Facilities subject to EPCRA Section 313 are required to report all releases and other waste management activities involving toxic chemicals for which the facility has exceeded an activity threshold. Specifically, in Section 8, Column A of the Form R, facilities must report quantities of a toxic chemical released or managed as waste for the prior year. Must a facility report on quantities of a toxic chemical released or managed as waste for the prior year if the facility was not required to file a Form R or Form A for that toxic chemical in the prior year?
The owner or operator of a facility may put "NA" in Column A of Sections 8.1 through 8.7 of the Form R if the toxic chemical was not present at the facility in the prior year. "NA" is also appropriate for Column A if the toxic chemical was present at the facility in any amount during the prior year, but there was no possibility for a release or other waste management activity of that toxic chemical to occur during the prior year. For example, if the facility did not have an on-site recycling operation for the waste stream containing the toxic chemical in the prior year, the facility may put "NA" in Column A of Section 8.4 (on-site recycling). Otherwise, the owner or operator should provide a reasonable estimate for prior year release and other waste management activities of a toxic chemical in Column A of Sections 8.1 through 8.7.