Release reporting

Several different sets of regulations require a manufacturer to report certain releases to the environment. Toxic materials are covered xmder right-to-know legislation. 40CFR372 gives a specific list of chemicals and chemical categories. It also defines 

Each facility is responsible for understanding and meeting its obligations vmder this rule. 

EPA also heis published rules (40CFR300,302, and 355) which require that continuous releases of hazardous substances be reported. First, the person in charge of a facility must satisfy the requirements of Section 103 of CERCLA by initial notification of releases that exceed the reportable quantity for any material on the CERCLA list of hazardous substances. 

When a release is determined to be a statistically significant increase above background level, it must be reported as set out in 40CFR302.6. It is the reporter s responsibility to convince EPA of the adequacy of the statistical test that is used. 40CFR302.8 Appendix C contains a simple nonparametiic test that will be accepted. This involves simply reporting any release that is greater than each of the previous nineteen. The annual report should include 

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The Superfund Amendments and Reauthorization Act of 1986 (SARA) Tide III requires emergency planning based on threshold planning quantities (TPQ) and release reporting based on RQs in 40 CER part 355 (used for SARA 302, 303, and 304). The TPQ for acrolein is 500 lb (227 kg), and its RQ is 1 lb (0.454 kg). SARA also requires submission of aimual reports of release of toxic chemicals that appear on the Hst in 40 CER 372.65 (for SARA 313). Acrolein appears on that Hst. This information must be included in all MSDSs that are copied and distributed for acrolein. 

All the PMBs are Hsted on the U.S. EPA s Toxic Substances Control Act NonConfidential Chemical Substances Inventory (Table 8). In the early to mid-1980s, pseudocumene, mesitylene, hemimellitene, and trimethylbenzene were coveted by TSCA Section 8(a) Preliminary Assessment Information Rule (PAIR) reporting requirements (22) and by TSCA Section 8(d) for health and safety data (23). Mesitylene is the subject of a test rule subacute oral toxicity and subchtonic oral toxicity in tats were underway in 1994 (24). The Safe Drinking Water Act (SDWA) allows monitoring for pseudocumene and mesitylene at the discretion of the State (25). Of the PMBs, only pseudocumene is subject to SARA Tide III section 313 annual release reporting (26). 

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. 

The Toxic Chemical Release Reporting Form, EPA Form R, consists of four parts ... 

A covered multi-establishment facility must make chemical threshold determinations and report all relevant information about releases and waste treatment associated with a listed chemical, even from establishments that are not in SIC codes 20-39. EPA realizes, however, that certain establishments in a multi-establishment facility can be, for all practical purposes, separate business units. Therefore, individual establishments may report separately, provided that the total release is reported for the whole facility is represented by the sum of releases reported by the separate establishments. 

For each release estimate, you are required to indicate the principal method used to determine the amount of release reported. You will enter a letter code that identifies the method that applies to the largest portion of the total estimated release quantity. 

Note that you may be covered by the supplier notification rules even If you are not covered by the section 313 release reporting requirements. For example, even if you have less than 10 full-time employees or do not manufacture or process any of the chemicals in sufficient quantities to trigger the release reporting requirements, you may still be required to notify certain customers. 

Calculates and prints Tier I and Tier II inventory reports. Also assists with inventory and chemical storage information required for Toxic Chemical Release Reports. Requires 640K memory and hard disk. 

Computerized Toxic Chemical Release Reporting System... 

Manages occupational health records, MSDSs, chemical information, and employee records. Aids with emergency release reports. 

For the environmental engineer, this handbook provides extensive technical data on toxic chemical properties and detailed instructional aid on how to properly prepare toxic chemical release inventory reporting. The volume contains numerous examples on preparing SARA Title III chemical release reports and provides a compendium of State and Regional contacts within the Environmental Protection Agency. 

Toxic Chemicals Release Reporting-Emissions Inventory (Section 313)... 

Toxic chemical release reporting community right-to-know list Not included 40 CFR 372.65, ERA 1998j... 

EPA. 1987a. Toxic chemicals release reporting community right-to-know. U.S. Environmental Protection Agency. Eederal Register 52 21152-21208. 

Toxic Chemical Release Reporting Community Right-to-Know... 

Following the immediate response activities (including release reporting, immediate containment, and monitoring of explosive hazards), the actions that the facility must implement as initial abatement measures include the following ... 

Release reporting. Manufacturing businesses with ten or more employees that manufactured, processed, or otherwise used a listed toxic chemical in excess of the established threshold must file annually a Toxic Chemical Release form with U.S. EPA and the state. Documentation supporting release estimates must be kept for three years. 

EPA Administrative stay of toxic chemical release reporting requirements Yes EPA 1994a (59 FR 43048)... 

Toxic chemical release reporting Community right-to-know... 

EPA OTS (Appendix VIII) Groundwater monitoring list (Appendix IX) Restriction on land disposal, proposed treatment standards Toxic chemical release reporting... 

Use only chemical protective clothing that has undergone material and construction performance testing against the specific agent that has been released. Reported permeation rates may be affected by solvents, components, or impurities in munition grade agents. 

EPA OTS Toxic Chemical Release Reporting Rule Yes EPA 1988b (40 CFR 372)... 

Toxic Chemical Release Reporting -List of Chemicals Yes 40 CFR 372.65 EPA 1988d... 

Considerable confusion exists in the literature about the TRI release reporting data and monitoring data available for di-ft-octylphthalatc and its more common branched isomer, di(2-ethylhexyl)phthalate (EPA 1992a Vista Chemical 1992). The confusion exists because the terms "dioctyl phthalate" and "DOP" are often used as synonyms for di(2-ethylhexyl)phthalate, which is the largest volume plasticizer used in PVC. Consequently, some of the historical release and monitoring data reported in the literature as "dioctyl phthalate" and "DOP" refer to the more common branched isomer rather than di-ft-octylphthalate. 

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