Understanding Electronic TRI Reporting

In 1986 Congress passed the Superfund Amendment and Reauthorization Act (SARA), which details funding for a number of issues, including environmental ones. A part of that act is the Emergency Planning and Community Right-to-Know Act (EPCRA), which requires that the EPA maintain (and make available to the public) information on uses and the releases of listed toxic chemicals.

Section 313 of the EPCRA (Title III of the SARA) requires facilities that meet or exceed certain guidelines complete and submit an EPA form R, the Toxic Chemical Release Inventory (TRI) Reporting form. Facilities must report the quantities of both routine and accidental releases, the maximum local inventory of toxic chemicals, and the amount transferred off-site. Subsequent congressional acts have modified reporting requirements slightly.

Facilities must submit a separate form R for each toxic chemical manufactured, processed, or otherwise used at each covered facility.

For additional information about electronic TRI reporting, click the following links or use the scroll bar to scan the page.

EPA TRI form Filing Requirements

Using Emissions Management for TRI Reporting

Submitting Electronic TRI Report Files

Setting Up Emissions Management for TRI Reporting

General Work Flow for Electronic TRI Reporting

 

EPA TRI form Filing Requirements

Owners and operators of facilities must file a form R if the facility meets all of the following criteria:

The Essential Electronic TRI Reporting tool can calculate threshold values and determine the chemicals you must report. For additional information, refer to Determining Threshold Exceedances.

Government publications further describe qualifying criteria and provide examples that you can use to test your facility’s need to file annual reports that include worksheets for determining if you have reached established thresholds.

Completing EPA form R or form A

There are two versions of the TRI report; the quantity of a chemical manufactured, processed, or otherwise used and released at your facility determines which report you must submit.

The decision to use form R or form A for a chemical is user-determined.  For initial guidance regarding overall material TRI reporting eligibility, evaluate reporting threshold results in Sphera Essential. For information about form R/form A eligibility requirements and compliance criteria, refer to he EPA's Toxic Release Inventory form instructions.  

Submitting Electronic TRI Report Files

The Essential Electronic TRI Reporting tool extracts data from each of four modules (Air, Waste, Water, and Chemical Inventory), compiles the results and generates reporting files that can be submitted to the US EPA electronically. These electronic files are referred to as a submission and may be imported into the US EPA's TRI-MEweb software for validation and printing. For each submission, you will need to define your reporting configuration, assign chemicals and chemical categories, and create your submission data before you can generate your TRI report data files.

What is a submission?

A submission consists of the following information: reporting period, your last year's submission, report configuration, the list of chemicals and chemical categories included in the report, and the required data in XML format for TRI reporting. It stores a historical record of the setup for each electronic TRI reporting submission. Establish submissions and generate reports using the TRI Report form .

What do I configure for my submission?

Before you run your TRI report, you will need to configure how your submission data should be reported. When you configure your submission, you are setting up the various reporting options applicable to the generation of a TRI report. These reporting options include identification of your organization's location, facility contacts, reported values for each section of the report, emission models, and your discharge monitoring report configuration. Establish configurations using the TRI Configuration form.

How do I select chemicals and chemical categories?

On the TRI Report form, three lists can be used for selecting the chemicals and chemical categories to include in your report. You can make your selections from the SARA 313 regulatory list that you specify when you create your TRI reporting submission. You can select from the list that is based on the outcome of reporting threshold determinations (e.g., Manufacturing, Processing, and Otherwise Use). Or, you can select from a list of all pure chemicals and chemical categories.

What do I do with the TRI reporting files?

Once you have entered the desired data for your submission, run the report to generate the electronic TRI reporting files. You can then import these files into the US EPA TRI-MEweb software, check them for quality and validity, and submit them to the appropriate state and federal agencies.

General Work Flow for Electronic TRI Reporting

The following is a general work flow for electronic TRI reporting that you may find helpful:

  1. Review or establish required TRI information about your facility. For each entity:

  1. Review or establish validation tables for your chemicals and chemical categories.

  2. Configure your TRI reporting submission using the TRI Configuration form.

  3. Establish an electronic TRI reporting submission using the TRI Report form.

  4. Evaluate reporting thresholds to determine a list of chemicals and chemical categories using the TRI Report form.

  5. Select and assign your chemicals and chemical categories via the TRI Report form.

  6. Generate the electronic TRI reporting data files using the TRI Report form.

  7. Upload TRI reporting data files into the US EPA TRI-MEweb application.

  8. Perform quality control by validating the report data.

  9. Submit the TRI report through the TRI-MEweb application to file a paperless report.  Additional options include printing the TRI report or generating a disk containing the TRI reporting files for state and other agency submissions.

Using Emissions Management for TRI Reporting

The Essential Electronic TRI Reporting tool is a comprehensive reporting utility. You can use this tool to select the necessary information you have already set up in the Emissions Management modules and generate the electronic TRI reporting files. For each submission, you can specify a facility, date range, and a list of chemicals. Manually select chemicals or allow the Electronic TRI Reporting tool to evaluate threshold values and select the chemicals for you.

Because all of the Emissions Management modules support a common relational database, you can set up your facility and your material information once and reference that information from any module. For electronic TRI reporting, this is important because the toxic chemical information you need to report can flow into the report from the Essential Air, Waste, Water, Chemical Inventory, and FEMS modules. For example, to obtain a total for benzene at your facility, you could combine your DMR loading calculations that track benzene at your outfalls, your emission modeling calculations that track benzene emissions, your on-site storage, and your shipments of benzene to off-site storage and disposal locations. The Electronic TRI Reporting tool would generate a TRI report that combines all your benzene totals.

Specific values can be included or excluded to avoid double counting threshold values. For instance, when a raw material is tracked in inventory, passes through a process, and is ultimately contained in a waste or emission stream, it produces several threshold values. You can document quantities using mixtures and material speciation, which essentially breaks down chemical mixtures into pure materials and chemical categories for regulatory reporting purposes. For additional information, refer to Speciating Material Releases.

The Electronic TRI Reporting tool incorporates values and calculations that you must set up prior to generating the report. The types of information that might be derived from each module are described briefly in the following sections. For detailed information on entering data and setting up calculations in each module, refer to online help for the module.

Note:  You must update your calculations for each module before attempting to generate an electronic TRI report.

Modeled or Estimated Chemical Emissions

Use the Air module to address monitoring, emission estimation, reporting, and recordkeeping tasks. A representation of your enterprise must be established based on a defined hierarchy—entity, production unit, and process unit (include your sources, control devices, emission points, and other components). The representation includes the emissions flow and the relationship between process units. Monitoring data may be used to indicate compliance with limits and as dynamic values in emission equations, allowing you to maintain accurate emission inventories based on production factors.

The Air module contains a powerful calculator, so you can determine at any time how production is affecting compliance and adjust your operation accordingly. Emissions data is calculated by evaluating source emission models, control models, and production schedules. Initiate the calculation process to evaluate emissions data. Keep your emissions inventory up to date by continuing to enter monitoring data, creating new production schedules to reflect the operations at your facility, and recalculating. Past and present emissions data is stored in your Essential database, which allows for reporting flexibility.

Emissions Management contains a number of equations for modeling the emissions from your sources. You can build additional emission equations, as necessary, for modeling the behavior of sources and control devices. Sources are modeled using emission models and scenarios to determine how sources operate during certain activities and under certain conditions, as well as how the materials emitted during the activities are calculated. Control devices are modeled using a control model that contains a set of abatement efficiencies, called an abatement model or a condenser equation.

Shipped, Disposed, and Treated Chemical Wastes

Facilities that generate hazardous waste have many recordkeeping and reporting concerns, as well as stringent procedures that must be followed when treating or disposing waste material.

Establish containers to manage waste. Add material contents and place each container in a storage area. In the Waste module, process units designated as storage areas are used to:

You can ship containers, bulk materials, or both. Designate a point of origin for bulk material shipments to document a source. Specify important shipment information, such as the disposal methods for containers or bulk materials, the date received by the receiving facility, and a date on or after the receipt date when the waste will be disposed.

Inventory Transactions and Estimates

The Chemical Inventory module allows you to track the inventory of materials in storage locations. Log every inventory transaction that occurs at your facility, such as material additions, transfers, and uses. Balance adjustments can be made as necessary. Use transactional data to maintain the most detail for your material inventory. You can use transactional data for form R reporting and other purposes, such as air emissions modeling.

You can also use inventory estimates for form R reporting. When you use inventory estimates, you are estimating the amount of a material in a storage area as of a given date. This method eliminates the need to enter detailed inventory transaction information at your facility.

Wastewater Loading Calculations

The Essential Water module is a comprehensive system for monitoring, documenting, and reporting pollutants in outfalls. Facilities that discharge pollutants into surrounding waters are responsible for recording and maintaining data that shows the quality and quantity of those pollutants. Facilities routinely track both the source of the discharge (process water, storm water runoff, non-contact cooling water) and the destination of the discharge (body of water, injection well, landfill).

The Water module streamlines the processes of storing, manipulating, and reporting a facility’s water data. For example, you can track pollutant quality and quantity at a given discharge point as well as compare them to the maximum exceedable quality and quantity limits. You can enter monitoring data collected at your facility, sampling as frequently as required by your permits. If loading values for monitoring parameter samples are needed, you can specify whether a parameter’s data will be input directly or should be calculated. Compare raw data and calculated values with pollutant limits to prove compliance. You can then express this data in a report such as a Discharge Monitoring Report (DMR).

Incidents and One-Time Non-Production-Related Releases

The Emissions Management Solution allows you to record key details about releases of hazardous substances to help you meet notification and reporting requirements. You can document the materials that were released during an incident and indicate whether some or all of the material was released to the environment and whether some or all of the material was contained and disposed of.

If the material was released into the air, you can enter the estimated amount released and whether it was a fugitive (non-point) or stack release. If the release occurred through a stack, you can identify the stack. If some or all of the material spilled into a body of water, you can enter the estimated amount released and the water body affected. If the material was released through an outfall that you monitor for pollutants, you can enter the amount released and specify the outfall name.

If you were able to contain all or some quantity of the spilled material, you can specify the amount and final destination of that material. Also, you can indicate that you disposed of it on-site, such as in an approved landfill, or treated it on-site in a disposal system, such as an incinerator. If you were able to contain all or a quantity of the material and send it to a POTW (Publicly Owned Treatment Works), you can enter the amount shipped and specify the POTW name.

Note:  If the release involved more than one amount, the quantity of material released is summed and totaled.

You can generate a report of the speciated emissions released during a particular incident that lists pure materials, CAS number, and quantity in pounds, as well as the medical information entered. The report also includes other details about the incident such as the start and end dates, location, and description. If the material released is not SARA reportable, you can exclude it from your form R.

Setting Up Emissions Management for TRI Reporting

Listed below is an overview of the procedures you can use to set up your Emissions Management Solution and generate a useful electronic TRI report that reflects your operations.

  1. Establish your facility information.

    Note:  Data is reported per entity; there is no roll-up functionality when a parent/child relationship exists. For example, if a TRI report is generated for an entity that is a parent of two different child entities, just the data associated with the parent entity is included. To report data for the child entities, a separate TRI reporting submission for each child must be established.

  2. Set up material information.

  3. Create emission models and calculations using the Air module. Enter operational data and calculate emission information.

  4. Use the Waste module to define waste storage areas and document movement and storage of bulk and containerized waste materials. Include waste recycling, treatment, and disposal information.

  5. Use the Chemical Inventory module to record and maintain running balances and/or estimates of materials.

  6. Set up loading calculations and record sample data for outfalls using the Water module.

  7. Use the Incident form to document any one-time non-production related releases of materials.

  8. Enter fugitive emissions monitoring data using the FEMS module.

  9. Generate Chemical Release Inventory (CRI) reports to check your data against a single data source. You may need to run multiple reports to get actual totals that correspond to the form R results.

  10. Use the Electronic TRI Reporting tool to establish a report configuration and submission, evaluate reporting thresholds, and generate the electronic TRI reporting files.

  11. Use the US EPA’s TRI-MEweb software to validate, submit, and print reports as necessary.

 

Related topics

 Speciating Material Releases

 Generating Electronic TRI Reporting Files

 Determining Threshold Exceedances

 Identifying Data Sources

 Configuring TRI Reporting Submissions