How to Successfully Submit a Toxic Release Inventory Report

Don’t wait until the last minute to turn in your Toxic Release Inventories (TRIs), also called 313s.  They must be submitted no later than July 1, 2014.  Under Section 313 of the Emergency Planning and Community Right-to-Know Act, the US EPA compiled a list of over 650 chemicals that, when processed, manufactured, or otherwise used above certain thresholds, must be reported.  Once you determine that your use of a particular substance triggers TRI reporting, you’ll look at all the ways it is “released,” such as air emissions, storm water discharge, discharge to wastewater treatment works, or recycled.  TRIs also offer an opportunity to highlight any pollution prevention or source reduction efforts by your facility.

Helpful Tips:

1. Check with your state environmental agency.  The federal system transmits to the state in many cases, but there may be additional reporting requirements or fees.

2. Once you have certified the report, you should receive a receipt.  The process in not complete until you receive a confirmation email from the US EPA.

3. The EPA recently sent out Facility Access Keys to use in conjunction with your TRI Facility ID.  This should arrive via e-mail to both preparers and certifiers from last year.

4. When determining your applicability, keep in mind that TRI, for any particular substance, is determined by the amount processed, manufactured, or otherwise used.  This differs from other programs, like Right-to-Know and SPCC, which are based on amount stored, or hazardous waste reporting for LQGs based on amount generated.

5. Some states require a full material balance for each reported substance, where all material “in” must equal the sum of all material “out”.  Even if your state does not require this, it can be a good way to spot opportunities for improvement in usage efficiency and source reduction.

6. Earlier is always better, since the computer system tends to bog down the closer you get to the deadline of July 1.

If you have questions or concerns about preparing your report, Stone Environmental, located in Westerville, Ohio, would love to help.  We have experience in preparing annual TRI reports, SPCC and SWP3 plans, hazardous waste contingency plans, and integrated contingency plans.  Our reputation is built on responsiveness to the needs of individual clients and clear communication with clients, review agencies, and regulators.  To learn more about the services we provide give us a call at 614-865-1874 or visit our website!

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