Ah, the Toxics Release Inventory (TRI)! For many facilities, the deadline to submit the annual report for 2015 is just a couple of weeks away—July 1. The U.S. Environmental Protection Agency (EPA) sits on this enormous pile of data and is finding new and inventive ways of using the information. Will the Agency’s most recent endeavor up your ante for compliance obligations?
 |
Tens of thousands of facilities are required to report under the Emergency Planning and Community Right-to-Know Act (EPCRA). Facilities in different industry sectors, facilities in Indian country, and federal facilities must annually report how much of each toxic chemical they managed through recycling, energy recovery, treatment, and environmental releases.
Earlier this year, the EPA Office of the Inspector General (OIG) said that it is embarking on a plan to determine how the EPA uses TRI data to identify potentially unregulated facilities in its major media programs. The focus is on whether TRI facilities that fall under risk management plan (RMP) criteria are filing those plans and whether TRI facilities that are surface water dischargers are receiving their permits. The project also seeks to identify whether RMP facilities and surface water dischargers subject to TRI are filing their annual TRI reports.
Will Your TRI Data Trigger RMP Requirements?
In this project, the TRI data will show each reporting facility’s maximum amount of a TRI-regulated chemical present at the facility at any time during the year, based on two-digit codes.
Although TRI reports, on their own, will not show whether a facility has violated the requirement to file an RMP plan, the OIG noted that the EPA could use the TRI data to develop a list of facilities with more than the threshold quantity of an RMP-regulated chemical, and then investigate further, possibly by requesting more information from each facility.
Near Future for RMP
The EPA recently released proposed changes to RMP requirements. In addition, thousands of retail facilities face tougher RMP requirements because of recent changes the Occupational Safety and Health Administration (OSHA) has made to the Process Safety Management standard requirements.
Tip: If you file TRI reports, but do not have an RMP or a surface water discharge permit, this is a good time to examine your TRI data to look for any discrepancies with other environmental compliance reports and permits.
Do you need to find out if you are required to submit an RMP? Check Enviro.BLR.com® for all the information you need to be compliant with EPA’s chemical accident prevention program.