Recording: Live Expert: EPCRA Part 2 – TRI Reporting

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Additional Questions Regarding TRI:

EPA has determined that ceramic/brick industries emit dioxins/furans during processing and have issued MACT standards addressing such emissions. For EPCRA, if a facility emits dioxin/furan only as a byproduct from the ceramic vitrification process, is any dioxin/furan emitted reportable under the TRI?

If dioxin/furan is a byproduct of operations at the facility (i.e., it is coincidentally manufactured from the ceramic vitrification process), then yes, you would include dioxin/furan in your threshold calculations.

Can you explain the ammonia 10% reporting rule and how it applies to a 25% ammonium hydroxide solution?

Assuming this is for “otherwise use.” We suggest that you review the ammonium hydroxide SDS to determine the percentage of ammonia in the solution, then multiply that by 10% when you determine if over the 10,000 pound threshold for the total “otherwise use” category for ammonia. (Note: the amount of ammonia vs ammonium hydroxide is pH dependent).

Do ethylene oxide commercial sterilization facilities fall under the listed NAICS codes or does it only include medical device manufacturing that use ethylene oxide to sterilize new devices?

The EPA website indicates that ethylene oxide sterilizers fall under “product sterilization and packaging services” (NAICS code 561910), which is not a TRI-covered sector. Although some facilities do report, it is not required.

Are shipbuilding codes included in the list of facilities that are regulated under TRI?

Yes, here are a couple of listed NAICS under Transportation Equipment Manufacturing:

NAICS 336611 Ship Building and Repairing
NAICS 336612 Boat Building
NAICS 488390 Other Support Activities for Water Transportation (limited to facilities that are primarily engaged in providing routine repair and maintenance of ships and boats from floating drydocks).

There are also several other NAICS codes under fabricated metal product manufacturing, Nonmetallic Mineral Product Manufacturing, and Wood Product Manufacturing for prefabrication, for example, that may apply.