TOXIC RELEASE INVENTORY (TRI) REPORTING

Affordable TRI Reporting Compliance for Texas Industrial & Commercial Facilities

We help small to mid-size Texas businesses comply with EPCRA Section 313 Toxic Release Inventory (TRI) reporting requirements under 40 CFR Part 372. Our TRI reporting services are designed for facilities that manufacture, process, or otherwise use listed toxic chemicals above reporting thresholds, without the cost, complexity, or overhead of large consulting firms.

TerraLuna Environmental LLC supports facilities across Texas, including manufacturing plants, metal finishers, chemical processors, fabricators, refineries, utilities, and industrial operations subject to EPA TRI reporting. We deliver accurate, defensible TRI submissions that stand up to EPA and TCEQ scrutiny.

Our approach is straightforward: determine applicability, calculate thresholds correctly, prepare compliant TRI Form R reports, and reduce enforcement risk.

How We Help (Our Cost-Effective TRI Reporting Services): 

We help facilities comply with EPCRA Section 313 and 40 CFR Part 372 through practical, budget-conscious TRI services tailored to your operations: 

• TRI applicability evaluations (NAICS code review and activity analysis)
• Chemical usage and threshold determinations
• Release and waste management calculations (air, water, land, off-site transfers)
• Form R and Form A preparation and submission
• EPA Central Data Exchange (CDX) submissions
• Initial TRI reporting for newly covered facilities
• Amended TRI reports and corrections
• EPCRA inspections, audits, and EPA inquiries support
• TRI tracking and documentation
• Employee training on TRI Reporting and recordkeeping
   

What we help you achieve:

• Accurate TRI determinations and reporting under EPCRA Section 313
• Correct use of Form R or Form A Certification Statements
• Defensible calculations for manufacturing, processing, and otherwise use thresholds
• Compliance support during EPA or TCEQ inspections and data reviews
• Reduced enforcement risk through complete, well-documented submissions
• Ongoing TRI compliance management without hiring in-house staff

TRI reporting is a public disclosure program, and errors or omissions can result in EPA enforcement, penalties, and reputational risk. 

Who This Applies To (Am I Affected?):

EPCRA Toxic Release Inventory (TRI) reporting applies to certain Texas facilities that meet all three of the following criteria during the reporting year:

• Operate under a covered NAICS code
  TRI reporting applies only to facilities in specific industry sectors identified by EPA, including manufacturing, metal processing, chemical handling, utilities, and certain waste management and industrial operations.
• Have 10 or more full-time equivalent (FTE) employees
  This includes full-time, part-time, and temporary employees combined to equal 10 FTEs or more at any point during the calendar year.
• Manufacture, process, or otherwise use TRI-listed chemicals above reporting thresholds
  Facilities must report if listed chemicals are manufactured, processed, or otherwise used above EPA threshold quantities, even if releases are minimal or well-controlled.
  • Manufacture: 25,000 pounds
  • Process: 25,000 pounds
  • Otherwise Use: 10,000 pounds 
  • For the above thresholds: Lower thresholds apply to Persistent, Bioaccumulative, and Toxic (PBT) chemicals, such as mercury and certain dioxins. 

Facilities that meet all three criteria are required to submit annual TRI reports (Form R or Form A) to the U.S. Environmental Protection Agency (EPA). In Texas, TRI reporting is closely scrutinized and often reviewed alongside other EPCRA and TCEQ compliance programs.

What Chemicals are subject to EPCRA TRI Reporting?

TRI reporting covers more than 800 listed toxic chemicals and chemical categories regulated under EPCRA Section 313. Common TRI Chemicals Categories include: 

• Metals and metal compounds from metal shavings, grinding dust, welding activities, abrasive cleaning/blasting and other metal operations:  
  • Lead and lead compounds
  • Chromium, nickel, zinc, manganese
• Solvents and Degreasers from wipe cleaning, spray applications, evaporative losses, paints and thinners usage, or other operations:
  • Toluene, xylene, methanol
  • MEK, acetone, trichloroethylene
• Acids and Bases from process tanks, spent solutions, wastewater neutralization, or other operations:
  • Sulfuric acid
  • Hydrochloric acid 
  • Nitric acid
• Plastics and Resins
  • Styrene
  • Formaldehyde
• Combustion Byproducts
  • Nitrate compounds
  • Ammonia
•  Persistent Bioaccumulative Toxics (PBTs)
  • Mercury and mercury compounds
  • Lead
  • Certain dioxins and PCBs

Many TRI-listed chemicals are embedded in everyday materials, maintenance activities, and waste streams, not just primary production processes. Facilities often trigger TRI reporting without realizing it.

Common facility types we support for Tier II Reporting:

• Manufacturing and processing facilities 
• Machine shops 
• Metal fabrication shops/facilities
• Blasting and Coating facilities 
• Equipment yards and industrial service facilities
• Oilfield Support facilities
• Food & kindred products facilities 
• Power generation and utility facilities 
• Chemical manufacturers 
• And many other industrial sectors

Why This Is Required (Plain-English Explanation)

The Toxic Release Inventory was created to provide transparency into how toxic chemicals are managed across the U.S.

TRI Reporting helps:

• Communities understand chemical risks in their area
• EPA identify pollution trends and compliance issues
• Facilities improve environmental performance and accountability.

Simplified Regulatory Background

The Toxic Release Inventory program is authorized under the Emergency Planning and Community Right-to-Know Act (EPCRA), Section 313 and is administered by the U.S. Environmental Protection Agency (EPA).

Why this matters for your facility:

In Texas, TRI reporting is often reviewed alongside other EPCRA programs (such as Tier II reporting and Pollution Prevention Plan) and may be evaluated during inspections or data reviews involving EPA Region 6 and state and local regulatory agencies. 

Where facilities Commonly Struggle:

We routinely see TRI  Reporting compliance issues (non-compliance) such as: 

• Misunderstanding what counts as manufacturing vs. otherwise use
• Underestimating chemical quantities over the calendar year
• Failing to identify coincidental manufacturing
• Incorrect release calculations
• Missing July 1 reporting deadlines
• Submitting Form A when Form R is required
• Lack of internal tracking systems 
• Lack of employee knowledge about chemical release reporting obligations

Failing to submit TRI reports, submitting incomplete or incorrect Form R data, or lacking up-to-date chemical inventories, and release information tracking can expose a facility to significant compliance risk. Inadequate understanding of site processes, chemical usage, or toxic releases often results in reporting errors that may trigger regulatory scrutiny and enforcement actions, in addition to not submitting an annual report or performing an assessment each year for reporting applicability. Civil penalties for noncompliance can reach up to $25,000 per day for each violation, creating substantial financial and operational consequences for affected facilities. 

We close these gaps by maintaining accurate chemical inventories, preparing accurate TRI FORM Rs, submitting reports on time, and training employees to support regulatory compliance.

Why choose TerraLuna Environmental LLC?

We provide practical, affordable EPCRA TRI Reporting compliance services tailored to small and mid-size Texas facilities. 

What sets us apart:

• Transparent, affordable pricing
• Deep knowledge of Section 313 of EPCRA and TRI Reporting requirements 
• Familiarity with EPA's CDX TRI-MEweb Reporting tool 
• Specialized support for small to mid-size facilities without the high cost of other consulting firms. 

Find out more about TerraLuna Environmental LLC in our ABOUT US Page!