Reporting Year 2011 ft
Li i
as
gjS
Emergency Planning + Community RIGHT-TO-KNOW Act (EPCRA) Section 313
SEFA	S'i "
Toxics Release Inventory
Reporting	Require
Advanced Concepts
Note: This program includes audio narration.
Use speakers or headphones for audio. Click Notes button for captions.

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T R I REPORTIN G R E QJJ^ I J^E MENTS
TRI Training Module Agendas
Basic Concepts Module
1.	Introduction
2.	Covered Sectors
3.	Threshold (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.	TRl-MEweb Updates
3/14/2012

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Section I:
Recent TRI Program Changes

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T R I REPORTIN G R E QJJ^ I J^E MENTS
TRI Program Changes for RY 2011
Key program changes and changes to TRI reporting Form R are
listed in the front of the Reporting Forms & Instructions, as well
as ;n TRI-MEweb, and on EPA's TRI website.
RY2008 was the last year that software was offered. Only
TRI-MEweb is offered this year.
3/14/2012
4

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TRI REPORTINGiEQUIREMEN T JL
TRI Reporting Process
Covered Primary
NAICS Code(s) or
Federal facility?
NO
YES
Ten Employees?
(20,000 hrs/yr)
YES
NO
V)
MPOU
Section 313
Chemicals?
MPOU*
Thresholds
Exceeded?
o
-o
*MPOU: Manufacture (including import), process, or otherwise use
3/14/2012
Reporting Thresholds
Met; Form R/Form A
Required

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Section II:
Advanced Reporting Guidance

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Threshold Guidance
3/14/2012
The following activities are not considered "manufacturing," "processing," or
"otherwise use"
¦	Remediation
•	Chemicals being remediated are not manufactured, processed, or otherwise used
•	Chemicals used to remediate waste ARE counted as otherwise used
•	Chemicals manufactured when treating or remediating waste ARE counted toward
manufacturing threshold
¦	Treatment of wastes generated on-site
•	Wastes brought in from off-site for treatment or other management count towards
the otherwise use threshold
¦	Storage
¦	Recycling on-site for use on-site
¦	Transferring chemicals off-site for further waste management
•	Not including recycling. Chemicals sent off-site for recycling are counted as
processed.
These activities do not constitute threshold activities, but are not exempt from
reporting if threshold is exceeded through other activities unless specifically
eligible for one of the reporting exemptions
Chemicals coincidentally manufactured during waste treatment or remediation
must be considered


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Threshold Guidance - Combustion
• Section 313 chemicals may be
coincidentally manufactured during
combustion of:
-	Oil
¦	Coal
-	Natural gas
¦	Waste
¦	Other materials
•	Includes acid aerosols and metal
compounds manufactured as by-products of
fuel combustion
•	Any Section 313 chemicals in fuels combusted for energy are
considered otherwise used.
3/14/2012

8

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Threshold Guidance - Combustion
Reminder:
• Even where your activity s covered by an
"otherwise use" exemption such as motor
vehicle maintenance, if section 313
chemical are manufactured as by-products,
coincidentally as impurities, or otherwise
manufactured, they must be considered
toward the manufacturing threshold.
3/14/2012

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Exemption Guidance
Reminder:
Section 313 chemicals in fuels added to motor vehicles as part of
the facility's service or product do not qualify for the motor
vehicle maintenance exemption
¦ Considered toward processing threshold
Laboratory activities exemption only applies to certain activities
that take place in a laboratory and they must be under the direct
supervision of a technically qualified individual
3/14/2012
10

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T R I REPORTIN G R E QJJ^ I J^E MENTS
	Chemical List Changes
A rule was published on November 26, 2010, adding 16 new chemicals
and chemical compounds to the TRI list of reportable chemicals.
¦ Reporting for these new chemicals is required for Reporting Year 2011
(i.e., for reports due July 1, 2012).
Individual Listings

Chemicals added to the Polycyclic
Aromatic Compounds (PACs) category
Chemical Name
CAS#
Chemical Name
CAS#
1-Amino-2,4-dibromoanthraquinone
81-49-2
1,6-Dinitropyrerie
42397-64-8
2,2-bis(Bromomethyl)-1,3-propanediol
3296-90-0
1,8-Dinitropyrene
42397-65-9
Furan
110-00-9
6-Nitrochrysene
7496-02-8
Glycidol
556-52-5
4-Nitropyrene
57835-92-4
Isoprene
78-79-5


Methyleugenoi
93-15-2


o-Nitroanisole
91-23-6


Nitromethane
75-52-5


Phenolphthalein
77-09-8


T etrafluoroethylene
116-14-3


Tetrariitromethane
509-14-8


Vinyi Fluoride
75-02-5


3/14/2012
11

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Chemical List Changes
On October 17, 2011, the 1994
administrative stay for TRI reporting for
hydrogen sulfide (H ,S) was lifted (76
FR 64022). H2S reporting will be
effective for Reporting Year 2012, for
Form R reports due to the Agency on
July 1,2013,
3/14/2012

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Metals and Metal Compound Category
Elemental metals (metals in their neutral state) and their
corresponding metal compound categories are listed separately
under Section 313
¦	Separate activity threshold determinations
¦	Report for each listing (e.g., nickel or nickel compound) only if
the threshold for each listing is exceeded
¦	If threshold exceeded for both the elemental metal and metal
category compound (e.g., nickel and nickel compounds), you
may report separately or file one combined report
•	If combined, file as metal category compound
•	The reason both the elemental metal and its compound may be
reported on the same compound form is that while the entire
weight of the compound is used to determine the threshold, only
the amounts of the parent metal are reported.
3/14/2012
13


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Metal Cyanide Compounds Guidance
A metal cyanide compound, such as cadmium cyanide, requires
separate reporting under both cadmium and cyanide*
¦ For report the metal compounds, such as cadmium
compounds:
•	for threshold determinations, use entire weight of compound
•	for release and other waste management reporting, report only
the weight of metal portion of the compound
¦ For cyanide compounds
•	for threshold determinations, use weight of entire compound
•	for release and other waste management reporting, report
weight of entire compound


* Qualifier for cyanide compounds states: X+CN", where X=H+ or any other group where a formal
dissociation may occur. For example, KCN or Ca(CN)2


3/14/2012

14
TRI

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Nitrate Compounds
Water dissociable nitrate compounds category
¦	Reportable only when in aqueous solution
¦	For threshold determinations, use weight of entire nitrate
compound
¦	Calculate only weight of nitrate ion portion when reporting
releases and other waste management quantities on Form R
¦	Nitrate compounds are produced most commonly when nitric
acid is neutralized or in biological treatment of wastewater
¦	Exemption may apply for nitrates in intake water (used for
processing or non-contact cooling)
3/14/2012
15

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Quiz #4 Question 1
1. A facility processes 200,000 lbs. of a mixture containing 10% zinc
chromate (ZnCr04) and 15% chromium dioxide (Cr02) by weight.
For which of the following chemical categories was the processing
threshold exceeded?
A. Chromium compounds only
B.
Zinc compounds only


C.
Neither


D.
Both





16


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T R I REPORTIN G R E QJJ^ I J^E MENTS
Quiz #4 Question 2
2. A facility neutralizes 20,000 lb of nitric acid (HN03) with sodium
hydroxide (NaOH) in an on-site wastewater treatment system.
The neutralization is 100% complete and generates sodium
nitrate (NaN03), which is discharged to a nearby water body.
The molecular weight (MW) of HN03 = 63 and the MW of NaNOs
= 85. 1 mole of HN03 generates 1 mole of NaN03.
Does the facility exceed the manufacturing threshold for nitrate
compounds?
YES
NO

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Quiz #4 Question 3
3. A facility neutralizes 20,000 lb of nitric acid (HN03) with sodium
hydroxide (NaOH) in an on-site wastewater treatment system.
The neutralization is 100% complete and generates sodium
nitrate (NaN03), which is discharged to a nearby water body.
The molecular weight (MW) of HN03 = 63 and the MW of NaN03
= 85. 1 mole of HN03 generates 1 mole of NaN03.
In this example, should the facility report release of 27,000 lb of
nitrate compounds as to a stream or water body? (Section 5.3
on Form R)?
YES
NO

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Ammonia Guidance
Ammonia
Aqueous ammonia - threshold
determination and release and other
waste management quantity calculations
for aqueous ammonia from any source
(i.e., anhydrous ammonia placed n water
or water dissociable ammonium salts) is
based on 10% of the total ammonia
present in aqueous solutions
Anhydrous ammonia - include 100% for
thresholds and releases
• Including air releases from aqueous
ammonia
Amounts from aqueous sources and
anhydrous sources get added together
for threshold determinations and
ammonia reports
3/14/2012

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Acid Aerosols
Hydrochloric and sulfuric acids have a chemical qualifier...they
are reportable only if in the aerosol form.
¦	These aerosols are common combustion products of coal and
other fuels combustion (includes mists, vapors, gas, fog, and
other airborne forms of any particle size)
Threshold determination for closed-loop acid reuse systems
(sulfuric and hydrochloric acid only).
¦	Acid aerosol manufactured and otherwise used
¦	To determine whether you have exceeded a threshold for acid
aerosols in a closed-loop acid reuse system:
* See EPA's Guidance for Reporting Sulfuric Acid and Guidance for Reporting Hydrochloric
Acid for specific calculations
Total Amount
of Acid in
Reuse System
Total Virgin
Acid Added
in RY
Amount Acid
Aerosols
Manufactured/
Otherwise Used
—_—_
ninssed-l nop
e
r—	*

3/14/2012
20

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TRI REPORTING REQUIREMEN T S
Chemical Migration Guidance
Migration of a Section 313 chemical contained in waste reported
as disposed or released in previous years:
¦	For example, leachate from landfill
¦	Report only the initial release of chemical to the environment
Year 1
2,000 lbs to surface impoundment
(Form R, Section 5.5.3B)
A
Year 2
500 lbs leachate in year 2
Not reported on Year 2 Form R
Leachate
3/14/2012

21

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TRI REPORTING REQUIREMEN T S
Chemical Migration Guidance
Migration of a Section 313 chemical contained in waste disposed or
released from one environmental medium to another within the
reporting year:
¦	For example, volatilization from a landfill
¦	Release estimates must be calculated and reported for all media in
Part II, Sections 5, 6, and 8 of Form R
Year 1
2,000 lbs to surface impoundment
(Form R: 1,000 lbs in Section 5.5.3B)
Year 1
1,000 lbs to air
(Form R: 1,000 lbs in Section 5.1)
3/14/2012

22

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T R I REPORTIN G R E QJJ^ I J^E MENTS
EPA Self-Disclosure Audit Policy
Audit Policy enhances environmental protection through
incentives for companies to self-police, disclose and correct
violations
Facilities that meet all 9 conditions of
the Audit Policy shall have 100% of the
gravity based penalty waived. However,
EPA reserves the option to collect any
significant economic benefit which may
have been realized by the facility.
In the last five years alone, over 2,600 entities have self-
disclosed violations at over 7,000 facilities under EPA's
Compliance Incentive Policies.
3/14/2012
23

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E PA Self-D isclos ure Audit Pol icy
Conditions to qualify (nine criteria):
¦	Systematic Discovery of the Violation through Environmental Audit or
Due Diligence
¦	Voluntary Discovery
¦	Prompt Disclosure
¦	Discovery and Disclosure Independent of Government or Third Party
Plaintiff
¦	Correction and Remediation

¦	Prevent Recurrence
¦	No Repeat Violations
¦	Other Violations Excluded
¦	Cooperation


•
For more information, including a copy of the Audit Policy visit:
¦ www.eDa.aov/comDliance/incentives/auditina/auditDolicv.html


3/14/2012


24
¦m ll 1
11 111

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T R I REPORTIN G R E QJJ^ I J^E MENTS
EPA Small Business Compliance Policy
Similar to Audit Policy, but available only to small businesses
¦	Small businesses employ 100 or fewer ndividuals across all facilities
and operations
Small businesses that meet all 4 conditions of the policy may have
100% of the gravity based penalty waived. However, EPA reserves
the option to collect any significant economic benefit which may have
been realized by the facility.
Conditions to qualify (four criteria):
¦	Good Compliance Record
¦	Voluntary Discovery
¦	Prompt Disclosure
¦	Correction and Remediation
For more information, including a copy of the Small Business
Compliance Policy and a Q&A document, visit:
¦	www.epa.gov/compliance/incentives/smallbusiness/index.html
3/14/2012
25

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Audit Policy: Incentive for New Owners
Federal Register notice published August 2008
Offers incentives for new owners of facilities that want to make a
"clean start" by addressing environmental noncompliance that
began prior to acquisition.
¦	Penalty mitigation beyond what the Audit Policy generally
provides
¦	Modification of certain Audit Policy conditions
For a detailed description of how EPA will apply the Audit Policy to
new owners of regulated facilities, visit:
www.epa.gov/compliance/incentives/auditinq/newowners-
incentives.html
3/14/2012
26

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EPCRA Section 313 Enforcement
Non-federal facilities (including GOCOs) violating any statutory or
regulatory requirement are subject to penalties of up to $37,500 per day
per violation (periodically adjusted for inflation)
Companies subject to citizen suits and could also be liable for attorney
fees and litigation costs (EPCRA § 326(f))
Government's penalty for Section 313 of EPCRA is determined by
applying the Enforcement Response Policy (ERP) to each violation
For EPA's EPCRA enforcement policies, visit:
http://cfpub.epa.gov/compliance/resources/policies/civil/epcra/index.cfm
3/14/2012	27

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Section III: :< 9g|ltf_
Detailed PBT Guidance

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T R I REPORTIN G R E QJJ^ I J^E MENTS
PBT Chemicals
•	Aromatics - Benzo(g,h,i)perylene, Dioxin and dioxin-like compounds
category, Hexachlorobenzene, Octachlorostyrene, Pentachlorobenzene,
Polycyclic aromatic compounds (PAC) category, Polychlorinated
biphenyl (PCB), and Tetrabromobisphenol A (TBBPA)
•	Metals - Mercury, Mercury compounds category, Lead, and Lead
compounds category
•	Pesticides - Aldrin, Chlordane, Heptachlor, Isodrin, Methoxychlor,
Pendimethalin, Toxaphene, Trifluralin
•	PBT chemicals are subject to separate and lower reporting thresholds
and different reporting requirements than the other TRI chemicals
¦	Must use Form R (cannot use Form A)
¦	Quantities can be reported in decimal amounts
¦	Cannot use range codes
¦	Cannot use the de minimis exemption
3/14/2012
29

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Dioxin and Dioxin-l ke Compounds
PBT activity threshold for dioxins = 0.1 gram manufactured,
processed, or otherwise used for the entire reporting year!
Dioxins formed as unwanted byproducts when chlorinated
materials nvolved n combustion or other high-temperature
processes, such as:
Fossil fuel and wood combustion
¦ Waste incineration
Metallurgical processes
What it takes to exceed the 0.1 gram activity threshold?
64,500 tons of coal combusted in a utiIIIity boiler
8.33 million gallons of fuel oil combusted in a utility boiler
1,230 tons copper scrap fed to a secondary copper smelter
3/14/2012
30

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Dioxin and Dioxin-lke Compounds
Dioxin and Dioxin-like Compounds Toxicity Equivalency (TEQ)
Information Rule:
¦	Final rule issued May 10, 2007 (72 FR Page 26544), in effect since RY2008
¦	In addition to the total mass grams released for the entire chemical category,
facilities that have the data are required to report the quantity of each of the
17 members in the dioxin category on a Form R Schedule 1
¦	Speciated values reported in Schedule 1 must add up to values reported on
the Form R
¦	Data is used to calculate TEQ values that are made available to the public
along with the mass data
¦	TRI-MEweb can provide a report showing reported gram values converted
into TEQ values
• In calculating TEQ, EPA uses Toxic Equivalency Factors (TEFs) developed by
the World Health Organization in 2005
(http://www.who.int/ipcs/assessment/tef update/en/)
¦	Be aware that in RY2008 the order of the 17 members of the dioxin category
changed on the Schedule 1
3/14/2012

31

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Dioxin and D oxin-l uke Compounds
•	Dioxin and dioxin-like compounds are measured based on the
individual compounds within the category - not as a total quantity.
•	Emission factors for dioxin and dioxin-like compounds are based
on emission factors for individual compounds within the category.
•	As a result, the information required on Form R Schedule 1
should be available to facilities that file Form R reports for the
dioxin and dioxin-like compounds category
32

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Lead and Lead Compounds
Raw materials processed by a variety of facilities may contain
metallic lead or lead compounds:
¦	Metal ores
¦	Coal
¦	Wood
¦	Oil & Oil products: heating oils, gasolines
Lead used in solder and other alloys is in the elemental NOT the
compound form (i.e., this is lead, not a lead compound)
Lead-acid batteries will typically meet the articles exemption
Sending old paint containing lead off-site for disposal or
treatment is not a threshold activity
Other sources of lead and lead compounds for PBT threshold:
¦	Lead solder, lead babbitt, castings/molds, contaminants of
aluminum and other common base alloys, X-Ray film
¦	Cement, asphalt, graphite brushes, leaded glass
¦	Transfers of lead and lead compounds off-site for recycling
3/14/2012
33

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Lead and Lead Compounds
PBT activity threshold for lead and lead compounds:
¦	100 pounds for lead (not contained in stainless steel, brass, or bronze)
¦	100 pounds for lead compounds
Non-PBT activity threshold for lead:
¦	Non-PBT thresholds apply to lead contained in stainless steel, brass,
or bronze*
•	25,000 lbs for manufacture or process
•	10,000 lbs for otherwise use
*lf elemental lead is removed from the qualified alloy, such as vaporization during melting of an alloy,


the 100 lb threshold applies


3/14/2012

34
TRI

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Lead Threshold Determination Flow Chart
Activity thresholds and reporting requirements for lead related to
stainless steel, brass or bronze alloy qualifier
* This flowchart does
not apply to Lead
Compounds, a
separately listed
TRI chemical
YES r
NO
YES
NO
Did the facility exceed the 100 lb.
threshold considering only lead not in
stainless steel, brass or bronze
alloy?
Did the facility exceed the 100 lb.
threshold considering only lead not in
stainless steel, brass or bronze
alloy?
Did the facility exceed the 25,000/10,000 lb. threshold,
considering lead in stainless steel, brass or bronze alloy1 AND
lead not stainless steel, brass or bronze alloy?
1 The de minimis exemption may be considered for quantities of the lead in
stainless steel, brass or bronze alloy
May use Form R, without
range reporting in Sections 5
and 6 of Part II.
Only required to report
releases and transfers of lead
not in stainless steel, brass,
or bronze alloy.
No reporting for
lead required
Must use Form R, without
range reporting in Sections 5
and 6 of Part II.
Report releases and transfers
from BOTH lead in stainless
steel, brass, or bronze alloy
and lead not in stainless steel,
brass, or bronze alloy.
1
May use Form A2 or R; range
reporting can be used in
Sections 5 and 6 of Part II
Report releases and transfers
from BOTH lead in stainless
steel, brass, or bronze alloy
and lead not, in stainless steel,
brass, or bronze alloy.
2 Must meet additional requirements for Form A use.
3/14/2012	35


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Quiz #6 Question 1
1. A facility combusts 13,600,000 lbs. of coal to fire its boilers. The coal
contains elemental lead (Pb) at 7.0 ppm by weight. In combusting
the coal, the facility otherwise uses lead and coincidentally
manufactures lead compounds. The facility has no other information
about the chemical makeup of the lead compounds manufactured
and assumes it is the lowest-weight oxide - PbO. Based on
molecular weights (Pb = 207, PbO = 223), the facility knows that 223
lbs. of PbO is formed for every 207 lbs. Pb combusted.
Which of the following thresholds have been exceeded for lead or

lead compounds?

A. Otherwise Use only

B. Manufacturing only

C. Neither

D. Both Answer


36


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T R I REPORTIN G R E QJJ^ I J^E MENTS
Quiz #6 Question 2
2. A facility processes two alloys that include lead, a stainless steel
alloy with 20,000 lbs. of lead, and another alloy, which is not
stainless steel, brass, or bronze, with 275 lbs. of lead.
Which of the following processing thresholds have been exceeded?
A.	Only the 25,000 lbs. processing threshold for total lead
B.	Only the 100 lbs. threshold for lead not in stainless
steel, brass, or bronze
C.	Neither
D.	Both

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PACS and Benzo(g,h,i)perylene
PBT activity threshold
¦	PAC category threshold: 100 pounds
¦	Benzo(g,h,i)perylene threshold: 10 pounds
•
Present in coal, fuel oil, other petroleum products, such as asphalt
and roofing tars
•
Asphaltic concrete (blacktop) typically contains 4 -10% paving
asphalt
•
Most uses of blacktop are NOT EXEMPT

¦ Process areas and roadways - NOT EXEMPT

¦ Employee parking lot - EXEMPT
•
See also EPA's PACs guidance
(www.epa.aov/tri/auide docs/pdf/2001/oacs2001 .pdf)
3/14/2012
38
TRI

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T R I REPORTING REQU IJLE MENTS
PACs (cont.)
• Quantity required to meet threshold
Fuel Material
Typical Concentration
Quantity Needed to Meet
Threshold (gallons)
No. 6 Fuel Oil (Bunker C)
2461 ppm
5,140
No. 2 Fuel Oil
10.0 ppm
1,410,000
Crude Oil
depends on type of crude

Gasoline
17 ppm
1,060,000
Paving Asphalt
178 ppm
51,800
From EPA's Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds Category
3/14/2012
39

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Mercury and Mercury Compounds
PBT activity threshold:
10 pounds for mercury
10 pounds for mercury compounds
Combustion of fuels is expected to be a main source of mercury
triggering a reporting threshold
Combustion involves the otherwise use of mercury compounds
in fuel, and the manufacture of elemental mercury
Amount of fuel required to exceed a threshold
No. 2 Fuel Oil: 1.41 x 109 gallons
Coal: 11,000 - 120,000 tons
No. 6 Fuel Oil: 1.89 x 109 gallons

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Mercury and Mercury Compounds
Present in some switches and lights
Bulbs and switches may qualify as articles for which the
articles exemption would apply IF less than 0.5 pound of
Section 313 chemicals are released from all like items as a
result of processing or use of the items during the year
Mercury may be present in measurement devices such as
thermometers or manometers. The addition of mercury to these
devices needs to be considered in threshold and release
calculations.
Present in Caustics/Acids (if produced in mercury cell process -
not common)
May be present in mined ores
3/14/2012
41

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Polychlorinated Biphenyls (PCBs)
PBT activity threshold: 10 pounds
Manufacturing: PCBs may be manufactured as a product of
incomplete combustion (PIC)
Otherwise use:
On-site treating or disposing PCB-contaminated waste

received from off-site



Combusting PCB-contaminated oil


3/14/2012


42


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Polychlorinated Biphenyls (PCBs)
NOT manufacturing, processing, or otherwise use
On-site disposal or treatment of PCBs
• Exception: if PCBs were received as wastes from off-site they are
counted towards "otherwise use" threshold
Off-site shipment of PCBs for disposal or treatment
Transformers containing PCBs may be considered articles and thus
exempt from consideration towards reporting and release thresholds
for PCBs.
Leaks may negate article exemption if 0.5 lbs of PCBs are
released in a reporting year.
3/14/2012
43

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Reference Sources
EPA Industry Guidance located at
www.epa.gov/tri/quide docs/
AP-42: Compilation of Air Pollutant Emission Factors located at
www.epa.gov/ttn/chief
Technology Transfer Network located at www.epa.gov/ttn
- AP-42
¦ WATER9 program
TANKS program
Perry's Chemical Engineer's Handbook; CRC Handbook of
Chemistry and Physics; Lange's Handbook of Chemistry
3/14/2012
45

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TRI REPORTIN G R E Q U IJLE MENTS
Pollution Prevention Information
OPPT Pollution Prevention (P2)
¦	www.epa.gov/opptintr/p2home/index.htm
Pollution Prevention Information Clearinghouse (PPIC)
- (202) 566-0799
¦	www.epa.gov/opptintr/ppic/index.htm

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TRI Contact Information
TRI Technical Support
¦	For technical questions related to
TRI-MEweb and the Central Data
Exchange (CDX), please contact the
CDX Hotline at helpdesk@epacdx.net or
call toll-free at (888) 890-1995.
TRI Information Center
¦	Provides a toll free number that
facilities may call to obtain guidance on
TRI reporting requirements and help on
completing the TRI reporting forms.
¦	The number is (800) 424-9346. Callers
in the Washington, D.C. metropolitan
area call (703) 412-9810. The TDD is
(800) 553-7672.

3/14/2012

47

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T R I REPORTIN G R E QJJ^ I J^E MENTS
TRI-Data Processing Center
For hand courier, certified mail, Fed Ex, UPS delivery:
CGI Federal, Inc.
c/o EPA Reporting Center
12601 Fair Lakes Circle
Fairfax, VA 22033
For regular mail:
TRI Reporting Center
P.O. Box 10163
Fairfax, VA 22038
3/14/2012
48

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T R I REPORTIN G R E QJJ^ I J^E MENTS
Benefits of TRI-MEweb and Submitting Via CDX
TRI forms can be filled from any computer that has an Internet
connection
It saves time and money
Using TRI-MEweb significantly reduces reporting errors
TRI-MEweb has integrated TRI Assistance Library
EPA provides instant email confirmation of transmitted and certified
submission
Electronic Signature allows for quick, paperless submissions
IMPORTANT: TRI-ME desktop software is no longer available. EPA
only supports TRI-MEweb.
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Benefits of TRI-MEweb 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.
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Section V:
TRI-MEweb Updates

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T R I REPORTING REQU IJLE MENTS
TRI-MEweb Features
Fully supports dioxin Form R/Schedule 1 reporting and provides
calculated TEQ values for these forms
Fully supports "Reporting By Part"
Allows reporting for first-time filers and provides instant TRIFID
identification for new facilities
Supports original and revised reporting for RY2005 - 2010
Generates submission diskettes for state reporting
Ability to upload third party vendor data using TRI-MEweb XML
schema to allow quicker multi-chemical data uploads.
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Important Notices on
TRI-MEweb requires new certifiers to register with the Central Data
Exchange (CDX) prior to being able to certify TRI-MEweb forms.
¦	Registration includes creating, signing, and sending an electronic
signature agreement (ESA) to the TRI data processing center
¦	This process is estimated to take a minimum of 5 business days
¦	Submission of the ESA is one time only as long as the certifier
represents the facility
¦	EPA recommends that facilities using TRI-MEweb register their
certifier immediately upon accessing the application
¦	For more information about TRI-MEweb, please visit:
www.epa.gov/tri/report/software/index.htm
• EPA's CDX recently changed from SSL encryption to TLS
encryption.
¦	If users are not able to access the CDX or TRI-MEweb due to a
security setting issue, change security settings in the web browser.
¦	If using "Internet Explorer," in "Tools" menu, select "Internet
Options." Under the "Advanced" tab, scroll to the bottom and check
the "Use TLS 1.0" box.
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TRI-MEweb Registration (Preparer)
Preparer Registration Decision Tree
Person Identified as a
Preparer
i
I
Yes
No
Do you have a CDX
account?
Yes
Do you have a TRI-
MEweb Preparer
Role?
No
Create a CDX Account
with the TRI-MEweb
Preparer Role
Add TRI-MEweb
Preparer Role to CDX
Account
Log into CDX at
https:cdx.epa.gov
Select "TRI-MEweb:
Prepare Submission"
and enter access key
to get facility data
Note: For more information, see the TRI-MEweb Tutorials at www.epa.aov/tri
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T R I REPORTIN G R E QJJ^ I J^E MENTS
TRI-MEweb Registration (Certifier)
Certifier Registration Decision Tree
Person Identified as a
Certifier
I
Yes
Do you need to add a
new TRIFID to your
Certifier Account?
No
Do you have a CDX
account?
Yes
Do you have a TRI-
MEweb Certifier Role?
No
Create a CDX Account
with the TRI-MEweb
Certifier role
Add TRI-MEweb
Certifier Role to CDX
Account
Yes
Add TRIFID to Certifier
Role
No
Log in at
https://cdx.epa.gov and
certify awaiting forms
Note: For more information, see the TRI-MEweb Tutorials at www.epa.aov/tri
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TRI-MEweb Tutorials
TRI-MEweb has integrated on-line tutorials to assist users with
common functions in the application,
¦	Tutorials cover areas such as
•	Overview
•	Registration
•	Accessing Your Facility
•	Nominating a Certifying Official
•	Section 8 Calculator
•	Submitting Data
•	Certifying Data
•	Getting Help
The tutorials can be viewed at:
¦	www.epa.gov/tri/report/software/index.htm
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TBI
56

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T R I REPORTIN G R E QJJ^ I J^E MENTS
	www.epa.gov/tri
TRI website for reporting materials and guidance
Includes:
¦	Electronic versions, or links to electronic versions, of the statutes,
regulations, executive orders, chemical-specific guidance
documents, and industry-specific guidance documents
TRI Frequently Asked Questions (FAQ) Service
¦	Browse frequently asked questions and answers
¦	Submit new questions
¦	Access to the service is available from the TRI Web site:
www.epa.gov/tri/. Click on "Frequent Questions" on the left side
menu bar.
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Facility Data Profiles
Review your Facility Data Profile (FDP) immediately
FDP provides an opportunity to review data submitted to EPA
Allows EPA to highlight errors and possible issues with your
submission
You MUST provide a Technical Contact email address on your TRI
forms to receive real-time notification of FDP availability
Use TRI-MEweb to receive your FDP sooner (than paper submissions)
If you have problems accessing your FDPs, contact:
¦	E-mail: tri.efdp@epacdx.net
¦	Web: www.triefdp.org
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Revising TRI Data - Preferred Method
•	The preferred method for submitting revised TRI forms is
TRI-MEweb, through the Internet via EPA's CDX.
•	For more information regarding revisions, go to:
¦	www.epa.qov/tri/report/index.htm#revise
•	For states that participate in the TRI Data Exchange (TDX),
submitting via CDX to EPA will also satisfy your state obligations.
For states that do not participate in TDX, revisions must also be
submitted in the state-specified format (e.g., diskette, paper,
etc.)To determine if your state is CDX capable go to:
¦	www, e pa. q ov/tri/sta ke ho I de rs/state/state exchange/
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Withdrawing TRI Data - Preferred Method
Submitting a withdrawal TRI form, using TRI-MEweb, through
the Internet via EPA's CDX, is the preferred method for RY2005
- 2010
For more information regarding withdrawals, go to:
¦ www.epa.gov/tri/report/reviseandwithdrawl/withdraw TRI data,
pdf
Please be aware if your state is a TRI Data Exchange (TDX)
participant, submitting to EPA via CDX will also satisfy your
state obligations. For states that are not TDX participants,
withdrawals must also be submitted in the state-specified format
(e.g., diskette, paper, etc.)
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Submitting Withdrawals
Withdrawals can be made through the reporting software or in
hardcopy
¦	RY2007 forward: You may submit a photocopy of your original
submission (from your file). Using blue ink, re-sign and re-date
the certification statement on Page 1 and enter appropriate
withdrawal code(s) in space on page 1 of the form.
¦	RY2006 and prior years: Please submit a photocopy of the
form you wish to withdraw (from your files), and attach - as a
cover page - page 1 of the current year's reporting form, which
includes a field for the withdrawal codes. Using blue ink,
please sign and date the certification statement and enter
appropriate withdrawal code(s) in space on page 1 of the
current year's form.
EPA may audit withdrawals at any time
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T R I REPORTIN G R E QJJ^ I J^E MENTS
Submitting Revisions and Withdrawals
Form R submitted to replace previously filed Form A Certification
Statement
Considered to be a late submission of a Form R and a request for a
withdrawal of the previously filed Form A Certification Statement
Do not check the revision box!
¦ Note that submitting a Form A when a Form R is required s
considered a less severe violation than failing to submit either form
(cfpub.epa.gov/compliance/resources/policies/civil/epcra/index.cfm)
For a change in chemical reported (including a metal to a metal
compound) you must withdraw the original submission and re-submit
for the new chemical. This is not a revision.
See www.epa.qov/tri/report/index.htm#revise
for more information on revisions and withdrawals
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TRI-MEweb Demo
If you are viewing an Online Training Module,
please visit www.epa.aov/tri to view the
TRI-MEweb tutorials.
3/14/2012

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