Bluestone completed EPRCA 312 (Tier II Chemical Inventory Reporting) and 313 (Threshold and Release Reporting) as required for the FBI Quantico Complex for Reporting Years 2016, 2017, and 2018.
To complete Form Rs, Bluestone used the Environmental Protection Agency (EPA) TRI-ME Web software (or EPA-designated replacement program) for agency submittal. The Government requested that Bluestone complete all submittal data using provided information and a site visit was not performed. Upon receipt of data, Bluestone develop an updated inventory of chemicals from the various Units and Divisions present at the facility. Bluestone then analyzed the data and provide documentation for all assumptions made and exemptions used throughout the project, including all mathematical calculations in preparation of the Form Rs. Bluestone ensured that all threshold documentation and release estimates were calculated using methodologies developed by the EPA and available industry guidance documents. Bluestone worked with a limited timeframe to gather all data and return completed reports to FBI to ensure submit to VDEQ prior to the regulatory deadline. Following submittal of final documents, Bluestone developed a report summarizing data collected, methods, results, and submittal confirmations to provide FBI with a record of background information.
Bluestone also completed and documented EPCRA 313 threshold evaluations (Non-Range and Range Complex Activities), as required. The FBI Quantico Complex only reports on lead and copper. Bluestone performed an information request and data review to ensure that all data provided by the FBI was accurate for submittal. Bluestone used the data to calculate the amount of lead and copped released from the site due to waste disposal, recycling, and air emissions. Bluestone utilized the EPA software for complete the submittal and provided the FBI representative with an electronic version of the Chemical Inventory and TRI Form R for review. Following approval of the draft forms, Bluestone prepared the online submittal for FBI certification. Bluestone also developed a summary report providing details on data gathered, calculation methods, submittal results, and explanations for items EPA identified as potential errors. All documents were submitted to FBI with sufficient time for review and correction prior to regulatory deadline.
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