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K Blake Kidd May 6, 2014

Toxics Release Inventory (TRI) Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) Section 313 2014 Environmental Trade Fair and Conference. Air Quality Division. K Blake Kidd May 6, 2014. TRI Topics. Background TRI submissions Source reduction

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K Blake Kidd May 6, 2014

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  1. Toxics Release Inventory (TRI) Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) Section 313 2014 Environmental Trade Fair and Conference Air Quality Division K Blake Kidd May 6, 2014

  2. TRI Topics • Background • TRI submissions • Source reduction • Information resources

  3. Background

  4. What is TRI? • Established under EPCRA • Publicly accessible United States Environmental Protection Agency (EPA) database contains information on disposal and other releases of over 680 toxic chemicals from more than 20,000 U.S. industrial facilities

  5. What is TRI? cont. • Goals of TRI • Provides communities with information regarding toxic chemical releases and waste management activities • Supports informed decisions by industry, government, nongovernmental organizations, and the public • Multimedia reporting: • Air • Water • Underground injection • Land

  6. TRI Regulations • Superfund Amendment and Reauthorization Act Title III, Section 313 • EPCRA • Title 40 Code of Federal Regulations, Part 372 • Texas Health and Safety Code, Chapter 370

  7. TRI Chemicals • Approximately 680 chemicals and chemical categories are currently on the TRI list. • Persistent bioaccumulative toxins (PBT) chemicals have lower thresholds and different reporting requirements. • Twenty chemicals and chemical categories are subject to PBT and lead rules, including dioxin and dioxin-like compounds. • The EPA maintains the list.

  8. Trigger Amounts for TRI Reporting Facilities must report if site-level usage totals at least: • For each non-PBT chemical: • 25,000 pounds, manufactured; or • 25,000 pounds, processed; or • 10,000 pounds, otherwise used. • For PBT chemicals: • 10 or 100 pounds, depending on the chemical; or • 0.1 grams of dioxin or dioxin-like compounds.

  9. TRI Industry Sectors Common Sectors Reporting Releases in Texas • Chemicals • Electric utilities • Petroleum • Hazardous waste/Solvent recovery • Primary metals • Paper • Food/Beverage/Tobacco • Fabricated metals • Plastics and rubber • Stone/Clay/Glass

  10. Reporting

  11. Reporting Criteria Facilities must meet all three criteria • 10 or more full-time employees or 20,000 man hours as defined by the EPA • Industry sector must be covered by the North American Industry Classification System code list found in Table I of the January 2014 EPA publication 260-R-14-001, Toxic Chemical Release Inventory Reporting Forms and Instructions • Manufacture, process, or otherwise use more than the triggering amount for that classification of a TRI chemical

  12. Reporting Criteria, cont. Additionally, persistent, bioaccumulative, toxic chemicals (PBTs) have lower reporting thresholds: • >100 lbs. of aldrin, lead, lead compounds, methoxychlor, polycyclic aromatic compounds (PACs), pendimethalin, tetrabromobisphenol A, trifluralin • >10 lbs. of benzo(g,h,i)perylene, chlordane, heptachlor, hexachlorobenzene, isodrin, mercury, mercury compounds, octachlorostyrene, pentachlorobenzene, polychlorinated biphenyls (PCBs), toxaphene • >0.1 grams of dioxin and dioxin-like compounds

  13. Reporting Process • Submit TRI reports to EPA using TRI-MEweb by July 1st following the reporting year. • Each chemical must be reported using either Form A or Form R. • Facilities determine which reporting form to use by following the EPA guidance document, Toxic Chemical Release Inventory Reporting Forms and Instructions available at: www2.epa.gov/sites/production/files/2014-02/documents/rfi_RY2013_120413.pdf . • When using TRI-MEweb, the submission is automatically submitted to the TCEQ.

  14. Source Reduction

  15. Pollution Prevention and Source Reduction • The Pollution Prevention Act states “that pollution should be prevented or reduced at the source whenever feasible…” • The TRI program has increased the prominence of pollution prevention information to address this policy • Source reduction is defined as: • any practice that reduces the amount of pollutant prior to waste management activities; and • reduces the hazards to public health and the environment associated with the release.

  16. Reporting Source Reduction Activities and Methods Section 8.10 • Were any Source Reduction Activities newly implemented for the reporting year? • Choose all relevant source reduction activity code(s). W-codes • Choose all relevant source reduction method code(s). T-codes

  17. Reporting Source Reduction Activities W-codes • Good operating procedures • Inventory control • Spill and leak prevention • Raw material modifications • Process modifications • Cleaning and degreasing • Surface preparation and finishing • Product modifications

  18. Source Reduction Activity Examples • Good operating practices Improved maintenance schedule • Inventory control Institute better labeling procedures • Spill and leak prevention Installed vapor recovery system • Raw material modifications Increased purity • Process modifications • Instituted re-circulation within a • process • Cleaning and degreasing • Improved rinse equipment • Surface preparation and finishing • Improved application techniques • Product modifications • Modified packaging

  19. Source Reduction Activity Methods T-codes Internal or external methods or information sources used to identify the possibility for implementing a source reduction activity. • Internal P2 audit • External P2 audit • Materials balance audit • Participative team management • Employee recommendation • State government technical • assistance program • Federal government technical • assistance program • Trade association assistance • program • Vendor assistance

  20. Resources

  21. EPA Online Training Toxic Chemical Release Inventory Reporting Forms and Instructions http://www2.epa.gov/sites/production/files/2014-02/documents/rfi_ry2013_120413.pdf TRI Basic Training http://www2.epa.gov/toxics-release-inventory-tri-program/training-tri-reporting-ry-2013#basic TRI Advanced Training http://www2.epa.gov/toxics-release-inventory-tri-program/training-tri-reporting-ry-2013#advanced

  22. TRI Training Workshops and Webinars Live Workshops Houston: April 8, 2014 Dallas: April 30, 2014 Houston: May 2, 2014 Training Webinar Basic Concepts: May 28, 2014, 10am – 1 pm CDT Advanced Concepts: May 30, 2014, 10am- 1 pm CDT More information available at http://region6.tri-training.com/

  23. TRI Information Sources EPA TRI home page http://www2.epa.gov/toxics-release-inventory-tri-program EPA TRI Explorer http://www.epa.gov/triexplorer/ EPA Envirofacts http://www.epa.gov/enviro/

  24. Contact Information EPA Region 6 Enforcement Coordinator Morton Wakeland, Jr. (214) 665 - 8116 TRI Information Center (operated by the EPA) (800) 424 - 9346 Central Data Exchange hotline (888) 890 - 1995 TCEQ TRI Hotline Blake Kidd (512) 239 - 4TRI {4874}

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