Question # 55

55. How should a federal facility, which has not previously reported under EPCRA section 313, begin efforts to make threshold determinations and release and other waste management calculations for activities at the facility?
Federal facilities should utilize the best readily available information needed to make threshold determinations and release and other waste management calculations. For example, a release through an air stack or to a receiving stream may be estimated from the appropriate air and water permits. Permit applications may also include the mathematical equations that were used to calculate permitted release amounts. These equations potentially could be modified and used to calculate releases for section 313 reporting purposes. Reaction equations and engineering notes also may provide a good source of information for release calculations and on-site waste management activities. For transfers off-site for further waste management, annual or biannual RCRA reports provide an excellent source of information. These reports refer to specific hazardous waste manifests. From the manifests, it may be possible to estimate the amounts of EPCRA section 313 chemicals in the waste transferred off-site. Invoices and shipping receipts are essential if a reportable EPCRA section 313 chemical that is not a RCRA waste, is sent off-site for recycling or disposal. In addition, the EPA has produced estimation guidance manuals for specific industries and for specific chemicals. Information about how to obtain these guidance manuals is available on the EPA website: https://www.epa.gov/chemicals-under-tsca.