Calendar year 2017, as an odd-numbered year, has special significance to facilities in Minnesota that report releases under EPCRA 313 Toxic Release Inventory, or TRI.
The Minnesota Toxic Pollution Prevention Act (TPPA) requires facilities that report toxic chemical releases under EPCRA 313 to prepare a Pollution Prevention Plan (P2 Plan) for chemicals reported on EPA Form R. In addition to submitting their EPA Form R to the Environmental Protection Agency (EPA) and the Minnesota Emergency Planning and Community Right-to-Know Act (EPCRA) Program, TRI reporting sites must prepare a Pollution Prevention Plan and to submit annual Pollution Prevention Progress Reports based on those plans to the Minnesota EPCRA Program.
There are two reoccurring P2 requirements for TRI reporting sites in Minnesota:
- Annual P2 Progress Report – due with TRI report on July 1, and
- Biennial Update to Pollution Prevention (P2) Plan – due by Jan 1 for each odd-numbered year (update required in 2017 must be completed by January 1, 2018)
The Pollution Prevention Plan and Progress Report do not apply to chemicals that are not required to be reported on EPA Form R, are reported on EPA Form A, or are reported on EPA Form R but have no on-site release or off-site transfer amounts.