Facilities subject to EPCRA 313 (40 CFR Part 372) must report releases and other waste management activities of toxic chemicals that they manufacture, process, or otherwise use. These facilities must report on-site waste treatment methods and efficiencies for toxic chemicals in waste streams in Part II, Section 7A, and the quantities of toxic chemicals in wastes treated on site when the toxic chemicals become chemically converted or destroyed in Part II, Section 8.6. A facility purchases an EPCRA 313 toxic chemical and uses it to treat a wastestream on site. The toxic chemical (the "treator") chemically converts during the process of treating the on-site wastestream. Is the facility required to report the Section 313 treator toxic chemical as "treated on site" in Part II, Sections 7A and 8.6 of the Form R?
When a facility treats a wastestream with a toxic chemical that is not a waste or part of a wastestream prior to its use as a treator, the facility should not report the toxic chemical (the treator) as "treated on site" in Sections 7A or 8.6 of the Form R, even if it becomes chemically converted or destroyed during the treatment process; the facility should include the amount of the treator chemical used in this process toward the facility's otherwise use threshold. If, however, a facility treats a wastestream with a toxic chemical that is, itself, a waste or part of a waste stream prior to the treatment process, the facility must report the toxic chemical as "treated on site" in Sections 7A and 8.6 of the Form R if it becomes chemically converted or destroyed during the treatment process. Additional guidance on waste management calculations can be found in the Revised 1998 EPCRA Section 313 Questions and Answers Document and on the TRI Guidance Documents Web site.