Lesson Learned - Chemicals to Report on Form R/TRI
Its that time of year when facilities have either started or are in the process of putting together their annual Toxic Release Inventory (TRI) or Form R due on July 1st. The Form R is required under the Emergency Planning and Community Right-to-Know Act (EPCRA). Facilities must submit their Form R to both EPA and their state environmental agency to report the amounts of regulated toxic chemicals released to the air, water, or land the previous year. A few questions come up every year on what galvanizers should be reporting. The biggest confusion often arises on the reporting of zinc compounds.
So what types of materials need to be reported on the Form R? The following table lists the applicable chemical and reporting categories. There are three reporting categories: manufacturing, processing, or otherwise use. Manufacturing and processing both have a reporting threshold of 25,000 pounds. Otherwise use activities have a reporting threshold of 10,000 pounds. Lead has a different reporting threshold of only 100 pounds.
|Hydrochloric Acid (Aerosol)||O|
|Sulfuric Acid (Aerosol)||O|
|Zinc (Fume or Dust)||O|
|M = Manufacturing, 25,000 lbs
P = Processing, 25,000 lbs 11
O = Otherwise Use, 10,000 lbs
|* Lead is reportable for any activity (M,P,O) at 100 lbs.|
The majority of chemicals are otherwise used in the galvanizing process with only chromium compounds being processed, ammonia being manufactured and otherwise used, and zinc compounds being otherwise used and manufactured as a byproduct. Ammonia is manufactured as it is processed for on-site use and is otherwise used as a manufacturing aid. Chromium in the quench are processed as a formulation component. Hydrochloric and sulfuric acid are reported in the form of acid aerosols and are otherwise used as ancillary or otherwise use. Lead is otherwise used as a chemical processing aid and has a lower reporting threshold regardless of activity of 100 pounds. Nickel is also otherwise used as a chemical processing aid. Zinc in the form of fume or dust is otherwise used as ancillary or otherwise use. Zinc compounds are manufactured as byproducts and otherwise used as a chemical processing aid.
If your facility exceeds the threshold for a chemical for manufacturing, processing, or otherwise used, then a Form R needs to be completed. For hydrochloric acid and sulfuric acid, the reporting threshold should only take into account the acids in aerosol form. In calculating the threshold for zinc, only zinc in the form of fume or dust should be taken into account.
Once the need to report is established, then the determination of where the chemical is released to the environment has to be calculated. The chemical can be released to the environment via air, water, soil, and waste. It is important to not count the same chemical twice. Recycled and returned to the process is not considered to be a release to the environment and should not be included on the Form R. Be cautious and check to ensure that double reporting of a chemical is not done. For example, if a Metaullics Zinkoff Recovery System (MZR) is used to melt the skimmings and recover the zinc added back into the process, the recovered zinc does not need to be reported, otherwise, the amount being used would end up being double reported.
Reporting of zinc skimmings can be tricky in calculating the total of zinc compounds. Zinc skimmings are not considered a reportable release under zinc compounds because they are directly reused in a process. However, they do need to be taken into account when calculating the reporting threshold number of 10,000 or 25,000 pounds. In other words, they are considered a product since you are selling to a consumer. Form R is used for reporting wastes that are being released to the environment.
Taken from EPAs EPCRA Section 313 Questions and Answers Publication is an excerpt that discusses the terms of reuse.
If a covered facility sends metal scraps containing chromium off-site to be remelted and subsequently reused, does it report the amount of toxic chemical in the metal as recycled off-site? Assuming no contaminants are removed during the melting process, the chromium in the metal scraps is not actually being recovered but merely melted and reused. Therefore, the amount of the toxic chemical in the metal scraps would not be reportable in Part II, Sections 6.2 or 8 of the Form R. However, because the facility is repackaging and distributing the toxic chemicals in commerce, it should consider these amounts of the toxic chemical towards the facilitys processing threshold. If the covered facility exceeds a chemical activity threshold, it is required to file a TRI Report for that chemical.
EPA has also clarified the terms of recycling and reuse.
Quantities of toxic chemicals that are directly reused on-site or sent off-site for direct reuse without undergoing any reclamation or recovery steps prior to that reuse need not be reported. Assuming no contaminants are removed during the melting process, the toxic chemical in the metal scraps is not actually being recovered but merely melted and reused. Therefore, the amount of the toxic chemical in the metal scraps would not be reportable in Part II, Sections 6.2 or 8 of the Form R.
If toxic chemicals are directly reused without any intervening reclamation or recovery steps the toxic chemicals are not considered recycled for Form R reporting purposes. Reclamation or recovery would not include simple phase changing of the toxic chemical before further reuse (e.g., simple remelting of scrap metal).
When putting together your facilitys Form R, if a chemical is manufactured, processed or otherwise used and exceeds the reporting thresholds, a Form R report must be filled out for that chemical. Once that determination is made, then release estimates can be calculated. Any data or calculations used to justify the decision to report or not report should also be kept with a copy of the years submittal.
If a past report needs to be corrected, EPA does allow for revisions to be made. TRI Reports or Form Rs can be revised if the accuracy is not correct based on new information or better data. Facilities may only revise TRI reporting forms submitted for reporting years 1991 through the current reporting year and must be done using TRI-MEweb. Facilities may request a revision for one or more of the following reasons:
- RR1 new monitoring data
- RR2 new emission factor(s)
- RR3 new chemical concentration data
- RR4 recalculation(s)
- RR5 other reason(s)
Information on revising the TRI reports can be found at https://ofmpub.epa.gov/apex/guideme_ext/f?p=104:42:::no:42:p42_id:ri_1_5.
The AGA has developed a very detailed guidance document which focuses on completing the Toxic Release Inventory Form R. Included in the guidance document are calculations of reporting thresholds and release estimates.