EHS Topic of the Month: R Form Reporting

EPA Reporting for the TRI (Toxics Release Inventory or "R Form") is due July 1!

Each year, certain industrial facilities submit Toxics Release Inventory (TRI) data to EPA. The data are due by July 1st and cover waste management activities that occurred during the previous calendar year. EPA makes this data publicly available.

The majority of non-ferrous foundries must consider whether they are required to report their discharges of metal or metal compounds on the Section 313 TRI (R Form), due every July 1 for the previous calendar year. Metals reported include: chromium, copper, lead, manganese and nickel.

Foundries may also need to report if they machine castings or metal shapes in any way the changes the height, shape, or diameter of the piece. The machined parts must be considered in threshold determinations and any releases, including recycling.

If you machine any castings or objects that release more than 0.5 pounds of a reportable metal you MUST consider the releases, including those to the air, as a point source or a fugitive release. Most machining operations do NOT have collection systems on the operation, so they would release fugitive dust. Whether the machine is enclosed or not (such as a CNC machine) will affect how much dust is released. Whether the piece is machined dry or wet will also affect the release.

You must have some basis for deciding if there are no releases. If there are releases, you need some basis as to how you determined those releases. You will also need to evaluate how any chips, dust, turnings, etc. are handled and if they must be reported.

Any releases must be added to your foundry numbers unless you report machining operations as a separate source. Machining operations would be a separate source if they are located at a different physical location—NOT a separate building on the same property. It must be separated by other properties, a street, etc.

You CAN report the machining separately if it operates as an independent unit on the same site, but it will have the same identification number as the foundry and any other operations on that physical site.

For more information about TRI reporting, visit https://www.epa.gov/toxics-release-inventory-tri-program.