Contributor: Paul Simonetta, CHMM, CPEA Business Title: Project Manager Contact Information: Triton Environmental, Inc. New Haven, CT 06410 Phone: 203 498 8833 E-mail: psimonetta@tritonenvironmental.com Affiliation: Triton Environmental Inc. (Triton) is a full service company offering environmental consulting and engineering services. Triton's services are focused in five (5) disciplines including regulatory compliance, air compliance, assessment/ remediation, coastal permitting and land use planning. Biography: Mr. Simonetta is a Project Manager at Triton Environmental, Inc. (Triton) with over 10 years of combined environmental compliance experience in industrial manufacturing and consulting. Prior to entering the environmental consulting field, Mr. Simonetta worked for industrial manufacturers developing and managing Environmental Health and Safety (EH&S) regulatory programs. Mr. Simonetta's current responsibilities with Triton involve regulatory compliance permitting, reporting and auditing for industrial clients.

Title of Presentation: Lessons Learned - Persistent Bioaccumulative Toxins (PBTs), Reporting - New SARA Title III Form R Chemicals Author: Paul Simonetta, CHMM, CPEA Key Words: EPCRA reporting, PBTs, Form R, SARA Title III Abstract: Objective - To present lessons learned while completing the Toxic Chemical Release Report (Form R) during the first year that the new chemicals and compounds, Persistent Bioaccumulative Toxins (PBTs), were required to be reported (July 1, 2001). The Toxic Chemical Release Report is a component of the Emergency Planning Community Right-to-Know Act (EPCRA), also known as SARA Title III. Scope - Present an overview of the new requirements on PBTs. Discussion of the chemicals and brief history. Discuss affected industries broken down into three major categories including fuel consumption, fuel storage and industrial processes. Process of determining applicability (review of EPA economic analysis, calculations, etc.). Completion of calculations and Form R submittal. Present case studies and essential information (lessons learned) for late submitters or for next years submittals. Issues - EPA Economic Analysis (with associated emission, discharge and release factors), Applicability determinations, No De Minimus Exemptions, Lower Reporting Thresholds Developments - To be determined between now and July 1st of this year. Conclusions - Unknown until reports are submitted by July 1st of this year.