TRI (Form R and Form A) Reporting Requirements [40 CFR 372]
Three criteria must be met during the previous calendar year in order to require your facility must report under SARA Section 313:
- 10 or more full-time employees, or any combination equal to 20,000 hours
- Primary NAICS code among those listed in the Federal Register, and federal facilities. The SIC-to-NAICS code conversion table recommended by EPA is available at http://www.census.gov/epcd/www/naics.html
- Manufactured, processed, or otherwise used a SARA 313 toxic chemical in excess of its established threshold:
- For non-PBT SARA 313 toxic chemicals (see 40 CFR 372.65), the thresholds are:
- Manufacturing—25,000 lb
- Processing—25,000 lb
- Otherwise use—10,000 lb
If the SARA 313 toxic chemical is a persistent bioaccumulative toxic chemical (see 40 CFR 372.28), or PBT, the thresholds are lowered to:
If your facility that meets these criteria for 2007, you must submit a Form R or Form A to EPA by July 1 of 2008. Ensure that you don’t overlook any chemicals are in your raw materials (such as lead and chromium in steel, or barium in pigments). Also keep in mind that you might manufacture chemicals in your air emissions or wastewater discharges that must be accounted for in your TRI report.
If your facility manufactured or used toxic chemicals at or above EPA thresholds during 2007, you may find it much easier to report using EPA’s Toxics Release Inventory Made Easy (TRI-ME) reporting software. The internet-based version, TRI-MEweb, offers several advantages over the standard TRI-ME desktop software.
Some advantages of reporting via TRI-MEweb are:
- Previous year TRI-ME data is automatically imported to make the reporting process even more efficient.
- Section 8 is automatically calculated by TRI-ME Web from data input in other sections.
- The facility will receive instant receipt confirmation.
- If reported via Central Data Exchange (CDX) or TRI-MEweb, many states allow EPA to send the state TRI report automatically.
- TRI-MEweb is available from any computer with Internet access.
- Errors may be corrected quickly online.
- Revisions and withdrawals of previously submitted TRI reports will be easier if reported using TRI-MEweb.
- TRI-MEweb has a feature called the Trend Analysis Report, by which a facility can compare current releases to previous years.
Like using the TRI-ME desktop software to report via CDX, TRI-MEweb expedites the Facility Data Profile (FDP) process to correct any errors that will otherwise become public information. EPA’s SARA 313 Q+A and guidance documents are incorporated into all versions of the TRI-ME reporting software, and free technical support is offered by EPA. TRI-ME also allows those concerned with saving paper to file paperless reports. Although TRI-ME will not print a paper copy to mail to EPA, it will print paper file copies and state paper submissions. While paper copies or electronic media generated from TRI-ME (or other approved software) may still be mailed, EPA prefers facilities to use TRI-ME to report over the Internet.
TRI Form Changes for the 2007 Reporting Year
EPA made some changes to the TRI forms for reporting year 2007. One change is the addition of a field to indicate the Public Contact’s e-mail address. Most of the changes are to help streamline corrections to or withdrawal of TRI reports after submission.
The 2007RY forms have additional fields in which up to two revision or withdrawal codes may be entered. EPA believes the codes will help improve the efficiency of the revision or withdrawal process. The revision codes cover reasons such as new monitoring of chemical concentration data, as well as new emission factors or calculations. The withdrawal codes are based upon the TRI reporting thresholds. For more information, including other required information to submit with a revision of withdrawal, see pages 4–7 of the TRI 2007RY Forms and Instructions.
New Basis of Estimate Codes for Form R Reports
For reporting year (RY) 2007 and afterward, EPA has changed the Basis of Estimate codes by subdividing the monitoring (formerly “M”) and emission factor (formerly “E”) codes used on the Form R. EPA believes this modification will better enable a facility to accurately describe the method used to determine the amount of toxic chemical released. EPA’s TRI 2007RY Forms and Instructions have a more complete description of where these codes must be used in the Form R. The new codes M1, M2, E1, and E2 are described as follows:
- (M1) Based on continuous monitoring data or measurements for the toxic chemical
- (M2) Based on periodic or random monitoring data or measurements for the toxic chemical
- (C) Based on mass balance calculations, such as calculation of the amount of the toxic chemical in streams entering and leaving process equipment
- (E1) Based on published emission factors, such as those relating release quantity to through-put or equipment type (e.g., air emission factors)
- (E2) Based on site-specific emission factors, such as those relating release quantity to through-put or equipment type (e.g., air emission factors)
- (O) Based on other approaches, such as engineering calculations (e.g., estimating volatilization using published mathematical formulas) or best engineering judgment. This would include applying an estimated removal efficiency to a waste stream, even if the composition of the stream before treatment was fully identified through monitoring data.
For consulting assistance with your TRI reporting requirements, contact Amy Knight
at 919-469-1585, Ext. 224. Links to other recent changes in the TRI program are available at http://epa.gov/tri