Pounds released

Note that total annual releases of less than 0.5 pounds from the processing or otherwise use of an article maintains the article status of that item. Thus, if the only releases you have are from processing an article, and such releases are less than 0.5 pounds per year, you are not required to submit a report for that chemical. The 0.5 pound release determination does not apply to just a single article, ft applies to the cumulative releases from the processing or use of that same typ>e of article (e.g., sheet metal or plastic film) that occurs over the course of the calendar year. 

According to the most recent Toxics Release Inventory (Table 5-1), in 1996, the estimated releases of 17,097 pounds of mercury to the air from 31 large processing facilities accounted for about 20% of annual environmental releases for this element (TRI96 1998). This is slightly more (13%) than the estimated 13,885 pounds that were released to the air in 1994 (TRI94 1996), but 35% less than the 21,288 pounds released to the air in 1991 (Table 5-2). The TRI data listed in Tables 5-1 and 5-2 should be used with some caution, since only certain types of facilities are required to report (EPA 1996f). This is not an exhaustive list. 

The Comprehensive Environmental Response, Compensation, and LiabiHty Act of 1980 (CERCLA) requires notification to the National Response Center of releases of quantities of hazardous substances equal to or greater than the reportable quantity (RQ) in 40 CER 302.4, which is one pound (0.454 kg). 

Release Reporting. Both the Comprehensive Environmental Response, Compensation, and Liabihty Act (CERCLA) and EPCRA have requirements for reporting releases to the air, ground, or water. Lists of reportable chemicals or family of chemicals and their reportable quantity (RQ) have been issued (9). A reportable quantity is the amount, in pounds or kilograms, below which a release does not have to be reported. CERCLA requires only the reporting of releases from the CERCLA Hst however, EPCRA requires reporting releases of both EPCRA- and CERCLA-Hsted substances. 

All four butanols are registered ia the United States on the Environmental Protection Agency Toxic Substances Control Act (TSCA) Inventory, a prerequisite for the manufacture or importation for commercial sale of any chemical substance or mixture ia quantities greater than a 1000 pounds (454 kg). Additionally, the manufacture and distribution of the butanols ia the United States are regulated under the Superfund Amendments and Reauthorization Act (SARA), Section 313, which requires that anyone handling at least 10,000 pounds (4545 kg) a year of a chemical substance report to both the EPA and the state any release of that substance to the environment. 

If this event occurs, 1200 pounds of material is expected to be released to the environment. 

According to TRI data, the petroleum refining industry releases (discharges to the air, water, or land without treatment) and transfers (shipped off-site) a total of 482 million pounds of pollutants per year, made up of 103 different chemicals. This represents about 11 % of the total pounds of TRI chemicals released and transferred by all manufacturers in a year. In comparison, the chemical industry generates on the average 2.5 billion pounds per year, accounting for 33% of all releases and transfers. 

If the processing or otherwise use of similar articles results in a total release of less than 0.5 pound of a toxic chemical in a calendar year to any environmental media, EPA will allow this release quantity to be rounded to zero and the manufactured items remain exempt as articles. EPA requires facilties to round off and report all estimates to the nearest whole number. The 0.5 pound limit does not apply to each individual article, but applies to the sum of all releases from processing or use of like articles. 

You must submit a report If you exceed any threshold for any listed chemical or chemical category. For example, if vour facility processes 22.000 pounds of a listed chemical and also otherwise uses 16,000 pounds of that same chemical, although you do not exceed the process threshold, you do exceed the othenwise used threshold (10,000 pounds) and you therefore must report. However, in preparing your reports, you must consider all non-exempted activities and all releases of that chemical from your facility, not just the releases from the otherwise use activity. 

Threshold determinations for metal-containing compounds present a special case. If, for example, you process several different lead compounds, you would base your threshold determination on the total weight of all lead compounds processed. However, If you process both the parent" metal (lead) as well as one or more lead compounds, you must make threshold determinations for both because they are separately listed toxic chemicals. If you exceed thresholds for both the parent metal and compounds of that same metal, EPA allows you to file one combined report (e.g., one report for lead compounds, including lead) because the release Information you will report In connection with metal compounds will be the total pounds of the parent metal released. 

Report releases and off-site transfers to the nearest pound. Do not report fractions of pounds. 

Only on-site releases of the toxic chemical to the environment for the calendar year are to be reported in this section of the form. The total releases from your facility do not include transfers or shipments of the chemical from your facility for sale or distribution in commerce, or of wastes to other facilities fortreatment ordisposal (see Pari III, Section 6). Both routine releases, such as fugitive air emissions, and accidental or nonroutine releases, such as chemical spills, must be included in your estimate of the quantity released. EPA requires no more than two significant digits when reporting releases (e.g., 7521 pounds would be reported as 7500 pounds). 

Releases of Less Than One Pound. Total annual releases or off-site transfers of a toxic chemical from the facility of less than 1 pound may be reported in one of several ways. You should round the value to the nearest pound. If the estimate is 0.5 pounds or greater, you should either check the range bracket of"1-499 in column A.1 orenterTin column A.2. J2a not use both oolumns A. 1 and A.2. If the release is less than 0.5 pounds, you may round to zero and check the "0 bracket in A.t. 

Zero Releases. If you have no releases of a toxic chemical to a particular medium, report either NA, not applicable, or 0, as appropriate. Report NA only when there is no possibility a release could occur to a specific media or off-site location. If a release to a specific media or off-site location could occur, but either no release occurred orthe annual aggregate release was less than 0.5 pounds, report zero. However, if you report zero releases, a basis of estimate must be provided in column B. For example, if hydrochloric acid is Involved in the facility processing activities but the facility neutralizes the wastestreams to a pH of 6-9, then the facility reports a 0 release for the chemical. If the facility has no underground injection well, it enters NA for that item on the form. If the facility does not landfill the acidic waste, it enters NA for landfills... 

For reports submitted for calendar years 1987, 1988, and 1989 only, you may take advantage of range reporting for releases to an environmental medium that are less than 1,000 pounds forthe year. If you choose this option, mark one of the three boxes, 0, 1-499, or 500-999, that corresponds to releases of the chemical to the appropriate environmental medium (i.o., any line item). You are not required, however, to use these range check boxes you have the option of providing a specific value in column A.2, as described below. However, gg not mark a range and also enter a specific estimate in A.2. 

For releases to any medium that amount to 1,000 pounds or more forthe year, you must provide an estimate in pounds per year in column A.2. Any estimate provided in column A.2 should be reported to no more than two significant figures. This estimate should be in whole numbers. Do not use decimal points. 

If you do not use the range reporting option, provide your estimates of total annual releases (in pounds) in column A.2. 

You must estimate, as accurately as possible, the quantity (in pounds) of the chemical or chemical category that is released annually to each environmental medium. Include only the quantity of the toxic chemical contained in the wastestream in this estimate. If the toxic chemical present at your facility was part of a mixture or trade name product, calculate only the releases of the chemical, not the other components of the mixture or trade name product. If you are only able to estimate the releases of the mixture or trade name product as a whole, you must assume that the release of the toxic chemical is... 

A. Total Release (pounds/year) B. Basis of Estimate C. Prom Stormwater... 

Enter the total pounds of the toxic chemical contained In all wastes from the reporting facility (air emissions, water discharges, solid wastes and off-sIte transfers) generated during the reporting year. This quantity may be the sum of all the release amounts reported on Form R if there is no on-site treatment of the chemical. The quantity will often be greater than the total reported release amounts because it includes waste prior to treatment. 

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) A.1 Reporting Ranges 0 1- 99 500-999 A.2 Enter Estimate (enter code) ... 

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