EH-413 Tree Logo EPCRA Note Pad
 
Section 313 (Module 5):
 
Toxic Chemical Release Inventory		 Module 5 graphic
 
     
 
Notes for: Step 1, Step 2, Step 3, Step 6, Step 8, Step 9, Step 14, 15 & 16, Step 23, Step 28, Step 29, Step 31, Step 32, Step 33, , Step 34, and Step 35
  
 
 
 
Notes for Step 1        Back to Step 1    GOTO: Top of Page
 
 
As directed by Executive Order 12856, DOE facilities are to comply with the reporting requirements of EPCRA. This guidance is written for DOE, not contractor, compliance with EPCRA.
 
DOE encourages the use of EPA's Automated Form R software, which allows facilities to report by magnetic diskette. For more information regarding this software or to obtain a diskette, contact EPA's EPCRA Hotline 1-800-535-0202.
 
Many DOE facilities perform manufacturing functions (i.e., manufacturing nuclear fuels, nuclear fuel reactor cores, nuclear reactor controls, nuclear reactors (military and industrial), manufacturing bombs and parts, missile warheads, and performing nuclear fuel scrap reprocessing). The SIC Code manual, available from NTIS (1-800 336-4700) contains a complete SIC code list. If a question arises consult your appropriate compliance coordinator for a determination.
 
 
 
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Every Toxic Chemical (TC) used at the facility should already be recorded on the Optional Comprehensive Inventory Worksheets or an alternate facility-wide inventory system. If this has not been accomplished, please complete Module 1: Inventory of Chemicals. Module 1 guides you through the process of identifying all TCs and collecting the necessary information on them.
 
 
 
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The following concentrations, forms, uses and activities are excluded from the reporting requirements of Section 313.
 
  1. TCs manufactured, processed, or otherwise used in a laboratory under the direct supervision of a technically qualified individual. This exemption does not apply to:
    &nbps;
    1. Specialty chemical production,
    2. Manufacture, processing or use of TCs in pilot plant scale operations,
    3. Activities conducted outside the laboratory.

     
  2. De minimus: TCs present in a mixture in a concentration below 1% or .1% if the TC is a carcinogen.
     
  3. Article:  TCs present in an article which does not release a TC under normal conditions of processing or use at the facility.
     
  4. Use as a structural component of the facility.
     
  5. Use of products for routine janitorial or facility grounds maintenance. Examples include use of janitorial cleaning supplies, fertilizers, and pesticides similar in type or concentration to consumer products.
     
  6. Personal use by employees or other persons at the facility of foods, drugs, cosmetics, or other personal items containing toxic chemicals, including supplies of such products within the facility such as in a facility operated cafeteria, store, or infirmary.
     
  7. Use of products containing toxic chemicals for the purpose of maintaining motor vehicles operated by the facility.
     
  8. Use of toxic chemicals present in process water and non-contact cooling water as drawn from the environment or from municipal sources, or toxic chemicals present in air used either as compressed air or as part of combustion.
     
 
 
 
Notes for Introduction to Steps 5 - 25        Back to Introduction to Steps 5 - 27    GOTO: Top of Page
 
 
The DOE Site Office distributes worksheets to all prime contractors that manufacture, process, or other wise use a listed chemical. After completion by the contractors, the worksheets are returned to the DOE Site Office which issued the worksheets to the contractor that manufactured, processed, or otherwise used the chemical. The DOE Site Office aggregates the quantities of toxic chemicals to determine if any chemical thresholds for the entire site were exceeded.
 
 
 
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Only one worksheet will be completed for each toxic chemical present at the facility. Do not begin a worksheet for each product (i.e., Methanol may be contained in five different products/mixtures which are used at the facility. Information on all five of these products would be entered on the same worksheet.) However, a separate worksheet must be started for each TC (i.e., If the facility had both methanol and formaldehyde on site, one worksheet would be started for methanol and a separate worksheet would be started for formaldehyde).
 
 
 
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Check both the names and CAS numbers against EPA's EHS list. Manufactures often use synonyms which are different from EPA's regulatory chemical names.
 
 
 
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Examples of information sources include purchase records, inventory data, or calculations made by your process engineer.
 
 
 
Notes for Step 14, Step 15, Step 16        Back to: Step 14, STEP 15, STEP 16    GOTO: Top of Page
 
 
The regulatory definitions of each use classification are not always intuitively obvious. It is advisable to read the explanations included in the instructions for Steps 14 through 16 carefully.
 
 
 
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DOE Site Office combines reported quantities from each site prime contractor to determine which TCs exceed the thresholds for Manufactured, Processed or Other-wise Used.
 
 
 
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DOE Site Offices need to ensure they do not double-count transfers of waste and TCs from one prime contractor at the site to another prime contractor at the same site.
 
 
 
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You may make photocopies of this page to submit with each chemical, however the certification signature (preferably in blue ink) must be an original on each copy. Photocopied signatures are not acceptable.
 
 
 
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Like the certification, the off-site locations information can be made generic for all toxic chemicals. If you include all possible off-site disposal locations this page can be photocopied and included with the five page Form R submission for each reportable toxic chemical.
 
 
 
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You will need to submit a complete five page Form R for each reportable toxic chemical.
 
 
 
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EPA's instructions for completing the Form R are found in 40 CFR 372.85 and EPA's "Toxic Chemical Release Inventory Reporting Form R and Instructions".
 
As required by the Pollution Prevention Act of 1990, the Form R now includes information regarding on-site energy recovery processes and source reduction and recycling activities. This data is new to the Form R (Sections 7B, 7C, and 8).
 
 
 
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If you are submitting reports on magnetic diskette, you must enclose a certification cover letter signed by the DOE official listed in Section 3 of Part I of the Form R (name and official title of the owner/operator or senior management official) for each separate facility.
 
 
 
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This documentation must be retained for a minimum of three years.
 
 
 
DOE Office of Environmental Policy and Guidance