Toxic Release Inventory Reporting

Toxic Release Inventory Reporting

Reporting of the Toxic Chemical Release Inventory (Toxics Release Inventory [TRI]) is required by Section 313 of the Emergency Planning and Community Right-to-Know Act ([EPCRA], or Title III of the Superfund Amendments and Reauthorization Act of 1986 [SARA]). The information contained in Form R or Form A constitutes a “report,” and the submission of a report to the appropriate authorities constitutes “reporting.”

EPCRA Section 313 requires that chemical releases and other waste management details be reported to the public. The United States Environmental Protection Agency (USEPA) also requires this information be provided to them to assist them in determining the need for future regulations. Quantities of routine and accidental releases and releases resulting from catastrophic or other one-time events, as well as the maximum amount of EPCRA Section 313 chemicals on site during the calendar year and the amount contained in wastes managed on-site or transferred off-site must be reported by the facilities.

A completed Form R or Form A must be submitted for each EPCRA Section 313 chemical manufactured, processed, or otherwise used at each applicable facility. An applicable facility is one that meets all of the following criteria:

	Facility has 10 or more full-time employee equivalents
	Facility is included in the SIC Codes 10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4939 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4953 (limited to facilities regulated under Resource Conservation and Recovery Act (RCRA) Subtitle C, 42 U.S.C. Section 6921 et sq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in solvent recovery services on a contract or fee basis)
	Facility manufactures, processes, or otherwise uses any EPCRA Section 313 chemical in quantities greater than the established threshold in the course of the calendar year

All TRI Reports should be generated with the use of the Toxics Release Inventory – Made Easy (TRI-ME) Software Version 2003.

The TRI-ME 2003 software can be downloaded from the EPA website at www.epa.gov/tri. Changes from the TRI-ME 2002 software include the following:

Part II, Section 5.5.3 Surface Impoundments has been divided into 5.5.3A – RCRA Subtitle C Surface Impoundments and 5.5.3B – Other Surface Impoundments

Part II, Section 8.1 has been divided into:

8.1a – Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfill and other landfills;

8.1b – Total other on-site disposal and other releases;

8.1c – Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle Landfills, and other landfills; and

8.1d – Total other off-site disposal or other releases

The M codes used in Column C of Section 6.2 of the Form R have been updated.

M63 (Surface Impoundment) was deleted and replaced by M codes M66 (RCRA Subtitle C Surface Impoundment) and M67 (Other Surface Impoundments); and

M71 (Underground Injection) was deleted and replaced by M codes M81 (Underground Injection to Class I Wells) and M82 (Underground Injection to Class II-V Wells).

The U codes used in Section 7B of the Form R have been updated.

Code U09 (Other Energy Recovery Methods) has been deleted

All changes to the software and other TRI information are available to download and print on the TRI webpage.

TRI submissions are due to the USEPA, and state agency on or before July 1, 2004. Submissions can be made by diskette, paper copy, or electronically over the internet via USEPA’s Central Data Exchange (CDX).

For further information: http://www.epa.gov/nonroad-diesel/2004fr.html

Author: Sharon S. Diday, ACCI Project Engineer

Date: 05/27/04

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