U.S. EPA’s Toxics Release Inventory (TRI) program is the agency’s primary mechanism to inform the public about releases of certain toxic chemicals occurring in communities throughout the U.S. as mandated by Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). The first TRI reports were filed in 1988 by more than 19,000 manufacturing facilities. Today, over 21,000 facilities file annual TRI reports by the July 1^st deadline.

Illinois facilities represent a small subset of the TRI universe, representing 968 facilities in reporting year 2023 (RY2023). The top five industries (based on quantity of release) filing TRI reports in Illinois for RY2023 include:

1. Fossil Fuel Electric Power Generation (NAICS 221112)
2. Copper Rolling, Drawing, Extruding, and Alloying (NAICS 331420)
3. Petroleum Refineries (NAICS 324110)
4. Iron and Steel Mills and Ferroalloy Manufacturing (NAICS 331110)
5. Soybean and Other Oilseed Processing (NAICS 311224)

The most common Illinois TRI reported chemicals in RY2023 were:

1. Nitrate Compounds (water dissociable) (15.4%)
2. Copper and Copper Compounds (14.3%)
3. Zinc and Zinc Compounds (12.0%)
4. N-Hexane (9.2%)
5. Manganese and Manganese Compounds (7.7%)

There are several key nuances that all Illinois facilities should be aware of as they navigate this year’s TRI reporting.

Illinois Industry Tips & Tricks for TRI Reporting

Trinity’s Illinois office created this list of key TRI takeaways for the most common industry types in Illinois. Note that most of the takeaways are broadly applicable to all industry types.

• Facilities may produce several different TRI chemicals during combustion. These chemicals should be considered as ‘manufactured’ by the facility. Facility specific analytic data, process knowledge, or information from industry and EPA sources, amongst other sources, can be used to identify the chemicals manufactured. For Electric Generating Facilities, if no better information is available for the quantity of metals manufactured during coal and oil combustion, Table 3-4 and Table 3-5 of the U.S. EPA guidance document for Electric Generating Facilities can be used.
• EPA revised AP-42 Chapter 7, Liquid Storage Tanks in October 2024 and issued a new TANKS 5.1 software program for estimating tank emissions. Facilities should update their storage tank calculations to match the new AP-42 section, as applicable.
• Metal alloys typically contain TRI metals (not metal compounds), whereas paints and powder coats typically contain metal compounds (not elemental metals). Keep in mind that metals and metal compounds are separate TRI chemical listings and should be evaluated individually. Mill certifications and company stock listings/reference books are a common resource for determining metal content in metal alloys. TRI metal concentrations are typically low and frequently require the use of a special calculation for concentration ranges that straddle the de minimis value (see Example 6 from EPA’s TRI reporting instructions).
• The article exemption has a 0.5-pound release threshold. Common activities that can negate the article exemption due to having “high” (i.e., annual releases greater than 0.5 pounds) metal releases include laser and plasma cutting, metal parts washing, abrasive blasting, and acid etching.
• Multi-establishment facilities that report releases separately still must complete a threshold determination that includes the chemicals at all establishments combined. U.S. EPA guidance includes:

“EPA recognizes that some facilities have unique and separate activities (“establishments”) taking place at the same facility, and for some of these facilities it may be easier and more appropriate for individual establishments to manage their chemical usage and management information separately. EPA provides for these cases and allows individual establishments at the same facility to report separately. However, for threshold determinations, quantities of EPCRA Section 313 chemicals manufactured, processed, or otherwise used in all establishments in that facility must be combined and considered together. Also, the combined releases and other waste management activities reported separately for each establishment must equal those for the facility as a whole.”

• Refineries may consider combustion of refinery fuel gas in heaters and boiler as ‘on-site energy recovery’ for TRI reporting. However, parent metals, metal compound categories, metals with qualifiers, or individually-listed metal compounds may not be designated as treated with on-site or off-site recovery processes, therefore don’t assume all constituents of fuel gas are “treated”.
• For purposes of TRI reporting, RCRA empty is not equal to EPCRA empty. See the TRI Instructions Table, “ Summary of Residue Quantities from Pilot-Scale Experimental Study” (also copied below) for guidance on how to quantify release from container residues if no measurements are available.

EPCRA Section 311 Reporting Reminder

Pursuant to Section 311 of EPCRA, facilities are required to submit a material safety data sheet (MSDS) and/or a list of hazardous chemicals as defined under the Occupational Safety and Health Administration (OSHA), to the Illinois Emergency Management Agency (IEMA), the Local Emergency Planning Committee (LEPC), and the fire department with jurisdiction over the facility. MSDS (or SDS) reporting is a one-time requirement for facilities. However, if a facility acquires a new hazardous chemical that exceeds the reporting thresholds defined in EPCRA Section 311, the facility is required to submit the MSDS/SDS within three months to IEMA, the LEPC, and the fire department with jurisdiction over the facility. The three-month deadline to update the MSDS/SDS report is commonly overlocked, and facilities often submit new chemical information as part of the Section 312 (Tier II) report, due annually by March 1st. IEMA has emphasized the requirement to keep MSDS/SDS reporting up to date and requested facilities submit an MSDS/SDS report if they have not yet done so.

Upcoming TRI Training Opportunities

Trinity is offering a complimentary webinar series, Industrial Insights: Overcoming TRI Reporting Challenges in Your Industry, from April through May. Each 1-hour webinar focuses on key TRI nuances for certain industrial sectors, including:

• Chemicals – 4/22/2025
• Metal Fab and Finishing – 4/24/2025
• Fuel Terminals – 4/29/2025
• Mining & Quarry – 5/1/2025
• Food & Beverage – 5/6/2025
• Semiconductor – 5/8/2025
• Concrete & Asphalt – 5/13/2025
• Printing & Coating – 5/14/2025
• Natural Gas Plants – 5/20/2025
• Refineries – 5/21/2025
• Pulp & Paper – 5/22/2025

Trinity Consultants assists a number of Illinois industries and clients with TRI reporting, dating back over 30 years. For more information and/or for assistance with your facility’s TRI reporting, please contact Trinity at 630.495.1470 or email Brad Berglund.