Superfund Amendments and Reauthorization Act (SARA) Title III Toxics Release Inventory (TRI) – Form R and Form A

A Form R report must be filed to the EPA (EPCRA Reporting Center) and the appropriate state agency for each Section 313 toxic chemical manufactured or processed in excess of 25,000 pounds during the course of a calendar year and for any toxic chemical otherwise used in quantities exceeding 10,000 pounds, if the facility has 10 or more full-time employees and is included in a specified Standard Industrial Classification (SIC) Code.

The Form A is a simplified form of reporting and is intended as a means to reduce the compliance burden. The Form A must be submitted on an annual basis for each eligible chemical. If a facility meets the requirements for a Form A, they only have to file a Form A and not a Form R. A Form A report applies to facilities do not exceed a total annual reportable amount of 500 pounds and the amount manufactured, processed, or otherwise used does not exceed one million pounds.

The term “manufacture” means to produce, prepare, compound, or import an EPCRA Section 313 chemical. The term “process” means the preparation of a listed Section 313 chemical, after its manufacture, for distribution in commerce. “Otherwise use” means any use of an EPCRA 313 chemical, including an EPCRA Section 313 chemical contained in a mixture or other trade name product, or waste that is not covered by the terms of “manufacture” or “process”.

SARA Title III – Form R Services
Evaluate chemical releases to determine if any releases require reporting under Title III TRI and submit the appropriate forms (Form R or Form A) to the EPA and the appropriate state agency.

Tier II Reporting

Tier II reporting is a federal requirement and is part of Title III of the Superfund Amendments and Reauthorization Act (SARA) i.e. Emergency Planning and Community Right to Know Act. Its purpose is to identify the amount and location of hazardous materials stored at your facility. If the plant maintains the level of hazardous materials required to meet the reporting threshold, you must submit the appropriate Tier II forms each year by the specified deadline. The reporting requirements vary depending on the hazardous material.

Tier II Reporting Services
Evaluate hazardous materials stored at a facility and determine whether reporting requirements are triggered. If required, gather necessary storage information and submit appropriate forms before the annual deadline to the appropriate regulatory agency.

CERCLA Continuous Release Reporting

Releases of hazardous air pollutants (HAPs), EPCRA designated extremely hazardous substances (EHSs), and CERCLA hazardous substances not specifically regulated under a federally enforceable permit must be reported to the National Response Center (NRC), the State Emergency Response Commissions (SERC), and the Local Emergency Planning Committees (LEPC) if they are released in quantities over the reporting threshold. If the release is “continuous” and “stable in quantity and rate”, then a continuous release report can be filed, instead of reporting each time a release occurs.

CERCLA Continuous Release Reporting Services
Assess process to determine if release reporting is required. If required, submit reports to the EPA.

Annual Waste Summary Reports

The Annual Waste Summary is a report that lists the quantities of hazardous waste disposed of each year. An annual Wasdte Summary is required for the following facilities:

• Industrial Conditionally Exempt Small Quantity Generator, generating 100kg or more of Class I waste
• Small Quantity Generator
• Large Quantity Generator
• Maquiladora Generator or its Texas Parent Company

Annual Waste Summary Report Services
Collect waste manifest data and report generated waste.