The data reported by industrial facilities helps communities and emergency response agencies plan for emergencies involving hazardous substances. We can provide the EPA enforcement consulting to assist you with this reporting.

1. Toxic Release Inventory
EPCRA & Community Right-to-Know Program Compliance
The Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) provides the US EPA with the authority to require
industrial facilities to report information on the storage, use, and release
of hazardous and toxic chemicals at their facility. The data reported by
industrial facilities helps communities and emergency response agencies
plan for emergencies involving hazardous substances. We can provide
the EPA enforcement consulting to assist you with this reporting.
EPCRA includes four distinct chemical reporting requirements:
emergency planning, emergency release notification, hazardous
chemical storage reporting, and toxic chemical release inventory
reporting.
Section 301-303: Emergency Planning
Emergency planning activities are required by Sections 301-303 of
EPCRA. Facilities that maintain any Extremely Hazardous Substance
(EHS) on site above the applicable threshold planning quantity must
notify the State Emergency Response Commission (SERC) and the

2. Local Emergency Planning Committee (LEPC) within 60 days after they
first maintain the substance on site.
Section 304: Emergency Release Notification
Emergency release notification is required by Section 304 of EPCRA.
Any facility that accidentally releases an EHS or CERCLA hazardous
chemical into the environment in an amount greater than the reportable
quantity for that substance must immediately notify the SERC and
LEPC of the release. CERCLA releases must also be reported to the
National Response Center.
Section 311 and 312: Hazardous Chemical Storage Reporting
Requirements (Tier II)
Hazardous chemical storage reporting is required by Sections 311-312 of
EPCRA. Section 311 requires facilities to either submit copies of safety
data sheets (SDSs) for chemicals used on the site above the applicable
threshold, or a detailed list of the chemicals used on the site above the
applicable threshold. The information must be submitted to the SERC,
LEPC, and local fire department.
Section 312 requires facilities to submit an annual inventory report (Tier
II) for all hazardous substances stored on the site above 10,000 pounds.
Hazardous substances include all chemicals for which facilities are
required to prepare or maintain an SDS. The report must also include all
EHSs stored on the site above 500 pounds or the applicable threshold
planning quantity, whichever is lower. The report is due by March 1 each
year and is submitted to the SERC, LEPC, and local fire department.
Most states use the EPA Tier II form, but some states, such as New
Jersey, have developed their own form. In both New Jersey and
Pennsylvania, Tier II reports are submitted to the state electronically.
Tier II reports, due on March 1 of each year. Since the 2013 reporting
year, revisions to the federal regulations for Community Right-To-Know
reporting require additional facility information be submitted on state
and federal forms.
The revisions include changes to the storage quantity range codes used
(though states may elect to maintain their previous codes), changes to

3. the method for reporting mixtures versus pure chemicals, and the
capability to identify a reported substance as an on-EHS substance based
on the material concentration. Revised information fields on the Tier II
reports include: spaces to provide written descriptions of storage
conditions, maximum number of occupants, TRI ID number (if
applicable), facility RMP number (if applicable), and additional facility
contact information, and check boxes for indicating if the facility is
subject to EPCRA Section 302 (Storage of Extremely Hazardous
Substances) and if the facility was manned or unmanned. Optional data
fields for voluntarily providing specific details about the facility that
would aid in emergency response situations have also been added to the
Tier II reports.
Section 313: Toxic Chemical Release Inventory (TRI)
Toxics release inventory (TRI) reporting is required by Section 313 of
EPCRA. TRI reporting, also known as Form R reporting, is required in
order to provide the public with information on a number of hazardous
chemicals that are released, disposed of, recycled, or treated in their
community each year. Facilities are required to perform a “threshold
analysis” each year in order to determine whether they are subject to TRI
reporting. The threshold analysis must include a review of all materials
used on site during the reporting year. The total amount of each chemical
used must be compared to the applicable reporting threshold. If a
threshold is exceeded for any chemical, either a Form R or Form A
report must be submitted to the EPA by July 1 each year.
The toxic release inventory is a complicated, high liability program. It is
important that whether the facility is subject to reporting or not that there
is support documentation on the threshold analysis. EPA expects this
documentation when they conduct onsite inspections. The EPA can
assess substantial fines for non-reporting or incorrect reporting. ESC has
been helping clients with their TRI reporting for many years. ESC will
determine whether the facility is subject to reporting, what chemical(s)
need to be reported, and whether there are any applicable reporting
exemptions. If the facility must report, ESC will estimate releases to
each environmental medium, complete and submit the reports, and

4. provide the client with supporting information that documents the basis
for the reporting and release estimates.
For contact Us:-->
1528 Walnut Street, Suite 500,
Philadelphia, PA 19102
(215) 731-4200
info@envirostrat.com
http://www.envirostrat.com/toxic-release-inventoryform-r/