It's getting towards that time of year again when folks start digging for information on TRI Reporting. Lately we've been getting a lot of visits online for things like "TRI Reporting at asphalt plants" or "Section 313 Reporting at asphalt plants."
Regardless of what you call it, TRI, Toxic Release Inventory Reporting, Form R Reporting, etc., it's all referring to Section 313 Reporting of EPRCA regulations.
It's great to see asphalt producers take notice and start thinking about reporting seriously, as the USEPA is cracking down at facilities of all kinds across the country more and more every year.
TRI Reporting at Asphalt Plants
Understanding your responsibilities is vital, since there can be huge penalties for any type of facility, asphalt or not, that should be doing Toxic Release Inventory Reporting and isn't.
Even if you're doing Section 313 Reporting incorrectly, or incompletely, you're out of compliance and could run the risk of receiving a violation from the USEPA, and trust me, you don't want that.
Fortunately, for asphalt facilities, the question of whether or not they have to do TRI Form R Reporting is much more straight-forward, and a lot simpler than other industries.
If you're still unsure what is TRI Reporting, click that link for an article that summarizes what the reporting is.
Ok, so let's say you're an asphalt producer, and want to know if you need to do Toxic Release Inventory Reporting. Let's discuss what chemicals might trigger the need to do reporting, and where you could find this information.
- Check your air permit. What have you or your state agency identified as being released via stack emissions? What are you being regulated on? The best first step to determine if asphalt producers need to do any reporting is to check those regulated emission chemicals against the TRI listing. For example, let’s say your permit includes lead (Pb) emissions, which have a reporting threshold of 100 pounds. Where does the lead come from in your stack emissions? Was it from fuel use, aggregate dust, or other sources? You need to determine the amount of lead in those materials, the total amount of lead processed during the year, and if exceeds the applicable reporting threshold, then you must do Toxic Release Inventory Reporting for your asphalt plant.
- How much fuel are you using? A fairly common area of chemicals to report at asphalt facilities are the PAC, or polycyclic aromatic compounds, which can normally be found in fuels like on or off-road diesel or gasoline. Like lead, these also have a lower threshold of 100 pounds. You need to go through your fuel records, and determine the amount of fuel you've been using, and figure out the levels of PACs in the fuel you've been using. This can be tricky, and there's several ways you can go about finding that data such as asking vendors or reviewing your SDS.
- Safety Data Sheets (SDS). Another great source of information are your safety data sheets for all materials used at your plant. Scan them carefully, look for applicable chemicals, and do your calculations of use based on toxic chemical concentration and amount used. Not the easiest of exercises, but it has to be done to fully determine reporting applicability.
You're probably thinking I don't know what these chemicals are, but I don't have any on-site. Unfortunately, you're probably wrong about that. The USEPA maintains a List of Lists of the chemicals you have to report on. Just be warned, this is a list of the chemicals, not materials, so you might review the list and think well I don't use any lead, so I don't have to report. That's wrong, and you need to review the chemicals in your materials.
It can be a headache, especially for those who have never done this before, those who don't have the time, or those who are in charge of a large, multi-operation facility. I stress you need to get this right. If that means hiring an environmental manager, or outside help, or getting additional resources, do it. The fines for non-compliance are extreme, and I've seen facilities shut down temporarily because of the EPA. It's not worth it.
Do I need to do Section 313 Reporting at my asphalt plant?
So you've figured out what you have, and you determine you need to report. Great! Unfortunately, that's only the first step.
The second step is estimating releases to the environment. Generally, at an asphalt facility, these will be stack emissions. The amount of release that is permitted should be listed on your air permit, or you can estimate using AP-42 emission factors. In all likelihood, the amount of releases will be pretty small, but they have to be estimated nonetheless.
This can be a little tricky, and you need to present this information correctly. Again, if you're unsure, get help however and wherever you can.
TRI reporting at an asphalt facility doesn’t have to be tricky, and it's very important since most asphalt producers aren’t interested in a big fine. I'm talking 7 to 8 figure fines handed out by the USEPA, and I'm not exaggerating. What's the best course of action for an asphalt producer? Find out where you stand, and if you need to report, do what’s necessary to come into compliance. Toxic Release Inventory Reporting at asphalt facilities, or any type of facility, isn't a walk in the park. If you're struggling with Section 313 Reporting at your operation click here to contact us, or call us at 609-693-8301 to discuss your needs today.