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TRI Reporting

SARA TRI, Form R Reporting

Do I need to file a SARA TRI, Form R? Possibly. It can be tricky but ESSG can help determine if you are required and/or prepare your reports for you.

Evaluation:

The evaluation phase of the ESSG's SARA Title III Toxic Release Inventory (TRI) Reporting is the first step designed to help determine if you have a requirement to comply with the EPA's Superfund Amendments and Reauthorization Act of 1986, (SARA Title III) section 313. In this step ESSG will perform the following to help identify if your facility is required to file EPA's TRI, Form R or Form A report(s):

 

  1. Compile your section 313 inventory;

  2. Break down the TRI candidates found within your inventory and group them in aggregate chemical totals;

  3. Review all identified Section 313 TRI candidates found in your chemical inventory;

  4. Compile your yearly quantities;

  5. Match your annual quantities against the EPA section 313 thresholds;

  6. Determine your reporting requirements as they pertain to the regulatory standard;

  7. Conduct a chemical mass balance formulation for each chemical requiring a TRI report; and

  8. Determine the acceptable calculated amount of the 313 chemical released under normal manufacturing processes.

 

Reporting:

If the evaluation phase determines that your facility is required to file TRI report(s), then ESSG will perform the following for each chemical that requires reporting:

  1. Prepare the annual toxic release information;

  2. Prepare the required annual source reduction and waste minimization information;

  3. Prepare your facility ownership, location, and production information required in each report;

  4. Determine the facilities longitude and latitude for your facility;

  5. Prepare and complete any current year reports in the most recent forms, issued by the EPA (Form R or Form A);

  6. Submit for your review and records, all sections and calculations required for the report;

  7. Return required reports for approval and signature by the authorized representative at your facility;

  8. Send reports to the EPA via Certified Mail (The Return Receipt Slips will be returned directly to you); and

  9. Leave signed report copies with you for your records.