Questions and Answers

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  • 1 - 26 of 26
Questions and AnswersKeyword(s)Category(hidden - contains search text)(hidden - contains search text)FedFac
Reporting Criteria; Threshold Determination4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19104 19-104 104 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Reporting Criteria; Threshold Determination (Activity Threshold) 104. Who is responsible for EPCRA section 313 reporting if a covered solvent recovery service arrives at a covered facility and either recycles ethylene glycol antifreeze on-site with a mobile recovery unit or removes the ethylene glycol antifreeze for off-site recycling?All covered facilities are responsible for EPCRA section 313 reporting obligations of the toxic chemical while the toxic chemical is at a facility, including while the chemical is in an on-site mobile recovery unit. Although this facility may not directly operate the mobile solvent recovery unit, the facility controls the unit’s operations while on-site because it has contracted or paid a fee for the unit’s services. Therefore, if the mobile unit recovers toxic chemicals from the solvents on-site the facility would include those toxic chemicals in its facility-wide release and other waste management calculations. If the mobile solvent recovery unit removes toxic chemicals from the facility for off-site recycling, the facility would report the amount of the chemicals sent off-site as an off-site transfer for recycling. However, the facility must account for any releases of the toxic chemical from the unit while it remains on-site. Finally, those toxic chemicals that are transferred off-site are considered processed and therefore, must be applied toward the facility’s processing threshold.</div></b><div style="visibility:hidden"></div></b>-
Disposal; Manufacture; Metals; Otherwise Use; Treatment for Destruction; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19208 19-208 208 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Disposal (Dispose); Manufacture (Manufactured; Manufacturing; Produce; Produced); Metals; Otherwise Use; Treatment for Destruction (Incineration); Waste 208. A DOD facility receives old munitions, which contain EPCRA section 313 chemicals, from other DOD facilities for destruction (treatment). The method of destruction (treatment) is open burning. How should the DOD facility report for this activity?The receiving DOD facility would have to count the amount of EPCRA section 313 chemicals in the munitions toward its otherwise use threshold. The definition of “otherwise use” includes the disposal, stabilization and treatment of an EPCRA section 313 chemical received from off-site for the purposes of further waste management. For those EPCRA section 313 chemicals meeting the otherwise use threshold, and which are not destroyed during the treatment process, the facility would have to make release and other waste management calculations. As an example, metals are not destroyed during treatment activities; and the facility would have to make release and other waste management calculations for the metals, provided they meet the reporting threshold. Starting January 1, 1998, facilities must count the amount of an EPCRA section 313 chemical manufactured during the destruction of waste received from off-site toward its 10,000-pound otherwise use threshold if the facility subsequently stabilizes or disposes the EPCRA section 313 chemical on-site. The receiving DOD facility should determine the amount of EPCRA section 313 chemicals “manufactured” as a result of the destruction process. In addition, the facility must count the amount of a manufactured EPCRA section 313 chemical toward the facility’s 25,000-pound manufacturing threshold for that chemical.</div></b><div style="visibility:hidden"></div></b>Y
Activity Threshold; Energy Recovery4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19232 19-232 232 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Activity Threshold (Threshold Determination); Energy Recovery 232. A treatment, storage, and disposal (TSD) facility receives waste from off-site containing a listed toxic chemical, blends the waste with a fuel to increase its heat value, repackages the blended fuel in different container(s), and then transfers the waste off-site to a cement kiln that burns the waste. Is this facility manufacturing, processing, or otherwise using the toxic chemical contained in this waste received from off-site for the purposes of further waste management?No. The repackaging and subsequent transfer off-site of EPCRA section 313 toxic chemicals in waste fuel for burning for energy recovery is not, in itself, a covered manufacturing, processing, or otherwise use threshold activity as those terms are defined in the EPCRA section 313 regulations (40 CFR Part 372). Therefore, covered facilities are not required to consider the repackaging and subsequent transfer off-site of toxic chemicals for energy recovery to any type of boiler or industrial furnace (as defined in 40 CFR Section 372.3) toward threshold calculations. Similarly, toxic chemicals in waste that are repackaged and sent off-site for disposal or for treatment for destruction would likewise not be considered toward a facility’s manufacturing, processing, or otherwise use threshold determination. Covered facilities should keep in mind, however, that if they exceed an activity threshold elsewhere at the facility for the listed chemical contained in the waste fuel, the facility should report the quantity of the toxic chemical in the waste fuel sent off-site for energy recovery in Part II, Section 6.2 and Section 8 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Metals; Recycling; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19597 19-597 597 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Metals; Recycling (Recycle); Waste 597. During the reporting year, a federal facility discharges waste containing listed EPCRA section 313 metals to an on-site cooling pond. The metals accumulate and settle, and the water is then drained from the cooling pond, leaving a heavy metal sludge. The sludge is then dredged and sent off-site to a recycler. How should the EPCRA section 313 chemicals left in the pond, after the sludge has been removed for recycling, be reported?Listed EPCRA section 313 chemicals remaining in the pond after the sludge has been removed should be reported as “released to land.” Listed EPCRA section 313 chemicals left in the pond water, which have been drained off, should be reported according to their disposition: either discharged to a stream (back into the cooling pond), discharged to a POTW, transferred to other off-site locations, treated on-site, or recycled on-site. </div></b><div style="visibility:hidden"></div></b>Y
Form R; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19632 19-632 632 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Form R; Waste 632. Many federal facilities send their hazardous waste containing EPCRA section 313 chemicals to off-site TSD facilities. If a federal facility is reporting these toxic chemicals on a Form R report, what is the facility’s obligation to ascertain the final, known disposition of the EPCRA section 313 chemical for purposes of choosing a waste management code in Part II, section 6.2.C.?The federal facility is required to use the best data available at the facility to identify the final, known disposition of an EPCRA section 313 chemical that it is reporting on a Form R report for the purpose of entering a waste management code in Part II, section 6.2.C of the Form R. While obtaining additional information from the off-site location concerning the fate of the particular EPCRA section 313 chemical is not required, it is certainly an option for facilities who lack a complete understanding of the final disposition of an EPCRA section 313 chemical in a waste sent off-site.</div></b><div style="visibility:hidden"></div></b>Y
Form R; POTW4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19633 19-633 633 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Form R; POTW 633. Section 6.1 of the Form R requires covered facilities to indicate how much of a TRI chemical was transferred off-site to publicly-owned treatment works (POTWs) during a given reporting year. Section 8 of the Form R requires facilities to use their best readily available information to determine the final disposition of the toxic chemical initially sent to the POTW and then distribute the amount reported in Section 6.1 among Sections 8.1c, 8.1d, and 8.7, as appropriate. Beginning with Reporting Year 2013, TRI-MEweb uses chemical-specific default POTW rates to distribute the amounts in Section 8. Are facilities required to use the default values?EPCRA requires facilities to submit the most accurate readily available information. If facilities do not have information on the removal and destruction rates for a chemical transferred to a particular POTW, then they may use the chemical-specific default POTW rates provided in TRI-MEweb. TRI-MEweb has assumed the chemicals ultimate disposition using experimental and estimated data on removal and destruction rates at POTWs compiled by EPAs Risk-Screen Environmental Indicators (RSEI). The percentages that EPA provides are automatically pre-loaded in TRI-MEweb and are applied to quantities provided in Section 6.1 to assist with Section 8 calculations and as guidance for users who do not know the ultimate disposition of their off-site transfers to POTWs. If the facility has more accurate information readily available on the final disposition of the subject chemical, users should edit the default values and use the more accurate information in place of the default percentages. </div></b><div style="visibility:hidden"></div></b>-
Acids; Neutralization; pH4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19646 19-646 646 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Acids (Acid Aerosol); Neutralization; pH 646. A covered facility generates a waste stream in the form of a filter press cake that contains nitric acid, a toxic chemical. Before the filter cake is sent to an off-site landfill for disposal, the nitric acid in the filter cake is neutralized to pH 7. How should the facility report the disposal of this nitric acid on its Form R?Because the nitric acid is neutralized to a pH 6 or above during on-site treatment, no nitric acid is present in the filter cake sent off-site for disposal. Therefore, the off-site transfer would not be reported in the Form R for nitric acid. The on-site waste treatment of the nitric acid must be reported in Part II, Section 7A (On-Site Waste Treatment Methods and Efficiency) and in Section 8.6 (Quantity Treated On-Site). In addition, the facility must determine if the neutralization of the nitric acid in the filter cake results in the manufacture of a water dissociable nitrate compound category in an aqueous solution, which is a listed category under EPCRA section 313.</div></b><div style="visibility:hidden"></div></b>-
Recycling4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19670 19-670 670 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Recycling (Recycle) 670. How should a covered facility report a transfer in which it sends wastes containing a toxic chemical off-site to a waste broker who in turn sends the wastes to a recycling facility?Covered facilities are required to report information on off-site transfers for purposes of recycling in both Sections 6 and 8 of the Form R. In Section 6, the facility should report the final disposition of which it has knowledge of the toxic chemical in the waste. When a facility knows that a toxic chemical in wastes sent to a broker is ultimately being recycled, but does not know the location of the recycler, the waste broker is considered the final destination, and the transfer should be reported as M93 (transfer to waste broker-recycling) along with the location of the waste broker. If the location of the recycler to whom the broker sends wastes containing the toxic chemical is known, the recycler is considered the final destination, and the transfer should be reported as recycling with the appropriate code. The location of the recycler, not the waste broker, should be reported. The facility would also report the amount of the listed toxic chemical sent off-site for recycling in Section 8.5 (Quantity Recycled Off-Site). </div></b><div style="visibility:hidden"></div></b>-
Off-Site Disposal; Release Reporting; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19674 19-674 674 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Off-Site Disposal; Release Reporting; Waste Treatment 674. The Form R instructions require the listing of different types of on-site waste treatment for a particular waste stream. Does this apply to sequential treatment of a toxic chemical sent off-site? Should the same estimate for amount sent off-site be entered for both waste treatment steps or just the final treatment step?The reporting facility is not required to list sequential waste treatment steps for waste sent off-site. The facility should report in Part II, Section 6.2 the one code that best describes the primary type of waste management activity occurring within the sequence and report the total quantity of the listed toxic chemical sent to this off-site location.</div></b><div style="visibility:hidden"></div></b>-
Fertilizer; Land Treatment; Off-Site Disposal4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19675 19-675 675 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Fertilizer; Land Treatment; Off-Site Disposal 675. If Facility A transfers a toxic chemical in waste off-site to another facility who applies the waste to land for treatment, must Facility A report the amount sent off-site on the Form R? Should Facility A also report volatilization of the toxic chemical that occurs off-site during application to land, as a fugitive air release in Part II, Section 5.1?Facility A must report the amount of toxic chemical in waste sent off-site for disposal as an off-site transfer for disposal. The facility should report this amount in Part II, Section 6.2, using disposal code M73, and in Section 8.1. The facility should not report the amount released to air during off-site application to land, since this activity did not occur on-site. In Part II, Section 5.1, facilities should only report amounts of toxic chemicals that are released on-site.</div></b><div style="visibility:hidden"></div></b>-
Direct Reuse; Fertilizer4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19676 19-676 676 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Direct Reuse; Fertilizer 676. Facility A produces a byproduct containing a toxic chemical. The facility gives some of the byproduct away, and sells some of the byproduct. In both cases, the off-site facility uses the byproduct as fertilizer for farming. Should Facility A report the amount of toxic chemical in the byproduct given away or sold, on the Form R?If the toxic chemical in the byproduct is sent off-site to be directly reused as a fertilizer, then the transfer would not be considered a transfer off-site for waste management purposes, and Facility A would not report, as a transfer off-site for waste management, the amount sold/given away. However, because the facility distributed the toxic chemical into commerce, the facility must consider the quantity of toxic chemical shipped off-site for direct reuse (i.e., both the amounts given away and sold) as fertilizer as processed for threshold determinations.</div></b><div style="visibility:hidden"></div></b>-
Recycling; Ultimate Disposition4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19677 19-677 677 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Recycling (Recycle); Ultimate Disposition 677. A residue of a listed toxic chemical is present in empty drums that are sent to an off-site facility where the drums are recycled, but the listed toxic chemical is not recycled. The facility has no information as to how the listed toxic chemical in the drum is managed. How should the facility report this activity?Though the drums are recycled, the final disposition of the toxic chemical is unknown. Because this facility does not know how the toxic chemical is managed, the toxic chemical should be reported as an unknown disposal, code M99 (Unknown Disposal) in Part II, Section 6.2.C and quantity released in Section 8.1. </div></b><div style="visibility:hidden"></div></b>-
Off-Site Disposal4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19678 19-678 678 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Off-Site Disposal 678. A covered facility receives listed toxic chemicals in a tank car. Once emptied, the car remains at the facility for a period of time before being returned to the supplier. Does the residue in the tank car that leaves the facility have to be counted as an off-site transfer for Section 313?If the facility knows the car will be refilled, the residue is not counted as an off-site transfer. If the facility knows it will be cleaned out and the quantity disposed or otherwise managed as waste, it must be counted as an off-site transfer for disposal. </div></b><div style="visibility:hidden"></div></b>-
Recycling4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19679 19-679 679 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Recycling (Recycle) 679. If a waste is sent to an off-site facility to be recycled or reclaimed, does the material meet the requirements for being recycled or reclaimed for the purposes of Section 313 regardless of what the off-site recycling facility actually does with the waste?In order to report the listed toxic chemical as recycled off-site, the reporting facility must have positive knowledge that the listed toxic chemical being reported is actually being recycled by the off-site facility. </div></b><div style="visibility:hidden"></div></b>-
POTW; Release to Water4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19680 19-680 680 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management POTW; Release to Water (Releases to Receiving Streams) 680. A covered facility treated its wastewater on-site and discharged it to a pipe which runs through a POTW and then on to a stream. The POTW does not treat the waste but it monitors the wastewater and allows it to pass into the stream if it meets treatment standards. If it does not meet standards, the POTW shuts a valve in the pipe and the wastewater is released to a water body under the POTW’s NPDES permit. How should the wastewater be listed on the Form R?The facility should consider the wastewater as a transfer off-site to the POTW since the POTW is ultimately responsible for the release. The POTW has the authority to allow or prevent that release and it enters the stream under their NPDES permit. Because the covered facility knows that the POTW does not treat (destroy) the listed toxic chemical but allows it to pass through into the stream, the facility should also report the quantity sent off-site in Part II, Section 8.1 (Quantity Released). </div></b><div style="visibility:hidden"></div></b>-
Recycling; Threshold Determination4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19682 19-682 682 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Recycling (Recycle); Threshold Determination (Activity Threshold) 682. How should a covered facility treat a toxic chemical in a solvent sent off-site for distillation and returned to the facility for reuse?The amount of a toxic chemical in the solvent sent to another facility for distillation is reported as a transfer of the toxic chemical to an off-site location for recycling (i.e., it should be reported in Part II, Sections 6.2 and 8.5 of the Form R). The quantity of the solvent returned to you must be treated as if it were a quantity of the toxic chemical purchased from any other supplier and must be used for threshold determination. </div></b><div style="visibility:hidden"></div></b>-
Off-Site Disposal4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19683 19-683 683 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Off-Site Disposal 683. A covered printer uses solvent to clean presses and sends soiled rags to a launderer. Is the listed toxic chemical in the material sent to the launderer considered waste transferred to an off-site location? Which disposal code should be used?The material sent to the launderer is considered an off-site transfer. The facility could use code M90 (Other Off-site Management) or M99 (Unknown Disposal) in Part II, Section 6.2.C of the Form R if it does not know the final disposition of the toxic chemical in the rags. </div></b><div style="visibility:hidden"></div></b>-
RCRA ID Number4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19684 19-684 684 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management RCRA ID Number 684. A covered facility sends waste off-site to another facility. During the reporting year, the off-site transfer facility is bought by another company. The off-site transfer facility name changes but the RCRA identification number and facility address remains the same. What name should be reported as the off-site transfer facility?The facility should give the name of the off-site transfer facility as it was known on December 31 of the reporting year; that information being the most accurate and up-to-date information known. </div></b><div style="visibility:hidden"></div></b>-
Landfill; RCRA ID Number4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19685 19-685 685 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Landfill; RCRA ID Number 685. What RCRA identification number does a facility list if it sends a non-hazardous waste containing a Section 313 toxic chemical to a solid waste landfill?If an off-site location such as a solid waste landfill does not have a RCRA identification number, the facility would enter 'NA' in the space provided. If the facility does have such a RCRA identification number, it must list the number, if known, even though the waste being transferred may not be a regulated RCRA hazardous waste. </div></b><div style="visibility:hidden"></div></b>-
Release Reporting4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19687 19-687 687 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Release Reporting 687. A covered facility produces 200,000 pounds of a listed toxic chemical in waste annually. Of that amount, the facility treats 100,000 pounds on-site and sends 100,000 pounds to an off-site treatment plant that has a 99.9 percent efficiency. Can the facility factor in the efficiency when it reports the off-site transfer amount in Part II, Section 6.2 of the Form R?Section 6.2 of the Form R requires you to report the actual amount of listed toxic chemical you send off-site. The efficiency would be taken into account by the off-site facility if they are reporting under Section 313. The 100,000 pounds of the toxic chemical that are treated on-site should be reported in Part II, Section 7A and in Section 8. </div></b><div style="visibility:hidden"></div></b>-
Electricity Generating Facility; Energy Recovery4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19689 19-689 689 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Electricity Generating Facility (EGF); Energy Recovery 689. Do EGFs that burn coal tar with their coal/oil report this amount in Part II, Section 8 of the Form R as energy recovery?No. While coal tar is a by-product of destructive distillation in the production of coke, it is not a waste. Therefore, EPA would not interpret its combustion to be a waste management activity and it would not be reportable in Section 8 of the Form R </div></b><div style="visibility:hidden"></div></b>-
Disposal; Off-Site Disposal; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19691 19-691 691 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Disposal (Dispose); Off-Site Disposal; Waste Treatment 691. A petrochemical company generates a waste stream which contains a toxic chemical. The waste stream is treated at a treatment plant that is located within the boundaries of the petrochemical facility. The treatment plant is neither owned nor operated by the petrochemical company. An agreement has been made between the petrochemical company and the treatment plant that the petrochemical company is responsible for disposal of the sludge generated by the treatment plant (e.g., by transferring the sludge to a landfill). The treatment plant has a NPDES permit and the remaining waste is discharged to a receiving stream. (ln other words, some of the listed toxic chemical sent to the treatment plant returns to the petrochemical plant in sludge and is subsequently sent to an off-site landfill. The remainder of the listed toxic chemical, which does not return to the petrochemical plant in sludge, is sent directly to a receiving stream). How should the petrochemical plant report these off-site transfers of toxic chemicals in wastes? Should the petrochemical plant report the treatment occurring at the treatment plant in Part II, Section 7A (Waste Treatment Methods and Efficiencies) of the Form R?Even though the treatment plant is located within the boundaries of the petrochemical plant, it is neither owned nor operated by the same person as the petrochemical plant. Therefore, the treatment plant and the petrochemical plant are separate facilities. Since the petrochemical plant does not directly treat the waste, it is not responsible for filling out Part II, Section 7A (Waste Treatment Methods and Efficiencies), on its Form R for the toxic chemical. The petrochemical plant reports only two off-site transfers: (1) the total amount of toxic chemical that is sent to the treatment plant (along with the name and address of the treatment plant); and (2) the amount of listed toxic chemical that is sent to a landfill in sludge (along with the name and address of the landfill). This can be interpreted as reporting a portion of the toxic chemical twice, but since the treatment plant is a separate facility, the total amount sent to the treatment plant has to be reported as an off-site transfer. The petrochemical plant does not need to report the receiving stream since the waste is not discharged directly from the petrochemical plant to the receiving stream.</div></b><div style="visibility:hidden"></div></b>-
Releases; Waste; Wastewater Treatment; Water Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19980 19-980 980 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Releases (Released); Waste; Wastewater Treatment; Water Treatment 980. A federal facility reporting under EPCRA section 313 discharges wastewater containing EPCRA section 313 chemicals to a Federally Owned Treatment Works (FOTW) facility. The FOTW is located on a separate site that is not contiguous or adjacent to the reporting facility. For purposes of Form R reporting, should discharges to FOTWs be considered equivalent to discharges to Publicly Owned Treatment Works and reported in Part II, Section 6.1, or should these releases be reported in Part II, Section 6.2 as “wastewater treatment (excluding POTW)” (i.e., code M61)?If a federal facility reporting under EPCRA section 313 discharges waste-water containing EPCRA section 313 chemicals to a FOTW, the facility should report the discharge to the FOTW as a discharge to a POTW (Part II, section 6.1 of Form R), because the operations performed by the FOTW are essentially equivalent to those performed by a POTW. </div></b><div style="visibility:hidden"></div></b>Y
Disposal; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19981 19-981 981 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Disposal (Dispose); Waste 981. A federal facility, which exceeds a reporting threshold for an EPCRA section 313 chemical, sends waste containing the EPCRA section 313 chemical off-site for disposal. Besides its own waste, the federal facility acts as a waste broker for the same EPCRA section 313 chemical for another federal facility within the same parent federal agency. How should the federal facility report for this chemical?The federal facility should report for the amount of the EPCRA section 313 chemical that it sent off-site for disposal, as well as the amount received from the other federal facility. The total amount should be entered in Part II, section 6.2.A, under “transfers to other off-site locations.” The method of disposal by the off-site location should be entered in Part II, section 6.2.C. </div></b><div style="visibility:hidden"></div></b>Y
Direct Reuse; Disposal; Energy Recovery; Reclamation; Recycling; Reuse; Treatment for Destruction4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19988 19-988 988 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Direct Reuse; Disposal (Dispose); Energy Recovery; Reclamation (Reclaim); Recycling (Recycle); Reuse; Treatment for Destruction (Incineration) 988. Under Section 313 of EPCRA and Section 6607 of the Pollution Prevention Act of 1990, facilities that meet certain criteria must report annually the quantities of toxic chemicals that they dispose or otherwise release, treat for destruction, combust for energy recovery, and recycle, as well as quantities that they transfer off-site for disposal, treatment for destruction, energy recovery, or recycling. If a TRI covered facility sends metal scraps containing a toxic chemical off-site to be melted and subsequently reused, is the toxic chemical in the metal scraps considered to be transferred off-site for recycling?Quantities of toxic chemicals that are directly reused on-site or sent off-site for direct reuse without undergoing any reclamation or recovery steps prior to that reuse need not be reported. Assuming no contaminants are removed during the melting process, the toxic chemical in the metal scraps is not actually being recovered but merely melted and reused. Therefore, the amount of the toxic chemical in the metal scraps would not be reportable in Part II, Sections 6.2 or 8 of the Form R. If the facility is repackaging and distributing the toxic chemical in commerce as part of its reuse, the facility should consider the amounts of toxic chemical toward the facility’s processing threshold. EPA has not yet promulgated regulations defining the term “recycle” for the purpose of EPCRA section 313. Even so, for the purposes of TRI reporting, EPA considers toxic chemicals “recycled” when the toxic chemicals are recovered for reuse. If toxic chemicals are directly reused without any intervening reclamation or recovery steps the toxic chemicals are not considered recycled for Form R reporting purposes. Reclamation or recovery would not include simple phase changing of the toxic chemical before further reuse (e.g., simple remelting of scrap metal). Changing the relative amounts of the chemicals in an alloy (which may occur when mixed scrap metal is melted together) would constitute a reclamation or recovery step. Another example of a recovery step would be removing toxic chemicals using a pollution control device or removing contaminants from the toxic chemical after it has been used and can no longer be reused for its intended purpose without reclamation or recovery. Accordingly, if the scrap metal is not mixed with other scrap with varying concentrations of chemicals and can be melted and directly reused, without any recovery steps, then the toxic chemicals in the scrap metal are being directly reused and do not need to be reported as recycling. Facilities should use their best readily available information in determining if the scrap sent off-site is being directly reused or instead is recycled because of an intervening reclamation or recovery step prior to reuse. Additional information regarding direct reuse can be found in the Toxic Chemical Release Inventory Reporting Forms and Instructions.</div></b><div style="visibility:hidden"></div></b>-
Facility; RCRA ID Number; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.B. Transfers to Off-Site Locations For Further Waste Management
<div style="visibility:hidden">19989 19-989 989 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.B. Transfers to Off-Site Locations For Further Waste Management Facility; RCRA ID Number; Waste 989. If a TRI-covered facility transfers waste to a facility located in a foreign country, how does the facility complete the RCRA identification (ID) number and address fields on the Form R for transfers to off-site locations?The facility should enter NA in the RCRA ID field. For the address, the facility should enter the complete address of the receiving facility in the off-site address fields, the city in the city field, the foreign state or province in the county field, the postal code in the zip code field, and the foreign country code in the country field. The most commonly used foreign country codes are listed in Table IV of the Reporting Forms and Instructions. The facility does not need to enter information in the state field. Additional guidance can be found in the Toxic Chemical Release Inventory Reporting Forms and Instructions.</div></b><div style="visibility:hidden"></div></b>-
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