United States
Environmental Protection Office of Pesticides EPA 560/--9G-3 15
Agency and Toxic Substances August 1990
&EPA Section 313
Emergency Planning and
Community Right-to-Know Act
Quality Assurance Audit Manual
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EPA 560/4-90-013
August 1990
EPCRA SECTION 313 QUALITY ASSURANCE
AUDIT MANUAL
by
Radian Corporation
2455 Horsepen Road, Suite 250
Herndon, VA 22071
Contract No. 68-D9-0169
Work Assignment 1-03
U.S. Environmental Protection Agency
Office of Pesticides and Toxic Substances
401 M Street, S.W.
Washington, D.C. 20460
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TABLE OF CONTENTS
Section page
1.0 INTRODUCTION 1-1
2.0 AUDITOR TRAINING 2-1
2.1 Overview of Section 313 Program 2-1
2.2 EPCRA Section 313 Reporting Instructions . 2-1
2.2.1 Qualifiers 2-1
2.2.2 Chemical Categories 2-4
2.2.3 Exemptions 2-5
2.2.4 Chemical Releases to the Environment On-Site . . 2-7
2.2.5 Chemical Transfers to Off-Site Locations .... 2-8
2.3 Additional References 2-8
3.0 SITE AUDIT PREPARATION 3-1
3.1 Review of Facility Form R Reports 3-1
3.1.1 Facility Identification Data (Part I) 3-1
3.1.2 Chemical-Specific Information (Part III) .... 3-2
3.2 Industry Investigation 3-5
4.0 SITE AUDIT 4-1
4.1 Pre-visit Completion of the Audit Checklist 4-1
4.1.1 Technical Review 4-1
4.1.2 Supplier Notification 4-2
4.1.3 Logistics 4-3
4.2 Completion of the Audit Checklist 4-3
4.2.1 Arrival and Entry Procedures 4-3
4.2.2 Kick-off Meeting 4-4
4.2.3 Facility Tour 4-4
4.2.4 Review of Section 313 Chemicals 4-6
4.3 Closing Conference 4-13
APPENDIX A DEFINITIONS
APPENDIX B TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM R
APPENDIX C AUDIT CHECKLIST
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LIST OF TABLES
Table Pa^e
2-1 DESCRIPTION OF STANDARD INDUSTRIAL CLASSIFICATION (SIC)
CODES 2-2
2-2 SECTION 313 CHEMICAL CATEGORIES 2-6
3-1 REGULATORY DATA CHECKLIST 3-3
3-2 EXAMPLE OF FACILITY SUMMARY MATRIX 3-4
3-3 EPA GUIDANCE DOCUMENTS FOR INDUSTRY INVESTIGATIONS 3-6
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1.0 INTRODUCTION
Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA Title III) requires facilities whose
activities fall into Standard Industrial Classification (SIC) Codes 20-39 to
file annual reports of releases of certain chemicals to the environment. The
purpose of Section 313 is to inform the general public about releases of
listed chemicals by facilities. Data collected under Section 313 will aid in
developing future regulations, guidelines, and standards.
The information required under Section 313 is submitted by
facilities on the Toxic Chemical Release Inventory Reporting Form (Form R) and
is due to EPA for any calendar year on or before July 1 of the following year.
Facilities are required to retain on-site copies of all forms submitted, along
with the supporting materials used to develop information in the report, for a
period of three years from the date of submission. These materials must also
be readily available for inspection by the EPA or other authorized
organizations.
The data included on each Form R report is entered into the Toxic
Release Inventory (TRI) database, which is accessible to members of the
public. Because the nature of the information is sensitive for each facility
submitting a Form R report and for the database as a whole, industry and EPA
alike are interested in ensuring its high quality. The purpose of this manual
is to assist those who want or need to review Form R data to evaluate the
quality of data submitted. This quality assurance assessment is conducted by
reviewing information submitted on Form R reports and all supporting
documentation, and by completing an audit checklist. This manual is designed
for use during technical data quality audits unrelated to inspections
conducted for the purpose of enforcing the requirements of EPCRA § 313.
However, enforcement personnel may use the manual as a technical reference
supplementing their standard enforcement procedures.
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2.0 AUDITOR TRAINING
2.L Overview of Section 313 Program
Gvr.ers arui operators of facilities are required to submit a separate
Toxic Chemical Release Inventory Reporting Form (Form R) for each listed
chemical if they ir,eet the following three criteria:
• The facility has the equivalent of 10 or more full-time
employees;
• The facility is included in SIC Codes 20 through 39; and
The facility "manufactured," "processed," or "otherwise used"
any listed chemical in quantities exceeding a threshold during
the reporting year.
A description of SIC Codes 20 through 39 is presented in Table 2-1-.
Definitions of bold-face terms are given in Appendix A.
2.2 EPCRA Section 313 Reporting Instructions
The EPA publication entitled Toxic Chemical Release Inventory
Reporting Form R and Instructions. Revised 1989 Version (EPA 560/4-90-001)
outlines the reporting requirements for EPCRA, Section 313. The form and
instructions are revised periodically. Auditors should read this document
carefully to become familiar with the regulations. Some key areas requiring
additional clarification are discussed below.
2.2.1 Qualifiers
Nine of the chemicals listed in SARA Section 313 as subject to
reporting include qualifiers which restrict the form of the chemical that is
subject to reporting. A listed chemical is subject to reporting only when it
is manufactured, processed, or otherwise used in the restricted manner.
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Table 2-1
DESCRIPTION OF STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODES
SIC Code Description
20 Food and kindred products
21 Tobacco products
22 Textile mill products
23 Apparel and other finished products made from fabrics and other
similar materials
24 Lumber and wood products, except furniture
25 Furniture and fixtures
26 Paper and allied products
27 Printing, publishing, and allied industries
28 Chemicals and allied products
29 Petroleum refining and related industries
30 Rubber and miscellaneous plastic products
31 Leather and leather products
32 ' Stone, clay, glass, and concrete products
33 Primary metal industries
34 Fabricated metal products, except machinery and transportation
equipment
35 Industrial and commercial machinery and computer equipment
36 Electronic and other electrical equipment and components, except
computer equipment
37 Transportation equipment
38 Measuring, analyzing, and controlling instruments; photographic,
medical and optical goods; watches and clocks
39 Miscellaneous manufacturing industries
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Chemicals that do not include qualifiers in the Section 313 listing are
subject to reporting in all forms that are manufactured, processed, or
otherwise used.
Five types of qualifiers are included in the list of toxic
chemicals. These qualifiers are described below.
(1) Fume or dust. Aluminum, vanadium, and zinc contain the
qualifier "fume or dust." Fume or dust refers only to dry
forms of these metals. If a facility does not use these metals
in either of these forms, they are not reportable. "Zinc
Compounds" is a listed chemical category; therefore, any
facility that manufactures, processes, or otherwise uses zinc
in the form of a compound must report it if the applicable
threshold is met.
(2) Manufacturing Qualifiers. Saccharin is only reportable if it
is manufactured. Isopropyl alcohol is only reportable if it is
manufactured using the strong acid process.
(3) Solutions. Ammonium nitrate and ammonium sulfate contain the
qualifier "solution." If a facility manufactures, processes,
or otherwise uses these chemicals in forms other than
solutions, they are not reportable.
(4) Phosphorus (yellow or white). The qualifier "yellow or white"
refers to the chemical state of phosphorus. Only facilities
that manufacture, process, or otherwise use phosphorus in the
yellow or white states are subject to reporting. Facilities
that manufacture, process, or otherwise use phosphorus in the
black or red states are not subject to reporting requirements.
(5) Asbestos (friable). The qualifier "friable" means crumbled,
pulverized, or reducible to a powder with hand pressure.
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Facilities chac manufacture, process, or otherwise use asbescos
in this form are subject to reporting. Removal and off-sice
transfer of asbestos that is a structural component is exempt
from reporting'requirements. However, asbestos that is
transferred from waste piles that is manufactured, processed,
or otherwise used is considered a release under Section 313 and
is therefore subject to reporting.
(6) Aluminum Oxide (fibrous). Fibrous aluminum oxide is a man-made
fiber. It is processed to produce strands or filaments which
can be cut to various lengths depending on the ultimate
application. Facilities which manufacture, process, or
otherwise use aluminum oxide in the fibrous form are subject to
reporting.
2.2.2 Chemical Categories
Section 313 lists 20 chemical categories that are subject to
reporting, in addition to the specific chemicals listed. These chemical
categories are listed in Table 2-2. Sixteen of the chemical categories
consist of metal compounds in which the parent metal is listed separately.
For example, "Antimony Compounds" is a listed chemical category, while
"Antimony" is a listed chemical. Metal compounds are defined as including any
unique chemical substance that contains the named metal as part of that
chemical's structure.
Metal compounds present a special case in making threshold
determinations and release estimates. The three cases presented below
illustrate the proper methods for determining thresholds and estimating
releases for metals and metal compounds.
Case 1. A facility processes several antimony compounds. The
threshold determination should be based on the total weight of all
antimony compounds processed. If the threshold is exceeded, the
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facility should file a report for antimony compounds. Release
estimates are then based only on the amount of parent metal (in this
case, antimony) released.
Case, 2. A facility processes antimony. The threshold determination
should be based on the total weight of antimony processed. If the
threshold is exceeded, the facility should file a report for
antimony. Release estimates are then based only on the amount of
parent metal (antimony) released.
Case 3. A facility processes both antimony and antimony compounds.
Two threshold determinations should be completed (one for the parent
metal, one for the metal compound category). If one threshold is
exceeded, a report should be filed for that chemical or chemical
category (either antimony or antimony compounds). If both
thresholds are exceeded, the facility may file two separate reports
OR may combine the information into one joint report for antimony
compounds, including antimony. The release quantity reported, in
either case, is the total amount of parent metal (antimony)
re J.eased.
2.2.3 Sumptions
four classes of exemptions are permitted under SARA Section 313
reporting:
(1) De Minimis Limitations;
(2) Exemptions;
(3) Chemical Use Exemptions; and
(4) Laboratory Activity Exemptions.
The de minimis limitation and the article exemption are described in
Appendix A. Chemical uses which are exempted include:
• Use of chemicals as structural components of the facility;
• Use of chemicals for routine janiCorial or facility grounds
maintenance;
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Table 2-2
SECTION 313 CHEMICAL CATEGORIES
Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds
Chlorophenols
Chromium Compounds
Cobalt Compounds
Copper Compounds
Cyanide Compounds
Glycol Ethers
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Polybrominated Biphenyls (PBBs)
Selenium Compounds
Silver Compounds
Thallium Compounds
Zinc Compounds
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Use of foods, drugs, cosmetics, or other personal items
containing toxic chemicals by employees or'other persons ac a
facility;
• Use of products containing toxic chemicals for the purpose of
maintaining motor vehicles operated by the facility; and
Use of toxic chemicals present in process water and non-contact
cooling water as drawn from the environment or municipal
sources, or present in air used as compressed air or as part of
combustion.
These exempt uses include office supplies, such as "Liquid Paper"1" correction
fluid, as well as gasoline used for the operation of motor vehicles at a
facility.
The laboratory activity exemption states that toxic chemicals used
in a laboratory under the supervision of a technically qualified individual
are exempt from reporting. Examples of exempt laboratory activities include
quality control tests or research. This exemption does not apply to specialty
chemical production or to pilot-scale operations.
2.2.4 Chemical Releases to the Environment On-Site
Reportable releases to the environment include emissions to air,
discharges to receiving streams or water bodies, underground injection, and
on-site releases to land. These releases are described below.
(1) Emissions to Air. All air emissions from a facility are
classified as either fugitive or stack air emissions. Stack
air emissions are released through a point source such as a
stack, vent, duct, or other confined air stream as a directed
air flow. Fugitive air emissions are released through a non-
point source such as an equipment leak or an evaporative loss
from a ventilation system.
(2) Discharges to Water. Discharges to receiving streams and water
bodies include process outfalls, releases from on-site
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wastewater treatment plants, and stormwater runoff. This
category does not include discharges to a publicly owned
treatment work (POTW) or off -site wastewater treatment plane.
(3) Underground Injection. Underground injection includes all
releases of chemicals into injection wells, including Class I
wells. Class I wells include hazardous waste disposal wells or
industrial and municipal disposal wells which inject fluids
beneath the lowermost formation containing an underground
source of drinking water.
On-Site Releases to Land. Releases to land include landfills,
land treatment or application farming, surface impoundments, or
other types of disposal at the facility.
2.2.5 Chemical Transfers to Off-Site Locations
Mixtures containing a reportable chemical may be transferred off-
site to a POTW or to another location for disposal, treatment, or storage.
Quantities transferred for recycling or reuse purposes are not reportable.
For example, a facility uses toluene as a cleaning solvent in its process.
The spent solvent is then transferred off -site for reuse. Therefore, this
transfer is not considered reportable.
2. 3 Additional References
An auditor may use the following publications, in addition to the
reporting instructions, to enhance understanding of the Section 313 program
requirements:
• Toxic Chemical Release Inventory Questions and Answers (EPA
560/4-90-003)
• Estimating Releases and Waste Treatment Efficiencies for the
Toxic Chemical Release Inventory Form (EPA 560/4-88-002)
• Common Synonyms for Section 313 Chemicals (EPA 560/4-90-005)
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• Toxic Chemical Release Inventory: Clarification and Guidance
for the Metal Fabrication Industry (EPA 560/4-90-012)
« Toxic Air Pollutant Emission Factors - A compilation for
selected Air Toxics Compounds and Sources (EPA 450/2-88-006a)
Section 313 Interpretive Guidance System (ASKSAM Database)
Industry-Specific Technical Guidance Documents (EPA 560-4-88-
004 a through 1, p, and q)
Compilation of Air Pollution Emission Factors (AP-42, OAQPS,
Sept. 1985)
Section 313, EPCRA Guidance for Food Processors (EPA 560/4-90-
014)
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3.0 SITE AUDIT PREPARATION
Auditors should thoroughly review all available facility information
available and should conduct an investigation of the industry prior to
visiting a facility. This preparation will increase the auditor's familiarity
with the industry and with the particular plant to be visited. Identification
of discussion topics, such as typical chemicals used at a facility and points
of release in its process system, will maximize time efficiency and will
minimize disruption to the facility.
3.1 Review of Facility Form R Reports
The primary source of information the auditor needs to review is the
Form R chemical report(s) submitted by a facility to EPA. Each Form R report
contains three types of information: facility identification data, off-site
location data, and chemical-specific data. A blank Form R report is shown in
Appendix B.
3.1.1 Facility Identification Data (Part I)
A facility's Standard Industrial Classification (SIC) Code(s) are
listed in Section 3.5 of the Form R report. The 4-digit SIC Code indicates
the primary products manufactured at a facility. This information is
beneficial during investigation of the industry to identify typical
manufacturing operations that may occur at a particular facility. If a
facility is not included in SIC Code(s) 20 through 39, it is not required to
report.
Auditors should note if a facility entered an EPA Identification
Number (Section 3.8), a National Pollutant Discharge Elimination System
(NPDES) Permit Number (Section 3.9), or an Underground Injection Well Code
(UIC) Identification Number (Section 3.11) on the Form R report. A facility
is required to enter its EPA identification number, if one is assigned to it
under the Resource Conservation and Recovery Act (RCRA), and to list all
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permits assigned under the NPDES program. A listed permit number does not
necessarily mean a facility releases a Section 313 toxic chemical to that
medium. A facility is required to list only UIC permits for Class I deep
wells to which 313 chemicals were injected; however, a UIC number may not be
available if the injection well is not of a regulated class.
Information that can be reviewed for the facility are reports
submitted to State and USEPA. An auditor should use the checklist in
Table 3-1 to identify other facility information that should be available for
review.
3.1.2 Chemical-Specific Information (Part III)
Auditors should thoroughly review all information contained in the
chemical-specific part of the Form R report. It is helpful to prepare a
facility rummary matrix outlining the chemicals and the releases reported by a
facility. This matrix may then be used during the on-site audit. An example
of this format is presented in Table 3-2.
Th; auditor should then prepare a list of questions to resolve with
the facility contact during the site audit. These questions typically seek to
clarify vh-jn .er or not a facility mistakenly misinterpreted the reporting
instructions when reporting releases to the environment. For example, several
items in Tib}i 3-2 may require clarification. These include:
• Whether any material sent off-site was recycled or reused;
• Whether any chemical was used in a process or operation that
would cause it to become volatile;
a • Whether discharges to the receiving stream were between pH 6
and pH 9; and
• Whether releases reported for lead compounds only include the
parent metal.
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Table 3-1
REGULATORY DATA CHECKLIST
Data Regulatory Authority
NPDES Permit and Permit Applications CWA
Discharge Monitoring Reports CWA
Pretreatment Standards Permit State or local
Air Emissions and Permit Applications or CAA or State
Air Emissions Inventory Data
Hazardous Waste Records Maintained Pursuant RCRA
to RCRA Requirements, such as Manifests,
Part B Permits, Biennial Reports, etc.
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Table 3-2
EXAMPLE OF FACILITY SUMMARY MATRIX
313 Chemical Use
Toluene U
Hydrochloric U
Acid
Lead P
Compounds
fugitive
10,000
1-499
0
Stack
10,000
0
2,500
Receiving
Stream
0
200
50
Under-
ground
Injection
0
0
0
On- Site
land
0
0
1,000
POTW
0
0
0
Other
Off-Site
Locations
500
0
20,000
Maximum
Amount
On-Site
5,000
2,000
10,000
UJ
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3.2 Industry Investigation
Before the site visit, auditors should complete a study of the
manufacturing process performed at the facility. The following information
should be identified:
• Chemicals used in the process;
• Areas of the process where chemical releases may occur;
• Wastes generated during the process; and
• Typical treatment of the wastes generated.
Auditors should use the 4-digit SIC Code(s) and the description of processes
given by the technical representative to begin the industry investigation. A
chemical encyclopedia such as Kirk-Othmer's Encyclopedia of Chemical
Technology may be used to become more familiar with a. particular industry or
industrial process. Industry-specific guidance documents published by EPA for
use in EPCRA Section 313 reporting are listed in Table 3-3. Auditors should
also review past years' Toxic Release Inventory (TRI) output for the relevant
SIC code(s). Auditors should obtain a list of Section 313 listed chemicals
typically used or generated in the manufacturing or treatment processes of
interest to the facility. This list will help auditors identify chemicals
during the facility tour and audit that facility personnel may have
overlooked.
Auditors should gather chemical specific-information which may be
needed to make on-site calculations, or to determine where releases may occur.
This information includes the following chemical properties:
• Volatility/vapor pressure;
• Solubility;
• Henry's law constant (for dilute compounds);
• Specific gravity/density;
• Molecular weight; and
• Fate of chemical in solution.
Many methods of estimating releases, such as those detailed in Estimating
Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form (EPA 560/4-88-002) also known as the "Green Book," require the
use of such parameters in order to complete release calculations. Some
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Table 3-3
EPA GUIDANCE DOCUMENTS FOR INDUSTRY INVESTIGATIONS
Title III Section 313 Release Reporting Guidance, EPA 560/4-88-004 a through
1, p and q, Estimating Chemical Releases from:
a. Monofilament Fiber Manufacturing
b. Printing Operations
c. Electrodeposition of Organic Coatings
d. Spray Application of Organic Coatings
e. Semiconductor Manufacture
f. Formulating Aqueous Solutions
g. Electroplating Operations
h. Textile Dyeing
i. Presswood and Laminated Wood Products Manufacturing
j. Roller, Knife, and Gravure Coating Operations
k. Paper and Paperboard Production
1. Leather Tanning and Finishing Processes
p. Wood Preserving
q. Rubber Production and Compounding
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chemical properties may also dictate where an auditor looks for releases. For
example, if a particular chemical is highly volatile, the auditor should look
closely at air release estimates.
Understanding typical industrial uses and typical storage practices
of a particular chemical is also helpful. This information can be found in a
standard chemical dictionary such as The Condensed Chemical Dictionary
published by the Van Nostrand Reinhold Company. Auditors need to become
familiar with the treatment technologies used in the industry, and if time and
resources allow, need to investigate the efficiencies of different treatment
units.
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4.0 SITE AUDIT
A sice audit will cake 1-2 days on-sice to complete depending on the
size and complexity of a facility and the nature of the audit program. While
on-site, auditors should review all submitted data and supporting materials
the faci! ity has available from its EPCRA Section 313 reporting. Auditors
should document all calculations and assumptions on the audit checklist, which
is included in Appendix C. Specific instructions for completing the audit
checklist are provided in Sections 4.1 and 4.2.
Please note that Sections 1.0 and 2.0 of the checklist are completed
once for each facility, Section 3.0 is completed for every § 313 chemical
identified .at the facility by the auditor, and Sections 4.0 through 6.0 are
completed for every § 313 chemical which meets the reporting requirements. An
appropriate number of copies of Sections 3.0 through 6.0 should be made by the
auditor prior to the audit.
4.1 P*. e-visit Completion of the Audit Checklist
Unless the intention of the audit program is to conduct an
unannounced visit, it is beneficial for the auditor to contact the technical
representative of a facility prior to the audit. Auditors should complete
Section ',.0 of the audit checklist at this time. Topics to be discussed with
the facility contact include a technical review of the facility as well as the
logistics of the site visit.
4.1.1 Technical Review
Question 1.1. Ask the facility contact how many Form R
chemical reports were submitted for the reporting year.
Confirm that this is the number of reports you received for the
facility.
Question 1.2. Ask the facility contact how many Section 313
chemicals were identified as being at the facility during the
reporting year, but do not include chemicals which were
reported. This will help you estimate the level of effort
needed to complete the audit for this facility. Remember to
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bring enough copies of Section 3.0 of the checklist for each
§ 313 chemical at the facility (including those the facility
may have overlooked).
Question 1.3. If the facility submitted revised reports for
the reporting year, confirm whether or not you have the most
updated version. If you do not, either request the new
information over the phone or ask the facility to have the new
data available at the time of the visit. Review the amended
Form R report(s) and determine the reason for the amendment.
Question 1.4. List all chemicals which had revised chemical
reports.
Question 1.5. Full-time equivalent employees is equal to the
number of hours worked by employees divided by 2,000 (i.e., two
part-time employees working 1,000 hours per year each are
equivalent to one full-time employee). Remember, if the
facility had less than 10 full-time employees, it was not
required to report.
Question 1.6. Ask the facility contact to describe the major
industrial processes performed at the facility during the
reporting year. This will help you prepare for the site visit
by becoming familiar with these processes prior to visiting the
facility.
Questions 1.7-1.10. These questions will help you evaluate the
current state of operations that you will observe during the
facility tour and how it relates to the facility's Form R
report data.
4.1.2 Supplier Notification
Question 1.11. Document if the facility received the
appropriate notification from it's supplier(s) regarding
mixtures containing § 313 chemicals.
Question 1.12. Record the names and addresses of any suppliers
that did not provide notification to the facility.
Queation 1.13. Record whether or not the facility distributed
mixtures containing § 313 chemicals during the reporting year.
Question 1.14. If the facility distributed mixtures containing
§ 313 chemicals, record if it developed and distributed the
appropriate information to its customers. Ask to see an
example of the information distributed.
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4.1.3
Logistics
• Question 1.5. Clarify with the facility contact whether or no:
the facility will be operating under normal conditions and if
there will be any problems with a tour of the facility.
• Question 1.6. Identify any personal protective equipment (PPE)
you will need in order to participate in a facility tour.
• Question 1.7. This question will give you an idea of the size
of the facility and how long a tour may take to complete. At
larger facilities, make it clear to the facility contact that
the tour should cover the major processing areas.
• Question 1.18. Document the procedures used by the facility to
collect and process information for EPCRA § 313 reporting.
Note the number of people involved in calculating the amounts
of chemical manufactured, processed, and otherwise used in
calculating release estimates. Clarify whether or not these
people will be available during the audit to answer questions.
• Questions 1.19-1.21. Ask the facility contact to recommend a
hotel near the facility if an overnight stay is required. Be
sure you have directions to the facility and a set time to meet
the facility contact.
Finally, clarify with the facility contact that all supporting materials used
to develop information contained within the Form R chemical reports must be
available for review. In addition, request that copies of process flow
diagrams be available at the time of the visit.
4.2
Completion of the Audit Checklist
The audit checklist is intended to be stand alone documentation of
each EPCRA, Section 313 audit. All information pertaining to the facility,
its processes, and the completion of its Form R chemical reports must be
documented on or attached to the checklist.
4.2.1
Arrival and Entry Procedures
Arrival and entry procedures should be followed as outlined in the
EPCRA Section 313 Inspection Manual. These procedures include arriving at the
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facility during normal working hours and presenting your credentials and, as
appropriate, Notice of Inspection to the proper facility official.
4.2.2 Kick-off Meeting
On arrival at the site, meet with the facility's representative(s)
to briefly discuss the purpose of the audit program and to review the agenda
for the visit. Respond to any questions the facility may have at this time
regarding the audit. If possible, obtain copies of process flow diagrams for
use during the audit.
4.2.3 Facility Tour
Before beginning the facility tour, review all processes with the
representative and go over any changes that have occurred since the reporting
year. Ask questions identified during the pre-visit review of the facility's
Form R reports and identify any Section 313 chemicals manufactured, processed,
or used at the facility that were not reported.
Complete Section 2.0 of the audit checklist, Introduction and
Facility Tour, at this time.
• Question 2.1. Record all Section 313 chemicals reported by the
facility here. If the facility reported a chemical category,
such as "Lead compounds," enter NA in the first two boxes of
the Chemical Abstract Service (CAS) number. Sections 3.0
through 6.0 of the SI must be completed for each chemical
listed here.
If the facility reported a chemical which is not included in
the Section 313 list of toxic chemicals, check the box
indicating the chemical is not a 313 chemical. This would
include a chemical reported which is listed with a qualifier
and the facility does not use it in the listed form. For
example, isopropyl alcohol is a listed chemical with the
qualifier "manufacturing-strong acid process." Only facilities
which manufacture isopropyl alcohol by the strong acid process
should report it as a Section 313 chemical.
• Question 2.2. Record all chemicals documented by the facility
for Section 313 reporting, which did not have Form R chemical
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reports submitted. If the chemical is not included in the
Section 313 list, check the box indicating the chemical is not
a Section 313 chemical. Section 3.0 of the checklist must be
completed for each chemical listed here.
• Question 2.3. Record all other Section 313 chemicals
identified by the auditor during the audit. Section 3.0 of the
checklist must be completed for each chemical listed here.
« Question 2.4. Record all mixtures identified during the audit
which may contain § 313 chemicals in column a. Follow-up on
mixtures which are identified during the facility tour to
determine if a § 313 chemical is present. This is done by
reviewing the material safety data sheet (MSDS) to verify the
constituents of the mixture and to record concentrations of any
§ 313 chemical in the mixture. Record these data in columns b
and c. Complete columns d and e during the threshold
determination in Section 3.0.
The remainder of Section 2.0 is for use during the facility tour.
During the tour of the facility, focus on areas where Section 313
chemicals are used in process lines and treatment areas. Sketch process
diagram(s) if none are available from the facility. In particular, identify
areas where releases could occur in the facility (e.g., drains, exhaust fans,
vents, ducts, etc.), keeping in mind the following items:
• Housekeeping practices;
• Method(s)of receiving and unloading chemicals;
• Storage practices;
• Disposal methods(s);
• Use(s) of each Section 313 chemical; and
• Waste treatment and pollution control devices.
Record descriptions and document how each Section 313 chemical is used to
determine its activity classification (i.e., manufactured, processed, or
otherwise used). Finally, document what types of control methods are utilized
at the facility. Make a. qualitative assessment of their efficiency by
observing their operation and then recording these observations in Section 2.0
of the audit checklist. For example, a degreasing unit which is open to the
atmosphere would release a greater amount of solvent to the air than a unit
with a solvent recovery system.
4-5
-------
4.2.4 Review of Section 313 Chemicals
Complete Sections 3.0 through 6.0 of the audit checklist for each
Section 313 chemical manufactured, processed, or otherwise used at the
facility which meets the requirements for reporting. Complete Section 3.0 of
the survey instrument for every Section 313 chemical used by the facility.
Document all calculations and assumptions on the appropriate worksheets in
Section 6.0. Calculations should be reproducible by a reviewer unfamiliar
with the facility. Collect supporting documents for responses on the
checklist for use as evidence in any potential enforcement actions.
Section 3.0: Review of Threshold Determination
Section 3.0 reviews the facility's decision to report a chemical,
including the activities of the chemical and the amount used. Be sure and
record the chemical name at the top of the page.
• Question 3.1. Check all the ways the facility indicated the
chemical is employed at the facility in the right hand column.
Obtain the facility's documentation to establish the quantities
employed. In addition, based on the facility tour and process
diagrams, establish your own use determinations and record your
answer in the reviewer column.
If the chemical was present as an impurity, be sure to document
the percent concentration. If a chemical is only present below
de minimis concentrations (0.1% for carcinogens, 1.0% for all
others), it is exempt from reporting. The de minimis exemption
only applies to toxic chemicals in mixtures and products. It
does not apply to chemicals in waste streams from manufacturing
processes or to chemicals which undergo intentional
benefication.
Note: activities n through s are exempt from reporting. Do
not include these activities in threshold or release estimates.
Record the activity classification the facility established for
this chemical in the left-hand column. Document your own
activity classification of the chemical and record your answer
in the reviewer column.
• Questions 3.2 and 3.2.1. Indicate whether this chemical was
reported by the facility. If it was, skip to Question 3.3. If
4-6
-------
it was not, record in Q 3.2.1 why the facility felt this
chemical was not reportable.
Question 3.3. Document whether or not this chemical is exempt
from reporting. The chemical is exempt if it is contained in
an article that is processed or used at the facility or if all
of its activities are exempted uses.
Questions 3.4 and 3.4.1: Determine whether or not the facility
has supporting documentation available on the threshold
determination for this chemical and obtain copies. If
documentation is unavailable, check the reason in Q 3.4.1 which
most closely describes why not.
Question 3.5: Determine what information the facility used to
estimate the amount of chemical manufactured, processed, or
otherwise used and record the estimation approach used. Keep
in mind that more than one approach may apply.
Question 3.6. Review the facility's documentation of the
threshold determination for this chemical. Record the amount
of chemical used for each type of activity as documented by the
facility in the facility column. If the facility did not
estimate these quantities, check box d. If there is not enough
information available to estimate quantities, check box e.
Complete question 2.4, located in Section 2.0 of the audit
checklist. Information for column c, "Concentration of
Chemical," can be retrieved from the USDS for the mixture.
Column d information, "Amount of Mixture Used for Year," can be
determined from facility documentation, including purchase and
inventory records. Calculate column e data, "Amount of
Section 313 Chemical Used," by multiplying column c by
column d.
Complete the threshold determination worksheet in Section 6.0.
Enter a description for each use of the chemical at the
facility. Record the amount of chemical used in the
appropriate activity column. If the chemical was not used for
a particular activity, enter zero.
Question 3.7. The reviewer should be able to recalculate the
threshold determination using available documentation from the
facility if no new data is introduced into the calculation.
Check box a if the reviewer's value is within a factor of 2 of
the facility's value. Check box b if it is within a factor of
10, and box c if it is not within a factor of 10.
The reviewer must recreate the threshold determination if the
facility has no documentation available or if the reviewer is
aware of additional, more accurate information to use. This
information must have been available to the facility at the
4-7
-------
time of reporting. Obtain copies of all documentation that
were available to a facility showing that an unreported
chemical exceeded the threshold. Check box d if the reviewer's
value is within a factor of 2 of the facility's value. Check
box e if it is within a factor of 10, and box f if it is not
within a factor of 10.
If the facility overlooked this chemical, check box g.
Question 3.8. Document if a threshold is exceeded from the
chemical amounts listed in the reviewer column of Question 3.6.
If either the "manufactured" or "processed" value'is greater
than 25,000 pounds, or if the "otherwise used" value is greater
than 10,000 pounds, a threshold is exceeded.
If a threshold is not exceeded, skip to Question 3.10.
Question 3.9. Record and document the maximum amount of this
chemical on-site at any time during the reporting year. The
facility value is obtained from the Form R report and/or from
facility documentation. The reviewer value should be
calculated on the worksheet in Section 6.0 and then recorded in
the reviewer column.
Question 3.10. Indicate whether this chemical was:
Correctly included. Chemical was reported by the
facility, is not exempt, and exceeded the applicable
threshold limit. Go to Section 4.0.
Correctly omitted. Chemical was not reported by the
facility, and is either exempt or did not exceed the
applicable threshold limit. Go to the next chemical.
Incorrectly included. Chemical was reported by the
facility, but is either exempt or did not exceed the
applicable threshold limit. Continue to question 3.11.
Incorrectly omitted. Chemical was not reported, but is
not exempt and exceeds the applicable threshold limit. Go
to Question 3.12.
Question 3.11: Record the reason given by the facility which
most closely describes why this chemical was reported.
Although the facility was aware this chemical did not
exceed the threshold limit, it was reported anyway "to be
safe."
The facility incorrectly assumed a threshold limit was
exceeded (i.e., did not complete a calculation).
4-8
-------
The facility misclassified the chemical activity as
"otherwise used," when it is really "processed" or
"manufactured."
The facility made a calculation error while determining
the threshold quantity, which resulted in the chemical
exceeding a threshold limit.
The facility reported the chemical because a threshold
limit was exceeded. However, all uses of the chemical are
exempt and therefore are nonreportable.
Any other reason not previously described. Be thorough,
but brief, in your description.
Go to the next chemical.
• Question 3.12. Record the reason given by the facility which
most closely describes why this chemical was not reported.
The facility overlooked the activity of a chemical as
being "manufactured," "processed," or "otherwise used."
Examples include:
Manufacturing by-products;
Wastewater treatment by-products;
Wastewater treatment chemicals; and
Cleaning chemicals.
The facility misclassified the chemical activity as
"processed" or "manufactured," when it is really
"otherwise used."
The facility made a calculation error while determining
the threshold quantity, which did not exceed a threshold
limit.
Any other reason not previously described. Be thorough,
but brief, in your description.
Continue with this chemical to Section 4.0
Section 4.0: Review of Release Estimates
Section 4.0 contains questions which describe the type of
information used by the facility to estimate releases of a chemical by medium
(e.g., fugitive air, receiving stream, etc.). This section must be completed
for every chemical that meets the reporting requirements for Section 313.
4-9
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Answer each question for each release medium at the facility. For example, if
a facility does not have an underground injection well, do not complete the
underground injection column. Use the codes on the Section 4.0 code list to
answer each question.
• Question I. Obtain the facility's supporting documentation on
each release estimate available for this chemical. If
documentation is unavailable, enter the code for the reason
which most closely describes why not. If the facility
overlooked this chemical, enter N4 and skip to Section 4.1.
• Question 2. If the facility used monitoring data to develop
any release estimates, record and document the reason for
whether or not the data are available for review. If
monitoring data were not used, enter NA. Obtain copies of the
available data.
• Question 3. If the facility recorded a value in the percent
from stormwater column (question 5.C. on the Form R report),
record and document the reason for whether or not the data are
available for review.
• Question 4. Record and document the source of any emission
factors used by the facility to develop release estimates. If
emission factors were not used, enter NA.
• Question 5. Record whether or not each air or waste stream
which contributed to the release estimates was only counted
once. Any streams which were double-counted must be documented
in the release calculations in Section 6.0. An example of
double counting would be reporting releases vented from a spray
booth that are also reported as building fugitive emissions.
• Question 6. Record and document whether or not air or waste
streams containing <1% of the chemical were included in release
calculations. If they were not included by the facility, enter
the code to explain why not. If the facility does not have any
air streams containing <1% of the chemical, enter NA.
• Question 7. Record and document whether or not on-site
treatment of the chemical is included in the facility's release
estimate(s). If it was not included, enter the code to explain
why not. If the facility does not treat streams containing
this chemical, enter NA.
• Question 8. If the facility reported sequential treatment,
record and document whether or not the efficiency was based on
overall treatment of the chemical.
4-10
-------
• Question 9. Record and document whether or not treatment
efficiencies used by the facility were consistent with vendor
specifications or with EPA published efficiencies. Compare
efficiencies recorded on the facility's Form R report with
literature values before the site visit. Any inconsistencies
should be discussed with the facility representative during the
survey and documented in Section 6.0. If the facility did not
use treatment efficiencies in the release determination, enter
NA.
Section 4.1: Sources of Chemical Releases and Transfers
Section 4.1 is designed to sununarize information on the sources of
chemical release or transfer considered by the facility for each release
estimate. For each release medium, indicate whether or not the source of
release was:
Y - Considered in release estimate;
N - Overlooked in release estimate; or
NA - Not present at the facility for the chemical and medium.
This section is intended to guide the reviewer through Section 5.0
calculations. Please note that the shaded areas of the matrix should not be
completed.
Section 5.0: Summary of Release Estimates
Section 5.0 is designed to summarize both the facility and auditor
release estimate for each medium and the method(s) used to estimate each.
When entering the release estimate for a. particular medium, sum each
occurrence of the release type. For example, the facility may release a
chemical to two or more receiving streams. The amount in each should be added
and the total recorded in the appropriate column.
• Question 1. Document the facility's release estimates for each
medium, which were reported on the Form R. If the facility did
not report a release, enter zero.
4-11
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Question 2. Enter the code for the method(s) that was actual!1/
used by the facility to estimate each release. This may not
necessarily be what the facility reported on the Form R
chemical report.
Monitoring data. Estimate is based on monitoring data or
on measurements for the toxic chemical as released to the
environment and/or off-site facility.
Mass balance. Estimate is based on mass balance
calculations, such as a calculation of the amount of the
toxic chemical in streams entering and leaving process
equipment.
Emission factors. Estimate is based on published emission
factors, such as those relating release quantity to
through-put or equipment type.
Engineering judgment. Estimate is based on engineering
calculations (e.g., estimating volatilization using
published mathematical formulas) or best engineering
judgment. This includes applying an estimated removal
efficiency to a waste stream, even if the composition of
the stream before treatment was fully characterized by
monitoring data.
Question 3. After reviewing the facility's documentation for
this release estimate, record whether or not the facility used
the best method for determining the release. Remember that the
four primary methods are monitoring data, mass balance,
emission factors, and engineering judgment. To decide if one
method is better than another, it is necessary to evaluate the
type and quality of data available to the facility at the time
of reporting.
. If the facility used the best method based on available data,
skip to Question 6.
Question 4. Record the method you feel would be better based
on available data to the facility. Be sure and document
thoroughly in Section 6.0 why this method is a more accurate
one for this facility.
Question 5. Using the preferred method stated in Question 3,
calculate a new release estimate for the facility on the
worksheet in Section 6.0 and record your answer here. Be sure
to calculate fugitive and stack release estimates separately.
Question 6. Using the same method as the facility, recalculate
the release estimates on the worksheet in Section 6.0 and
record your answer here. Be sure and calculate fugitive and
stack release estimates separately. If the facility had no
4-12"
-------
documentation and the reviewer is unable to recreate the
estimate, enter "Unknown."
Section 6.0: Calculations
Section 6.0 contains worksheets for completing the following
calculations:
• Threshold Determination;
• Maximum On-Site; and
• Release Estimates.
Please document all assumptions made during calculations. Record and document
the basis for your conclusion the facility's reported release is accurate or
inaccurate. A second reviewer, not necessarily familiar with the facility,
should be able to recreate your calculations.
4.3
Closing Conference
A.<: the completion of the audit, summarize your observations.
However, do not draw any conclusions concerning the facility's compliance or
non-compliance. A final meeting with the facility officials will enable the
inspector to "wrap-up" an inspection. Necessary receipts for document should
be prepare-1 :.o later than this time, and information gaps should be resolved:
either 'b* ob' aining the necessary information or written promise that the
information will be forthcoming.
Since the inspector is often the only contact between the Agency and
the regulated industries, he should be acutely aware of opportunities to
maintain and improve Agency -Indus try relations. The closing conference
pro%-ides an ideal opportunity to offer various kinds of help to facility
officials.
It is very important for the inspector — as an industry relations
representative --to follow up all referrals and offers for help. A letter,
telephone call, or repeat visit will indicate to facility officials a genuine
4-13
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interest on the part of the Agency. Such an expression of interest will
immeasurably aid in the Agency's industry relations and voluntary compliance
program.
0-»j~ _ v • -. v'' * I : •'' '*-"v ° »
\'; ' '.. - .'ja Agency
^- '• ' -' • ,V3
40i "• -.- .:; -.. Lr;J
-------
APPENDIX A
DEFINITIONS
-------
ARTICLE'
An article is defined as a manufactured item that is formed to a
specific shape or design during manufacture, that has end-use functions
dependent in whole or in part upon its shape or design during end-use, and
that does not release a toxic chemical under normal conditions of the process-
ing or use of that item at the facility or establishments.
DEMINIMIS LIMITATION2
The de minimis level is 1.0% by mass of a chemical in a mixture, or
0.1% if the chemical meets the OSHA carcinogen standard. If a toxic chemical
is present'in a mixture below de minirais levels, the quantity of chemical in
that mixture is exempt from both threshold and release determinations.
Please note that this exemption applies to toxic chemicals present
in mixtures and products. It does not apply to chemicals in wastestreams from
manufacturing processes or chemicals which undergo intentional benefication.
DOCUMENTATION2
A facility is supposed to keep a copy of each report completed. In
addition, it is supposed to keep the supporting materials used to develop the
information contained in the report. These records are supposed to be kept at
the facility for a. period of three years from the date of the submission and
are supposed to be readily available for inspection by EPA.
'Defined in 40 CFR 372.3.
Explained in Toxic Chemical Release Inventory Reporting Form R and
Instructions (EPA 560/4-90-001).
-------
FACILITY1
A facility is defined as "all buildings, equipment, structures, and
other stationary items which are located on a single site or on contiguous or
adjacent sites and which are owned or operated by the same person."
FULL-TIME EMPLOYEE1
A "full-time employee" is defined as 2000 work hours per year.
IMPORT1
"Import" means to cause a chemical to be imported into the customs
territory of the United States. In this definition, "to cause" means to
intend that, the chemical be imported and to control the identity of the
imported chemical and amount to be imported.
IMPURITY*
A chemical present as an impurity is produced coincidentally as a
result of the manufacture, processing, or use of another chemical but remains
primarily in the mixture or product with that other chemical.
MANUFACTURE1
"Manufacture" means "to produce, prepare, import, or compound a
toxic chemical." This definition includes toxic chemicals produced
coincidentally during the manufacture, processing, use or disposal of another
chemical or mixture.
'Defined in 40 CFR 372.3.
Explained in Toxic Chemical Release Inventory Reporting Form R and
Instructions (EPA 560/4-90-001).
-------
MIXTURE'
A mixture is "any combination of two or more chemicals, if the
combination is not, in whole or in part, the result of a chemical reaction.
However, if a combination was produced with a chemical reaction but could have
been produced without a chemical reaction, it is also treated as a mixture."
OTHERWISE USE1
"Otherwise use" or "use" is defined as any use of a toxic chemical
not covered by the terms "manufacture" or "process" and includes non-
incorporative-type activities.
PROCESS'
A chemical is processed if it is prepared for distribution in
commerce after its manufacture. Processing includes preparation in the same
chemical form or physical state as that received by the facility, or
preparation which produces a change in chemical form or physical state. This
also applies to listed chemicals contained in mixtures or trade name products.
RELEASE'
A release is any "spilling, leaking, pumping, pouring, emitting,
emptying, discharging, injecting, escaping, leaching, dumping, or disposing
into the environment (including the abandonment or discarding of barrels,
containers, and other closed receptacles) of any toxic chemical."
'Defined in 40 CFR 372.3.
-------
TECHNICALLY QUALIFIED INDIVIDUAL3
A "technically qualified individual" means a person or persons (1)
who, because of education, training, or experience, or a combination of these
factors, is capable of understanding the health and environmental risks
associated with the chemical substance which is used under his or her
supervision, (2) who is responsible for enforcing appropriate methods of
conducting scientific experimentation, analysis, or chemical research to
minimize such risks, and (3) who is responsible for the safety assessments and
clearances related to the procurement, storage, use, and disposal of the
chemical substance as may be appropriate or required within the scope of
conducting a research and development activity.
THRESHOLD4
Section 313 sets reporting threshold quantities dependent on the
activity of a chemical and the year for which a report is submitted. A report
must be submitted for a chemical if the quantity manufactured, processed, or
otherwise used exceeds the threshold. The thresholds are as follows:
1989 and
1987 1988 Subsequent Years
Manufactured 75,000 Ibs 50,000 Ibs 25,000 Ibs
Processed 75,000 Ibs 50,000 Ibs 25,000 Ibs
Otherwise Used 10,000 Ibs 10,000 Ibs 10,000 Ibs
The threshold applies to the annual throughout of the chemical and
not the amount stored on site.
'Defined in 40 CFR 720.3(ee).
'Defined in 40 CFR 372.25.
-------
APPENDIX B
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM R
-------
_l
frnportant: Type or print: read instructions before completing forrn.)
Form Approved QMS No : :0"0-0093
Aporoval Expires :__li_Ll__
U.S. Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Rlght-to-Know Act of 1986.
also known aa Title III of tne Suoerfund Amendments and Reauthonzatlon Act
EPA FORM
PART I.
FACILITY
IDENTIFICATION
INFORMATION
(This space for your optional use.)
Collection o' m'ormat.on I MM— ai»C '3
vary trom 30 lo 34 rxxjrt s<
an average of 32 -q
instructions. saarc-'^g e«i:
source*. gatnar.ng ana -r-a ":
Cata -«»o«c arc zor-s'
'evewing tne coi'eciior* Df -rcr"-i' cr
S«no comments -egarcmg :rv» Dur2«n
estimate or ary otier afoect o? •"•«
collection of -n'orn^ation. °c -c.."g
luqoettions for reouonq tnu Dc.rc»n :o
Chief nformation ^oiicv 3*a^cr
(PM-2231. US EPA. 40! M St S.v
Wainington. 0 C 20460 *r:n " = •
Suroen ana to tne Office of nicr-^at'on
ana Regulatory Attain. C" ce e'
Management ana Budget =aoen~on<
Reauction °roiect 2070-00931
Wasnington. O.C. 20603.
1.
. 1 Are you claiming tne cnemical loantity on oage 3 traoe tecret?
J No (Do not answer 12:
Go to question i 3 ]
[ J Vet (Answer Question 12:
Attaen suBstintmien forms.)
1.2 if " Vet" m 1.1, n tnu cooy:
[ j Sanitliea [ J Unsanitu
1 . 3 Reoorting Y»ar
19
2. CERTIFICATION (Read and sign after completing ail sections.)
I hereby certify that I have revieweo the attached Documents ana that, to tne beat of my Knowledge and belief, the submitted information is true and
complete and that the amounts ana values in this report a/e accurate eased on reasonable estimates using data avanaoie to tne oreoareri of ;~:f ••port
Name and official title of owner/coerator or senior management official
Signature
Oat* signed
3. FACILITY IDENTIFICATION
3.1
Facility or Establishment Name
Street AOdress
City
State
County
Zip Co
THI Facility Identification Number
WHERE TO SEND COMPLETED FORMS:
1. EPCRA REPORTING CENTER
P.O. BOX 23779
WASHINGTON. DC 20028-3779
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE (S«« instru
in Appendix G)
3.2
This recort contains information for (Check only one I:
I An entire facility
b. [ j Part of a facility.
3.3
Technical Contact
Telepnone Number (include area cooei
3.4
Public Contact
Teleonone Number (include area cooei
3.5
SIC Cod* (4 digit)
a.
b.
d.
Latitude
Longitude
3.6
Degree*
Minute*
Second!
Degree.
Minute*
Seconds
3.7
Dun & SraottnMt Number(t)
a.
3.8
EPA identification Numeer(*> (P.CAA i.O. NO. )
3.9
NPOES Permit NumMrd)
a.
Receiving Stream* or Water Bodlet (enter one name oer box)
3.10
3.11
Underground ln|ecticn Well Code (LXC) Uentifitatian Numeerisl
4. PARENT COMPANY INFORMATION
4.1
Name of Parent Company
42
Parent Company't Dun A Bradttreet Number
EPA Form 9350-1 11-901 Revteed - Do not use prevtou*. versions.
-------
D
'Important: Type or print; read
instructions before completing form. >
rj (This soace for your ootionai jse
rt CD A EPA FORM PI
t* tKA PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.1 POTW nam*
Street Aoare**
City
State
County
Zip
1.2 POTW nam*
Street Aoarcti
City County
State Zip
2. OTHER OFF-SITE LOCATIONS (DO NOT REPORT LOCATIONS TO WHICH WASTES ARE SENT ONLY FOR RECYCLING OR RgusEi.
2.1 Off-tit* location nam*
EPA identification Numoer (RCRA fO. No. )
Street Addreo
City
State
I* location unoer control of reporting facility
County
Zip
or parent company?
2.2 Off-tit* location nam*
EPA identification Numoer (RCRA lO. No. )
Street Aodre**
City County
State Zip
I* location under control of reporting facility or parent company?
2.3 Off-tit* location nam*
2.4 Off-tit* location nam*
EPA identification Numoer (RCRA ID. No.)
EPA identification Numoer (RCRA lO. No.)
Street Addre**
Street Adore**
City
County
City
County
State
ZIP
State
Zip
I* location unoer control of reporting facility or parent company?
[ ]v.a [ ],
I* location under control of reporting facility or parent company?
[
[ IN
2.5 Off-alt* location nam*
2.6 Off-alt* location nam*
EPA identification Numoer (RCRA O. No.)
EPA identification Numoer iRCRA O. No.)
Street Aoorett
Street Adore**
City
County
City
County
State
Zip
State
Zip
If location unoer control of reporting facility or parent oomoany?
[ U [ ]
I* location unoer control of reporting facility or parent company?
I U
No
Check if additional page* of Part 8 an; ai;»anM-. xo»
EPA Form 9350-1 (1-90) R*via*d - Do not ua* pr*v
-------
_!
Important: Type or print: read instructions before completing form.)
Page 3 o'
A EPA
EPA FORM R
PART III. CHEMICAL-SPECIFIC INFORMATION
(This soace (or your cotionai u
1. CHEMICAL lOENTITYlDo not comoiete tnis section if you comoiete Section 2.1
(Reserveal
1.2
CAS Number (Em»r ooiy oo« numo«r •xactly a* it aocwari on tn« 313 Hit. Entar NA if raooning a cn«mtc«i category.
1.3
Chemical or Chemical Category Nam* (Enter oniy on* nam« exactly a* it aoouri an tn« 313 n«t. i
1.4
Generic Chemical Name (Complete oniy il Pan I. Section 1.1 < cnecxed "Yee." Generic name mutt o» itructuraiiy ae«cnotive.
MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1.
2.
Generic Cnemical N«m« Prov.o«o Oy Suoon«r (Limit tn« n«m« to •
of 70 cn«r«ct«ri («.g., tximew*. i«tt«rt. io«c«*. ounctuationi )
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
Manufacture the
chemical:
a. I J Produce
b, I J Import
if produce or import:
f 1 For on-slte
C-L J use/processing
e.[ J As a byproduct
f 1 For sale/
d-l J distribution
f. I J As an impurity
A. Total Release
(pounds/year)
A.1
Reporting Ranges
0 1-490 SOO-009
3.2
Process the
chemical:
a. [ J As a reactant
d-[ J Repackaging onty
b.
f 1 As a formulation
component
f 1 As an article
3.3
Otherwise us*
th* chemical:
f 1 As a chemical
a I J processing aid
4. MAXIMUM AMOUNT OF THE CHEMICAL ON-SITE AT ANY TIME DURING THE CALENDAR YEAR
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
You may report releases of less than
1.000 pounds by checking ranges under A. 1.
(Do not use both A.1 and A.2)
S.1 Fugltlv* or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to receiving e . I )
• traam* or water bedlam '••'•' I——I
(Enter letter cod* for ftnMrn
from Part i SectioB«ltOMeas O'.5:3.
the box ' '
5.4 Underground Injection on-slt*
5.5 R*l*aa*e to
5.5.1 Lanolin
5.5.2 Lmnd tr«atrr*nt/aopilcatlon farming
5.5.3 Surtae* impoundmant
5.5.4 Oth» dltootal
[ J (Check It additional information ia providea on Part lV-8uOO*«rn«ntai information. I
EPA Form 9350-1 (1-90) Revised - Do not us* previous version*.
-------
•'Important: Type or print: read instructions before completing form..
= 338 -I
dEPA
EPA FORMR
PART III. CHEMICAL-SPECIFIC INFORMATION
(continued)
(This space for your octionai '-sa
6. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report transfers
of less than 1.000 oounds by
checking ranges unaer A. 1. (Do
not use both A.I and A.2)
Ditcnarge to POTW
tenter location numoer
6.1.1 from Part «. Section i.
Otner o«-«ite location
- - . lenter location numoer
o.i.l 'rom Part II. Section 2.)
Otner off-fit* location
. . . (enter location numoer
O.Z.Z from Part n. Section 2.
Other off-»ite location
(enter location numoer
6.2.3 'rem Pan n. Section 2.
A. Total Transfers
fDOunds/yeari
A 1
Reporting Ranges
0 :-»9fl 500-999
[ I [ I [ I
A.2
Enter
Estimate
8. Basis of Estimate
(enter code)
C.Type of Treatment
Disposal
(enter code!
6.
1,bD
6.2.1b
D
6.2.2b
D
? 2 3b D
[ ] (Check if additional Information Is provided on Part IV-Supplemental Information.)
7. WASTE TREATMENT METHODS AND EFFICIENCY
r 1 Not Applicable (NA) - Check if no on-site treatment is applied to any wastestream containing the chemical or cnerncai
L J category.
A. General
Wastestream
(enter code)
B. Treatment
Method
(enter code)
C. flange of
Influent
Concentration!
(enter code)
D. Sequential
Treatment?
(check If
applicable)
E. Treatment
Efficiency
Estimate
F. Basec on
Operating
Data?
Yes No
7.1a
D
7.ib
7.1c
D
7.ld
[ 1
7.1f
7.2a
D
7.2b
7.20
n
7 2d
[ 1
7.2*
7.2f
7.
» D
7.3b
7.
3« n
7.3d
7.3*
7.3f
7.4a
D
7.4b
7.4c
7.4d
7.4*
7.4f
[ ] [ I
7,5a
n
7.5b
7.
- n
7.5d
[ I
7.5e
7.5f
[ I [ ]
7.6a
D
7.6b
7.6c
7.6d
7.6*
7.6f
[ ] [ I
7.7a
7.7b
7.7c
7.7d
7.79
>-7< ( } ( }
7.J
7.8b
7.8c
n
r.8d [ ]
7.8*
7.8f
7.9a
D
7.flb
7.9c
D
7.9d
7.9*
7.9f
7.10«
D
7.10b
7.10e
7.10d
[
7.10*
7.10f
[ ] (Check If additional Information !• provided on Part IV-Supplemental Information.)
B. POLLUTION PREVENTION: OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indicate actions taken to reduce the amount of the chemical being released from the facility. See the Instructions for coded
items and an explanation of what Information to include.
A. Type of
Modification
(enter code)
B. Quantity of the Chemical in wattes
Prior to Treatment or Disposal
C. Index
D. Reason for Action
(enter code)
Current Prior i
reporting year i
year (pounds/year) i
(pounds/year)
Or percent change
(Check (») or (-))
n.n
EPA Form 9350-1 (1-90) Revised - Do not use previous versions.
-------
D
•important: Typr or print: read instructions before completing form.)
• =age 5 of 5
3EPA
EPA FORM R
PART IV. SUPPLEMENTAL INFORMATION
Use this s»ctlon If you need additional space for answers to questions in Part III.
Number the ill et uted sequentially from lines in prior sections (e.g.. 5.3.4. 6.1.2. 7.11 ]
(This soace for your ootionai use
ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
(Part III. Section 5.3)
Vou may report releases of less than
1.000 pounds by checking ranges under A.I.
(Do not use both A.I and A.2)
S.3 Discharges to
receiving streams or
water bodies 5.3.
(Enter letter cooe for stream
from Part Section 3.10 In e »
trie oox oro«ioed.) Jl
_D
5.3
5.3.
5.3.
5.3 a
A. Total Release
(pounds/year I
A.1
Reporting Ranges
0 • -«9C 500-999
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided)
i.3 bi—
5.3.
S.3.
C.% From
Stormwater
5.3._c
S.3._c
5.3.
ADDITIONAL INFORMATION ON TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
(Part III. Section 6)
You may report transfers
of less than 1.000 pounds by checking
ranges under A.I. (Do not use
both A.I and A.2)
6.1. IS?
Dlicnarge to °OTW
'enter location nomoer
Part u. Section i.)
Other off-«ite locit.on
e i (enter location :
"•'• from Part II. Sectic.>2.)
6.2.
Other oft-tite lot.'...on r—'
(enter location *h.rroer 2
•fro
from Part II. SoeT M 2.1
6.2.
Other or-tite icea: an
(enter location nirr ger
. from Part K, Settlor 2.)
A.Total Transfers
(pounds/year)
A.1
Reporting Ranges
0 1 -»99 500-999
] [ ]
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code
in box
provided)
C. Type of Treatment
Disposal
(enter coea
in box
provided)
6.1.
6.2. b
6.2
ADDITIONAL INFORMATION ON WASTE TREATMENT METHODS AND EFFICIENCY (Part III. Section 7)
A. General
Wasteetreem
(enter code
In box provided)
—•a
—•a
D
8. Treatment
Method
(enter code
in box provided)
7.
7.
7.
7.
C. Range of
Influent
Concentration
(enter code)
—• n
D
n
n
•_• D
7. .a
'._.Q
,. .Q
, -a
EPA Form 9350-
7. b
7. b
7. b
7. J>
1 (1-90) Revi
sx
j -
Do
not usi
'• « C
r_. D
7. = C
7 . [^
i previous versio
1
ns
7. d[ ]
7. d[ ]
7. d[ ]
7. d[ ]
•
7. e *
7. • %
7. e ,%
7. e %
•* •
'• '[ ][ 1
7- f[ ][ ]
••7—<( ]( 1
»—'[ 1
0. Sequential
Treatment?
(check If
applicable)
-«[ 1
-"[ 1
•— -I 1
E. Treatment
Efficiency
Estimate
5.2. b M 6.2.
. b CD 6.2. i
F. Based on
Operating
Data?
Yes
No
'[ It I
-'[
• '[ ][ ]
• '[
• <[ ][ I
-------
APPENDIX C
AUDIT CHECKLIST
-------
Facility ID:
EPCRA SECTION 313 REPORTING
AUDIT CHECKLIST
-------
Facility ID:
Date of Visit: |_|_J-|_J_H_I_I through |_|_|-|_l_ -|_l
Facility Name:
Address:
City:
State:
Telephone:
Facility Contact:
Auditors:
-------
Facility ID:
SECTION 1.0
PRE-VISTT
TELEPHONE CONTACT
TECHNICAL REVIEW
1.1. How many Form R chemical reports were submitted for this facility for the reporting year?
1.2. How many 313 chemicals were identified by this facility, but not reported, for the reporting
year?
1.3. Did the facility submit any revised Form R chemical reports for the reporting year?
YES r~j NO |~~1 (Skip to Q. 1.5)
1.4. List the chemicals which had revised chemical reports here.
1.5. How many full-rime equivalent employees did the facility have during the reporting year?
I_I_!_L
NOTE: If there were less than 10 full-time equivalent employees, this facility was not required to
report
1.6. Briefly describe the number and type of industrial processes performed at this facility during
the reporting year.
-------
Facility ID:
1.7. Has the facility's process operations significantly changed since the reporting year (including
equipment, chemicals, feedstock, etc.)?
YES r~] NO r~j (Skip to Q. 1.9)
1.8. Briefly describe any process changes.
1.9. Has the facility implemented any new treatment technologies since the reporting year?
YES r~j NO PI (Slap to Q. 1.11)
1.10. Briefly describe any new treatment operations.
SUPPLIER NOTIFICATION
1.11 Did the facility receive notification from chemical/material suppliers of ail Section 313
chemicals in their products supplied to the facility during the reporting year?
YES
(Skip to Q. 1.13) NO r~]
1.12 Record the name(s) and address (es) of suppliers which did not notify this facility of
Section 313 chemicals in their products.
-------
Facility ID:
1.13 Did the facility distribute chemicals listed under Section 313 in mixtures or as trade name
products during the reporting year?
YES r~\ NO r~j (Skip to Q. 1.15)
1.14 Did. the facility develop and distribute supplier notification information under Section 313
requirements?
YES ..... r~j NO ..... r~j (Skip to Q. 1.15)
LOGISTICS
1.15. Will the facility be operating under normal conditions at the rime of the audit?
YES ..... rn NO ..... rn
1.16. What personal protective equipment will be needed to participate in a facility tour?
Hard Hat
Safety Boots I 1
Safety Glasses I I
Respirator I I
Other r~j
1.17. How large an area (# buildings, acres, etc.) do the production areas, storage facilities, and
treatment areas of the facility occupy?
(Consoler this when planning the type and duration of tour that would be most useful)
1.18 Briefly describe the procedures used to collecc and document information for EPCRA reporting,
including the number of people involved at the facility and whether they will be available
during the audit to answer questions.
-------
1.19. Hotel recommendation:
1.20. Directions to facility:
1.21. Time to meet:
Facility ID:
-------
Facility ID:
SECTION 2.0
INTRODUCTION AND FACILITY TOUR
313 CHEMICALS PRESENT ON-SITE
2.1 List all chemicals reported on the facility's Form R chemical reports.
Chemical Name
CAS
Not a 313 Chemical
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
a
D
a
-------
Facility ID:
Chemical Name
CAS
Not a 313 Chemical
LLLLLHJJ-IJ Q
LLLLIJ-LIJ-U _ Q
. LLLLLHJJ-IJ Q]
- LLLLU-LLHJ Q
LLLLIJ-LLI-LI Q]
LLUJJ-LLHJ Q
2.2 List all chemicals not reported on the facility's Form R chemical reports, but documented by
the facility.
NONE rn
Chemical Name CAS # Not a 313 Chemical
LLLLU-LLHJ Q
LLLLU-LLHJ Q
LLLUJ-LLHJ Q
D
-------
Facility ID: .
2.3 List other 313 chemicals not reported or documented, but identified by the surveyor during
the site visit.
NONE r~j
Chemical Name CAS #
8
-------
Facility ID:
2.4 List all mixtures identified during the facility tour which may contain Section 313 chemicals.
a.
Mixture Name
b.
Section 313
Chemical
Present
c.
Concentration
of Chemical1
d.
Amount of
Mixture Used
for Year2
e.
Amount of
Section 313
Chemical
Used2
'If concentration of chemical is below de minimis (0.1% for carcinogens, 1.0% for all others), do not
include mixture in threshold determination.
Complete columns d and e during threshold determination.
-------
Facility ID:
Process iyi
10
-------
Facility ID:
Treatment Unit Operarion(s):
11
-------
Facility ID:
Facility Tour Notes:
12
-------
Facility ID:
Facility Tour Notes (Cont'd)
13
-------
Facility ID:
SECTION 3.0
REVIEW OF THRESHOLD DETERMINATION
Chemical Name:
3.1 How is this chemical employed at the facility? (Check all that appfy)
Facility Reviewer Facility Reviewer
I I I I Manufacture
a. Import/produce for on-site use/processing .... (~~| I I
b. Import/produce for sale/distribution j~~| I I
c. By-product of process I 1 I I
d. By-product of waste treatment I I I I
e. Impurity1 (% = ) j 1
[~| [~~"1 Process (incorporarive activity)
f. Chemical reactant (raw materials,
intermediates, etc.) I I I I
g. Formulation component I I I I
h. Article component [~~| I I
i. Repackage F~J |~~J
[""I f~~j Otherwise Use (nonincorporative activity)
j. Chemical processing aid (added to reaction
mixture) r~J r~j
k. Manufacturing aid (process lubricants,
coolants, etc.) [~~| I I
1. Ancillary use (cleaners, degreasers, lubricants) . j 1 ( [
'If impurity is present below de minimis concentrations (0.1% for carcinogens, 1.0% for all others),
it is exempt from reporting.
14
-------
Facility ID:
3.2
I 1 Exempt Uses
m. Laboratory chemical
n. Structural component
o. Routine janitorial/facility grounds maintenance
p. Personal employee use '.
q. Motor vehicle maintenance
r. Intake water component
s. Contained in an article
Was the chemical reported by the facility?
YES r"j (Co to Q. 3.3) NO . . .
D
D
D
D
D
D
n
D
n
n
D
3.2.1 If no, why did the facility decide this chemical was not reportable?
h
c.
d.
Exempt use
Overlooked chemical altogether
Other (specify)
LJ
DfSldp
i r
n
1 — 1
to Q 3.6)
3.3 Is chemical exempt from reporting?
YES r~] (GotoQ 3.10) NO r""j (Continue)
3.4 Is documentation supporting the threshold determination available for review?
YES r~| (GotoQ 3.5) NO
3.4.1 If no, why not?
a. Documentation cannot be located
b. Documentation was not retained by facility . . . .
c. Facility unaware that documentation is required
n
D
D
15
-------
I :
Facility ID:
3.5 What was the basis of estimate used by the facility for the amount manufactured, processed,
or otherwise used during the reporting year? Check all thai apply.
a. Purchase/inventory records I 1
b. Emission factors
c. Mass balance .
d. Assumed threshold exceeded (no calculations completed)
e Process recipes
f. Monitoring data I 1
g. Production data I 1
h. Other (specify) I I
3.6 How much chemical did the facility manufacrure, process, or otherwise use during the
reporting year?1
Facility Reviewer
a. Manufactured Ibs Ibs
b. P'-ocessed Ibs Ibs
c. Ocherwise used Ibs Ibs
d. Facility did not estimate these quantities I I
e. Reviewer unable to estimate quantities I I
'Record calculations and assumptions for the threshold determination on the worksheet in Section 6.0.
16
-------
Facility ID:
3.7 Was the reviewer's estimate of the amount of chemical manufactured, processed, or otherwise
used recalculated using available documentation or recreated using other facility data?
a. Recalculated, within a factor of 2 I I
b. Recalculated, within a factor of 10 I j
c. Recalculated, greater than a factor of 10 I I
d. Recreated, within a factor of 2 I I
e. Recreated, within a factor of 10 I 1
f. Recreated, greater than a factor of 10 I I
g. Facility did not estimate these quantities I I
h. Reviewer unable to estimate quantities1 I I
3.8 Was a threshold exceeded for this chemical in 1988?
YES I I (This chemical should have been reported. Continue)
NO I I (This chemical should not have been reported. Skip to Q. 3.10)
Cannot be determined .... I I (Skip to next chemical)
3.9 What is the maximum amount of this chemical on-site at any time?2
Facility Reviewer
a. Maximum on-site Ibs Ibs
3.10 This chemical was:
a. Correctly included j~~| (Go to Section 4.0)
b. Correctly omitted [ ] (Skip to next chemical)
c. Incorrectly included I I (Go to Q 3.11)
d. Incorrectly omitted PH (Go to Q 3.12)
'Document why you are unable to estimate chemical quantities for the reporting year on the threshold
determination worksheet in Section 6.0.
'Record calculations and assumptions for the maximum on-site quantity on the worksheet in
Section 6.0.
17
-------
Facility ID:
3.11 Why was this chemical incorrectly included:
a. Facility reported, although amount used was below threshold
b. Facility incorrectly assumed threshold was exceeded I I
c. Chemical activity was misclassified I 1
d. Threshold quantity was miscalculated I I
e. Chemical was exempt I I
f. Other (specify) f~~j
(Skip to next chemical)
3.12 Why was this chemical incorrectly omitted?
Chemical activity was overlooked I I
c.
a.
b. Chemical activity was misclassified I I
Threshold quantity was miscalculated I I
d. Other (specify) I I
(Continue to Section 4.0)
18
-------
Facility ID:
SECTION 4.0
REVIEW OF RELEASE CALCULATIONS
19
-------
CODE LIST FOR SECTION 4.0
01
Q2
Y = Yes
N1 = Documentation cannot be located
N2 - Documentation was not retained by facility
N3 = Facility unaware that documentation required
N4 = Facility overlooked chemical
N5 = Other
NA = Facility does not have a release for
this medium
Y = Yes
N1 = Facility unable to locate data
N2 = Facility did not retain data
NA = Monitoring data not used
05
Q6
Y = Yes
N = No
NA = Facility does not have a release for
this medium
Y
N1
N2
N3
NA =
= Yes
Facility misinterpreted de minimis rule
Facility overlooked chemical
Other
Facility does not have a release for
this medium
Q3
Q4
Y = Yes
N1 = Facility unable to locate data
N2 = Facility did not retain data
N3 = Facility did not base estimate
on monitoring data
NA = Percent from stormwater estimate
was not reported
Q7
1
2
3
4
Q8
Facility derived factors
EPA published emission factors
Trade association factors
Other
Q9
Y
N
NA
Y
N
NA
Y
N'
NA
= Yes
No, facility overlooked treatment
No treatment of this chemical for this
release medium occurred
= Yes
= Facility incorrectly reported treatment efficiency
= Sequential treatment uses not reported
= Yes
= No
= No treatment efficiencies were used
NA = Emission factors not used
-
-------
Facility ID:
SECTION 4.0 REV1KW OE RELEASE ESTIMATES
Chemical Mama
1 . Is documentation on release
estimate available for review? 0
2. If monitoring data were used,
is it available for review?
3. If a percent from stormwater estimate
was reported, is the monitoring data it
is based on available for review?
4. If emission factors were used,
what is the source of the factors?
5. Was each air or waste stream
counted only once In release
estimates? (2)
6. Were all air or waste streams
containing <1% of the chemical
included in release calculations?
7. Was on-site treatment of this
chemical included in release
estimates?
8. If sequential treatment was reported,
was the efficiency based on the
overall treatment?
9. Were treatment efficiencies
used consistent with vendor specs
or EPA published efficiencies? ©
Fugitive
Air
Stack
Air
Receiving
Stream
Under-
Ground
Land
On-Site
POTW
OH-Site
Transfer
(T) If the facility overlooked this chemical, enter N4 and skip to Section 4.1
(2) If no, document all streams double counted in release calculation in Section 6.0
(5) |f no, document inconsistency of treatment efficiencies used in Section 6.0
-------
Facility
-------
Facility ID:
SECTION 5.0
SUMMARY OF RELEASE ESTIMATES
...,......(.«. Sitl
. ., - . *~ •---». -t..-JS»
23
-------
CODE LIST FOR SECTION 5.0
(T) M = Monitoring data or direct measurements
C = Mass balance calculations
E = Published emission factors
OC = Engineering calculations
OJ = Engineering judgement
OH = Hazardous waste manifests
O = Other
NA = Facility did not estimate release
Y = Yes
N = No
NA = Facility did not estimate release
(3) Document why this method is more accurate in Section 6.0
(4) Document release calculations in Section 6.0
-------
Facility ID:
SECTION 5.0 SUMMARY OF RELEASE ESTIMATES
NJ
Ol
Chemical Name
1 . Enter facility's release estimate (in Ibs.)
(Check range, if appropriate)
2. What method(s) did the facility
use to estimate their release? (T)
3. Based on data available to the facility
is this the best method to determine
a release estimate? (2)
IF YES. SKIP TO QUESTION 6.
4. What method(s) could be used to
calculate a more accurate release
estimate? (f) (3)
5. Enter the reviewer's release estimate
using the preferred methods',*). (4)
6. Enter the reviewer's release estimate
using the same metnod(s) as the
facility. (4) (Check ranae. If aDDrooriatel
Fugitive
Air
1-499 500-999
i — i r-ri
1-499 500-999
r — i i — i
1-499 500-999
1 D 1 1
Stack
Air
1-499 500-999
CHI CT_m
1-499 500-999
r.-n i — i
1-499 500-999
c. — i i — i
Receiving
1-499 500 999
cm c:-i
1-499 500-999
1 1 Cm
1-499 500-999
cm rrn
Under-
Ground
Injection
1 499 500-999
1-499 500-999
1-499 500-999
Land
On-Sito
1-499 500-999
1-499 500-999
1-499 500-999
cm cm
POTW
1-499 500-999
1-499 500-999
1-499 500-999
Off-Site
Transfer
I 499 500 999
1-499 500-999
i_i_:i L. . i
1-499 500 999
1:1:11 i' i
-------
Facility ID:
SECTION 6.0
CALCULATIONS
26
-------
Facility ID:
THRESHOLD DETERMINATION
WORKSHEET
Chemical Name:
Description of Use
TOTALS
Amount
Manufactured
Amount
Processed
Amount
Otherwise Used
Calculations:
27
-------
Facility ID:
MAXIMUM ON-SITE WORKSHEET
Chemical Name:
INSTRUCHDNS:
Calculate the maximum amount of the chemical on-site at any one time during the
reporting year. Keep in mind the following:
• All storage areas (raw materials and products) where this chemical may be
kept;
• The amount of chemical being used at any time; and
• The amount of chemical in each waste stream.
Storage Areas:
Chemical in U«.e:
Total:
Total:
Chemical in Waste Streams
Total:
Total On-Site:
28
-------
Facility ID:
RELEASE ESTIMATE WORKSHEET
Chemical Name:
INSTRUCTIONS: Record all calculations for release estimates below in the appropriate sections. Be
sure to identify if calculations use the same method as the facility or a preferred
method.
Fugitive Air
Stack Air
29
-------
FacUity ID:
Chemical Name:
Receiving Stream
Underground Injection
Land On-Site
30
-------
Facility ID:
Chemical Name:
Off-Site Transfer to POTW
Off-Site Transfer
31
-------
50277-101
REPORT DOCUMENTATION
PAGE
l._REPORT NO.
EPA 560/4-90-018
3. Recipient** Accmdon No.
4. Title and Subtitle
Section 313, Emergency Planning and Community Right-to-Know
Act & Quality Assurance Audit Manual
S. Report Oite
August 1990 Date Publish
7. Author(s)
Deborah S. Matthews and M. Timothy MeAdams
8. Performing Organization Rept. No.
9. Performing Organization Nam* and Addr***
Radian Corporation
2455 Horsepen Road, Suite 250
Herndon, VA 22071
10. Project/Tatk/Work Unit No.
Work Assign. 1-03
11. Contract(C) or Grant(G) No.
(O 68-D9-0169
(G)
12. Sponsoring Organization Nam* and Addrts*
US Environmental Protection Agency
Office of Toxic Substnaces (TS-779)
401 M St. SW
Washington, DC 20460
13. Type of Report & Period Covered
Final
14.
15. Supplementary Not**
1C. Abstract (Limit: 200 word*)
This document is designed to aid EPA staff and contractors when evaluating the quality of
data submitted on EPA Form R, the report submitted to EPA by industrial facilities for
Toxic Release Inventory (TRI) reporting. The TRI is an annual inventory compiled by EPA
of releases of listed toxic chemicals into the environment by manufacturing facilities.
Such facilities are required to submit release estimates and other pertinent data under
requirements of Section 313 of the Emergency Planning and Community Right^to-Know Act
(EPCRA) of 1986.
This manual contains background information on TRI reporting requirements, suggestions
for preparing for a site audit and an audit checklist. The checklist questions are
designed to aid the auditor in assessing the completeness and quality of the TRI data as
he reviews the Form R reports and supporting documentation. This manual is intended for
use during technical data quality audits unrelated to EPCRA Section 313 enforcement
inspections, but may be used by enforcement personnel as a supplemental technical
reference.
17. Document Analyst* *. Descriptor*
b. Identlflera/Open-Ended Term*
c. COSATt Held/Group
IS. Availability Statement
Release unlimited
19. Security Ctes* (Tttta Report)
Unclassified
20. Security Class (Thts •*••)
Unclassified
21. r**.* •>
79
See Instruction* on Ravers*
S72 (4-7
»m*-*»
------- |