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June 08, 2015
TRI to keep up with the changes
By Timothy P Fagan, Senior Legal Editor - EHS

Memorial Day has passed and the beginning of summer is upon us.  In the world of environmental compliance this means that Toxics Release Inventory (TRI) reports are on the top of the “to-do” list.  TRI reports are due July 1.

TRI reports, as mandated under Section 313 of the Emergency Planning and Community Right to Know Act and implemented under 40 CFR 372, are required to be submitted by facilities with 10 or more full-time employees, in specified Standard Industrial Classification (SIC)  and North American Industry Classification System (NAICS) codes, that manufacture, process, or otherwise use listed TRI chemicals in excess of the established thresholds.  The thresholds per calendar year are:

  • 25,000 lb per toxic chemical manufactured or processed, other than persistent  bioaccumulative toxic (PBT) chemicals;
  • 10,000 lb per toxic chemical for chemicals otherwise used, other than PBT chemicals; and
  • As listed in 40 CFR 372.28 for PBT chemicals.

Reporting is done primarily through EPA’s TRI-MEweb online application. However, trade secret submissions must still be submitted on paper with trade secret substantiation forms.  In addition, many states attach fees to TRI reports that must be submitted separately from the TRI report.

Changes to the TRI reporting program for the 2014 Reporting Year (RY) (i.e., the report due on July 1, 2015) include a new chemical to report, new chemicals to track for next year, and enhancements to TRI-MEweb.

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New Chemicals

The EPA has made changes to the list of chemicals and chemical categories subject to inclusion in TRI reports.

  • o-Nitrotoluene (CAS# 88-72-2).  Facilities are required to include o-Nitrotoluene in TRI reports for the 2014 RY if the applicable thresholds are exceeded.  The EPA added o-Nitrotoluene to the TRI list because it was recently classified as “reasonably anticipated to be a human carcinogen” by the National Toxicology Program.    
  • Nonylphenol category.  Facilities are not required to include chemicals in the nonylphenol category for the 2014 RY, but should begin tracking these chemicals.  Reporting nonylphenol category chemicals will begin with the 2015 RY TRI reports due July 1, 2016.  The EPA added the nonylphenol category, which includes the following, to the TRI list because these substances are highly toxic to aquatic organisms:
    • 4-Nonylphenol (CAS#  104-40-5)
    • Isononylphenol (CAS# 11066-49-2)
    • Nonylphenol (CAS# 25154-52-3)
    • 4-Isononylphenol (CAS# 26543-97-5)
    • 4-Nonylphenol, branched (CAS# 84852-15-3)
    • Nonylphenol, branched (CAS# 90481-04-2)

TRI-MEweb Enhancements

The EPA has also made changes to TRI-MEweb, including the following, to facilitate communication with the agency and enhance the usefulness of the reported information as it is shared with the regulated community and the public through EPA’s various TRI data analysis tools. 

  • TRI-MEweb can be used to update facility information and to inform the EPA about your reporting status, e.g., you may indicate that you will no longer be reporting and provide the reasons.
  • For surface water discharges, the Reach Code (i.e., the 14-digit code assigned to a body of water by USGS’s National Hydrology Dataset) will be assigned to receiving waters to create consistency and enhance accuracy.  In most instances, this field will be populated automatically.
  • When addressing source reduction and waste management, you must indicate whether the data are based on a production ratio or an activity ratio, and a “wizard” exists to help you navigate this section.
  • Fields and checkboxes have been added to make it easier for you to provide information on your source reduction activities, such as expected results of source reduction activities, barriers to source reduction, and any other useful information.

Use the data

For many, compiling a TRI report is a large undertaking, so make it worthwhile by using your report as an opportunity to identify areas where you can make improvements at your facility.  Where are the opportunities for source reduction and pollution prevention?  Also, use EPA’s TRI data analysis tools to find out what other facilities are doing to reduce releases.  Can similar strategies be implemented at your facility?

Anything you can do to reduce your toxic releases is good for the environment, good for your facility’s image, and may be good for the bottom line.


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