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SARA Title III, Section 313: TRI Support

Nationwide Facilities

Partners has been assisting a leading manufacturer of engineered bearings and powertrain components and products with their annual Toxic Release Inventory (TRI) Form R submissions since 2017. Partners initially conducted TRI applicability evaluations and prepared subsequent Form Rs for applicable reportable chemicals for 11 different sites throughout the eastern and central United States.

Partners has worked closely with corporate and plant level environmental, health & safety (EHS) personnel to develop targeted, facility-specific information requests, followed by preparation of calculation spreadsheets to evaluate the types and amounts of TRI-subject chemicals manufactured, processed, or otherwise used at each of the facilities. Once it is determined that certain chemicals at a facility are required to be reported under the TRI program, Partners calculates releases to the environment via air emissions, wastewater discharges, stormwater discharges, and as hazardous waste. The amount that a particular applicable chemical was recycled, as well as other waste minimization efforts, is also evaluated and reported on the annual Form Rs.

Since program inception, the number of sites evaluated under the TRI program has grown to 17 as the client acquires new facilities through acquisitions and mergers. The Form R reportable chemicals at these facilities typically include metals (chromium, manganese, nickel, etc.) present in alloys, as well as solvents such as methanol and ammonia used in heat treating and product inspections. The number of Form Rs per site vary from year to year, but they typically range from one (1) to six (6) reportable chemicals.
Partners has been successful in tackling challenges associated with developing tracking systems and calculation spreadsheets for each of the different sites, especially with acquired sites that have different tracking systems. Partners’ staff has developed close working relationships and confidence with personnel throughout the organization and has provided consulting assistance for a variety of related environmental issues beyond the TRI program.

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