For industrial facilities operating in Georgia, staying on top of environmental reporting is critical. One specific requirement that facility managers must be aware of is the Toxics Release Inventory (TRI) Report. This article breaks down what the TRI is, who needs to report, and the specific triggers relevant to your industry.
What is the TRI Report?
The TRI is established under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Its primary purpose is to inform decision-making by creating a public database containing information on toxic chemical releases and waste management practices. This ensures that communities, state officials, and local officials are aware of the quantities of certain toxic chemicals released by industrial and federal facilities across the United States.
Who Needs to Submit a TRI Report?
Not every facility is required to report. According to the manual, ready-mix concrete facilities are covered by the TRI program and must submit a report if they meet the following specific criteria:
1. Employee Count: The facility has more than 10 full-time employees, or the total employee hours exceed 20,000 hours.
2. Chemical Activity: The facility engages in the manufacturing, processing, or use of TRI-listed chemicals that surpass specific reporting thresholds.
The “Lead” Factor in Concrete Production
For the concrete industry, the most common trigger for TRI reporting is lead. Lead is a heavy metal subject to reporting when usage exceeds the threshold of 100 pounds.
You might wonder where lead comes from in concrete manufacturing. It is primarily found in:
• Raw Materials: Limestone and clay, which are primary components of cement, naturally contain small amounts of lead and other heavy metals like chromium, cadmium, and mercury.
• Additives: Fly ash, a byproduct of coal combustion often used as a cement supplement, may also contain trace amounts of lead, cadmium, nickel, and mercury.
Calculating the Threshold
Determining if you need to report requires a close look at your material usage. For example, cement suppliers provide data on the lead content in their products. In 2020, analysis showed that the Holcim (Theodore Plant) had a lead content of 44 ppm, while the Holcim (Holly Hill Plant) had 10 ppm.
Here is a sample calculation: If a facility uses 10 million pounds (5,000 tons) of cement per year with a lead content of 10 ppm (0.011%), the calculation reveals that 100 pounds of lead are used in the manufacturing process.
Since this amount meets the reporting threshold of 100 pounds, the facility is required to submit a TRI report for that calendar year.
Summary
For facilities in Georgia, understanding the chemical composition of your raw materials—specifically regarding trace metals like lead in cement and fly ash—is essential for maintaining compliance with EPCRA Section 313. If your facility meets the employee and chemical usage criteria, ensure you submit your TRI report to avoid regulatory issues.
Not Sure What Applies to Your Facility?
Phone: 770-359-9271
Email: info@bowenenvironmental.com
