• Facilities must keep a copy of each TRI report filed for at least three years from the date of submission.
• EPA may conduct data quality reviews of Form R or Form A Certification Statement submissions.

Sound recordkeeping practices are essential for accurate and efficient Toxics Release Inventory (TRI) reporting. It is in the facility’s interest, as well as the Environmental Protection Agency’s (EPA’s), to maintain records properly. Records are not just recommended, they are required under 40 CFR 372.10.

Facilities must keep a copy of each report filed for at least three years from the date of submission. Because the Emergency Planning and Community Right-to-Know Act (EPCRA) has a five-year statute of limitations, it is best practice to keep these records for five years, instead of the minimum three years. Regardless how long these records are kept, they will be of use when completing future reports.

Facilities must maintain those documents, calculations, worksheets, and other forms upon which they relied to gather information for prior reports. In the event of a problem with data elements on a facility’s Form R or Form A Certification Statement, EPA may request documentation from the facility that supports the information reported.

EPA may conduct data quality reviews of Form R or Form A Certification Statement submissions. An essential component of this process involves reviewing a facility’s records for accuracy and completeness. EPA recommends that facilities keep a record for those EPCRA 313 chemicals for which they did not file EPCRA 313 reports.

EPA also recommends keeping records of all documentation containing Central Data Exchange (CDX) account information for the preparer(s) and certifying official(s) that use TRI-MEweb to prepare and certify the reporting facility’s TRI Form R and/or Form A Certification Statement. These CDX documents include the electronic signature agreement (ESA) and the facility’s unique alphanumeric access key.

Records to maintain include:

• Previous years’ EPCRA 313 reports;
• EPCRA 313 Reporting Threshold Worksheets;
• Engineering calculations and other notes;
• Purchase records from suppliers;
• Inventory data;
• EPA National Pollutant Discharge Elimination System (NPDES) permits and monitoring reports;
• EPCRA 312 Tier II Reports;
• Monitoring records;
• Flowmeter data;
• Resource Conservation and Recovery Act (RCRA) Hazardous Waste Generator’s Report;
• Pretreatment reports filed by the facility with the local government;
• Invoices from waste management companies;
• Manufacturer’s estimates of treatment efficiencies;
• RCRA manifests;
• Process diagrams that indicate emissions and other releases;
• Records for those EPCRA 313 chemicals for which they did not file EPCRA 313 reports; and
• CDX account information including unique access key to pre-load facility account into TRI-MEweb and copies of the ESA(s) submitted to EPA for approval.

Note that each owner or operator who determines that they are eligible, and wishes to apply the alternate threshold to a particular chemical, must retain records substantiating this determination for a period of three years from the date of the submission of the Form A. These records must include sufficient documentation to support calculations as well as the calculations made by the facility that confirm their eligibility for each chemical for which the alternate threshold was applied.