Toxic Release Inventory - la-awma.org
24
Toxic Release Inventory Why, What, and How? Karen Brignac Environmental Compliance Manager PPM Consultants, Inc.
Transcript of Toxic Release Inventory - la-awma.org
Toxic Release Inventory Why, What, and How?
Karen Brignac
Environmental Compliance Manager
PPM Consultants, Inc.
Background – 1980s
CAA HAPs – Part 61
Air Permits
Local Community Knowledge
“Trust Us” Attitude
Bhopal, India
December 3, 1984
Union Carbide plant
Methyl Isocyanate
Surrounding city
Over 3000 dead
Hundreds of thousands injured
US Reaction
What is stored at your plant?
How do you control it?
How much is released?
How do I know I am safe?
Congressional Action
EPCRA
Emergency Planning and Community Right-to-Know Act
Stand alone part of Superfund Amendments and Reauthorization Act
Passed October 17, 1986
Major Sections
Section 311 – Local Emergency Planning (SERC, LEPC)
Section 312 – Chemical Inventory Reporting (Tier II)
Section 313 – Chemical Release Reporting (TRI)
TRI Timeline
Proposed rule – June 4, 1987
Final rule – February 16, 1988
First report due July 1, 1988, for releases during 1987
Section 8 added in 1991
More chemicals added in 1994
PBT’s added in 1999
TRI Impact
For the first time, facilities were required to report all releases of listed toxic chemicals
Many sites did not have the data collected in this form anywhere
Data made available to the public
Initial TRI Data Release
EPA required to release all data
Public outcry!
Facility management now aware of all releases
Facilities called on to explain releases
Voluntary programs to reduce emissions
Who Must Report
Listed SIC code (20 – 39)
More than 10 full time employees
“Manufacture” or “process” more than 25,000 pounds per year of listed chemical
“Otherwise use” more than 10,000 pounds per year of listed chemical
Thresholds are lower for PBTs
Chemicals
Chemicals were initially specified by Congress based on state lists
EPA can add based on toxicity of chemical
Can petition EPA to delist chemical
Currently 581 chemicals and 30 chemical categories
Supplier Notification
For chemicals purchased as mixtures, supplier must include statement on MSDS if:
– TRI chemical present in amount greater than 1%
– Or if carcinogen, greater than 0.1%
(Same as OSHA requirements)
De Minimis
If chemical is present in mixture at concentrations lower than MSDS requirements, then chemical in that stream does not have to be considered
Thresholds
Look at all manufacturing, processing, and use of chemical on-site
Do not have to do additional sampling – use readily available data
Don’t forget chemicals manufactured as part of combustion or treatment – Fuels
– Salts from water treatment
Report (Form R)
Part I – Facility Information
Part II – Chemical Specific Information
– Identification
– Releases
– Transfers/Disposal/Treatment
– Recovery
– Recycling
Releases Section 5
Once threshold is exceeded, must report all releases of the chemical
Look at air emission inventories, DMRs, waste reports
Report to 2 significant digits (except for dioxin)
Releases, continued
Air – stack and fugitive
Water – report by stream or POTW
Waste on site – landfills, landfarms, etc.
Waste off-site – report by disposer
– Include site name, address, EPA ID number (if applicable)
On-site Treatment Section 7
Look at each stream that contains the chemical and list the treatment steps
Air – flare, condenser, carbon adsorption, etc.
Water – settling, biotreatment, clarification, pH adjustment, etc.
Solids – settling, filtration, etc.
Section 8
Amount released
Amount recovered on-site
Amount treated on and off-site
Amount combusted for energy recovery on and off-site
Section 8, continued
Treatment on-site - water treatment, flares – metals are not treated
Recovered on-site – condensers, scrubbers, separators
Combusted for energy recovery – boilers – chemical must have energy value
Reporting
Initial reports by paper (UGH!)
EPA developed TRI ME software for computers
All reporting now required to use TRI-ME Web
Anyone can input and submit data with login
Electronic signature agreement and approval by responsible official
Future?
EPA at one time proposed reducing the frequency of reporting
Proposal pulled due to public outcry
Program likely to stay with minor changes
Last Thoughts
TRI marked a turning point in industry/community relations
Industry forced to estimate and address toxic chemical releases
Public a very important part in the process
Lasting impact – CAAA of 1990
