Toxics Release Inventory Presentation to: Arizona Chamber of - PowerPoint PPT Presentation

Toxics Release Inventory Presentation to: Arizona Chamber of Commerce Industry Environment Committee May 10, 2017 Angela Baranco TRI Program Coordinator US EPA Region 9 https://cdx.epa.gov https://www.epa.gov/tri-meweb 1

Outline Region 9 Pacific Southwest • Overview: History and Purpose of TRI Program • How to determine if a facility needs to report • Reporting exemptions • Form R Overview • Form A Overview • Common reporting errors • How TRI data is used and presented to the Public https://cdx.epa.gov https://www.epa.gov/tri-meweb 2

What is TRI? • TRI is the Toxics Release Inventory : a public database where citizens can learn about which toxic chemicals and quantities are released by which facilities in their communities. Waste Releases to the Recycling & Pollution Transfers Environment Treatment Prevention • Facilities are required to file a TRI report annually for each TRI chemical exceeding a certain threshold for certain facility activities. • Over 650 toxic chemicals or chemical categories. About 20,000 U.S. facilities file TRI reports. • TRI forms must be filed by July 1 for the previous calendar year. https://cdx.epa.gov https://www.epa.gov/tri-meweb 3

What is TRI? • Congress determined that U.S. citizens have the right to know about certain toxic chemical s being used by facilities and what these facilities release to the environment, treat, transfer or recycle. • Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986. • Requires facilities to report and EPA to collect, maintain, and provide public access to the TRI data. https://cdx.epa.gov https://www.epa.gov/tri-meweb 4

Why was the Toxics Release Inventory created? Bhopal, India December 1984 • Methyl isocyanate gas was released at a Union Carbide chemical plant. • Thousands died the first night, thousands more since • Survivors continue to suffer with permanent disabilities. Institute, West Virginia August 1985 • Chemical release at a similar facility in the U.S. Bhopal memorial for those • killed and disabled by the More than 100 people hospitalized. 1984 toxic gas release • These events led to increased concern about local preparedness for chemical emergencies and the availability of information on hazardous substances. • The passage of the Emergency Planning and Community Right-to-Know Act in 1986 was part of the United States’ response. https://cdx.epa.gov https://www.epa.gov/tri-meweb 5

Which facilities must report to TRI? 1. Facility must be in a TRI-covered industry sector or category , including: Coal/Oil Hazardous Manufacturing Certain Mining Federal Facilities Electricity Waste Facilities Generation Management 2. Facility must have the equivalent of at least 10 full-time employees. 3. Facility must manufacture, process or otherwise use more than a certain amount of a TRI-listed toxic chemical in a calendar year. https://cdx.epa.gov https://www.epa.gov/tri-meweb 6

What facilities do not report to TRI? 1.Industries/sectors not covered by TRI program 2. Facilities with less than 10 full-time employee equivalents. 3. Facilities that do not manufacture, process or use more than a certain amount of a TRI-listed toxic chemical in a calendar year. Retail / Stores Oil and Gas Facilities without TRI- Small Facilities listed toxic chemicals https://cdx.epa.gov https://www.epa.gov/tri-meweb 7

What do facilities report to TRI? • On-site releases of TRI chemicals to: – Air – Water – Land • Transfer of TRI chemical waste to off-site locations • Other waste management: – Recycling – Treatment – Energy Recovery • Pollution prevention activities https://cdx.epa.gov https://www.epa.gov/tri-meweb 8

Determining Need to Report https://cdx.epa.gov https://www.epa.gov/tri-meweb 9

Industry Sectors Covered https://cdx.epa.gov https://www.epa.gov/tri-meweb 10

Definition of “Facility” https://cdx.epa.gov https://www.epa.gov/tri-meweb 11

Example of Multi-Establishment Facility https://cdx.epa.gov https://www.epa.gov/tri-meweb 12

Employee Threshold https://cdx.epa.gov https://www.epa.gov/tri-meweb 13

TRI Chemical Activity Threshold https://cdx.epa.gov https://www.epa.gov/tri-meweb 14

TRI Chemical Activity Thresholds (excludes PBT chemicals which have lower thresholds) https://cdx.epa.gov https://www.epa.gov/tri-meweb 15

TRI Chemicals & Chemical Categories 16 https://cdx.epa.gov https://www.epa.gov/tri-meweb

TRI Chemicals with Qualifiers - Examples https://cdx.epa.gov https://www.epa.gov/tri-meweb 17

TRI Chemical Categories https://cdx.epa.gov https://www.epa.gov/tri-meweb 18

PBT Chemicals: Persistent, Bioaccumulative, Toxic https://cdx.epa.gov https://www.epa.gov/tri-meweb 19

PBT Chemicals & Activity Thresholds https://cdx.epa.gov https://www.epa.gov/tri-meweb 20

Manufacturing Activity – 25,000 pounds https://cdx.epa.gov https://www.epa.gov/tri-meweb 21

Processing Activity – 25,000 pounds https://cdx.epa.gov https://www.epa.gov/tri-meweb 22

Otherwise Use – 10,000 pounds https://cdx.epa.gov https://www.epa.gov/tri-meweb 23

Thresholds for Compound Categories https://cdx.epa.gov https://www.epa.gov/tri-meweb 24

Threshold for TRI Chemicals in Mixtures Exact concentration – use concentration known/provided - Upper bound – use upper limit - Range – use midpoint - Lower bound – subtract out other known constituents, - create a range, use midpoint of range https://cdx.epa.gov https://www.epa.gov/tri-meweb 25

Exemptions from TRI Reporting https://cdx.epa.gov https://www.epa.gov/tri-meweb 26

De Minimis Exemption ; OR Article Exemption 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 TRI chemical under normal processing or use conditions at the facility. https://cdx.epa.gov https://www.epa.gov/tri-meweb 27

Article Exemption Examples https://cdx.epa.gov https://www.epa.gov/tri-meweb 28

Laboratory Exemption Not Exempt Exempt https://cdx.epa.gov https://www.epa.gov/tri-meweb 29

Motor Vehicle Maintenance Exemption https://cdx.epa.gov https://www.epa.gov/tri-meweb 30

Additional Threshold Guidance https://cdx.epa.gov https://www.epa.gov/tri-meweb 31

Combustion https://cdx.epa.gov https://www.epa.gov/tri-meweb 32

TRI Reporting Requirements • Annual – by July 1 for previous calendar Reporting Year • Electronic: TRI-MEweb via https://www. • Each TRI chemical is reported separately • Facility-level reporting • Releases only – not total TRI chemical quantity on-site • Methodology and calculations for threshold determinations are not submitted but MUST BE MAINTAINED ON-SITE at the facility for 3 years • Data and approach determined by facility – Reliable estimates for determinations are required by law • EPA allows two significant figures for releases, but more precision may be reported if used to calculate estimate. • For PBT chemicals, 0.1 pound (100 micrograms for dioxins) is the smallest amount REQUIRED to be reported. https://cdx.epa.gov https://www.epa.gov/tri-meweb 33

Record Keeping & Documentation https://cdx.epa.gov https://www.epa.gov/tri-meweb 34

Form R - Stack, Point, Fugitive - Water bodies (incl. storm water) - UIC wells, Landfills, Surface impoundments, other - POTW - Optional https://cdx.epa.gov https://www.epa.gov/tri-meweb 35

Form R • Activity use(s) of each chemical: Manufacturing, Processing, Otherwise used • Quantity of chemical released into each environmental category • Quantity of chemical transferred off-site • Methods and quantities of on-site waste treated, energy recovery, recycling • Pollution Prevention activities Form A • Must NOT be a PBT chemical • Does not exceed 1M pounds for manufacturing, processing or otherwise use • Does not exceed 500 pounds for the total annual waste management (including releases, disposal, recycling, energy recovery, treatment https://cdx.epa.gov https://www.epa.gov/tri-meweb 36

Common Reporting Errors • Otherwise Uses : If a facility only meets the threshold for this Activity category, it triggers reporting the use of ALL TRI CHEMICALS for EVERY REPORTING ACTIVITY CATEGORY • Failing to report to TRI based on quantity of releases instead of ACTIVITY USE THRESHOLD • Using wrong threshold for PBT chemicals • Incorrect calculations for Compounds and Mixtures • Use total compound mass for threshold but only Parent metal for releases • Uncertainty about “ Article” definition for that exemption • Not reporting TRI chemical “ manufactured” coincidentally in a process/activity • Form not signed / submitted by Certifying Official https://cdx.epa.gov https://www.epa.gov/tri-meweb 37

TRI-MEweb Reporting https://cdx.epa.gov https://www.epa.gov/tri-meweb 38

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