Do annual TRI reporting requirements apply to nitrate compounds?

In a recent EPA Enforcement Alert, EPA stresses that toxic release inventory (TRI) reporting requirements apply to facilities that generate water dissociable nitrate compounds as by-products during wastewater treatment processes. Data from the TRI suggests that many facilities reporting chemicals such as ammonia, sodium nitrite, and nitric acid may also have reporting obligations for nitrate compounds.

EPA has made clear through TRI reporting instructions and guidance documents that nitrate compounds generated as by-products must be reported when these compounds are in excess of reporting thresholds.

Companies that fail to fully report nitrate compounds risk enforcement actions and penalties of up to $27,500 per day under EPCRA Section 325.