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
                                      ii

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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.
                                      2-1

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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


                                      2-2

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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.
                                      2-3

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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;
                                      2-5

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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
              2-6

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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
                                      2-7

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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)
                            2-9

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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
                                      3-1
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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.
                                      3-2

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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.
                                      3-3

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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
I

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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
                                      3-5

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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
                                      3-6

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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.
                                      3-7

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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.
                                      4-2

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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
                                      4-3

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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


                                      u-u

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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

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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

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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

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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

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                    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

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          •    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"

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               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

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APPENDIX A
DEFINITIONS

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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).

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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).

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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.

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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.

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                    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

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                                                                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

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                             Facility ID:
          SECTION 4.0





REVIEW OF RELEASE CALCULATIONS
               19

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                                        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
                                                                                                                               -

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                                                                                  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

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                                                                                              Facility 
-------
                                                      Facility ID:
                                  SECTION 5.0


                       SUMMARY OF RELEASE ESTIMATES
...,......(.«. Sitl
 .  .,  - .                                                      *~                 •---». -t..-JS»
                                       23

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                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

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                                                                                     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

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                   Facility ID:
 SECTION 6.0





CALCULATIONS
      26

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                                                      Facility ID:
                             THRESHOLD DETERMINATION
                                    WORKSHEET
Chemical Name:

Description of Use











TOTALS
Amount
Manufactured












Amount
Processed












Amount
Otherwise Used












Calculations:
                                         27

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                                                               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

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                                                               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

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                                                             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

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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*-*»

-------