Determining Threshold Exceedances

A material must be included on the EPA form R when the reporting threshold has been exceeded in any one of three activity types: manufacture, process, or otherwise-use. The Electronic TRI Reporting tool can calculate threshold exceedances for TRI reporting.

For instruction on how to determine threshold exceedances, click the following links or use the scroll bar to scan the page.

Overview of Threshold Determinations

Section 313 of the EPCRA (Title III of the SARA) requires facilities that meet or exceed certain thresholds complete and submit an EPA form R, the Toxic Chemical Release Inventory (TRI) Reporting form. Use the Electronic TRI Reporting tool to determine whether your processing, manufacturing, or otherwise-use activities have resulted in quantities of toxic materials that exceed these thresholds. The threshold value for manufacturing and processing activities is 25,000 pounds; the threshold value for toxic materials that you otherwise use is 10,000 pounds.

Chemical data from the Essential Air, Water, Waste, Chemical Inventory, and FEMS modules can be included when determining thresholds. Depending on which modules are used to manage and report toxic chemicals, waste values may be tracked using any or all of:

• Estimated values based on models for calculated emissions

• Waste tracking values

• Inventory transactions and estimated values

• Wastewater monitoring and loading values

• Fugitive emissions (FEMS) values

• Incident and one time non-production release values

When establishing an electronic TRI reporting configuration, identify which types of values to include in each threshold calculation. For estimated values based on models for calculated emissions, the emission models to include for each threshold determination can be selected. The Electronic TRI Reporting tool produces a threshold report to review prior to generating the electronic files. The Reporting Threshold Determination report includes totals for each chemical you must report for each processing, manufacturing, or otherwise-use activity, as well as a threshold quantity value.

Depending on the number of materials, amount of data, and the threshold options selected, the Electronic TRI Reporting tool may require several hours of processing time to calculate threshold information for all the toxic chemicals that must be reported.

SARA Activity Determination

The Electronic TRI Reporting tool can be used to determine whether your processing, manufacturing, or otherwise-use activities have resulted in quantities of toxic materials that exceed regulatory thresholds. The threshold value for manufacturing and processing activities is 25,000 pounds; the threshold value for toxic materials that you otherwise use is 10,000 pounds. In the Chemical Inventory module, SARA activities can be assigned to inventory transactions, inventory estimates, and/or to components of mixture materials. Activities assigned by inventory transaction/estimate apply to the material inventoried, including all components when the material is a mixture. An activity assigned specifically to a component of a mixture applies only to the component within that mixture. Each component of a mixture may be associated with the same activity as the other components of the mixture or be assigned a different activity. The advantage of using component-level activity assignments is that the components of a mixture may be assigned different activities. For example, one component may be used as a reactant and another as a manufacturing aid within the same mixture.  

For inventory transactions and estimates, activities are assigned on the Inventory Transactions form and Inventory Estimates form, respectively. A SARA activity is assigned to a component on the Material Component form which is accessed via the Material Composition and Properties section on the Material form. Since a component of a mixture can be a pure material or another mixture (composed of pure materials), both component pure materials and component mixtures can be assigned an activity. Consequently, when the Electronic TRI Reporting tool performs threshold calculations that involve inventory transactions/estimates, the following hierarchical order is used to determine the SARA activity associated with the results:

1. Component-level assigned SARA activity.

2. Mixture-level assigned SARA activity. (Up to three levels of materials may be identified for a mixture, where level one is the mixture being defined, level two is a pure material or a mixture, and level three consists of the pure materials that are a part of a mixture on level two. Refer to Speciating Material Releases for additional information on mixture levels.)

3. Inventory-level (Transaction/Estimate) assigned SARA activity.

Caution:  The hierarchical order applies to inventory estimates and Material Use transactions only. The SARA activities associated with Addition inventory transactions are always used for SARA activity determination, regardless of component- or mixture-level assignments.

If a pure component of the mixture material inventoried has been assigned a SARA activity, the threshold calculation using the mass of the component in the material is performed and associated with the SARA activity assigned to the component, regardless of whether or not a SARA activity was assigned to the inventory estimate or Material Use inventory transaction for the mixture material.

If a pure component of a mixture has not been assigned a SARA activity, the SARA activity for threshold calculations is determined as follows:

• When the pure component is a direct component (mixture level two) of the material inventoried, threshold calculations are performed using the mass of the component in the material and the results are associated with the SARA activity assigned to the inventory estimate or Material Use inventory transaction.

• When the pure component is a component of a mixture (mixture level three) which is a component of the material inventoried (mixture level two), threshold calculations are performed using both the mass of the mixture and the component, and associated with the SARA activity assigned to the component mixture (mixture level two). If no activity has been assigned to the component mixture, threshold calculation results are associated with the SARA activity assigned to the inventory estimate or Material Use inventory transaction.

Both the SARA activity and mass (concentration %) must be specified for threshold calculations to occur. The threshold calculation cannot be performed for a component if both attributes are not provided. For materials containing components that are mixtures, the mass must be defined at the pure component level (mixture level three) and the mixture component level (mixture level two). Otherwise, the calculation will not be performed for that component.

For additional information, review SARA Activity Identification Examples. A variety of scenarios that show how the Electronic TRI Reporting tool identifies SARA activities for reporting purposes are provided.

Special Considerations

• Component-level SARA activity threshold determination applies to all inventory estimates and Material Use inventory transactions only. The SARA activities associated with Addition inventory transactions are always used for SARA activity determination, regardless of component- or mixture-level assignments.

• If component-level SARA activity threshold determination is not appropriate for your facility, be sure an activity is not assigned to any component of a mixture material. Assign all activities on the Inventory Transaction form and/or Inventory Estimates form.

• To accurately report on material uses, it may be necessary to establish mixtures based on how their components are used (i.e., different SARA activities).

SARA Activity Identification Examples

Four examples that show how the Electronic TRI Reporting tool identifies SARA activities for reporting purposes are provided below. Each scenario involves different activity assignments; threshold determination results follow each example.

• Example 1 (No Inventory Transaction/Estimate activity assigned.)

• Example 2 (All components/transactions/estimates have been assigned an activity.)

• Example 3 (No activity assigned to Component 2.)

• Example 4 (Components of mixtures that are components of the material inventoried.)

Note:  All of the components in the examples are included in the EPCRA Section 313 Toxic Chemicals regulatory list.

Example 1

Mixture: Test Solvent A     Material Effective Date:  01/01/2004

Example 1 Threshold Results

The activity assigned to each component is used for reporting.

Example 2

Mixture: Test Solvent B     Material Effective Date:  01/01/2004

Example 2 Threshold Results

The activity assigned to each component supercedes the activity that has been associated with the inventory transaction/estimate.

Example 3

Mixture: Test Solvent C     Material Effective Date:  01/01/2004

Example 3 Threshold Results

No activity has been assigned to Component 2, so the activity associated with the inventory transaction/estimate was used for Carbaryl.

Example 4

Mixture: Test Solvent XYZ     Material Effective Date:  01/01/2004

Example 4 Threshold Results

No activity has been assigned to Component 2 of Mixture Component 1, so the activity assigned to Solvent 100 (Mixture Component 1) was used for formaldehyde (Component 2) in Solvent 100.

Identifying Threshold Values

The data identified for the electronic TRI reporting submission becomes the basis for the data the Electronic TRI Reporting tool uses to calculate threshold values. In other words, if you do not plan to include certain data in the electronic TRI report, the Electronic TRI Reporting tool will not consider that data when it calculates thresholds to determine which chemicals must be reported.

For Section 5 of the form R, toxic chemicals that your facility discharged or released to an environmental medium and disposed of on-site must be reported. For Section 6, toxic chemicals transferred to off-site locations must be documented. When establishing your report configuration, select data from the Essential Air, Water, Waste, Chemical Inventory, and FEMS modules, as well as incident data. (The incident reporting functionality can be accessed from any of these modules, except FEMS.) For both form R sections, data can be selected for each line from one or more modules. Indicate if the Electronic TRI Reporting tool should include the data when calculating activity thresholds (i.e., manufacturing thresholds, processing thresholds, or otherwise-use thresholds.)

Estimated values can be modeled using the Essential Air module for any of the values in form R, Section 5 or Section 6. For example, emission models to estimate wastewater discharges can be set up. Or, values can be documented using another method such as establishing loading calculations and entering sampling data. Then, all the appropriate data sources could be selected: estimated values, waste tracking values, wastewater monitoring values, or incident values for each of the line items in Section 5 or Section 6.

The TRI Configuration form is used to identify data for determining thresholds. Select the data sources you plan to use for reporting on-site releases, on-site disposals, and off-site transfers to environmental media. The selections are used to calculate values for the corresponding section of the form R. Only sources of data that apply to each on-site release type, on-site disposal type, and off-site transfer type are available for selection. Details about each data source selection are provided below, along with special conditions that should be considered when setting up your configuration for threshold determination and TRI reporting.

• Estimated Values

• Waste Tracking Values

• Wastewater Monitoring Values

• Inventory Values

• Incident Values

• FEMS Values

For information about establishing a TRI configuration, refer to Configuring Electronic TRI Reporting Submissions.

Estimated Values

Using the Essential Air module, emission models can be established and estimated emission values calculated. When selecting the Estimated Values option for any of the Section 5 or Section 6 line items, the specific models to be included in threshold determination and electronic TRI reporting calculations must be identified. Assign emission models for any or all of the threshold calculations in the Manufacturing Thresholds section, the Processing Thresholds section, and the Otherwise Use Thresholds section on the TRI Configuration form. Assign emission models for electronic TRI reporting calculations in the Estimated Values section.

Note:  If models have been set up to test or evaluate what if scenarios, be sure to exclude them from the threshold and report calculations, since they do not reflect an actual operating scenario. Likewise, if emission models have been established to model various threshold activities, select only the models that apply for each activity.

Waste Tracking Values

Use the Waste module to track the transfer, disposal, and discharge of waste materials. Manage waste in containers or in bulk quantities, track waste materials throughout your enterprise, and maintain details about the transportation of waste materials off-site.

Wastewater Monitoring Values

Use the Essential Water module to calculate wastewater values at your outfalls. To include wastewater values in the electronic TRI report and in your threshold calculations, set up a DMR in the Water module. The DMR should include loading calculations for all reporting chemicals. When selecting wastewater data for the form R, specify the DMR (federal or state) that includes the applicable loading data, along with a loading calculation method for your DMR data.

Inventory Values

When using the Essential Chemical Inventory module to track quantities of material at your facility, data selection for the items in Section 5 or Section 6 is not required. Material use can be identified with a SARA activity directly in the Chemical Inventory module; each SARA selection option for determining threshold values activity is associated directly with one of the three threshold types. Therefore, material use that flows into the Electronic TRI Reporting tool from the Chemical Inventory module is already associated with a threshold activity. However, one of the following determination methods for including data in the reporting threshold and maximum quantity on-site calculations must be specified:

1. Use Inventory Transactions Only

2. Use Inventory Estimates Only

3. Determine by Storage Area - For each individual storage area, the inventory calculation basis, transaction data or inventory estimates, is used to determine whether method a or b (above) applies.

Select the Determination Method in the Calculations section on the TRI Configuration form and select the Inventory Values option for any or all of the threshold calculations in the Manufacturing Thresholds, Processing Thresholds, and Otherwise Use Thresholds sections.

Note:  Refer to SARA Activity Determination for additional information about identifying material use in the Chemical Inventory module.

Incident Values

Incidents or one-time non-production-related releases of toxic chemicals can be documented in the Essential Air, Water, Waste, or Chemical Inventory modules. Include incident data by selecting the Incident Values option for any or all of the threshold calculations in the Manufacturing Thresholds, Processing Thresholds, and Otherwise Use Thresholds sections on the TRI Configuration form.

FEMS Values

Use the Essential FEMS module to calculate fugitive emission values at your entity. Include Fugitive Emission values in threshold calculations and electronic TRI reporting by setting up a calculation method in the FEMS module. Specify the calculation method in the Calculation section on the TRI Configuration form when selecting the FEMS Values option for any or all of the threshold or TRI report calculations.

Special Considerations

Account for the following special considerations when setting up the configuration for threshold determination and TRI reporting:

• Double-counting chemical quantities - For Wastewater, Waste, and Incident values, selecting the check boxes for more than one threshold activity will force the Electronic TRI Reporting tool to include the same values in the calculation of multiple thresholds. To avoid double-counting chemical quantities, select only the threshold activity where the value actually applies.

• Allocating quantities among thresholds - When the Wastewater, Waste, or Incident values must be split among more than one threshold activity, estimate chemical emissions by creating emission models in the Air module. Then, identify specific models for each threshold activity.

• Otherwise-Use Threshold - Materials received from off-site for further waste management including disposal, stabilization, or treatment for destruction must be included in the Otherwise-Use threshold activity. The Waste module cannot be used to account for detailed on-site waste management activities of materials received from off-site. It is recommended that a model be set up in the Air module for estimating waste material instead.

Generating the Reporting Threshold Determination Report

The Reporting Threshold Determination report is generated via the TRI Report form and details the threshold determinations for all of the materials stored at your facility that are:

• in the regulatory list specified in your electronic TRI reporting submission and

• stored, generated, and tracked using the Essential Air, Water, Waste, and Chemical Inventory modules.

For a particular date range, the Electronic TRI Reporting tool determines from your estimates or storage area inventory transactions, estimated releases, wastewater monitoring, waste tracking, and incident data, the quantities of each material that were used in each of the three threshold activity types. Include any or all of these data sources for your manufacturing, processing, and otherwise-use activities. (Remember that the inventory of a storage area can be calculated using either transactions or estimates, not both.)

If the chemical or chemical category exceeded the threshold in any of the threshold activities, the report identifies the material. Use the threshold determination results to determine if an EPA form R is required for your facility.

Note:  When evaluating thresholds for chemical categories that identify metal compounds, the entire mass of the chemical compound is used. When reporting releases for chemical categories that identify metal compounds, only the mass of the metal in the chemical compound is used.

When the Reporting Threshold Determination report is generated, the Electronic TRI Reporting tool creates a Threshold Exceedance list that contains the chemicals or chemical categories exceeding the threshold. You can select the list and assign the chemicals or chemical categories to be included in the form R on the TRI Report form.

Before the Reporting Threshold Determination report can be generated, an electronic TRI reporting submission must be established and a valid bank of the required data must exist in your Essential database. When the report needs to be revised or recalculated, make adjustments on the TRI Configuration form and re-evaluate your thresholds. When revisions are made for your threshold determination results, the data that comprises your electronic TRI reporting submission is changed.

To generate a Reporting Threshold Determination report

Tip:  The procedure below assumes your electronic TRI reporting submission has been set up. Refer to Establishing an Electronic TRI Reporting Submission when necessary.

1. Click Reports > Electronic TRI Reporting > Electronic TRI Reporting in the Navigation Tree.
   
   The Electronic TRI Report list appears.

2. Locate the appropriate electronic TRI reporting submission and click the link to display the TRI Report form.

3. Expand the Chemicals/Categories in Submission section if necessary and click Evaluate Reporting Threshold.
   
   The Threshold Determination Progress window and progress bar are displayed indicating the progress made in compiling and evaluating data. Depending on the number of materials, amount of data, and the threshold options you selected, the Electronic TRI Reporting tool may require several hours of processing time to calculate threshold information for all the toxic chemicals you must report.

4. Review the reporting threshold message displayed next to the Add Chemicals/Categories link in the Chemical/Categories in Submission section. When the Reporting Thresholds last evaluated on [date] message is displayed, the report is available for review.
   
   For more information on report statuses, refer to Reviewing Threshold Determination Report Statuses.

5. Click View Threshold Report to review threshold determination results.
   
   For additional information, refer to Evaluating Threshold Determination Report Statuses.

Reviewing Threshold Determination Report Statuses

Check the status of your Reporting Threshold Determination report in the Chemicals/Categories in Submission section on the TRI Report form. One of the following messages is displayed next to the Add Chemicals/Categories link in the section:

• Reporting Thresholds not yet evaluated - The Electronic TRI Reporting tool has not evaluated thresholds for the selected electronic TRI reporting submission, i.e., the Reporting Threshold Determination report has not been generated.

• Reporting Thresholds last evaluated on [date] - The Reporting Threshold Determination report was most recently generated on the date specified. When the report is regenerated, the new report data will overwrite any existing threshold data. In addition, chemicals and chemical categories assigned to the electronic TRI reporting submission will be overwritten with the new threshold determination results.

Evaluating Threshold Determination Report Results

Note:  You must generate a Reporting Threshold Determination report before viewing and evaluating the results.

In the Chemicals/Categories in Submission section on the TRI Report form, view threshold determination results by clicking View Threshold Report. The Essential Reporter is displayed showing the report contents. An option is available to print a paper copy. If the chemical or chemical category exceeded the threshold in any of the threshold activities, the report identifies the material. Review the results to determine if an EPA form R is required for your facility.

Note:  When evaluating thresholds for chemical categories that identify metal compounds, the entire mass of the chemical compound is used. When reporting releases for chemical categories that identify metal compounds, only the mass of the metal in the chemical compound is used.

When the Reporting Threshold Determination report is generated, the Electronic TRI Reporting tool also creates a Threshold Exceedance list that contains the chemicals or chemical categories on the report. Select the list and assign the chemicals or chemical categories to be included in the form R via the TRI Report form. Refer to Identifying Submission Chemicals and Chemical Categories.

To revise or recalculate the report, make adjustments on the TRI Configuration form and re-evaluate your thresholds. When revisions are made for threshold determination results, the data that comprises your electronic TRI reporting submission is changed.

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