Reporting Year 2017 \ Emergency Planning + Community RfSMT?T|b-KNOW Act (EPCRA) Section 313 Toxics Release Reporting Requ Advanced Concepts ------- T RJ_ REP ORTING REQUIREMENTS TRI Training Module Agendas Basic Concepts Module 1. Introduction 2. Covered Sectors 3. Threshold (RETT and Non-PBT) 4. Reporting Exemptions 5. Threshold Determinations 6. Overview of Form R 7. Alternate Threshold Rule (Form A) 8. TRI-MEweb Introduction Advanced Concepts Module 1. Recent TRI Program Changes 2. Advanced Reporting Guidance 3. Detailed PBT Guidance 4. Tools and Assistance 5. TRI-MEweb 2 ------- TRI Reporting Requirements Covered Primary NAICS Code(s) or Federal facility? "MPOU: Manufacture (including import), process, or otherwise use ------- I R_L REP ORTING REQUIREMENTS 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 T 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 I Complete Final QA/QC I Certify Form 4 Submit to EPA & State or Tribe ------- Sectfonjlr- ¦ &' i fi f Recent TRfT^fograhi^hanges ------- T RJ_ REP ORTING REQUIREMENTS TRI Program Changes for RY 2017 Key program changes and changes to TRI reporting Form R are listed in the front of the Reporting Forms & Instructions, as well as in TRI-MEweb, and on EPA's TRI website. A rule was published on December 26, 2017, adopting the 2017 North American Industry Classification System (NAICS) codes for TRI reporting. Facilities should refer to the 2017 NAICS codes when completing TRI reporting forms. 6 ------- T RJ_ REP ORTING REQUIREMENTS Chemical List Changes A rule was published on November 28, 2016, adding hexabromocyclododecane (HBCD) category to the TRI list of reportable chemicals • Facilities that manufacture, process or otherwise use HBCD must submit reports for this chemical category by July 1, 2018 on data for Reporting Year 2017 • https://www.epa.qov/toxics-release-inventorv-tri-proqram/addition-hexabromocvclododecane- hbcd-cateqorv-tri-list-final A rule was published on November 23, 2015, adding 1 -bromopropane to the TRI list of reportable chemicals • Facilities that manufacture, process or otherwise use 1-bromopropane that meet manufacture, process, otherwise use and other threshold criteria submitted reports on this chemical starting in Reporting Year 2016 • http://www2.epa.gov/toxics-release-inventorv-tri-proqram/addition-1-bromopropane A rule was published on September 30, 2014, adding a nonylphenol category to the TRI list of reportable chemicals Facilities that manufacture, process or otherwise use nonylphenol began submitting chemical reports to the Agency for Reporting Year 2015 http://www2.epa.qov/toxics-release-inventorv-tri-proqram/addition-nonvlphenol-cateqorv 7 ------- Electronic Reporting to TRI • Facilities are required to report all non-trade secret TRI data to EPA using the TRI-MEweb online reporting application • To revise or withdraw a previously-submitted TRI reporting form, facilities need to use TRI-MEweb to do so electronically • Facilities may submit, revise, or withdraw TRI forms going back to reporting year (RY) 1991 8 ------- Section 4fo IM Advanced Reporting Guidance ------- T RJ_ REP ORTING REQUIREMENTS Non-PBT TRI Chemical Activity Thresholds A facility meeting the first two applicability criteria for reporting 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 Most of the 650+ chemicals and chemical categories on the Section 313 list are non-PBT chemicals. 10 ------- T RJ_ REP ORTING REQUIREMENTS PBT Chemicals and Activity Thresholds • PBT chemicals are subject to separate and lower activity thresholds (See 40 CFR § 372.28) ¦ 100 Ib/yr (manufactured, processed, or otherwise used) • Aldrin •Pendimethalin • Hexabromocyclododecane •Polycyclic Aromatic Cmpds. • Lead* •Tetrabromohisphenol A •Trifluralin 2 r\ • Lead Cmpds. U (/) • Methoxychlor Q) L_ ¦ 10 Ib/yr (manufactured, processed, or otherwise used) H • Chlordane •Benzo(g, h, ijperylene h QQ • Heptachlor •Hexachlorobenzene Q_ • 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 ------- T RJ_ REP ORTING REQUIREMENTS Threshold Guidance 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 s exceeded through other activities unless specifically eligible for one of the reporting exemptions Chemicals coincidentally manufactured during waste treatment or remediation must be considered ------- 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. 13 ------- Exemption Guidance Reminder: Even where your activity is 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. 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 14 ------- T RJ_ REP ORTING REQUIREMENTS 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 For metal compounds calculations: Use full compound mass for threshold determination Use only parent metal mass for release and waste quantities ¦ 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. 15 ------- T RJ_ REP ORTING REQUIREMENTS Metal Cyanide Compounds Guidance A metal cyanide compound, such as cadmium cyanide, requires separate reporting under both cadmium and cyanide* ¦ For reporting 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 ------- Nitrate Compounds Qualifier: "Water dissociable; 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 Common nitrate compounds sources ¦ Nitrate compounds are produced most commonly when nitric acid is neutralized or in biological treatment of wastewater ¦ Nitrate compound releases to surface water may result from storm water run off ¦ Exemption may apply for nitrates in intake water (used for processing or non-contact cooling) 17 ------- T RJ_ REP ORTING REQUIREMENTS Quiz #1 Question 1 A facility processes 200,000 lb of a mixture containing 10% zinc chromate and 15% chromium dioxide 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 18 ------- T RJ_ REP ORTING REQUIREMENTS Quiz #1 Question 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 NaN03 = 85. One mole of HN03 generates one mole of NaN03. Does the facility exceed the manufacturing threshold for nitrate compounds? Select Yes or No. 19 ------- T RJ_ REP ORTING REQUIREMENTS Quiz #1 Question 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. One mole of HN03 generates one mole of NaN03. The MW of the nitrate ion N03 = 62. 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)? Select Yes or No. 20 ------- 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 in 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 21 ------- I R_L REP ORTING REQUIREMENTS 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 reuse systems that generate acid aerosol. ¦ Acid aerosols are manufactured and otherwise used ¦ Applicable for sulfuric and hydrochloric acid only Total Amount of Acid in Reuse System Total Virgin Acid Added in RY Amount Acid Aerosols Manufactured/ Otherwise Used * See EPA's Guidance for Reporting Sulfuric Acid and Guidance for Reporting Hydrochloric Acid for specific calculations 22 ------- 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, volat lization 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) iff k 199 23 ------- I R_L REP ORTING REQUIREMENTS 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) Year 2 500 lbs leachate in year 2 Not reported on Year 2 Form R 24 ------- T RJ_ REP ORTING REQUIREMENTS EPA Compliance Incentives The Agency implements policies that reduce or waive penalties under certain conditions for facilities that discover, disclose, correct and prevent future violations. Current Compliance Incentive Policies, Guidance and Audit Protocols can be found by visiting: http://www.epa.gov/compliance/audit-protocols 25 ------- T R_L REP ORTING REQUIREMENTS EPA Self-Disclosure Audit Policy Conditions to qualify (nine criteria): ¦ Systematic Discovery of the Violation through Environmental Audit or the Implementation of a Compliance Management System ¦ 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 nformation, including a copy of the Audit Policy visit: www.epa.gov/compliance/epas-audit-policv 26 ------- E PAS ma 11 Business Compliance Pol icy EPA Compliance Incentive Policy 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/small-business-compliance 27 ------- T R_L REP ORTING REQUIREMENTS Revising TRI Data • Revised TRI data that are not trade-secret must be submitted using TRI- MEweb through the Internet via EPA's CDX. You may only revise back to RY 1991 • If your state or tribe participates in the TRI Data Exchange (TDX) then submitting via CDX to EPA will also satisfy your obligation to report to the state or tribe in which your facility is located if the revision is for RY 2005 through the present reporting year. Otherwise, revisions must also be submitted n the state- or tribe-specified format. To determine if your state or tribe is in TDX go to: http://www2.epa.gov/toxics-release- inventorv-tri-proqram/tri-data-exchange r - * * 28 ------- Withdrawing TRI Data You must use TRI-MEweb to withdraw a TRI form (except for trade secrets). You may withdraw forms back to RY 1991 For more information regarding withdrawals, go to the following tutorial: https://www3.epa.gov/tri/tutorials/TRIT-33/ Please be aware if your state or tribe is a TRI Data Exchange (TDX) participant, submitting to EPA via CDX will also satisfy your state obligations for reporting years back to 2005. For states or tribes that are not TDX participants, withdrawals should also be submitted in the specified format for the state/tribe 29 ------- Submitting Revisions and Withdrawals Form R submitted to replace previously filed Form A Certification Statement ¦ Must withdraw the previously filed Form A Certification Statement and then submit a Form R. The Form R s considered to be a late submission if submitted after the reporting deadline 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. EPA may audit revisions or withdrawals at any time. 30 ------- EPCRA Section 313 Enforcement Owners and operators of covered facilities violating any statutory or regulatory requirement are subject to penalties of up to $37,500 per day per violation (periodically adjusted for inflation) Owners and operators of covered facilities subject to citizen suits 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 statutory penalty factors as described in 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 31 ------- SectidfiJJJ* V i i I m- Detailed PBT Guidance ------- PBT Chemicals • Organic Compounds - Benzo(g,h,i)perylene, Dioxin and dioxin-like compounds category, Hexabromocyclododecane, 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 33 ------- Dioxin and Dioxin-like Compounds Dioxin and dioxin-like compounds are reported in grams The manufacture, process, or otherwise used activity thresholds are 0.1 gram Dioxins formed as unwanted byproducts when chlorinated materials involved in 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 utility boiler 8.33 million gallons of fuel oil combusted in a utility boiler 1,230 tons of copper scrap fed to a secondary copper smelter 34 ------- Dioxin and Dioxin-like Compounds Dioxin and dioxin-like compounds category is composed of 17 individually listed compounds 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 individual members, which must add up to the total mass for the category Dioxin and Dioxin-like Compounds Toxicity Equivalency (TEQ) Each compound has an assigned Toxic Equivalency Factors (TEFs) that is multiplied with the compound mass to yield TEQ TEQ for each of the compounds are summed to provide a category TEQ TEQ values are made available to the public along with mass data Emission factors, listed compounds, TEFs and other guidance: www.epa.qov/toxics-release-inventorv-tri-proqram/quidance-dioxin-and- i ij* j i -^i* ^ dioxin-compounds-cateqorv 35 ------- 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 36 ------- Lead and Lead Compounds Under TRI, lead is classified as a PBT except for lead contained in stainless steel, brass, and bronze alloys. 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 pounds for manufacture or process • 10,000 pounds for otherwise use *if elemental lead is removed from the qualified alloy, such as vaporization during melting of an alloy, the 100 lb threshold applies 37 ------- Lead Threshold Determination Flow Chart Activity thresholds and reporting requirements for lead related to stainless steel, brass or bronze alloy qualifier 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 no r wi X 1 YES This flowchart does not apply to Lead Compounds, a separately listed TRI chemical 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? YES 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. _L NO No reporting for lead required YES 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 NO 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 iead 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. ------- T RJ_ REP ORTING REQUIREMENTS Quiz #2 Question 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 used. Which of the following thresholds have been exceeded for lead or lead compounds? A. Otherwise Use only B. Manufacturing only C. Neither D. Both 39 ------- T RJ_ REP ORTING REQUIREMENTS Quiz #2 Question 2 The facility in the previous question combusted 13,600,000 pounds of coal in the reporting year and has exceeded the reporting threshold for lead compounds. The facility has no monitoring data on their point source lead emissions from combusting the coal. They determined that their best available information for calculating their point source air emissions is the published emission factor for lead from controlled coal combustion from EPA's AP-42* which is 4.2E-04 lb Pb/ton of coal combusted. What are the facility's point source emissions of lead from coal combustion? A. 2.86 lb B. Range Code 'A' C. 95.2 lb D. Either 2.86 lb or Range Code 'A' 40 ------- T R_L REP ORTING REQUIREMENTS 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 Some uses of paving asphalt (blacktop) are NOT EXEMPT ¦ Paved process areas and roads for process vehicles (e.g., on-site haul trucks) - NOT EXEMPT ¦ Employee parking lot and non-processes access roads - EXEMPT See also EPA's PACs guidance www.epa.qov/sites/production/files/documents/2001pacs.pdf 41 ------- T RJ_ REP ORTING REQUIREMENTS 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 42 ------- T R_L REP ORTING REQUIREMENTS 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 43 ------- T R_L REP ORTING REQUIREMENTS 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 44 ------- 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 45 ------- T RJ_ REP ORTING REQUIREMENTS 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. ------- Sectidn4^» 'V < > a ¦ Tools and Assistance ------- T RJ_ REP ORTING REQUIREMENTS 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 GuideME ¦ Browse frequently asked questions and answers ¦ Browse guidance materials ¦ Available at: http://epa.gov/tri/quideme 48 ------- Reference Sources EPA Industry Guidance located at www.epa.gov/toxics- release-inventorv-tri-proqram/quidance-documents-tri- J I reporting AP-42: Compilation of Air Pollutant Emission Factors located at https://www3.epa.gov/ttnchie1/publications.html Technology Transfer Network located at www.epa.gov/technical-air-pollution-resources - AP-42 ¦ WATER9 program TANKS program Perry's Chemical Engineer's Handbook; CRC Handbook of Chemistry and Physics; Lange's Handbook of Chemistry 49 ------- Pollution Prevention Information Visit the new TRI Pollution Prevention web page ¦ www.epa.gov/tri/p2 Pollution Prevention Information Clearinghouse (PPIC) - (202) 566-0799 ¦ www.epa.gov/ppic 50 ------- T R_L REP ORTING REQUIREMENTS 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) 348-5070. The TDD is (800) 553-7672. 51 ------- ------- T RJ_ REP ORTING REQUIREMENTS TRI-MEweb and Submitting Via CDX • Electronic filing via TRI-MEweb is required No paper submissions are accepted (except for trade secrets), including revisions and withdrawal TRI-MEweb supports new reporting, revisions & withdrawals for RY 1991 - current year TRI-MEweb can import current year reporting forms with data submitted for the prior reporting year and assists users in finding reporting errors EPA provides instant email confirmation of transmitted and certified submissions TRI-MEweb resources ncluding tutorials are available to help users at: www2.epa.gov/toxics-release-inventorv-tri-proqram/tri-meweb-resources • Use hard-copy form only for trade secret reporting Information about trade secret reporting at: www2.epa.qov/toxics-release-inventorv-tri-proqram/tri-reportinq-forms-and- II J B 1 instructions 53 ------- T RJ_ REP ORTING REQUIREMENTS Accessing TRI-MEweb TRI-MEweb is accessed through EPA's Central Data Exchange (CDX) CDX is accessed through: https://cdx.epa.gov TRI-MEweb users must have a CDX account Select TRI-MEweb user role: preparer or certifying official Within TRI-MEweb, new users must gain access to their facility Option 1: New facility, never reported to TRI Option 2: Enter six-digit facility access code Option 3: Enter TRIFID and Technical Contact Name For assistance with accessing your facility, contact the CDX helpdesk at helpdesk@epacdx.net or call toll-free at (888) 890-1995. ------- Certifying Official Information All non-trade secret forms must be certified by an electronic signature from a senior management official New certifying officials must submit an electronic signature agreement (ESA) and a facility certification agreement form before pending submissions can be certified Returning certifying officials do not need to submit an ESA as long as they continue to represent the same facility year to year TRI-MEweb now includes a built-in Certification module, accessible by users registered as certifying officials New certifying officials will answer personalized security questions in addition to their CDX password for digital procedures 55 ------- T RJ_ REP ORTING REQUIREMENTS Signing and Certifying Forms • New Certifying officials must complete the following two requirements - Electronic signature agreement (ESA) Must be completed only once, not annually, applicable to all facility profiles Option 1: Real-time ESA approval - verify user's identity electronically Option 2: Mail in signature form - minimum of 5 business days to process ¦ TRIFID Certification Agreement Form Must be completed after access to TRI-MEweb is granted by ESA approval Facility profiles are added to TRI-MEweb using access keys or prior year information Certifying officials must have a digitally signed TRIFID Certification Agreement for each facility profile before access to any pending submission (s) for certification is granted. • New certifying officials must submit an ESA and digitally sign a TRIFID certification agreement form before pending submissions can be reviewed and certified 56 ------- State and Tribal Submission Requirements For most facilities, reporting via TRI-MEweb automatically satisfies EPA and state or tribal reporting requirements via data sharing through the TRI Data Exchange (TDX) For facilities in states or tribal lands not participating in TDX, TRI- MEweb will help prepare separate submissions to satisfy state or tribal reporting requirements All States currently participate in TDX www2.epa.gov/toxics-release- inventorv-tri-proqram/tri-data-exchanqe _r I i_r i_r As of December 2017, one tribe (Oneida Tribe Of Indians Of Wisconsin) participates in TDX TDX does not support reporting for years prior to 2005 57 ------- 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: ¦ https://www.epa.gov/toxics-release-inventorv-tri-proqram/tri- meweb-mini-tutorials 58 ------- Electronic^Facility Data Profiles Facilities can obtain a copy of their electronic Facility Data Profile (eFDP) using TRI-MEweb Review your eFDP immediately after certifying TRI forms in CDX to verify that EPA processed your data correctly The eFDP 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 eFDP availability If you have problems accessing your eFDPs, contact: ¦ E-mail: tri.efdp@epacdx.net 59 ------- TRI-MEweb Demo If you are viewing an Online Training Module, please visit www.epa.gov/tri to view the TRI-MEweb tutorials. 60 ------- ------- |