Questions and Answers

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  • 1 - 19 of 19
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Facility; Otherwise Use; Threshold Determination; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19146 19-146 146 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Facility; Otherwise Use; Threshold Determination (Activity Threshold); Waste 146. A federal facility conducts remediation activities on soils contaminated in prior years. The facility is using an EPCRA section 313 chemical as part of the remediation action. Is the facility required to count the amount of EPCRA section 313 chemical used for remediation activities when making threshold determinations?Yes. The use of EPCRA section 313 chemicals to remediate wastes is an otherwise use activity. The facility should include the EPCRA section 313 chemicals used when making its otherwise use threshold determinations and release and other waste management calculations.</div></b><div style="visibility:hidden"></div></b>Y
Aluminum; Energy Recovery; Metals; Recycling; Treatment for Destruction; Waste; Waste Management Activities; Zinc4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19558 19-558 558 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Aluminum; Energy Recovery; Metals; Recycling (Recycle); Treatment for Destruction (Incineration); Waste; Waste Management Activities; Zinc 558. For Toxics Release Inventory (TRI) reporting under EPCRA section 313, is on-site conversion of a metal compound to an elemental metal or from the elemental form of a metal to a compound of that same metal considered treatment for destruction?Generally, if the conversion of a listed TRI toxic chemical into another substance (listed or not) takes place in a waste stream, it is considered treatment for destruction of the initial chemical. Metals, however, generally are not considered as treated for destruction because only the weight of the parent metal is reported and the parent metal cannot be destroyed. Therefore, the conversion of an elemental metal to a compound of the same metal or from a metal compound to the elemental form of the same metal is not considered treatment for destruction, even when such conversion takes place in a waste stream. There are, however, a few instances in which a TRI metal or metal category compound may be considered treated for destruction upon its conversion to another form or substance because the newly formed substance is not a listed TRI chemical. For example, when elemental barium or a barium compound is converted to barium sulfate in a waste stream, this is reported as treatment for destruction because barium sulfate is not a listed TRI chemical. Similarly, aluminum and zinc, which are only reportable in the form of fumes or dusts, are considered treated for destruction when they are converted into non-reportable forms if this conversion takes place in a waste stream. Additional information regarding treatment for destruction can be found in the Waste Management Activities: Recycling, Combustion for Energy Recovery, Treatment for Destruction, Waste Stabilization and Release document on GuideME.</div></b><div style="visibility:hidden"></div></b>-
Catastrophic One-Time Event; NA vs. 0; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19622 19-622 622 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Catastrophic One-Time Event; NA vs. 0 (NA; NA vs. zero); Waste Management Activities 622. On the Form R, a covered facility owner/operator must provide information about routine and non-routine releases for each reported toxic chemical. Specifically, in Part II, Section 8.8, an owner/operator must report the quantity of any release of a toxic chemical into the environment or transferred off-site as a result of a remedial action, catastrophic event, or one-time event not associated with production processes. If the facility did not experience any such release or transfer, must the owner/operator report zero, or may the owner/operator report “NA” in Section 8.8?While either notation, NA or zero, may be entered in Part II, Section 8.8 of the Form R, they are not synonymous. If a remedial action, catastrophic event, or one-time event not associated with production processes results in a release into the environment or an off-site transfer of the listed non-PBT chemical and the annual aggregate release was less than 0.5 pound, then a facility owner/operator should enter zero in Section 8.8. For PBT chemicals, facilities should report releases and other waste management amounts greater than 0.1 pound (and for dioxin and dioxin-like compounds 0.0001 gram) at a level of precision supported by the accuracy of the underlying data and the estimation techniques on which the estimate is based. (see (64 FR 58734; October 29, 1999) and Guidance for Reporting Toxic Chemicals with the Dioxin and Dioxin-like Compounds Category (EPA-745-B-00-021)). An owner/operator should only report NA for Section 8.8 on the Form R if no release or transfer occurred as a result of these activities.</div></b><div style="visibility:hidden"></div></b>-
Fuel; Process; Releases; Remediation; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19659 19-659 659 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Fuel; Process (Processing; Processed; Processes); Releases (Released); Remediation (Remedial); Waste 659. A federal facility is involved in the remediation of benzene. The facility also uses benzene as a manufacturing aid in the blending of fuel additives. The amount of benzene used in the fuel blending operations exceeds the 25,000-pound processing threshold under EPCRA section 313 and the facility has more than 10 FTEs. If benzene is released to the air during remediation, does that release get reported in Part II, section 8.1 of the Form R?No. All releases and other waste management of an EPCRA section 313 chemical resulting from remedial actions should be reported under Part II, section 8.8 (as well as in sections 5 and 6) of the Form R and are not to be reported under Part II, sections 8.1 through 8.7 of the Form R.</div></b><div style="visibility:hidden"></div></b>Y
Releases; Remediation4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19660 19-660 660 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Releases (Released); Remediation (Remedial) 660. A federal facility is submitting a Form R report for an EPCRA section 313 chemical. During a remediation project, the same chemical is transferred from one medium to another. For example, soil excavation during groundwater remediation causes an EPCRA section 313 chemical to be released to the air. How should the release be reported on the Form R?If a federal facility exceeds reporting thresholds for the chemical in other non-exempt activities at the facility then the release of that EPCRA section 313 chemical from one medium to another due to remediation activities must be reported on the Form R, unlike EPCRA section 313 chemicals that transfer to another medium as a result of natural migration. Releases of EPCRA section 313 chemicals that occur as a result of remediation activities during the reporting year are reported in section 8.8 and the appropriate sections of Part II, sections 5 and 6 of the Form R report.</div></b><div style="visibility:hidden"></div></b>Y
Energy Recovery; Fuel; Otherwise Use; Releases; Waste4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19690 19-690 690 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Energy Recovery; Fuel; Otherwise Use; Releases (Released); Waste 690. A federal facility voluntarily reports releases of EPCRA section 313 chemicals contained in motor vehicle fuel. The motor vehicles are operated by the facility and they report the combustion of the EPCRA section 313 chemicals that occurs in the vehicle engine as “otherwise used” and subject to the 10,000-pound threshold. Would the combustion process that occurs in the vehicle engine be considered a reportable energy recovery method (i.e., Part II, sections 7B and 8.2) for the Form R reporting?No. The quantity of EPCRA section 313 chemical reported in Part II, sections 7B and 8.2 of the Form R as used for energy recovery include EPCRA section 313 chemicals present in wastes, not in raw materials. Therefore, the combustion of EPCRA section 313 chemicals contained in fuel that occurs in a motor vehicle engine is not considered a reportable energy recovery method on the Form R report.</div></b><div style="visibility:hidden"></div></b>Y
Activity Threshold; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19705 19-705 705 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Activity Threshold (Threshold Determination); Waste Management Activities 705. If a covered facility counts the amount of a listed toxic chemical towards an activity threshold, is it automatically exempted from reporting this amount as undergoing a waste management activity on the Form R?No. If, for example, a facility combusts a toxic chemical in a waste for energy recovery, the owner or operator would consider the amount combusted for energy recovery towards the otherwise use threshold. If the facility exceeds a threshold for this chemical, the owner or operator would also report the method and amount of energy recovery in Part II, Sections 7 and 8 on the Form R. </div></b><div style="visibility:hidden"></div></b>-
Metals; Recycling; Reuse; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19706 19-706 706 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Metals; Recycling (Recycle); Reuse; Waste Management Activities 706. If a covered facility sends metal scraps containing chromium off-site to be remelted and subsequently reused, does it report the amount of toxic chemical in the metal as recycled off-site?Assuming no contaminants are removed during the melting process, the chromium 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. However, because the facility is repackaging and distributing the toxic chemicals in commerce, it should consider these amounts of the toxic chemical towards the facility's processing threshold. If the covered facility exceeds a chemical activity threshold, it is required to file a TRI Report for that chemical. </div></b><div style="visibility:hidden"></div></b>-
Energy Recovery; PACs4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19707 19-707 707 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Energy Recovery; PACs 707. EPCRA section 313 listed polycyclic aromatic compounds (PACs) are used as binders for coke in carbon anodes. The anodes are baked in a ring furnace and the PACs are combusted. The heating value of the PACs allow for a reduction in the use of natural gas. Should the amount of PACs combusted be reported as burned for energy recovery on the Form R?In this scenario, EPCRA section 313 chemicals are being burned in the process, not in a waste management activity. Toxic chemicals reported as released or otherwise managed as waste on the Form R, including quantities reported for energy recovery, should not include chemicals consumed during processing activities. Therefore, the PACs combusted as part of the process in a ring furnace, should not be included as combusted for energy recovery under EPCRA section 313. These quantities should, however, be considered when making the facility's otherwise use threshold.</div></b><div style="visibility:hidden"></div></b>-
Metals; POTW; Release Reporting; Waste Management Activities; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19708 19-708 708 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Metals; POTW; Release Reporting; Waste Management Activities; Waste Treatment 708. If I send ten pounds of chromium (or any metal) to a POTW or other wastewater treatment facility, where should I report the ten pounds in Section 8 of the Form R?Because metals cannot be destroyed, they should not be reported as treated in Part II, Section 8.6 or 8.7 of the Form R. If you do not know what the POTW does with the metal constituents they receive, you should assume they are released and report the ten pounds sent to a POTW in Part II, Section 8.1 on the Form R.</div></b><div style="visibility:hidden"></div></b>-
Source Reduction; Waste Management Activities; Waste Treatment4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19710 19-710 710 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Source Reduction; Waste Management Activities; Waste Treatment 710. Would RCRA permitted incineration of a listed toxic chemical count as a source reduction activity under Part II, Section 8.10 of the Form R?Section 8.10 of the Form R is for reporting actions or techniques that prevent a toxic chemical from becoming a waste to be disposed, treated, combusted for energy recovery, or recycled. Incineration is considered waste treatment (assuming there is no energy recovery) and is reportable under Part II, Sections 6.2.C or 7A, as well as Section 8.6 or 8.7, depending on whether it is performed on- or off-site. It should not, however, be reported as a source reduction activity in Part II, Section 8.10. </div></b><div style="visibility:hidden"></div></b>-
Release Reporting; Remediation; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19711 19-711 711 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Release Reporting; Remediation (Remedial); Waste Management Activities 711. Is dredging a lagoon (or surface impoundment) containing a toxic chemical once every five years (routine procedure) considered a remedial action under the Pollution Prevention Act? If so, how should releases from the dredging be reported in Section 8.8 of the Form R?Because the dredging of the lagoon (or surface impoundment) occurs routinely every five years, it is not considered a remedial action under the Pollution Prevention Act, and accordingly, releases from the dredging should not be reported as releases from remedial actions. Instead, releases and other waste management quantities of the toxic chemical resulting from dredging would be reported in Sections 5 or 6 and in Section 8 of the Form R, depending on the ultimate disposition of the chemical. </div></b><div style="visibility:hidden"></div></b>-
Activity Index; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19712 19-712 712 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Activity Index (Production Ratio; Activity Ratio); Waste Management Activities 712. For the purposes of reporting in Part II, Section 8.9 of the Form R, a facility must provide a ratio of the reporting year production to prior year production, or provide an activity index based on a variable other than production that is the primary influence on the quantity of the reported toxic chemical recycled, combusted for energy recovery, treated, or released (including disposed). How should one-time or batch processors determine an activity index or production ratio for reporting in Section 8.9 of the Form R?A one-time processor in its first year of using a listed toxic chemical should report 'NA' in Section 8.9 of the Form R. If a one-time processor uses a toxic chemical on a yearly basis but in different products, applications, and quantities, then a production ratio based on production or application involving the toxic chemical should be calculated as follows: production involving the toxic chemical in the current year divided by production involving the toxic chemical in the prior year. Batch processors should calculate a ratio based on campaigns involving the toxic chemical from year to year as follows: campaign production in the current year divided by the campaign production in the prior year. </div></b><div style="visibility:hidden"></div></b>-
Activity Index4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19714 19-714 714 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Activity Index (Production Ratio; Activity Ratio) 714. Can a covered facility within the seven newly added industry sectors report 'NA' in Part II, Section 8.9 (Production Ratio or Activity Index) of the Form R, for reporting year 1998?For reporting year 1998 only, facilities in the seven newly added industries may use 'NA' in Part II, Section 8.9 (Production Ratio or Activity Index) of the Form R. In future years, these newly added facilities may only use 'NA' in this section if the reported toxic chemical was not manufactured, processed or otherwise used in the year prior to the reporting year. All other facilities covered by EPCRA section 313 may only use 'NA' for the 1998 reporting year, and all future years, if the reported toxic chemical was not manufactured, processed or otherwise used in the year prior to the reporting year.</div></b><div style="visibility:hidden"></div></b>-
NA4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19717 19-717 717 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management NA 717. Are covered facilities in a newly added industry sector required to provide an estimate in column A, Section 8 (Prior Year Estimate) of the Form R for the first year in which their industry is covered?No. For only that first reporting year that the industry sector was added to TRI's covered sectors list, covered facilities in a newly added industry sector are not required to provide an estimate for the prior year in column A, Section 8 of the Form R. However, if the facility has information to develop an estimate, then reporting the estimate may provide valuable information that may clarify the facility's yearly estimates.</div></b><div style="visibility:hidden"></div></b>-
Energy Recovery; NA; Recycling; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19718 19-718 718 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Energy Recovery; NA; Recycling (Recycle); Waste Management Activities 718. In Section 8, Columns C and D of the Form R, facilities must report quantities of a toxic chemical released or managed as waste for the following year and second following year. When would it be appropriate for a facility to put “NA” in these columns?The owner or operator of a facility should enter “NA” in Columns C and D of Sections 8.1 through 8.7 of the Form R if there will be no on-site or off-site treatment, combustion for energy recovery, or recycling on the waste stream containing the TRI chemical or the chemical will not be present at the facility in either of the following years. It would also be appropriate to enter “NA” if the facility shut down during the reporting year and will not be operating in the following year or second following year. </div></b><div style="visibility:hidden"></div></b>-
Source Reduction; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19720 19-720 720 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Source Reduction; Waste Management Activities 720. If a covered facility modifies a process for economic reasons resulting in a waste reduction, should this be reported as source reduction?Yes. Any changes that result in less of the listed toxic chemical being generated in waste may be included. Codes are provided to identify changes such as equipment and technology modifications, as well as process changes, procedure modifications, and improved housekeeping. </div></b><div style="visibility:hidden"></div></b>-
Catastrophic One-Time Event; Release Reporting4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19723 19-723 723 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Catastrophic One-Time Event; Release Reporting 723. Are releases due to a pipe rupture that was caused by premature failure of the pipe (no direct cause known) considered a catastrophic release and reportable in Part II, Section 8.8?Releases reported in Part II, Section 8.8 of the Form R should be the result of a remedial action, a catastrophic event or a one-time release not associated with normal or routine production processes. In general, pipes have an expected life span. If a pipe ruptures during its expected life span for no known reason, the release should be considered a one-time release not associated with normal or routine production processes and should be reported in Section 8.8. However, if the pipe bursts because it was in use after its expected life span it should not be considered a one-time release because it should have been replaced.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Landfill; Releases; Remediation; Threshold Determination; Waste; Waste Management Activities4. Completing the Form R: Releases and Waste Management Calculations >
4.D. Waste Management
<div style="visibility:hidden">19929 19-929 929 2019 Questions and Answers Consolidation4. Completing the Form R: Releases and Waste Management Calculations 4.D. Waste Management Activity Threshold (Threshold Determination); Landfill; Releases (Released); Remediation (Remedial); Threshold Determination (Activity Threshold); Waste; Waste Management Activities 929. A federal facility conducts remediation activities on soils contaminated in prior years. The soils contain EPCRA section 313 chemicals. Is the facility required to report under EPCRA section 313 for these remediated chemicals?EPCRA section 313 chemicals undergoing remediation are not included in threshold determinations because remediated chemicals are not manufactured, processed, or otherwise used. However, if a covered facility exceeds an activity threshold for a listed chemical elsewhere at the facility, any releases and other waste management activities of the listed EPCRA section 313 chemicals undergoing remediation must be included in the facility's release and other waste management calculations. In that event, a release does not include material already in a landfill but does include any material releases to the environment (including being placed in a landfill) or transferred off-site due to the remediation activity. While federal facilities are not required to make threshold determinations for remediated EPCRA section 313 chemicals, they should consider the spirit of EO 13148 by providing this information to the public. </div></b><div style="visibility:hidden"></div></b>Y
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