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Regulatory Updates

2021 EPA TRI Reporting Requirements for Natural Gas Processing Facilities

Catriona V. Smith & Melissa Hart | July 9, 2021

There is a strong indication the EPA may be finalizing a rule to add natural gas extraction or processing plants (SIC 13 – Oil and Gas Extraction Sector and relevant portion of the corresponding NAICS code subject) to the scope of industrial sectors to EPCRA (Emergency Planning and Community Right-To-Know Act) Toxics Release Inventory (TRI) reporting, based on the Spring 2021 Unified Agenda of Regulatory and Deregulatory Actions. The notice of proposed rulemaking was originally issued January 06, 2017 (82 FR 1651) and is slated for final approval December 2021.

Natural gas (NG) processing facilities are stationary, surface facilities that receive gas from a gathering system that collects raw natural gas from off-site wells. These facilities prepare the gas to meet industrial or pipeline specifications and extract heavier liquid hydrocarbons from the raw or field natural gas. This processed pipeline-quality natural gas is then transferred to consumers via intra- and inter-state pipeline networks. Natural gas liquids and contaminants separated from the natural gas during the processing are sent downstream to petrochemical manufacturers and refineries, released, or otherwise handled or treated.

In preparing natural gas and associated products, these facilities deal with over 21 TRI-covered chemicals. Accordingly, TRI reporting by these facilities would provide a significant amount of release and waste management data that would increase the amount of information available to the public and further the purposes of TRI.

Natural gas processing facilities that primarily engage in sulfur recovery from natural gas (NAICS 211112) are currently subject to TRI reporting requirements. Facilities primarily engaged in natural gas extraction (e.g., exploration, fracking, etc.) are not included in this proposal.


EPA estimates that at least 282 NGP facilities in the United States would meet the TRI thresholds for at least one of the TRI-listed chemicals. These facilities must then assess the three (3) criteria for TRI reporting:

  1. Employee threshold of 10 or more full-time employees or equivalent (20,000 hours per year)
  2. Classified as NAICS industrial code (211112 with no exclusions); and
  3. Meet one or more of the following activities thresholds, which includes the manufacture, processing, or otherwise use of at least one TRI-listed chemical in excess of applicable threshold quantities.
    • Examples of TRI-listed chemicals subject to threshold determinations and reporting include, n-hexane, hydrogen sulfide, toluene, benzene, xylene, and methanol.

It would clearly add an additional reporting requirement to the industry and require an additional investment of resources and cost.

Catriona Smith

Catriona (Cat) Smith has over 30 years of professional experience in the interpretation and application of regulations for industrial facilities relating to compliance, remediation and negotiations with regulatory agencies. Her clients include upstream and downstream oil and gas, chem-pharma, petrochem, manufacturing and federal, state, and local governments. Ms. Smith is a Vice President and Environmental Sector Market Director for TRC, with nationwide responsibilities to manage our clients’ PFAS challenges, support and grow our Oil and Gas clients and bring multi-disciplinary solutions to their complex projects. Contact Cat at

Melissa Hart

Melissa Hart has over 30+ years of experience in private industry and consulting. Her environmental experience is focused on air pollution regulatory compliance; EPCRA/SARA compliance (including Tier II inventory, TRI reporting, and auditing); due diligence; air permitting; civil penalty calculations and enforcement negotiation; and Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS). Ms. Hart has worked in multiple industrial sectors, including aircraft and automotive assembly/manufacturing; automotive parts; food and beverage operations; miscellaneous metal fabrication; fertilizer plants; air filter fabrication; and miscellaneous surface coating operations. She holds a BS in Chemical Engineering from University of Missouri – Columbia.

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