Reporting Year 201 % W • « I- •"f < Emergency Planning + Community £feHT?Tip-KNOW Act (EPCRA) Section 313 Toxics Release Reporting Requ Basic Concepts Do I Need to Report to TRI and How Do I Report ------- fl IP R ' E P r. R rw rl N G III R E r 7 r - M*—^ ¦ 1 w m i* r n f M E N T S TRI Training Module Agendas Basic Concepts Module 1. Introduction 2. Covered Sectors 3. Thresholds (PBT and Non-PBT) 4. Reporting Exemptions 5. Threshold Determinations 6. Overview of Form R 7. Alternate Threshold Rule (Form A) 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 ------- ------- T R I REPORTING REQUIREMENTS What is EPCRA Section 313 & TRI? • Section 313 of EPCRA requires facilities to file a TRI report annually for each Section 313 chemical exceeding an activity threshold (manufacturing, processing or otherwise using) ¦ Section 313 chemical list contains over 650 chemicals and chemical categories • Facilities exceeding an activity threshold must report if they are: ¦ In a "covered sector" (defined by NAICS codes); and ¦ Have 10 or more employees • Submit TRI reports to U.S. EPA, and either ¦ designated state officials, or ¦ designated tribal office • TRI reports must be submitted by July 1st following the calendar year's activities (aka Reporting Year (RY)) ¦ [e.g. July 1, 2018 deadline for RY 2017 (January 1 - December 31, 2017) activities] ------- TRI Reporting Requirements Covered Primary NAICS Code(s) or Federal facility? "MPOU: Manufacture (including import), process, or otherwise use Reporting Thresholds Met; Form R/Form A Required ------- 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 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 * Complete Final QA/QC I Certify Form * Submit to EPA & State or Tribe ------- Section I: Covered Sectors ------- T R I R B P O rBH N G R g Q U Pk E M E N T g Industrial Sectors Covered Industrial Sector Notes Manufacturing Facilities engaged in the mechanical or chemical transformation of materials or substances into new products Metal mining Not including metal mining services, and uranium, radium, and vanadium ores Coal mining Not including coal mining services Electrical utilities Limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce Treatment, Storage, and Disposal facilities Limited to facilities regulated under the Resource Conservation and Recovery Act, Subtitle C, 42 U.S.C. Section 6921 et seq. Solvent recovery services Limited to facilities primarily engaged in solvent recovery services on a contract or fee basis Chemical distributors Facilities engaged in the wholesale distribution of chemicals and allied products Petroleum bulk terminals Facilities engaged in the wholesale distribution of crude petroleum and petroleum products from bulk liquid storage facilities ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Covered NAICS Codes 2017 North American Industry Classification System (NAICS) codes are used for TRI reporting. To determine whether your facility's primary NAICS code is covered by TRI regulations, see: www2.epa.gov/tri/mv-facilitvs-six-diqit-naics-code-tri-covered-industrv TRI-Covered* Industries NAICS ¦ 212 Mining ¦ 221 Utilities 31 - 33 Manufacturing All Other Miscellaneous Manufacturing (includes some sectors under NAICS 1119,1133, 2111,4883, 5417, 8114) 424 Merchant Wholesalers, Non-durable Goods 425 Wholesale Electronic Markets and Agents Brokers 511, 512, 519 Publishing 562 Hazardous Waste Federal Facilities * Note: For many of these NAICS codes, there are reporting exceptions. 9 ------- T R I REPORTING REQUIREMENTS Federal Facilities • Federal facilities (covered by Executive Order 13423 and its implementing instructions) ¦ Required to report regardless of their NAICS code • Includes military bases, federal prisons, national parks, etc. ¦ Other reporting requirements apply • 10 or more full-time employees • Exceed manufacture, process, or otherwise use thresholds of a listed chemical ¦ The federal agency or department that owns or operates the facilities is responsible for reporting ¦ Government owned contractor operated (GOCO) facilities • Same reporting requirements as non-federal facilities • Counted as federal facilities in TRI data analysis 10 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Definition of "Facility" • TRI reporting requirements are determined by activities at "facilities" ¦ Primary NAICS code determination at facility level ¦ Employee threshold determination at facility level ¦ Chemical threshold determinations made at fac ity level • "Facility - all buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites and which are owned or operated by the same person (or by any person which controls, is controlled by, or under common control with, such person)." EPCRA § 329 (4)) ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Example of a Multi-Establishment Facility • Three separate establishments located on contiguous/ adjacent property owned by same person(s), is one facility under EPCRA (40 CFR § § 372.22(b) and 372.3) ¦ Establishment - unique and separate economic unit of a facility (See 40 CFR § 12 ------- T R I REPORTING REQUIREMENTS Multi-Establishment Facility • Three separate establishments located on contiguous/ adjacent property owned by same person(s), is one facility under EPCRA (40 CFR § § 372.22(b) and 372.3) Value added of food processing establishment = value of final food products - value of warehousing - value of farm products. 13 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Multi-Establishment Facility • Three separate establishments located on contiguous/ adjacent property owned by same person(s), is one facility under EPCRA (40 CFR § § 372.22(b) and 372.3) Value added of food processing establishment = value of final food products - value of warehousing - value of farm products. 14 ------- T R I REPORTING REQUIREMENTS Employee Threshold • 10 or more full-time employee equivalents (i.e., 20,000 hours) (40 CFR § § 372.3 and 372.22(a)) ¦ All persons employed by a facility regardless of function • Includes operational staff, administrative staff, contractors, dedicated sales staff, company drivers, off-site direct corporate support ¦ Add all hours from part-time and full-time employees • Includes holidays, vacation and sick-leave ¦ Does NOT include ntermittent services from non-employees • Excludes contract drivers or contractors performing intermittent service functions such as janitorial services • See 1998 Q&A #21, #29 and #38 for examples • Total hours worked for each employee can be determined using time management systems 15 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #1 Question 1 Would the facility described below be covered by TRI and, therefore, need to consider its chemical use for possible reporting? Select Yes or No. A manufacturing facility, owned by ABC Corporation, with 100 full-time employees YES NO ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #1 Question 2 Would the facility described below be covered by TRI and, therefore, need to consider its chemical use for possible reporting? Select Yes or No. A maintenance and warehouse facility, owned by ABC Corporation, with 5 full-time employees, a few blocks away from the manufacturing facility described in Question 1 YES NO ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #1 Question 3 Would the facility described below be covered by TRI and, therefore, need to consider its chemical use for possible reporting? Select Yes or No. A maintenance and warehouse facility, owned by ABC Corporation, with 5 full-time employees, next door to the manufacturing facility described in Question 1 YES NO ------- Section II: •. ' - 4iar Thresholds^(P6T andlSlorftPBT) ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Toxic Chemical Activity Thresholds • A TRI report must be prepared and submitted for any chemical that has exceeded an activity threshold. • Threshold calculations are based on cumulative quantities of each Section 313 chemical manufactured, processed, or otherwise used over the reporting year for the whole facility. • Each activity threshold is treated separately ¦ Quantify separately amounts of toxic chemicals that are manufactured, processed, or otherwise used at the facility ¦ Compare amounts in each activity to the toxic chemical's applicable threshold • Lower thresholds apply to the 21 chemicals/chemical categories designated as persistent, bioaccumulative, and toxic (PBT) chemicals. ------- t m i in p NG 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. 21 ------- T R I REPORTING REQUIREMENTS Listed PBT* TRI Chemicals • Within the list of 650+ chemicals and chemical categories, there is a subset designated as being of special concern and commonly referred to as PBT chemicals (40 CFR § 372.28) • PBT chemicals have lower activity thresholds and different reporting requirements than non-PBT TRI chemicals ¦ Special rules often apply to PBT chemicals • 21 chemicals and chemical compound categories are classified as PBTs and have lower activity thresholds *PBT = Persistent, Bioaccumulative, Toxic 22 ------- W m I R E P NG REQUTREMEN PBT Chemicals and Activity Thresholds PBT chemicals are subject to separate and lower activity thresholds (See 40 CFR § 372.28) ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Section 313 Chemicals and Chemical Categories • Current list contains over 650 individual chemicals and chemical categories (See Table II of the EPA's TRI Reporting Forms and Instructions document.) There are 4 parts to the chemical list: ¦ Individual chemicals alphabetically by name ¦ Individual chemicals by CAS # ¦ Chemicals with qualifiers ¦ Chemical categories • The list can change - check every year. Changes are listed in the front of the TRI Reporting Forms and Instructions, on the TRI website, and in TRI-MEweb. • Section 313 chemical list and more information available at: http://www2.epa.qov/toxics-release-inventorv-tri-proqram/trHisted-chemicals 24 ------- T R I REPORTING 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 threshold determinations for manufacture, process or otherwise use began reporting on this chemical in Reporting Year 2016 http://www2.epa.gov/toxics-release-inventorv-tri-program/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 that meet threshold determinations for manufacture, process or otherwise use began reporting on this chemical category in Reporting Year 2015 http://www2.epa.gov/toxics-release-inventorv-tri-program/addition-nonvJphenol-categorv 25 ------- T R I REPORTING REQUIREMENTS Section 313 Chemicals With Qualifiers Qualifiers - Listed chemicals with parenthetic qualifiers subject to TRI reporting only if manufactured, processed, or otherwise used in specified form (40 CFR § 372.25(g)). Below are some examples (see Table II of EPA's TRI Reporting Forms and Instructions document): Chemical CAS# Qualifier Aluminum 7429-90-5 Fume or dust Aluminum Oxide 1344-28-1 Fibrous forms Asbestos 1332-21-4 Friable forms Isopropyl alcohol 67-63-0 Only manufacturers using strong acid process Phosphorus (not phosphate) 7723-14-0 Yellow or white Saccharin 81-07-2 Manufacture only Hydrochloric acid 7647-01-0 Acid aerosols Sulfuric acid 7664-93-9 Acid aerosols Vanadium 7440-62-2 Except when contained in alloy 26 ------- T R I REPORTING REQUIREMENTS TRI Chemical Categories • Metal compound chemical categories - Antimony Compounds - Arsenic Compounds - Barium Compounds * - Beryllium Compounds - Cadmium Compounds - Chromium Compounds ** - Cobalt Compounds - Copper Compounds *** For all categories: Includes any unique chemical substance that contains the element or compound as part of that chemical's infrastructure * Does not include Barium Sulfate CAS 7727-43-7 ** Except chromite ore and unreacted ore component of processing residue (see RFI for further information) *** Does not include copper Phthalocyanine compounds that are substituted with only hydrogen, and/or chlorine and/or bromine Note: Elemental metals and metal compounds are separately listed chemicals under Section 313. Lead Compounds Manganese Compounds Mercury Compounds Nickel Compounds Selenium Compounds Silver Compounds Thallium Compounds Vanadium Compounds Zinc Compounds ------- T R I REPORTING R E Q U I R E M E N T S EPCRA TRI Chemical Categories (examples) Chlorophenols 1 OH I rotcix H (5-X); X = 1 to 5 Cyanide Compounds XCN where X=H or any other group where a formal dissociation may occur. For example, KCN or Ca(CN)2 Diisocyanates 20 individual compounds cited in Category Dioxin and Dioxin-Like Compounds: 17 individual compounds cited in Category Ethylenebisdithiocarbamic acid, salts and esters (EBDCs) Includes a substance that may contain EBDC or EBDC salt or ester as part of its infrastructure Certain Glycol Ethers Complex definition Nicotine and salts Includes a substance that may contain it or salt as part of its infrastructure Nitrate compounds Water dissociable, reportable only when in aqueous solution Polybrominated Biphenyls (PBBs) H(10-X); X = 1 to 10 28 ------- T R I REPORTING REQUIREMENTS ManufacturingActivities • Manufacturing (EPCRA § 313(b)(1 )(C)(i) and 40 CFR § 372.3) - generating a Section 313 chemical ¦ Intentionally producing chemicals for: • Sale • Distribution • On-site use or processing (e.g., intermediates) ¦ Coincidentally producing chemicals as impurities* or by- products**: • At any point at the facility, including waste treatment (#152 of 1998 Q&A) and fuel combustion (#252 and #254 of 1998 Q&A) ¦ Importing • "Cause" to be imported *lmpurity=TRI chemical that still remains with the final facility product as it is distributed into commerce (#151 and #319 of 1998 Q&A) **By-product=TRI chemical that is separated out from the process mixture before it becomes the final product 29 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Processing Activities • Processing (EPCRA § 313(b)(1 )(C)(ii) and 40 CFR § 372.3) - preparation of a Section 313 chemical, after its manufacture, for distribution in commerce: ¦ Use as a reactant to manufacture another substance or product ¦ Add as a formulation component ¦ Incorporate as an article component ¦ Repackage for distribution ¦ Quantities sent off-site for recycling ¦ Incidentally include as an impurity ------- T R I REPORTING REQUIREMENTS Repackaging as a Processing Activity Repackaging a Section 313 chemical for distribution in commerce is considered processing ¦ Repackaging includes: • From container to tanker truck and vice versa • Between similar size containers • Via pipeline to/from a tank ¦ Repackaging does not include: • Sampling without repackaging • Re-labeling Repackaging without distribution into commerce is not processing Transfer to a storage tank for mere storage is not processing 31 ------- T R I REPORTING REQUIREMENTS Otherwise Use Activities • Otherwise Use (40 CFR § 372.3) - includes most activities that are NOT manufacturing or processing. Examples ¦ Chemical processing aid (e.g., solvents, catalysts, buffers, non-incorporative reagents) ¦ Manufacturing aid (e.g., lubricants, refrigerants, coolants, hydraulic fluids, metalworking fluids) ¦ Ancillary activities • Fuels, cleaners, degreasers • Chemicals used to remediate or treat wastes • Fabrication and/or use of tools in your process • Installation of piping and process-related equipment, e.g., reactors, constructing storage tanks, asphalt roadways 32 ------- T R I REPORTING REQUIREMENTS Otherwise Use Activities (continued) Managing wastes received from off-site also counts as "Otherwise Use" ¦ Disposal treatment for destruction on-site, or stabilization that does not result in further distribution in commerce are considered otherwise use if: • Section 313 chemical was received from off-site for the purposes of further waste management, or • Section 313 chemical was manufactured as a result of waste management activities on materials received from off-site for the purpose of further waste management. On-site energy recovery is an otherwise use activity. ¦ Waste management activities, ncluding on-site recycling, treatment for destruction, waste stabilization and release/disposal of Section 313 chemicals in wastes generated on-site are not threshold activities. 33 ------- T R I REPORTING REQUIREMENTS Calculating Activity Thresholds The threshold quantity is the total amount manufactured, processed, or otherwise used, NOT the amount released. Calculate the total amount of Section 313 chemical used for a specific threshold activity Each activity threshold is calculated separately and they are not additive Example of Calculating Activity Thresholds Over the course of a reporting year, a facility manufactures 24,000 pounds of a non-PBT chemical, subsequently process that amount, and also happen to otherwise use 9,000 pounds of the same chemical. That facility has not exceeded a non-PBT chemical activity threshold and would NOT be required to submit a TRI report for that chemical. Calculations for reporting waste management may be different from threshold quantities. 34 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Threshold Determination for Compound Categories Count together all compounds within the same chemical category for each activity, even if different compounds within a category are used in separate operations Consider the entire weight of all the different chemical compounds in the same chemical category when determining thresholds Note: calculations for release and other waste management estimates of metal compounds based on the parent metal weight only; and for nitrate compounds are based on weight of nitrate ion only ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Activities That Are Not TRI Threshold Activities • Activities that, alone, do NOT constitute a threshold activity ¦ Storage ¦ Remediation of on-site contamination (assuming no listed chemicals are manufactured during remediation) ¦ Re-labeling without repackaging ¦ Direct reuse onsite ¦ On-site recycling (not including wastes received from off-site) ¦ Transfers sent off-site for further waste management (not including recycling) ¦ Repackaging (and blending, if any) of waste fuels for burning for energy recovery. (However, all fuels, including waste fuels (with blending, if any), are considered otherwise used when combusted for energy recovery.) Note: While these activities are not ncluded in the threshold determination, releases and wastes from these activities are not exempt from reporting if threshold is exceeded through other activities (unless specifically eligible for one of the reporting exemptions). 36 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #2 Question 1 A plant uses benzene as a raw material to manufacture liquid industrial adhesive. The plant adds 27,000 lb of benzene to its liquid adhesive-making operation during the reporting year, but 3,000 lb are volatilized during the operation. How much of the benzene should be applied toward the processing activity threshold? Select your choice. A. 27,000 lb B. 24,000 lb C. 3,000 lb ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #2 Question 2 If a facility processes 20,000 lb of methylene diphenyl diisocyanate (MDI) in one operation and 10,000 lb of isophorone diisocyanate in another operation during the reporting year, what should it apply towards it's processing threshold for the diisocyanates category? Select your choice. A. 10,000 lb B. 20,000 lb C. 30,000 lb ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Quiz #2 Question 3 A facility processes 18,000 lb copper sulfate, 10,000 lb of cuprous oxide, and otherwise uses 12,000 lb of aqueous sulfuric acid solution in a closed system. For which TRI chemicals or chemical categories would the facility need to submit a TRI form? Select your choice. A. copper compounds and sulfuric acid B. only copper compounds C. only sulfuric acid ------- Sectidn-Jjjt* ¦ ' * * i M' Reporting Exemptions ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Reporting Exemptions If an exemption applies, then the amount of Section 313 chemical subject to the exemption does NOT have to be included in: ¦ Threshold determinations ¦ Release and waste management reporting Recognize that exemptions only apply to certain limited circumstances Misusing exemptions may lead to enforcement action ------- T R I REPO W W N G RE'QUPREMEN f 1 Reporting Exemptions Types of exemptions (40 CFR § 372.38) ¦ De minimis ¦ Article ¦ Laboratory activities ¦ NAICS code specific • Coal mining extraction activities • Metal mining overburden ¦ "Otherwise use" exemptions • Motor vehicle maintenance • Routine janitorial or facility grounds maintenance • Structural components • Personal use • Intake water and air ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 De Minimis Exemption The quantity of a non-PBT Section 313 chemical in a mixture or other trade name product is eligible for the de minimis exemption (40 CFR § 372.38(a)) if the chemical is: ¦ An OSHA-defined carcinogen present at a concentration of less than 0.1% OR ¦ Any other non-PBT TRI chemical present at a concentration of less than 1% The TRI de minimis level appears next to each chemical on the chemical list in Table II of the TRI Reporting Forms and Instructions (1.0, 0.1 or * for PBT chemicals where de minimis is not allowed (See 40 CFR § 372.38(a))) 43 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 De Minimis Exemption HOW IT WORKS... De minimis exemption generally applies to non-PBT chemicals: ¦ Iri mixtures or trade name products received from off-site, including imported ¦ Coincidentally manufactured as m purities that remain in products distributed in commerce De minimis exemption does not apply to: ¦ Manufactured chemicals (in most cases): this includes by- products produced from manufacturing, processing, otherwise use, or any waste management ¦ Wastes received from off-site ¦ FBI chemicals (except for supp lier notification) ------- T R I REPO Rllf N G RE'QuPREMEN f 1 PBT Chemicals and the De Minimis Exemption The de minimis exemption cannot be applied to PBT chemicals. All other EPCRA section 313 exemptions can apply to PBT chemicals. Facilities that receive a mixture and know that PBT chemicals are present must consider each PBT chemical in threshold and release calculations regardless of whether or not supplier notification was provided ------- t m i in p NG REQUTREMEN De Minimis Exemption: How It Works... (cont) Processing a non-PBT Section 313 chemical in a mixture to below the de minimis concentration does NOT exempt the chemical from threshold determinations and release calculations Raw Material Primer Mixture Products (90% Toluene) 1% Toluene > 1% EE mm e-5 rar T~] n klB 1 Ifc^l id H ¦ ¦ ¦ ¦ bI s Paint (<1% Toluene) Toluene <1% De minimis exemption does NOT apply Threshold determination required Release calculations required De minimis exemption does NOT apply Threshold determination required Release calculations still required ------- T R I REPORTING REQUIREMENTS De Minimis Exemption: How It Works... Processing a non-PBT Section 313 chemical in a mixture to above the de minimis concentration triggers threshold determinations and, if thresholds are met, release calculation requirements Solvent Raw Material containing trace amounts of toluene containing 1 % rn~i rm cnn 11P i INI MM iTTl iTtl \m ~ A Toluene < 1% Acme Industries Toluene > 1% Paint Stripper Concentrated Toluene > 1% De minimis exemption DOES apply Threshold determination not required Release calculations not required • De minimis exemption does MOT apply • Threshold determination required • Release calculations still required 47 ------- T R I REPORTING REQUIREMENTS Article Exemption Applicability To qualify for the article exemption, the article must meet 3 criteria (40 CFR § 372.3): 1. Is formed into a specific shape or design during manufacture; and 2. Has end-use functions dependent in whole or in part on its shape or design during end-use; and 3. Does NOT release a Section 313 chemical under normal processing or use conditions at a facility ------- T R I REPORTING REQUIREMENTS Article Exemption: How it Works Releases of a Section 313 chemical from an article may negate the exemption. To maintain the article status, total releases from all like items must be: ¦ In a form having a specific shape or design; or ¦ Recycled, directly reused; or ¦ 0.5 pound or less released per year (may be rounded down to zero) If more than 0.5 pound per year of a Section 313 chemical is released from all like items in a form not having a specific shape or design and is not recycled or directly reused, none of the items meet the articles exemption End use must be dependent upon the item's initial shape or design (For example, sheet metal must maintain its initial thickness, and wire and pipe must maintain their initial diameter.) See TRI Reporting Forms and Instructions for more on the article exemption 49 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Article Exemption: Examples Wire is cut to specified lengths. Wastes include off-spec cuts and dust. ¦ Generation of off-spec cuts that are recognizable as articles wi I not, by themselves, negate the article status ¦ Dust and off-spec cuts not recognizable as articles, with greater than 0.5 pound of ANY Section 313 chemical released annually, and not recycled or directly reused, negate the article status Fluorescent light bulbs containing mercury are installed and used. Following use, the bulbs are crushed for recycling at the facility and mercury is released. ¦ Crushing bulbs for recycl ng after use for lighting at the facility is not considered release under normal conditions of processing or use at this facility; the article exemption may apply. ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Article Exemption Article Exemption is often inappropriately used! - IIn many instances when metals are machined, cut, or ground, n any manner, the article exemption may not be applicable. Generally, the articles exemption does not apply to the actual manufacturing of articles. ------- U r F ft T R I RE P N G REQUIREMEN Laboratory Activity Exemptions HOW IT WORKS... Section 313 chemicals used in these laboratory activities under the direct supervision of a technically qualified individual ARE exempt from threshold and release and waste management reporting (40 CFR § 372.38(d) and 1998 Q&A #311): ¦ Sampling and analysis ¦ Research and development ¦ Quality assurance ¦ Quality control Section 313 chemicals used in these laboratory activities are NOT exempt: ¦ Specialty chemical production ¦ Pilot-scale plant operations ¦ Activities not conducted in lab ¦ Support services • Photo processing • Equipment maintenance/cleaning 52 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Motor Vehicle Maintenance Exemption • Section 313 chemicals used to maintain vehicles operated by the facility are eligible for the exemption from threshold determinations (40 CFR § 372.38(c)(4)) ¦ "Otherwise use" exemption • Motor vehicles include cars, trucks, tanks, and forklifts • Motor vehicle maintenance includes: ¦ Fueling and adding other fluids (e.g., ethylene glycol) ¦ Body repairs ¦ Parts washing Note: This exemption does NOT apply to "manufacture" of Section 313 chemicals from combustion of fuels. 53 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Routine Janitorial or Facility Grounds Maintenance Exemption • Section 313 chemicals contained in products used for non-process related routine janitorial or facility grounds maintenance ARE eligible for exemption (40 CFR § 372.38(c)(2)): ¦ Phenol in bathroom disinfectants ¦ Pesticides or fertilizers used on lawns ¦ "Otherwise use" exemption • Section 313 chemicals used in the following activities are NOT exempt ¦ Faci ity equipment maintenance ¦ Cleaning or maintenance activities that are directly associated with or integral to the production process at the facility Note: Chemicals otherwise used in janitorial or grounds maintenance activities may not be exempt if part of your facility's "process" is to provide these services (e.g., federal hospitals, prisons, parks). Also, chemicals manufactured during routine janitorial or facility ground maintenance are not exempt. 54 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Structural Component Exemption • Section 313 chemicals used as structural components are eligible for exemption (See 40 CFR § 372.38(c)(1)). Building components that are process-related are not "structural components" as contemplated by the exemption. • Non-process-related building components that are "structural components" and therefore eligible for the exemption include: Potable water pipes and other non-process-related pipes and structures • Processed-related building components that are NOT "structural components" and therefore NOT eligible for the exemption include: Refractory brick, boiler tubes, process-related pipes, anodes used in electroplating, grinding wheels, & metal working tools Structural components that are integral to a non-industrial facility's "process" (e.g., federal prisons, hospitals, parks) 55 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Other Section 313 "Otherwise Use" Exemptions • Section 313 chemicals contained in non-process related items for employee personal use (40 CFR § 372.38(c)(3)) Non-federal Facilities: HCFC 22 in air conditioners used solely for employee comfort (exemption does NOT cover process coof ng using chemical- based cooling systems) Chlorine used to treat on-site potable water Phenol used in a facility medical dispensary Federal Facilities: Does not include TRI chemicals used for providing services to non-employees (e.g., patients in federal hospitals, prisoners, park visitors) • Section 313 chemicals found in intake water and air 56 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Sector Specific Exemptions Coal mining extraction activities are exempt from threshold determinations and release reporting (40 CFR § 372.38(g)) (applies to NAICS Codes 212111-212113): ¦ Coal extraction: physical removal or exposure of ore, coal, minerals, waste rock, or overburden prior to beneficiation, and encompasses all extraction-related activities prior to beneficiation (40 CFR § 372.3) Chemicals in metal mining overburden that are processed or otherwise used are specifically exempt from TRI reporting (40 CFR § 372.38(h)) (applies to NAICS Codes 212221, 212222, 212230, 212299): ¦ Overburden: unconsolidated material that overlies a deposit of useful materials or ores (40 CFR § 372.3) ------- SectidrUy* f fNj Mil Threshold Determination ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Chemical Information Management All non-exempt manufacture/processes/otherwise use of Section 313 chemicals at the facility must be counted towards chemical activity thresholds. Tracking toxic chemicals entering facility ¦ Purchasing/Inventory ¦ Contractors ¦ Capital purchases (e.g., chiflers, process equipment) ¦ Direct purchases (credit card or other emergency purchases) ¦ Direct and indirect materials ¦ Manufacturing by products/i ntermediates generated Need cooperation and support from all functional groups purchasing or using Section 313 chemicals Be comprehensive to ensure accurate threshold determination! 59 ------- T R I REPORTING REQUIREMENTS Threshold Determinations Identify Chemicals and Concentrations: ¦ SDS ¦ Product or Specifications ¦ Available Supplier/Vendor Product QA/QC data ¦ Industry Standards (API, ASTM, etc.) ¦ Waste Profiles ¦ Process Knowledge ¦ Other References (AP-42. WebFIRE, Merck Index) ¦ Supplier Notification Collect Data to Calculate Thresholds: ¦ Inventory or Purchase Records ¦ Throughput/Production Data ¦ Integrated Supplier Records ¦ EPCRA or Other Env. Reports ¦ Air Permits I MACT or Simlar Standards I Emission Inventories ¦ Water Permits I DMR's I Discharge Reports ¦ Annual/Biennial Waste Reports ¦ User Records ¦ Other Vendor Records (can call vendor) ------- T R I REPO Rllf N G RE'QuPREMEN f 1 TRI Chemicals Contained in Mixtures For the threshold quantity, only include the amount of the TRI chemical in the mixture, not the weight of the entire mixture. The de minimis exemption (40 CFR § 372.38(a)) applies to non- PBT chemicals contained in mixtures at less than 1.0% or 0.1% (for carcinogens). ¦ The de minimis exemption is related to the concentration of the chemical in a mixture, NOT the quantity of the mixture used. A metal alloy can be thought of as solid solution. To determine threshold quantity, multiply the concentration of the TRI chemical in the alloy by the total weight of alloy processed or otherwise used. ------- T R I REPORTING REQUIREMENTS Determining Concentrations in Mixtures or Other Trade Name Products Determine whether thresholds were exceeded for listed chemicals in a mixture (40 CFR § 372.30(b)(3)): ¦ Exact concentration - use concentration provided: • SDS = 25% Use 25% ¦ Upper bound - use upper limit • SDS < 25% Use 25% ¦ Range - use the midpoint of the range • SDS: 30 - 50% Use 40% ¦ Lower bound - subtract out other known constituents, create a range, and use the midpoint of range • SDS: >75% toxic chemical Use 87.5% (top of range = 100%) • SDS: >75% toxic chemical Use 80% (range = 15% water 75%-85%) 62 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Determining Concentrations in Wastes • If concentration is exact, upper bound, range, or lower bound, use the guidance for mixtures and other trade name products discussed earlier • If concentration is below detection limit, use engineering judgment: ¦ If the Section 313 chemical IS expected to be present, assume 1/2 of full detection limit ¦ If the Section 313 chemical is NOT expected to be present, assume 0 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Supplier Notification Supplier notification - requires suppliers of mixtures or trade name products to covered facilities (See 40 CFR § 372.45(a)) to: ¦ Identify Section 313 chemical(s) by name and CAS number ¦ Identify Section 313 chemical(s) as being subject to Section 313 requirements ¦ Provide concentration (or range) of Section 313 chemicals in mixtures and other trade name products (not wastes) ¦ Provide notification at least annually in writing or attached to the SDS ¦ Update notification when changes occur The Regulatory Information section of the SDS should identify any chemicals that are subject to TRI reporting Suppliers of mixtures containing PBT chemicals below de minimis concentrations do not need to supply notification 64 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Watch for Double Counting • For threshold determinations, Section 313 chemicals recycled from spent or contaminated materials or Section 313 chemicals directly reused: ¦ Count original amount used only once ¦ Materials n use from previous years, count only the quantity added during current reporting year • Section 313 chemicals stockpiled or in inventory but not manufactured, processed, or otherwise used during reporting year are NOT counted for threshold determinations Chemicals sent off-site for recycling and returned to the facility are considered new materials and counted for threshold determinations 65 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Count the Original Amount Used Only Once Example: If a chemical is blended into a product mixture, and then this mixture is packaged for sale into 55 gallon drums, these are both processing activities, the chemical is "processed" twice. Only count this quantity once towards the processing threshold. ¦ During Reporting Year, 20,000 lb of toluene were blended with other chemicals to create a paint product. ¦ The paint product (containing the 20,000 lb of toluene) was then packaged into 55 gallons drums for sale. ¦ The processing threshold quantity for this faci ity for Reporting Year = 20,000 lb ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Multi-Establishment Facility Reporting as multi-establishment facility (40 CFR § 372.30(c)) ¦ Use the 'Manage Establishments' option to create multiple establishments for which to submit reporting forms ¦ Multi-establishment facilities have the option to file separate Form R reports for each part of the facility ¦ Threshold calculations must account for all the facility's activities and are not performed at the establ shment level ¦ Form R reports must nclude all non-exempt releases and other waste management activities at the facility ¦ Use the 'Report by Part' option in TRI-MEweb to prepare separate Form R reports for the multi-establishment facility ¦ Avoid double-counting at the facility of chemicals involved in intra-facility transfers ------- T R I REPORTING REQUIREMENTS Example: EPCRA Section 313 Non-PBT Chemical Reporting Threshold Worksheet Facility Name: OMNI CHEMICAL Date Worksheet Prepared:. Toxic Chemical or Chemical Category: T^iuerK.' Prepared Bv: J.S.P. Reporting Year: Step 1. Identify amounts of the toxic chemical manufactured, processed, or otherwise used. Mixture Name or Other Identifiei Information Source Percent by Weight Total Weight (in lb) Amount of the Listed Toxic Chemical by Activity (in lb): Manufactured Processed Otherwise Used 1. Bulk Toluene SDS 93 23.000 22,500 2. Joe's Deqreaser Purchasina 50 10,000 5000 3. Bathroom Paint Vendor 5 30,000 1.500 4. Parts Washer Fluid Purchasina 40 10.000 4.000 5. 6. 7. Subtotal: (A) lb (B) 22,500 lb (O 10,500 lb Step 2. Identify exempt forms of the toxic chemical that have been included in Step 1. Mixture Name as Listed Above Applicable Exemption Note Fraction or Percent Exempt (if Applicable) Exempt Amount of the Toxic Chemical from Above (in lb): Manufactured Processed Otherwise Used 1. Bathroom Paint Struct. Como. 100 1.500 2. i. 4 * d 7 Subtotal: (A,) lb (B,) 22,500 lb (C,) 1,500 lb Step 3. Calculate the amount subject to threshold: (A - At) lb (B - li,) 22.500 lb (C- Cj) 9,000 lb Compare to thresholds for section 313 reporting. 25.000 lb 25.000 lb 10,000 lb If any threshold is met, reporting is required for all activities. Do not submit this worksheet with Form R. Retain for your records. 68 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Lessons Learned Begin early Implement a program to gather "real-time" data on usage Searches for historical information can be difficult Team approach Include all relevant personnel (e.g., engineering, purchasing, environmental, waste management, operations) Recordkeeping & Documentation Keep good records and document all work ------- T R I REPORTING REQUIREMENTS Record Keeping and Documentation Importance of good record keeping Detailed records improve reporting accuracy and data quality Reduces replication of effort from year to year ¦ Well-labeled calculations and engineering assumptions serve as standard operating procedures (SOPs) for future years Ensures consistency from year to year, especially if personnel responsible for reporting change EPA Requirements Records used to complete Form R must be kept for three years from the time the report was submitted (40 CFR § 372.10) EPA may review records during a data quality audit ------- 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 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 * Complete Final QA/QC I Certify Form ~ Submit to EPA & State or Tribe TRI 71 ------- Section V: < 7 9 fan Overview offoran R ------- T R I REPORTING REQUIREMENTS Overview of Form R Two principal types of information required ¦ Facility-specific ¦ Chemical-specific One form submitted to EPA and to the State/Tribe for each Section 313 chemical or chemical category exceeding applicable thresholds (assuming other reporting criteria are met.) Forms must be submitted electronically via TRI-MEweb. No paper submissions are accepted (except for trade secrets), including revisions and withdrawals. ------- T R I REPORTING R E Q U I R E M E N T S Form R Content Parti Section 1: Reporting Year Section 2: Trade Secret Information Section 3: Certification Section 4: Facility Identification Section 5: Parent Company Info Part II Section 1: Toxic Chemical ID Section 2: Mixture Component ID Section 3: Activities & Uses Section 4: Max Amt on site for CY Section 5: On-site Releases Section 6: Off-site Transfers Section 7: On-site Waste Treatment, Energy Recovery, Recycling Processes Section 8: Source Reduction and Waste Management Activities 74 ------- T R I REPO W W N G RE'QUPREMEN f 1 Facility Identification • Select your facility with 'My Facilities' ¦ For returning users, TRI-MEweb stores faci.ity information • Select "Edit" to view or make changes to the facility ¦ For new TRI users reporting for an existing TRI facility, look up the existing TRI facility using 'Access/Add Facility' • Option 1: Enter TRI Facility ID (TRIFID) and Technical Contact Name and Phone Number • Option 2: Enter six-to-seven digit facility access key ¦ For new facilities that have never reported to TRI, set up a new facility using 'Access/Add Facility' • Option 3: Generate new facility in TRI-MEweb, TRIFID and access key assigned. ------- T R I REPORTING REQUIREMENTS Facility Identification • Facility Name and Address (Section 4.1) ¦ Facility name • Standard facility names are available through the Facility Registry System (www. eoa. gov/enviro/html/fii/ez. html) ¦ Street address (no PO Box or other mailing address) • Mailing address required if different from street address • Full or Partial Facility and Federal Facility Designation (Section 4.2) ¦ Facility type (select one) • Federal facility; • Government Owned, Contractor Operated (GOCO); or • Neither ¦ For multi-establishment facilities, option to indicate reporting for part of a facility (Form R only). • Facilities reporting by part use the same TRIFID for all reports ------- T R I REPORTING REQUIREMENTS Facility Identification • Parent Company Information (Section 5) ¦ Parent company name • TRI-MEweb preloads standardized Parent Company names for prior TRI reporters. (Can change pre-loaded Parent Company names, if necessary) • For new TRI reporters, the TRI-MEweb software has a list of standardized Parent Company names. If reporters cannot find correct name from the provided list, enter a new name. ¦ Parent company Dun and Bradstreet Number • Facility Dun and Bradstreet Numbers (Section 4.6) To verify the accuracy of facility and parent company D&B number and name, go to: https://www.dnb.com/product/dIw/form cc4.htm or call 1-888-814-1435 ------- T R I REPORTING REQUIREMENTS Facility Identification (continued) Primary arid Secondary NAICS codes (Section 4.5) ¦ Enter primary 6-digit NAICS code ¦ Enter other applicable NAICS codes in decreasing order of significance www.naics.com/search.htm http://www2.epa.qov/toxics-release-inventorv-tri-proqram/mv- facilitvs-six-diqit-naics-code-tri-covered-industrv ------- T R I REPORTING REQUIREMENTS Part II - Chemical-Specific information TRI-MEweb preloads previous year's chemicals To select new chemical (Part II Sections 1.1-1.3, 2.1) ¦ Select CAS number or category code and name of chemical or chemical category - except on trade secret "sanitized" form; or ¦ Enter generic name only if claiming chemical name as a trade secret (40 CFR 350); or ¦ Report generic name provide by supplier, if supplier claims trade secret Contact information (Part I, Section 4.3 and 4.4) ¦ List name, phone number, and email • Technical contact- should be able to explain data to EPA • Facilities should provide an email address for the technical contact (not provided in TRI's public data release) • Public contact - should be able to represent the facility's data to the public. 79 ------- ft* rJ ¦ - - - Activities and Uses Specify use(s) of the Section 313 chemical (Section 3) (e.g., manufacture, process, or otherwise use) ¦ Report only activities taking place at reporting facility ¦ Check all applicable boxes 3.1 Manufacture «, Yes Q No 3,1 Did vour facility manufacture 1.1-Dimethyl hydrazine in Reportina Year 2012? i$i Yes 0 No a. Was 1,1-Dimethyl hydrazine produced at your facility? i." i Yes i$ No g] Yes b. Was 1.1-Dimethyl hydrazine imported by your facility? c. Was 1.1-Dimethvl hydrazine produced or imported for on-site use or processina? mYes d. Was 1.1-Dimethvl hydrazine produced or imported for sale or distribution? O Yes e. Was 1.1-Dimethvl hydrazine produced or imported as a byproduct? ~ Yes f. Was 1,1-Dimethyl hvdrazine produced or imported as an impurity? 3.2 Process 0 Yes ® No 3.2 Did your facility process 1,1-Dimethyl hydrazine in Reportina Year 2012? 3.3 Otherwise Use a Yes 0 No 3.3 Did vour facility otherwise use 1.1-Dimethvl hydrazine in Reportina Year 2012? ~ Yes a. Was 1,1-Dimethyl hvdrazine otherwise used as a chemical processina aid? ~ Yes b, Was 1.1-Dimethvl hvdrazine otherwise used as a manufactured aid? M Yes c. Was 1,1-Dimethyl hvdrazine otherwise used as ancillary or for another use? 80 ------- T R I REPORTING REQUIREMENTS Maximum On-Site Amount Select appropriate code indicating the maximum quantity on-site during the reporting year (Section 4). Range Code: [ -- Seiect a Range Code -- r*j — Select a Range Code — 1 0-99 lbs 2 100 - 999 lbs 3 1000 - 9999 lbs 4 10,000 -99,999 lbs 5 100,000-999,999 lbs 6 1,000,000- 9,999,999 lbs 7 10,000,000 - 49,999,999 lbs 8 50,000,000 - 99,999,999 lbs 9 100,000,000 - 499,999,999 lbs 10 500,000,000 - 999,999,999 lbs 11 greater than 1 billion lbs Use maximum total (non-exempt) amount present at one time during reporting year, even if the Section 313 chemical is present at more than one location at the facility ¦ Based on amount in storage, process, and wastes ¦ Maximum amount on site may differ from the Tier ll-reported maximum amount on site value • Tier II is usually by mixtures, Form R is chemical-specific • Tier II excludes hazardous wastes, Form R does not ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Reporting Releases and Waste Management Quantity of the toxic chemical entering each environmental medium on-site (Section 5) Transfers to other off-site locations (Section 6) On-site waste treatment, energy recovery, and recycling methods and quantities (Sections 7 and 8.2, 8.4, and 8.6) ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Tools and Data Sources for Release and Waste Management Calculations Previous year Form R report(s) and documentation Process flow diagrams Environmental monitoring data Permit applications EPCRA, CERCLA, RCRA, NPDES, CAA and other env. reports Waste management manifests, invoices, and waste profiles Engineering calculations and other notes • EPA guidance (AP-42, WebFIRE, TANKS, WATER9) ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Estimating Quantities Released and Managed as Waste Consider all sources (routine and non-routine) Reasonable estimates are required by law The facility needs to determine the best approach Data and approach must be documented, and should be consistent! ------- T R I REPORTING REQUIREMENTS Data Precision EPA allows using two significant figures when reporting releases and other waste management estimates ¦ The number of significant figures is typically the number of non- zero digits ¦ If estimate is more precise, additional significant figures may be used based on precision of data used to calculate estimate • Regardless of estimation precision, however, non-PBT chemical quantities should be entered in whole numbers in TRI-MEweb • Note that certain waste management quantities calculated automatically by TRI-MEweb may include up to two decimals • For estimates of non-PBT Section 313 chemicals under 1,000 pounds, a range code can be used: ¦ A= 1-10 pounds; B = 11-499 pounds; C = 500-999 pounds • Note: If you enter a range code, TRI data tools used by the public will display the midpoint of the range (e.g., 5, 250, or 750 lbs). 85 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Data Precision (continued) For PBT chemicals, report releases and other waste management quantities at a level of precision supported by the data and estimation techniques used For PBT chemicals, 0.1 pound (100 micrograms for dioxins) is the smallest amount required to be reported ¦ Estimates < 0.05 pounds (< 50 micrograms for dioxins) can be rounded down to zero pounds TRI-MEweb will allow for decimal reporting for PBT chemicals (e.g., 9.3 pounds) ------- T R I REPORTING REQUIREMENTS "NA" vs. "0" All data elements in Sections 5 and 6 must be completed. If you determine that there was no release or transfer quantity: ¦ Use "NA" (not applicable) when no possib ility of the Section 313 chemical being released to or otherwise managed as waste in that media (e.g., facility has no on-site landfill) or has not transferred any waste to an off-site location) OR ¦ Use "0" when no release occurs or < 0.5 pound of a non-PBT Section 313 chemical from a waste stream is directed towards that medium • Example: Discharge to water is zero; however, release possible if control equipment fails • Must indicate a Basis of Estimate code (i.e., M1, M2, C, E1, E2, O) for all numerical estimates, including "0" 87 ------- If r i ft i*' ¦ Quantity Entering Each Medium Report total releases of the Section 313 chemical to each environmental medium on-site - air, water, land (Section 5). Enter Total Release, report total quantity ¦ Range codes can be used in Sections 5 and 6 for non-PBT Section 313 chemical quantities less than 1,000 pounds* • A - 1 - 10 pounds • B- 11 - 499 pounds • C = 500 - 999 pounds * Note that similar quantities reported in Section 8 of Form R must be actual values and not ranges. The Section 8 Calculator in TRI-MEweb will assume the midpoint of any ranges reported in Sections 5 and 6 when calculating quantities for Section 8. If you do not wish to use the midpoint of the range in Section 8 calculations, it is best to enter a value rather than a range in Section 5. ------- T R I REPORTING REQUIREMENTS Basis of Estimate Codes One of the following "Basis of Estimate" codes must be listed on the Form R for each release and waste management quantity reported: ¦ Continuous monitoring (M1) ¦ Periodic or random monitoring (M2) ¦ Mass balance calculation (C) ¦ Published emissions factors (E1) ¦ Site-specific emissions factors (E2) ¦ Engineering calculations (O) • Everything NOT M1, M2, C,E1 or E2 above, such as: Best engineering judgment Estimated removal efficiencies Non-chemical-specific and non-published emission factors • Use the code ori the Form R for the method used to estimate the largest portion of the release 89 ------- T R I REPORTING REQUIREMENTS Fugitive or Non-Point Air Emissions Enter total fugitive releases of the Section 313 chemical, including leaks, evaporative losses, building ventilation, or other non-point air emissions (Section 5.1) Example Using a Mass Balance Basis of Estimate (C): ¦ 5,000 lbs of a volatile solvent are added during the year as part of the manufacture of a quid adhesive. 4,950 lbs of the solvent are contained in the final liquid adhesive product. • Input (5,000 lbs) = Output (4,950 lbs) + Air Loss (50 lbs) • Fugitive air emissions from this process = 50 lbs Law of Mass Balance: What Goes In = What Comes Out 90 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Estimating Releases When No Data Available (Fugitive) Example: Metal dust observed on floor near or within metalworking operation - indicates fugitive air emission occurring and possible transfer off-site; no additional data are available: ¦ Work with operations personnel familiar with the operation to gather relevant information about the releases or waste generation Document the calculations performed and keep records for future reporting and in case of audit Basis of Estimate code 'O' will likely be used Range codes may be used in some situations 91 ------- T R I REPORTING REQUIREMENTS Stack or Point-Source Air Emissions Enter total releases to air from point sources, including stacks, vents, pipes, ducts, storage tanks, or other confined air streams (Section 5.2) Data sources/tools ¦ Air permit applications ¦ CAA Title V air inventories ¦ Process and production data ¦ Published emission factors ¦ Facility-specific monitoring data and emissions factors Example using an Emission Factor basis of estimate (El): ¦ 500,000 tons of coal are combusted in a fluidized bed combustor ¦ EPA emission factor: 0.11 lb mercury emitted 11,000,000 lb coal combusted ¦ 500,000 tons x 2,000 pounds I ton x (0.11 lb mercury 11,000,000 lb coal) = 110 lb mercury ¦ 110 pounds of mercury are released through the stack ¦ Note: A portion of mercury may be present in resulting ash and would need to be reported as such ------- T R I REPORTING REQUIREMENTS On-Site Wastewater Discharges Releases to streams or water bodies (Section 5.3) ¦ Use the map provided in TRI-MEweb to select the name of the receiving stream or waterbody. If not found, manually enter the name. ¦ Optional: Reach Code, which describes the specific location of the outfall. TRI- MEweb will automatically provide the Reach Code by using the map. ¦ Enter the total amount of Section 313 chemical released to each receiving stream or waterbody ¦ Enter the basis of estimate code ¦ Indicate percentage of total release quantity contributed by stormwater runoff (choose NA if not applicable). ¦ Select NA box for Section 5.3 if the facility does not discharge the Section 313 chemical to streams or water bodies. Stream or Water Body Name Reach Code (optional} Quantity lbs Range Code Basis of Estimate Code %from Stormwater Mississippi River 07110004000001 54 M2 - Monitoring. 100% fj} Edit X Delete Periodic/Random ------- T R I REPORTING REQUIREMENTS Calculating Wastewater Discharges Release to stream or water body (Section 5.3) and Discharges to POTW (Section 6.1) are not the same ¦ Direct AND Indirect Discharges • Don't forget storm water! ¦ If no monitoring data exists, estimate based on process knowledge and/or mass balance calculation Data Sources ¦ DMRs (or related wastewater monitoring reports) ¦ Other monitoring data such as permit applications 94 ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Calculating Wastewater Discharges Calculate the yearly pounds of methanol discharged using the following data concerning wastewater discharges of methanol: Date Cone, (mg/l) Flow (MGD) Amt. (lb/day) 3/1 1.0 1.0 8.33 9/8 0.2 0.2 0.33 Average = 4.33 MGD = million gallons per day 1 mg/l = 8.33 lb/million gal Assuming 365 days of discharge and no other sources: 4.33 lb/day x 365 day = 1,580 lb total release Basis of Estimate Code: M2 Include receiving stream or waterbody name and Reach Code (optional) Indicate NA for contribution from stormwater. 95 ------- T R I R E P ( TING REQUIREMENTS On-Site Injection Wells Underground injection to Class I wells (Section 5.4.1) ¦ Enter total amount of Section 313 chemical injected into Class I wells at facility and basis of estimate code Underground injection to Class II - V wells (Section 5.4.2) ¦ Enter total amount of Section 313 chemical injected into Class II - V wells at facil ity and basis of estimate code Total Quantity: - or - lbs Range Code: | No Code Selected Basis of Estimate: J No Value Selected 3 Note: Basis of estimate code must be entered. 96 ------- T R I REPORTING REQUIREMENTS Other Disposal to Land On-Site Enter quantity of toxic chemical entering each on-site land disposal option (Section 5.5) ¦ On-site landfills: RCRA Subtitle C (Section 5.5.1A) ¦ On-site landfills: other (Section 5.5.1 B) ¦ On-site land treatment and application farming (Section 5.5.2) ¦ On-site surface impoundments: RCRA Subtitle C (Section 5.5.3A) ¦ On-site surface impoundments: Other (Section 5.5.3B) ¦ Other disposal (includes spills or leaks to land) (Section 5.5.4) Quantities released to air or water during the reporting year of the initial release to land (e.g., volatilization from surface impoundments) are not included in the land disposal quantity ------- T R I REPO Rllf N G RE'QuPREMEN f 1 On-Site Waste Management Examples of on-site waste management ¦ Air pollution control devices ¦ Wastewater treatment processes ¦ Energy recovery devices ¦ Recycling devices ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Waste Treatment Methods and Efficiency Report each waste treatment method that each waste stream containing the Section 313 chemical undergoes (Section 7A) ¦ Include even if method has no effect on the chemical ¦ Report the efficiency of the waste treatment methods at eliminating the Section 313 chemical from the waste stream • Includes destruction or physical removal jyi Waste a. General b. Waste Treatment Waste Treatment c. Waste Treatment Efficiency Profile Stream Method(s) Name Code Sequence Chemical L - Liquid H075 oxidation waste streams (non-aque |Select a Range Edj1 j r^^ete! Select a Range El - Greater than 99.9999% E2 - Greater than 99.99%, but less than or equal to 99.9999% E3 - Greater than 99%, but less than or equal to 99.99% E4 - Greater than 95%, but less than or equal to 99% E5 - Greater than 50%, but less than or equal to 95% E6 - Equal to or greater than 0%, but less than or equal to 50% Select from the list and click Add Selected: |~i Enter quantity treated on-site (destruction only) 99 ------- ft* rJ Energy Recovery Methods and Quantity Enter on-site energy recovery quantity and methods for Section 313 chemical ¦ Section 313 chemical must be combustible and have a significant heating value (>5,000 BTU/lb.) ¦ Combustion unit is integrated nto an energy recovery system (e.g., industrial furnace, industrial kiln, or boiler) Enter codes in descending order by quantities combusted Quantity Used for Energy Recovery Onsite: Current Year (lbs) Energy Recovery Methods: (Select the order of energy recovery methods used) First Method Second Method Third Method J Not Selected _*_] | Not Selected jJ | Not Selected MM 100 7T ------- T R I REPORTING REQUIREMENTS Recycling Methods and Quantity Enter quantity and methods used for on-site recycling of the Section 313 chemical (Sections 7C and 8.4 current year) ¦ Codes for recycling methods used are found in EPA's TRI Reporting Forms and Instructions document ¦ Do not nclude energy recovery processes Enter codes in descending order by quantities recycled Qua ntity Re cycl e d 0 nsite: | current Year (lbs) Recycling Methods: (Select 2fte order of recycling methods used) First Method Second Method | Not Selected | Not Selected 101 ------- T R I REPORTING REQUIREMENTS Off-Site Transfers Includes both off-site location information and quantities of Section 313 chemicals transferred to off-site locations Report quantities of chemical sent off-site to each POTW or other location for recycling, energy recovery, waste treatment, or disposal Report only total quantity of chemical transferred off-site, not the quantity of entire waste stream mixture In Sections 6.1 and 6.2, Total Transfers, report total quantity ¦ Range codes can be used in Sections 5 and 6 for non-PBT Section 313 chemical quantities less than 1,000 pounds* • A - 1 - 10 pounds • B - 11 - 499 pounds • C = 500 - 999 pounds * Note that similar quantities reported in Section 8 of Form R must be actual values and not ranges. The Section 8 Calculator in TRI-MEweb will assume the midpoint of any ranges reported in Sections 5 and 6 when calculating quantities for Section 8. If you do not wish to use the midpoint of the range in Section 8 calculations, it is best to enter a value rather than a range in Section 6. 102 ------- T R I REPORTING REQUIREMENTS Transfers to POTWs Discharges to publicly owned treatment works ¦ Enter total quantity of the Section 313 chemical transferred to all POTWs and basis of estimate ¦ Select POTW name and location for each POTW ¦ May be able to find official name of POTW: • Using TRI-MEweb search tool • Facility Registry System: www. eoa. gov/enviro/html/fii/ez. html Example using an Engineering Calculations basis of estimate (O): ¦ A wet grinding process generates wastewater with 300 lbs of lead (contained in particulates) during the year. This wastewater undergoes on-site filtration prior to being sent to the POTW. Manuals from the filter equipment vendor indicate a 95% removal efficiency for particulates of this size. • 300 x 0.95 = 285 lbs removed from the wastewater • 300 - 285 = 15 pounds remaining in the wastewater after filtration • 15 pounds of lead are transferred off-site to the POTW • You may enter the percentage of the chemical that is released by the POTW and it will be applied in the automatic Section 8 calculations (otherwise default percentages will be used). 103 ------- T R I REPORTING REQUIREMENTS Other Off-site Transfers Enter transfers to other off-site locations (Section 6.2) ¦ Include name, address, and EPA identification (RCRA ID) number of the receiving facility ¦ Enter quantity, basis of estimate, and M code for each different waste management activity (waste treatment, disposal, recycling, and energy recovery) ¦ Check "NA" box to indicate no transfers to off-site locations Data/tools ¦ Waste manifests and vendor receipts ¦ RCRA reports ¦ Waste characterization - analyses, profiles ------- T R I REPORTING REQUIREMENTS Off-Site Waste Transfers Identify all sources of off-site transfers of TRI chemicals Potential off-site waste transfers of reportable chemicals ¦ Hazardous waste ¦ Non-hazardous waste (e.g., waste oil and coolant) ¦ Trash ¦ Scrap metal (reuse versus recycle) ¦ Container residue: RCRA empty is NOT EPCRA empty - BE COMPREHENSIVE! Identify sources for waste composition data Identify final disposition of each Section 313 chemical: ¦ Disposal, waste treatment, energy recovery, recycling by selecting the appropriate code 105 ------- T R I REPORTING REQUIREMENTS Release and Waste Management Estimates Helpful hints for accurate release estimates ¦ Always use your best available information ¦ Estimate the quantity of Section 313 chemical, not the entire waste stream ¦ Differentiate fugitive from stack air emissions ¦ Zero air emissions for volatile organic compounds (VOCs) are unl kely ¦ Watch out for releases of Section 313 chemicals with qual ifiers ¦ Check your math and document your work! Result of release estimation errors ¦ Incorrect release estimates and inconsistencies could carry over from year to year 106 ------- T R I REPORTING REQUIREMENTS Waste Management Hierarchy Section 8 of Form R: Source Reduction and Waste Management Waste Management Hierarchy ------- T R I REPORTING REQUIREMENTS Production-Related Waste Managed (Section 8.1-8.7) The sum of sections 8.1 through 8.7 represents the total quantity of waste generated through regular production activities at your facility for the reporting year. _ Prior Year Current Year Following Year Second Following Year ** Waste Management Description (RY2009) (RY2010) (RY2011) (RY2012) 8.1a) Total on-site disposal... 0 0 h NA |rj I- NA 8.1b) Total other on-site disposal... 390 410 I4O0 |~ NA [407 I- NA 8.1c) Total off-site disposal... 0 0 |= NA jT NA 8.1d) Total other off-site disposal... 1050 1145 |~ NA [1068 |~ NA 8.2) Quantity used for energy recovery onsite 0 0 fo NA [0 NA 8.3) Quantity used for energy recovery offsite 0 NA I p NA p NA 8.4) Quantity recycled onsite 0 0 jo f NA [15 NA 8.5) Quantity recycled offsite 0 NA j p NA | p NA 8.6) Quantity treated onsite 5000 5150 I5100 f NA 14970 P NA 8.7) Quantity treated offsite 0 0 Fi ~ NA (0 I- NA TRI-MEweb includes a Section 8 Calculator feature that helps calculate Section 8 estimates from estimates reported in previous portions of on-line application. A validation feature ensures consistency between Sections 5 and 6 and Section 8. 108 ------- T R I REPORTING REQUIREMENTS Section 8: Relationship to Sections 5 and 6 Part II. Sections 8.1 - 8.7 8.1a Total on-site disposal to Class I UIC wells, RCRA & other landfills 5.4.1 + 5.5.1 A + 5.5.1 B - 8.8 (on-site release or disposal due to catastrophic event) 8.1b Total other on-site disposal or other releases 5.1, 5.2, 5.3.1, 5.3.2, 5.3.3, 5.4.2, 5.5.2, 5.5.3A, 5.5.3B, 5.5.4 - 8.8 (on-site release or disposal due to catastrophic event) 8.1c Total off-site disposal to Class I UIC wells, RCRA & other landfills Section 6.2, M64, M65, and M81 - 8.8 (off-site disposal due to catastrophic event) 8.1d Total other off-site disposal or other releases 6.1 (for metals and metal category compounds only) + 6.2 (quantities associated with M codes M10, M41, M62, M66, M67, M73, M79, M82, M90, M94, M99) - 8.8 (off-site disposal due to catastrophic event) 8.3 Off-site energy recovery 6.2, M56 and M92 - 8.8 (off-site energy recovery due to catastrophic events) 8.5 Off-site recycling 6.2, M20, M24, M26, M28, and M93 - 8.8 (off-site recycling due to catastrophic events) 8.7 Off-site treatment 6.1 (excluding metals and metal category compounds), 6.2 (quantities associated with M codes M50, M54, M61, M69, M95) - 8.8 (off-site treatment due to catastrophic event) Note: Quantity reported in 6.1 is distributed among 8.1c, 8.1 d and 8.7 based on final disposition. TRI-MEweb provides default percentages for making this distribution. Metals and metal category compounds should not be reported in 8.7. 109 ------- T R I REPORTING REQUIREMENTS Section 8: Relationship to Section 7 Part II. Sections 8.1 - 8.7 8.2 On-Site Energy Recovery • Determine quantity for activities described in 7B • Report quantity actually combusted in energy recovery unit (i.e., consider efficiency) 8.4 On-Site Recycling • Determine quantity for activities described in 7C • Report quantity actually recycled (i.e., consider efficiency) 8.6 On-Site Treatment • Determine quantity of the chemical for activities on waste stream described in 7 A • Report quantity actually destroyed (i.e., consider efficiency) • Metals and metal category compounds cannot be reported here ------- T R I R BP O Rllf N G RE'QUPREMEN f 1 Non-Production-Related Waste Managed Enter the quantity of Section 313 chemical released into the environment or transferred off-site (Section 8.8) as a result of: Remediation Catastrophic events (e.g., earthquake, hurricane, fire, floods) Other one-time events not associated with production processes (e.g., pipe rupture due to unexpected weather) Does not include quantities treated, recovered for energy, or recycled ON- SITE Quantities in Sections 8.1 through 8.7 should not include amounts reported in Section 8.8 TRI-MEweb calculator will subtract any quantities reported as non-production- related waste from 8.1-8.7 quantities 111 ------- T R I REPORTING REQUIREMENTS Production Ratio or Activity Ratio Production ratio or activity ratio (Section 8.9) A ratio of production or activity involving the Section 313 chemical in the reporting year to production or activity in the previous year Puts year-to-year changes in chemical quantities released and managed as waste into the context of production Tips: Consider using a production ratio when production is directly related to the amount of chemical used or produced Consider using an activity ratio when the chemical is "otherwise used" and the amount is determined by a variable other than production The Production Ratio/Activity Ratio is a ratio, not a percent change You can provide information on the variable you used in your ratio in the "Optional Miscellaneous Info" section using the button in TRI-MEweb A Production Ratio Wizard is now available in TRI-MEweb to help you calculate your Production Ratio or Activity Ratio ------- t r i i if o Rllf n g re'quPremen f 1 Production Ratio or Activity Ratio Examples Example (Production Ratio): Oven manufacturing 40,000 ovens assembled (Current RY) = 1.14 35,000 ovens assembled (Prior RY) Example (Activity Ratio): Tank washouts 50 Washouts (Current RY) = 0.83 60 Washouts (Prior RY) Additional Production / Activity Variable Examples, by Industry ¦ Refractory Manufacturing: Tons of brick manufactured ¦ Chemical Wholesalers: Gallons of glycol ethers packaged ¦ Electric Power Generation: Megawatt-hours of electricity produced ¦ National Security: Man-days of training per year ¦ Synthetic Dye Manufacturing: Number of color changeovers ¦ Waste Treatment and Disposal: Tons of waste landfilled on-site 113 ------- T R I REPORTING REQUIREMENTS Source Reduction Activities • Report Source Reduction activities implemented for the chemical, and the methods used to identify those activities (Section 8.10) ¦ Include only those source reduction activities implemented for the first time during the reporting year • Include activities that reduce the total quantity of chemical waste released (including disposal), recycled, combusted for energy recovery, or treated ¦ Examples of Source Reduction Activities • Process or equipment changes (e.g., replacements, adjustments) • Product redesign • Changed production schedule to minimize equipment changeovers • Green chemistry practices (e.g., Optimized reaction conditions or otherwise increased efficiency of synthesis) • You may also report the estimated annual reduction associated with each activity using range codes provided ¦ Based on expected amount of chemical waste generation once the activity has been implemented as a percentage of the amount that would have been generated otherwise 114 ------- T R I REPORTING REQUIREMENTS Optional Pollution Prevention Information Report additional information in the open-ended Pollution Prevention Information text field (Section 8.11) ¦ This optional section provides an opportunity to publicly highlight any steps your facility took to reduce the amount of toxic chemicals entering the environment ¦ Information about recycling, energy recovery, and treatment is welcome in addition to details about source reduction activities ¦ Facility can provide nformation on previous years' activities Tips ¦ Be specific ¦ Enter useful URLs ¦ Note any barriers inhibiting P2 (using checkboxes in TRI-MEweb) ¦ Put information unrelated to P2 in Section 9.1 TRI's P2 website features P2 information reported by facilities and includes a P2 reporting tip-sheet http://www.epa.gov/tri/p2 115 ------- T R I REPORTING REQUIREMENTS Optional Miscellaneous Information Optional Miscellaneous Information (Section 9.1) - Facility can provide any useful additional information related to any portion of the Form R submission in this new data field - Examples of information to include: • Changes in production • Facility closures • Staffing changes • Calculation methods, e.g., emission factors • Explanation of data quality alerts • TRI-MEweb provides a pick-list of suggested topics for this Section • When providing optional miscellaneous information, it is helpful to check the box next to the topic to which your information pertains 116 ------- Sectidn yjf a m" Alternate Threshold Kale ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Form A Eligibility If alternate threshold criteria met: Have the option to file a Form A in eu of a Form R No detailed release, other waste management, or source reduction reporting Maintain records and calculations used to determine Form A eligibility Facilities can submit a combination of Forms R and Forms A. Some chemicals may meet Form A criteria, others may not. If a facility submits a Form A and does not meet the qualifying criteria, it may result in an enforcement action. ------- T R I REPORTING REQUIREMENTS Criteria for Submitting Form A Must NOT be a PBT chemical Do not exceed 1,000,000 pounds of the toxic chemical manufactured, processed, or otherwise used. Do not exceed 500 pounds for the total annual waste management (i.e., releases including disposal, recycling, energy recovery, and treatment) of the Section 313 chemical. Equivalent to the sum of the quantities calculated for Sections 8.1 - 8.7 of the Form R 119 ------- Sectionyjl: TRI-MEweb Introduction ------- T R I REPORTING 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 2/5/2018 121 ------- T R I REPORTING 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: Enter TRIFID and Technical Contact Name ¦ Option 2: Enter six-digit facility access code ¦ Option 3: New facil ity, never reported to TRI • For assistance with accessing your facility, contact the CDX helpdesk at helpdesk@epacdx.net or call toll-free at (888) 890-1995. ------- T R I REPORTING 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 Signature Agreement 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 Signature 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 Signature Agreement before pending submissions can be reviewed and certified 123 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 Optional Facility-Level Information • Facilities may provide optional information on facility operations • Section 9.1 of the Form R allows a facility to provide optional miscellaneous information on the form submission or facility • However, some types of miscellaneous information do not fit well into a TRI reporting form or arise outside of the reporting process ¦ TRI-MEweb allows you to provide optional facility-level information without preparing and submitting a TRI reporting form ¦ Accessible on the Facility Management Screen: Click the Take Action button and select 'Not Reporting?' ------- T R I REPORTING REQUIREMENTS Optional Facility-Level Information • Topics on which you may elect to provide information include: ¦ Faci lity name or address has changed ¦ Facility contact information has changed ¦ Facility closed either completely or temporarily ¦ Facility did not trigger reporting due to Not having 10 or more full-time employee equivalents Not being in a covered NAICS sector Having fallen below reporting threshold for one or more chemicals Benefits of providing this information nclude: ¦ Keep address and contact nformation up-to-date to help EPA contact your facility Ensure email notices reach proper facility contacts ¦ Provides clarity on why reporting may have changed substantially Could minimize need for EPA to contact facility on data quality matters 125 ------- T R I REPO Rllf N G RE'QuPREMEN f 1 For More Information and Assistance • For more information on TRI requirements, see the second part of this training course on TRI Advanced Concepts. • For TRI reporting guidance, information and tutorials on the TRI-MEweb reporting software, and the latest changes to the TRI Program please visit www.epa.gov/tri. • Industry-specific and chemical-specific guidance can be found at: www.epa.gov/tri/quide docs/index.htm I 1_ 1_* • For help accessing CDX accounts, password resets, accessing a facility, or completing an ESA, contact the CDX helpdesk: https://cdx.epa.gov/Contact ------- ------- |