Toxics Release Inventory (TRI) Reporting
Yorke Engineering’s staff is uniquely qualified to manage or assist with the Toxics Release Inventory (TRI) reporting process from start to finish. We have worked on complex operations, such as chemical manufacturing, and simple operations alike and always put our clients’ needs first. Yorke staff has experience working with the U.S. Environmental Protection Agency (EPA) and has performed TRI reporting for numerous clients in the past decade.
General TRI Services
- Quantifying on-site chemical inventories;
- Quantifying annual chemical use;
- Preparation of Form R and Form A for submittal on TRI-MEweb;
- Review of Persistent Bioaccumulative Toxics (PBTs) and per- and polyfluoroalkyl substances (PFAS);
- TRI-MEweb guidance and setup; and
- Determination of exemption from TRI reporting, including applicability of de minimis and other exemptions.
TRI Reporting Categories
- Fugitive and Stack Air Emissions – On-Site;
- Surface Water Discharges – On-Site;
- Land Releases – On-Site;
- Disposal – Off-Site;
- Recycling – On-Site and Off-Site;
- Energy Recovery – On-Site and Off-Site; and
- Treatment – On-Site and Off-Site.
TRI Reporting
TRI reporting is completed annually for facilities with certain Standard Industrial Classification (SIC) or North American Industry Classification System (NAICS) codes and over 10 full-time equivalent employees. TRI reporting is required based on the prior year’s manufacture, processing, or other use of TRI listed compounds. The thresholds for most compounds are 25,000 pounds for manufacture or processing of chemicals and compounds and 10,000 pounds for compounds or chemicals that are otherwise used. However, chemicals of special concern (e.g. PBTs and PFAS) have lower thresholds (for example, the threshold for dioxin is 0.1 grams). The TRI program does allow for certain exemptions such as the article exemption and de minimis exemption. More information on TRI program exemptions can be found in 40 CFR §372.28.
When thresholds of manufacture, processing, or other use are exceeded, a Form R or Form A is required to be submitted to TRI-ME Web by July 1st. Depending on if a Form R or Form A is required, the TRI forms may include information about the compound/chemical that exceeded thresholds, the facility, chemical inventory, on-site treatment, and releases to air, water, recycling, waste (hazardous or otherwise), and land.
TRI Updates
Every year, new compounds are added to the list of TRI compounds, so reviewing the new materials can be an important part of a TRI review. Since 2020, the EPA has been adding PFAS to the list of TRI compounds. Starting in 2025 (based on 2024 calendar year data), there will no longer be a de minimis concentration for PFAS in TRI reporting.