1. K Blake Kidd September 30, 2015 Toxics Release Inventory (TRI) Emergency Planning and Community Right-To- Know Act of 1986 (EPCRA) Section 313 2015 Pollution Prevention Workshop Air Quality Division

2. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 2 Topics Background TRI reporting Waste reduction Resources

3. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 3 Background

4. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 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. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 5 What is TRI? cont. Goals of TRI o Provide communities with information regarding toxic chemical releases and waste management activities o Support informed decisions by industry, government, nongovernmental organizations, and the public Multimedia reporting: o Air o Water o Underground Injection o Land

6. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 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. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 7 Who Reports? 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

8. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 8 What Gets Reported? Approximately 594 individual chemicals and 34 chemical categories that include four categories with 68 specifically listed chemicals are currently on the TRI list. Some chemical and chemical categories are classified as Persistent Bioaccumulative Toxic (PBT) chemicals and have different reporting requirements. Qualifiers are applied to some chemicals and chemical categories to account for physical forms, including dust, fumes, fibrous forms, friable materials, aerosols, and chemical allotropes, or manufacturer or manufacturing techniques, or geographical origins.

9. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 9 TRI Reporting

10. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 10 Reporting Criteria Facilities must meet all three criteria of 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 Industrial 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; and Manufacture, process, or otherwise use more than the threshold amount for that classification of a TRI chemical.

11. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 11 Threshold Reporting Amounts Facilities meet criteria requirements if site-level usage totals for each non-PBT chemical are at least: 25,000 pounds, manufactured (produce, prepare, compound, or import a TRI chemical); 25,000 pounds, processed (preparation of a TRI chemical for distribution in commerce); or 10,000 pounds, otherwise used.

12. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 12 Threshold Reporting Amounts, cont. For a facility to meet criteria requirements for PBT chemicals, manufacturing, processing, and otherwise use site-level totals must be at least: 100 lbs. for aldrin, lead, lead compounds, methoxychlor, polycyclic aromatic compounds, pendimethalin, tetrabromobisphenol A, and trifluralin; 10 lbs. for benzo(g,h,i)perylene, chlordane, heptachlor, hexachlorobenzene, isodrin, mercury, mercury compounds, octachlorostyrene, pentachlorobenzene, polychlorinated biphenyls, and toxaphene; or 0.1 grams for dioxin and dioxin-like compounds.

13. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 13 Reporting Process Submit TRI reports to EPA using TRI-Meweb by July 1 st following the reporting year. Each chemical must be reported using either Form A or Form R. Facilities determine the reporting form to use by following the EPA guidance document, Toxic Chemical Release Inventory Reporting Forms and Instructions available at: http://www2.epa.gov/sites/production/files/2015-01/documents/rfi_ry2014_111914.pdf. When using TRI-Meweb, the submission is automatically submitted to the Texas Commission on Environmental Quality (TCEQ).

14. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 14 Form A vs. Form R Reporting Form A reports only include facility information and the chemical name. Form R reports include facility information, chemical name, release amounts, transfer information, and other waste management activities for air, water, underground injection, and land media both on-site and off-site.

15. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 15 Form A Reporting Criteria Can use Form A if following criteria are met: Do not exceed 500 pounds for the total annual reportable amount* for that chemical, and Chemical amounts manufactured or processed or otherwise used do not exceed one million pounds. *The total annual reportable amount is equal to the combined total quantities released, treated, recovered, and combusted at the facility, plus the amounts transferred to off-site locations.

16. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 16 Form A Reporting Differences PBT chemicals are ineligible for Form A reporting. Using only Form A reports does not trigger the Waste Reduction Policy Act. Form A reports are not charged a TOX fee.

17. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 17 Waste Reduction

18. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 18 Pollution Prevention 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. Section 8.10 of the Form R report includes newly implemented source reduction activities, methods identifying the origins of the source reduction, and estimated annual reduction ranges.

19. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 19 Waste Reduction Hierarchy

20. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 20 Source Reduction 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.

21. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 21 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

22. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 22 Source Reduction in Texas for 2013 Number of Activities Reported by Activity Type 295 facilities reported 1156 newly implemented source reduction activities.

23. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 23 Recycling in Texas for 2013 Total waste recycled by all industry sectors – 501,660 tons. Tons of Waste Recycled by Industry Sector

24. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 24 Energy Recovery in Texas for 2013 Total waste burned for energy recovery by all industry sectors – 494,151 tons. Tons of Waste Burned for Energy Recovery by Industry Sector

25. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 25 Waste Treatment in Texas for 2013 Total waste treatment by all industry sectors – 972,860 tons. Tons of Waste Treated by Industry Sector

26. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 26 Resources

27. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 27 EPA Online Training Toxic Chemical Release Inventory Reporting Forms and Instructions http://www2.epa.gov/sites/production/files/2015- 01/documents/rfi_ry2014_111914.pdf TRI Basic Training Slides http://www2.epa.gov/sites/production/files/2015- 02/documents/ry14_basic_concepts.pdf TRI Advanced Training Slides http://www2.epa.gov/sites/production/files/2015- 02/documents/ry14_advanced_concepts.pdf

28. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 28 TRI Information Sources EPA TRI home page http://www.epa.gov/tri/index.htm EPA TRI Explorer http://www.epa.gov/triexplorer/ EPA Envirofacts http://www.epa.gov/enviro/

29. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 29 TRI Reporting Guidance TRI Threshold Screening Tool https://cdxnode64.epa.gov/cdx-tri-threshold/action/Home General, Industry-specific, and Chemical-specific Guidance Documents http://www2.epa.gov/toxics-release-inventory-tri- program/guidance-documents-tri-reporting

30. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 30 TRI Audit and Compliance Policies EPA Audit Policy Home Page http://www2.epa.gov/compliance/epas-audit-policy EPA Small Business Compliance Policy Home Page (100 or fewer employees) http://www2.epa.gov/compliance/small-business-compliance

31. Air Quality Division Toxics Release Inventory KBK September 30, 2015 Page 31 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 (888) 890 - 1995 TCEQ TRI Helpline (512) 239 - 4TRI {4874}