Reporting Year 2017 \

Emergency Planning + Community RfSMT?T|b-KNOW Act (EPCRA) Section 313

Toxics	Release

Reporting	Requ

Advanced Concepts


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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

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TRI Reporting Requirements

Covered Primary
NAICS Code(s) or
Federal facility?

"MPOU: Manufacture (including import), process, or otherwise use


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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


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Sectfonjlr- ¦ &' i fi f
Recent TRfT^fograhi^hanges


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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


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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


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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


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Section 4fo	IM

Advanced Reporting Guidance


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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


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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




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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




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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.

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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

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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.

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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


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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)

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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

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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.

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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.

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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

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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


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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

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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


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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

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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


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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

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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	-	* *

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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

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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.

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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

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SectidfiJJJ* V i i I m-
Detailed PBT Guidance


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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

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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


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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

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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

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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

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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

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.


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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

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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'

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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

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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

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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

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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

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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

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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.


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Sectidn4^» 'V < > a ¦

Tools and Assistance


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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

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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

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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

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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.

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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

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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.


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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

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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

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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

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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:

¦	https://www.epa.gov/toxics-release-inventorv-tri-proqram/tri-
meweb-mini-tutorials



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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

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TRI-MEweb Demo

If you are viewing an Online Training Module,
please visit www.epa.gov/tri to view the
TRI-MEweb tutorials.

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