786. If a quantity of an EPCRA section 313 chemical meets the criteria for a reporting exemption, should it be included on the Form R report Part II, section 4.1: Maximum Amount of the Toxic Chemical On-Site at Any Time During The Calendar Year?
No. If a federal facility uses an EPCRA section 313 chemical in a manner that meets the criteria for a reporting exemption, that amount of the EPCRA section 313 chemical is exempt from threshold determinations and release and other waste management calculations. If a Form R report is required because of other, non-exempt uses, exempted quantities should not be included in calculations for Part II, section 4.1.