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Section 8 Resources for Third Party Load Users
Equations for Completing Section 8.1 – 8.7 of the Reporting Form R
The relationship between Sections 5-6 to Sections 8.1, 8.3, 8.5, 8.7, and 8.8 are provided below in equation form. These equations demonstrate how to complete Sections 8.1, 8.3, 8.5, and 8.7 for the current year. Any equations used in third-party load software should match these equations.
*Note: If you reported any quantities in Sections 5 or 6 as a result of remedial actions, catastrophic events, or other one-time events not associated with the production process, do not include these amounts in the equations for Section 8.1, 8.3, 8.5, or 8.7. These amounts must be reported only in Section 8.8.
- Section 8.1a = Section 5.4.1 + Section 5.5.1A + Section 5.5.1B *
- Section 8.1b = Section 5.1 + Section 5.2 + Section 5.3 + Section 5.4.2 + Section 5.5.2 + Section 5.5.3A + Section 5.5.3B + Section 5.5.4 *
- Section 8.1c = Section 6.1 (portion of transfer that is untreated and ultimately disposed of in landfills or UIC Class I Wells) + Section 6.2 (quantities associated with M codes M64, M65 and M81) *
- Section 8.1d = Section 6.1 (portion of transfer that is untreated and ultimately disposed of or otherwise released, other than disposal to landfills or UIC Class I Wells) + Section 6.2 (quantities associated with M codes M10, M41, M62, M66, M67, M73, M79, M82, M90, M94, and M99) *
- Section 8.2 is not related to Sections 5 or 6.
- Section 8.3 = Section 6.2 (quantities associated with M codes M56 and M92) *
- Section 8.4 is not related to Sections 5 or 6.
- Section 8.5 = Section 6.2 (quantities associated with M codes M20, M24, M26, M28, and M93) *
- Section 8.6 is not related to Sections 5 or 6.
- Section 8.7 = Section 6.1 (portion of transfer that is ultimately treated) + Section 6.2 (quantities associated with M codes M40, M50, M54, M61, M69, and M95) *
- Section 8.8 = Section 5 (total) + Section 6 (total) – Section 8.1a – Section 8.1b – Section 8.1c – Section 8.1d – Section 8.3 – Section 8.5 – Section 8.7
To promote consistency of quantities reported across sections of Form R, EPA discourages rounding in Section 8.
Determining Portions of POTW Transfers Ultimately Treated, Disposed of, or Otherwise Released
Facilities should use their best readily available information to determine the final disposition of the toxic chemical sent to the POTW and distribute the amount reported in Section 6.1 among Sections 8.1c, 8.1d, and 8.7 (as indicated in the equations above). Removal and destruction rates for toxic chemicals sent to POTWs, based on experimental and estimated data, can be found in Table VI of the Reporting Forms and Instructions. EPA recommends using these percentages to distribute the amounts reported in Section 6.1 unless you have better information about the specific POTW readily available.
While Section 5 and 6 may (in some cases) be completed using range codes, numeric values must be used for all inputs in the Section 8 equations above. Unless you use the midpoint of a range (i.e., 5, 250, or 750 lbs) in the Section 8 equations, EPA recommends reporting a numeric value in Section 5/6 instead of reporting a range code. Note that if you enter a range code in Sections 5 or 6, TRI data tools used by the public will display the midpoint of the range. Thus submitting a range code in Sections 5/6 but using a value other than the midpoint of the range in your Section 8 calculations may create confusion and the appearance of internal inconsistency in your submission.