FORM R REPORTS

Reference Point/Description	Latitude	Longitude	Collection Method	Accuracy Value
ENTRANCE POINT OF A FACILITY OR STATION	37.179423	-77.417027	ADDRESS MATCHING-HOUSE NUMBER	50

RCRA ID NUMBER
VAP512201107

NPDES PERMIT NUMBER
VAR051963

UIC ID NUMBER
NO DATA

To correct the FRS latitude, longitude or program ID values click on the "Report an Error" button in the top right corner of this page. Facilities wishing to correct other data elements with the FORM R or FORM A should refer to the related TRI-MEweb tutorial..

For more information, see Collection of Latitude, Longitude and Program ID Data Has Been Discontinued.

---

PART I. FACILITY IDENTIFICATION INFORMATION (FORM R)

DOCUMENT CONTROL NUMBER: 1319217631466

Facility Registry System ID:  110038263456

Section 1. Reporting Year

Reporting Year: 2019

Section 2. Trade Secret Information

2.1 Trade Secret: NO

2.2 Sanitized Copy: Unsanitized

Section 3. Certification

CERTIFYING OFFICIAL'S NAME	CERTIFYING OFFICIAL'S TITLE	CERTIFYING OFFICIAL'S SIGNATURE	DATE SIGNED
DAN GOODROW	EHS MANAGER	Electronic	27-FEB-20

Section 4. Facility Identification

TRI Facility ID: 23805BLCHT22BES

4.1 Facility Name and Address.

Facility Information

NAME	STREET	CITY	COUNTY	STATE	ZIP CODE
BLEACHTECH LLC	2020 BESSEMER RD	PETERSBURG	PETERSBURG (CITY)	VA	23805

BIA Tribal Code	Tribe
NO DATA	NO DATA

Mailing Information

NAME	STREET	CITY	STATE	ZIP CODE
BLEACHTECH LLC	350 RYAN ROAD	SEVILLE	OH	44273

PROVINCE	COUNTRY (NON - US)
NO DATA	NO DATA

4.2 Facility Classification

ENTIRE FACILITY	PARTIAL FACILITY	FEDERAL FACILITY	GOCO FACILITY
YES	NO	NO	NO

4.3 Technical Contact

Not Available to the Public as this information is only for Intranet.

4.4 Public Contact

NAME	PHONE
DAN GOODROW	3304167081

4.5 NAICS Codes

NAICS CODE	PRIMARY	NAICS CODE DESCRIPTION
325180	YES	Other Basic Inorganic Chemical Manufacturing

4.7 Dun Numbers

DUNS NUMBER
784761285

5. Parent Company Information

Parent Company Name: BLEACHTECH LLC

Parent Company DUNS Number: 784761285

---

PART II. CHEMICAL - SPECIFIC INFORMATION

DOCUMENT CONTROL NUMBER: 1319217631466

Section 1. Toxic Chemical Identity

1.1 CAS Number: 7647-01-0       PFAS Indicator: NO
1.2 Toxic Chemical or Chemical Category Name: Hydrochloric acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size)

1.3 Generic Chemical Name: NA

1.4 Distribution of Each Member of the Dioxin and Dioxin like Compounds Category

NA	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
NO

Section 2. Mixture Component Identity

2.1 Supplier Provided Generic Chemical Name: NA

Section 3. Activities and Uses of the Toxic Chemical

3.1 Manufacture the Toxic Chemical:

Produce: NO	Import: NO	On-Site Use/Processing: NO
Sale/Distribution: NO	Byproduct: NO	Impurity: NO

3.2 Process the Toxic Chemical:

Reactant: NO

Formulation Component: YES

Sub-Uses: P203 Reaction diluents

Article Component: NO

Repackaging: NO

Impurity: NO

Recycling: NO

3.3 Otherwise Use the Toxic Chemical:

Chemical Processing Aid: NO

Manufacturing Aid: NO

Ancillary or Other Use: NO

Section 4. Maximum Amount of the Toxic Chemical Onsite During the Calendar Year

Maximum Chemical Amount: 1000 to 9999

Section 5. Quantity of the Toxic Chemical Entering each Environmental Medium Onsite

5.1 Fugitive or Non-Point Air Emissions

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
NO	1 - 10	Pounds	O - Other Approaches

5.2 Stack or Point Air Emissions

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
NO	1 - 10	Pounds	E2 - Emission Factor, Site-specific

5.3 Discharges to Receiving Streams or Water Bodies

NA	STREAM/WATER BODY NAME	REACH Code	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	% FROM STORMWATER
YES	NA

5.4-5.5 Disposal to Land Onsite

5.4.1 Underground Injection Onsite to Class I Wells.

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.4.2 Underground Injection Onsite to Class II-V Wells.

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5 Disposal to Land Onsite

5.5.1A RCRA Subtitle C Landfills

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.1B Other Landfills

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.2 Land Treatment/Application Farming

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.3A RCRA Subtitle C Surface Impoundments

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.3B Other Surface Impoundments

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.4 Other Disposal

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

Optional Waste Rock Piles Information

Section 5.5 quantities include "waste rock piles":	NO
Quantity of "waste rock piles" (pounds/year*):

*For Dioxin and Dioxin-like Compounds, report in grams/year

Section 6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations

6.1 Discharges to Publicly Owned Treatment Works (POTWs)

1 - NAME:	ADDRESS:
CITY:	STATE:
COUNTY:	ZIP CODE:

POTW AMOUNT SEQUENCE	TOTAL TRANSFERS (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	WASTE MANAGEMENT TYPE
NO DATA	NO DATA		NO DATA	NO DATA

6.2 Transfers to other Off-Site Locations

RCRA Number:	Parent Company Controlled:
Name:	Address:
City:	State:
County:	Zip Code:
Country Code (Non - US):	Province:

TOTAL TRANSFERS (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	WASTE MANAGEMENT TYPE
NO DATA		NO DATA	NO DATA

Section 7A. On-Site Waste Treatment Methods and Efficiency

7A.1a. Waste Stream: NA

7A.1b.	WASTE TREATMENT METHOD(S) SEQUENCE
1	NO DATA

7A.1d. Waste Treatment Efficiency Estimate:

Section 7B. On-Site Energy Recovery Processes

ON SITE ENERGY RECOVERY PROCESSES
NA

Section 7C. On-Site Recycling Processes

ON SITE RECYCLING PROCESSES
NA

Section 8. Source Reduction and Recycling Activities

SECTION	TYPE OF QUANTITY	UNITS	PRIOR YEAR	CURRENT REPORTING YEAR	FOLLOWING YEAR	SECOND FOLLOWING YEAR
8.1a	Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills		NA	NA	NA	NA
8.1b	Total other on-site disposal or other releases	Pounds	10	10	10	10
8.1c	Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills		NA	NA	NA	NA
8.1d	Total other off-site disposal or other releases		NA	NA	NA	NA
8.2	Quantity Used for Energy Recovery Onsite		NA	NA	NA	NA
8.3	Quantity Used for Energy Recovery Offsite		NA	NA	NA	NA
8.4	Quantity Recycled Onsite		NA	NA	NA	NA
8.5	Quantity Recycled Offsite		NA	NA	NA	NA
8.6	Quantity Treated Onsite		NA	NA	NA	NA
8.7	Quantity Treated Offsite		NA	NA	NA	NA

8.8 One-Time Event Release: NA

8.9 Production Ratio   or   Activity Ratio : 1

8.10 Source Reduction Activities

SOURCE REDUCTION ACTIVITIES	METHOD 1	METHOD 2	METHOD 3	ESTIMATED ANNUAL REDUCTION
NA

8.11 Additional Data Indicator: NO

No Data Found

---

PART I. FACILITY IDENTIFICATION INFORMATION (FORM R)

DOCUMENT CONTROL NUMBER: 1319219422122

Facility Registry System ID:  110038263456

Section 1. Reporting Year

Reporting Year: 2019

Section 2. Trade Secret Information

2.1 Trade Secret: NO

2.2 Sanitized Copy: Unsanitized

Section 3. Certification

CERTIFYING OFFICIAL'S NAME	CERTIFYING OFFICIAL'S TITLE	CERTIFYING OFFICIAL'S SIGNATURE	DATE SIGNED
DAN CASMEY	EHS REPRESENTATIVE	Electronic	07-SEP-21

Section 4. Facility Identification

TRI Facility ID: 23805BLCHT22BES

4.1 Facility Name and Address.

Facility Information

NAME	STREET	CITY	COUNTY	STATE	ZIP CODE
BLEACHTECH LLC	2020 BESSEMER RD	PETERSBURG	PETERSBURG (CITY)	VA	23805

BIA Tribal Code	Tribe
NO DATA	NO DATA

Mailing Information

NAME	STREET	CITY	STATE	ZIP CODE
BLEACHTECH LLC	350 RYAN ROAD	SEVILLE	OH	44273

PROVINCE	COUNTRY (NON - US)
NO DATA	NO DATA

4.2 Facility Classification

ENTIRE FACILITY	PARTIAL FACILITY	FEDERAL FACILITY	GOCO FACILITY
YES	NO	NO	NO

4.3 Technical Contact

Not Available to the Public as this information is only for Intranet.

4.4 Public Contact

NAME	PHONE
DAN CASMEY	3302341569

4.5 NAICS Codes

NAICS CODE	PRIMARY	NAICS CODE DESCRIPTION
325180	YES	Other Basic Inorganic Chemical Manufacturing

4.7 Dun Numbers

DUNS NUMBER
784761285

5. Parent Company Information

Parent Company Name: BLEACHTECH LLC

Parent Company DUNS Number: 784761285

---

PART II. CHEMICAL - SPECIFIC INFORMATION

DOCUMENT CONTROL NUMBER: 1319219422122

Section 1. Toxic Chemical Identity

1.1 CAS Number: 7782-50-5       PFAS Indicator: NO
1.2 Toxic Chemical or Chemical Category Name: Chlorine

1.3 Generic Chemical Name: NA

1.4 Distribution of Each Member of the Dioxin and Dioxin like Compounds Category

NA	1	2	3	4	5	6	7	8	9	10	11	12	13	14	15	16	17
NO

Section 2. Mixture Component Identity

2.1 Supplier Provided Generic Chemical Name: NA

Section 3. Activities and Uses of the Toxic Chemical

3.1 Manufacture the Toxic Chemical:

Produce: NO	Import: NO	On-Site Use/Processing: NO
Sale/Distribution: NO	Byproduct: NO	Impurity: NO

3.2 Process the Toxic Chemical:

Reactant: YES

Sub-Uses: P104 Initiators P103 Intermediates P199 Other P102 Raw materials P101 Feedstocks

Formulation Component: YES

Sub-Uses: P203 Reaction diluents

Article Component: YES

Repackaging: NO

Impurity: NO

Recycling: NO

3.3 Otherwise Use the Toxic Chemical:

Chemical Processing Aid: NO

Manufacturing Aid: YES

Sub-Uses: Z299 Other

Ancillary or Other Use: NO

Section 4. Maximum Amount of the Toxic Chemical Onsite During the Calendar Year

Maximum Chemical Amount: 100 to 999

Section 5. Quantity of the Toxic Chemical Entering each Environmental Medium Onsite

5.1 Fugitive or Non-Point Air Emissions

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
NO	1 - 10	Pounds	M1 - Monitoring, Continuous

5.2 Stack or Point Air Emissions

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
NO	1 - 10	Pounds	M1 - Monitoring, Continuous

5.3 Discharges to Receiving Streams or Water Bodies

NA	STREAM/WATER BODY NAME	REACH Code	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	% FROM STORMWATER
YES	NA

5.4-5.5 Disposal to Land Onsite

5.4.1 Underground Injection Onsite to Class I Wells.

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.4.2 Underground Injection Onsite to Class II-V Wells.

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5 Disposal to Land Onsite

5.5.1A RCRA Subtitle C Landfills

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.1B Other Landfills

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.2 Land Treatment/Application Farming

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.3A RCRA Subtitle C Surface Impoundments

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.3B Other Surface Impoundments

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

5.5.4 Other Disposal

NA	TOTAL RELEASE (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE
YES

Optional Waste Rock Piles Information

Section 5.5 quantities include "waste rock piles":	NO
Quantity of "waste rock piles" (pounds/year*):

*For Dioxin and Dioxin-like Compounds, report in grams/year

Section 6. Transfers of the Toxic Chemical in Wastes to Off-Site Locations

6.1 Discharges to Publicly Owned Treatment Works (POTWs)

1 - NAME:	ADDRESS:
CITY:	STATE:
COUNTY:	ZIP CODE:

POTW AMOUNT SEQUENCE	TOTAL TRANSFERS (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	WASTE MANAGEMENT TYPE
NO DATA	NO DATA		NO DATA	NO DATA

6.2 Transfers to other Off-Site Locations

RCRA Number:	Parent Company Controlled:
Name:	Address:
City:	State:
County:	Zip Code:
Country Code (Non - US):	Province:

TOTAL TRANSFERS (per year)	UNIT OF MEASURE	BASIS OF ESTIMATE	WASTE MANAGEMENT TYPE
NO DATA		NO DATA	NO DATA

Section 7A. On-Site Waste Treatment Methods and Efficiency

7A.1a. Waste Stream: NA

7A.1b.	WASTE TREATMENT METHOD(S) SEQUENCE
1	NO DATA

7A.1d. Waste Treatment Efficiency Estimate:

Section 7B. On-Site Energy Recovery Processes

ON SITE ENERGY RECOVERY PROCESSES
NA

Section 7C. On-Site Recycling Processes

ON SITE RECYCLING PROCESSES
NA

Section 8. Source Reduction and Recycling Activities

SECTION	TYPE OF QUANTITY	UNITS	PRIOR YEAR	CURRENT REPORTING YEAR	FOLLOWING YEAR	SECOND FOLLOWING YEAR
8.1a	Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills		NA	NA	NA	NA
8.1b	Total other on-site disposal or other releases	Pounds	255	10	245.5	245.5
8.1c	Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, and other landfills		NA	NA	NA	NA
8.1d	Total other off-site disposal or other releases		NA	NA	NA	NA
8.2	Quantity Used for Energy Recovery Onsite		NA	NA	NA	NA
8.3	Quantity Used for Energy Recovery Offsite		NA	NA	NA	NA
8.4	Quantity Recycled Onsite		NA	NA	NA	NA
8.5	Quantity Recycled Offsite		NA	NA	NA	NA
8.6	Quantity Treated Onsite		NA	NA	NA	NA
8.7	Quantity Treated Offsite		NA	NA	NA	NA

8.8 One-Time Event Release: NA

8.9 Production Ratio   or   Activity Ratio : 1

8.10 Source Reduction Activities

SOURCE REDUCTION ACTIVITIES	METHOD 1	METHOD 2	METHOD 3	ESTIMATED ANNUAL REDUCTION
NA

8.11 Additional Data Indicator: NO

No Data Found

9.1 Miscellaneous, Additional or Optional Information regarding the Form R submission

COMMENT TYPE	DESCRIPTION	COMMENT TEXT
REV	Reason for Revision	A release of chlorine equal to or greater than the Reportable Quantity was reported to the National Response Center on September 13, 2019 but no quantity of chlorine was reported as an accidental/one-time release in section of 8.8 for chlorine for reporting year 2019.We did not include the "release" of "0" in our Form R submittal since we reported zero (0), an unknown quantity of Chlorine to the NRC 1258106. We were not aware of the 1258101 report (called in by Petersburg FD Chief Jim Reid) that referenced 15,000 gallons of bleach as the Material ReleasedThe waste tank involved at the time of the incident contained a few thousand gallons of brine, along with similar amounts each of process chemicals, inclusive of less than two (2) gallons of sodium hypochlorite (bleach) .Relative to 1258101 an argument could be made that as there was not 15,000 gallons of "Bleach" as was reported and which we were only recently aware existed, should be voided. In fact there needs to be clarification made of the fact that two independent and unrelated calls into NRC were made and that together they created an erroneous picture of what actually occurred, since the EPA is requesting information that combines 1258101 and 1258106 into a 15,000 gallon release of Chlorine as the narrative for RY 2019 states: "Your facility reported accidental release of 15000 GALLON(S) of CHLORINE for reporting year 2019 to National Response Center (NRC) (SEQ #: 1258101 ONLY 1258106 SHOULD BE CONSIDERED) on September-13-2019, but your facility did not report any quantity as accidental / one-time release in section 8.8 of Form R for CHLORINE for reporting year 2019". The amount of chlorine was difficult to determine as the specific quantities of each material was not known. There was HCl in the waste tank for the purposes of bringing down pH levels of the NaOH present. The NaClO was most likely less than two (2) gallons so based on this, it is estimated that a release of approximately 3-4 lbs of Chlorine was released as a result of the reaction of bleach with the HCL being added to the tank.

---