REQUIREMENTS
Estimating Releases When No Data Available (Fugitive)
Example: Metal dust observed on floor
near or within metalworking operation -
indicates fugitive air emission occurring
and possible transfer off-site; no
additional data are available:
¦	Work with operations personnel
familiar with the operation
¦	Use best engineering judgment to
estimate quantity released -
document the basis of the judgment
3/14/2012
90

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Stack or Point-Source Air Emissions
Enter total releases to air from point sources, including stacks, vents,
pipes, ducts, storage tanks, or other confined air streams (Section
5.2)
Data sources/tools
¦	Air permit applications
¦	CAA Title V air inventories
¦	Process and production data
¦	Published emission factors
¦	Facility-specific monitoring data and emissions factors
Example using an Emission Factor basis of estimate (E1):
¦	500,000 tons of coal are combusted in a fluidized bed combustor
¦	EPA emission factor: 0.11 lb mercury emitted /1,000,000 lb coal combusted
¦	500,000 tons x 2,000 pounds I ton x (0.11 lb mercury 11,000,000 lb coal) = 110
lbs. mercury
¦	110 pounds of mercury are released through the stack
¦	Note: A portion of mercury may be present in resulting ash and would need to
be reported as such

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TR! REPORTING REQUIREMENTS
On-Site Wastewater Discharges
Releases to streams or water bodies (Section 5.3)
¦	Enter the stream or water body to which your facility directly
discharges the chemical
• Check "NA" Box if the facility does not discharge to receiving
streams or water bodies.
¦	Enter the total amount of releases to each receiving stream or
water body, including amounts from stormwater runoff, if available
¦	Indicate the percentage of the total quantity (by weight)
contributed by stormwater
Stream or Water Body Name
Quantity
lbs
n _ . Basis of
Range Code Estimate Code
%from
Stormwater

Swift Creek
54
M2- Monitoring,
Periodic/Random
10-0% j
EdII ) (X Delete)

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Calculating Wastewater Discharges
Release to stream or water body (Section 5.3) and Discharges to
POTW (Section 6.1) are not the same
¦	Direct AND Indirect Discharges
• Don't forget storm water!
¦	If no monitoring data exists, estimate based on process
knowledge and/or mass balance calculation
Data Sources
¦	DMRs (or related wastewater monitoring reports)
¦	Other monitoring data such as permit applications
3/14/2012
93

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—H-m-rn—it—
TRI REPORTING REQUIREMENTS
Calculating Wastewater Discharges
Calculate the yearly pounds of methanol discharged using the
following data concerning wastewater discharges of methanol:

Date
Cone, (mg/l)
Flow (MGD)
Amt. (lbs/day)

3/1
1.0
1.0
8.33

9/8
0.2
0.2
0.33
Correct way


Average
=
4.33
Incorrect way

0.6 mg/l x
0.6 MGD x 8.33 =
3.00
MGD = million gallons per day
• Basis of Estimate Code: M2
1 mg/l = 8.33 lbs/million gal
3/14/2012
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On-Site Injection Wells
Underground injection to Class I wells (Section 5.4.1)
¦	Enter total amount of Section 313 chemical injected into Class I
wells at facil ity and basis of estimate code
Underground injection to Class II - V wells (Section 5.4.2)
¦	Enter total amount of Section 313 chemical njected into Class
II - V wells at facility and basis of estimate code




Total Quantify: lbs


- or -


Range Code: n0 code Selected ^


Basis of Estimate: J No Value Selected


Note: Basis of estimate code must be entered.

3/14/2012
95
TRI

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Disposal to Land On-Site
Enter quantity of toxic chemical entering each on-site land disposal
option (Section 5.5)
¦	On-site landfills: RCRA Subtitle C (Section 5.5.1A)
¦	On-site landfills: other (Section 5.5.1 B)
¦	On-site land treatment and application farming (Section 5.5.2)
¦	On-site surface impoundments: RCRA Subtitle C (Section 5.5.3A)
¦	On-site surface impoundments: Other (Section 5.5.3B)
¦	Other disposal (includes spills or leaks to land)
Quantities released to air or water during the reporting year of the
initial release to land (e.g., volatilization from surface impoundments)
are not included here

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TRI REPORTING REQUIREMENTS
On-Site Waste Management
Examples of on-site waste
management
¦	Air pollution control devices
¦	Wastewater treatment processes
¦	Energy recovery devices
¦	Recycling devices
3/14/2012	97

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TRI REPORTING REQUIREMENTS
Waste Treatment Methods and Efficiency
Report each waste treatment method that the Section 313
chemical undergoes (Section 7 A)
¦	Include even if method has no effect on the chemical
¦	Focuses on the entire waste stream and the waste treatment
efficiency applies to the Section 313 chemical within the waste
stream
Waste a- General b. Waste
Treatment Waste Treatment c.Waste Treatment Efficiency
Profile Stream Method(s)
Name Code Sequence
Chemical L - Liquid HG75
oxidation waste
streams
(non-aque
| Select a Range
Qgfa Ed 11 ) (X Delete)
Select a Range

El - Greater than 99.9999%
E2 - Greater than 99.99%, but less than or equal to 99.9999%
E3 - Greater than 99%, but less than or equal to 99.99%
E4 - Greater than 95%, but less than or equal to 99%
E5 - Greater than 50%, but less than or equal to 95%
E6 - Equal to or greater than 0%, but less than or equal to 50%
Select from the list and click Add Selected: H

Enter quantity treated on-site (Section 8.6 current year)
3/14/2012
TRI
98

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TR! REPORTING REQUIREMENTS
Energy Recovery Methods and Quantity
Enter on-site energy recovery quantity and methods for Section
313 chemical
¦	Section 313 chemical must be combustible and have a
significant heating value (5,000 BTU/lb.)
¦	Combustion unit is integrated into an energy recovery system
(e.g., industrial furnace, industrial kiln, or boiler)
Enter codes in descending order by quantities combusted
Quantity Used for Energy Recovery Onsite:

Current Year (lbs)
Energy Recovery Methods:
(Select the order of energy reco very methods used}
First Method Second Method
Third Method

| Not Selected _*j | Not Selected | Not Selected
3
3/14/2012
99

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TR! REPORTING REQUIREMENTS
Recycl ng Methods and Quantity
Enter quantity and methods used for on-site recycling of the Section 313
chemical (Sections 7C and 8.4 current year)
¦	Codes for recycling methods used are found in EPA's TRI Reporting
Forms and Instructions document
¦	Do not include energy recovery processes
Enter codes in descending order by quantities recycled
Qua ntity Re cycl e d 0 nsite: | current Year (its)


Recycling Methods:
(Select the order of recycling methods used)
First Method Second Method


| Nat Selected _*j | Not Selected


3/14/2012

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TR! REPORTING REQUIREMENTS
Off-Site Transfers
Includes both off-site location information and quantities of
Section 313 chemicals transferred to off-site locations
Report quantities of chemical sent off-site to each POTW or
other location for recycling, energy recovery, waste treatment,
or disposal
Report only total quantity of chemical transferred off-site, not
the quantity of entire waste stream mixture
In Sections 6.1 and 6.2, Total Transfers, report total quantity
| Range codes can be used in Sections 5 and 6 for non-PBT
Section 313 chemical quantities less than 1,000 pounds*
•	A = 1 - 10 pounds
•	B = 11 - 499 pounds
•	C = 500 - 999 pounds
* Note that similar quantities reported in Section 8 of Form R must be actual values and not ranges. The
Section 8 Calculator in TRI-MEweb will assume the midpoint of any ranges reported in Sections 5 and 6
when calculating quantities for Section 8.
3/14/2012	101


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TR! REPORTING REQUIREMENTS
Transfers to POTWs
Discharges to publicly owned treatment works
¦	Enter total quantity of the Section 313 chemical transferred to all
POTWs and basis of estimate
¦	Select POTW name and location for each POTW
¦	May be able to find official name of POTW:
•	Using TRI-MEweb search tool
•	Enforcement & Compliance History Online (ECHO):
www.eDa-echo.gov/echo/ OR
•	Facility Registry System: www, epa. gov/enviro/html/fii/ez. html
Example using an Engineering Calculations basis of estimate (O):
¦	A wet grinding process generates wastewater with 300 lbs of lead
(contained in particulates) during the year. This wastewater
undergoes on-site filtration prior to being sent to the POTW.
Manuals from the filter equipment vendor indicate a 95% removal
efficiency for particulates of this size.
•	300 x 0.95 = 285 lbs removed from the wastewater
•	300 - 285 = 15 pounds remaining in the wastewater after filtration
•	15 pounds of lead are transferred off-site to the POTW
3/14/2012
102

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TR! REPORTING REQUIREMENTS
Other Off-site Transfers
Enter transfers to other off-site locations (Section 6.2)
¦	Include name, address, and EPA identification (RCRA ID)
number of the receiving facility
¦	Enter quantity, basis of estimate, and M code for each different
waste management activity (waste treatment, disposal,
recycling, and energy recovery)
¦	Check "NA" box to indicate no transfers to off-site locations
Data/tools
¦	Waste manifests and vendor receipts
¦	RCRA reports
¦	Waste characterization - analyses, profiles

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Off-Site Waste Transfers
•	Approach: ID potential sources^ ID data/tools^ estimate
Potential off-site waste transfers of reportable chemicals
¦	Hazardous waste
¦	Non-hazardous waste (e.g., waste oil and coolant)
¦	Trash
¦	Scrap metal (reuse versus recycle)
¦	Container residue: RCRA empty is NOT EPCRA empty
¦	BE COMPREHENSIVE!
•	Also need to be sure to identify ALL possible sources of waste
composition data
Identify final disposition of each Section 313 chemical:
¦	Disposal, waste treatment, energy recovery, recycling
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Release and Waste Management Estimates
Helpful hints for accurate release estimates
¦	Always use your best available information
¦	Estimate the quantity of Section 313 chemical, not the entire
waste stream
¦	Differentiate fugitive from stack air emissions
¦	Zero air emissions for volatile organic compounds (VOCs) are
unlikely
¦	Watch out for releases of Section 313 chemicals with qualifiers
¦	Check your math and document your work!
•
Result of release estimation errors



¦ Incorrect release estimates and inconsistencies could carry



over from year to year


3/14/2012


105


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TRI REPORTING REQUIREMENTS
Pollution Prevention Hierarchy
Section 8 of Form R






Source Reduction
Recycling
Treatment



3/14/2012

106

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TR! REPORTING REQUIREMENTS
Source Reduction and Recycl ng (Section 8)
The sum of sections 8.1 through 8.7 represents the total quantity of waste
generated through regular production activities at your facility for the
reporting year.
Waste Management Description
Prior Year
(RY2009)
Current Year
(RY201B)
Following Year
(RY2011)

Second Following Year
(FCY2012)

8.1a) Total on-site disposal...
0
0
I'D
r Nfl
|o
r na
8.1b) Total other on-site disposal...
390
410
|400
r NA
|407
r na
8.1c) Total off-site disposal...
0
0
|o
r Nfl
|o
r na
8.1d) Total other off-site disposal...
1050
1145
|1100
r na
|1068
r na
8.2) Quantity used for energy recovery onsite
0
0
|o
r na
|o
r na
8.3) Quantity used for energy recovery offsite
0
NA
I
" p NA
I
p NA
8.4) Quantity recycled onsite
0
0
|o
r na
[o-
r na
8.5) Quantity recycled offsite
0
NA
I
17 NA
I
F NA
8.6) Quantity treated onsite
5000
5150
|5100
r na
|4970
r na
8.7) Quantity treated offsite
0
0
|o
r na
|o
r na
TRI-MEweb includes a Section 8 Calculator feature that helps calculate
Section 8 estimates from estimates reported in previous portions of on-line
application. A validation feature ensures consistency between Sections 5
and 6 and Section 8.

3/14/2012





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TR! REPORTING REQUIREMENTS
Section 8: Relationship to Sections 5 and 6
Part II. Sections 8.1 - 8.7
8.1a
Total on-site disposal to Class I UIC wells, RCRA & other landfills
5.4.1 + 5.5.1 A + 5.5.1B -8.8 (on-site release or disposal due to catastrophic event)
8.1b
Total other on-site disposal or other releases
5.1, 5.2, 5.3.1, 5.3.2, 5.3.3, 5.4.2, 5.5.2, 5.5.3A, 5.5.3B, 5.5.4 - 8.8 (on-site release or disposal due to catastrophic
event)
8.1c
Total off-site disposal to Class I UIC wells, RCRA & other landfills
Section 6.2, M64, M65, and M81 - 8.8 (off-site disposal due to catastrophic event)
8.1d
Total other off-site disposal or other releases
6.1 (for metals and metal category compounds only) + 6.2 (quantities associated with M codes M10, M41, M62, M66,
M67, M73, M79, M82, M90, M94, M99) - 8.8 (off-site disposal due to catastrophic event)
8.3
Off-site energy recovery
6.2, M56 and M92 - 8.8 (off-site energy recovery due to catastrophic events)
8.5
Off-site recycling
6.2, M20, M24, M26, M28, and M93 - 8.8 (off-site recycling due to catastrophic events)
8.7
Off-site treatment
6.1 (excluding metals and metal category compounds), 6.2 (quantities associated with M codes M50, M54, M61,
M69, M95) - 8.8 (off-site treatment due to catastrophic event)
Note: Quantity reported in 6.1 is distributed among 8.1c, 8.1d and 8.7 based on final disposition. Metals and metal
category compounds should not be reported in 8.7.
3/14/2012
108

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TR! REPORTING REQUIREMENTS
Section 8: Relationship to Section 7
Part II. Sections 8.1 - 8.7
8.2
On-Site Energy Recovery
•	Determine quantity for activities described in 7B
•	Report quantity actually combusted in energy recovery unit (i.e., consider efficiency)
8.4
On-Site Recycling
•	Determine quantity for activities described in 7C
•	Report quantity actually recycled (i.e., consider efficiency)
8.6
On-Site Treatment
•	Determine quantity of the chemical for activities on wastestream describes in 7 A
•	Report quantity actually destroyed (i.e., consider efficiency)
•	Metals and metal category compounds cannot be reported here

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TR! REPORTING REQUIREMENTS
Remedial, Catastrophic, or One-Tome Amounts
Enter the quantity of Section 313
chemical released into the environment
or transferred off-site (Section 8.8) as a
result of:
•	Remediation
•	Catastrophic events (e.g.,
earthquake, hurricane, fire, floods)
•	One-time events not associated with
production processes (e.g., pipe
rupture due to unexpected weather)
Does not include Section 313
chemicals treated, recovered for
energy, or recycled ON-SITE
Quantities in Sections 8.1 through 8.7
should not include amounts reported in
Section 8.8
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Production Ratio or Activity Index
Production ratio or activity index (Section 8.9)
¦ A ratio of production or activity involving the Section 313
chemical in the reporting year to production or activity in the
previous year
Allows quantities of the Section 313 chemical reported in
Sections 8.1 through 8.7 in the current year to be compared
to quantities reported in the prior year
Example (Production Ratio):
Oven manufacturing
40.000 ovens assembled (Current RY) = 1.14
35,000 ovens assembled (Prior RY)
Example (Activity Index):
Tank washouts
50 Washouts (Current RY) = 0.83
60 Washouts (Prior RY)

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Source Reduction Activities
Practices used with respect to the chemical, and the methods used
to identify those activities (Section 8.10)
¦ Includes those source reduction activities implemented for the first
time during the reporting year
• Include activities that reduce or eliminate quantities reported in
Sections 8.1 through 8.7
¦ Possible Source Reduction Activities
•	Standard operating procedures
•	Process changes or equipment changes (e.g., replacements,

adjustments)

• Raw material changes

• l/l/or/c orders for process changes

• Product redesign specifications

• Audit reports and follow-up actions

• Waste minimization section of the RCRA hazardous waste report

• State/corporate pollution prevention reports
3/14/2012
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TR! REPORTING REQUIREMENTS
Optional Source Reduction Information
Optional Additional Source Reduction,
Recycling, and Pollution Control
Information (Section 8.11)
Facility should indicate whether
additional optional nformation on
source reduction, recycling, or pollution
control activities is included with the
report
A one-page summary is encouraged
Facility can provide information on
previous years' activities
New Section Added: Miscellaneous and
Optional Information (Section 9.1)
Facility can provide any useful
additional information related to any
portion of the Form R submission in
this new data field
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Section VI : j
Alternate Threshold Rule

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Form A Eligibility
•
If alternate threshold criteria met:
Have the option to file a Form A in lieu of a Form R
No detailed release, other waste management, or source
reduction reporting
Maintain records and calculations used to determine Form A
eligibility


•
Facilities can submit a combination of Forms R and Forms A.
Some chemicals may meet Form A criteria, others may not.


•
If a facility submits a Form A and does not meet the qualifying
criteria, it may result in an enforcement action.


3/14/2012


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Criteria for Submitting Form A
Must NOT be a PBT chemical
Do not exceed 1,000,000 pounds of the toxic chemical
manufactured, processed, or otherwise used.
Do not exceed 500 pounds for the total annual waste
management (i.e., releases including disposal, recycling, energy
recovery, and treatment) of the Section 313 chemical.

Equivalent to the sum of the quantities calculated for Sections
8.1 - 8.7 of the Form R

3/14/2012

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TRI

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TR! REPORTING REQUIREMENTS
Quiz #3 Question 1
1. A facility manufactures 100,000 lbs. of a rion-PBT Section
313 chemical. They sell 99,950 lbs. as a product. They
emit 25 lbs. to the air out of a stack, and send 25 lbs. off-
site for treatment.
Do they meet the criteria for submitting a Form A?
Select Yes or No.
YES
NO

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	IflUM 4


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Quiz #3 Question 2
2. A facility uses 50,000 lbs. of nitric acid as a cleaner. The
entire amount is neutralized in their on-site wastewater
treatment operation and there are no air or water releases.
Do they meet the criteria for submitting a Form A?
Select Yes or No.
YES
NO

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TRI REPORTING REQUIREMENTS
Benefits of	TRI-MEweband Submitting Via CDX
TRI forms can be filled from any computer that has an Internet
connection
It saves time and money
Using TRI-MEweb assists users in finding reporting errors
TRI-MEweb helps users address new reporting requirements for
chemicals that have been added to TRI list
EPA provides instant email confirmation of transmitted and certified
submission
Electronic Signature allows for quick, paperless submissions

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Benefits of TRI-MEweh and Submitting Via CDX (cont.)
CDX submissions are processed automatically, unlike paper
submissions, which leads to faster Facility Data Profile (FDP) access
Reduced data collection costs for EPA, States, and Regulated
Community
Facilities in participating States can submit TRI information to both
EPA and their State simultaneously.
¦	To view States that are on the exchange network, go to
www.epa.gov/tri/stakeholders/state/state exchange/
¦	Facilities in other states can generate CD's or diskettes for their
state reporting using TRI-MEweb.
¦	TRI-MEweb also allows facilities to make revisions or withdrawals to
current year forms and forms from the past five reporting years.

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For More [information and Assistance
•	For more information on TRI requirements, see the second part of this
training course on TRI Advanced Concepts.
•	For TRI reporting guidance, information and tutorials on the TRI-MEweb
reporting software, and the latest changes to the TRI Program please
visit www.epa.gov/tri.
• Industry-specific and chemical-specific guidance can be found at:
www.epa.qov/tri/quide docs/index.htm
I	~i_*	-mT

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End of Module
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TR! REPORTING REQUIREMENTS
Quiz Answers

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TR! REPORTING REQUIREMENTS
Quiz #1 Question 1
1. Would the facility described below be covered by TRI and, therefore, need to
consider its chemical use for possible reporting?
Select Yes or No.
A manufacturing facility, owned by ABC Corporation, with 100 full-time employees
YES	NO
Answer: Yes.
As a manufacturing facility, its primary NAICS code will be among those covered
by EPCRA Section 313 (TRI). In addition, the facility employs more than 10 full-time
employees. This facility would need to consider whether it has exceeded any
activity thresholds for TRI chemicals or chemical categories, to determine if it
needed to report.
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TR! REPORTING REQUIREMENTS
Quiz #1 Question 2
2. Would the facility described below be covered by TRI and, therefore, need to
consider its chemical use for possible reporting?
Select Yes or No.
A maintenance and warehouse facility, owned by ABC Corporation, with 5 full-time
employees, a few blocks away from the manufacturing facility described in
Question 1
YES	NO
Answer: No.
The facility's maintenance and warehouse activities are represented by a primary
NAICS code that will not he among those covered by EPCRA 313 (TRI). In addition,
the facility has fewer than 10 full-time employees. This facility would not need to
report.
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TR! REPORTING REQUIREMENTS
Quiz #1 Question 3
3. Would the facility described below be covered by TRI and, therefore, need to
consider its chemical use for possible reporting?
Select Yes or No.
A maintenance and warehouse facility, owned by ABC Corporation, with 5 full-time
employees, next door to the manufacturing facility described in Question 1
YES	NO
Answer: Yes.
The maintenance and warehouse activities are considered part of the
manufacturing facility because they are on adjacent properties. Since the employee
threshold is exceeded, this facility would need to consider any chemical use at the
warehouse and maintenance establishment along with that of the manufacturing
facility, to determine if the facility needed to report.
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TR! REPORTING REQUIREMENTS
Quiz #2 Question 1
1. A plant uses benzene as a raw material to manufacture liquid industrial adhesive
for sale. The plant adds 27,000 lbs. of benzene to its liquid adhesive-making
operation during the reporting year, but 3,000 lbs. are volatilized during the
operation. How much of the benzene should be applied toward the processing
activity threshold? Select your choice.
A.	27,000 lbs.
B.	24,000 lbs.
C.	3,000 lbs.
Answer: A is correct
27,000 total lbs. of benzene is processed. Always apply the total amount that enters
a process toward the activity threshold. The quantity of benzene processed
exceeds the 25,000 lbs. processing threshold for non-PBT chemicals, therefore, the
facility would need to complete a TRI form for benzene. The quantity released to the
environment would be reported on the TRI Form R.
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TR! REPORTING REQUIREMENTS
Quiz #2 Question 2
2. If a facility processes 20,000 lbs. of 2-Butoxyethanol in one operation and 10,000
lbs. of 2-(2-Butoxyethoxy)ethanol in another operation during the reporting year,
what should it apply towards it's processing threshold for glycol ethers?
Select your choice.
A.	10,000 lbs.
B.	20,000 lbs.
C.	30,000 lbs.
Answer: C is correct.
2-Butoxyethanol and 2-(2-Butoxyethoxy)ethanoi are both chemicals within the
glycol ethers chemical category; therefore, the quantities of each chemical
processed during the reporting year should be summed. The facility has exceeded
the reporting threshold for processing (25,000 lbs.) and would need to report for the
glycol ethers chemical category.
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TR! REPORTING REQUIREMENTS
Quiz #2 Question 3
3. A facility processes 18,000 lbs. copper sulfate, 10,000 lbs. of cuprous oxide, and
otherwise uses 12,000 lbs. of aqueous sulfuric acid solution in a closed system. For
which TRI chemicals or chemical categories would the facility need to submit a TRI
form?
Select your choice.
A.	copper compounds and sulfuric acid
B.	only copper compounds
C.	only sulfuric acid
Answer: B is correct.
The facility has exceeded the 25,000 lbs. processing threshold for copper
compounds (18,000 + 10,000 = 28,000) and would need to submit a TRI form for
copper compounds. The qualifier for sulfuric acid (see Section 313 ChemicalsJ
indicates that it is only reportable in an aerosol form. Because the facility only used
the sulfuric acid in an aqueous form (and does not generate acid aerosols), it does
not need to consider it towards the otherwise use threshold, and no report for
sulfuric acid is required.
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TRI REPORTING REQUIREMENTS
Quiz #3 Question 1
1. A facility manufactures 100,000 lbs. of a non-PBT Section 313 chemical. They sell
99,950 lbs. as a product. They emit 25 lbs. to the air out of a stack, and send 25 lbs.
off-site for treatment. Do they meet the criteria for submitting a Form A?
Select Yes or No.
YES	NO
Answer: Yes.
The total amount of the chemical manufactured (100,000 lbs.) is below the 1,000,000
lbs. threshold for using Form A. The total annual reportable amount* (50 lbs.) is
below the 500 lbs. threshold.
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TR! REPORTING REQUIREMENTS
Quiz #3 Question 2
2. A facility uses 50,000 lbs. of nitric acid as a cleaner. The entire amount is
neutralized in their on-site wastewater treatment operation and there are no air or
water releases. Do they meet the criteria for submitting a Form A?
Select Yes or No.
YES	NO
Answer: No.
The total amount of the chemical manufactured, processed, or otherwise used
(50,000 lbs.) is below the 1,000,000 lbs. threshold for using Form A. However, the
annual reportable amount* (50,000 lbs.) is greater than the 500 lbs. threshold,
because all 50,000 lbs. of nitric acid are treated onsite. The facility would file a Form
R for nitrate compounds.
3/14/2012
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