TRI Reporting for 2014 – What’s New?

(labeled chemical waste drum)

The July 1 deadline for Toxic Release Inventory (TRI) reporting again looms! What’s new for your Form R (or Form A) reports?

You can find information on the TRI reporting changes on the EPA website. Notably, you should be aware of the following revisions and updates:

New TRI chemicals: The chemical o-nitrotoluene has been added to the list of chemicals subject to TRI reporting requirements and should be reported for 2014.

New TRI-MEweb features: TRI-MEweb is EPA’s required on-line reporting application. You can now use TRI-MEweb to update facility location and contact information without having to submit a TRI reporting form, or to indicate that you will not be submitting a form for one or more previously reported chemicals or even will not be reporting at all for the current year.

For 2014, the following data entry requirements and options apply:

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How to Comply with Toxics Release Inventory Reporting Requirements

EPCRA_training-20140508-web-cover

Are you ready for the July 1 deadline for Toxics Release Inventory (TRI) reporting of your releases, disposals and off-site transfers of listed toxic chemicals? Look HERE for guidance on TRI Form R (and Form A) reporting.

We have put together an informational presentation – as shown in the above screen capture of the title page – to help you and responsible personnel in your organization understand the reporting requirements set forth in the Emergency Planning and Community Right-to-Know Act (EPCRA), which include the annual TRI reports. This presentation is described in greater detail and accessible HERE. Both free PDF download and fully editable Powerpoint presentation (PPT) formats are available.

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As Time Goes By… the Hazardous Waste Biennial Report Comes Due!

image: waste containers

Um, yeah, this may not be the best example of drum storage…

Once again, the March 1 deadline looms for large quantity generators of hazardous waste as well as facilities that treated, stored or disposed of hazardous waste on-site to submit their hazardous waste biennial reports to the US Environmental Protection Agency.

If in any month in 2013 your facility

  • generated more than 1,000 kilograms (2,200 pounds, or about four to five 55-gallon barrels) of RCRA hazardous waste,
  • generated or accumulated more than 1 kg of acute hazardous waste, or
  • generated or accumulated more than 100 kg of spill cleanup material contaminated with acute hazardous waste,

then you are a RCRA Large Quantity Generator (LQG) and must complete and file the 2013 Hazardous Waste Report. Hazardous wastes imported to your facility from a foreign country should be included in your generator count.

And if in 2013 your facility treated, stored or disposed of hazardous wastes on-site as a permitted hazardous waste facility, you must complete and file the 2013 report.

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Tier Two. Almost due. So, what’s new?

Changes to Tier Two Hazardous Chemical Inventory reporting requirements are now effective!

On July 13, 2012, EPA published a final rule to revise Tier I and Tier II reporting forms, as well as the Confidential Location Information Sheet. The revisions added some new data elements and revised some existing data elements.

The rule became effective on January 1, 2014. Facilities must comply with the new requirements on the Tier II inventory form for reporting year 2013, which is due by March 1, 2014. (Note that your state may have specific requirements for reporting and submission the Tier II inventory form and/or the state reporting form or format. Contact T. Cozzie Consulting or your state for information on state specific reporting requirements.)

The reporting requirements under the community right-to-know provisions of EPCRA sections 311 and 312 are on-going obligations. These requirements apply to owners and operators of facilities that store hazardous chemicals in quantities at or above reporting thresholds specified in 40 CFR part 370. Under EPCRA section 312, if a hazardous chemical is present at or above the reporting threshold , the facility owner or operator is required to submit an emergency and hazardous chemical inventory form (Tier II or state equivalent, as no states currently accept the shorter Tier 1 form) to the SERC, LEPC and the local fire department by March 1 annually.

Changes to the reporting requirements that take effect for the 2013 reporting year include the following:

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