Questions and Answers

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Disposal; Facility; Landfill; Recycling; Releases; Underground Injection; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19013 19-013 13 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Disposal (Dispose); Facility; Landfill; Recycling (Recycle); Releases (Released); Underground Injection; Waste 13. What should I know about the different types of disposal or other releases?The TRI Program collects data on a number of different types of disposal or other releases, as well as on certain waste management and recycling practices. For more information on the differences between these data elements, please refer to the Toxics Release Inventory (TRI) and “Factors to Consider When Using TRI Data” on the TRI Web site. Disposal or other releases of chemicals into the environment occur through a range of practices that may ultimately affect the potential for human exposure to the toxic chemicals. Most disposal or other release practices are subject to a variety of regulatory requirements designed to limit environmental harm. Facility releases may include discharges to air, water, and land. Facilities limit contamination and human exposure by disposing of or otherwise releasing waste in certain ways. For example: - they may dispose of harmful materials in Class I underground injection wells located in isolated formations beneath the lowermost underground source of drinking water, thereby limiting the potential for contamination of drinking water; and - they may dispose of wastes in landfills that have liners, covers, leak-detection systems, and groundwater monitoring systems, thereby limiting the potential for human exposure to the contents of the landfill.</div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Ultimate Disposition4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19081 19-081 81 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Ultimate Disposition 81. If a facility in one of the newly added industries, which begins reporting for activities conducted in 1998, has information on the amount of seepage from a landfill in 1998, do they report this amount as a release to land, since they were not required to report the initial disposal to land in the previous year?No. Facilities are required to report only the amounts that are disposed during the reporting year in which they are disposed, provided certain thresholds have been met and the facility does not conduct any further activities involving amounts previously disposed. Amounts that move within the same media, such as seepage from a landfill to surrounding soils, do not have to be included in release estimates in subsequent years. EPA requires reporting of the amount of toxic chemical placed in an on-site landfill during the year. EPA does not require the facility to estimate migration from the landfill in subsequent years, provided the facility does not conduct activities that further involve the listed toxic chemical disposed.</div></b><div style="visibility:hidden"></div></b>-
Disposal; Facility; Landfill; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19082 19-082 82 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Disposal (Dispose); Facility; Landfill; Waste 82. A facility disposes of an amount of waste in a surface impoundment in year 1 for which no report was required. In year 2, a report for the chemical is required and the chemical has migrated from the surface impoundment to ground water. Does the facility have to report the amount migrated in year 2?No, facilities are only required to report amounts released or otherwise managed in the year that the amounts were released or otherwise managed for chemicals for which they exceeded thresholds (40 CFR Section 372.85(b)(14)). If a facility exceeds thresholds in a subsequent year for a chemical that was disposed of in a preceding year, the facility should not report amounts previously released or otherwise managed. Facilities are also not required to estimate the migration of chemicals from landfills except for the current reporting year.</div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Ultimate Disposition4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19083 19-083 83 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Ultimate Disposition 83. In 1999, a facility disposes of a waste containing benzene in an on-site landfill, but does not exceed an activity threshold for benzene. The facility does not report the amount of benzene released to the landfill in 1999. In 2000, the facility exceeds a threshold for benzene. If some of the benzene released to land in 1999 seeps from the landfill to groundwater (i.e., migration of previously disposed materials), does the facility report the amount of benzene that seeped into groundwater during 1999?No. EPA requires reporting of the amount of a toxic chemical placed in an on-site landfill during the reporting year in which these amounts are disposed. Amounts disposed in previous years are not reportable in subsequent submissions provided no additional activity is performed with these amounts.</div></b><div style="visibility:hidden"></div></b>-
Disposal; Otherwise Use; Release Reporting; Underground Injection4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19214 19-214 214 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Disposal (Dispose); Otherwise Use; Release Reporting; Underground Injection 214. A covered toxic chemical manufacturer receives other facilities’ wastes containing listed toxic chemicals and disposes of them in their deep well. Does the receiving facility need to report these toxic chemicals?Starting with reporting year (RY) 1998, this is a reportable activity and the quantity disposed of would be applied to the otherwise use threshold. However, prior to RY 1998 the receiving and disposing of toxic chemicals would not be factored into a threshold determination because it does not fit any definition of process or otherwise use. However, even prior to RY 1998, if the manufacturing facility manufactures, processes, or otherwise uses the same listed toxic chemical above the threshold amount, the disposal of other facilities’ wastes containing this listed toxic chemical would be reported as a release on the Form R even though the amount of the listed toxic chemical in these wastes was not included in the threshold determination.</div></b><div style="visibility:hidden"></div></b>-
De minimis Exemption; Point Source Air Emissions; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19263 19-263 263 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical De minimis Exemption; Point Source Air Emissions; Releases (Released) 263. If a covered facility processes steel and releases chromium up the stack, do they have to report?Yes, if the chromium content in the steel exceeds de minimis concentration levels and the reporting threshold is met, the facility is required to report under EPCRA section 313 for chromium.</div></b><div style="visibility:hidden"></div></b>-
Nitrate Compounds; Otherwise Use; Release to Land; Releases; Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19274 19-274 274 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Nitrate Compounds (Nitrates); Otherwise Use; Release to Land (Land Release); Releases (Released); Treatment 274. Are toxic chemicals, such as nitrate compounds from waste treatment systems, that are used for farming at a facility to be reported as a release to land and is this an otherwise use activity?The use of listed toxic chemicals such as nitrate compounds for farming is to be reported as a release to land under EPCRA section 313. Listed toxic chemicals applied to land during use for farming constitute a release to an environmental medium (land) and are to be reported as such. This is consistent with the instructions for Section 5.5 of the Form R which state that land treatment/application farming is a disposal method that is considered a ‘release to land.’ Thus, whether or not this use is intended to be a disposal method, the total quantity released to land during use for farming should be reported as a release to land under Section 5.5.2 of the Form R. The amount of a listed toxic chemical used for farming at a covered facility must also to be applied towards the otherwise use reporting threshold.</div></b><div style="visibility:hidden"></div></b>-
Point Source Air Emissions; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19332 19-332 332 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Point Source Air Emissions; Releases (Released) 332. During the manufacture of phosphoric acid, traces of the listed toxic chemical are pumped along with solid material to gypsum stacks. The phosphoric acid percolates through the stack slowly and is recirculated back to the manufacturing process. Is the manufacturer required to report the presence of the chemical in the gypsum stacks as a release?EPA considers this to be a recirculation of the process water. The facility is not required to report the presence of the chemical in a process water recirculation system as a release (40 CFR Section 372.38(c)(5)). If process water containing the toxic chemical escapes the recirculation system and enters the environment, then it would be necessary to count those chemicals towards the activity thresholds and report such releases of the chemical.</div></b><div style="visibility:hidden"></div></b>-
Facility; Releases; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19374 19-374 374 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Facility; Releases (Released); Waste 374. A non-motorized barge is brought into dry dock for maintenance at a federal facility. While in dry dock, there are releases of a toxic chemical from the barge. Would the releases of this toxic chemical be reportable?Yes. Releases of toxic chemicals from the barge while in dry dock on facility grounds must be included in release and other waste management calculations if reporting thresholds for those toxic chemicals are exceeded by the facility.</div></b><div style="visibility:hidden"></div></b>Y
Release Reporting; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19393 19-393 393 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Releases (Released) 393. A covered facility sends a 55-gallon drum containing less than one inch of a listed toxic chemical off-site for disposal. For purposes of the RCRA hazardous waste regulations, the container is considered an empty container as defined in 40 CFR Section 261.7 (i.e., RCRA-empty). Must the facility report the listed toxic chemical contained in the RCRA-empty container as an off-site transfer for purposes of disposal on the Form R even though it is not considered to contain hazardous waste under RCRA?Yes. The definition of an empty container pursuant to 40 CFR Section 261.7 does not apply to EPCRA section 313. Even though the residue remaining in a container rendered RCRA-empty is no longer considered a hazardous waste under federal RCRA regulations, it is still considered a toxic chemical under EPCRA section 313. The status of a listed toxic chemical as a nonhazardous waste under RCRA has no impact on the applicability of EPCRA regulations on that chemical. Under EPCRA Section 329, the term release is defined as “any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles) of any toxic chemical.” In Part II, Section 8.1 of the Form R, EPA requires facilities to report all releases of listed toxic chemicals, except those quantities released to the environment as a result of remedial actions, catastrophic events, or one-time events not associated with production processes. Disposal of a RCRA-empty container which contains any amount of a listed toxic chemical is generally reportable in Section 8.1 when transferred from or disposed at an EPCRA section 313 covered facility. If, however, the facility has total reportable amounts of a non-PBT chemical not exceeding 500 pounds, it may be eligible for the higher alternate reporting threshold in 40 CFR Section 327.27.</div></b><div style="visibility:hidden"></div></b>-
Articles Exemption; Release Reporting; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19474 19-474 474 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Articles Exemption (Article Exemption); Release Reporting; Releases (Released) 474. A covered facility builds and repairs ships. During its welding operations, the facility uses a filler material to bind steel plates. This welding operation releases minor quantities of a toxic chemical. How are estimates of toxic chemical releases to be made?If releases of the toxic chemical from the steel plate processing are recycled or reused or if the total amount released is 0.5 pound or less for the reporting year, then the releases are exempt from reporting under the article exemption. If the article exemption does not apply, the covered facility must include releases from the welding operation if thresholds are exceeded. EPA has developed tables to be used in estimating releases of metal in fumes for various types of welding and one for cutting mild steel. These tables can be found in Clarification and Guidance for the Metal Fabrication Industry (1998 version).</div></b><div style="visibility:hidden"></div></b>-
Estimating Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19509 19-509 509 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Estimating Releases 509. How should a facility estimate sulfuric acid drifting (aerosol) out of a cooling tower? There is no accepted procedure/guidance for how to best estimate this sulfuric acid drift. Is this reportable?Amounts of sulfuric or hydrochloric acid aerosols that drift from process steps are considered a release and are reportable provided the facility has exceeded thresholds. Facilities must use their best readily available information in developing estimates. This information may come from a variety of sources, and to assist facilities in determining what is reportable for sulfuric acid aerosols, EPA has published a guidance document entitled, EPCRA section 313 Guidance for Reporting Sulfuric Acid (EPA-745-R-97-007; November 1997). Facilities may also find equipment operating specification information useful in developing threshold determinations and release and other waste management calculations.</div></b><div style="visibility:hidden"></div></b>-
Reasonable Estimates4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19566 19-566 566 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Reasonable Estimates 566. Ozone is manufactured as a result of the generation and transmission of electric power. Must the electricity generating facility report the amount of ozone manufactured?Yes. Amounts of ozone (a toxic chemical) manufactured at a covered facility must be considered toward the facility's manufacturing threshold for ozone. If the facility knows that ozone is being manufactured, then the facility must use its best readily available information to provide reasonable estimates in making threshold and release and other waste management calculations. </div></b><div style="visibility:hidden"></div></b>-
Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19567 19-567 567 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Releases (Released) 567. What is the definition of a toxic chemical 'release' under EPCRA section 313?Under Section 329, EPCRA defines a release as any 'spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment (including the abandonment or discarding of barrels, containers, and other closed receptacles).' Under Section 313, covered facilities are required to take into account in their reports all toxic chemicals entering each environmental medium (e.g., 'routine' and 'accidental' releases).</div></b><div style="visibility:hidden"></div></b>-
Accidental Releases; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19568 19-568 568 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Accidental Releases; Releases (Released) 568. What is the difference between a release under EPCRA Section 304 and a release under EPCRA section 313? Would accidental releases reported under Section 304 have to be included in the Section 313 report?Section 304 releases are accidental releases of extremely hazardous substances, requiring an emergency notification. Reporting under Section 313 includes the total amount of the toxic chemicals, both routine, operational and accidental releases. Thus, Section 304 releases of listed Section 313 toxic chemicals must be factored into releases reported under Section 313.</div></b><div style="visibility:hidden"></div></b>-
Monitoring; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19569 19-569 569 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Monitoring; Releases (Released) 569. Is it true that covered facilities need not make any special effort to measure or monitor releases for Section 313 reporting and may use information that is on hand?Yes, EPCRA section 313 states that covered facilities need not conduct monitoring or other activities beyond that required by other statutory or regulatory requirements (EPCRA section 313(g)(2)). Congress included this language to limit the burden on the affected industry for development of release and other required data. Without measurement or monitoring data, the facility is required to make reasonable estimates using its best readily available data.</div></b><div style="visibility:hidden"></div></b>-
Reasonable Estimates; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19570 19-570 570 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Reasonable Estimates; Releases (Released) 570. Section 313(g)(2) of EPCRA states that the owner or operator of a facility may use readily available data. In some cases, the available data may be known to be non-representative and reasonable estimates offer more accurate release information. Would EPA, in this instance, favor use of the estimates rather than data?Yes, it is preferable to use reasonable estimates using the best readily available information if available data (including monitoring data) is known to be non-representative. </div></b><div style="visibility:hidden"></div></b>-
Readily Available; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19571 19-571 571 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Readily Available; Releases (Released) 571. Section 313(g)(2) of EPCRA states that the owner or operator of a facility may use readily available data for reporting releases of toxic chemicals. If a federal facility has monitoring or emissions data for an EPCRA section 313 chemical that they do not believe are representative, should they still use that data to complete the release calculations on the Form R report?No. If a federal facility has monitoring or emissions data that are not considered “representative,” the data need not be used. In such cases, a more accurate estimate based on mass balance calculations, published emissions factors, engineering calculations, or best engineering judgement should be used. In such instances, a federal facility should document why the available monitoring data were believed to be unrepresentative.</div></b><div style="visibility:hidden"></div></b>Y
Readily Available; Reasonable Estimates4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19572 19-572 572 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Readily Available; Reasonable Estimates 572. If a covered facility has analytical data that will take extensive time and money to calculate emissions, can that facility use the maximum emissions level specified in their permit to calculate their emissions?EPCRA allows facilities to use its best readily available data to provide information required under Section 313. When data are not readily available, EPCRA allows facilities to use 'reasonable estimates' of the amounts involved. An owner/operator facility must use his/her best judgment to determine whether analytical data are readily available. If they are not, the facility's use of maximum emissions levels, as specified in its permits, may be a reasonable basis from which to form its estimates. In any event, the owner/operator should carefully document the reason for its decision making.</div></b><div style="visibility:hidden"></div></b>-
Detection Limit; Reasonable Estimates4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19573 19-573 573 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Detection Limit; Reasonable Estimates 573. If a covered facility has analytical data indicating the concentration of a Section 313 chemical is below the limits of detection and the facility has no information on the probability of the chemical being present in that waste stream (e.g., Superfund waste), should the facility use half the detection limit? What documentation will EPA require if the facility asserts that it had no basis for expecting the Section 313 chemical to be present?If the facility has no information to indicate that the chemical exists in the waste stream, it may assume that the concentration is zero. If the facility has reason to believe that the listed toxic chemical is present, it may use half of the detection limit. The facility should document that it looked at all readily available data in making this determination.</div></b><div style="visibility:hidden"></div></b>-
Basis of Estimate; Concentration; Reasonable Estimates4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19574 19-574 574 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Basis of Estimate; Concentration; Reasonable Estimates 574. Is it appropriate for a covered TSD facility to develop an average concentration for a Section 313 chemical contained in thousands of different waste streams managed by the facility, and then use that average as a basis for threshold determinations? If so, does EPA have a recommended approach for developing such an average?EPCRA allows covered facilities to use the best readily available data to provide information required under EPCRA section 313. When data are not readily available, EPCRA allows facilities to use reasonable estimates of the amounts involved. A facility must use its best judgment to determine whether data are readily available. Thus, with regard to use of average concentration levels, a facility must use its best judgment to decide whether the raw data from which it might base any average concentration level are readily available. In any event, a facility should carefully document its decision making. For example, if a facility decides to use average concentration levels, it should document why the raw data from which the averages are based are not readily available, how it arrived at any average concentration level used, and why the average concentration level is a reasonable estimate of the amount of the toxic chemical in the waste stream. EPA does not have a recommended approach for determining average concentration levels.</div></b><div style="visibility:hidden"></div></b>-
Chromium; Reasonable Estimates4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19575 19-575 575 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Chromium (Chromium Compounds); Reasonable Estimates 575. A covered treatment, storage, and disposal (TSD) facility receives a waste from off-site that contains chromium. The waste profile indicates only that the waste stream contains chromium. The waste profile does not indicate if the waste contains elemental chromium or a chromium compound. Can the TSD make threshold determinations based on the assumption that the chromium contained in the waste stream is present as elemental chromium?A facility must use the best readily available information to determine which listed chemicals or compounds are being manufactured, processed or otherwise used. If the waste profile is incomplete or inaccurate, the facility should look to other sources of information that it believes are more representative of the needed information. Facilities should document assumptions and calculations used in making their determinations.</div></b><div style="visibility:hidden"></div></b>-
Best Available Information; Emissions Factors; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19576 19-576 576 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Best Available Information; Emissions Factors; Releases (Released) 576. A paint manufacturer needs to estimate emissions of Section 313 chemicals. How can the owner or operator estimate solvent emissions from open or partially open mixing tanks, and speciate total solvent emissions data into specific compound emissions?Facilities should use the best readily available information. Emissions Factors are available in Compilation of Air Pollutant Emissions Factors (AP-42) for estimating total VOC emissions from paint manufacturing.</div></b><div style="visibility:hidden"></div></b>-
Emissions Factors4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19577 19-577 577 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Emissions Factors 577. Many pulp and paper mills burn wood for on-site electricity and may trigger manufacturing thresholds when one naturally occurring compound changes to another (e.g., copper or manganese compounds change to copper or manganese oxides). Does EPA publish emissions factors for metals manufactured from the burning of trees?Emissions Factors provided in Section 1.6 - Wood Waste Combustion in Boilers of EPA’s document AP-42, Compilation of Air Pollutant Emissions Factors can be used to calculate emissions for metal manufactured from the burning of trees. However, if a facility has better readily available information that would enable the facility to more accurately calculate the emissions generated, the facility should use that information.</div></b><div style="visibility:hidden"></div></b>-
Detection Limit; Monitoring; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19578 19-578 578 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Detection Limit; Monitoring; Releases (Released) 578. If a facility monitors for a toxic chemical and the measurement is below the limit of detection of the method, can they report zero releases?The facility must use reasonable judgment as to the presence and amount of the listed toxic chemical based on the best readily available information. An indication that a reportable chemical is below detection is not equivalent to stating that the chemical is not present. If the reportable Section 313 chemical is known to be present, a concentration equivalent to half the detection limit should be used. The facility should not estimate releases based solely on monitoring devices, but the facility should also rely on its knowledge of specific conditions at the plant. </div></b><div style="visibility:hidden"></div></b>-
Best Available Information; Releases; Reporting Deadline4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19579 19-579 579 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Best Available Information; Releases (Released); Reporting Deadline 579. Form R requires estimates of the release to the environment of listed toxic chemicals in specific release categories. If a facility is unable to complete its estimate of these releases by the deadline, should the company leave that entry blank and promise a future estimate, or make the best estimate possible and submit later revisions?Any covered facility must report by July 1 for the previous reporting year, and the data provided should be the best estimate using the best readily available data. Records supporting the data must be kept for three years. If more accurate data are developed, the facility may submit revised forms. EPA can take enforcement action if they believe that the data do not represent reasonable estimates. </div></b><div style="visibility:hidden"></div></b>-
Disposal; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19583 19-583 583 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Disposal (Dispose); Releases (Released) 583. Is the disposal of toxic chemicals in wastes in the form of dusts, shavings, or turnings that result from grinding or drilling of metal items considered a 'release of a toxic chemical?'Yes, disposal of dusts, shavings, or turnings containing Section 313 toxic chemicals is considered a release (40 CFR Section 372.3).</div></b><div style="visibility:hidden"></div></b>-
Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19584 19-584 584 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Releases (Released) 584. Tank trucks and rail cars physically enter a facility. While loading for transport, toxic chemical emissions occur. Are these emissions subject to reporting under Section 313?Yes. As long as the toxic chemicals are not under active shipping papers and the loading and the releases occur within the facility boundary, the releases must be reported if the facility meets the toxic chemical activity, employee, and NAICS code criteria.</div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Releases; Transportation Exemption4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19585 19-585 585 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Releases (Released); Transportation Exemption 585. A covered facility receives a shipment of gasoline from a tank truck. The loading dock is located within the facility boundaries. The tank truck delivers gasoline through a hose into the tank operated by the facility. While stationed at the dock, the valve of the tank truck ruptures and the gasoline leaks from the hose of the tank truck. This release occurs before the shipping papers are signed off by the facility operator. Gasoline contains listed Section 313 toxic chemicals such as benzene. If an activity threshold for benzene is met, would the facility be required to report this quantity of benzene released on the Form R?No. In the above case, the chemicals in the tank truck are considered under active shipping until the shipping papers are signed at the loading dock. Section 327 of EPCRA states that '(e)xcept as provided in Section 304, this title does not apply to the transportation, including the storage incident to such transportation, of any substance or toxic chemical subject to the requirements of this title, including the transportation and distribution of natural gas.' In the above scenario, the material in the tank truck is considered to fall under the transportation exemption, and releases from this truck would be exempt from reporting under Section 313. This release, however, would be reportable under Section 304 of EPCRA, if the quantity of any extremely hazardous substance (EHS) or CERCLA hazardous substance released exceeds the reportable quantity (RQ) within a period of 24 hours. EPA would encourage the facility to include the amount in its Form R in order to provide the public with the full picture of benzene releases that occurred at the facility for that reporting year. </div></b><div style="visibility:hidden"></div></b>-
Fugitive Air Emissions; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19587 19-587 587 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Fugitive Air Emissions; Releases (Released) 587. Are releases from lab hoods considered fugitive air emissions?The releases from lab hoods are point source air emissions. Therefore, the releases are reportable and should be accounted for in Part II, Section 5.2 of the Form R, if the facility exceeds an appropriate threshold. (See also Section 2D on the Laboratory Exemption.) </div></b><div style="visibility:hidden"></div></b>-
Landfill; Migration; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19589 19-589 589 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Landfill; Migration (Migrated); Releases (Released) 589. Do we need to report leaking, abandoned landfills? What if we don't know if it is leaking?Leaks from landfills need not be reported. EPA requires reporting of the amount of a toxic chemical placed in an on-site landfill during the year. The facility is not required to estimate migration from the landfill for years other than the reporting year. </div></b><div style="visibility:hidden"></div></b>-
Groundwater; Migration; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19590 19-590 590 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Groundwater; Migration (Migrated); Releases (Released) 590. Are groundwater releases required to be reported? If so, what if a facility has a surface impoundment which it suspects is leaking? How is the amount being released calculated?Releases to underground injection wells, surface impoundments, or landfills should be reported. Estimates of amounts leaking from such disposal and possibly reaching groundwater should not be reported. EPA may model the potential for such leaks or migration, but does not require facilities to estimate such further migrations. </div></b><div style="visibility:hidden"></div></b>-
Threshold Determination4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19591 19-591 591 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Threshold Determination (Activity Threshold) 591. A mining facility stores coal or ore outside. One or more listed toxic chemicals are contained within the storage piles. Due to exposure and weathering influences, other listed toxic chemicals are manufactured in the storage piles and may subsequently run-off onto land or surface water. How should the facility consider the manufacturing of listed toxic chemicals within a storage pile?Amounts of listed toxic chemicals known to be manufactured on-site from the storage of raw materials, mixtures, or trade name products must be considered toward the manufacturing threshold for those chemicals. The term manufacture means 'to produce, prepare, import, or compound a toxic chemical.' If the mining facility has knowledge that a listed toxic chemical is manufactured on-site, the facility should count the amount of the listed toxic chemical manufactured toward the manufacturing threshold. </div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Storage4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19592 19-592 592 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Storage 592. A mining facility leaches metals from an outdoor ore pile and collects the leachate for further processing. Should the toxic chemicals in the pile be reported as a release to land on the Form R?During the leaching, the ore pile is considered part of the facility’s process, and toxic chemicals in the pile should not be reported as a release to land. Once the leaching process is complete, and the ore pile is 'closed,' the facility will report the toxic chemicals remaining in the pile as a release to land in Part II, Section 5.5.4 (Other Disposal) of the Form R. However, amounts of listed toxic chemicals that escape the pile during the facility’s leaching process and are either released to land or surface water, for example, must be considered toward release calculations if a threshold has been exceeded. </div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Releases; Storage4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19593 19-593 593 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Releases (Released); Storage 593. A manufacturing facility that produces electricity by burning coal stores the coal in an on-site stockpile that is exposed to the outside atmosphere. The facility meets the threshold criteria (40 CFR Section 372.22) for filing a Form R for the toxic chemical benzene. Since the stockpiled coal contains benzene and is exposed to the outside atmosphere, would all the benzene in the coal need to be reported on the Form R as a release to land on-site?No. A facility does not have to report toxic chemicals contained in an on-site stockpile of material that is intended for otherwise use on-site as a release to land on-site. However, any toxic chemical that escaped to air or remains in the soil from the stockpile material (e.g., evaporative losses to air, material leached to the ground, etc.) must be reported as released to the environment on-site. Once a covered facility meets the criteria for filing a Form R under EPCRA section 313 for a toxic chemical (such as benzene), all releases of that chemical at the facility are to be reported. Releases of non-PBT chemicals from the stock pile will be eligible for the de minimis exemption.</div></b><div style="visibility:hidden"></div></b>-
Disposal; Recycling; Releases; Ultimate Disposition4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19596 19-596 596 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Disposal (Dispose); Recycling (Recycle); Releases (Released); Ultimate Disposition 596. A covered facility discharges waste containing listed Section 313 metals to an on-site cooling pond. The metals accumulate and settle over time, and the water is then drained from the cooling pond, leaving the heavy metal sludge. The sludge is then dredged and sent off-site to a recycler. How should the toxic chemicals left in the pond, after the sludge has been removed for recycling, be reported?A facility must report the ultimate disposition of listed toxic chemicals from the facility during the reporting year. Listed toxic chemicals remaining in the sediments after the sludge is sent off-site to a recycler are 'released to land.' Listed toxic chemicals sent to a receiving stream when the wastewater is drained are 'released to water.' </div></b><div style="visibility:hidden"></div></b>-
Definition of Facility; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19599 19-599 599 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Definition of Facility; Releases (Released) 599. A covered facility is adjacent to a lagoon which the facility does not own but to which it pays to discharge wastes. The facility, however, is in effect the operator of the lagoon. In one year, the facility released a listed mineral acid into the lagoon as an attempted pH control. Must the facility report for the release of the listed mineral acid, even though the process was a one-time treatment method that will not be repeated?Yes, the facility must report the release of the listed acid if it meets the threshold criteria for reporting. The facility was acting as operator of the waste treatment site and must report listed chemicals otherwise used in excess of the threshold. Because the facility operates the lagoon and it is adjacent to the rest of the site, the lagoon is part of the facility (40 CFR Section 372.3).</div></b><div style="visibility:hidden"></div></b>-
Chemical Conversion; Chlorine; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19600 19-600 600 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Chemical Conversion (Activity Threshold); Chlorine; Releases (Released) 600. How are chlorine releases reported? Must chlorine, CAS number 7782-50-5, be reported if it is transformed into another chemical compound during the release process?If chlorine is present in waste released by a facility it must be reported even though the chlorine may be transformed in the environment subsequent to the release. If the chlorine is transformed in the waste stream prior to any releases, the facility must still report if an activity threshold is met, but the amount reported may be zero.</div></b><div style="visibility:hidden"></div></b>-
Chlorine; Estimating Releases; Releases; Waste Treatment; Water Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19601 19-601 601 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Chlorine; Estimating Releases; Releases (Released); Waste Treatment; Water Treatment 601. How can one estimate emissions of chlorine from use in cooling water treatment? We have tried to estimate the emissions for some cooling water systems based on the amount of water evaporation, wind drift and the amount of chlorine used, but the releases seem too high.Estimating emissions based on the amount used overestimates releases since chlorine is only slightly soluble in water, it reacts with chemicals in the water and it dissipates in side reactions. Multiplying measured residual chlorine by recirculation rate by lost water fraction may also overestimate releases (residual includes other forms of chlorine), but may be the only way to make a reasonable estimate. Please refer to EPA’s EPCRA section 313 Reporting Guidance for Food Processors (EPA 745-R-98-011; August 1998).</div></b><div style="visibility:hidden"></div></b>-
Acids; Chemical Conversion; Release Reporting; Release to Land; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19602 19-602 602 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Acids (Acid Aerosol); Chemical Conversion (Activity Threshold); Release Reporting; Release to Land (Land Release); Releases (Released) 602. A facility mines magnesium-rich brine from an on-site well. After extracting the magnesium, it disposes of the brine in on-site disposal wells. In order to keep the disposal well formation clean and usable, the facility pumps 280,000 pounds of a reportable mineral acid into the wells. The facility considers this an otherwise use of the acid. Since the acid would be neutralized before it migrates off-site, is it also a release to land?Yes. The facility must consider their use of a reportable acid as an on-site release to land even though subsequent to the release the acid may be neutralized in the process of cleaning the well. EPA does not allow facilities to reduce the quantity reported as released to the environment based on conversions of a chemical in the environment after the chemical has been released by the facility. </div></b><div style="visibility:hidden"></div></b>-
Fugitive Air Emissions; Point Source Air Emissions; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19603 19-603 603 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Fugitive Air Emissions; Point Source Air Emissions; Releases (Released) 603. Our facility paints metal cabinets and the paint solvents contain a listed toxic chemical. The system consists of a closed, vacuum vented painting room and a closed oven room vented by an oven stack. Are releases from the vent to the outside of the building over the painting room considered 'releases from building ventilation systems' and therefore reported as fugitive emissions?No, fugitive releases are emissions that are not in a confined directional air flow. Since your building vent system over the painting room is a confined air stream, it can be combined with the oven stack as a stack or point emissions in Part II Section 5.2 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19604 19-604 604 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Release Reporting; Releases (Released) 604. Where does one report routine leaks from pipes? Would these be reported as disposed to land?Reporting leaks from pipes requires determining where the released toxic chemical goes. For example, a toxic chemical that evaporates would be reported as a fugitive air emissions in Part II, Section 5.1 of the Form R. A nonvolatile material leaking into land, or any material leaking from an underground pipe, would be reported as a release to land and entered in Part II, Section 5.5.4 'Other Disposal.' In either case, the toxic chemical would also be reported in Section 8.1.</div></b><div style="visibility:hidden"></div></b>-
Releases; Treatment Efficiency4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19605 19-605 605 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Releases (Released); Treatment Efficiency 605. In calculating releases from incinerators, boilers, industrial furnaces and like units, is it sufficient to base the amount released on the efficiency of the unit?Release calculations based solely on the efficiency of the unit may not be sufficient. Facilities must use the best readily available information. For example, the 99.99 percent efficiency of an incinerator may not refer to the destruction and removal of the chemical being reported on the Form R. If that is the case, the efficiency may have no relation to the release quantity of the chemical being reported. Even if the surrogate waste is the chemical being reported, the 99.99 percent efficiency may not only include the quantity of the chemical destroyed by combustion, but may also include the quantity of the chemical that is physically removed. The quantity of the chemical removed can include undestroyed chemical in the ash, and undestroyed chemical discharged from air pollution control devices like scrubbers, precipitators, baghouses, etc. Furthermore, releases of the chemical due to faulty equipment upstream from the feeding point of the combustion device can also be counted as quantity removed and included in the 99.99 percent efficiency calculation. As a result, release calculations based solely on the efficiency of the unit might count the chemical removed as destroyed. This will result in under-reporting of the quantity of the chemical released to the environment. The facility should also examine its operating records to account for chemical releases during upset conditions such as those released from an emergency dump stack. </div></b><div style="visibility:hidden"></div></b>-
Metals; Releases; Treatment Efficiency; Treatment for Destruction4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19606 19-606 606 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Metals; Releases (Released); Treatment Efficiency; Treatment for Destruction (Incineration) 606. Why does EPA not allow covered facilities to use the efficiency of a combustion unit (e.g., incinerator, industrial furnace or boiler) to calculate releases of metals from the unit?Metals cannot be destroyed by combustion. Therefore, the efficiency of a combustion unit has no relation to the releases of metals from the unit. </div></b><div style="visibility:hidden"></div></b>-
Asbestos; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19607 19-607 607 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Asbestos; Releases (Released) 607. A covered manufacturing facility uses more than 10,000 pounds of friable asbestos in a diaphragm cell process during the course of a reporting year. During the process, material containing friable asbestos is washed in a treatment unit where it coagulates and is removed by a pressure filter. The filter cake containing asbestos is wetted with ethylene glycol, and the resulting filter cake/ethylene glycol mixture is subsequently landfilled on-site in a closed container. Should the facility report the placement of this asbestos in a landfill as a 'release to land' on the Form R?EPA interprets 'friable' under EPCRA section 313 '...as being crumbled, pulverized, or reducible to a powder with hand pressure' (53 FR 4519; February 16, 1988). Facilities are required to report releases or other waste management of only the friable form of asbestos. The facility will report zero releases of friable asbestos to land because the ethylene glycol/asbestos mixture is not considered to contain friable asbestos since the asbestos contained therein is wet (i.e., with ethylene glycol). The facility would report the amount of friable asbestos that is treated in Part II, Section 8.6. Note that because ethylene glycol is also a listed toxic chemical, the facility would also need to consider this chemical for threshold determinations and release and other waste management calculations.</div></b><div style="visibility:hidden"></div></b>-
Byproduct; Chemical Conversion; Release Reporting; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19608 19-608 608 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Byproduct (Coincidental Manufacturing); Chemical Conversion (Activity Threshold); Release Reporting; Releases (Released) 608. Do the Section 313 reporting requirements overlook the possibility that a substance can lose its chemical identity as a byproduct in a reaction, and that the difference between “input and output” volumes may not always be due to a release?EPA does recognize that a toxic chemical can lose its chemical identity in a reaction by being converted into a new chemical. The facility must still account for the amount they either manufacture or process regardless of whether the listed toxic chemical is converted to another toxic chemical in the process. Releases and other waste management estimates must then be calculated for any part of the process involving the Section 313 listed toxic chemical. In addition, if the byproduct created is a listed toxic chemical, the facility must consider it toward the manufacturing threshold. </div></b><div style="visibility:hidden"></div></b>-
Basis of Estimate; Emissions Factors; Releases; Waste; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19609 19-609 609 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Basis of Estimate; Emissions Factors; Releases (Released); Waste; Waste Management Activities 609. For TRI reporting, EPA has identified four basic methods that a facility may use to develop the estimates for releases and other waste management activities: monitoring data, mass balance calculations, emissions factors, and other approaches such as engineering calculations. The best method for calculating the quantities of each release and other waste management activity will depend on the facility's site-specific knowledge and available data sources. What potential data sources are available for each basis of estimate type?Potential monitoring data sources can include stack monitoring data, outfall monitoring data, air permits, industrial hygiene monitoring data, National Pollution Discharge Elimination System (NPDES) permits, publicly owned treatment works (POTW) pretreatment standards, effluent limitations, Resource Conservation and Recovery Act (RCRA) permit data, hazardous waste analysis, pH for acids, and continuous emissions monitoring. The basis of estimate code used in Section 5 or 6 of the TRI Form R for monitoring data is either M1 or M2, depending on whether the estimate was based on continuous monitoring data (M1) or periodic or random data or measurements (M2). Potential data sources for mass balance calculations can include supply records, a hazardous material inventory, an air emissions inventory, pollution prevention reports, hazardous waste manifests, and spill event records. The applicable basis of estimate code for mass balance calculations is C. Potential emissions factors can include AP-42 emissions factors, other EPA emissions factors, published facility or trade association chemical-specific emissions factors, site-specific emissions factors relating release quantity to through-put or equipment type (e.g., air emissions factors), or other site-specific emissions factors developed specifically for a situation or process on-site that takes into account the actual field conditions at the location. The applicable basis of estimate code is either E1 or E2, depending on whether the estimate was based on published emissions factors (E1) or site-specific emissions factors (E2). Other potential data sources can include engineering calculations, best engineering judgment, volatilization rates, Raoult's Law, Henry's Law, and solubilities. The applicable basis of estimate code for these types of other approaches is O. The potential sources and factors provided above are only examples. A facility can use any source of information so long as the source is consistent with EPCRA section 313(g)(2): the owner or operator of a facility may use readily available data (including monitoring data) collected pursuant to other provisions of law, or, where such data are not readily available, reasonable estimates of the amounts involved. For more details on release estimate calculations, refer to the TRI Reporting Forms and Instructions (Appendix B).</div></b><div style="visibility:hidden"></div></b>-
Basis of Estimate; Emissions Factors; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19610 19-610 610 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Basis of Estimate; Emissions Factors; Releases (Released) 610. If a company measures its own leaks (valve, flange, pump, etc.) and determines a new fugitive factor, is the code 'E' or 'M' or 'O'?The company should use the code M if it measured releases of the toxic chemical from its equipment at the facility to determine its release amount. 'E' is used only for published emissions factors which are chemical specific. However, in this case, the company would use 'O' which is used if it measured leaks generally or applied non-published factors developed at other facilities.</div></b><div style="visibility:hidden"></div></b>-
Basis of Estimate; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19611 19-611 611 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Basis of Estimate; Releases (Released) 611. If total releases are obtained using a combination of estimating techniques, how do we report 'Basis of Estimate' in Section 5, Column B?Report the basis of estimate code associated with the technique used to calculate the major portion of each release entry. See examples in the current Form R instructions. </div></b><div style="visibility:hidden"></div></b>-
Emissions Factors; Releases4. Completing the Form R: Releases and Waste Management Calculations >
4.A. Releases of the Toxic Chemical
<div style="visibility:hidden">19612 19-612 612 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.A. Releases of the Toxic Chemical Emissions Factors; Releases (Released) 612. Are SOCMI (Synthetic Organic Chemicals Manufacturing Industry) emissions factors applicable to the petroleum refining industry as well as to organic chemical manufacturers?Yes, SOCMI fugitive emissions factors can be used for the petroleum refining industry even though they are based upon synthetic organic chemicals manufacturing. The refinery user would have to correct for differences in concentrations of the mixtures, because SOCMI factors are based upon pure substances being released.</div></b><div style="visibility:hidden"></div></b>-
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