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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


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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

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Outline

  • 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

2 Region 9 Pacific Southwest https://cdx.epa.gov https://www.epa.gov/tri-meweb

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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.

Releases to the Environment Waste Transfers Recycling & Treatment Pollution 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.

3 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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What is TRI?

  • Congress determined that U.S. citizens have

the right to know about certain toxic chemicals 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.

4 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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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.
  • More than 100 people hospitalized.
  • 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.

Bhopal memorial for those killed and disabled by the 1984 toxic gas release

5 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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Which facilities must report to TRI?

  • 1. Facility must be in a TRI-covered industry sector or category,

including:

  • 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.

Manufacturing Coal/Oil Electricity Generation Certain Mining Facilities Hazardous Waste Management Federal Facilities

6 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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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.

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Oil and Gas Retail / Stores Small Facilities Facilities without TRI- listed toxic chemicals

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

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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

8 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 9

Determining Need to Report

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

Industry Sectors Covered

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 11

Definition of “Facility”

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 12

Example of Multi-Establishment Facility

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

Employee Threshold

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 14

TRI Chemical Activity Threshold

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 15

TRI Chemical Activity Thresholds (excludes PBT chemicals which have lower thresholds)

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

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TRI Chemicals & Chemical Categories

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 17

TRI Chemicals with Qualifiers - Examples

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

TRI Chemical Categories

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 19

PBT Chemicals: Persistent, Bioaccumulative, Toxic

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 20

PBT Chemicals & Activity Thresholds

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 21

Manufacturing Activity – 25,000 pounds

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 22

Processing Activity – 25,000 pounds

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 23

Otherwise Use – 10,000 pounds

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 24

Thresholds for Compound Categories

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 25

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

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 26

Exemptions from TRI Reporting

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 27

De Minimis Exemption Article Exemption

; OR

  • 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.

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

Article Exemption Examples

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 29

Laboratory Exemption

Exempt Not Exempt

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 30

Motor Vehicle Maintenance Exemption

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

Additional Threshold Guidance

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

Combustion

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 33

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.

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 34

Record Keeping & Documentation

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 35

Form R

  • Stack, Point, Fugitive
  • Water bodies (incl. storm water)
  • UIC wells, Landfills, Surface impoundments, other
  • POTW
  • Optional
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https://cdx.epa.gov https://www.epa.gov/tri-meweb 36

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

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 37

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

TRI-MEweb Reporting

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 39

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EP EPA A Pr Prog

  • gram

am Of Offi fice ces

Who uses TRI Data and for What Purposes?

  • Identify how many TRI facilities operate in the community and

where they are located.

  • Identify which chemicals are being released by TRI facilities.
  • Track increases or reductions of toxic chemical releases from

facilities located in the community over time.

  • Compare the toxic chemical releases and pollution

prevention efforts of facilities in one location with similar facilities across the country.

  • Prioritize efforts to reduce pollution from facilities located in

the area.

Communities, NGOs, Citizens

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

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EP EPA A Pr Prog

  • gram

am Of Offi fice ces

  • Studies on health impacts, sector analyses, technology,

environmental pollution, industry trends More on TRI uses at https://www.epa.gov/toxics-release-inventory-tri-program/tri-data-uses

Researchers, Universities Press, Elected Officials, Lobbyists

  • Publicity, Public Information
  • Promote agendas

Business/Industry

  • Competitive edge, Industry trends, Public Relations

Regulators

  • Trends in releases and pollution prevention
  • Comparison tool for compliance

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

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How to access TRI data: epa.gov/tri

42 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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How to access TRI data - myRTK

  • 1. Go to:

www.epa.gov/tri/myrtk

  • 2. Enter your location
  • 3. Click “Find Facilities”
  • Easy to use application

available in English and Spanish

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

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Summary TRI Facility Report - myRTK

Click on the bubble and facility name to see a summary facility report 44 https://cdx.epa.gov https://www.epa.gov/tri-meweb

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TRI Fact Sheets

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

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 46

TRI Resources & Tools

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  • TRI Homepage: www.epa.gov/tri
  • All Data Tools: https://www.epa.gov/toxics-release-

inventory-tri-program/tri-data-and-tools

  • myRTK: www.epa.gov/tri/myrtk
  • TRI.NET: https://www.epa.gov/toxics-release-

inventory-tri-program/trinet

Additional TRI Data Tools

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

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https://cdx.epa.gov https://www.epa.gov/tri-meweb 48

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For more information about TRI:

  • Angela Baranco: EPA Region 9 TRI Coordinator

baranco.angela@epa.gov (415) 947-4262

  • Call EPA’s TRI Information Center: 1-800-424-9346. Select

menu option #3 for TRI

  • Visit the TRI Program’s website: www.epa.gov/tri
  • Contact the TRI Help Desk by email: tri.help@epa.gov

49 https://cdx.epa.gov https://www.epa.gov/tri-meweb