How TRI Reporting Connects to P2 Planning in Texas

In Texas, facilities that report under the Toxics Release Inventory (TRI) are often also subject to the state’s Pollution Prevention (P2) Planning requirements under the Waste Reduction Policy Act (WRPA). These programs are closely linked, and understanding how they overlap is key to staying compliant.

What Are TRI-Listed Chemicals?

TRI-listed chemicals are over 800 specific substances designated by the EPA under EPCRA Section 313 due to their potential to cause serious harm to human health or the environment. This includes:

• Heavy metals like lead, mercury, and cadmium

• Solvents such as toluene, xylene, and methylene chloride

• Carcinogens like benzene and formaldehyde

• Persistent, bioaccumulative, and toxic (PBT) chemicals

  
  

Facilities that manufacture, process, or otherwise use these chemicals above certain thresholds must submit TRI reports each July to EPA and TCEQ, disclosing releases to air, water, land, and off-site transfers.

Who Has to Do P2 Planning in Texas?

If your Texas facility meets either of the following, you are required to maintain a P2 Plan:

• You are a Small Quantity Generator (SQG) or Large Quantity Generator (LQG) of hazardous waste in Texas;

  AND

• You file a TRI report for any listed chemical

TCEQ requires the development of a P2 Plan for on-site documentation as well as submittal of an Executive Summary and signed Certificate to the TCEQ within 90 days after TRI Form R is filed.

How TRI and P2 Are Connected

The TRI report identifies what you released into the environment and in what quantities, while your P2 Plan maps out how you’ll reduce or eliminate those releases through source reduction. That means preventing pollution up front, not just treating it after the fact.

The plan must:

• List each TRI chemical reported

• Describe how the facility plans to reduce its generation or use over time

• Identify specific projects, goals, or technologies to reduce waste and emissions
  

Each year, you must submit a Pollution Prevention Executive Summary and Annual Progress Report (APR) to TCEQ via the STEERS online reporting system.

Why It Matters

P2 Plans not only help reduce regulatory risk and environmental impact, but they can also lead to cost savings by improving efficiency, reducing material use, and minimizing waste disposal needs.

In short, TRI reporting tells you what you're releasing. P2 planning shows how you'll reduce it (at the source)!

Here's a great guidance document from TCEQ: https://web-ded.uta.edu/cedwebfiles/eti/OP_Fact_Sheet/RCRA/WRPA-Texas.pdf