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. Mandated by 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 1st deadline.
Kansas facilities represent a small subset of the TRI universe, representing 329 facilities in reporting year 2023 (RY2023). However, Kansas facilities still encompass a wide range of industry types (119 different industries in RY2023) covering a variety of TRI chemical types (129 different TRI chemicals reported in RY2023) illustrating the diversity of Kansas’ economic activity. The top industries filing TRI reports in Kansas for RY2023 include:
- Ready-Mix Concrete Manufacturing (NAICS 327320)
- Farm Machinery and Equipment Manufacturing (NAICS 333111)
- Other Aircraft Parts and Auxiliary Equipment Manufacturing (NAICS 336413)
- (Tie) Other Animal Food Manufacturing (NAICS 311119)
- (Tie) Ethyl Alcohol Manufacturing (NAICS 325193)
- (Tie) Asphalt Paving Mixture and Block Manufacturing (NAICS 324121)
Interestingly (and perhaps intuitive from the top industry list), the most common Kansas TRI reported chemicals in RY2023 were all metals and metal compounds:
- Lead and lead compounds (8.1% of all Kansas facilities reporting)
- Manganese and manganese compounds (6.4%)
- Chromium and chromium compounds (5.8%)
- Nickel and nickel compounds (4.9%)
- Zinc and zinc compounds (4.4%)
Toluene (ranked 7th) is the most common reported non-metal. Kansas’ variety of industrial activity is on full display as no single TRI chemical is reported by more than 10% of all the facilities in Kansas. Despite this variety, there are still several key TRI nuances that all Kansas facilities should be aware of as they navigate this year’s reporting.
Kansas Industry Tips & Tricks for TRI Reporting
Trinity’s Kansas City office created this list of key TRI takeaways for the most common industry types in Kansas. Note that most of the takeaways are broadly applicable to all industry types.
Ready-Mix Concrete & Asphalt Paving
- With the removal of the de minimis limit for supplier notifications, ready-mix facilities need to be hyper vigilant in reviewing cement and fly ash Safety Data Sheets (SDS’s) for lead compound and mercury compound content. Due to their low reporting thresholds (100 pounds and 10 pounds, respectively), a relatively small amount of cement and fly ash usage can trigger reporting for these facility types.
- Watch out for nitrate compounds (e.g., calcium nitrate, sodium nitrate, etc.) present in admixtures such as accelerators and corrosion inhibitors. Apart from lead compounds, this is the most common TRI chemical reported in this industrial sector.
- 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 fuel and asphalt storage tank calculations to match the new AP-42 section, as applicable. Trinity’s TankESP software is another tool for estimating tank emissions.
Metal Fabrication (including Farm Equipment & Aircraft Part Manufacturing)
- Carbon steel, stainless steel, and other 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 straddle calculation (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.
Food Manufacturing
- EPA updated their TRI Guidance for Food Manufacturers in January 2025, including consolidating information and adding external references (page count decreased from 160 pages to 28 pages) and more content related to the manufacture and release of water dissociable nitrate compounds from wastewater treatment. All food manufacturers with wastewater treatment activities are encouraged to read the updated guidance document.
- For ammonia refrigeration systems, only the amount of new ammonia charged to the system in the given reporting year counts against the 10,000-pound otherwise use threshold (see Q&A #140). When quantifying ammonia releases, consider ammonia emission losses from the refrigeration equipment, ammonia entrained in used oil removed from the compressors, and any fugitive ammonia losses or wastewater ammonia releases from wastewater treatment activities.
Ethanol Manufacturing
- Ensure that all byproducts of fermentation are considered for TRI manufacturing thresholds. Common byproducts include acetaldehyde, acrolein, formaldehyde, methanol, and formic acid.
- Water-only scrubbers are efficient at removing alcohols (e.g., methanol) and formaldehyde (typically 99% or more efficient), but not efficient at removing acrolein or acetaldehyde (typically 1% or less efficient). Facilities with outlet-only stack test results need to back-calculate inlet concentrations of these TRI chemicals for comparison to the manufacturing threshold; likewise, outlet data is needed to estimate air releases and wastewater releases.
- Facilities should quantify the “ammonia equivalent” percent present in ammonium compounds associated with wastewater treatment chemicals (e.g., urea ammonium nitrate, ammonium sulfate, ammonium hydroxide, etc.) for reporting purposes. Remember that aqueous ammonia includes a 10% qualifier for applicability and release purposes.
Upcoming Kansas TRI Training Opportunities
Trinity is hosting a
TRI Workshop in Dodge City on April 10th.
Taylor Wilson, P.E. and
Jacob Harrington will be co-teaching. The four-hour workshop covers all key aspects of TRI applicability and release reporting, including custom content that varies depending on the particular workshop’s attendees.
- 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 Kansas 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
913.894.4500 or email
Taylor Wilson, P.E. or
Jacob Harrington.
