Questions and Answers

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  • 1 - 17 of 17
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Form R; Otherwise Use; Waste; Waste Management Activities; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19215 19-215 215 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Form R; Otherwise Use; Waste; Waste Management Activities; Waste Treatment 215. A facility purchases an EPCRA 313 toxic chemical and uses it to treat a waste stream on-site. The toxic chemical (the “treator”) chemically converts during the process of treating the on-site waste stream. Is the facility required to report the Section 313 treator toxic chemical as “treated on-site” in Part II, Sections 7A and 8.6 of the Form R?When a facility treats a waste stream with a toxic chemical that is not a waste or part of a waste stream prior to its use as a treator, the facility should not report the toxic chemical (the treator) as “treated on-site” in Sections 7A or 8.6 of the Form R, even if it becomes chemically converted or destroyed during the treatment process; the facility should include the amount of the treator chemical used in this process toward the facility’s otherwise use threshold. If, however, a facility treats a waste stream with a toxic chemical that is, itself, a waste or part of a waste stream prior to the treatment process, the facility must report the toxic chemical as “treated on-site” in Sections 7A and 8.6 of the Form R if it becomes chemically converted or destroyed during the treatment process (see: Toxic Chemical Release Inventory Reporting Forms and Instructions, Section D.7).</div></b><div style="visibility:hidden"></div></b>-
Facility Maintenance Exemption; Treatment for Destruction; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19275 19-275 275 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Facility Maintenance Exemption (Janitorial); Treatment for Destruction (Incineration); Waste Treatment 275. On-site wastewater treatment plant sludges which may contain trace amounts of Section 313 toxic chemicals are composted on-site on concrete pads. The finished compost is then used as daily cover for the on-site sanitary landfill and for landscaping around the site. Is this considered land treatment, land impoundment, or not a release?Some listed toxic chemicals in the composted material may degrade such that the chemical is treated for destruction in the compost. In those cases, the listed toxic chemical should be reported as treated on-site (in Part II, Sections 7A (On-site Waste Treatment and Efficiencies) and 8.6 (Quantity Treated On-site)). If the listed toxic chemical is not destroyed, the amounts applied to the on-site sanitary landfill as cover should be reported in Part II, Section 5.5.1B (Other Landfills) and in Section 8.1a (Quantity Released) on the Form R. Although any quantities used as landfill cover would not be exempt from reporting, the amount used for landscaping on-site is exempt under the facility grounds maintenance exemption (40 CFR Section 372.38(c)(2)).</div></b><div style="visibility:hidden"></div></b>-
Chemical Category; Nitrate Compounds; Recycling; Release to Land; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19276 19-276 276 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Chemical Category (Compound Category); Nitrate Compounds (Nitrates); Recycling (Recycle); Release to Land (Land Release); Waste Treatment 276. Are toxic chemicals, such as nitrate compounds, that are used as fertilizer for growing crops considered to be recycled or treated since they are taken up by the crops and re-circulated back into the environment? Can a covered facility reduce the amount of toxic chemicals reported as released to land by the amount the crops take up?Although during such use nitrate compounds or other toxic chemicals may be taken up by plants and cycled back into the ecosystem, such use is not considered treatment or recycling under EPCRA section 313. The toxic chemicals are reported as released to land on the Form R. 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>-
Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19636 19-636 636 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Waste Treatment 636. Does Section 7A (On-Site Waste Treatment Methods and Efficiency), of the Form R apply only to the facility completing the report?Yes, this Section of the Form R applies only to the treatment of waste streams containing toxic chemicals that occur on-site at the reporting facility.</div></b><div style="visibility:hidden"></div></b>-
Energy Recovery; Metals; Ultimate Disposition4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19688 19-688 688 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Energy Recovery; Metals; Ultimate Disposition 688. A covered facility sends a toxic chemical in a paint thinner waste to a firm for fuel blending purposes. Should the amount of toluene and xylene in the waste be reported on the Form R, Part II, Section 6 as a transfer off-site?A toxic chemical in a waste stream sent off-site for waste fuel blending is considered combusted for energy recovery if the listed toxic chemical has a significant heat value and is combusted in an energy recovery device. EPA believes that waste blended into fuel will be combusted in an integrated energy recovery device. Where both elements are met, the quantity of the toxic chemical must be reported as an off-site transfer for purposes of energy recovery on the Form R. However, other reportable toxic chemicals in the waste (e.g., metal pigments) that are incombustible or that do not add significant heat value to energy recovery upon combustion must be reported as off-site transfers for purposes of waste treatment or disposal, as appropriate. Please note that metals cannot be treated or combusted for energy recovery purposes and, therefore, should be reported as disposed in Section 8 of the Form R, unless the facility has knowledge the metals are being recycled.</div></b><div style="visibility:hidden"></div></b>-
Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19692 19-692 692 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Waste Treatment 692. Where multiple sources are combined for waste treatment, should each source be listed in the Part II, Section 7 of the Form R with a common efficiency, or should only the combined waste stream be shown?Report only the combined (or aggregate) waste stream and report the treatment and its efficiency. However, a waste stream that is treated before combination with other wastes, which are then subsequently treated, should be reported on a separate line.</div></b><div style="visibility:hidden"></div></b>-
Influent Concentration; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19693 19-693 693 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Influent Concentration; Waste Treatment 693. A covered facility has a sequential waste treatment process in which the influent concentration and treatment efficiency for each step is known. How should they report in Section 7A of the Form R?The facility should report influent concentration for the first step and report overall treatment efficiency for the entire process as per the Form R instructions. </div></b><div style="visibility:hidden"></div></b>-
Influent Concentration; Metal Compounds; Metals; Release Reporting; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19694 19-694 694 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Influent Concentration; Metal Compounds; Metals; Release Reporting; Waste Treatment 694. In Part II, Section 7A of the Form R, should covered facilities report the influent concentration to a treatment system for metal compounds in a waste stream for the parent metal only? How do I consider treatment efficiencies for metal compounds?For metal compounds, the calculation of the reportable concentration and waste treatment efficiency must be based on the weight of the parent metal, not on the weight of the metal compounds. Metals are not destroyed, only physically removed or chemically converted from one form to another. The waste treatment efficiency reported must represent only the physical removal from the waste stream (except for incineration), not the percent conversion from one form to another. If a listed waste treatment method converts but does not remove a metal (e.g., chrome reduction), the method must be reported with a waste treatment efficiency of zero.</div></b><div style="visibility:hidden"></div></b>-
Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19695 19-695 695 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Waste Treatment 695. If a wastewater treatment system contains an oil skimmer or other phase separation treatment, is this reported as a sequential waste treatment step for each of the separated phases, or just for one phase?The separation step is a sequential waste treatment step for one liquid phase (the one with the larger volume, typically the water phase). The other phase must be considered a new waste stream and must be listed separately on the form if treated subsequent to its separation.</div></b><div style="visibility:hidden"></div></b>-
Treatment Efficiency; Waste; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19696 19-696 696 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Treatment Efficiency; Waste; Waste Treatment 696. Section 7A of the Form R requires facilities to report on-site waste treatment methods and their efficiency. Does a facility have to report a treatment method used on a waste stream containing a TRI chemical if the treatment does not destroy, chemically convert, or physically remove the chemical within the waste stream?Most of the information reported on the Form R is specific to the TRI chemical, rather than the waste stream containing that chemical. However, facilities must report waste treatment methods applied on-site to waste streams that contain the TRI chemical, even if the waste treatment method does not remove the specific TRI chemical being reported. In the event that a facility is reporting a waste treatment that does not destroy, chemically convert, or physically remove the TRI chemical, the efficiency is zero and the facility must report efficiency code E6 (equal to or greater than 0%, but less than or equal to 50%) for that treatment method (see: TRI Reporting Forms and Instructions, Section D.7).</div></b><div style="visibility:hidden"></div></b>-
Acids; Waste Treatment; pH4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19697 19-697 697 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Acids (Acid Aerosol); Waste Treatment; pH 697. We send our sludge to a biological treatment device on-site. The microbes in the system exist in buffered solution. As a result, the toxic chemical (a mineral acid) in the sludge is neutralized (pH 7.3). How do I account for biological and neutralization treatment in one process in Part II, Section 7A of the Form R? After that, the waste goes to settling ponds where solids settle out. Is this also a sequential treatment step?First, list the biological treatment, even though it does nothing to the toxic chemical, and then enter the neutralization treatment, which has a 100 percent efficiency since pH 7.3 is considered complete neutralization for an acid. As for the settling ponds, the toxic chemical ceased to exist upon complete neutralization, so this step does not need to be included in Part II, Section 7A of the Form R for the mineral acid. However, any coincidental manufacture of toxic chemicals during this process should be considered towards the manufacturing threshold determination. </div></b><div style="visibility:hidden"></div></b>-
Incineration; Treatment Efficiency; Treatment for Destruction; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19698 19-698 698 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Incineration (Treatment for Destruction); Treatment Efficiency; Treatment for Destruction (Incineration); Waste Treatment 698. A covered facility has a liquid waste stream containing a toxic chemical which is incinerated. The incineration destroys 99.9 percent of the chemical. However, 0.1 percent is released to air. Does the facility need to report this waste stream in the waste treatment Section of the Form R?If the threshold is met, the facility must report this liquid waste stream as treated for destruction in Part II, Section 7 of the Form R. The listed toxic chemical remaining after incineration in the gaseous waste stream must be reported as stack or point source air emissions in Part II, Section 5.2 of the Form R. The amount of the listed toxic chemical destroyed is also reported in Part II, Section 8.6 of the Form R, and the stack or point source air emissions are also reported in Part II, Section 8.1 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Acids; Neutralization; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19700 19-700 700 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Acids (Acid Aerosol); Neutralization; Waste Treatment 700. We have two waste streams, one containing “an unlisted caustic material” and the other phosphoric acid, that are combined for neutralization. The combined waste stream then stays in the settling pond until the solid settles out. The water is sent to a POTW, the solid to a landfill. How should we report on these toxic chemicals? When does a toxic chemical cease to exist by neutralization?Neutralization is the treatment method for phosphoric acid. If the pH is 6 or above then the efficiency is 100 percent (i.e., no phosphoric acid is released) and no off-site transfer should be reported. If the waste is acidic, (i.e., pH below 6) report the transfer of phosphoric acid sent off-site and calculate efficiency from the input and the remaining acid.</div></b><div style="visibility:hidden"></div></b>-
Acids; Neutralization; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19701 19-701 701 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Acids (Acid Aerosol); Neutralization; Waste Treatment 701. If a covered acid, such as phosphoric acid, is spilled onto a concrete pad and immediately neutralized with a base, how is this reported on the Form R? How would the spill be reported if it were spilled directly on the land and neutralized?If the acid spilled on the concrete pad is 100 percent neutralized, the facility would only report any non-neutralized air releases of the toxic chemical in Part II, Sections 5 and 8 on the Form R. If the spill were released directly to land before being neutralized, only the amount of the chemical that seeped into the land (i.e., not neutralized) and any air releases occurring as a result of the spill would be reported in Part II, Sections 5 and 8 on the form. Note that if the spill is considered a one-time, non-routine event, the entire amount spilled (that is not neutralized) should be reported in Part II, Section 8.8 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19702 19-702 702 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Release Reporting; Waste Treatment 702. How is an auxiliary scrubber that is designed and used only to mitigate emergency releases reported?The influent concentration and treatment efficiency of the scrubber as it operates during an emergency event should be reported. The emergency scrubber is not considered to be sequential treatment with a scrubber which treats routine emissions from the same process, unless the two units function in series on a single waste system.</div></b><div style="visibility:hidden"></div></b>-
Best Available Information; Treatment Efficiency; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19703 19-703 703 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Best Available Information; Treatment Efficiency; Waste Treatment 703. A waste stream containing glycol ethers is sent through several treatment steps, none of which are specifically intended to remove the glycol ethers. During the settling process, some of the glycol ethers present in the waste stream unintentionally evaporate into the ambient air. Should the facility owner or operator report the glycol ether as being treated and, if so, what waste treatment efficiency estimate is reported?Any releases of a toxic chemical, even during treatment, must be estimated and reported in Part II, Section 5 of the Form R. Part II, Section 7 of the Form R must be completed if a waste stream containing the glycol ethers is treated, regardless of whether the treatment methods actually remove the glycol ethers. If, for whatever reason, glycol ethers are removed during the treatment of a waste stream, the owner or operator should use the best readily available information to determine how much of the glycol ethers are removed during the treatment process and use this information to estimate a 'treatment efficiency' for the toxic chemical.</div></b><div style="visibility:hidden"></div></b>-
Storage Tanks; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.C. Waste Treatment Methods and Efficiency
<div style="visibility:hidden">19704 19-704 704 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.C. Waste Treatment Methods and Efficiency Storage Tanks; Waste Treatment 704. A covered facility owner or operator has a conservation vent on a bulk storage tank. The conservation vent prevents emissions from the tank during material loading, unloading, and storage. Should this conservation vent be listed in Part II, Section 7A of the Form R as a waste treatment method since it is reducing the toxic chemical emissions from the tank?No. Part II, Section 7 of the Form R is only for the description of waste treatments that occur on-site. In the above scenario, the conservation vent functions as a preventive device. The conservation vent does not function as a waste treatment step. (Another example of a preventative device is a floating roof storage tank, the function of which would not be considered waste treatment). </div></b><div style="visibility:hidden"></div></b>-
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