COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

DS-FJEE MEMORANDUM FOR RECORD JUN 112014 ENVIROt 4iENT EHEALTH DFpARTM SUBJECT: EPCRA Section 313 Toxic Release Inventory (TRI) reporting May 29, 2014 Section 313 reporting is required when toxic chemicals are manufactured or processed exceeding 25,000 lbs or otherwise used exceeding 10,000 lbs in a calendar year. There are also lower thresholds for chemicals of special concern from 0.1 grams to 100 pounds. These chemical lists are in the Simplified Environmental Compliance in California guide supplement 6C and 6H respectively. After review of activities and processes at Defense Distribution Depot San Joaquin, there is no Section 313 TRI reporting required for covering calendar year 2013. The following activities conducted at Defense Distribution Depot San Joaquin are not considered threshold activities for reporting: • Mission stock storage of hazardous materials items do not constitute "Manufacture, process or otherwise use" so does not meet an activity threshold for reporting. (1998 EPCRA Section 313 Q&A #87) • Mission packaging operations do not fall under the EPCRA definition of repackaging or processing. We do not remove the toxic chemical from the smallest unit, but rather we simply place it in a larger container while the contents remain in the smaller container. (1998 EPCRA Section 313 Q&A #136) • Remediation activities at the depot consist of cleaning organic contaminants from ground water and minimal contaminated soil disposal. Ground water treatment is accomplished through air stripping, which is exempt. (1998 EPCRA Section 313 Q&A #94). Soil disposal contains minimal levels of organics not on the toxic chemical lists. • Hazardous waste generated onsite is shipped offsite for disposal; this is not considered a threshold activity for reporting. The following activities are exempt from reporting according to 40 CFR 372.38 (c) (2): • Batteries used in industrial forklifts are exempted as articles. (1999 EPCRA Section 313 Q&A #66) • Office supplies that may contain EPCRA 313 chemicals are exempt as personal use (1999 EPCRA Section 313 Q&A 483) • Routine janitorial activities that might have section 313 chemicals (1998 EPCRA Section 313 Q&A #259). • Motor vehicles maintenance activities. (1999 EPCRA Section 313 Q&A #63) • Water treatment for potable drinking water and public swimming pools is "personal use" (1998 EPCRA Section 313 Q&A #261). • Pest control activities fall under facility maintenance and personal use exemptions (1998 EPCRA Section 313 Q&A #259 & Q #267). 1 of 2