International Business Machines Corporation SARA Title III/Community Right-To-Know Compliance
Posted on July 29, 2015
Client: International Business Machines Corporation
Project Type: SARA Title III/Community Right-To-Know Compliance
- Environmental Compliance Programs
- Sara Title III Planning and Reporting
International Business Machines Corporation (IBM), one of the nation’s leading manufacturers of computer and semiconductor equipment, operates a facility in East Fishkill (Hopewell Junction), New York, which is utilized principally for semiconductor research, development and manufacturing.
As part of its overall environmental compliance services, the firm offers technical support to the IBM East Fishkill facility in the area of SARA Title III planning and reporting. The primary purpose of Title III or Emergency Planning and Community Right-to-Know Act (EPCRA) is to inform communities and citizens of the potential exposure to toxic chemicals. Sections 311 and 312 require businesses to report the locations and quantities of toxic chemicals stored on-site to state and local governments on an annual basis (Tier I and Tier II Forms). Section 313 requires specific manufacturing facilities to report annual releases of toxic chemicals to the environment (Form R).
In compliance with SARA Title III, the firm completes the following services for IBM East Fishkill facility:
• Applicability Determinations
• Materials Accounting/Chemical Usage Reconciliation
• Annual Toxic Chemicals Inventory (Tier I/Tier II)
• Annual Toxic Release Inventory (Form R)
• Emergency Planning and Notification
Section 313 TRI Audit
IBM retained the firm to conduct an audit in accordance with SARA Title III Section 313 Toxic Release Inventory (TRI) requirements. The audit was conducted in two phases including a pre-audit component and a detailed audit of specific data. The pre-audit process consisted of information review and interviews with IBM East Fishkill facility representatives responsible for the preparation of data presented in the TRI forms. The detailed audit focused on an evaluation of selected data sets utilized to prepare the TRI reports.
The firm prepared a report summarizing the findings pertaining to the accuracy and completeness of the audited information associated with the IBM East Fishkill facility TRI program. The audit report was organized into four sections that corresponded to the categories of the information included in the TRI Reporting Forms:
• Chemical Usage/Threshold Determinations
• Releases to Air/On-site Treatment
• Releases to Water/On-site Treatment
• Off-site Transfers
Chemical Usage/Threshold Determinations
Chemical usage data was audited to determine TRI thresholds and materials accounting. The firm also conducted a chemical receipt audit. This audit consisted of a one-to-one comparison of chemical receipts (in the form of packing slips) to data records maintained by the IBM East Fishkill facility. The audit was conducted in the following stages:
• Identification of Chemical Receiving Procedures
• Identification/Selection of Target Chemicals
• Identification of Vendors of Target Chemicals
• Audit of Vendors Supplying Multiple Target Chemicals
• Audit of Vendors Supplying Individual Target
Data reviewed during the audit focused on the comparison of Material Safety Data Sheets (MSDSs) to the database summaries with regard to the chemical composition of the products and the percent of the products/materials used at the facility. If a MSDS failed to provide the quantities of hazardous materials in the product, the firm contacted the manufacturer directly to obtain the quantities of the hazardous materials in the product.
The quantities listed were compared with previous MSDS values to determine if the established quantities of hazardous chemicals used and released was accurate and remained unchanged from the previous year. Any differences were noted and the proper modifications are made. In one example, the manufacturers of fuel oil used by the IBM East Fishkill facility reduced the amount of naphthalene in its product. This reduction caused the quantity of naphthalene used at the facility to fall well below the reporting threshold. Because of this reduction, it is no longer necessary for the IBM East Fishkill facility to report naphthalene under the TRI program.
Releases to Air/On-site Treatment
The firm calculated the quantity of TRI chemicals at the IBM East Fishkill facility released to the environment in air and treated on-site using several methods and sources of data which varied for each chemical and/or process. Data reviewed during the audit included:
• Analytical laboratory reports,
• Database summaries (including a database of process emission sources),
• Instrument data logs, and
• Summaries of toxic chemical releases.
Laboratory reports were selected for review to confirm the data. A summary of the comparison of laboratory reports to the database summaries were included in the Audit report.
Releases to Water /On-site Treatment
The firm calculated the quantity of TRI chemicals at the IBM East Fishkill facility released to the environment in water and treated on-site that were based on analytical laboratory results of wastewater samples and wastewater flow measurements. Analytical laboratory reports for nitrates were reviewed to verify the calculation of the quantity of nitrates released to the environment in water. Monthly flows conveyed through the wastewater treatment plants, reported in the Discharge Monitoring Reports (DMRs), were also reviewed to verify the quantity of wastewater discharged from the facility during the reporting year. Review of laboratory analytical reports and DMRs confirmed the calculation of nitrates released to the environment in water.
The quantity of TRI chemicals transferred off-site is calculated based on analytical laboratory results of waste samples collected prior to off-site shipment and knowledge of the waste constituents. The percent concentration by weight of TRI chemicals in samples obtained from laboratory reports is multiplied by the total weight of the shipment obtained the manifests to calculate the quantity of TRI chemicals transferred off-site in the shipments. Selected analytical laboratory reports and the corresponding manifests were reviewed to verify the calculation of the weight of TRI chemicals transferred off-site per shipment.
Preparation of the Audit Report
The final step in the audit process is the preparation of the Audit Report. After the Audit Report was reviewed by IBM, the firm responded to any comments and prepared a final Audit Report. The conclusions and recommendations of the Audit Report identified specific changes to the data utilized to calculate reportable quantities for SARA Title III TRI Form R submittals. These changes were incorporated into the information presented on the Form Rs. In addition, the firm continues to provide ongoing technical and regulatory support to the IBM East Fishkill facility relating to SARA Title III compliance and regulatory applicability.
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