A covered TRI facility otherwise uses a solvent containing trichloroethylene (TCE), a listed toxic chemical, in its production process. Once the solvent has been used, the facility reclaims it on site and then reuses it. This on-site recycling process occurs several times until the solvent can no longer be used. How should the facility consider the TCE in the solvent for purposes of EPCRA Section 313 threshold determination and release and waste management calculations?
For threshold determination, the amount of the TCE in the solvent should be counted only once toward the otherwise use threshold, regardless of how many times the solvent is reused on site. However, for release and other waste management calculations, the facility must consider the quantity of TCE recycled on site each time it is recycled, and report the aggregate total quantity in Part II, Section 8.4 of the Form R. In addition, the facility would report the on-site recycling methods in Part II, Section 7C. Additional guidance on double counting can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document.