TRI Training Module Agendas Basic Concepts Module 1. Introduction - PowerPoint PPT Presentation

T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S TRI Training Module Agendas Basic Concepts Module 1. Introduction 2. Covered Sectors R Reporting Year 2013 R Reporting Year 2013 ti ti Y Y 2013 2013 Thresholds (PBT and Non-PBT) 3. 4. Reporting Exemptions 5. Threshold Determinations 6. Overview of Form R Alternate Threshold Rule (Form A) 7. Emergency Planning + Community RIGHT-TO-KNOW Act (EPCRA) Section 313 Emergency Planning + Community RIGHT-TO-KNOW Act (EPCRA) Section 313 Advanced Concepts Module 1. Recent TRI Program Changes T T Toxics Release Inventory Toxics Release Inventory i i R l R l I I t t Advanced Reporting Guidance Ad d R i G id 2. Detailed PBT Guidance 3. Reporting Requirements Reporting Requirements 4. Tools and Assistance Basic Concepts Basic Concepts 5. TRI-MEweb Updates Do I Need to Report to TRI and Do I Need to Report to TRI and How Do I Report How Do I Report 2/4/2014 1 2/4/2014 2 T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S 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 600 chemicals and chemical categories • Facilities exceeding an activity threshold must report if they are:  In a “covered sector” (defined by NAICS codes); and Introduction Introduction  Have 10 or more employees • Submit TRI reports to U.S. EPA, and either  designated state officials, or  designated tribal office designated tribal office …….by July 1st following the calendar year’s activities (aka Reporting Year (RY)) [e.g. July 1, 2014 deadline for RY 2013 (January 1 - December 31, 2013) activities] 2/4/2014 4

T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S TRI Process – 2 Part Process TRI Reporting Process Applicability & Release/Waste Mgmt. Reporting Threshold Determinations Covered Primary Covered Primary NO Identify total Use TRI-MEweb to NAICS Code(s) or releases and Complete Federal facility? off-site transfers Form R or Form A Determine quantities of Identify Section STOP Section 313 NO 313 chemicals Ten Employees? chemicals and manufactured, YES (20,000 hours/year) whether they are processed, or manufactured, otherwise used at processed, or the site otherwise used MPOU* NO Identify other waste on-site for the Section 313 management reporting year YES practices Chemicals? MPOU* NO Complete Thresholds YES Final QA/QC Exceeded? ceeded Identify pollution prevention YES activities Submit to EPA & State If a Threshold is Reporting Thresholds Exceeded… Met; Form R/Form A Required *MPOU: Manufacture (including import), process, or otherwise use 2/4/2014 5 2/4/2014 6 T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S Industrial Sectors Covered Industrial Sector Notes Facilities engaged in the mechanical or chemical transformation of Manufacturing materials or substances into new products Not including metal mining services, and uranium, radium, and Metal mining vanadium ores Coal mining Not including coal mining services Section I: Section I: Limited to facilities that combust coal and/or oil for the purpose of Electrical utilities generating electricity for distribution in commerce Covered Sectors Covered Sectors Treatment, Storage, and Limited to facilities regulated under the Resource Conservation Disposal facilities and Recovery Act, Subtitle C, 42 U.S.C. Section 6921 et seq. Limited to facilities primarily engaged in solvent recovery services Solvent recovery services on a contract or fee basis Facilities engaged in the wholesale distribution of chemicals and Chemical distributors allied products Petroleum bulk terminals Facilities engaged in the wholesale distribution of crude petroleum and petroleum products from bulk liquid storage facilities 8

T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S Covered NAICS Codes Federal Facilities • 2012 North American Industry Classification System (NAICS) codes are used for • Federal facilities (covered by Executive Order TRI reporting. 13423 and its implementing instructions) • To determine whether your facility’s primary NAICS code is covered by TRI  Regardless of their NAICS code g regulations, see: l i • Includes federal prisons, national parks, www2.epa.gov/tri/my-facilitys-six-digit-naics-code-tri-covered-industry federal hospitals • TRI-Covered* Industries NAICS  With 10 or more full-time employees  212 Mining (equivalent of 20,000 hours per year)  221 Utilities  That exceed manufacture, process,  31 - 33 Manufacturing or otherwise use thresholds of a listed  All Other Miscellaneous Manufacturing (includes 1119, 1131, 2111, 4883, 5417, chemical 8114)  Government unit responsible for reporting on  424 Merchant Wholesalers, Non-durable Goods activities conducted at Federal facilities activities conducted at Federal facilities  425 Wholesale Electronic Markets and Agents Brokers  Does not change existing requirements of  511, 512, 519 Publishing private contractors of government owned  562 Hazardous Waste contractor operated (GOCO) facility to report.  Federal Facilities * Note: For many of these NAICS codes, there are reporting exceptions. 2/4/2014 9 2/4/2014 10 T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S T R I R E P O R T I N G R E Q U I R E M E N T S Definition of “Facility” Example of a Multi-Establishment Facility • TRI reporting requirements are determined by activities at • Three separate establishments located on contiguous/ adjacent “facilities” property owned by same person(s), is one facility under EPCRA (40 CFR §§ 372.22(b) and 372.3)  Primary NAICS code determination at facility level y y  Establishment - unique and separate economic unit of a facility (See 40 CFR §  Employee threshold determination at facility level 372.3)  Chemical threshold determinations made at facility level Generic Products Food Processing • “Facility - all buildings, equipment, structures, and other (NAICS 311421) 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).” y, , p ) Generic Products Farm G i P d t F (EPCRA § 329 (4)) (NAICS 111219) Gen. Prod. Warehouse (NAICS 49312) 2/4/2014 11 2/4/2014 12