United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
EPA745-B-00-005
May 2000
&EPA Emergency Planning and Community
Right-To-Know Act Section 313 Reporting
Guidance for the Printing, Publishing, and
Packaging Industry
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT vii
OVERVIEW viii
CHAPTER 1 - INTRODUCTION 1-1
1.0 PURPOSE 1-1
1.1 Background on EPCRA Section 313 and PPA Section 6607 1-2
CHAPTER 2 - REPORTING REQUIREMENTS 2-1
2.0 PURPOSE 2-1
2.1 Must You Report? 2-2
2.2 SIC Code Determination 2-4
2.3 Number of Employees 2-7
2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section
313 Chemicals or Chemical Categories 2-8
2.5 Activity Categories 2-10
2.6 Persistent, Bioaccumulative, and Toxic (PBT) Chemicals 2-13
2.7 How Do You Report? 2-15
2.8 Form R 2-16
2.9 Alternate Threshold and Form A 2-16
2.10 Trade Secrets 2-18
2.11 Recordkeeping 2-19
CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL CATEGORY
ACTIVITY THRESHOLD DETERMINATIONS 3-1
3.0 PURPOSE 3-1
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported), Processed, or
Otherwise Used 3-1
Qualifiers 3-4
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for
Each EPCRA Section 313 Chemical and Chemical Category 3-9
3.2.1 Concentration Ranges for Threshold Determination 3-13
3.2.2 Evaluation of Exemptions 3-14
3.2.2.1 DeMinimisExemption 3-15
3.2.2.2 Articles Exemption 3-18
3.2.2.3 Facility-Related Exemption 3-19
Laboratory Activity Exemption 3-19
3.2.2.4 Activity-Related Exemptions (Otherwise Use
Exemptions) 3-20
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TABLE OF CONTENTS (Continued)
Page
3.2.3 Additional Guidance on Threshold Calculations for Certain
Activities 3-22
3.2.3.1 Reuse Activities 3-22
3.2.3.2 Remediation Activities 3-23
3.2.3.3 Recycling Activities 3-23
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313 Chemical and
Chemical Category and Determine Which Ones Exceed an Activity
Threshold 3-24
CHAPTER 4 - ESTIMATING RELEASE AND OTHER WASTE MANAGEMENT
QUANTITIES 4-1
4.0 PURPOSE 4-1
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities 4-1
4.1.1 Step 1: Prepare a Process Flow Diagram 4-3
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical
Categories and Potential Sources of Chemical Release and Other
Waste Management Activities 4-3
4.1.3 Step 3: Identify Release and Other Waste Management Activity
Types 4-4
4.1.4 Step 4: Determine the Most Appropriate Method(s) and Calculate
the Estimates for Release and Other Waste Management Activity
Quantities 4-16
4.1.4.1 Monitoring Data or Direct Measurement (code M) ... 4-18
4.1.4.2 Mass Balance (code C) 4-19
4.1.4.3 Emission Factors (code E) 4-21
4.1.4.4 Engineering Calculations (code O) 4-23
4.1.4.5 Estimating Release and Other Waste Management
Quantities 4-25
4.2 Determination of Release and Other Waste Management Activity
Quantities from Printing Operations 4-30
4.2.1 Imaging/Film Processing 4-35
4.2.1.1 Step 1: Prepare Process Flow Diagram 4-36
4.2.1.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities .... 4-36
4.2.1.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-36
4.2.1.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-37
4.2.2 Image Carrier Preparation 4-38
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TABLE OF CONTENTS (Continued)
Page
4.2.2.1 Step 1: Prepare Process Flow Diagram 4-40
4.2.2.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities .... 4-40
4.2.2.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-41
4.2.2.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-41
4.2.3 Printing 4-42
4.2.3.1 Step 1: Prepare Process Flow Diagram 4-45
4.2.3.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities .... 4-46
4.2.3.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-46
4.2.3.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-48
4.2.4 Post-Press 4-53
4.2.4.1 Step 1: Prepare Process Flow Diagram 4-53
4.2.4.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities .... 4-54
4.2.4.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-54
4.2.4.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-54
Appendix A EPCRA SECTION 313 GUIDANCE RESOURCES
Appendix B BASIC CALCULATION TECHNIQUES
Appendix C GUIDANCE FOR REPORTING AQUEOUS AMMONIA
Appendix D UNIT CONVERSION FACTORS
INDEX
in
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LIST OF TABLES
Page
2-1 SIC Codes Covered by EPCRA Section 313 Reporting 2-4
2-2 SIC Codes for Facilities That May Perform Printing Operations 2-5
2-3 EPCRA Section 313 Chemicals and Chemical Categories Commonly Encountered
in Printing Operations 2-9
2-4 Activity Categories 2-12
2-5 Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals 2-13
3-1 Reporting Thresholds 3-9
3-2 Definitions and Examples of Manufacturing Subcategories 3-11
3-3 Definitions and Examples of Processing Subcategories 3-12
3-4 Definitions and Examples of Otherwise Use Subcategories 3-13
3-5 EPCRA Section 313 Reporting Threshold Worksheet 3-26
3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet 3-28
4-1 Summary of Liquid Residue Quantities From Pilot-Scale Experimental
Study 4-9
4-2 Potential Data Sources for Release and Other Waste Management
Calculations 4-18
4-3 Release and Other Waste Management Quantity Estimation Worksheet .... 4-26
4-4 Typical Release and Other Waste Management Activity Types and
Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Imaging/Film Processing 4-37
4-5 Typical Release and Other Waste Management Activity Types and
Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Image Carrier Preparation Operations 4-41
4-6 Typical Release and Other Waste Management Activity Types and
Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Printing Operations 4-48
IV
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LIST OF TABLES (Continued)
Page
4-7 Typical Release and Other Waste Management Activity Types and
Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Post-Press Operations 4-54
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LIST OF FIGURES
Page
2-1 EPCRA Section 313 Reporting Decision Diagram 2-3
4-1 Release and Other Waste Management Activity Calculation Approach 4-2
4-2 Possible Release and Other Waste Management Types for EPCRA Section
313 Chemicals and Chemical Categories 4-5
4-3 Overall Process Flow Diagram 4-34
4-4 Process Flow Diagram - Imaging/Film Processing 4-36
4-5 Process Flow Diagram - Image Carrier Preparation 4-40
4-6 Process Flow Diagram - Printing Step 4-45
4-7 Process Flow Diagram - Post-Press 4-53
VI
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ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of the Graphic Arts Technical Foundation; Doreen Monteleone, Foundation of the Flexographic
Technical Association; the Flexible Packaging Association; Ben Cooper, the Printing Industry of
America; the Gravure Association of America; and the Screen Printing and Graphic Imaging
Association. Without the insight provided by those in industry with actual experience in
fulfilling the reporting requirements of EPCRA Section 313 we would not have been able to
produce a document that we believe will be of great assistance to those who must prepare future
EPCRA Section 313 reports.
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OVERVIEW
This document supersedes the booklet entitled Title III Section 313 Release
Reporting Guidance, Estimating Chemical Releases from Printing Operations, dated January
1988. It is intended to assist establishments and facilities performing printing operations in
complying with the Emergency Planning and Community Right-To-Know Act (EPCRA) Section
313 and Pollution Prevention Act (PPA) Section 6607 reporting requirements, the preparation of
Form R or the alternate certification statement, Form A. The EPCRA Section 313 program is
commonly referred to as the Toxic Chemical Release Inventory (TRI).
The principal differences in this new document include:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
U.S. Environmental Protection Agency's (EPA's) interpretive guidance on
various issues specific to printing operations; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
documents.
This document is designed to be a supplement to the annual issue of the Toxic
Chemical Release Inventory Reporting Forms and Instructions, ( TRI Forms and Instructions). It
is organized to provide a step-by-step guide to compliance with EPCRA Section 313 and PPA
Section 6607, starting with how to determine if your facility must report and ending with
guidance for estimating release and other waste management activity quantities.
The printing, publishing, and packaging industry includes firms whose business is
dominated by printing operations, firms performing operations commonly associated with
printing such as platemaking or bookbinding, and publishers, whether or not they actually print
their own material. It is estimated that 97% of all printing activities can be categorized into five
different printing processes:
1. Lithography.
2. Gravure.
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3. Flexography.
4. Letterpress.
5. Screen Printing.
The equipment, applications, and ink formulations for each of these processes
differ; however, they all print an image on a substrate (cardboard, paper, packaging, etc.)
following the same basic sequence:
1. Imaging.
2. Pre-press.
3. Printing.
4. Post-press.
The primary sources of release and other waste management quantities of EPCRA Section 313
chemicals and chemical categories are from solvents found in the ink formulations and solvents
used in cleanup operations.
Not all printing, publishing, and packaging establishments will have all unit
operations described in this document; however, each of the unit operations discussed are
common operations found in printing operations covered by EPCRA Section 313 reporting
requirements. You should select the operation, or combination of operations, that most closely
fits the activities at your establishment.
Chapter 1 introduces EPCRA Section 313 and PPA Section 6607 reporting and
provides a brief background on Section 313 of EPCRA and Section 6607 of PPA.
Chapter 2 discusses reporting requirements and begins with how to determine
whether your facility must report. This determination is based on your answers to a series of four
questions:
Is your facility's primary SIC Code on the EPCRA Section 313 list?
Does your facility employ ten or more full-time employees or the
equivalent?
Does your facility manufacture, process, or otherwise use any EPCRA
Section 313 chemicals or chemical categories?
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• Does your facility exceed any of the activity thresholds for an EPCRA
Section 313 chemical or chemical category?
If the answer to ANY ONE of the first three questions is "No" you are not
required to submit an EPCRA Section 313 report for any chemical. If you answer "Yes" to the
first three questions and "No" to the fourth, you are not required to submit an EPCRA Section
313 report for that chemical or chemical category. If you answer "Yes" to ALL four questions,
the next step is to determine what kind of report you must prepare, a Form R or the alternate
certification statement, Form A. Chapter 2 provides detailed information on the requirements for
each kind of report. Chapter 2 concludes with a discussion on how to address trade secrets and
the records that should be kept to support your reporting.
Chapter 3 discusses how to calculate the activity thresholds (manufacture,
process, and otherwise use) for the EPCRA Section 313 chemicals or chemical categories.
Information is provided on how to determine which EPCRA Section 313 chemicals or chemical
categories your facility manufactures, processes, or otherwise uses and how to calculate the
quantities of each. Detailed information is also provided on the various exemptions:
• De minimis exemption;
• Article exemption;
• Facility-related exemption; and
• Activity-related exemptions.
Chapter 3 concludes with a discussion of how to determine which EPCRA Section 313
chemicals or chemical categories exceed a reporting threshold.
Chapter 4 discusses how to estimate the release and other waste management
activity amounts for those EPCRA Section 313 chemicals and chemical categories for which you
must prepare a report. The first part of this chapter provides a step-by-step approach designed to
minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical or
chemical category and any potential sources or types of release and other waste management
activities. This procedure consists of:
• Preparation of a detailed process flow diagram;
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• Identification of EPCRA Section 313 chemicals and chemical categories
and potential sources of chemical release and other waste management
activities;
• Identification of the potential types of release and other waste
management activities from each source; and
• Determination of the most appropriate methods for estimating the
quantities of listed EPCRA Section 313 chemical and chemical category
release and other waste management activities.
The second part of Chapter 4 is organized by the four typical activities in printing
operations where EPCRA Section 313 chemicals and chemical categories are used: imaging, pre-
press (platemaking), printing, and post-press. The commonly used EPCRA Section 313
chemicals and chemical categories, process descriptions, release and other waste management
estimates, example calculations, and common problems are presented.
This document includes examples and common errors applicable to printing
operations. These examples are based on information identified during voluntary site surveys of
facilities that have filed EPCRA Section 313 reports in the past, discussion with representatives
of the Graphic Arts Technical Foundation, the Gravure Association of America, the Foundation
of the Flexographic Technical Association, the Flexible Packaging Association, the Printing
Industry of America, the Screen Printing and Graphic Imaging Association, and on questions
received by the EPCRA Hotline.
XI
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CHAPTER 1 - INTRODUCTION
1.0 PURPOSE
The purpose of this guidance manual is two-fold. The primary purpose is to assist
facilities performing printing operations in complying with the reporting requirements of Section
313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and of
Section 6607 of the Pollution Prevention Act of 1990 (PPA). This manual explains the EPCRA
Section 313 reporting requirements and discusses specific release and other waste management
activities encountered at many facilities that conduct these operations. Since each plant is
unique, the recommendations presented may have to be modified for your particular facility. The
secondary purpose is to provide information to other interested parties (such as management,
legal professionals, inspectors, consultants, teachers, students, and the general public) about the
processes and some of the toxic chemicals used in this industry.
This manual is intended solely for guidance and does not alter any statutory or
regulatory requirements. The document should be used in conjunction with the appropriate
statutes and regulations but does not supersede them. Accordingly, the reader should consult
other applicable documents (for example, the statute, the Code of Federal Regulations (CFR),
relevant preamble language, and the current Toxic Chemical Release Inventory Reporting Forms
and Instructions (TRI Forms and Instructions)).
This document supersedes the 1988 document entitled Title III Section 313
Release Reporting Guidance, Estimating Chemical Releases from Printing Operations. This
new document includes:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
U.S. Environmental Protection Agency's (U.S. EPA's) interpretive
guidance on various issues specific to printing operations; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
document.
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It is intended to supplement the TRI Forms and Instructions document that is updated and
published annually by U.S. EPA. It is essential that you use the current version of the TRI Forms
and Instructions to determine if (and how) you should report. Changes or modifications to
EPCRA Section 313 reporting requirements are reflected in the annual TRI Forms and
Instructions and should be reviewed before compiling information for the report.
The objectives of this manual are to:
• Reduce the level of effort expended by those facilities that prepare an
EPCRA Section 313 report; and
• Increase the accuracy and completeness of the data being reported.
U.S. EPA cannot anticipate every potential issue or question that may apply to
your facility. Therefore, this manual attempts to address those issues most prevalent or common
for printing operations. Used in conjunction with the most current TRI Forms and Instructions
and Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form (2000 version), facilities should be able to provide complete and accurate
information for EPCRA Section 313 reporting. Additional discussions on specific issues can be
found in U.S. EPA's current edition of EPCRA Section 313, Questions and Answers (the 1998
edition is EPA 745-B-98-004), which is available on the U.S. EPA's TRI website
(http://www.epa.gov/tri) or by contacting the EPCRA Hotline at 1-800-424-9346 In the
Washington, DC metropolitan area, call 703-412-9810.
1.1 Background on EPCRA Section 313 and PPA Section 6607
The following overview of EPCRA Section 313 and Section 6607 of the PPA,
will provide you with a basic understanding of the objectives and requirements of this program,
and will help you in completing your forms.
One of the primary goals of EPCRA is to increase the public's knowledge of, and
access to, information on both the presence of toxic chemicals in their communities and on
releases into the environment and other waste management activities of those chemicals.
EPCRA Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2,
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Section 2.2) to submit annual reports (commonly referred to as Form R reports and Form A
reports) on over 600 EPCRA Section 313 chemicals and chemical categories. Covered facilities
report the amounts released or otherwise managed as waste. However, if a facility meets the
reporting criteria for listed toxic chemicals, the facility must report even if there are no releases
or other waste management quantities associated with these chemicals. Throughout this
document, whenever EPCRA Section 313 chemicals are discussed, the discussion includes
chemical categories, as appropriate. Chemicals or chemical categories may be added or deleted
from the list. Therefore, before completing your annual report, be sure to check the most current
list included with the TRI Forms and Instructions when evaluating the chemicals and chemical
categories present at your facility. Copies of the reporting package can be requested from the
EPCRA Hotline, 1-800-424-9346.
All facilities meeting the EPCRA Section 313 reporting criteria must report the
annual release and other waste management activity quantities (routine and accidental) of
EPCRA Section 313 chemicals and chemical categories to all environmental media. A separate
report is required for each EPCRA Section 313 chemical or chemical category that is
manufactured (including imported), processed, or otherwise used above the reporting threshold.
The reports must be submitted to U.S. EPA and State or Tribal governments, on or before July 1,
for activities in the previous calendar year. The owner/operator of the facility on July 1 is
primarily responsible for the report, even if the owner/operator did not own the facility during the
reporting year. However, property owners with no business interest in the operation of the
facility, other than a lessor interest, are exempt from reporting requirements.
EPCRA also mandates U.S. EPA to establish and maintain a publicly available
database system consisting of the information reported under Section 313 and under Section
6607 of the PPA. This database, known as the Toxic Chemical Release Inventory (TRI)
database, can be accessed through the following sources:
U.S. EPA Internet site, http://www.epa.gov/tri;
Envirofacts Warehouse Internet site, http://www.epa.gov/enviro/; and
Right-to-Know network, http://www.rtk.net/trisearch.html.
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However, information qualifying as a trade secret, in accordance with the
regulatory requirements, is protected from public release. In addition to being a resource for the
public, TRI data are also used in the research and development of regulations related to EPCRA
Section 313 chemicals and chemical categories.
To reduce the reporting burden for small businesses, U.S. EPA established an
alternate activity threshold of one million pounds manufactured, processed, or otherwise used for
facilities with total annual reportable amounts of 500 pounds or less for each EPCRA Section
313 chemical or chemical category. Provided the facility does not exceed either the reportable
amount or the alternate threshold, the facility may file a certification form (Form A) rather than
file a Form R. By filing the Form A the facility certifies that they do not exceed the reportable
amount of 500 pounds or exceed the alternate threshold of one million pounds for the respective
chemical or chemical category.
Note that the annual reportable amount includes the quantity of the EPCRA
Section 313 chemical or chemical category in all production-related waste management
activities, not just releases (see the discussion in Section 2.8 for more detail). Also note that
either a Form A or a Form R, but not both, must be submitted for each EPCRA Section 313
chemical or chemical category above any reporting threshold, even if there are zero release and
other waste management activity quantities.
Violation of EPCRA Section 313 reporting provisions may result in federal civil
penalties of up to $27,500 per day for each violation (61 FR 69360). State enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.
Members of the Graphic Arts Technical Foundation, the Foundation of the
Flexographic Technical Association, the Gravure Association of America, the Flexible
Packaging Association, the Printing Industry of America, and the Screenprinting and Graphic
Imaging Association provided input on common problems, specific to printing operations,
encountered by those completing the EPCRA Section 313 reports. U.S. EPA has combined this
input with questions forwarded to the EPCRA Hotline and those identified during voluntary site
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surveys of facilities that have filed EPCRA Section 313 reports in the past. Selected issues and
guidance addressing these common problems are presented throughout this document as
applicable.
The TRI Forms and Instructions contain discussions of common problems in
completing the EPCRA Section 313 reports. You are encouraged to read this document before
filling out the Form R (or Form A) for your facility.
If, after reading this manual, you still have questions about EPCRA Section 313
reporting, please contact the EPCRA Hotline at 1-800-424-9346 or refer to the U.S. EPA's TRI
website, http://www.epa.gov/tri. Assistance is also available from the designated EPCRA
Section 313 Coordinator in the U.S. EPA regional office and the EPCRA contact in your state
(see the TRI Forms and Instructions for a current list of these contacts). Additional guidance is
also available in the resources listed in Appendix A.
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CHAPTER 2 - REPORTING REQUIREMENTS
2.0 PURPOSE
The purpose of this chapter is to help you determine if you must prepare an
EPCRA Section 313 report(s) and, if so, what kind of a report(s) should be prepared (Form R or
the alternate certification statement, the Form A). This chapter presents the EPCRA Section 313
reporting requirements to help you determine if these requirements apply to your facility. It also
discusses the reporting of trade secrets and the records that must be kept.
To understand the following discussion you must first understand how EPCRA
defines a facility. The term "facility" is defined as, "all buildings, equipment, structures, and
other stationary items which are located on a single site or on contiguous or adjacent sites and
which are owned or operated by the same person (or by any person who controls, who is
controlled by, or who is under common control with such person). A facility may contain more
than one establishment" (40 CFR 372.3). An "establishment" is defined as, "an economic unit,
generally at a single physical location, where business is conducted, or where services or
industrial operations are performed" (40 CFR 372.3).
U.S. EPA recognizes that for business reasons it may be easier and more
appropriate for establishments at one facility to report separately. However, the combined
quantities of EPCRA Section 313 chemicals or chemical categories manufactured, processed, or
otherwise used in all establishments making up that facility must be considered for threshold
determinations. Also, the combined release and other waste management activity quantities
reported singly for each establishment must total those for the facility as a whole.
Note that if a facility is comprised of more than one establishment, once an
activity threshold is met by the facility, providing the facility meets the SIC Code and employee
threshold criteria, release and other waste management activities from all establishments at the
facility must be reported.
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Example - Multiple Establishments
Your facility has a printing and a bookbinding establishment, both with SIC Codes covered under EPCRA
Section 313. One establishment used 23,000 pounds of copper, an EPCRA Section 313 chemical, during the year
to manufacture gravure cylinders. Another establishment purchased and used 4,000 pounds of copper during the
year as a pigment in the coating of book covers. Both activities constitute processing of the EPCRA Section 313
chemical (as presented in Section 2.5 and described in detail in Chapter 3) and the total for the facility exceeded
the 25,000-pound processing threshold for the year. Thus, if your facility meets the employee threshold, you must
file one Form R for copper from your facility, or two Form Rs, one from each establishment. Please note that
you may be eligible to file one Form A for the facility but you cannot file a separate Form A for each
establishment.
2.1 Must You Report?
How do you determine if your facility must prepare an EPCRA Section 313
report? Your answers to the following four questions will help you decide (illustrated by Figure
2-1):
1) Is the primary SIC Code for your facility included in the list covered by
EPCRA Section 313 reporting (see Section 2.2)?
2) Does your facility have 10 or more full-time employees or the equivalent
(see Section 2.3)?
3) Does your facility manufacture (which includes importation), process, or
otherwise use EPCRA Section 313 chemicals or chemical categories (see
Section 2.4)?
4) Does your facility exceed any applicable thresholds of EPCRA Section
313 chemicals or chemical categories (for non-PBT chemicals: 25,000
pounds per year for manufacturing; 25,000 pounds per year for processing;
or 10,000 pounds per year for otherwise use - see Section 2.5; for PBT
chemicals - see Section 2.6 for applicable thresholds)?
If you answered "No" to any of the first three questions, you are not required to
prepare any EPCRA Section 313 reports. If you answered "Yes" to ALL of the first three
questions, you must complete a threshold calculation for each EPCRA Section 313 chemical at
the facility, and submit an EPCRA Section 313 report for each chemical and chemical category
exceeding the applicable threshold.
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Is Your Facility's Primary SIC Code Included
on the EPCRA Section 313 List?
(See Section 2.2)
NO
YES
Does Your Facility Have 10 or More Full-Time
Employees or the Equivalent?
(See Section 2.3)
NO
YES
Does Your Facility Manufacture, Process, or
Otherwise Use any EPCRA Section 313
Chemicals or Chemical Categories?
(See Section 2.4)
NO
STOP
NO EPCRA
SECTION 313 REPORTS
REQUIRED FOR ANY
CHEMICALS OR
CHEMICAL CATEGORIES
YES
Does Your Facility Exceed Any of the
Thresholds for a Chemical or Chemical
Category (after excluding quantities that are
exempt from threshold calculations)
(See Section 2.6)
NO
AN EPCRA SECTION 313 REPORT IS
NOT REQUIRED FOR THIS CHEMICAL
OR CHEMICAL CATEGORY
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
Is the Amount Manufactured, OR Processed, OR Otherwise Used less than or equal to 1,000,000
pounds AND is the Reportable Amount less than or equal to 500 Ib/yr
(See Section 2.9)
YES
NO
FORM A OR FORM R
IS REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY (FOR PBT
CHEMICALS, A FORM R IS REQUIRED)
FORM R IS REQUIRED FOR THIS
CHEMICALORCHEMICAL
CATEGORY (FORM A CANNOT BE
SUBMITTED)
Figure 2-1. EPCRA Section 313 Reporting Decision Diagram
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2.2
SIC Code Determination
Facilities with the SIC Codes presented in Table 2-1 are covered by the EPCRA
Section 313 reporting requirements.
Table 2-1
SIC Codes Covered by EPCRA Section 313 Reporting
SIC Codes
10
12
20 through 3 9
4911, 4931, and 4939
4953
5169
5171
7389
Industry
Metal Mining
Coal Mining
Manufacturing
Electric and Other Services and
Combination Utilities
Refuse Systems
Chemicals and Allied Products
Petroleum Bulk Stations and Terminals
Business Services
Qualifiers
Except SIC Codes 1011, 1081, and 1094
Except SIC Code 1241
None
Limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce
Limited to facilities regulated under
RCRA Subtitle C
None
None
Limited to facilities primarily engaged in
solvent recovery services on a contract or
fee basis
Table 2-2 presents a listing of each SIC Code for facilities typically engaged in
printing operations, with brief descriptions. You should determine the SIC Code(s) for your
facility, based on the activities on site. For assistance in determining which SIC Code best suits
your facility refer to Standard Industrial Classification Manual, 1987 published by the Office of
Management and Budget.
As an independent activity, printing operations would most likely be included
under SIC Code 27 - Printing, Publishing, and Allied Industries. In addition, some printing
operations may fall under SIC Code 26 - Paper and Allied Products.
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Table 2-2
SIC Codes for Facilities That May
Perform Printing Operations
SIC Code
2653
2657
2672
2673
2674
2677
2678
2679
2711
2721
2731
2732
2741
2752
2754
2759
2761
2771
2782
2789
2791
2796
3999
SIC Description
Corrugated and solid fiber boxes
Folding paperboard boxes, including sanitary
Coated and laminated paper, n.e.c.*
Plastics, foil, and coated paper bags
Uncoated paper and multiwall bags
Envelopes
Stationary, tablets, and related products
Converted paper and paperboard products, n.e.c.*
Newspapers: publishing, or publishing and printing
Periodicals: publishing, or publishing and printing
Books: publishing, or publishing and printing
Book printing
Miscellaneous publishing
Commercial printing, lithography
Commercial printing, gravure
Commercial printing, n.e.c.*
Manifold business forms
Greeting cards
Blankbooks, looseleaf binders and devices
Bookbinding and related work
Typesetting
Platemaking and related services
Manufacturing Industries, n.e.c.*
* n.e.c. - not elsewhere classified
Note that auxiliary facilities can assume the SIC Code of another covered
establishment if the primary function is to support the covered establishment's operations. For
the purpose of EPCRA Section 313, auxiliary facilities are defined as those that are primarily
engaged in performing support services for another covered establishment or multiple
establishments of a covered facility, and are in a different physical location from the primary
facility. In addition, auxiliary facilities perform an integral role in the primary facility's
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activities. In general, the auxiliary facility's basic administrative services (e.g., paperwork,
payroll, employment) are performed by the primary facility. If an auxiliary facility's primary
function is to support/service a facility with a covered SIC Code, the auxiliary facility assumes
the covered SIC Code as its primary SIC code and must consider the other reporting requirements
(40 CFR Section 372.22) to determine if it must comply with the EPCRA Section 313 reporting
requirements. However, if the SIC Code for the primary facility is not covered by EPCRA
Section 313, then neither the primary nor the auxiliary facility is required to submit a report.
If your facility has more than one SIC Code (i.e., several establishments with
different SIC Codes are owned or operated by the same entity and are located at your facility),
you are subject to reporting requirements if:
All the establishments have SIC Codes covered by EPCRA Section 313;
OR
The total value of the products shipped or services provided at
establishments with covered SIC Codes is greater than 50% of the value of
the entire facility's products and services; OR
Any one of the establishments with a covered SIC Code ships and/or
produces products or provides services whose value exceeds the value of
services provided, products produced and/or shipped by every other
establishment within the facility.
A pilot plant within a covered SIC Code is considered a covered facility and is
subject to reporting, provided it meets the employee and activity criteria (note that pilot plants are
not eligible for the laboratory exemption, which is discussed in Section 3). Warehouses on the
same site as facilities in a covered SIC Code, and warehouses that qualify as auxiliary facilities of
covered facilities, are also subject to reporting, provided all applicable reporting requirements are
met.
While you are currently required to determine your facility's reporting eligibility
based on the SIC code system described above, it is important to be aware that the SIC code
system will be replaced by a new system in the future. On April 9, 1997 (62 FR 17287), the
Office of Management and Budget promulgated the North American Industrial Classification
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System (NAICS). NAICS is a new economic classification system that replaces the SIC code
system as a means of classifying economic activities for economic forecasting and statistical
purposes. The transition to the new NAICS may require regulatory actions. As a result, the SIC
code system is still required to be used as the mechanism to determine your facility's reporting
eligibility. EPA will issue notice in the Federal Register to inform you and other EPCRA
Section 313 facilities of its plans to adopt the NAICS and how facilities should make their
NAICS code determination.
2.3 Number of Employees
If your facility meets SIC Code and activity threshold criteria, you are required to
prepare an EPCRA Section 313 report if your facility has 10 or more full-time employees or the
equivalent. A full-time employee equivalent is defined as a work year of 2,000 hours. If your
facility's employees hours total 20,000 or more hours in a calendar year, you meet the 10 or more
employee threshold criterion.
The following information should be included in your employee calculations:
• Owners;
• Operations/manufacturing staff;
• Clerical staff;
• Temporary employees;
• Sales personnel;
• Truck drivers (employed by the facility);
• Other non-manufacturing or off-site facility employees directly supporting
the facility;
• Paid vacation and sick leave; and
• Contractor employees (maintenance, construction, etc. but excluding
contracted truck drivers and minor intermittent service vendors (e.g., trash
handlers)).
In general, if an individual is employed or hired to work at the facility, all the
hours worked by that individual (including paid leave and overtime) for the facility should be
counted in determining if the 20,000-hour criterion has been met.
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Example - Employee Equivalent Calculation
Your facility has six full-time employees working 2,000 hours/year. You also employ two full-time sales people
and a delivery truck driver (employed by the facility) who are assigned to the plant, each working 2,000
hours/year but predominantly on the road or from their homes. The wastewater treatment system (on site and
owned by the facility) is operated by a contractor who spends an average of two hours per day and five days per
week at the plant. Finally, you built an addition to the plant warehouse during the year, using four contractor
personnel who were on site full time for six months (working on average of 1,000 hours each). You would
calculate the number of full-time employee equivalents as follows:
• Hours for your nine full-time employees (six plant personnel, two salespeople, and one
delivery truck driver) are:
(9 employees) * (2,000 hours/year) = 18,000 hours/year
• Hours for the wastewater treatment system operator are:
(2 hours/day) x (5 days/week) x (52 weeks/year) = 520 hours/year; and
• Hours for the construction crew are:
(4 contractors) x (1,000 hours) = 4,000 hours/year.
Your facility has a total of 22,520 hours for the year, which is above the 20,000 hours/year threshold; therefore,
you meet the employee criterion.
2.4 Manufacturing. Processing, and Otherwise Use of EPCRA Section 313
Chemicals or Chemical Categories
If you are in a covered SIC Code and have 10 or more full-time employee
equivalents, you must determine which EPCRA Section 313 chemicals and chemical categories
are manufactured, processed, or otherwise used at your facility. You should prepare a list which
includes all chemicals and chemical categories found in mixtures and trade name products at all
establishments at the facility. This list should then be compared to the CURRENT list of
EPCRA Section 313 chemicals and chemical categories found in the TRIForms and Instructions
document for that reporting year (also available from the EPCRA Hotline, 1-800-424-9346).
Once you identify the EPCRA Section 313 chemicals and chemical categories at your facility,
you must evaluate the activities involving each chemical and chemical category and determine if
any activity thresholds have been met.
The original list of chemicals or chemical categories subject to EPCRA Section
313 reporting was a combination of lists from New Jersey and Maryland. Refinements to the list
have been made and changes are anticipated to continue. The list can be modified by U.S. EPA
initiatives or industry or the public can petition U.S. EPA to modify the list. When evaluating a
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chemical or chemical category for addition or deletion from the list, U.S. EPA must consider the
chemical's or chemical category's potential acute human health effects, chronic human health
effects, or its adverse environmental effects. U.S. EPA reviews these petitions and initiates a
rulemaking to add or delete the chemical or chemical category from the list, or publishes an
explanation why it denied the petition.
Note that chemicals and chemical categories are periodically added, delisted, or
modified. Therefore, it is imperative that you refer to the appropriate reporting year's list. You
can refer to the U.S. EPA's TRI website, http://www.epa.gov/tri, for updated guidance. Also,
note that a list of synonyms for EPCRA Section 313 chemicals and chemical categories can be
found in the U.S. EPA publication Common Synonyms for Chemicals Listed Under Section 313
of the Emergency Planning and Community Right-To-Know Act, (EPA 745-R-95-008). Table
2-3 lists the EPCRA Section 313 chemicals and chemical categories most frequently reported for
printing operations. Some of the chemicals may be used both as a carrier solvent in ink
formulations and for cleanup operations. This list is not intended to be all inclusive and should
only be used as a guide.
Table 2-3
EPCRA Section 313 Chemicals and Chemical Categories
Commonly Encountered in Printing Operations
Process
Ink solvent
Cleaning
Fountain solution
Cleaning
Cleaning
Acrylic coatings, gravure inks
Copper plating
Red ink pigments
Green ink pigment
Adhesive solvent
Ink solvent
Fountain solution cleaning
Plasticizer
Chemical
Toluene, MEK, Methanol, Xylene,
Ethylbenzene
Certain Glycol Ethers
Xylene (mixed), MffiK
Zinc Compounds
Copper
Barium Compounds
Copper Compounds
n-Hexane
n-Butyl Alcohol
Ethylene Glycol
Dibutyl Phthalate
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Table 2-3 (Continued)
Process
Cleaning solvent
Water-based inks and coatings
Cleaning
Etching
Chemical
Ethylbenzene,
Hexane
1 ,2,4-Trimethylbenzene,
Ammonia
Nitric Acid
2.5
Activity Categories
EPCRA Section 313 defines three activity categories for the listed chemicals and
chemical categories: manufacturing (which includes importing), processing, and otherwise use.
The activity thresholds are 25,000 pounds per year for manufacturing, 25,000 pounds per year for
processing, and 10,000 pounds per year for otherwise use.1 These thresholds apply to each
chemical or chemical category individually. The quantity of chemicals or chemical categories
stored on site or purchased is not relevant for threshold determinations. Rather, the
determination is based solely on the annual quantity actually manufactured (including imported),
processed, or otherwise used. Therefore, EPCRA Section 313 chemicals and chemical categories
that are brought on site and stored, but are not prepared in the reporting year for distribution in
that year or subsequent years or are not otherwise used on site during the reporting year, are not
considered towards any activity threshold.
Expanded definitions, with examples, of each of the three activities are found in
Chapter 3, Tables 3-2, 3-3, and 3-4. The terms are briefly defined in Table 2-4.
Relabeling or redistribution of an EPCRA Section 313 chemical or chemical
category where no repackaging occurs does not constitute manufacturing, processing, or
otherwise use of that chemical. This type of activity should not be included in threshold
determinations.
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Example - Relabeling
You buy a mixture in small containers that contains an EPCRA Section 313 chemical. When it arrives you put
your own label on each container and put the containers in a larger box with several other items you manufacture,
and sell the larger box as a kit. The quantity of the EPCRA Section 313 chemical in the small containers should
not be counted toward the processing threshold (because you did not repackage the chemical) or the otherwise use
threshold, nor should it be counted toward the manufacturing activity threshold unless the small containers were
imported. However, you must consider other EPCRA Section 313 chemicals that you manufactured in the kit
toward manufacturing and processing threshold determinations.
Example - Treatment of Wastes from Off Site
A large printing facility receives a waste containing 12,000 pounds of Chemical A, an EPCRA Section 313
chemical, from off-site. The facility treats the waste, destroying Chemical A and in the treatment process
manufactures 10,500 pounds of Chemical B, another EPCRA Section 313 chemical. Chemical B is disposed on
site.
Since the waste was received from off site for the purpose of waste management, the amount of Chemical A must
be included in the otherwise use threshold determination for Chemical A. The otherwise use threshold is 10,000
pounds and since the amount of Chemical A exceeds this threshold, all release and other waste management
activities for Chemical A must be reported.
Chemical B was manufactured in the treatment of a waste received from off site. Accordingly, the quantity of
chemical B should be counted towards the manufacturing threshold. However, the facility disposed of Chemical
B on site and "otherwise use" of a toxic chemical includes disposal, stabilization (without subsequent distribution
in commerce) or treatment for destruction if the toxic chemical that was disposed, stabilized, or treated for
destruction was manufactured as a result of waste management activities on materials received from off site for
the purpose of further waste management activities. Therefore, the amount of Chemical B must also be
considered in the otherwise use threshold determination. Thus, at 10,0500 pounds, the otherwise use reporting
threshold for Chemical B has been exceeded and all release and other waste management activities for Chemical
B must be reported.
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Table 2-4
Activity Categories
Activity
Category
Definition
Threshold1
(Ib/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical.
Manufacture also applies to an EPCRA Section 313 chemical that is produced
coincidentally during the manufacture, processing, otherwise use, or disposal of another
chemical or mixture of chemicals as a byproduct, and an EPCRA Section 313 chemical
that remains in that other chemical or mixture of chemicals as an impurity during the
manufacturing, processing, or otherwise use or disposal of any other chemical substance
or mixture. An example would be the production of ammonia or nitrate compounds in a
wastewater treatment system.
25,000
Process
To prepare an EPCRA Section 313 chemical, or a mixture or trade name product
containing an EPCRA Section 313 chemical, for distribution in commerce. For example,
the addition of EPCRA Section 313 listed pigments to ink should be reported if you
exceeded the reporting threshold. Processing includes the preparation for sale to your
customers (and transferring between facilities within your company) of a chemical or
formulation that you manufacture. For example, if you manufacture an EPCRA Section
313 chemical or chemical category or product, package it, and then distribute it into
commerce, this chemical has been manufactured AND processed by your facility.
25,000
Otherwise
Use
Generally, use of an EPCRA Section 313 chemical category that does not fall under the
manufacture or process definitions is classified as otherwise use. An EPCRA Section 313
chemical or chemical category that is otherwise used does not function by being
incorporated into a product that is distributed in commerce, but may be used instead as a
manufacturing or processing aid (e.g., catalyst), in waste processing, or as a fuel
(including waste fuel). For example, xylene used as a carrier solvent for ink is classified
as otherwise used.
OnMay 1, 1997 U.S. EPA revised the interpretation of otherwise use. The following new
otherwise use definition became effective with the 1998 reporting year (62 FR 23834,
May 1, 1997):
Otherwise use means "any use of a toxic chemical contained in a mixture or other
trade name product or waste, that is not covered by the terms manufacture or
process. Otherwise use of a toxic chemical does not include disposal, stabilization
(without subsequent distribution in commerce), or treatment for destruction
unless:
1) The toxic chemical that was disposed, stabilized, or treated for destruction was
received from off site for the purposes of further waste management; OR
2) The toxic chemical that was disposed, stabilized, or treated for destruction was
manufactured as a result of waste management activities on materials received
from off site for the purposes of further waste management activities."
10,000
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Also, note that the threshold determinations for the three activity categories
(manufacturing, processing, and otherwise use) are mutually exclusive. That is, you must
conduct a separate threshold determination for each activity category and if you exceed any
threshold, all release and other waste management activities of that EPCRA Section 313
chemical at the facility must be considered for reporting.
2.6
Persistent. Bioaccumulative., and Toxic (PBT) Chemicals
U.S. EPA promulgated the final rule for Persistent, Bioaccumulative, and Toxic
(PBT) chemicals in the October 29, 1999 Federal Register (64 FR 209). This rule applies for the
reporting year beginning January 1, 2000 (for EPCRA Section 313 reports that must be filed by
July 1, 2001).
In this rule, U.S. EPA has added seven chemicals and lowered the reporting
thresholds for 18 chemicals and chemical categories that meet the EPCRA Section 313 criteria
for persistence and bioaccumulation. The PBT chemicals and their final thresholds are listed in
Table 2-5.
Table 2-5
Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals
Chemical Name or Chemical Category
Aldrin
Benzo(g,h,i)perylene
Chlordane
Dioxin and dioxin-like compounds category
(manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that chemical)
Heptachlor
Hexachlorobenzene
Isodrin
Methoxychlor
CASRN
309-00-2
191-24-2
57-74-9
NA
76-44-8
118-74-1
465-73-6
72-43-5
Section 313 Reporting Threshold (in
pounds unless noted other-wise)
100
10
10
0.1 grams
10
10
10
100
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Table 2-5 (Continued)
Chemical Name or Chemical Category
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polycyclic aromatic compounds category
Polychlorinated biphenyl (PCBs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
Mercury
Mercury compounds
CASRN
29082-74-4
40487-42-1
608-93-5
NA
1336-36-3
79-94-7
8001-35-2
1582-09-8
7439-97-6
NA
Section 313 Reporting Threshold (in
pounds unless noted other-wise)
10
100
10
100
10
100
10
100
10
10
U.S. EPA also added two chemicals to the polycyclic aromatic compounds
(PACs) category that is listed above:
• Benzo(j,k)fluorene (fluoranthene)
• 3-methyl chloanthrene
These two chemicals are not to be reported individually; rather, they should be included within
the PACs compound category.
U.S. EPA finalized two thresholds based on the chemicals' potential to persist and
bioaccumulate in the environment. The two levels include setting Section 313 manufacture,
process, and otherwise use thresholds to 100 pounds for PBT chemicals and to 10 pounds for that
subset of PBT chemicals that are highly persistent and highly bioaccumulative. One exception is
the dioxin and dioxin-like compounds category. EPA set the threshold for the dioxin and dioxin-
like compound category at 0.1 gram.
U.S. EPA eliminated the de minimis exemption for the PBT chemicals. However,
this action does not affect the applicability of the de minimis exemption to the supplier
notification requirements (40 CFR 372.45(d)(l)). U.S. EPA also excluded all PBT chemicals
from eligibility for the alternate threshold of 1 million pounds (see Section 2.9) and eliminated
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range reporting of PBT chemicals and chemical categories for on-site releases and transfers off-
site for further waste management.
Concurrent with the additions and lowered thresholds discussed above, U.S. EPA
added "vanadium, except when contained in an alloy" and "vanadium compounds" to the list of
toxic chemicals subject to reporting under EPCRA Section 313. The corresponding thresholds
for vanadium and vanadium compounds remain 10,000 pounds if otherwise used, 25,000 pounds
if processed, and 25,000 pounds if manufactured. Please refer to the discussion on "Qualifiers"
in Section 3.1 if vanadium is a concern at your facility.
Note that U.S. EPA is currently developing five guidance documents for
chemicals modified in the PBT rule:
Dioxins and dioxin-like compounds;
Mercury and mercury compounds;
Vanadium and vanadium compounds;
Polycyclic aromatic compounds (PACs) category; and
Other PBT chemicals.
Please refer to this guidance if applicable to your facility.
2.7 How Do You Report?
You must submit an EPCRA Section 313 report for each EPCRA Section 313
chemical or chemical category that exceeds a threshold for manufacturing, OR processing, OR
otherwise use (providing you meet the employee and SIC Code criteria). Provided you do not
exceed certain alternate activity thresholds and total annual reportable amounts, you may prepare
a Form A (See Section 2.9) rather than a Form R. The TRI Forms and Instructions contain
detailed directions for the preparation and submittal of EPCRA Section 313 reports for the
reporting year. The TRI Forms and Instructions are sent to all facilities that submitted EPCRA
Section 313 reports the preceding year. However, if you do not receive a courtesy copy, you may
request copies of the TRI Forms and Instructions from the EPCRA Hotline (1-800-424-9346).
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2.8 FormR
Form R is the report in which the information required by EPCRA Section 313 is
reported. If you are submitting a Form R, it is essential that you use the TRI Forms and
Instructions for the appropriate reporting year. U.S. EPA encourages the electronic submittal of
the Form R, via the Automated Toxic Chemical Release Inventory Reporting Software (ATRS).
Use of the ATRS will save preparation time in data entry and photocopying and reduce errors via
on-line validation routines and use of pick lists. The ATRS can be found on the Internet at:
• http://www.epa.gov/atrs
The ATRS is available in both DOS and Windows versions. More information can be found in
the TRI Forms and Instructions and by calling the ATRS User Support Hotline at (703) 816-
4434.
The Form R consists of two parts:
Part I. Facility Identification Information. This part may be photocopied and re-
used for each Form R you submit, except for the signature, which must be original
for each submission.
Part II. Chemical Specific Information. You must complete this part separately
for each EPCRA Section 313 chemical or chemical category; it cannot be reused
year to year even if reporting has not changed.
Submission of incomplete EPCRA Section 313 reports may result in issuance of a
Notice of Technical Error (NOTE), Notice of Significant Error (NOSE), or Notice of Non-
compliance (NON). See the current TRI Forms and Instructions for more detailed information
on completing the Form R and submitting the EPCRA Section 313 report.
2.9 Alternate Threshold and Form A
U.S. EPA developed the Form A, also referred to as the "Certification Statement,"
to reduce the annual reporting burden for facilities with minimal amounts of EPCRA
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Section 313 chemicals or chemical categories released and otherwise managed as waste (59 FR
61488, November 1994; applicable beginning reporting year 1994 and beyond). On Form A you
certify that you are not required to report the release and other waste management information
required by EPCRA Section 313 and PPA Section 6607. A facility must meet the following two
criteria to use a Form A:
First, the total annual reportable amount of the EPCRA Section 313
chemical cannot exceed 500 pounds per year. The "reportable amount" is
defined as the sum of the on-site amounts released (including disposal),
treated, recycled, and combusted for energy recovery, combined with the
sum of the amounts transferred off site for recycling, energy recovery,
treatment, and/or release (including disposal). This total corresponds to
the total of data elements 8.1 through 8.7 on the 1999 version of the
Form R.
Second, the amount of the EPCRA Section 313 chemical manufactured,
processed, OR otherwise used cannot exceed one million pounds. It is
important to note that the quantities for each activity are mutually
exclusive and must be evaluated independently. If the quantity for any one
of the activities exceeds 1,000,000 pounds a Form A cannot be used.
Example - Form A Threshold
If the combined annual reportable amounts from all activities do not exceed 500 pounds, a facility that
manufactures 900,000 pounds of an EPCRA Section 313 chemical and processes 150,000 pounds of the same
chemical is eligible to use the Form A because the facility did not exceed the one million pounds for either
activity, even though the total usage exceeds one million pounds.
The Form A Certification Statement must be submitted for each eligible EPCRA
Section 313 chemical or chemical category. The information on the Form A will be included in
the publicly accessible TRI database; however, these data are marked to indicate that they
represent certification statements rather than Form Rs. Note that separate establishments at a
facility cannot submit separate Form As for the same chemical or chemical category; rather, only
one Form A per EPCRA Section 313 chemical or chemical category can be submitted per
facility.
While Form A requests facility identification and chemical identification
information, no release and other waste management quantity estimations to any media are
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required. You must simply certify that the total annual reportable amount did not exceed 500
pounds and that amounts manufactured, processed, or otherwise used did not exceed one million
pounds. Once the facility has completed estimates to justify the submission of a Form A, there is
a considerable time savings in using the Form A, especially in subsequent years, providing
activities involving the chemical or chemical category did not change significantly. It is strongly
recommended that you document your initial rationale and refer to it every year, to verify that
you have not modified a part of the process that would invalidate the initial rationale supporting
submission of Form A.
2.10 Trade Secrets
If you submit trade secret information, you must prepare two versions of the
substantiation form as prescribed in 40 CFR Part 350 (see 53 FR 28801, July 29, 1988) as well as
two versions of the EPCRA Section 313 report. One set of reports should be "sanitized" (i.e., it
should provide a generic name for the EPCRA Section 313 chemical or chemical category
identity). This version will be made available to the public. The second version, the
"unsanitized" version, should provide the actual identity of the EPCRA Section 313 chemical
and chemical category and have the trade secret claim clearly marked in Part I, Section 2.1 of the
Form R or Form A. The trade secrets provision only applies to the EPCRA Section 313 chemical
or chemical category identity. All other parts of the Form R or Form A must be filled out
accordingly.
Individual states may have additional criteria for confidential business information
and the submittal of both sanitized and unsanitized reports for EPCRA Section 313 chemicals
and chemical categories. Facilities may jeopardize the trade secret status of an EPCRA Section
313 chemical by submitting an unsanitized version to a state agency or tribal government that
does not require an unsanitized version.
More information on trade secret claims, including contacts for individual state's
submission requirements, can be found in the TRI Forms and Instructions.
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2.11 Recordkeeping
Complete and accurate records are absolutely essential to meaningful compliance
with EPCRA Section 313 reporting requirements. Compiling and maintaining good records will
help you to reduce the effort and cost in preparing future reports, and to document how you
arrived at the reported data in the event of U.S. EPA compliance audits. U.S. EPA requires you
to maintain records substantiating each EPCRA Section 313 report submission for a minimum of
three years. Each facility must keep copies of every EPCRA Section 313 report along with all
supporting documents, calculations, work sheets, and other forms that you used to prepare the
EPCRA Section 313 report. U.S. EPA may request this supporting documentation during a
regulatory audit.
Specifically, U.S. EPA requires the following records be maintained for a period
of three years from the date of the submission of a report (summarized from 40 CFR 372.10):
1) A copy of each EPCRA Section 313 report that is submitted.
2) All supporting materials and documentation used to make the compliance
determination that the facility or establishment is a covered facility.
3) Documentation supporting the report submitted, including:
• Claimed allowable exemptions,
• Threshold determinations,
• Calculations for each quantity reported as being released, either on
or off site, or otherwise managed as waste,
• Activity determinations, including dates of manufacturing,
processing, or use,
• The basis of all estimates,
• Receipts or manifests associated with transfers of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
4) For facilities submitting a Form A, all supporting materials used to make
the compliance determination the facility or establishment is eligible to
submit a Form A, including:
• Data supporting the determination the alternate threshold applies,
• Calculations of the annual reportable amounts,
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• Receipts or manifests associated with the transfer of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
Because EPCRA Section 313 reporting does not require additional testing or
monitoring you must determine the best readily available source of information for all estimates.
Some facilities may have detailed monitoring data and off-site transfer records that can be used
for estimates while others may only have purchase and inventory records. Examples of records
that you should keep, if applicable, might include:
Each EPCRA Section 313 report submitted;
EPCRA Section 313 Reporting Threshold Worksheets (sample worksheets
can be found in Chapter 3 of this document as well as in the TRI Forms
and Instructions);
EPCRA Section 313 Reporting Release and Other Waste Management
Quantity Estimation Worksheets (sample worksheets can be found in
Chapter 4 of this document);
Engineering calculations and other notes;
Purchase records from suppliers;
Formulation sheets;
Inventory data;
Material Safety Data Sheets (MSDS);
New Source Performance Standards;
National Pollutant Discharge Elimination System (NPDES)/State Pollutant
Discharge Elimination System (SPDES) permits and monitoring reports;
EPCRA Section 312, Tier II reports;
Monitoring records;
Air permits;
Flow measurement data;
Resource Conservation Recovery Act (RCRA) hazardous waste
generator's reports;
Pretreatment reports filed with local governments;
Invoices from waste management firms;
Manufacturer's estimates of treatment efficiencies;
Comprehensive Environmental Response, Conservation, and Liability Act
of 1980 (CERCLA) Reportable Quantity (RQ) reports;
RCRA manifests; and
Process flow diagrams (including emissions, releases, and other waste
management activities).
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CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR
CHEMICAL CATEGORY ACTIVITY THRESHOLD DETERMINATIONS
3.0 PURPOSE
This chapter provides a step-by-step procedure for determining if any EPCRA
Section 313 chemicals or chemical categories exceed a reporting threshold. Threshold
determinations are essentially a three step process:
Step 1) Identify any EPCRA Section 313 chemicals or chemical categories
you manufacture/import, process, or otherwise use.
Step 2) Identify the activity category and any exempt activities for each
EPCRA Section 313 chemical or chemical category.
Step 3) Calculate the quantity of each EPCRA Section 313 chemical or
chemical category and determine which ones exceed an activity
threshold.
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported). Processed, or Otherwise
Used
Compile lists of all chemicals and mixtures at your facility. For facilities with
many different chemicals and mixtures it is often helpful to prepare two lists: one with the pure
(single ingredient) chemicals (including chemical compounds) and one with the mixtures and
trade name products. On the second list, under the name of each mixture/trade name product,
write the names of all chemicals in that product. Next, compare the chemicals or chemical
categories on both lists to the current EPCRA Section 313 chemicals and chemical categories list
found in the TRI Forms and Instructions (remember that chemicals and chemical categories may
be periodically added and deleted and you should use the current reporting year's instructions).
Highlight the EPCRA Section 313 chemicals and chemical categories that are on your lists.
Review the lists to be sure each chemical or chemical category is shown by its
correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical
found in printing operations is toluene. Toluene (Chemical Abstracts Service (CAS) Registry
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No. 108-88-3) has several synonyms including methylbenzene, methylbenzol, phenylmethane,
and toluol. It must be reported on Form R (or Form A), Item 1.2, by its EPCRA Section 313
chemical name, toluene. Synonyms can be found in the U.S. EPA document Common Synonyms
for Chemicals Listed Under Section 313 of the Emergency Planning and Community Right-to-
Know Act (EPA 745-R-95-008).
While you must consider every chemical on the EPCRA Section 313 chemical or
chemical category list, you should be aware of the chemicals or chemical categories typically
used in printing operations. As a guide, the most frequently reported EPCRA Section 313
chemicals or chemical categories for reporting year 1995 in printing operations, and the
processes they are typically used in, are listed in Table 2-3.
A computerized spreadsheet may be helpful in developing your facility's chemical
or chemical category list and performing threshold calculations. The spreadsheet could show the
chemical or chemical category mixture with corresponding component concentrations; the yearly
quantity manufactured, processed, or otherwise used; and the CAS Registry number. The
spreadsheet could also be designed to identify the total quantity by activity category (amounts
manufactured, processed, and otherwise used) for each EPCRA Section 313 chemical or
chemical category in every mixture, compound, and trade name product.
An initial investment of time will be required to develop this spreadsheet;
however, the time and effort saved in threshold calculations in subsequent years will be
significant. Such a system will also reduce the potential of inadvertently overlooking EPCRA
Section 313 chemicals or chemical categories present in mixtures purchased from off-site
sources.
To develop the chemical or chemical category list and the associated activity
categories you may want to consult the following:
Material Safety Data Sheets (MSDSs);
Facility purchasing records;
New Source Performance Standards;
Inventory records;
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Air and water discharge permits;
Individual manufacturing/operating functions; and
Receipts or manifests associated with the transfer of each EPCRA Section
313 chemical or chemical category in waste to off-site locations.
The following is suggested useful information needed to prepare your EPCRA
Section 313 reports and should be included for each chemical or chemical category on your
spreadsheet:
• The mixture name and associated EPCRA Section 313 chemical or
chemical category names;
• The associated Chemical Abstract Service (CAS) Registry numbers;
• The trade name for mixtures and compounds;
• The throughput quantities; and
• Whether the chemical or chemical category is manufactured, processed, or
otherwise used at the facility (be sure to include quantities that are
coincidentally manufactured and imported, as appropriate).
MSDSs provide important information for the type and composition of chemicals
and chemical categories in mixtures, and for determining whether you have purchased raw
materials that contain EPCRA Section 313 chemicals and chemical categories. As of 1989,
chemical suppliers to facilities in SIC Major Group Codes 20 through 39 are required to notify
manufacturing customers of any EPCRA Section 313 chemicals and chemical categories present
in mixtures or trade name products distributed to facilities. The notice must be provided to the
receiving facility and may be attached or incorporated into that product's MSDS. If no MSDS is
required, the notification must be in a letter that accompanies the first shipment of the product to
your facility each year. This letter must contain the chemical name, CAS Registry number, and
the weight or volume percent (or a range) of the EPCRA Section 313 chemical or chemical
category in mixtures or trade name products.
Carefully review the entire MSDS. Although new MSDSs must list whether
EPCRA Section 313 chemicals or chemical categories are present, the language and location of
this notification is not currently standardized. Depending on the supplier, this information could
be found in different sections of the MSDS. The most likely sections of an MSDS to provide
information on EPCRA Section 313 chemicals or chemical categories are:
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Physical properties/chemical composition section;
Regulatory section;
Hazardous components section;
Labeling section; and
Additional information section.
Also, many EPCRA Section 313 chemicals or chemical categories are present as
impurities in mixtures. These quantities must also be considered in threshold determinations
unless the concentration is below the de minimis value (see Section 3.2.2.1).
COMMON ERROR - Mixture Components
Facilities often overlook EPCRA Section 313 chemicals that are present in small quantities of bulk solutions. For
example, a common chemical used in printing operations is xylene. Xylene is often purchased in large quantities
for use as a solvent, among other things. Most facilities correctly report for xylene; however, ethylbenzene is
typically present at up to 15% in solutions of xylene commercially available. Many facilities have historically
overlooked the ethylbenzene in their bulk xylene purchases.
Qualifiers
Several chemicals on the EPCRA Section 313 chemical and chemical category list
include qualifiers related to use or form. Some chemicals are reportable ONLY if manufactured
by a specified process or classified in a specified activity category. For example, isopropyl
alcohol is only reportable if it is manufactured using the strong acid process and saccharin is
reportable only if it is manufactured. Some other chemicals are only reportable if present in
certain forms. For example, only yellow or white phosphorus is reportable, while black or red
phosphorus is not reportable.
The qualifiers and associated chemicals and chemical categories are presented
below. Please make special note of the discussion pertaining to vanadium and vanadium
compounds.
Aluminum oxide (fibrous) - Aluminum oxide is only subject to threshold
determination and release and other waste management calculations when
it is handled in fibrous forms. U.S. EPA has characterized fibrous
aluminum oxide for purposes of EPCRA Section 313 reporting as a man-
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made fiber commonly used in high-temperature insulation applications
such as furnace linings, filtration, gaskets, joints, and seals.
Ammonia - (includes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources) On June 26, 1995,
U.S. EPA qualified the listing for ammonia (CAS Registry No. 7664-41-7)
and deleted ammonium sulfate (solution) (CAS Registry No. 7783-20-2)
from the EPCRA Section 313 chemical list. Both the qualification and the
deletion were effective as of reporting year 1994. The qualifier for
ammonia means that anhydrous forms of ammonia are 100% reportable
while only 10% of the total aqueous ammonia is reportable. Any
evaporation of ammonia from aqueous ammonia solutions is considered
anhydrous ammonia. This qualifier applies to both activity threshold
determinations and release and other waste management calculations.
Note that while ammonium sulfate is no longer an EPCRA Section 313
chemical, 10% of the aqueous ammonia formed from the dissociation of
ammonium sulfate (and all other ammonium salts) is reportable, and must
be included in both activity threshold determinations and release and other
waste management calculations. Additionally, any ammonium nitrate
must also be included in the threshold determination and the nitrate
portion included in the release and other waste management calculations,
for the nitrate compounds category. U.S. EPA has published guidance on
reporting for ammonia and ammonium salts in Emergency Planning and
Community Right-to-Know, EPCRA Section 313, Guidance for Reporting
Aqueous Ammonia, EPA 745-R-95-012 (see Appendix C).
Asbestos (friable) - Asbestos only needs to be considered when it is
handled in the friable form. Friable refers to the physical characteristics of
being able to crumble, pulverize, or reduce to a powder with hand
pressure.
Fume or dust - Two metals (aluminum and zinc) are qualified with "fume
or dust." This definition excludes "wet" forms such as solutions or
slurries, but includes powder, particulate, or gaseous forms of these
metals. There is no particle size limitation for particulates. For example,
use of zinc metal as a paint component is not subject to reporting unless
the zinc is in the form of a fume or dust. However, even though elemental
zinc is reportable only in the fume or dust form, all forms of zinc
compounds are reportable. Note that the entire weight of all zinc
compounds should be included in the threshold determination for zinc
compounds, while only the metal portion of metal compounds is reported
in the release and other waste management amounts. Prior to reporting
year 2000, vanadium was also qualified with "fume or dust." As of
reporting year 2000 this qualifier has been removed for vanadium such
that all physical forms are now reportable unless the vanadium is
contained in an alloy. Please see the discussion on vanadium and
vanadium compounds below, if applicable.
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Hydrochloric acid (acid aerosols) - On July 25, 1996, US EPA
promulgated a final rule delisting non-aerosol forms of hydrochloric acid
(CAS Registry No. 7647-01-0) from the EPCRA Section 313 chemical list
(effective for the 1995 reporting year). Therefore, threshold
determinations and release and other waste management estimates now
apply only to the aerosol forms. Under EPCRA Section 313, the term
aerosol covers any generation of airborne acid (including mists, vapors,
gas, or fog) without any particle size limitation. Therefore, any process
that intentionally sprays hydrochloric acid on an item for cleaning, etching,
or other purposes constitutes manufacture and otherwise use of the
hydrochloric acid aerosol. If the hydrochloric acid aerosol are used in a
process in which any part of the hydrochloric acid becomes incorporated
into a product which is then distributed in commerce, the aerosol is
considered to be processed. U.S. EPA has published guidance for
hydrochloric acid aerosols in Guidance for Reporting Hydrochloric Acid
(acid aerosols including mists, vapors, gas, fog, and other airborne forms
of any particle size). EPA 745-B-99-014. December, 1999.
Manufacturing qualifiers - Two chemicals, saccharin and isopropyl
alcohol, contain qualifiers relating to manufacture. The qualifier for
saccharin means that only manufacturers of the chemical are subject to the
reporting requirement. The qualifier for isopropyl alcohol means that only
facilities that manufacture the chemical by the strong acid process are
required to report. Facilities that only process or otherwise use these
chemicals are not required to report. Thus, a facility that uses isopropyl
alcohol as an ink solvent or in cleanup operations should not report for
isopropyl alcohol.
Nitrate Compounds (water dissociable; reportable only in aqueous
solution) - A nitrate compound is covered by this listing only when in
water and if water dissociable. Although the complete weight of the
nitrate compound must be used for threshold determinations for the nitrate
compounds category, only the nitrate portion of the compound must be
considered for release and other waste management calculations. One
issue recently raised by industry is how to report nitrate compounds in
wastewater and sludge that is applied to farms as a nitrogen source (either
on site or off site). Although during such use nitrate compounds may be
taken up by plants and cycled back into the ecosystem, U.S. EPA
considers that the nitrate compounds in wastewater/sludge to be managed
as waste. In this scenario, nitrate compounds should be reported as being
disposed to land (either on site or off site as appropriate). U.S. EPA has
published guidance for these chemicals in List of Toxic Chemicals Within
the Water Dissociable Nitrate Compounds Category and Guidance for
Reporting, EPA 745-R-96-004.
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Phosphorus (yellow or white) - Only manufacturing, processing, or
otherwise use of phosphorus in the yellow or white chemical forms require
reporting. Black and red phosphorus are not subject to EPCRA
Section 313 reporting.
Sulfuric acid (acid aerosols) - On June 26, 1995, U.S. EPA promulgated
a final rule delisting non-aerosol forms of sulfuric acid (CAS Registry No.
7664-93-9) from the EPCRA Section 313 toxic chemical list (effective for
the 1994 reporting year). Therefore, threshold determinations and release
and other waste management estimates now apply only to the aerosol
forms. Under EPCRA Section 313, the term aerosol covers any generation
of airborne acid (including mists, vapors, gas, or fog) without any particle
size limitation. Therefore, any process that intentionally sprays sulfuric
acid on an item for cleaning, etching, or other purposes constitutes
manufacture and otherwise use of the sulfuric acid aerosol. If the sulfuric
acid aerosol is used in a process in which any part of the sulfuric acid
becomes incorporated into a product which is then distributed in
commerce, the aerosol is considered to be processed. U.S. EPA has
published guidance for sulfuric acid aerosols in Guidance for Reporting
Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size). EPA 745-R-97-007. March 3, 1998.
Vanadium and vanadium compounds - Note that prior to reporting year
2000 (effective December 31, 1999 for EPCRA Section 313 reports that
must be filed by July 1, 2001), the fume or dust qualifier also applied to
vanadium. As of December 31, 1999, U.S. EPA removed this qualifier for
vanadium for reporting year 2000 and beyond. Concurrently, U.S. EPA
exempted all physical forms of metallic vanadium that are present in
alloys. Therefore, vanadium that is present in any physical form of alloys
should not be considered for EPCRA Section 313 reporting. However, if
vanadium is separated from the alloy, all physical forms of the vanadium
are considered to be manufactured and the quantity manufactured should
be applied to the 25,000-pound manufacturing threshold. If the vanadium
is subsequently processed or otherwise used, the applicable quantity
should also be applied to the processing or otherwise use threshold(s). If a
threshold is exceeded, all quantities released or otherwise managed as
waste must be reported as appropriate.
Concurrent with this rulemaking, U.S. EPA also added vanadium
compounds to the list of toxic chemicals subject to reporting under
EPCRA Section 313. U.S. EPA specifically excluded vanadium
compounds from the fume or dust qualifier and from the alloy exemption.
Therefore, all physical forms of vanadium compounds must be included in
threshold determinations and release and other waste management
activities estimates.
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In addition to these qualifiers, EPCRA Section 313 chemicals in two compound
categories often cause confusion for facilities performing printing operations. These are
discussed below:
• Copper Compounds - The copper compounds category no longer
includes copper phthalocyanine compounds substituted with only
hydrogen and/or chlorine and/or bromine. This change was effective for
the reporting year 1994 and beyond. Copper compounds may be found in
some blue and green ink pigments - Pigment Blue 15, Pigment Green 7,
and Pigment Green 36. For more information regarding this issue, refer to
the EPA document Toxics Release Inventory - Copper Phthalocyanine
Compounds Excluded for the Reporting Requirements Under the Copper
Compounds Category on the EPCRA Section 313 List (EPA-745-R-95-
007).
• Certain Glycol Ethers - The certain glycol ethers category includes glycol
ethers derived from ethylene glycol, diethylene glycol, and triethylene
glycol. It does not include glycol ethers derived from propylene glycol,
dipropylene glycol, or tripropylene glycol. Refer to the EPA document
Toxics Release Inventory - List of Toxic Chemicals Within the Glycol
Ethers Category (EPA 745-R-95-006) for a complete discussion,
definition, and examples of chemicals that should be included in the
certain glycol ethers category. For printing operations, the following
chemicals are commonly used and are included in the certain glycol ethers
category:
Ethyl ene glycol monobutyl ether (CAS Registry No. 111-76-2)
- also known as butyl cellosolve or 2-butoxyethanol
Ethyl ene glycol dimethyl ether (CAS Registry No. 110-71 -4)
- also known as 1,2-dimenthoxyethane
Diethylene glycol mono-n-butyl ether (CAS Registry No.
112-34-5)
- also known as butyl carbitol
Diethylene glycol monomethyl ether (CAS Registry No. 111-77-3)
- also known as 2-methoxyethoxy ethanol
Diethylene glycol monoethyl ether (CAS Registry No. 110-90-0)
- also known as 2-ethoxyethoxy ethanol
Diethylene glycol dimethyl ether (CAS Registry No. 111-96-6)
- also known as 2-methoxyethyl ether
Diethylene glycol diethyl ether (CAS Registry No. 112-36-7)
- also known as 2-ethyoxyethyl ether
There are two glycol ethers, 2-methoxyethanol (CAS No. 109-86-4) and 2-
ethoxyethanol (CAS No. 110-80-5) that are commonly used in printing
operations and that are on the EPCRA Section 313 individual chemical
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list. Threshold determinations should be made for each of these chemicals
individually and separately from the certain glycol ethers category.
The following chemicals are also commonly used in the printing,
publishing, and packaging industry but are not included in the certain
glycol ethers category:
Diethylene glycol (CAS Registry No. 111-46-6)
Propylene glycol methyl ether (CAS Registry No. 108-65-6)
Dipropylene glycol monomethyl ether (CAS Registry No.
3459-09-48)
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for Each
EPCRA Section 313 Chemical and Chemical Category
The next step is to identify the activity category (or categories) and any exempt
activities for each EPCRA Section 313 chemical and chemical category on your list. Table 3-1
lists the reporting thresholds for each of these activity categories (Tables 3-2 through 3-4 provide
detailed definitions of subcategories for each activity category). Each threshold must be
individually calculated; they are mutually exclusive and are not additive.
Table 3-1
Reporting Thresholds
Activity Category
Manufacture (including import)
Process
Otherwise use
Threshold1
25,000 pounds per year
25,000 pounds per year
10,000 pounds per year
'These reporting thresholds are for non-PBT chemicals. See Section 2.6 for the reporting thresholds
applicable to PBT chemicals.
Example -Threshold Determination
If your facility manufactures 22,000 pounds of an EPCRA Section 313 chemical or chemical category and you
also otherwise use 8,000 pounds of the same chemical or chemical category, you have not exceeded either
threshold, and an EPCRA Section 313 report for that chemical or chemical category is not required. However, if
your facility manufactures 28,000 pounds per year of an EPCPvA Section 313 chemical or chemical category and
otherwise uses 8,000 pounds of the same chemical or chemical category, you have exceeded the manufacturing
threshold and ALL release and other waste management quantities (except those specifically exempted) of that
chemical or chemical category must be reported on the Form R, including those from the otherwise use activity.
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Example - Xylene Isomers
Printing operations use the EPCRA Section 313 chemical xylene with the mixed isomers, CAS Registry No.
1330-20-7, being the most frequently reported type. Ortho-, meta-, and para-xylenes are listed on the EPCRA
Section 313 chemicals and chemical categories list in addition to xylene (mixed isomers). The mixed isomers
classification should be used when a mixture contains any combination of two or three of the isomers. The
threshold determination for xylene should be calculated for each isomeric form individually unless the xylenes are
manufactured, processed, or otherwise used as a mixture of xylene isomers. For example, a covered facility
annually uses 8,000 pounds of para-xylene, 6,000 pounds of ortho-xylene, and 8,000 pounds of mixed isomers as
carrier solvents in three separate processing lines. All three activities of xylene are classified as otherwise use as
the carrier is intended to evaporate and not remain with the product. There are no other uses of any form of
xylene in the facility. The otherwise use activity threshold of 10,000 pounds/year has not been reached for any of
the xylenes and an EPCRA Section 313 report need not be prepared for xylene. However, should any two of the
streams mix, the facility will exceed the otherwise use threshold for mixed isomers and an EPCRA Section 313
report must be prepared for the mixed isomer form of xylene.
COMMON ERROR - Threshold Determination for Recirculation
Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals or
chemical categories in a recirculation system rather than the amount actually used in the reporting year. The
amount of the EPCRA Section 313 chemical or chemical category that is actually manufactured (including the
quantity imported), processed, or otherwise used, not the amount in storage or in the system, should be the amount
applied to the threshold determination. For example, a solvent containing an EPCRA Section 313 chemical or
chemical category is used, recirculated on site, and reused as a solvent. The amount of EPCRA Section 313
chemical or chemical category recirculated in the on-site recycling process is not considered in the threshold
determination because it is considered a "direct reuse" and is not reportable. Only the amount of new chemical
added to the system should be included in the otherwise used threshold calculation. However, if you send a
solvent containing an EPCRA Section 313 chemical or chemical category off site for distillation and subsequent
recycling, it should be reported as a transfer to an off-site location for recycling (Part II, Sections 6.2 and 8.5 of
the 1999 Form R) because the distillation is considered a waste management activity. The amount of solvent
returned to you and subsequently used in the same reporting year must be included in the threshold determination.
If the reporting threshold is exceeded, the total quantity recycled should be reported in Section 8.4, i.e., the
amount recycled on site must be reported in Section 8.4 each time it is recycled.
Each of the activity categories is divided into subcategories. As discussed in the
TRI Forms and Instructions, you are required to designate EACH category and subcategory that
applies to your facility. Detailed definitions, including descriptions of subcategories for each
activity and selected examples, are presented in Tables 3-2, 3-3, and 3-4.
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Table 3-2
Definitions and Examples of Manufacturing Subcategories
Manufacturing
Activity Subcategory
Definition
Examples in Printing Operations*
Produced or imported
for on-site
use/processing
A chemical that is produced or imported
and then further processed or otherwise
used at the same facility.
Facilities conducting silk screening or
printing on T-shirts may import specialty
chemicals (dyes) from other countries,
which may contain EPCRA Section 313
chemicals and chemical categories.
Produced or imported
for sale/distribution
A chemical that is produced or imported
specifically for sale or distribution
outside the manufacturing facility.
Produced as a
byproduct
A chemical that is produced
coincidentally during the production,
processing, or otherwise use of another
chemical substance or a mixture and is
separated from that substance or mixture.
EPCRA Section 313 chemicals or
chemical categories produced and
released as a result of waste treatment or
disposal are also considered byproducts.
Produced as an
impurity
A chemical that is produced
coincidentally as a result of the
manufacture, processing, or otherwise use
of another chemical and remains
primarily in the mixture or product with
that other chemical.
: Printing operations do not typically manufacture EPCRA Section 313 chemicals or chemical categories.
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Table 3-3
Definitions and Examples of Processing Subcategories
Processing Activity
Subcategory
Definition
Examples in Printings
Operations*
Reactant
A natural or synthetic chemical used in chemical
or chemical category reactions for the
manufacture of another chemical substance or
product. Examples include feedstocks, raw
materials, intermediates, and initiators.
Formulation component
A chemical that is added to a product or product
mixture prior to further distribution of the
product and acts as a performance enhancer
during use of the product. Examples include
additives, dyes, reaction diluents, initiators,
solvents, inhibitors, emulsifiers, surfactants,
lubricants, flame retardants, and rheological
modifiers.
Article component
A chemical that becomes an integral component
of an article distributed for industrial, trade, or
consumer use.
Zinc compounds, barium
compounds, chromium compounds
Repackaging only
A chemical that is processed or prepared for
distribution in commerce in a different form,
state, or quantity. May include, but is not limited
to, the transfer of material from a bulk container,
such as a tank truck, to smaller containers such
as cans or bottles.
Zinc compounds, barium
compounds, chromium compounds
* More complete discussions of the industry-specific examples can be found in Section 4 of this guidance manual.
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Table 3-4
Definitions and Examples of Otherwise Use Subcategories
Otherwise Use Activity
Subcategory
Definition
Examples in Printings
Operations*
Chemical processing aid
A chemical or chemical category that is
added to a reaction mixture to aid in the
manufacture or synthesis of another
chemical or chemical category substance
but is not intended to remain in or become
part of the product or product mixture.
Examples include process solvents,
catalysts, inhibitors, initiators, reaction
terminators, and solution buffers.
Xylene, methyl ethyl ketone, zinc
compounds, glycol ethers, toluene,
methyl isobutyl ketone
Manufacturing aid
A chemical or chemical category that aids
the manufacturing process but does not
become part of the resulting product and is
not added to the reaction mixture during the
manufacture or synthesis of another
chemical substance. Examples include
process lubricants, metalworking fluids,
coolants, refrigerants, and hydraulic fluids.
Freon, hydraulic fluids
Ancillary or other use
A chemical or chemical category that is
used for purposes other than aiding
chemical processing or manufacturing.
Examples include cleaners, degreasers,
lubricants, fuels (including waste fuels), and
chemicals used for treating wastes.
Toluene, methyl ethyl ketone,
ethylbenzene
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Example - Chemical Processing Aid
A printing operation uses toluene as a carrier solvent. Ideally all the solvent would evaporate, however, studies
have shown 1% of the applied solvent remains on the printed material. Since the function of the solvent is to
improve the application of the ink and is a non-incorporative activity, the entire amount of toluene is considered
otherwise used. If the solvent's function was such that it was intended to remain with the printed material, it
would be considered processed, as is the case for pigments, binders, and other ink components intended to remain
with the printed material.
3.2.1
Concentration Ranges for Threshold Determination
You should use the best readily available information or where such data are not
available, reasonable estimates for all calculations in EPCRA Section 313 reporting; however,
the exact concentration of an EPCRA Section 313 chemical or chemical category in a mixture or
> 1O
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trade name product may not be known. The supplier or MSDS may only list ranges, or upper or
lower bound concentrations. U.S. EPA has developed guidance on how to use information in
this situation for threshold determinations.
• If the concentration is provided as a lower and upper bound or as a range,
you should use the mid-point in your calculations for the threshold
determination. For example, the MSDS for the trade name product states
methanol is present in a concentration of not less than 20% and not more
than 40%, or it may be stated as present at a concentration between 20 to
40 percent. You should use the mid-point value of 30% methanol in your
threshold calculations.
• If only the lower bound concentration of the EPCRA Section 313 chemical
or chemical category is specified and the concentration of other
components are given, subtract the other component values from 100
percent. The remainder should be considered the upper bound for the
EPCRA Section 313 chemical or chemical category and you should use
the given lower bound to calculate the mid-point as discussed above. For
example, the MSDS states that a solvent contains at least 50% methyl
ethyl ketone (MEK) and 20% non-hazardous surfactants. Subtracting the
non-hazardous contents from 100% leaves 80% as the upper bound for
MEK. The mid-point between upper (80%) and lower (50%) bounds is
65%, the value you should use in your threshold calculation.
• If only the lower bound is specified and no information on other
components is given you should assume the upper bound is 100% and
calculate the mid-point as above.
• If only the upper bound concentration is provided, you should use this
value in your threshold calculation.
Special guidance for concentration ranges that straddle the de minimis value is presented in
Section 3.2.2.1.
3.2.2 Evaluation of Exemptions
When determining thresholds, you can exclude quantities of any EPCRA Section
313 chemicals and chemical categories that are manufactured, processed, or otherwise used in
exempt activities. Exemptions are divided into four classes:
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1. De minimis exemption;
2. Article exemption;
3. Facility-related exemption; and
4. Activity-related exemptions.
COMMON ERROR - Exempt Activities
If an EPCRA Section 313 chemical or chemical category is used in exempt activities, the quantity used in these
activities does not need to be included in your threshold determinations or release and other waste management
calculations, even if the chemical is used in a reportable activity elsewhere in the facility.
3.2.2.1 De Minimis Exemption
If the amount of EPCRA Section 313 chemical(s) or chemical categories present
in a mixture or trade name product processed or otherwise used is below its de minimis
concentration level, that amount is considered to be exempt from threshold determinations and
release and other waste management calculations. Note that this exemption does not apply to
manufacturing, except for importation or as an impurity as discussed below. Also note that the
de minimis exemption does not apply to the manufacturing, processing, or otherwise use of the
PBT chemicals (refer to Section2.6). The de minimis concentration for EPCRA Section 313
chemicals and chemical categories is 1%, except for Occupational Safety and Health
Administration (OSHA)-defmed carcinogens, which have a 0.1% de minimis concentration.
Note that if a mixture contains more than one member of an EPCRA Section 313 chemical
category, the weight percent of all members must be summed. If the total meets or exceeds the
category's de minimis level, the de minimis exemption does not apply. U.S. EPA has published
several detailed questions and answers and a directive in the current edition of EPCRA Section
313 Questions and Answers (1998 edition is EPA 745-B-98-004; see Appendix A, Directive #2)
that may be helpful if you have additional concerns about the de minimis exemption. The TRI
Forms and Instructions list each EPCRA Section 313 chemical and chemical category with the
associated de minimis value.
Once the de minimis level has been equaled or exceeded, the exemption no longer
applies to that process stream, even if the EPCRA Section 313 chemical or chemical category
later falls below the de minimis concentration. All release and other waste management activities
that occur after the de minimis concentration has been equaled or exceeded are subject to
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reporting. The facility does not have to report release and other waste management activities that
took place before the de minimis concentration was equaled or exceeded.
Example - De Minimis
Your facility processes a mixture containing 1.1% nitric acid and 0.6% manganese. The de minimis exemption
would apply to manganese because the concentration is below 1% which is the de minimis level for manganese;
however, it would not apply to nitric acid. All of the nitric acid must be included in threshold determinations, and
release and other waste management calculations.
The de minimis exemption also applies to EPCRA Section 313 chemicals and
chemical categories that are coincidentally manufactured below the de minimis level only if that
chemical is manufactured as an impurity in a mixture and subsequently distributed in commerce.
In addition, the exemption applies to EPCRA Section 313 chemicals and chemical categories
below the de minimis concentration in an imported mixture or trade name product.
For some mixtures the concentration of EPCRA Section 313 chemicals and
chemical categories may be available only as a range. U.S. EPA has developed guidance on how
to determine quantities applicable to threshold determinations, and release and other waste
management calculations when this range straddles the de minimis value. In general, only the
quantity of the processed or otherwise used EPCRA Section 313 chemical or chemical categories
whose concentration exceeds the de minimis must be considered. Therefore, U.S. EPA allows
facilities to estimate the quantity below the de minimis and exclude it from further consideration.
The following examples illustrate this point.
Examples - De Minimis Concentration Ranges
Example 1:
A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is subject
to a 1% de minimis concentration exemption. The amount of mixture subject to reporting is the quantity
containing manganese above the de minimis concentration:
(8,000,000) x (0.0125 - 0.0099) - (0.0125 - 0.0025)
(Continued on next page)
5-16
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(Continued from previous page)
The average concentration of manganese that is not exempt (above the de minimis) is:
(0.0125+ 0.01)-(2)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste
management estimates is:
(8,000,000) x (0.0125-0.0099
(0.0125-0.0025)
(0.0125+0.01)
(2)
= 23,400 pounds
= 23,400 pounds manganese (which is below the processing threshold)
In this example, because your facility's information pertaining to manganese was available to two decimal places,
0.99 was used to determine the amount below the de minimis concentrations. If the information was available to
one decimal place, 0.9 should be used, as in Example 2 below.
Example 2:
As in Example 1, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS states
the mixture contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above de minimis) is:
(8,000,000) x (0.012 - 0.009) + (0.012 - 0.002)
The average concentration of manganese that is not exempt (above de minimis) is:
(0.012+ 0.01)+ (2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste
management estimates is:
(8,000,000) x (0.012-0.009)
(0.012-0.002)
(0.012+0.01)
(2)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold)
The exemption does not apply to EPCRA Section 313 chemicals or chemical
categories coincidentally manufactured as byproducts and separated from the product, nor does it
apply to EPCRA Section 313 chemicals and chemical categories coincidentally manufactured as
a result of waste management activities, from either on site or off site. (Under EPCRA Section
313, U.S. EPA does not consider waste to be a mixture.) For example, many facilities treat waste
solvents by incinerating them. If coal is used as the primary fuel source to incinerate these waste
solvents, combustion can result in the coincidental manufacture of sulfuric and hydrochloric acid
aerosols and metal compounds. Since the de minimis exemption does not apply to the
5-17
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coincidental manufacture of EPCRA Section 313 chemicals or chemical categories as a
byproduct or in a waste treatment process, the formation of these compounds must be considered
for threshold determinations, and release and other waste management calculations.
3.2.2.2 Articles Exemption
An article is defined as a manufactured item that:
• Is formed to a specific shape or design during manufacture;
• Has end-use functions dependent in whole or in part upon its shape or
design; and
• Does not release an EPCRA Section 313 chemical or chemical category
under normal conditions of processing or otherwise use of the item at the
facility.
If you receive a manufactured article from another facility or you produce the
article in your facility and process or otherwise use it without changing the shape or design, and
your processing or otherwise use does not result in the release into the environment of more than
0.5 pound of the EPCRA Section 313 chemical or chemical category in a reporting year for all
like articles, then the EPCRA Section 313 chemical or chemical category in that article is exempt
from threshold determinations and release and other waste management calculations (U.S. EPA
allows a release of 0.5 pound or less to be rounded to zero; the 0.5-pound limit does not apply to
each individual article, but applies to the sum of all releases from processing or use of all like
articles). Section 313 chemicals or chemical categories used to produce an article, however, do
not qualify for the article exemption.
The shape and design can be changed somewhat during processing and otherwise
use as long as part of the item retains the original dimensions. That is, as a result of processing
or otherwise use, if an item retains its initial thickness or diameter, in whole or in part, then it
still meets the article definition. If the item's original dimensional characteristics are totally
altered during processing or otherwise use, the item would not meet the definition. As an
example, items that do not meet the definition would be items that are cold extruded, such as lead
ingots formed into wire or rods. However, cutting a manufactured item into pieces that are
recognizable as the article would not change the exemption status as long as the diameter and the
3-18
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thickness of the item remain unchanged. For instance, metal wire may be bent and sheet metal
may be cut, punched, stamped, or pressed without losing the article status as long as no change is
made in the diameter of the wire or tubing or the thickness of the sheet and no releases above 0.5
pound per year occur for all like articles.
Any processing or otherwise use of an article that results in a release above 0.5
pound per year for each EPCRA Section 313 chemical or chemical category for all like articles
negates the exemption. Cutting, grinding, melting, or other processing of a manufactured item
could result in a release of an EPCRA Section 313 chemical or chemical category during normal
conditions of use and, therefore, could negate the article exemption if the total annual releases
from all like articles exceed 0.5 pound in a year. However, if all of the resulting waste is
recycled or reused, either on site or off site, so that the release of the EPCRA Section 313
chemical or chemical category does not exceed 0.5 pound for the calendar year, then the article's
exemption status is maintained. If the processing or otherwise use of similar manufactured items
results in atotal release of less than or equal to 0.5 pound of any individual EPCRA Section 313
chemical or chemical category to any environmental media in a calendar year, U.S. EPA will
allow this quantity to be rounded to zero and the manufactured items maintain their article status.
The 0.5-pound limit does not apply to each individual article, but applies to the sum of all
releases from processing or otherwise use of like articles for each EPCRA Section 313 chemical
or chemical category. The current edition of EPCRA Section 313 Questions and Answers (1998
edition is EPA 745-B-98-004) presents several specific question and answers/discussions
pertaining to the articles exemption.
3.2.2.3 Facility-Related Exemption
Laboratory Activity Exemption
EPCRA Section 313 chemicals and chemical categories that are manufactured,
processed, or otherwise used in laboratories under the supervision of a technically qualified
individual are exempted from the threshold determination (and subsequent release and other
waste management calculations). This exemption may be applicable in circumstances such as
laboratory sampling and analysis, research and development, and quality assurance and quality
3-19
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control activities. It does not include pilot plant scale or specialty chemical production. It also
does not include laboratory support activities. For example, chemicals used to maintain
laboratory equipment are not eligible for the laboratory exemption.
Example - Laboratory Activity Exemption
A printing facility at a separate research laboratory facility applies various formulations of inks containing
EPCRA Section 313 chemicals and chemical categories to various products. The testing is under the supervision
of a "technically qualified individual" in the laboratory. The EPCRA Section 313 chemicals and chemical
categories used in this activity would be exempt from EPCRA Section 313 reporting and should not be included
in any threshold determinations or release and other waste management calculations.
3.2.2.4 Activity-Related Exemptions (Otherwise Use Exemptions)
Some exemptions apply to the otherwise use of an EPCRA Section 313 chemical
and chemical category. The specific quantities of EPCRA Section 313 chemicals or chemical
categories used in these activities do not need to be included in facility threshold determinations
(nor the associated release and other waste management calculations). The following otherwise
use activities are considered exempt:
EPCRA Section 313 chemicals and chemical categories used in routine
janitorial or facility grounds maintenance. Examples are bathroom
cleaners, fertilizers, and garden pesticides similar in type or concentration
to consumer products. Materials used to clean process equipment do not
meet this exemption.
Personal use of items. Examples are foods, drugs, cosmetics, and other
personal items including those items within a facility-operated cafeteria,
store, or infirmary. Office supplies such as correction fluid are also
exempt.
Structural components of the facility Exemptions apply to EPCRA
Section 313 chemicals and chemical categories present in materials used to
construct, repair, or maintain structural components of a facility. An
example common to all facilities would be the solvents and pigments used
to paint buildings. Materials used to construct, repair, or maintain process
equipment are not exempt.
5-20
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EPCRA Section 313 chemicals and chemical categories used with
facility motor vehicles. This exemption includes the use of EPCRA
Section 313 chemicals and chemical categories for the purpose of
maintaining motor vehicles operated by the facility. Common examples
include gasoline, radiator coolant, windshield wiper fluid, brake and
transmission fluid, oils and lubricants, cleaning solutions, and solvents in
paint used to touch up the vehicle. Motor vehicles include, but may not be
limited to, cars, trucks, forklifts, locomotives, and aircraft. Note that this
exemption applies to the OTHERWISE USE of the EPCRA Section 313
chemicals and chemical categories. The coincidental manufacture of
EPCRA Section 313 chemicals and chemical categories resulting from
combustion of gasoline is not exempt and should be considered toward the
manufacturing threshold.
Example - Motor Vehicle Exemption
Methanol is purchased for use as a processing aid and as a windshield washer anti-
freeze in company vehicles. Only the amount used as a processing aid would be used in
facility threshold calculations. Even if the facility still exceeds the otherwise use
threshold, the amount in the anti-freeze is exempt from release and other waste
management calculations.
This exemption does NOT apply to stationary equipment. The use of
lubricants and fuels for stationary process equipment (e.g., pumps and
compressors) and stationary energy sources (e.g., furnaces, boilers,
heaters), are NOT exempt.
Example - Process Equipment Chemical Use
Lubricants containing EPCRA Section 313 chemicals or chemical categories used on
facility vehicles, or on-site structural maintenance activities that are not integral to the
process, are exempt activities. However, lubricants used to maintain pumps and
compressors that aid facility process operations are not exempt and the amount of the
EPCRA Section 313 chemicals and chemical categories in the lubricant should be
applied to the otherwise use threshold.
EPCRA Section 313 chemicals and chemical categories in certain air
or water drawn from the environment or municipal sources. Included
are an exemption for EPCRA Section 313 chemicals and chemical
categories present in process water and non-contact cooling water drawn
from the environment or a municipal source, or chemicals and chemical
categories present in air used either as compressed air or as an oxygen
source for combustion.
5-21
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Example - Chemicals in Process Water
A facility uses river water for one of its processes. This water contains approximately
100 pounds of an EPCRA Section 313 chemical or chemical category. The facility
ultimately returns the water that contains the entire 100 pounds of the EPCRA Section
313 chemical or chemical category to the river. The EPCRA Section 313 chemical or
chemical category in the water can be considered exempt because the EPCRA Section
313 chemical was present as it was drawn from the environment. The facility does not
need to consider the EPCRA Section 313 chemical drawn with river water for threshold
determinations or release and other waste management calculations.
3.2.3 Additional Guidance on Threshold Calculations for Certain Activities
This section covers three specific situations in which the threshold determination
may vary from normal facility operations: reuse, remediation, and recycling activities of EPCRA
Section 313 chemicals or chemical categories.
3.2.3.1 Reuse Activities
Threshold determinations of EPCRA Section 313 chemicals or chemical
categories that are reused at the facility are based only on the amount of the EPCRA Section 313
chemical or chemical category that is added to the system during the year, not the total volume in
the system. For example, a facility operates a refrigeration unit that contains 15,000 pounds of
anhydrous ammonia at the beginning of the year. The system is charged with 2,000 pounds of
anhydrous ammonia during the year. The facility has therefore otherwise used only 2,000 pounds
of the EPCRA Section 313 chemical or chemical category and is not required to report (unless
the facility has additional otherwise use activities of ammonia that, when taken together, exceed
the reporting threshold). If, however, the whole refrigeration unit was recharged with 15,000
pounds of new or fresh anhydrous ammonia during the year, the facility would exceed the
otherwise use threshold, and be required to report.
5-22
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3.2.3.2 Remediation Activities
EPCRA Section 313 chemicals and chemical categories undergoing remediation
(e.g., Superfund remediation) are not being manufactured, processed, or otherwise used.
Therefore, they are not included in the activity threshold determinations.
However, if you are conducting remediation of an EPCRA Section 313 chemical
or chemical category that is also being manufactured, processed, or otherwise used by the facility
above an activity threshold level, you must consider this activity for release and other waste
management calculations. You must report any release or other waste management quantities of
an EPCRA Section 313 chemical or chemical category due to remediation in Part II, Sections 5
through 8, accordingly, of the 1999 Form R. Those quantities would also be considered as part
of the amount for determining Form A eligibility. EPCRA Section 313 chemicals or chemical
categories used for remediation should be considered toward threshold determinations. If an
EPCRA Section 313 chemical or chemical category exceeds one of the reporting thresholds
elsewhere at the facility, all release and other waste management activity quantities of that
chemical or chemical category must be reported, including release and other waste management
activity quantities resulting from remediation.
Excavation (that is considered part of the remedial action) of material already
landfilled does not constitute a manufacturing, processing, or other use activity. However,
routine activities (e.g., dredging a lagoon), even if not performed every year, are not considered
to be remedial actions and are always subject to reporting.
3.2.3.3 Recycling Activities
For on-site recycling and reuse systems, where the same EPCRA Section 313
chemical or chemical category is recycled and reused multiple times, the recycled quantity should
be counted only once (at the time it is introduced into the system) for threshold calculations.
(Please note that for reporting on-site waste management activities the quantity of the EPCRA
Section 313 chemical or chemical category should be counted every time it exits the recycling
unit in Section 8 of Form R.) EPCRA Section 313 chemicals or chemical categories recycled off
-------
site and returned to the facility should be treated as newly purchased materials for purposes of
EPCRA Section 313 threshold determinations.
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313 Chemical and
Chemical Category and Determine Which Ones Exceed an Activity
Threshold
The final step is to determine the quantity and which EPCRA Section 313
chemicals and chemical categories exceed an activity threshold. At this point you should have:
1. Identified each EPCRA Section 313 chemical and chemical category at
your facility.
2. Determined the activity category for each EPCRA Section 313 chemical
and chemical category (manufactured, processed, or otherwise used).
Now, you must sum the amount for each EPCRA Section 313 chemical and
chemical category by activity category, subtract all exempt quantities, and compare the totals to
the applicable thresholds. Each EPCRA Section 313 chemical and chemical category exceeding
any one of the activity thresholds requires the submission of an EPCRA Section 313 report.
Provided you meet certain criteria you may prepare a Form A rather than a Form R (see Section
2.8).
COMMON ERROR - Assuming a Threshold is Exceeded
U.S. EPA recently published a report, The 1994 and 1995 Toxic Release Inventory Data Quality Report, EPA
745-R-98-002, with the site survey results of over 100 facilities to evaluate EPCRA Section 313 reporting quality.
One of the findings of this survey was that facilities that simply assumed that chemical activity thresholds were
exceeded were often in error. This resulted in many of these facilities filing EPCRA Section 313 reports when
thresholds were actually not exceeded. Unless the facility has strong grounds to support such an assumption, the
time spent in explicitly calculating the activity threshold is well spent.
5-24
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COMMON ERROR - Zero Release and Other Waste Management Quantities
If you meet all reporting criteria and exceed any activity threshold for an EPCRA Section 313 chemical or
chemical category, you must file an EPCRA Section 313 report for that chemical or chemical category, even if
you have zero release and other waste management activity quantities. Exceeding the chemical activity threshold,
not the quantity released or otherwise managed as waste determines whether you must report. Note that if the
release and other waste management activity quantity is 500 pounds or less for each chemical or chemical
category you may be eligible to use the alternate certification statement, Form A, rather than a Form R (see
Section 2-9).
To determine if an EPCRA Section 313 chemical or chemical category exceeds a
reporting threshold, you must calculate the annual activity amount of that chemical or chemical
category. Start with the amount of chemical or chemical category at the facility as of January 1,
add any amounts brought on site during the year and the amount manufactured (including
imported), and subtract the amount left in the inventory on December 31. If necessary, adjust the
total to account for exempt activities (see Section 3.2.2 for a discussion of exemptions). You
should then compare the result to the appropriate threshold to determine if you are required to
submit an EPCRA Section 313 report for that chemical or chemical category. Keep in mind that
the threshold calculations are independent for each activity category: manufactured, processed,
and otherwise used. If more than one activity category applies, the amount associated with each
category is determined separately.
Table 3-5 presents a work sheet that may be helpful when conducting your
threshold determinations. Table 3-6 illustrates how the work sheet can be used for the following
example:
Example - Threshold Worksheet
Assume your facility purchases, in the applicable reporting year, two mixtures that contain xylene (mixed
isomers). You purchased 25,000 pounds of Mixture A (which is 50% xylene, by weight, according to the MSDS)
and 110,000 pounds of Mixture B (which contains 20% xylene, by weight). Further, you determine that you
process the entire quantity of Mixture A, while you process only half of Mixture B and otherwise use the other
half. You do not qualify for any exempt activities.
In this example, you would have processed a total of 23,500 pounds of xylene (12,500 pounds from activities
associated with Mixture A and 11,000 pounds from activities associated with Mixture B). You would also have
otherwise used a total of 11,000 pounds (all from Mixture B). Therefore, you would not have exceeded the
25,000-pound threshold for processing; however, you would have exceeded the 10,000-pound threshold for
otherwise use and would be required to submit an EPCRA Section 313 report that includes releases and other
waste management quantities from all activities (including processing).
5-25
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Table 3-5. EPCRA Section 313 Reporting Threshold Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source
Total Weight
(Ib)
Percent
EPCRA
Section 313
Chemical or
Chemical
Category
by Weight
EPCRA
Section 313
Chemical or
Chemical
Category
Weight (Ib)
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
(A) Ib.
Processed
(B) Ib.
Otherwise Used
(o ib.
OJ
to
Exempt quantity of chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility,
activity)
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(A,) Ib.
Processed
(B,) Ib.
Otherwise Used
(C,) Ib.
Ib.
Ib.
Amount subject to threshold: (A-Aj)_
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities1: 25.000 Ib. 25.000 Ib.
If any one of the thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
Ib.
10.000 Ib.
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT chemicals.
-------
Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category: Xvlene (mixed isomers)
CAS Registry Number: 1330-20-7
Reporting Year: 1999
Date Worksheet Prepared: May 1. 2000
Prepared By:
Amounts of chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Information
Source
MSDS
MSDS
Total Weight
(Ib)
25,000
110,000
Percent
EPCRA
Section 313
Chemical or
Chemical
Category
by Weight
50%
20%
EPCRA
Section 313
Chemical or
Chemical
Category
Weight (Ib)
12,500
22,000
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
—
—
(A) 0 Ib.
Processed
12,500
11,000
(B) 23,500 Ib.
Otherwise Used
—
11,000
(C) 11,000 Ib.
OJ
to
Exempt quantity of chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)
none
none
Fraction or Percent Exempt
(if Applicable)
Amount of the EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(AO 0 Ib.
Processed
(BO 0 Ib.
Otherwise Used
(C^Olb.
Amount subject to threshold: (A-Aj) 0 Ib. (B-Bj) 23,500 Ib. (C-Q) 11,000 Ib.
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities1: 25.000 Ib. 25.000 Ib. 10.000 Ib.
If any one of three thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT chemicals.
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CHAPTER 4 - ESTIMATING RELEASE AND
OTHER WASTE MANAGEMENT QUANTITIES
4.0 PURPOSE
This chapter is intended to guide the user in developing a systematic approach for
estimating release and other waste management quantities of EPCRA Section 313 chemicals or
chemical categories from printing operations. Figure 4-1 diagrams a recommended approach for
estimating quantities of reportable EPCRA Section 313 chemicals or chemical categories.
This chapter also includes common EPCRA Section 313 reporting and
compliance issues as they apply to the printing industry. The general discussion (Section 4.1) is
followed by a presentation of specific examples and issues (Section 4.2).
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities
Release and other waste management activity quantities can be determined by
completing the following four steps, described in detail in the following sections.
Step 1) Prepare a process flow diagram.
Step 2) Identify EPCRA Section 313 chemicals and chemical categories
and potential sources of chemical release and other waste
management activities.
Step 3) Identify release and other waste management activity types.
Step 4) Determine the most appropriate method(s) and calculate the
estimates for release and other waste management activity
quantities.
4-1
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STEP 1: Prepare Process
Flow Diagram
STEP 2: Identify EPCRA
Section 313 Chemicals
or Chemical Categories
STEP 2: Identify Sources of Release
and Other Waste
Management Activities
Source 1
Source 2
STEP 3: Define the
Operation
Source 3
STEP 3: Identify Release and Other
Waste Management Activity
Types
i
i i ri\
Fugitive
Air
Point
Air
Discharge
to
Waterbody
Underground
Injection
Land
On Site
POTW
Transfer
Off Site for
Recycling
Transfer
Off Site for
Energy Recovery
Transfer
Off Site for
Treatment
Transfer On-Site
Off Site for Waste
Disposal Treatment
On-Site On-Site
Energy Recycling
Recovery
1
1
STEP 4: Review Available
Data & Choose
Estimation Method
STEP 4: Calculate Estimates for
Release and Other Waste
Management Activity
Quantities
Figure 4-1. Release and Other Waste Management Activity Calculation Approach
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For EPCRA Section 313 purposes, "sources" are defined as the streams or units
that generate the release and other waste management activity (such as process vents, container
residue, or spills) and "types" are defined as the environmental media corresponding to elements
in Sections 5 through 8 of the 1999 Form R (for example, releases to fugitive air, releases to
stack air, discharges to receiving streams or POTWs, or releases to land).
4.1.1 Step 1: Prepare a Process Flow Diagram
Preparing a process flow diagram will help you to identify potential sources and
types of EPCRA Section 313 chemicals and chemical categories released and otherwise managed
as waste at your facility. Depending on the complexity of your facility, you may want to diagram
individual processes or operations rather than the entire facility. The diagram should show how
materials flow through the processes and identify material input, generation, and output points.
Looking at each operation separately, you can determine where EPCRA Section 313 chemicals
and chemical categories are used and the medium to which they may be released or otherwise
managed as waste.
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories
and Potential Sources of Chemical Release and Other Waste Management
Activities
Once a process flow diagram has been developed, you must determine the
potential sources and the EPCRA Section 313 chemicals and chemical categories that may be
released and otherwise managed as waste from each unit operation and process. Remember to
include upsets and routine maintenance activities. Potential sources include:
Accidental spills and • Fittings;
releases; • Flanges;
Air pollution control devices • Process discharge stream;
(e.g., baghouses, electrostatic • Process vents;
precipitators, and scrubbers) • Pumps;
Clean up and housekeeping • Recycling and energy
practices; recovery byproducts;
Combustion byproducts; • Relief valves;
Container residues; • Stock pile losses;
-------
Storage tanks; • Treatment sludge;
Storm water runoff; • Volatilization from process
Tower stacks; or treatment; and
Transfer operations; • Waste treatment discharges.
Next, you must identify the EPCRA Section 313 chemicals and chemical
categories that may be released or otherwise managed as waste from each source. A thorough
knowledge of the facility operations and processes is required for this determination. You should
also consider whether any of the EPCRA Section 313 chemicals and chemical categories are
coincidentally manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals
typically used in common printing operations. This table can be used as an aid in identifying
which chemicals and chemical categories are found in your process. The list may not include all
the EPCRA Section 313 chemicals and chemical categories your facility uses, and it may include
many chemicals and chemical categories that you do not use.
4.1.3 Step 3: Identify Release and Other Waste Management Activity Types
For each identified source of an EPCRA Section 313 chemical or chemical
category, you should examine all possible release and other waste management activity types.
Figure 4-2 schematically represents the possible release and other waste management activity
types as they correspond to individual data elements of the Form R. Remember to include both
routine operations and accidents when identifying types. This diagram along with the following
descriptions can be used as a checklist to make sure all possible types of release and other waste
management activities have been considered.
a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) -
Includes all emissions to the air that are not released through stacks, vents,
ducts, pipes, or any confined air stream. Examples include:
• Equipment leaks from valves, pump seals, flanges,
compressors, sampling connections, open-ended lines, etc.;
• Releases from building ventilation systems, such as a roof
fan in an open room;
• Evaporative losses from solvent cleaning tanks, surface
impoundments, and spills; and
• Emissions from any other fugitive or non-point source.
4-4
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Point Sources
(Part II, Sections
5.2 and 8.1)
Fugitive Emissions
(Part II, Sections
5.1 and 8.1)
Toxic Chemical In
Operation
T
Transfer Off Site for Recycling
(Part II, Sections 6.2 and 8.5)
Transfer Off Site for Energy Recovery
(Part II, Sections 6.2 and 8.3)
Transfer Off Site for Treatment
(Part II, Sections 6.2 and 8.7)
Transfer Off Site for Disposal
(Part II, Sections 6.2 and 8.1)
On-Site Treatment
(Part II, Sections 7A and 8.6)
On-Site Energy Recovery
(Part II, Sections 7B and 8.2)
On-Site Recycling
(Part II, Sections 1C and 8.4)
POTW
(Part II, Sections
6.1 and 8.1, or 8.7)
Underground Injection
(Part II, Sections
Receiving Streams 5.4 and 8.1)
(Part II, Sections Land on site (|andfill,
5.3 and 8.1) land treatment,
surface impoundment)
(Part II, Sections
5.5 and 8.1)
Figure 4-2. Possible Release and Other Waste Management Types1
for EPCRA Section 313 Chemicals and Chemical Categories
1 Sections refer to 1999 Form R. Quantities released to the environment as a result of remedial actions, catastrophic
events, or one-time events should be reported in Part II, Section 8 as Subsection 8.8.
b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) -
Includes all emissions to the air that occur through stacks, vents, ducts,
pipes, or any confined air stream, including the emissions from storage
tanks and air pollution control equipment. Air emissions from printing
operations are often channeled through vapor recovery systems and/or air
pollution control devices, and are considered stack emissions. Note that
emissions released from general room air through a ventilation system are
not considered stack or point releases for the purpose of EPCRA Section
313 reporting unless they are channeled through an air pollution control
device. Instead, they are considered fugitive releases. However, you
should note that for certain state reporting requirements not associated
with EPCRA Section 313 reporting, some state air quality agencies
consider ventilation systems to be a stack or point source.
4-5
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c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3
of Form R) - Includes direct wastewater discharges to a receiving stream
or surface water body. Discharges usually occur under a NPDES or
SPDES permit.
d. Underground Injection On-Site to Class I Wells (Part II, Section 5.4.1
of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of
Form R) - Includes releases into an underground well at the facility.
These wells may be monitored under an Underground Injection Control
(UIC) Program permit. RCRA Hazardous Waste Generator Reports may
be a good source of information for wastes injected into a Class I well.
Injection rate meters may provide information for all the well classes.
e. Disposal to Land On-Site (Part II, Section 5.5 of Form R) - Includes
all releases to land on site, both planned (i.e., disposal) and unplanned
(i.e., accidental release or spill). The four predefined subcategories for
reporting quantities released to land within the boundaries of the facility
are:
(1) Landfill - The landfill may be either a RCRA permitted (Part II,
Section 5.5.1 A) or a non-hazardous waste landfill (Part II, Section
5.5. IB). Both types are included if they are located on site. Leaks
from landfills in the years subsequent to the disposal of the
EPCRA Section 313 chemicals or chemical categories in the
landfill do not need to be reported as a release.
(2) Land treatment/application farming - Land treatment is a
disposal method in which a waste containing an EPCRA Section
313 chemical or chemical category is applied to or incorporated
into soil. Volatilization of an EPCRA Section 313 chemical or
chemical category because of the disposal operation must be
included in the total fugitive air releases and should be excluded
from land treatment/application farming to avoid double counting.
Sludge and/or aqueous solutions that contain biomass and other
organic materials are often collected and applied to farm land.
This procedure supplies a nitrogen source for plants and supplies
metabolites for microorganisms. U.S. EPA considers this
operation to be land treatment/farming if it occurs on site. If a
facility sends this material off site for the same purpose, it is
considered to be a "transfer to an off-site location, disposal" and
should be reported under Sections 6.2 and 8.1 of the Form R.
The ultimate disposition of the chemical or chemical category after
application to the land does not change the required reporting. For
example, even if the chemical or chemical category is eventually
4-6
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biodegraded by microorganisms or plants, it is not considered
recycled, reused, or treated.
(3) Surface impoundment - A surface impoundment is a natural
topographic depression, man-made excavation, or diked area
formed primarily of earthen materials that is designed to hold an
accumulation of wastes containing free liquids. Examples include:
holding, settling, storage, and elevation pits; ponds; and lagoons.
Quantities of the toxic chemical released to surface impoundments
that are used merely as part of a wastewater treatment process
generally must not be reported in this section. However, if the
sludge from the surface impoundment contains the EPCRA Section
313 chemical or chemical category, then the EPCRA Section 313
chemicals or chemical categories in the sludge must be estimated
in this section unless the sludge is removed and subjected to
another waste management activity.
(4) Other disposal - Releases to land that do not fit the categories of
landfills, land treatment, or surface impoundment are classified as
other disposal. This disposal may include any spills or leaks of the
EPCRA Section 313 chemical or chemical category to land.
f. Discharges to Publicly Owned Treatment Works (POTW) (Part II,
Section 6.1 of Form R) - Includes the amount of EPCRA Section 313
chemical or chemical category in water transferred to an off-site POTW.
Note that metals and metal compounds transferred to a POTW must also
be reported in Section 8.1.
g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form R)
- Includes all off-site transfers containing the EPCRA Section 313
chemical or chemical category for the purposes of disposal, treatment,
energy recovery, or recycling. Off-site transfer for disposal includes
underground injection, landfill/surface impoundment, other land disposal
and transfer to a waste broker for disposal. The amount transferred off site
for disposal must also be reported in Section 8.1.
Be sure to consider metals and metal compounds that are present in inks
used in printing operations. Waste containing these pigments may be
present in spent filters or other waste generated from printing operations.
Also reported in Section 6.2 would be any residual EPCRA Section 313
chemicals or chemical categories in "empty" containers transferred off
site. U.S. EPA expects that all containers (bags, totes, drums, tank trucks,
etc.) will have a small amount of residual solids and/or liquid. On-site
cleaning of containers must be considered for EPCRA Section 313
reporting. If the cleaning occurs with a solvent (organic or aqueous), you
must report the disposition of the waste solvent as appropriate. If the
4-7
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containers are sent off site for disposal or reclamation, you should report
the EPCRA Section 313 chemical or chemical category in this section.
COMMON ERROR - Shipping Container Residue
Do not overlook residual chemicals in containers. U.S. EPA recently published The
1994 and 1995 Toxic Release Inventory Data Quality Report, EPA 745-R-98-002,
presenting the site survey results of over 100 facilities to evaluate EPCRA Section 313
reporting quality. This survey found the largest source of overlooked release and other
waste management activities was from container residue. So-called "empty" drums may
contain an inch or more of liquid after draining and similarly "empty" bags may contain
residues of dust and powder. Even though each individual drum or bag may only
contain a small amount of an EPCRA Section 313 chemical or chemical category, for
facilities that receive hundreds or thousands of drums or bags each year the annual
cumulative amount of an EPCRA Section 313 chemical or chemical category can be
substantial. The quantities should typically be reported in Section 6.2 (see Table 4-1
for estimates of liquid drum residual and the text of this section for estimates of residual
from solids). Please note that unlike RCRA, EPCRA Section 313 does not define what
constitutes an "empty" container. EPCRA Section 313 is merely trying to account for
all the quantities of toxic chemicals released and otherwise managed as waste.
Actual data and a knowledge of the unloading methods at your facility can
be used to estimate the quantity of residual EPCRA Section 313 chemicals
or chemical categories in containers. However, U.S. EPA has developed
guidance to assist facilities if no site-specific information is available.
Table 4-1 provides results from experimentation on residue quantities left
in drums and tanks when emptied. These results are presented as the mass
percent of the vessel capacity, and are categorized based on unloading
method, vessel material, and bulk fluid material properties such as
viscosity and surface tension.
4-8
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Table 4-1
Summary of Liquid Residue Quantities From
Pilot-Scale Experimental Studya'b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244 - 0.472
0.404
0.032-0.080
0.054
0.020-0.039
0.033
0.031-0.042
0.038
0.024 - 0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266-0.458
0.403
0.026-0.039
0.034
0.016-0.024
0.019
0.033-0.034
0.034
0.020 - 0.040
0.033
Motor Oil*
1.97-2.23
2.06
1.70-3.48
2.30
0.677 - 0.787
0.737
0.328-0.368
0.350
0.100-0.121
0.111
0.133-0.191
0.161
0.112-0.134
0.127
Surfactant
Solution*
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc. for the U.S. Environmental
Protection Agency, Office of Pesticides and Toxic Substances, Washington DC Contract No. 68-02-4248. June 30,
1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid
materials. At viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information
on this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
Tor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 97 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactant solution viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
4-9
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The following example describes how the information in the table can be used to
estimate the quantity of an EPCRA Section 313 chemical in water that was used
to clean drums on site.
Example - Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10% aqueous solution of the chemical.
Further, it is assumed that the physical properties of the solution are similar to water. The solution is pumped
from the drums directly into a mixing vessel and the "empty" drums are triple-rinsed with water. The rinse water
is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
From Table 4-1, the average drum residue quantity for this scenario is 2.29%. In this example, it can be assumed
that all of the residual solution in the drums was transferred to the rinse water. Therefore, the quantity of the
EPCRA Section 313 chemical transferred to the drum reclaimer should be reported as "zero."
The annual quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the
mean weight percent of residual solution remaining in a pumped steel drum by the total annual weight of solution
in the drums. If the density is not known, it may be appropriate to use the density of water (8.34 pounds per
gallon):
(0.0229) x (55 gal/drum) x (1,000 drums) x (8.34 Ib/gal) = 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 Ib solution) x (0.1) = 1,050 pounds of the EPCRA Section 313 chemical
Therefore, 1,050 pounds of the EPCRA Section 313 chemical are transferred to the POTW, and should be
reported in Part II, Sections 6.1 and 8.7 of the 1999 FormR. Because they cannot be destroyed, metals cannot be
reported as being treated, and metals and metal portions of metal compounds should be reported in Part II,
Section 6.1 and 8.1 of the 1999 Form R.
h. On-Site Waste Treatment (Part II, Section 7A of Form R) - Includes all
on-site waste treatment of EPCRA Section 313 chemicals or chemical
categories. The information reported in Section 7A focuses on the
treatment of the entire waste stream, not the specific EPCRA Section 313
chemical or chemical category. The information includes type of waste
stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment
methods or sequence; influent concentrations of the EPCRA Section 313
chemical or chemical category; treatment efficiency (combined removal
and destruction) of the entire method or sequence; and whether efficiency
data are based on actual operating data. Metals and metal portions of
metal compounds treated in a combustion process are not destroyed but
should still be reported as going through the treatment process, with a
treatment efficiency of zero. Note that only the metal portion of metal
compounds should be reported in the Form R. The following example
illustrates how Section 7A should be completed for on-site treatment of a
wastewater stream containing three EPCRA Section 313 chemicals or
chemical categories.
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Example - On-Site Waste Treatment
A process at your facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical
A). A second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal
(chemical B) and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are
in the process of completing separate Form Rs for each chemical.
The two wastewater streams are combined and sent to an on-site wastewater treatment system before being
released to a POTW. This system consists of an oil/water separator that removes 99% of chemical A; a
neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C);
and a settling tank where 95% of the metal (chemical B) is removed from the water (and eventually land filled off
site).
Section 7 A should be completed slightly differently when you file the Form R for each of the chemicals or
chemical categories. The table accompanying this example shows how Section 7A should be completed for each
chemical or chemical category. First, on each Form R you should identify the type of waste stream in Section
7A. la as wastewater (aqueous waste, code W). Next, on each Form R you should list the code for each of the
treatment steps that is applied to the entire waste stream, regardless of whether the operation affects the chemical
or chemical category for which you are completing the Form R (for instance, the first four blocks of Section
7 A. Ib of all three Form Rs should show: P19 (liquid phase separation), C11 (neutralization), P11
(settling/clarification), and N/A (to signify the end of the treatment system). Note that Section 7A.lb is the only
section of the Form R that is not chemical or chemical category specific. It applies to the entire waste stream
being treated. Section 7 A. Ic of each Form R should show the concentration of the specific chemical or chemical
category in the influent to the first step of the process (oil/water separation). For this example, assume chemicals
or chemical categories A, B, and C are all present at concentrations greater than 1%. Therefore, code "1" should
be entered. Section 7A. Id is also chemical specific. It applies to the efficiency of the entire system in destroying
and/or removing the chemical or chemical category for which you are preparing the Form R. You should enter
99% when filing for chemical A, 95% for chemical B, and 100% for chemical C. Finally, you should report
whether the influent concentration and efficiency estimates are based on operating data for each chemical or
chemical category, as appropriate.
Chemical A
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-^
7A.ld
99 %
7A.le
Yes No
X
Chemical B
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-^
7A.ld
95 %
7A.le
Yes No
X
Chemical C
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-^
7A.ld
100 %
7A.le
Yes No
X
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
Section 7A. Id refers to the amount of EPCRA Section 313 chemical or chemical category destroyed and/or
removed from the applicable waste stream. The amount actually destroyed should be reported in Section 8.6
(quantity treated on site). For example, when completing the Form R for chemical B you should report "0"
pounds in Section 8.6 because the metal has been removed from the wastewater stream, but not actually
destroyed. The quantity of chemical B that is ultimately land filled off site should be reported in Section 6.2 and
8.1. However, when completing the Form R for chemical C you should report the entire quantity in Section 8.6
because raising the pH to 7.5 will completely destroy the mineral acid.
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i. On-Site Energy Recovery (Part II, Section 7B of Form R) - Includes all
on-site energy recovery of reported EPCRA Section 313 chemicals and
chemical categories. U.S. EPA's view is that EPCRA Section 313
chemicals or chemical categories that do not contribute significant heat
energy during combustion processes should not be considered for energy
recovery. Therefore, only EPCRA Section 313 chemicals or chemical
categories with a significant heating value that are combusted in an energy
recovery unit, such as an industrial furnace, kiln, or boiler can be reported
for energy recovery. If an EPCRA Section 313 chemical or chemical
category is incinerated on site but does not significantly contribute energy
to the process, (e.g., chlorofluorocarbons (CFCs)) it must be considered
on-site waste treatment (see 4.1.3, h. above). Metals and metal portions of
metal compounds will never be combusted for energy recovery. Note that
only the metal portion of metal compounds should be reported in the Form
R.
j. On-Site Recycling (Part II, Section 7C of Form R) - Includes all on-site
recycling methods used on EPCRA Section 313 chemicals or chemical
categories.
k. Source Reduction and Recycling Activities (Part II, Section 8 of Form
R)1 - Provide information about source reduction and recycling activities
related to the EPCRA Section 313 chemical or chemical category for
which release and other waste management activities are being reported.
Section 8 uses some data collected to complete Part n, Sections 5 through
7. For this reason, Section 8 should be completed last. The relationship
between Sections 5, 6, and 8.8 to Sections 8.1, 8.3, 8.5, and 8.7 are
provided in equation forms below.
(1) Quantity Released (Part II, Section 8.1 of Form R) - The
quantity reported in Section 8.1 is the quantity reported in all of
Section 5 plus the quantity of metals and metal compounds
reported as discharged off site to POTWs in Section 6.1 plus the
quantity reported as sent off site for disposal in Section 6.2 minus
the quantity reported in Section 8.8 that was released on site or sent
off site for disposal:
§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal) -
§8.8 (on-site release or off-site disposal only)
(2) Quantity Used for Energy Recovery On-Site (Part II, Section
8.2 of Form R) - Estimate the quantity of the EPCRA Section 313
chemical or chemical category in wastes combusted for energy
recovery on site. This estimate should be the quantity of the
'The Subsection 8.1 through 8.8 designations are for the 1999 Form R. Please refer to the current reporting year TRI
Forms and Instructions for any changes.
4-12
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chemical or chemical category combusted in the process for which
codes were reported in Section 7B. Test data from trial burns or
other monitoring data may be used to estimate the quantity of the
EPCRA Section 313 chemical or chemical category combusted for
energy recovery purposes. If monitoring data are not available,
vendor specifications regarding combustion efficiency may be used
as they relate to the EPCRA Section 313 chemical or chemical
category. A quantity must be reported in Section 8.2 when a
method of on-site energy recovery is reported in Section 7B and
vice versa.
Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical or chemical category (1) must have a
significant heating value and (2) must be combusted in an energy
recovery unit, such as a waste heat boiler, an industrial furnace, or
a kiln. If an EPCRA Section 313 chemical or chemical category
that does not have a significant heating value (except metals and
metal compounds) is combusted for energy recovery on site, it
must be considered on-site waste treatment (see 4.1.3.h). Metals
and metal compounds in a waste that are combusted on site will
never be combusted for energy recovery or treated for destruction
and are therefore normally disposed. Note that "NA" should be
reported for EPCRA Section 313 chemicals or chemical categories
that do not have a significant heating value. This includes metals,
metal portions of metal compounds, halogens,
hydrochlorofluorocarbons (HCFCs), and CFCs.
(3) Quantity Used for Energy Recovery Off-Site (Part II, Section
8.3 of Form R) - The quantity reported in Section 8.3 is the
quantity reported in Section 6.2 for which energy recovery codes
are reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for energy recovery:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical or chemical category (1) must have a
significant heating value and (2) must be combusted in an energy
recovery unit, such as a waste heat boiler, an industrial furnace, or
a kiln. If an EPCRA Section 313 chemical or chemical category
that does not have a significant heating value (except metals and
metal compounds) is sent off site for energy recovery, it must be
considered off-site waste treatment (see 4.1.3 .g). However, this
does not apply to metals and metal compounds. Metals and metal
compounds sent off site for combustion in energy recovery units
4-13
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must be considered as sent off site for disposal because typically
they will ultimately be disposed. Metals and metal portions of
metal compounds will never be treated or combusted for energy
recovery. Note that only the metal portion of metal compounds
should be reported in the Form R. Also note that "NA" should be
reported for EPCRA Section 313 chemicals or chemical categories
that do not have a significant heating value. This includes metals,
metal portions of metal compounds, halogens, HCFCs, and CFCs.
(4) Quantity Recycled On-Site (Part II, Section 8.4 of Form R) -
Estimate the quantity of the EPCRA Section 313 chemical or
chemical category recycled in wastes on site. This estimate should
be the quantity of the chemical or chemical category recycled in the
process for which codes were reported in Section 7C. A quantity
should be reported in Section 8.4 when a method of on-site
recycling is reported in Section 7C and vice versa. To estimate this
quantity, you should determine if operating data exist that indicate
a recovery efficiency and use that efficiency value combined with
throughput data to calculate an estimate. If operating data are
unavailable, available vendor specifications may be appropriate.
(5) Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -
The quantity reported in Section 8.5 must be the same as the
quantity reported in Section 6.2 for which recycling codes are
reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for recycling:
If the facility has knowledge about metals being recovered, this
quantity should be reported in Section 8.5.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
COMMON ERROR - Direct Reuse vs. Recycling
The direct reuse of an EPCRA Section 313 chemical does not need to be
included in the amount reported in Part II, Section 8 of Form R. However,
recycling of the chemical should be included.
(6) Quantity Treated On-Site (Part II, Section 8.6 of Form R) -
Waste treatment in Section 8 is limited to the destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category in wastes. The quantities reported in Section 8.6
will be those that have undergone processes that are a subset of the
processes for which codes were reported in Section 7A, where
treatment includes physical removal from a waste stream. To
estimate the quantity treated, you should determine if operating
4-14
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data exist that indicate a treatment efficiency (e.g., destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category) and use that efficiency value combined with
throughput data to calculate an estimate. Because metals cannot be
destroyed or chemically converted into something other than the
metal or metal compound, metals cannot be reported as treated in
Section 8.6. Note that conversion of a metal from one oxidation
state to another (e.g., Cr(VI) to Cr(in)) is not considered treatment
for Section 8.6. If operating data are unavailable, available vendor
specifications may be appropriate. Section 7A must be completed
if a quantity is entered in Section 8.6.
(7) Quantity Treated Off-Site (Part II, Section 8.7 of Form R) -
The quantity reported in Section 8.7 must be the same as the
quantity reported in Section 6.2 for which treatment codes are
reported plus quantities sent to a POTW as reported in Section 6.1
except for metals and metal compounds. If a quantity is reported in
Section 8.8, subtract any associated off-site transfers for treatment:
§8.7 = §6.1 (except metals and metal compounds) + §6.2
(treatment) - §8.8 (off-site treatment)
Because metals cannot be destroyed or chemically converted into
something other than the metal or metal compound, metals cannot
be reported as treated in Section 8.7. Quantities of metals reported
in Section 6.1 and 6.2 should be reported in Section 8.1 (Quantity
Released) unless the facility has knowledge that the metal is being
recovered.
(8) Quantity Released to the Environment as a Result of Remedial
Actions, Catastrophic Events, or One-Time Events Not
Associated with Production Processes (Part II, Section 8.8 of
Form R) - The purpose of this section is to separate quantities
recycled off site, used for energy recovery off site, treated off site,
or released (including disposed) that are associated with normal or
routine production from those quantities that are not. The quantity
reported in Section 8.8 is the quantity of the EPCRA Section 313
chemical or chemical category released directly into the
environment or sent off site for recycling, energy recovery,
treatment, or disposal during the reporting year due to any of the
following events:
• Remedial actions;
• Catastrophic events such as earthquakes, fires, or floods; or
• One-time events not associated with normal or routine
production processes.
4-15
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The quantity reported in Section 8.8 should not be included with
quantities reported in Part n, Sections 8.1 through 8.7 of Form R,
but should be included in Part II, Sections 5 and 6 of Form R as
appropriate.
Spills that occur as a routine part of production operations and
could be reduced or eliminated by improved handling, loading, or
unloading procedures are included in the quantities reported in
Section 8.1 through 8.7 as appropriate. This includes small
drippings and spills that often occur during transfer operations and
loading/unloading operations associated with many painting
processes.
On-site releases and off-site transfers for further waste
management from remediation of an EPCRA Section 313 chemical
or chemical category or an unpreventable accident unrelated to
production (such as a hurricane) are reportable in Section 8.8.
On-site treatment, energy recovery, or recycling of EPCRA Section
313 chemicals or chemical categories in wastes generated as a
result of remedial actions, catastrophic events, or one-time events
not associated with production processes are not reported in Part n,
Section 8.8, nor in Sections 8.1 through 8.7 of Form R.
COMMON ERROR - Double Counting
Release and other waste management activities should not be "double counted." A single wastewater discharge
should not be listed as both a release to water (on site) and a discharge to POTW (off site). Similarly, a release to
land should not be listed as both a release to land (on site) and a transfer to an off-site landfill. Estimates of
release and other waste management activities should be prepared for Sections 5 through 7 of the Form R. For
the most part, Section 8 relies on the data collected to complete these previous sections. Therefore, Section 8
should be completed last. However, the data elements of Section 8 (8.1 through 8.7) are mutually exclusive and
care should be taken to avoid double counting.
4.1.4 Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
After you have identified all of the potential sources for release and other waste
management activity types, you must estimate the quantities of each EPCRA Section 313
chemical and chemical category released and otherwise managed as waste. U.S. EPA has
identified four basic methods that may be used to develop estimates (each method has been
4-16
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assigned a code that must be included when reporting). The methods and corresponding codes
are:
• Monitoring Data or Direct Measurement (M);
• Mass Balance (C);
• Emission Factors (E); and,
• Engineering Calculations (O).
Descriptions of these techniques are provided in the U.S. EPA publication,
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
Forms (1999 edition). They are also briefly described below. A more detailed discussion
including examples of selected calculation techniques is presented in Appendix B. U.S. EPA
does not require you to conduct additional sampling or testing for EPCRA Section 313 reporting;
however, you are required to use the best, readily available information to determine the method
that will result in the most accurate estimate. For example, it may not be appropriate to use
emission factors or engineering calculations if more accurate data, such as stack testing results,
are available. You are required to identify the primary method used for each estimation.
Many potential sources of data exist for these (and other) methods of developing
estimates. Table 4-2 presents potential data sources and the estimation methodology in which
they are most likely to be used. Based on site-specific knowledge and potential data sources
available, you should be able to determine the best method for calculating each release and other
waste management activity quantity.
Once all potential release and other waste management activity sources, types, and
estimation methods have been determined, an estimate for each EPCRA Section 313 chemical
and chemical category can be developed corresponding to the elements on Form R.
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Table 4-2
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data
• Air permits
* Continuous emission monitoring
• Effluent limitations
• Hazardous waste analysis
• Industrial hygiene monitoring data
• NPDES permits
• Outfall monitoring data
• pH for acids and bases
• POTW pretreatment standards
• RCRA permit
• Stack monitoring data
• New Source Performance Standards
• Title V Permit Data
Emission Factors
AP-42 chemical specific emission factors
Facility or trade association derived chemical-
specific emission factors
Mass Balance
• Air emissions inventory
• Hazardous material inventory
• Hazardous waste manifests
• MSDSs
• Pollution prevention reports
• Spill event records
• Supply and purchasing records
Engineering Calculations
• Facility non-chemical specific emission factors.
• Henry's Law
• Raoult's Law
• SOCMI* or trade association non-chemical
specific emission factors
• Solubilities
• Volatilization rates
*Synthetic Organic Chemicals Manufacturing Industry.
4.1.4.1
Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for
developing chemical release and other waste management activity quantity estimates. Your
facility may be required to perform monitoring under provisions of the Clean Air Act (CAA),
Clean Water Act (CWA), RCRA, or other statutory or regulatory requirements. If so, data should
be available for developing estimates. Data may have also been collected for your facility
through an occupational health and safety assessment. If only a small amount of direct
measurement data are available or if you believe the monitoring data are not representative, you
must decide if another estimation method would give a more accurate result.
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Example - Monitoring Data
Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in the
discharge is 2 mg/L. The wastewater treatment facility processed 1.5 million gallons of water. The treated
wastewater is discharged to an off-site POTW. The amount of copper transferred off site to the POTW (for
Sections 6.1 and 8.1 of the Form R) is estimated as follows:
Amount of copper transferred
=(2 mg/L) x I 1 1 x I I!? 1 x I t 1 x (! 50o ooo gal/yr)
i, 1,000 mgj ( 453.59 gj ( 0.2642 galj
= 25 Ib/yr
COMMON ERROR - Treatment Efficiencies
Vendor data on treatment efficiencies often represent ideal operating conditions. You should adjust such data to
account for downtime and process upsets during the year that would result in lower efficiencies. Remember that
efficiencies reported by vendors are often general and may not apply to specific chemicals. For example, an
incinerator or flare may be 99.99% efficient in destroying certain organic chemicals, but will have a 0% efficiency
in destroying metals.
4.1.4.2 Mass Balance (code C)
A mass balance involves determining the amount of an EPCRA Section 313
chemical or chemical category entering and leaving an operation. The mass balance is written as
follows:
Input + Generation = Output + Consumption
where:
Input refers to the materials (chemicals) entering an operation. For
example, chlorine added to process water as a disinfectant would be
considered an input to the water treatment operation.
Generation identifies those chemicals created during an operation
(manufactured, including coincidental manufacturing). For example,
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when nitrogen sources are used in biological wastewater treatment
systems, nitrate compounds and additional ammonia may be coincidentally
manufactured.
• Output refers to the materials (chemicals) leaving an operation by various
avenues. Output avenues may include on-site release and other on-site
waste management activities; transfers off site for recycling, energy
recovery, treatment, storage, or disposal; or the amount of chemical that
leaves with the final product. In a printing operation, for example,
pigments in the ink may leave the operation as part of the product.
• Consumption refers to the amount of chemical converted to another
substance during the operation (i.e., reacted).
The mass balance technique may be applied toward manufactured, processed, or
otherwise used chemicals. It is typically most useful for otherwise used chemicals that do not
become part of the final product, such as catalysts. For large inputs and outputs, a mass balance
may not be the best estimation method, because slight uncertainties in mass calculations can
yield significant errors in the release and other waste management estimates.
The gravure printing industry often uses a liquid-liquid mass balance approach to
calculate emissions of carrier solvents and/or diluents found in inks. Using this approach,
fugitive air emissions are assumed equal to the amount of the EPCRA Section 313 chemical used
minus the amount sold back to the vendor, the amount shipped off site as hazardous waste, and
the amount remaining in the product.
Example - Mass Balance
A facility otherwise uses a volatile EPCRA Section 313 chemical as an ink solvent and adds 20,000 pounds to the
system over the course of a year (to make up for system losses). The chemical is released to the air from hood
vents, during system filling operations and from leaks in valves and fittings. Monitoring data of the hazardous
waste collected from this system indicate that 1,200 pounds of the chemical were sent off site for treatment and/or
recovery. The remaining losses are assumed to be fugitive air releases and are estimated as follows:
Fugitive air releases of the EPCRA Section 313 chemical
= Amount input (Ib/yr) - Amount sent off site as hazardous waste (Ib/yr)
= 20,000 Ib/yr - 1,200 Ib/yr
= 18,800 Ib/yr
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COMMON ERROR - Mass Balances for Otherwise Used Chemicals
Facilities often do not account for the entire quantity of EPCRA Section 313 chemicals or chemical categories
that are otherwise used. Many EPCRA Section 313 chemicals and chemical categories used in printing operations
are classified as otherwise used. These may include ink solvents, diluents, and fountain solutions or fountain
solution additives. Such chemicals and chemical categories may or may not leave the facility with the product.
For those instances where the EPCRA Section 313 chemical or chemical category does not leave the facility in the
product, all throughput may be lost during processing through on-site releases to air, water, or land, or it may be
shipped off site for further waste management activities. Thus, the entire throughput is often reportable on Form
R as release and other waste management activities to various media. Be sure to consider the entire throughput in
these circumstances and partition it as appropriate. A mass balance may be the best starting point to estimate the
release and other waste management quantities.
4.1.4.3 Emission Factors (code E)
An emission factor is a representative value that attempts to relate the quantity of
a chemical or chemical category released with an associated activity. These factors are usually
expressed as the weight of chemical or chemical category released divided by a unit weight,
volume, distance, or duration of the activity releasing the chemical (e.g., pounds of chemical
released per pounds of product produced). Emission factors, commonly used to estimate air
emissions, have been developed for many different industries and activities. You should
carefully evaluate the source of the emission factor and the conditions for its use to determine if
it is applicable to the situation at your facility. If there are more than one EPA published
emission factor, you should determine which is most appropriate for your operations and
document your rationale.
The most widely known and used source for emission factors is U.S. EPA's
publication Compilation of Air Pollutant Emission Factors (AP-42). Volume I of AP-42
contains information on over 200 stationary source categories, including process descriptions and
potential sources of air emissions from these processes. Methodologies for estimating the
quantity of air pollutant emissions from these sources are presented as Emission Factors. For
EPCRA Section 313 purposes only CHEMICAL-SPECIFIC emission factors can be reported as
Code "E" - Emission Factor in Part n, Section 5, Column B, Basis for estimate, of the Form R.
AP-42 contains emission factors for individual chemicals and for the chemical group Volatile
Organic Compounds (VOCs). The VOC emission factors are NOT chemical specific and when
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used must be reported in Column B as Code "O" - Engineering Calculations. Each chapter in
Volume I covers a major industry or source category. Of special interest to printing operations
would be Chapter 4: Evaporation Loss Sources, in particular Sections 4.9.1, General Graphical
Printing; and 4.9.2, Publication Gravure Printing.
AP-42 can be accessed at the following Internet site:
• http://www.epa.gov/ttn/chief/ap42.html
In an effort to provide current emissions data in an easy-to-access format, U.S.
EPA has prepared a CD-ROM entitled Air CHIEF (Air ClearingHouse for Inventories and
Emission Factors). The Air CHIEF CD-ROM is updated annually and is available from the
Government Printing Office and can be ordered from their Web site. In addition to AP-42, the
Air CHIEF CD-ROM contains the Factor Information Retrieval (FIRE) data system, a database
management system containing U.S. EPA's recommended emission estimation factors for
criteria and hazardous air pollutants. The CD-ROM also contains installable copies of software
programs for air emission estimation models such as "TANKS" for VOC emission from storage
tanks; "WATERS" for air emissions from wastewater systems; and "CHEMDAT8" for VOC
emissions from Treatment, Storage, and Disposal Facility (TSDF) processes. Additional
information on Air CHIEF and the CD-ROM is available at:
• http://www.epa.gov/ttn/chief/airchief.html
Your facility may have developed non-chemical specific emission factors for
fugitive or stack emissions from printing operations based on stack tests for various air permits.
Be sure to consider these emission factors if appropriate. However, if such factors are used, they
are considered "engineering calculations" for the purposes of EPCRA Section 313 reporting.
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Example - Emission Factors
Emission factors have been developed for air releases of fuel constituents and combustion products from boiler
operations. AP-42 lists a range of formaldehyde emission factors when distillate (No. 2) fuel oil is consumed:
0.035 to 0.061 Ib formaldehyde generated/103 gal No. 2 fuel oil fired.
Assuming a facility met reporting requirements for formaldehyde, the facility operating a boiler using No. 2 fuel
oil could use the above emission factor to determine the amount of formaldehyde generated and subsequently
released to the air. If 1,000,000 gallons of No. 2 fuel oil is used during a reporting year, the amount of
formaldehyde generated would be between:
(0.035 lb/103 gal) x (1,000,000 gal) and (0.061 lb/103 gal) x (1,000,000 gal)
= 35 and 61 Ib of formaldehyde generated
If there are no engineering controls or air pollution control devices that would destroy or remove the
formaldehyde, this quantity should be reported in Part II, Sections 5.2 and 8.1 of the 1999 FormR.
NOTE: No. 2 fuel oil contains other EPCRA Section 313 chemicals and chemical categories and EPCRA Section
313 chemicals and chemical categories may also be coincidentally manufactured during combustion. All should
be considered for EPCRA Section 313 reporting.
4.1.4.4 Engineering Calculations (code O)
Engineering calculations are assumptions and/or judgments used to estimate
quantities of EPCRA Section 313 chemicals or chemical categories released or otherwise
managed as waste. The quantities are estimated by using physical and chemical properties and
relationships (e.g., Ideal Gas law, Raoult's law) or by modifying an emission factor to reflect the
chemical properties of the chemical in question. Engineering calculations rely on the process
parameters; you must have a thorough knowledge of your facility operations to complete these
calculations.
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Examples - Engineering Calculations
Example 1:
Stack monitoring data are available for xylene but you are required to report for toluene. Toluene is used in the
same application as xylene at your facility and the concentrations of the chemicals in the liquid feedstock are
approximately the same. You can estimate the emissions of toluene by adjusting the monitoring data of xylene by
a ratio of the vapor pressure for xylene to toluene. This example is an engineering calculation based on physical
properties and process operation information:
From facility stack monitoring data, you determine that an estimated 200 Ib of xylene are released as air emissions
during the reporting year. Toluene is also present in the air emissions, but not monitored. The stack operates at
approximately 20 °C. Based on literature data, the vapor pressure at 20° C for toluene is 22 millimeters of
mercury (mmHg) and for xylene is 6 mmHg. Using a ratio of the vapor pressures, the amount of toluene released
as air emissions from the stack can be calculated:
X Ib/yr toluene = 22 mmHg (vapor pressure of toluene*)
200 Ib/yr xylene 6 mmHg (vapor pressure of xylene)
X Ib/yr toluene = (200 Ib/yr xylenel (22 mmHg toluenel
(6 mmHg xylene)
Completing the calculation, you determine that 730 Ibs of toluene were released as stack air emissions during the
reporting year. The quantity of toluene released should be reported in Section 5.2 of the 1999 Form R.
Example 2:
A printing process uses 10,000 gallons per year of an ink that is 3% xylene by volume. All of the xylene in the
ink is assumed to evaporate during the printing operation. The printing process is equipped with a fume
collection hood that captures 80% of the ink vapors. The remaining 20% of the ink vapors are assumed to be
released as fugitive air emissions. The collection hood routes the ink vapors to an incinerator that is vented to the
atmosphere and has a destruction efficiency of 99% for xylene. The specific gravity of xylene is 0.86 and the
density of water is 8.34 Ib/gal. Fugitive air emissions and stack air emissions may be estimated as follows:
1. The total amount of xylene volatilized to air (assumed to be the total amount of xylene
in ink)
(10,000 gal/yr ink) x (0.03, three percent xylene) x
(0.86 xylene specific gravity) x (8.34 Ib/gal, density of water)
2,152 Ib/yr xylene evaporated from printing operations
2. The amount of xylene released as fugitive air emissions
(2,152 Ib/yr) x (0.2; twenty percent released as fugitive air emissions)
430 Ib/yr
3. The amount of xylene released as stack air emissions
(2,152 Ib/yr) x (0.8, eighty percent capture efficiency) x (1-0.99, percent not
incinerated)
17 Ib/yr
This should be reported in Part II, Section 5.2 and 8.1 of the 1999 Form R.
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Engineering calculations can also include computer models. Several computer
models are available for estimating emissions from landfills, wastewater treatment, water
treatment, and other processes.
Non-chemical-specific emission factors, Synthetic Organic Chemicals
Manufacturing Industry (SOCMI) emission factors, industry-determined emission factors for
processes or equipment, and site-specific emission factors also can be used, but must be
classified as "Engineering Calculations" for EPCRA Section 313 reporting.
4.1.4.5 Estimating Release and Other Waste Management Quantities
Once all sources, types, and appropriate estimation methodologies have been
identified, you can estimate the release and other waste management activity quantities of
EPCRA Section 313 chemicals or chemical categories for each element of the Form R. The
recommended approach is that you estimate amounts from all sources at your facility to each type
as identified by the elements of Form R. Table 4-3 presents a work sheet that may be helpful in
compiling this information.
If you prepare a Form R, you must also enter on-site treatment information in
Section 7 A, including the code for each treatment method used, the destruction and removal
efficiency for the EPCRA Section 313 chemical in the treated waste stream, and the
concentration of the EPCRA Section 313 chemical in the influent to treatment. You should
report treatment methods that do not actually destroy or remove the chemical by entering "zero
(0)" for removal efficiency. Similarly, on-site energy recovery methods and on-site recycling
methods must be reported in Sections 7B and 7C, respectively.
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Table 4-3. Release and Other
Waste Management Quantity Estimation Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared by:
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses, Spills, Surface Impoundments
Total =
5. land 8.1 or 8. 8
5. land 8. lor 8.8
5.1 and 8. lor 8. 8
5. land 8. lor 8.8
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
5.2 and 8. lor 8.8
5. 2 and 8. lor 8. 8
5.2 and 8. lor 8.8
5. 2 and 8.1 or 8. 8
5.2 and 8. lor 8.8
RECEIVING STREAM/WATER BODY DISCHARGE
Stormwater Discharge
On-Site Treatment Plant Discharge
Total =
5. 3 and 8. lor 8.8
5. 3 and 8.1 or 8. 8
5. 3 and 8. lor 8.8
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II - V Wells
Total =
5.4 and 8. lor 8.8
5. 4 and 8.1 or 8. 8
5.4 and 8. lor 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
ON-SITE LAND
RCRA Subtitle C Landfill
Other Landfill
Land Treatment/Application Farming
Surface Impoundment
Other Disposal
Total =
ON-SITE ENERGY RECOVERY
Industrial Kiln
Industrial Furnace
Industrial Boiler
Other Energy Recovery Methods
Total =
ON-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Acid Regeneration
Other Reuse or Recovery
Total =
ON-SITE TREATMENT
Air Emissions Treatment
Biological Treatment
Chemical Treatment
Incineration/Thermal Treatment
Physical Treatment
Solidification/Stabilization
Total =
5. 5 and 8. lor 8. 8
5. 5 and 8. lor 8.8
5. 5 and 8.1, or 8. 8
5.5 and 8. lor 8.8
5. 5 and 8.1 or 8. 8
5. 5 and 8. lor 8.8
8.2
8.2
8.2
8.2
8.2
8.4
8.4
8.4
8.4
8.4
8.6
8.6
8.6
8.6
8.6
8.6
8.6
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
Off-Site Location
(name)
OFF-SITE DISPOSAL
Solidification/Stabilization (metals and
metal compounds only)
Amount of metal and metal compounds to
POTW
Wastewater Treatment (excluding
POTWs) metals and metal compounds
only
Underground Injection
Landfill/Surface Impoundment
Land Treatment
Other Land Disposal
Other Off-Site Management
Total =
6.2 and 8. lor 8. 8
6.1 and 8. lor 8. 8
6. 2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8. 8
OTHER AMOUNTS SENT OFF SITE
Amounts sent for storage
Amounts sent for unknown waste
management practice
Total =
6.2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
OFF-SITE TREATMENT
Solidification/Stabilization
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Wastewater Treatment (to POTW
excluding metals and metal compounds)
Wastewater Treatment (excluding POTW
and metal and metal compounds)
Sent to Waste Treatment Broker
Total =
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.1 and 8. 7 or 8. 8
6.2 and 8.7 or 8.8
6.2 and 8. 7 or 8. 8
6.2 and 8.7 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
Off-Site Location
(name)
OFF-SITE ENERGY RECOVERY
Off-Site Energy Recovery
Sent to Energy Recovery Broker
Total =
6.2 and 8.3 or 8.8
6.2 and 8.3 or 8.8
6.2 and 8. 3 or 8. 8
OFF-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Sent to Recycling Waste Broker
Total =
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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4.2 Determination of Release and Other Waste Management Activity Quantities
from Printing Operations
This section discusses the five basic printing technologies (lithography,
(roto)gravure, flexography, screen, and letterpress) and the specific issues associated with each
that apply to EPCRA Section 313 reporting. A general description of each technique is followed
by more detailed discussions of the four fundamental steps that are common to each technique.
The suggested method to determine release and other waste management activity quantities from
each step are then presented in Sections 4.2.1 through 4.2.4 as follows:
Imaging/Film Processing (Section 4.2.1);
Image Carrier Preparation (Section 4.2.2);
Printing (Section 4.2.3); and
Post-press (Section 4.2.4).
The printing and publishing industry, defined most broadly, includes firms whose
business is dominated by printing operations, firms performing operations commonly associated
with printing such as platemaking or bookbinding, and publishers, whether or not they actually
print their own material. The printing industry produces a wide array of printed products as well
as materials used in the printing process. Some of the products produced within the industry
include newspapers, books, greeting cards, checks, annual reports, magazines, and packaging.
From the printing industry's perspective, the industry is organized by the type of
printing technology used: lithography, roto-gravure, flexography, screen, letterpress, and digital.
Facilities tend to employ one type of printing process exclusively, although some of the larger
facilities may use two or more types. Based on the estimated value of shipments from the U.S.
printing industry in 1990, lithography dominates the market with a 46% market share; gravure,
18%; flexography, 18%; letterpress, 10%; digital, 15%, and screen printing, 3 percent.2 The six
basic printing processes are described in the following paragraphs.
2Variation in facility counts occur across data sources due to many factors such as reporting and definitional
differences. This document does not attempt to reconcile these differences, but rather reports the data as they are
maintained by each source.
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Lithography. Lithography is a planographic method of printing (in contrast to
gravure, in which the image is etched or engraved below the surface of a plate or cylinder, or
flexography, in which the image is raised above the surface of the plate). Where the image area
and non-image area are in the same plane, the image area is ink receptive (water repellant) and
the non-image area is water receptive (ink repellant). In offset lithographic printing, ink is
transferred from the plate to a rubber blanket cylinder. The blanket cylinder is used to print the
substrate.
The lithographic printing industry is divided on the basis of press equipment
between sheet-fed (where individual sheets of paper are used), non-heatset web (where a
continuous roll of paper is used without the application of heat), and heatset web printing (where
a continuous roll of paper or other substrate material is used with the application of heat).
Lithographic inks do not typically contain EPCRA Section 313 chemicals or chemical categories,
but fountain solutions used in the process and cleanup solvents may contain these chemicals.
Gravure. Gravure printing is a printing process in which an image (type and art)
is etched or engraved below the surface of a plate or cylinder (rotogravure). On a gravure plate
or cylinder, the printing image consists of millions of minute cells etched or engraved into copper
cylinders that is subsequently plated with chrome. Gravure requires very fluid inks that flow
from the cells to the substrate at high press speeds. In addition to inks, other materials including
adhesives, primers, coatings, and varnishes may be applied with gravure cylinders. These
materials dry by evaporation as the substrate passes through hot air dryers. Solvent-borne or
waterborne ink systems can be used but these ink systems are not interchangeable. Both the
printing cylinders and the drying systems are specific to the solvent system in use.
The evaporated components of the ink and other materials may contain EPCRA
Section 313 chemicals or chemical categories to varying extents. Additional EPCRA Section
313 chemicals and chemical categories may be present in solvents used to clean presses and press
components. Rotogravure can be divided into the publication and product/packaging segments.
Because of the expense and complexity of rotogravure cylinder engraving, it is particularly suited
to long run printing jobs.
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Flexography. Flexographic printing is an example of relief printing where the
image area is raised relative to its non-image area. The pattern to be applied is raised above the
printing plate and the image carrier is made of rubber or other elastomeric materials. The major
applications of flexographic printing are flexible and rigid packaging; tags and labels;
newspapers, magazines, and directories; and consumer paper products such as paper towels and
tissues. Because of the ease of plate making and press set up, flexographic printing is more
suited to short production runs than gravure and accounts for about 85% of package printing.
Flexographic inks must be very fluid to print properly and include both
waterborne and solvent-based systems (solvent-based systems may include EPCRA Section 313
chemicals or chemical categories). The solvents must be compatible with the rubber or
polymeric plates; thus, aromatic solvents are not used. Some of the components of solvent-based
flexographic ink include alcohols (like ethyl alcohol); glycol ethers; aliphatic hydrocarbons;
acetates; and esters.
Flexographic printing can be divided between publication and packaging/product
printing. Additional distinctions can be made on the basis of web versus sheetfed press
equipment.
Digital. Digital printing is any printing completed via digital files, not restricted
to short runs and is able to provide variable printing such as incorporating data directly for a
compact database and printing to a digital press not using traditional methods of film or printing
plates.
Screen. In screen printing, ink is forced through a stencil placed over a porous
screen. The screens are generally made of silk, nylon, or metal mesh. Screen printing is used for
signs, displays, electronics, wall paper, greeting cards, ceramics, decals, banners, and textiles.
Ink systems used in screen printing include ultraviolet cure, waterborne (which
may contain ammonia), solvent borne, and plastisol (polyvinyl chloride). Plastisol is mainly used
in textile printing. Solvent-based ink systems (which may include EPCRA Section 313
chemicals or chemical categories) contain aliphatic, aromatic, and oxygenated organic solvents.
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Both sheetfed and web presses are used. Depending on the substrate printed, the
substrate can be dried after each station or, for absorbent substrates, after all colors are printed.
Solvent and waterborne inks are dried in hot air or infrared drying ovens. Dryer gasses are
typically partially recycled and partially vented (either to the atmosphere or to an air pollution
control system).
Letterpress. Letterpress printing uses a relief printing plate, as does flexography,
and viscous inks similar to lithographic inks. Various types of letterpress plates are available.
These plates differ from flexographic plates in that they have a metal backing. The industry
currently uses both sheetfed and web presses. The industry currently uses both sheet fed, heatset
web, and non-heatset web presses. Newspapers were traditionally printed by web non-heatset
letterpress; however, flexographic and lithographic presses are gradually replacing this process.
Letterpress is used to print newspapers, magazines, books, stationery, and advertising.
The equipment, applications, and chemicals for each of these printing
technologies differ; however, they all print an image on a substrate following the same basic
sequence and the associated EPCRA Section 313 reporting issues are similar. The fundamental
steps in printing are referred to as imaging/film processing, image carrier preparation, printing,
and post-press operations (see Figure 4-3). Process flow diagrams presenting typical sources for
EPCRA Section 313 chemical and chemical category release and other waste managed quantities
are presented in Sections 4.2.1 through 4.2.4. The type of printing technology that is used
depends on a variety of factors, including the substrate used (e.g., paper, plastic, metal, ceramic,
etc.), the length and speed of the print run, the required print image quality, and the end product.
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Inputs Process
(e.g., Raw materials) Operation
Typical Waste
Outputs
Corresponding Typical
Form R "Types"
Solvents
Inks
Film
Developer
Fixer
Developer
Fixer —
Plate Substrate
Adhesives
Coatings 1
Foundain Solutions
Inks
Solvents
Substrate
Substrate
Glue
Adhesives
Coatings
InkJet Inks
Air Emissions —
Aqueous Wastes •
Solid Wastes-""
'Aqueous Wastes-
Air Emissions^-^
Air Emissions
-Spent Solvents —
Container Residue,
Spent Ink-
Air Emissions
'Solid Wastes-
- Fugitive or Stack
• Discharge to Receiving
Stream or POTW
-On-Site Land Disposal
or Off-Site Transfer
- Discharge to Receiving
Stream or POTW
-Fugitive or Stack
- Fugitive or Stack
-On-Site Treatment or
Energy Recovery;
Off-Site Transfer
\ (Treatment, energy recovery, or disposal)
Off-Site Transfers
Off-Site Transfers or
On-Site Treatment
- Fugitive or Stack
-On-Site Disposal or
Off-Site Transfer
Figure 4-3. Overall Process Flow Diagram
The first step in the printing process, imaging/film processing, produces an image
of the material to be printed. Traditionally, this image is produced photographically, but with
increasing frequency the image is produced electronically. The production of a photographic
image involves a variety of chemicals similar to the ones used in other fields of photography,
especially black and white film chemistry, which is the most common. In the image carrier
preparation step, the image on the film is transferred to either an image carrier or plate. During
printing, ink is applied to the plate and the image is transferred to the substrate. In the post-press
step, the printed material may be subject to any one of numerous finishing operations, depending
on the desired form of the final product.
Each of the six predominant printing technologies differ significantly in how the
image is transferred from the image carrier to the substrate in the printing step. In general, the
imaging and post-press operations are fairly similar for all printing technologies and the
platemaking and press operations are specific to each technology.
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Each of the four printing steps is addressed in the following sections. Issues and
guidance specific to one of the five traditional printing technologies are included where
appropriate. While there are many steps involved prior to actual printing, there are only two
where Section 313 chemicals are used most commonly and released in appreciable quantities.
These are film processing and image carrier preparation.
4.2.1 Imaging/Film Processing
Imaging/film processing operations begin with composition and typesetting,
followed by the production of a photographic negative or positive. During composition, art and
text are arranged into the desired format, usually through the use of computer systems.
Computers can be equipped with both optical character recognition and photographic image
scanners and digitizers so that pre-typed material and images can be incorporated into the
document being composed.
Once the desired format and images are assembled, they are photographed to
produce transparencies. The purpose of this step is to produce a photographic negative (for
lithography and letterpress) or a positive (for gravure, screen printing, and other lithographic
processes). The printing industry photographic process uses input materials very similar to the
ones used in other fields of photography. The process uses paper, plastic film, or a glass base
covered with a light-sensitive coating called a photographic emulsion, usually composed of silver
halide salts and gelatin. The desired image is projected onto the film to produce a film negative
or a film positive. When the exposed photographic emulsion is developed, the silver halide in
the emulsion is converted to metallic silver, in proportion to the amount of exposure it has
received. The developing action is stopped by immersing the film in a fixing bath, which is
mainly composed of sodium thiosulfate ("hypo"). The fixed photographic emulsion is then
rinsed. If an image is to be printed as a color reproduction, negatives are made for each of the
colors to be used on the press. Multi-color printing is done by passing the same substrate
through several color-printing operations. Three or four basic colors are combined on the final
product to yield any color desired.
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4.2.1.1
Step 1: Prepare Process Flow Diagram
You should prepare a site-specific process flow diagram to help identify all
potential sources and types of chemical releases and waste management activities. A typical flow
diagram is presented in Figure 4-4.
Fugitive Air
I
Photographic Chemicals
Imaging/
Film Processing
T
Positive/Negative Film
Aqueous Process or Cleaning Waste
(typically discharged to POTWs after
silver recovery. Can also be sent off
site for treatment, disposal, or recycle)
Figure 4-4. Process Flow Diagram - Imaging/Film Processing
4.2.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and
Potential Sources of Chemical Release and Other Waste Management
Activities
As mentioned above, imaging/film processing operations are similar for each of
the five printing technologies and are essentially photographic processes. As such, the most
common potential source of EPCRA Section 313 chemicals or chemical categories is from the
use of film, glass., and other equipment cleaners, and film developers.
4.2.1.3
Step 3: Identify Release and Other Waste Management Activity Types
The primary source of release is the film processing unit itself. Release and other
waste management activity types include fugitive emissions to the air from the volatilization of
EPCRA Section 313 chemicals found in cleaning solutions, discharging of Section 313
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chemicals to POTWs from film processes and aqueous wastes sent off site for treatment,
disposal, or recycling. Typical release and other waste management activities and typical
EPCRA Section 313 chemicals or chemical categories found in imaging are presented in Table
4-4.
Table 4-4
Typical Release and Other Waste Management Activity Types
and Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Imaging/Film Processing
Type
Fugitive Air
Off-Site Transfer
(typically treatment, disposal,
or energy recovery)
Typical EPCRA Section 313 Chemicals
Ammonia, hexane, ethyl benzene, toluene,
xylene
Ammonia, hydroquinone, diethanolamine,
zinc compounds
EPCRA Section 313 chemicals and chemical categories used in these processes
are often used as ink solvents or cleaners in the application of inks to the printed material. The
combination of these various uses may exceed an activity threshold. If so, all release and other
waste management quantities must be estimated and reported as appropriate.
4.2.1.4 Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
Fugitive emissions from imaging/film processing operations can be estimated
using engineering calculations and mass balance approaches based on purchasing records.
Aqueous waste disposal can be estimated using hazardous waste manifest data, or other records
of shipment.
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EXAMPLE CALCULATION 4.1 - Imaging/Film Processing Operations
N-Hexane is used at a rotogravure printing facility in a variety of cleanup operations, including the film
processing area where it is used as a glass and equipment cleaner. You have determined that your facility is over
the reporting threshold for n-hexane, so a Form R is required.
The film shop used 100 pounds of n-hexane over the course of the year, and records indicate that 80 pounds were
collected as waste solvent or in cleanup rags and sent off site to an energy recovery facility. This quantity should
be reported in Part II, Section 8.3 (quantity used for energy recovery off site). The difference is assumed to be
_ A_ _._ _______
released as fugitive air emissions:
Fugitive air emissions = 100 (Ibs/year) - 80 (Ibs/year)
20 (Ibs/year)
This quantity should be reported as fugitive air releases in Part II, Section 5.1 (fugitive or non-point air
emissions). Note that if the cleaning operations were done in an enclosed area (such as under a hooded vent), the
emissions would be reported as stack air emissions in Part II, Section 5.2 (stack or point air emissions).
4.2.2 Image Carrier Preparation
Image carrier preparation operations include those operations used to create a
"plate" which is used in each printing process to carry or transfer ink in the form of the image to
the substrate. The following paragraphs contain a brief description of the platemaking process
for each of the five printing technologies.
Lithography. In lithography, a planographic plate is used where the image areas
and the non-image areas are on the same plane (they are neither raised nor depressed) and are
defined by differences in their physiochemical properties. The industry performs several types of
lithographic printing, but all types use a planographic plate and rely on the fundamental property
that oil and water do not mix. As a result, lithographic inks are traditionally oil-based derived
from petroleum. A metal or paper or plastic printing plate is coated with a light-sensitive
chemical which becomes ink receptive when exposed to light. Through the photographic
negative, the coating is exposed to light, chemically changing the exposed areas and making the
image areas ink-receptive. The non-image areas remain water-receptive. Water-based mixtures,
referred to as fountain solution, are applied to enhance the non-image area's ability to repel ink.
Fountain solutions may contain 5 to 10% isopropyl alcohol or they may contain alcohol
substitutes that meet the same needs but with a lower VOC content. It should be noted that while
isopropyl alcohol is considered a VOC, it is not subject to EPCRA Section 313 reporting
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requirements, unless being manufactured by the strong acid process. Therefore, isopropyl
alcohol processed or used in these operations should not be considered in threshold
determination. Through the use of inking rollers, ink is applied to the plate, adhering only to the
image areas. The image is transferred or offset from the plate to a rubber roller (the blanket),
which then transfers the image to the substrate being printed.
Gravure. Gravure printing uses almost exclusively electro-mechanically
engraved copper image carriers (plates) to separate the image area from the non-image area.
Typically, the gravure image carrier is a cylinder consisting of a steel or plastic base plated with
copper or a special alloy. Electronic impulses drive a diamond stylus which engraves minute
cells at the rate of over 3,000 per second. Today, most of the gravure cylinders are engraved
directly from digital files. Chemical etching, which is a dominant technology for the gravure
cylinder imaging in the past, represents a very small percentage of the total engravings done
today. It is used for special applications only.
Flexography and Letterpress. The traditional method of making flexography
and letterpress plates begins with exposing a metal plate through a negative then processing the
exposed plate using an acid bath. The resulting metal engraving may be used directly for
letterpress (flatbed), or alternatively used to mold a master using a bakelite board. The board,
under pressure and heat, fills the engraving and, when cooled, becomes a master for molding a
rubber plate with a raised area that will transfer the graphics. The second method of making
plates employs photopolymers in either a solid or liquid state. The photopolymer sheet
(consisting of monomers) is exposed to light through a negative and the unexposed areas are
washed out by means of a solvent or water wash. The result is the relief plate.
Screen Printing. Unlike the impervious plates used in the other four printing
techniques, the screen printing process uses a porous polyester mesh. The mesh is stretched
tightly over a frame, and a stencil, which defines the image to be printed, is applied to the mesh.
A squeegee applies pressure to the ink thereby forcing the ink through the open areas of the
screen. The thread count and diameter determine the amount of ink deposited onto the substrate
below.
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4.2.2.1
Step 1: Prepare Process Flow Diagram
As discussed above, image carrier preparation operations will differ significantly
depending on the printing technology employed; however, the general process streams and the
associated EPCRA Section 313 chemical and chemical category release and other waste
management activities are expected to be similar for each technology. You should prepare a site-
specific process flow diagram to help identify all potential sources and types of EPCRA Section
313 chemical and chemical category release and other waste management activities. A typical
flow diagram is presented in Figure 4-5.
Fugitive Air
(volatilization of developing chemicals)
Film Processing,
Screen Preparation, and
Platemaking Chemicals
Image Carrier
Preparation
T
T
-> Image Carrier
On-site
recycling
Aqueous Wastes
(typically discharged to
POTWs; can also be sent
off site for treatment,
disposal, or recycling)
Figure 4-5. Process Flow Diagram - Image Carrier Preparation
4.2.2.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and
Potential Sources of Chemical Release and Other Waste Management
Activities
As described above, image carrier preparation or platemaking operations are
unique for each of the five printing processes. Typical sources of EPCRA Section 313 chemicals
and chemical categories are flexographic plate developers, etching chemicals (typically nitric
acid) for metallic plates, and copper and chromium electroplating solutions.
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4.2.2.3
Step 3: Identify Release and Other Waste Management Activity Types
Release sources from image carrier preparation or platemaking processes include
process units and spent electroplating solutions. Release types include fugitive emissions to the
air from the volatilization of developing chemicals, and aqueous wastes sent off site for
treatment, disposal, or energy recovery. Acids used in image carrier preparation operations
(typically nitric acid used in etching of metal plates) and neutralized on site before being
discharged to a POTW should be identified as being treated on site if the pH of the effluent
remains between 6 and 9 ($QQ Estimating Releases for Mineral Acid Dischargers Using pH
Measurement, U.S. Environmental Protection Agency, June 1991). Typical release and other
waste management activities and typical EPCRA Section 313 chemicals or chemical categories
found in image carrier preparation operations are presented in Table 4-5.
Table 4-5
Typical Release and Other Waste Management Activity Types
and Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Image Carrier Preparation Operations
Type
Fugitive Air
POTW
Off-Site Treatment
Off-Site Energy Recovery
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Ethylene glycol, certain glycol ethers,
methanol
Ethylene glycol, certain glycol ethers,
methanol, nitric acid
Nitric acid, copper and chromium compounds
Ethylene glycol, certain glycol ethers,
methanol
4.2.2.4
Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
Fugitive emissions from image carrier preparation operations can be estimated
using engineering calculations and mass balance approaches based on purchasing records.
Aqueous waste disposal can be estimated using hazardous waste manifest data.
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Wastewater volumes are normally metered or may be estimated based on make-up
quantities required. Monitoring data for on-site wastewater treatment plant permits and NPDES
permit requirements can generally provide wastewater concentrations of EPCRA Section 313
chemicals and chemical categories that are directly or indirectly discharged in your facility's
wastewater. The following example provides an example using NPDES data for estimating the
quantity of an EPCRA Section 313 chemical discharged in wastewater.
EXAMPLE CALCULATION 4.2 - Image Carrier Preparation
Your facility collects spent electroplating solution from gravure cylinder making operations for shipment to an
off-site treatment facility. The solution contains copper compounds at a concentration of 200 (mg/L). Over the
course of a year you send 100,000 gallons of spent solution to an off-site facility for treatment.
Off-site transfers = 200 (mg/L) * (1 g/103 mg) * (1 lb/454 g) * 3.785 (L/gal) * 100,000 (gal/year)
167 (Ib./year)
This quantity should be reported in Part II, Section 6.2 (off-site transfers).
4.2.3 Printing
The majority of releases in the printing industry occur during the actual printing
step. For purposes of this discussion, printing also includes cleanup operations, that may occur
continuously during the print run or between runs. The EPCRA Section 313 chemicals and
chemical categories used in each printing technology differ; therefore, typical chemicals and
chemical categories specific to each technology are highlighted in the general discussion below,
which is followed by the suggested steps to identify and calculate release and otherwise managed
quantities.
The inks used in lithography are oil-based and traditionally do not contain
EPCRA Section 313 chemicals as solvents, but may contain reportable metals or metal
compounds. A metal or paper or plastic printing plate is coated with an ink-receptive image area.
The non-image areas remain water-receptive. Water-based mixtures, referred to as fountain
solution, are applied to enhance the non-image area's ability to repel ink. Fountain solutions may
contain isopropyl alcohol (which is not reportable if processed or otherwise used; see
"Manufacturing Qualifiers," Section 3.1) or certain glycol ethers (which may be reportable; see
Toxic Release Inventory; List of Toxic Chemicals Within the Glycol Ethers Category., U.S.
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Environmental Protection Agency, May 1995. EPA-745-R-95-006). Through the use of inking
rollers, ink is applied to the plate, adhering only to the image areas. The image is transferred or
offset from the plate to a rubber roller (the blanket), which then transfers the image to the
substrate being printed. Some lithographic inks are curable using ultraviolet energy or electron
beam, and do not contain solvents.
In gravure printing, ink is applied to the engraved cylinder, then wiped from the
surface by the doctor blade, leaving ink only on the engraved image area. The printing substrate
is brought into contact with the cylinder with sufficient pressure so that it picks up the ink left in
the depressions on the cylinder. Gravure printing requires low viscosity inks (with solvents
containing EPCRA Section 313 chemicals such as toluene, xylene, and methyl ethyl ketone
(MEK)) that fill the tiny depressions on the plate. To dry the ink and drive off the solvents, the
paper travels through drying ovens. The solvent-laden air can be passed through carbon beds to
trap and condense the solvent. Most of the ink solvents, and associated EPCRA Section 313
chemicals and chemical categories, are recaptured using this process, and can either be recycled
for reuse, reused directly in printing processes, sold back to the ink vendor, or destroyed by
thermal or catalytic oxidation.
In the typical flexographic printing sequence, the substrate is fed into the press
from a roll. The image is printed as the substrate travels through a series of stations with each
station printing a single color. Each station is made up of four rollers where the first roller
transfers the ink from an ink pan to the second roller, the meter roller (also known as an Anilox
Roll). Most Anilox rollers are equipped with a doctor blade system which shears excess ink
from the surface of the roller, allowing for better control of ink transfer to the actual printing
plate. Chambered doctor blades, a relatively new development, consist of an enclosed chamber
that holds a controlled amount of ink and two doctor blades. Since the ink is within an enclosed
system, solvent evaporation (and thus air emissions) is minimized.
The meter roller meters the ink to a uniform thickness onto the third roller, the
plate cylinder. The substrate moves between the plate cylinder and the fourth roller. The plate is
attached to the third roller (the plate cylinder) and the fourth roller (the impression cylinder)
applies pressure to the plate cylinder, thereby forming the image on the substrate. The printed
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web proceeds through an overhead dryer section to dry the ink before the next station. Upon
completion of the printing of the last color, the web may then move through an overhead tunnel
dryer to remove all residual solvents. The ink tray used on larger flexographic presses is very
long, allowing for significant evaporation of ink solvents (which typically contain EPCRA
Section 313 chemicals such as toluene or xylene). Printers with the more narrow presses (for
tags, labels, and tapes) generally use water-based inks (which may contain ammonia; see
Appendix C for guidance in reporting ammonia if applicable) and ultraviolet (UV) coatings. As
in gravure coating operations, fast-drying low-viscosity inks are used. These inks lie on the
surface of nonabsorbent substrates and solidify when solvents evaporate or are cured, making
flexography ideal for printing on impervious materials such as polyethylene, cellophane, and
other plastics and metallized surfaces. The soft plates allow quality printing on compressible
surfaces such as cardboard packaging.
Letterpress, like flexography, uses a plate with a raised image on a metal or
plastic plate. The three types of letterpresses in use today are the platen, flat-bed, and rotary. On
the platen press, the raised plate is locked on a flat surface. The substrate is placed on another
flat surface and pressed against the inked plate. The flat-bed cylinder press prints as the substrate
passes around an impression cylinder on its way from the feed stack to the delivery stack. These
presses are often very slow as compared to lithographic, flexographic, or gravure presses. The
most popular letterpress is the web-fed rotary letterpress. Designed to print both sides of the web
simultaneously, these presses are used primarily for printing newspapers.
Digital printing, or electronic printing, is primarily xerographic and laser
printing. In both processes, an image is recorded on a drum in the form of an electrostatic
charge. The electrostatic charge is then transferred to a sheet of material, generally paper. Toner,
a conductive fine dry powder, is then spread on the paper and attracted to the electrostatically
charged areas of the paper. The paper is then heat treated to melt and affix the toner to the paper.
The screen printing process uses a porous polyester mesh as a plate, unlike the
impervious plates used in the other four printing processes, . The mesh is stretched tightly over a
frame, and a stencil, which defines the image to be printed, is applied to the mesh. A squeegee
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applies pressure to the ink thereby forcing the ink through the open areas of the screen. A thread
count and porosity of the mesh determine the amount of ink deposited onto the substrate below.
The primary EPCRA Section 313 chemicals used in screen printing include organic solvents
found in ink, such as toluene. The chemical composition of the ink used varies depending on the
substrate printed and the end product produced. The screen printing process uses five main
categories of inks: UV-curable, solvent-based, water-based for graphic applications, plastisols for
textile applications, and water-based for textile applications. Depending on the ink category, a
wide variety of EPCRA Section 313 chemicals and chemical categories could be present;
including but not limited to:
4.2.3.1
Step 1: Prepare Process Flow Diagram
Again, the specific operations and associated EPCRA Section 313 chemicals and
chemical categories used in the printing step can vary tremendously depending on the specific
printing techniques employed. However, the general process streams, sources, and types of
EPCRA Section 313 chemicals and chemical categories are expected to be similar for each
technology.
Fugitive Air
Paper
Inks, Coatings
Printing/
Cleanup
Vapor Recovery,
Air Pollution
Control Device
->-Point Air
Non-aqueous Wastes
(typically sent off site for
treatment, disposal, energy
^ recovery, or recycling)
Printed Products
Aqueous Wastes
(typically sent off site for
treatment, disposal, energy
recovery, recycling, or
discharged to POTWs)
Figure 4-6. Process Flow Diagram - Printing Step
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A site-specific process flow diagram should be prepared to help identify all potential sources and
types of chemical release and waste management activities. A typical flow diagram is presented
in Figure 4-6.
COMMON ERROR
Metals may be present in waste inks and solvents sent off-site for energy recovery, treatment, or disposal. In
cases where the waste is sent off-site for energy recovery, the metals should not be reported as "Off-Site Energy
Recovery", but may be reported as "Off-Site Disposal" or if the ink is to be recycled, then "Off-Site Recycling."
4.2.3.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and
Potential Sources of Chemical Release and Other Waste Management
Activities
The majority of release and other waste management activities from printing
operations occur during the cleanup process of the printing step. Sources of EPCRA Section 313
chemicals and chemical categories include ink solvents, cleanup solvents, fountain solution,
fountain solution additives, and solvents found in coatings.
4.2.3.3 Step 3: Identify Release and Other Waste Management Activity Types
Releases from printing and cleanup operations usually occur in the form of
fugitive air and stack air emissions. Other waste management activity types associated directly
with the cleanup process of the printing step include on-site treatment (through the use of air
pollution control devices such as thermal oxidizers); on-site recycling (condensers or carbon
adsorption/absorption where the solvent is recovered and recycled); and off-site treatment,
disposal, or energy recovery or recycle. As discussed earlier, on-site and off-site waste
management activity (including treatment, disposal, recycling, energy recovery, etc.,) quantities
should be reported in Part II, Sections 7 and 8 of the Form R as appropriate. Please refer back to
Section 4.1.3 of this manual for a detailed discussion of how these quantities should be reported.
Non-heatset lithography and letterpress printing operations rarely use air pollution
control devices, so air releases from these operations are expected to be in the form of fugitive
emissions. However, depending on location and ambient air quality attainment status, heatset
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lithographers and heatset letterpress operations may utilize air pollution control devices
(oxidizers or carbon adsorption systems) and virtually all gravure shops and wide web
flexographic printers using solvent based ink coating systems are expected to have control
devices (oxidizers). Although flexo printers using solvent inks are required to have oxidizers in
most states, this is not true for all situations. Water ink users and small emitters nay not be
required to have oxidizers. In those instances where control devices (or drying ovens vented to
the atmosphere without the use of control devices) are employed, air emissions will occur in the
form of both fugitive (uncontrolled) and stack releases from the control stack.
Note that any EPCRA Section 313 chemical or chemical category sent through an
air pollution control device is considered to have been treated for destruction if it is converted to
another chemical or it is HC1 or H2SO4 acid aerosols. The treatment efficiency of the unit should
be reported in Section 7A and the quantity treated for destruction should be reported in Section
8.6. Also, note that any EPCRA Section 313 chemical or chemical category sent through an air
pollution control device is considered to have been captured for further waste management
activities if it is not converted to another chemical or it is not HC1 or H2SO4 acid aerosols. The
capture efficiency of the unit should be reported in Section 7 A and the quantity captured should
be reported in Sections 6 and/or 8 depending on the final disposition of the chemical or chemical
category.
Typical release and other waste management activities and corresponding EPCRA
Section 313 chemicals are presented in Table 4-6.
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Table 4-6
Typical Release and Other Waste Management Activity Types
and Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Printing Operations
Type
Fugitive Air
Stack Air
Off-Site Transfer From Container
Residue (off-site treatment, disposal,
energy recovery, or recycle)
On-Site Treatment
Off-Site Transfer From Liquid Cleaning
Waste (off-site treatment, disposal,
energy recovery, or recycle)
Typical EPCRA Section 313 Chemicals
Toluene, xylene, certain glycol ethers, MEK,
methanol, ammonia
Toluene, xylene, certain glycol ethers, MEK,
ethanol, MIBK
Zinc, toluene, xylene, MEK, MIBK, barium,
cadmium, manganese
Toluene, xylene, certain glycol ethers, MEK,
methanol, ammonia
Zinc, toluene, xylene, MEK, MIBK, barium,
cadmium, manganese
While the release and other waste management activity types identified above are
typical across the printing industry, not every operation is expected to have all release and other
waste management activity types. Release and other waste management activity types expected
from different technologies are as follows:
Lithography (non-heatset), Letterpress, Screen Printing: Fugitive air, Container
Residue, Off-Site Transfer
Heatset Lithography, Gravure, Flexography: Fugitive Air, Stack Air, Container
Residue, On-Site Treatment, Off-Site Transfer
4.2.3.4 Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
Many of the solvents and other EPCRA Section 313 chemicals and chemical
categories processed and otherwise used in certain printing operations are very volatile. It may
be appropriate to assume that most or all of the chemical or chemical category will evaporate and
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be released to the air, either as a fugitive emission, or as a stack emission if vapors are isolated or
channeled through an air pollution control device. Do not forget to account for any potential
container residue before estimating the quantity that may be volatilized during processing or
otherwise use. Potential container residue quantities can be estimated as discussed in Section
Mass balance techniques may be the most appropriate method of estimating air
releases. The total amount released can be estimated based on purchasing records combined with
beginning and end-of-year facility inventory amounts. If air pollution control equipment is used,
stack test data (which may be obtained from compliance tests, performance tests, etc.) can be
used to determine control efficiencies. Alternatively, short term stack test data are often used to
develop site-specific emission factors in terms of pounds of pollutant per unit time, or pounds of
pollutant per pounds of chemical used. These emission factors may be used to estimate annual
emissions based on operating parameters such as the amount of chemical used over the course of
a year or the number of hours of operation. See Section 4. 1 .4.3 for a complete discussion of
emission factors, including references for identifying factors associated with the printing industry
and corresponding examples. Remember that air pollution control devises are considered on-site
treatment systems. Therefore, Part II, Section 7A and 8.6 of the 1999 Form R should be
completed as appropriate for any EPCRA Section 313 chemical or chemical category entering the
devise. Note that any EPCRA Section 313 chemical or chemical category sent through an air
pollution control device is considered to have been treated for destruction if it is converted to
another chemical or it is HC1 or H2SO4 acid aerosols. The treatment efficiency of the unit should
be reported in Section 7A and the quantity treated for destruction should be reported in Section
8.6. Also, note that any EPCRA Section 313 chemical or chemical category sent through an air
pollution control device is considered to have been captured for further waste management
activities if it is not converted to another chemical or it is not HC1 or H2SO4 acid aerosols. The
capture efficiency of the unit should be reported in Section 7 A and the quantity captured should
be reported in Sections 6 and/or 8, depending on the final disposition of the chemical or chemical
category. Section 4. 1 .3(h) presents an example for on-site treatment.
EPCRA Section 313 chemicals and chemical categories sent off site for disposal,
treatment, energy recovery, or recycling can be estimated based on analytical data from
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hazardous waste manifests. Alternatively, if the amount of an EPCRA Section 313 chemical or
chemical category released in the form of air emissions (and the amount destroyed and removed
through the use of on-site control equipment, if applicable) is known, a mass balance approach
can be used with this information to determine the amount of the chemical sent off site.
EXAMPLE - Printing Operations (Fugitive Releases of Ethylene GlycoH
Ethylene glycol is used in a sheetfed offset lithographic printing process as a component in fountain solution
concentrate and is also found in the fountain solution additive.
You must determine whether a threshold is exceeded for this chemical. For these applications, the ethylene glycol
is not intended to remain in a product sold in commerce and is considered otherwise used. It is subject to a
10,000 pound per year reporting threshold. The relevant data are the amount of fountain solution concentrate and
fountain solution additive used, and the concentration of ethylene glycol found in each material. In the calendar
year, 10,000 gallons of fountain solution concentrate containing 0.717 pounds of ethylene glycol per gallon and
3,000 gallons of fountain solution additive containing 1.2 pounds per gallon ethylene glycol are added to the
fountain solution. Each solution is purchased in 55-gallon drums. It is assumed that after emptying the drums
into the process equipment, they are left open in a designated, outdoor drum storage area and allowed to
completely dry.
Threshold determination:
Amount otherwise used = (fountain solution concentrate) x (ethylene glycol concentration
in fountain solution concentrate) + (fountain solution additive) x (ethylene glycol
concentration in fountain solution additive)
(10,000 gallons/year) x (0.717 Ib ethylene glycol/gallon) + (3,000 gallons/year) x
(1.2 Ib ethylene glycol/gallon)
7,170 Ib ethylene glycol/year + 3,600 Ib ethylene glycol/year
10,770 Ib ethylene glycol/year
Because the otherwise use reporting threshold is exceeded, you must estimate and report all release and other
waste management activities of ethylene glycol.
Fugitive Air Release:
In this example, it is assumed that all ethylene glycol used at the facility evaporates during the printing operations
(none remains with the product). Further, since the drums were allowed to completely dry before being disposed,
no ethylene glycol is expected in container residue. Therefore, it can be assumed that the entire quantity of this
EPCRA Section 313 chemical volatizes and is released as a fugitive air emission.
Fugitive air release = 10,770 Ib ethylene glycol
This quantity should be reported in Part II, Section 5.1 and added to the total quantity reported in Part II, Section
8.1. Note that if a vapor collection system and/or an air pollution control device were used, Part II, Sections 7A
and 8.6 (on-site treatment) should be completed as appropriate; and any release from the device after treatment
should be reported in Part II, Section 5.2 (stack releases) as appropriate.
4-50
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EXAMPLE - Printing Operations (reporting for toluene)
Toluene is used in a gravure coating and printing operation as both an ink solvent as well as a cleanup solvent. In
this example, mass balances and other engineering calculations are used to estimate the associated release and
other waste management quantities.
Toluene is a highly volatile chemical and all of the toluene contained in the ink is assumed to volatilize during the
printing process. The printing press is controlled by a thermal oxidizer with an estimated destruction efficiency of
95% (based on compliance test results). It is operated under negative pressure (relative to the room) so that all of
the toluene from the ink is assumed to be routed through the control device.
Based on your facility's purchase records and hazardous wastes manifests, you estimate that 80% of the toluene
used in cleanup operations volatilizes, and the remainder is collected as waste solvent or in shop towels (from
hand wiping operations). The collected waste solvent and towels are sent to an off-site incinerator for energy
recovery purposes. Further, you estimate that 30% of the volatilized portion of the cleaning solvent is entrained
in the airflow into the control device, and the remainder is emitted as fugitive air releases.
Threshold Determination:
Your first step is to determine if you have exceeded an activity threshold for toluene. In both of the applications
presented in this example, toluene is not intended to remain in a product sold into commerce and it is considered
otherwise used. It is subject to the 10,000 Ib/year reporting threshold.
The relevant data for this calculation are the amount of ink used, the concentration of toluene in the ink, the
amount of cleanup solvent used, and the concentration of toluene in the cleanup solvent. This information was
determined from purchase records and MSDSs as follows:
Total amount of ink used = 4,000 gallons/year
Toluene concentration in the ink = 0.94 (Ib/gal)
Total amount of cleanup solvent used = 1,000 gallons/year
Toluene density in the cleanup solvent = 7.22 (Ib/gal)
Total amount of toluene otherwise used = 4,000 (gallons/year) x 0.94 (Ib/gal) + 1,000
(gallons/year) x 7.22 (Ib/gal)
= 10,980 (Ib/year)
This amount exceeds the otherwise use reporting threshold so you must estimate and report all release and other
waste management activities for toluene.
Fugitive Air Emissions:
Your next step is to estimate the amount of toluene released as fugitive emissions. As in the previous example,
each solution is purchased in 55-gallon drums, and it is assumed that after emptying the drums into the process
equipment, they are left open in a designated, outdoor drum storage area and allowed to completely dry.
Fugitive emissions = Amount of toluene used in cleanup operations x 80% (amount of toluene
assumed to volatilize in cleanup) x 70% (amount of volatilized toluene assumed to be emitted
as fugitive air releases; 30% is captured and sent to the control device)
= 1,000 (gallons/year) x 7.22 (Ib toluene/gal) x 0.8 x 0.7
= 4,043 (Ib toluene/year)
4-51
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This value should be reported in Part II, Section 5.1 (fugitive or non-point air emissions) and added to the total
releases reported in Part II, Section 8.1 (quantity released).
Stack Releases:
Now you must determine stack releases from the air pollution control device:
Stack releases = (amount of toluene used in ink + amount of toluene used in cleanup operations
and vented to the control device) x (1 - destruction and removal efficiency)
= [ (4,000 (gal/yr) x (0.94 Ib/gal) + (1,000 gal/yr) x (7.22 Ib/gal) x (0.8) x (0.3) ]
x (1-0.95)
= 275 (Ib toluene/yr)
This value should be reported in Part II, Section 5.2 (stack or point air emissions) and added to the total releases
reported in Part II, Section 8.1 (quantity released).
On-Site Treatment:
The next step is to determine the amount of toluene treated on site in the control device:
On-site treatment = (amount of toluene used in ink + amount of toluene used in cleanup
operations and vented to the control device) x (destruction or removal efficiency)
= [ (4,000 (gal/yr) x (0.94 Ib/gal) + (1,000 gal/yr) x (7.22 Ib/gal) x (0.8) x (0.3) ]
x (0.95)
= 5,218 (Ib toluene/year)
This value should be reported in Part II, Section 8.6 (quantity treated on site). Additionally, Part II, Section 7A
should be reported, as appropriate.
Off-Site Energy Recovery:
Your final step is to determine the amount of toluene sent off site for energy recovery:
Off-site energy recovery = amount of toluene used in cleanup operations x 20% (amount
collected as waste solvent and in shop rags)
= (1,000 gal/yr) x (7.22 Ib toluene/gal) x (0.2)
= 1,444 (Ib toluene/year)
This value should be reported in Part II, Section 8.3 (quantity used for energy recovery off site).
Special Note: Air emissions rules have recently been promulgated for printing operations. As a
result of these initiatives, U.S. EPA and other interested parties have developed methodologies
for estimating air emissions from this industry. While it is beyond the scope of this document to
present an in-depth analysis of all the work done to date, Appendix A contains a listing of other
sources of information which you may find useful in estimating air emissions from printing
operations. The majority of these documents deal with criteria pollutant emissions, specifically
VOCs; however, the estimation approaches may also be applied to calculate air releases of
EPCRA Section 313 chemicals and chemical categories.
4-52
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4.2.4
Post-Press
Post-press processes include, but are not limited to cutting, folding, collating,
binding, perforating, drilling, embossing, foil stamping, laminating, trimming, and ink jetting.
InkJet inks can be solvent-based or water-based. Typical solvents for solvent-based inkjets
include methanol, MEK, and MIBK. Cold glues are used for binding in typically water-based
latex that becomes impervious to water when it dries. Hot melts glues can also be used and are
very common in perfect binding operations.
4.2.4.1
Step 1: Prepare Process Flow Diagram
You should prepare a site-specific process flow diagram to help identify all
potential sources and types of EPCRA Section 313 chemical and chemical category release and
other waste management activities. A typical flow diagram is presented in Figure 4-7.
Point Air
(air pollution
control devices)
Fugitive Air
Printed Materials,
glues, adhesives,
inkjets, laminates
Post-press
I
-*• Books, Magazines, etc.
Container Residue
(to off-site treatment,
disposal, energy recovery,
or recycling)
Waste Paper
(scrap; typically sent off site for
treatment, disposal, energy
recovery, or recycling)
Figure 4-7. Process Flow Diagram - Post-Press
4-53
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4.2.4.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and
Potential Sources of Chemical Release and Other Waste Management
Activities
The primary source of EPCRA Section 313 chemicals and chemical categories
used in post-press operations are air emissions and clean-up operations associated with binding
and other finishing processes. Empty containers containing residual chemicals are a second
potential source.
4.2.4.3
Step 3: Identify Release and Other Waste Management Activity Types
Release and other waste management activity types from this operation include
fugitive emissions from the evaporation of solvents found in binding and finishing materials.
Typical release and other waste management activities and typical EPCRA Section 313
chemicals and chemical categories from post-press operations are presented in Table 4-7.
Table 4-7
Typical Release and Other Waste Management Activity Types
and Associated EPCRA Section 313 Chemicals and Chemical Categories
Found in Post-Press Operations
Type
Fugitive Air
Off-Site Disposal (of waste paper)
Off-Site Transfer from Container Residue
(disposal, treatment, energy recovery, or
recycle)
Typical EPCRA Section 313 Chemicals
and Chemical Categories
n-Hexane, methanol, MEK, and MIBK
Zinc, barium, cadmium and associated
compounds
n-Hexane, methanol, 1,1,1-trichloroethane
4.2.4.4
Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
Fugitive emissions from evaporative losses can be estimated using engineering
calculations and mass balances based on purchasing records as discussed in previous sections.
4-54
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Container residue can be estimated as discussed in Section 4.1.3(g).
EXAMPLE - Post-Press Operations (fugitive air releases of methanoH
Your facility uses methanol in a variety of applications, including as an ink solvent (80-90%) and also as the
solvent component in adhesives (50-60%) used in the binding process. Based on purchase records, you
determined that you have exceeded the reporting threshold of 10,000 pounds for operations classified as
otherwise used. Therefore, you must report methanol release and other waste management quantities for all
processes occurring at your facility.
For the binding process, methanol is released as fugitive air emissions and should be reported in Part II, Section
5.1 (fugitive or non-point air emissions) and added to the total releases reported in Part II, Section 8.1 (quantity
released).
The relevant data used to estimate releases are the amount of adhesive used and the concentration of methanol in
the adhesive. A mass balance approach will yield the amount of methanol released as a result of these operations.
4-55
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Appendix A
EPCRA SECTION 313 GUIDANCE RESOURCES
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Appendix A
TRI GUIDANCE RESOURCES
A.1 EPCRA Section 313 RELATED REFERENCES
40 CFR 372. Toxic Chemical Release Reporting: Community Right-to-Know: Final Rule
See 53 FR 4500, February 16, 1988.
Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting
Year - See also Automated Toxic Chemical Release Inventory Reporting Software (ATRS) under
Section A.2, Internet Sites.
U.S. EPA publishes this document each year to provide current guidance for preparing the Form
R and Form A reports. This document contains the most up-to-date list of chemicals for which
reports are required. It includes a blank Form R and Form A and provides step-by-step
instructions for completing each report. It also has a list of U.S. EPA regional and state contacts
for EPCRA Section 313 reporting. The current version of this document should always be
consulted in preparing the EPCRA Section 313 report.
Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the Emergency
Planning and Community Right-to-Know Act (EPA 745-R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the
reporting requirements of EPCRA Section 313. The glossary was developed to aid in
determining whether a facility manufactures, processes, or uses a chemical subject to EPCRA
Section 313 reporting.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-
Know Act ffiPCRA^ and Section 112frt of the Clean Air Act (as amended^ (EPA 740-R-95-001)
List of chemicals covered by EPCRA Sections 302 and 313, CERCLA Hazardous Substances,
and CAA 112(r). The list contains the chemical name, CAS Registry Number, and reporting
requirement(s) to which the chemical is subject.
The Emergency Planning and Community Right-to-Know Act: EPCRA Section 313 Release
Reporting Requirements. August. 1995 (EPA 745/K-95-052)
This brochure alerts businesses to their reporting obligations under EPCRA Section 313 and
assists in determining whether their facility is required to report. The brochure contains U.S. EPA
Regional contacts, the list of EPCRA Section 313 toxic chemicals and a description of the
Standard Industrial Classification (SIC) codes subject to EPCRA Section 313.
EPCRA Section 313 Questions and Answers: 1998 Version. (EPA 745-B-97-004).
Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements: Questions and Answers (EPA 745-R-95-011)
This document assists federal facilities in complying with Executive Order 12856. This
information has been compiled by U.S. EPA from questions received from federal facilities. This
document is intended for the exclusive use of federal facilities in complying with Sections 302,
A-l
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303, 304, 311, 312, and 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA) of 1986 and the Pollution Prevention Act of 1990, as directed by the Executive Order.
Supplier Notification Requirements (EPA 560/4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification
requirements under EPCRA Section 313. The pamphlet explains the supplier notification
requirements, gives examples of situations which require notification, describes the trade secret
provision, and contains a sample notification.
Toxic Chemical Release Inventory - Data Quality Checks to Prevent Common Reporting Errors
on Form R/Form A (EPA 745-R-98-012)
This is a compilation of Notices of Data Change, Significant Error, Noncompliance, or Technical
Error. It provides a listing of common errors found on the Form R reports submitted to U.S.
EPA. It also provides a discussion of the types of errors which result in each of the above
Notices as well as a list of Notice of Technical Error codes and descriptions.
Trade Secrets Rule and Form
See 53 FR 28772, July 29, 1988. This rule implements the trade secrets provision of the EPCRA
(Section 322) and includes a copy of the trade secret substantiation form.
A.2 INFORMATION SOURCES
Most of the materials included as reference in this manual are available from the following
sources:
National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OH 45242-2419
(800)490-9198
Fax:(513)489-8695
Internet: http://www. epa.gov/ncepihom/index.html
Emergency Planning and Community Right-to-Know (EPCRA) Information Hotline
U.S. Environmental Protection Agency
(800) 424-9346 or (703) 412-9810 (for the Washington, D.C. metropolitan area)
TDD: (800)553-7672
Internet Sites
TRI homepage: http://www.epa.gov/tri
This site contains information on the Toxic Release Inventory and provides links
to a variety of data and documents related to the TRI program.
Automated Toxic Chemical Release Inventory Reporting Software (ATRS):
http://www. epa.gov/atrs
This site provides access to the automated EPCRA Section 313 reporting forms
for electronic submittal of required data to U.S. EPA.
A-2
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Air CHIEF CD-ROM
http://www.epa.gov/ttn/chief/airchief.html
This site provides information on the Air CHIEF CD-ROM, contents, ordering
information, system requirements, and sources for additional information.
Clearinghouse for Inventories and Emission Factors (CHIEF):
http://www. epa.gov/ttn/chief/
This site provides access to the latest information and tools for estimating
emissions of air pollutants and performing emission inventories.
Code of Federal Regulations, 40 CFR: http://www.epa.gov/epacfr40
This site was created by U.S. EPA to expand access to Title 40 - Environmental
Protections of the Code of Federal Regulations.
Compilation of Air Pollutant Emission Factors (AP-42):
http://www. epa.gov/ttn/chief/ap42etc. html
This site provides access to files containing guidance for estimating emissions
from specific sources and emission factors.
Federal Register Notice: http://www.epa.gov/EPA-TRI
This site provides access to all Federal Register notices related to the TRI program
from 1994 to current.
Material Safety Data Sheets (MSDSs):
http://msds.pdc. Cornell, edu/issearch/msdssrch.htm
A key word searchable database of 325,000 MSDSs.
TANKS: http://www. epa.gov/ttn/chief/tanks.html
This site contains information on TANKS, a DOS-based computer software
program that computes estimates of VOC emissions from fixed and floating-roof
storage tanks.
WATER8/CHEMDATS: http://www. epa.gov/ttn/chief/software. html#water8
WATERS is an analytical model for estimating compound-specific air emissions
from wastewater collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3
spreadsheet for estimating VOC emissions from TSDF processes.
A-3
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A.3 INDUSTRY-SPECIFIC TECHNICAL GUIDANCE DOCUMENTS
In 1988 and 1990, U.S. EPA developed a group of individual guidance documents for industries
or activities in industries who primarily manufacture, process, or otherwise use EPCRA
Section 313 chemicals. See list of industries/activities below. U.S. EPA is currently revising
some of these documents and preparing additional documents. The newer versions will be
available beginning in the Fall of 1998.
Chemical Distribution Facilities. January 1999 (EPA 745-B-99-005)
Coal Mining Facilities. January 1999 (EPA 745-B-99-002)
Coincidental Manufacture/Byproducts (EPA 745-B-00-014)
Electricity Generating Facilities. January 1999 (EPA 745-B-99-003)
RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities. January 1999 (EPA 745-B-99-
004)
Estimating Releases and Waste Treatment Efficiencies
Food Processors. September 1998 (EPA 745-R-98-011)
Formulation of Aqueous Solutions
Foundry Operations (EPA 745-B-00-016)
Leather Tanning and Finishing Processes. April 2000 (EPA 745-B-00-012)
Metal Mining Facilities. January 1999 (EPA 745-B-99-001)
Metal Working and Electroplating Operations. April 2000 (EPA 745-B-00-015)
Monofilament Fiber Manufacture (EPA 745-B-00-013)
Petroleum Bulk Storage Facilities. January 1999 (EPA 745-B-99-006)
Presswood & Laminated Wood Products Manufacturing
Printing Operations. April 2000 (EPA 745-B-00-005)
Pulp. Paper, and Paperboard Production (EPA 745-B-00-010)
Rubber Production and Compounding. April 2000 (EPA 745-B-00-017)
Semiconductor Manufacture (EPA 745-R-99-007)
A-4
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Smelting Operations (EPA 745-B-00-009)
Spray Application and Electrodeposition of Organic Coatings. December 1998 (EPA 745-B-99-
014)
Textile Processing Industry. April 2000 (EPA 745-B-00-008)
Welding Operations (EPA 745-B-00-011)
Wood Preserving (EPA 745-B-00-007)
U.S. EPA, Office of Compliance, published a series of documents in 1995 called Sector
Notebooks. These documents provide information of general interest regarding environmental
issues associated with specific industrial sectors. The Document Control Numbers (DCN) range
from EPA/310-R-95-001 through EPA/310-R-95-018.
A.4 CHEMICAL-SPECIFIC GUIDANCE DOCUMENTS
U.S. EPA has also developed a group of guidance documents specific to individual chemicals
and chemical categories. These are presented below.
"Air Pollution Engineering Guide for the Graphic Arts Industry," May 1993, Graphic Arts
Technical Foundation.
Alternative Control Techniques (ACT) Document Offset Lithographic Printing. June 1994, U.S.
EPA.
Draft CTG Control of Volatile Organic Compound Emissions from Offset Lithographic Printing.
September 1993, U.S. EPA.
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting Aqueous Ammonia. July 1995 (EPA 745-R-95-012)
Emergency Planning and Community Right-to-Know EPCRA Section 313: List of Toxic
Chemicals within the Chlorophenols Category. November 1995 (EPA 745-B-95-004)
Estimating Releases for Mineral Acid Discharges Using pH Measurements. U.S. Environmental
Protection Agency. June 1991.
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size). November 1997 (EPA-745-R-97-007)
Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and
Guidance for Reporting. May 1995 (EPA 745-R-95-006)
Toxic Release Inventory List of Toxic Chemicals within the Nicotine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-004)
A-5
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Toxic Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category
and Guidance for Reporting. February 1995 (EPA 745-R-95-001)
Toxic Release Inventory List of Toxic of Chemicals within the Polycyclic Aromatic Compounds
Category. February 1995 (EPA 745-R-95-003)
Toxic Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-005)
Toxic Release Inventory List of Toxic of Chemicals within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting. May, 1996 (EPA 745-R-96-004)
Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid
Category. November 1994, EPA 745-B-94-003.
Toxics Release Inventory - Copper Phthalocyanine Compounds Excluded for the Reporting
Requirements Under the Copper Compounds Category on the EPCRA Section 313 List. April
1995, EPA 745-R-95-007.
Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category. November 1994,
EPA 745-B-94-004.
A.5 OTHER USEFUL REFERENCES
Air Pollution Engineering Guide for the Graphic Arts Industry. May 1993. Graphic Arts
Technical Foundation.
Alternative Control Techniques (ACT) Document Offset Lithographic Printing. June 1994. U.S.
EPA
Burgess, W.A. Recognition of Health Hazards in Industry. Harvard School of Public Health.
Boston, Massachusetts, John-Wiley & Sons.
CRC Handbook of Chemistry and Physics. Latest Edition, Robert C. Weast, Editor, CRC Press,
Inc., Florida.
Draft CTG Control of Volatile Organic Compound Emissions from Offset Lithographic Printing.
September 1993. U.S. EPA.
Locating and Estimating Air Emissions from Various Sources. Available from: National
Technical Information Services (NTIS), (703) 487-4650.
The Merck Index. Latest Edition, Merck & Co., Inc., New Jersey.
Perry, R.H. and C.H. Chilton, Chemical Engineer's Handbook. Latest Edition, McGraw-Hill
Book Company, New York.
A-6
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Sax, N.I. and R. J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van
Nostrand Reinhold Company, New York.
Toxics Release Inventory - Copper Phthalocyanide Compounds Excluded for the Reporting
Requirements Under the Copper Compounds Category on the EPCRA Section 313 List. April
1995. EPA 745-R-95-007.
Toxics Release Inventory - List of Toxic Chemicals Within Glycol Ethers Category. May 1995.
U.S. EPA.
A-7
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Appendix B
BASIC CALCULATION TECHNIQUES
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Appendix B
BASIC CALCULATION TECHNIQUES
This section will provide the basic techniques needed to use specific types of data or engineering
calculations. Examples are provided for:
(1) Stack monitoring data;
(2) Industrial hygiene data;
(3) Raoult's Law;
(4) Air emission factors;
(5) RCRA hazardous waste analysis data;
(6) NPDES monitoring data.
(1) Stack Monitoring Data
The following is an example of a release calculation using monitoring data.
Example: Stack monitoring data are available for a paint booth. The measured
average concentration of toluene is 0.1 ppmv (dry gas basis). The moisture
content in the stack is typically 10%, and stack conditions are maintained at 80°C
and atmospheric pressure. The stack gas velocity is 8 m/s. The diameter of the
stack is 0.3 m. Calculate the point air release of toluene.
Step 1. Calculate volumetric flow of stack gas stream.
Volumetric flow = (gas velocity) x [(IT) x (internal stack diameter)2/4)]
Volumetric flow = (8.0 m/s) x [(71) x (0.3 m)2/4] = 0.6 m3/s
Step 2. Correct for moisture content in stack gas stream.
Stack exhausts may contain large amounts of water vapor. The concentration of
the chemical in the exhaust is often presented on a dry basis. For an accurate
release rate, correct the vent gas flow rate for the moisture content by multiplying
by the term (1 - fraction water vapor). The dry gas rate can then by multiplied by
the chemical concentration.
(Note: If the toluene concentration is on a wet gas basis, no correction is necessary
for moisture content.)
B-l
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Dry volumetric flow = (Volumetric flow) x (1-fraction water vapor)
Dry volumetric flow = (0.6 m3/s) x (1-0.10) = 0.5 m3/s
Step 3. Convert ppmv to mg/m3.
• ppmv is defined as one part of a chemical in 106 parts of gas (1.0 m3/106
m3).
• Use the molar volume of a gas, corrected for stack temperature and
pressure conditions, calculated by the ideal gas law (PV = nRT). Note that
the molar volume of an ideal gas at 237 K and 1 atm is 22.4 L/mole.
• Molecular weight of toluene (MW) = 92.14 g/mole.
R = the Ideal Gas Constant (0.082057 L - atm per mole-Kelvin)
To calculate the molar volume of stack gas, use the ideal gas equation.
™ i i V RT
Molar volume = — =
For the example, the stack conditions are 80° C (353 K) and atmospheric pressure
(1 atm).
Molar volume = 0.082057 L atm x (353 K)/(latm)
I mole-Kj
= 29.0 L/mole
The conversion of ppmv to mg/m3 can now be calculated.
—- = (concentration of chemical, ppmv) x x (MW)
m31 ^ molar volume of gas)
B-2
-------
( 1,000 mg\ n - /3
— ^ = 0.3 mg/m3
I 1 § )
Using the example, the concentration of toluene is calculated as follows:
0.1 m3] x ( mole } x [92.14 g^l x [ L ^
106 m3 I 29.0 L! I mole J 1(T3 m3.
Step 4. Calculate air releases.
Air releases are calculated as follows:
Air Release=(volumetric flow, m3/s) x (concentration, mg/m3) x (operating time, s/yr)
The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year.
/-v *• *• I o hr | f . day ) f .~ week | ~ non , ,
Operating time = 8 x 5 y— x 52 = 2,080 hr/yr
^ dayj ^ weekj ^ yr )
A r> i m« 3/\ mi / ^ i 3,600s) f 2,080 hr) [ Ib
Air Release = (0.5 m /s) x (0.3 mg/m ) x I _? 1 x I -^ 1 x '
hr j ^ yr ) ( 454 gj ^ 1,000 mg
= 2.5 Ib/yr of toluene
It is important to note that this calculation assumes the measured emissions are
representative of actual emissions at all times; however, this is not always the case. Ideally, a
continuous emissions monitor provides the most representative data.
Also note that monitoring and stack data may have units that are different than
those used in the example. Modify conversion factors and constants to reflect your data when
calculating air releases.
(2) Industrial Hygiene Data
The following is an example of a release calculation using industrial hygiene data.
Example: Occupational industrial hygiene data shows that workers are exposed
to an average of 0.1 ppmv benzene (wet gas basis). The density of benzene vapor
is 0.2 lb/ft3. The ventilation system exhausts 20,000 acfm of room air at 70°F.
The plant operates 24 hours per day, 330 days per year.
The benzene concentration is on a wet gas basis, therefore a moisture correction
of the ventilation flow rate is not necessary. The industrial hygiene data is
collected at the same ambient conditions as the ventilation system, therefore no
-------
adjustment for temperature or pressure needs to be performed. A conservative
estimation of benzene fugitive releases could be calculated as follows:
Air Release = (ventilation flow rate, ft3/min) x (operating time, rnin/yr) x
(concentration of chemical, ppmv) x (vapor density of chemical, lb/ft3)
Benzene releases per year would be calculated as follows:
20,000 ft3 [60 mini I 24 hr) f 330 day) 0.1 ft3 benzene 0.2 Ib
x x x x x
min ) { hr ) { day ) ( yr ) ( 1Q6 ft3 air } ( ft3
= 190 Ib/yr of benzene
(3) Raoult's Law
The following is an example of a release calculation using Raoult's Law. Raoult's
Law states that the partial pressure of a compound in the vapor phase over a solution may be
estimated by multiplying its mole fraction in the liquid solution by the vapor pressure of the pure
chemical.
PA ~ XAiLP° - XA]GPT
where:
P° = Vapor pressure of pure liquid chemical A;
XAL = Mole fraction of chemical A in solution;
XA,G = Mole fraction of chemical A in the gas phase;
PA = Partial pressure of chemical A in the gas phase; and
PT = Total pressure.
Example: A wash tank holds a solution containing 10% by weight of
o-xylene (A) and 90% by weight of toluene (B). The tank is vented to the atmosphere; the
process vent flow rate is estimated as 100 acfm (2.83m3/min) based on a minimum fresh air
ventilation rate. The molecular weight of o-xylene is 106.17 g/mole and toluene is 92.14 g/mole.
The vapor pressure of o-xylene is 10 mm of Hg (0.19 psia). The total pressure of the system is
14.7 psia (atmospheric conditions). The process tank is in service 250 days/yr. Calculate the air
release of o-xylene.
Step 1: Calculate the mole fraction of o-xylene in the liquid solution.
B-4
-------
X
A,L
wt fraction A
MWA
wt fraction A wt fraction B
MW,
MWt
Where:
XA,L
MW
wt fraction
Mole fraction of chemical A in liquid solution;
Molecular weight of chemical, g/mole; and
Weight fraction of chemical in material.
X
A,L
0.1
106.17
0.1 0.9
+
106.17 92.14
XA,L = °-09
Step 2: Calculate the mole fraction of o-xylene in the gas phase.
X
A,G
where:
X
X
P°
PT
A,G
A,L
Mole fraction of chemical A in gas phase;
Mole fraction of chemical A in liquid solution;
Vapor pressure of pure liquid chemical A, psia; and
Total pressure of system, psia.
XAG = [0.09]
VA,G
0.19 psia
14.7 psia
= 0.001
Step 3: Calculate releases using Raoult's Law.
B-5
-------
Emissions = (X, r) x (APR) x (t) x (MWA) x _L
V A,G' V J \ > \ A' A/rr j
MV
where:
Emissions = Air release of pollutant A, g-A/yr;
XA G = Mole fraction of chemical A in gas phase;
APR = Air flow rate of room, m3/min;
t = Operating time of wash tank, min/yr;
MW = Molecular weight of chemical, g/g-mole; and
MV = Gas molar volume (22.4 L/mole at standard temperature
and pressure).
If conditions vary from standard temperature and pressure the gas molar volume
can be calculated using the ideal gas law and tank conditions as presented in
Example 1.
Emissions = (0.001) x
2.83m3l ( 250 day) ( 24 br\ ( 60 min) ( mole ) ( 106.17 g] I L
X
min ) ( yr ) ( day ) ( hr } (22AL) { mole } ( 10^3m3,
= 4.8 x 106g/yr
The emission of o-xylene is calculated as shown below.
Emissions = (4.8 x 106 g/yr) x —°_ = 10,570 Ib/yr of o-xylene
I 454 gj
Air releases for toluene can be calculated in a similar manner.
(4) Air Emission Factor
The following is an example of a release calculation using air emission factors.
Example: An industrial boiler uses 300 gallons per hour of No. 2 fuel oil. The
boiler operates 2,000 hours per year. Calculate emissions of formaldehyde using
the AP-42 emission factors.
AE = (EF) x (AU) x (QT)
B-6
-------
where:
AE = Annual emissions of pollutant, Ib/yr
EF = Emission factor of pollutant, lb/103 gallon of fuel. EF for
formaldehyde for an industrial boiler burning No. 2 fuel oil is
0.035 to 0.061 lb/103 gallons.
AU = Quantity of fuel used, gal/yr.
OT = Operating time, hr/yr.
Using an emission factor of 0.061 pounds of formaldehyde per gallon of fuel, the
air releases are calculated as follows:
AE =
0.061 Ib
103 gal
2,000
yr
= 36.6 Ib/yr of formaldehyde
(5) RCRA Waste Analysis
The following is an example of a calculation using RCRA waste analysis data.
Example: Spent paint wastes were disposed at an off-site waste treatment
facility. The quantity of paint waste shipped was five 55-gallon drums per year.
Analysis of the waste showed 5% cadmium by weight. Estimating the density of
the paint waste to be 9.5 Ib/gallon, the amount of cadmium to off-site disposal is
calculated as follows:
Amount of cadmium = (amount of paint waste disposed, gal/yr) x (concentration of cadmium, Ib/lb) x
(density of paint waste, Ib/gal)
f 55 gal] ( 9.5 lb] ( 51b Cd } 101 ,,, , , .
x §_ x x = 131 Ib/yr of cadmium
^ drum ) V gal J ^ lOOlb waste,)
(6) NPDES Data
The following is an example of a calculation using NPDES data.
NPDES permits require periodic monitoring of the effluent stream. In this
example, quarterly samples were taken to be analyzed for silver content. Each sample was an
hourly, flowrate-based composite taken for one day to be representative of the discharge for that
day. The total effluent volume for that day was also recorded. The following data were collected
on each sample day.
B-7
-------
Yearly Quarter Discharge Flow Rate
Sample Number (IP6 gal/dav) Total Silver (LJQ/L)
1 0.5 10
2 0.6 10
3 0.4 6
4 0.2 <3
To calculate the amount of silver in pounds discharged on each sample day, the
concentration of silver in the discharge is multiplied by the discharge flow rate for that day, as
shown below for the first quarter sample.
Amount of silver = (daily flow rate) x (silver concentration)
r. „ [ lOugl lg I lib 1 f 3.785L] 0.5 x io6gal
First Quarter: —^& x &_ x x &
I L ) lOVg 1454§J I gal H day
= 0.041b/day of silver
The amount of silver discharged during each of the other three monitoring events
was similarly determined to be:
0.05 Ib/day; 0.02 Ib/day, and 0.005 Ib/day.
For the last data point the concentration of silver was reported by the laboratory to
be less than the detection limit of 3 |ig/L. For this calculation the detection limit was used to
calculate the daily discharge, a conservative assumption.
The average daily discharge was calculated to be:
Ib/day = 0.03 Ib/day
0.04+ 0.05+0.02 + 0.005'!
4 J
The plant operates 350 days/year (plant shuts down for two weeks in July).
The estimated annual discharge of silver is calculated as follows:
Annual discharge = (350 day/yr) (0.03 Ib/day) = 10.5 Ib of silver/yr
B-S
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Appendix C
GUIDANCE FOR REPORTING AQUEOUS AMMONIA
-------
United States Environmental
Protect! on_Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
July 1995
EPA745-R-95-012
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
EPCRA Section 313
Guidance for Reporting Aqueous Ammonia
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using
listed toxic chemicals to report their environmental releases of such chemicals annually.
Beginning with the 1991 reporting year, such facilities also must report pollution prevention and
recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42
U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals
that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section
313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth
criteria for these actions.
CONTENTS
Section 1. Introduction C-2
1.1 Who Must Report C-2
1.2 Thresholds C-2
1.3 Chemical Sources of Aqueous Ammonia C-3
1.4 De Minimis Concentrations C-3
Section 2. Guidance for Reporting Aqueous Ammonia C-4
2.1 Determining Threshold and Release Quantities for Ammonia C-4
2.2 Chemical Sources of Aqueous Ammonia C-5
2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous
Ammonia
in Water C-5
2.2.2 Reporting of Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate) C-6
2.2.3 Reporting of Aqueous Ammonia Generated from the Dissociation
of Ammonium Nitrate C-7
Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia . . . C-10
C-l
-------
Section 1. Introduction
On June 30, 1995 EPA finalized four actions in response to a petition received in
1989 to delete ammonium sulfate (solution) from the list of toxic chemicals subject to reporting
under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA), 42 U.S.C. 11001. The four actions taken are summarized as follows: (1)
deleted ammonium sulfate (solution) from the EPCRA Section 313 list of toxic chemicals, (2)
required that threshold and release determinations for aqueous ammonia be based on 10 percent
of the total aqueous ammonia present in aqueous solutions of ammonia, (3) modified the
ammonia listing by adding the following qualifier: ammonia (includes anhydrous ammonia and
aqueous ammonia from water dissociable ammonium salts and other sources; 10 percent of total
aqueous ammonia is reportable under this listing), and (4) deleted ammonium nitrate (solution)
as a separately listed chemical on the EPCRA Section 313 list of toxic chemicals. All actions are
effective for the 1994 reporting year for reports due July 1, 1995, with the exception of the
deletion of ammonium nitrate (solution) as a separately listed chemical, which is effective for the
1995 reporting year for reports due July 1, 1996. At the time that these actions were finalized,
EPA indicated that the Agency would develop, as appropriate, interpretations and guidance that
the Agency determines are necessary to facilitate accurate reporting for aqueous ammonia. This
document constitutes such guidance for reporting under the ammonia listing.
Section 1.1 Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA Section
313, if it meets all three of the following criteria:
• It conducts manufacturing operations (is included in Standard Industrial
Classification (SIC) codes 20 through 39); and
• It has 10 or more full-time employees (or the equivalent 20,000 hours per
year); and
• It manufactures, imports, processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than
the "threshold" quantities specified below.
Section 1.2 Thresholds
Thresholds are specified amounts of toxic chemicals used during the calendar year
that trigger reporting requirements.
If a facility manufactures or imports any of the listed toxic chemicals, the
threshold quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
C-2
-------
If a facility processes any of the listed toxic chemicals, the threshold quantity will
be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility otherwise uses any of the listed toxic chemicals (without incorporating
it into any product or producing it at the facility), the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
Section 1.3 Chemical Sources of Aqueous Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia or
aqueous ammonia, they must report under the ammonia listing. EPA is providing a table of
Chemical Abstract Service (CAS) numbers and chemical names to aid the regulated community
in determining whether they need to report under the ammonia listing for aqueous ammonia.
This table includes a list of water dissociable ammonium salts which, when placed in water, are a
source of aqueous ammonia. The table contains only commonly used ammonium salts and
therefore is not exhaustive. If a facility manufactures, processes, or otherwise uses aqueous
ammonia, regardless of its source, it must report under the ammonia listing, even if the source of
the aqueous ammonia is not listed in the table provided in this document.
Section 1.4 DeMinimis Concentrations
The ammonia listing is subject to the one percent de minimis concentration. Thus,
solutions containing aqueous ammonia at a concentration in excess of one percent of the 10
percent reportable under this listing should be factored into threshold and release
determinations.
C-2
-------
Section 2. Guidance for Reporting Aqueous Ammonia
Note: for the purposes of reporting under the ammonia listing for aqueous
ammonia, water dissociable ammonium salts means that the ammonium ion dissociates from its
counterion when in solution.
Section 2.1 Determining Threshold and Release Quantities for Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia, the
quantity applied towards threshold determinations for the ammonia listing is the total quantity of
the anhydrous ammonia manufactured, processed, or otherwise used. The quantity reported
when calculating the amount of ammonia that is released, transferred, or otherwise managed is
the total quantity of anhydrous ammonia released or transferred.
If the facility manufactures, processes, or otherwise uses anhydrous ammonia in
quantities that exceed the appropriate threshold and subsequently dissolves some or all of the
anhydrous ammonia in water, then the following applies: 1) threshold determinations are based
on 100 percent of the anhydrous ammonia (simply 10 percent of aqueous ammonia); 2) release,
transfer, and other waste management quantities for the aqueous ammonia are calculated as 10
percent of total ammonia; 3) release, transfer, and other waste management quantities for the
anhydrous ammonia are calculated as 100 percent of the anhydrous ammonia.
If a facility manufactures, processes, or otherwise uses aqueous ammonia, the
quantity applied toward threshold determinations for the ammonia listing is 10 percent of the
total quantity of the aqueous ammonia manufactured, processed, or otherwise used. The quantity
reported when calculating the amount of ammonia that is released, transferred, or otherwise
managed is 10 percent of the total quantity of aqueous ammonia released or transferred.
If a facility dissolves a water dissociable ammonium salt in water that facility has
manufactured aqueous ammonia and 10 percent of the total aqueous ammonia manufactured
from these salts is to be included in manufacturing threshold determinations under the ammonia
listing.
If aqueous ammonia from water dissociable ammonium salts is processed or
otherwise used, then 10 percent of the total aqueous ammonia is to be included in all processing
and otherwise use threshold determinations under the ammonia listing.
Example 1: In a calendar year, a facility places 25,000 Ibs of anhydrous ammonia in water for
processing and processes 25,000 Ibs of aqueous ammonia from an ammonium salt. The
facility must include all of the 25,000 Ibs of anhydrous ammonia in the determination of the
processing threshold, but only 10 percent (or 2,500 Ibs) of the aqueous ammonia from the
ammonium salt in the processing threshold determination.
Total aqueous ammonia is the sum of the two forms of ammonia (un-ionized,
NH3, and ionized, NH4+) present in aqueous solutions. A precise calculation of the weight of
total aqueous ammonia would require determining the ratio of the two forms of ammonia present
C-4
-------
using the pH and temperature of the solution. The weight of total aqueous ammonia can be more
easily calculated by assuming that aqueous ammonia is comprised entirely of the NH4+ form or
the NH3 form. For the purpose of determining threshold and release quantities under EPCRA
Section 313, EPA recommends that total aqueous ammonia be calculated in terms of NH3
equivalents (i.e., for determining weights, assume total ammonia is comprised entirely of the
NH3 form). This method is simpler than using pH and temperature data to determine the ratio of
the two forms present and is consistent with the presentation of total ammonia toxicity in a
separate EPA document, Ambient Water Quality Criteria for Ammonia (EPA document #440/5-
85-001, January 1985).
Section 2.2 Chemical Sources of Aqueous Ammonia
Aqueous ammonia may be generated in solution from a variety of sources that
include the release of anhydrous ammonia to water and the dissociation of ammonium salts in
water. Water dissociable ammonium salts are not reportable in their entirety under the ammonia
listing; these salts are reportable to the extent that they dissociate in water, and only 10 percent of
the total aqueous ammonia that results when these salts dissociate is reportable. If these salts are
not placed in water, they are not reportable.
If these salts are purchased neat or as solids by a facility, then placed in water by
that facility, the facility is manufacturing aqueous ammonia.
Section 2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous Ammonia in
Water
If the source of aqueous ammonia is anhydrous ammonia in water, total aqueous
ammonia (calculated in terms of NH3 equivalents) is equal to the quantity of anhydrous ammonia
manufactured, processed, or otherwise used. A hypothetical scenario demonstrating the
calculations involved in reporting aqueous ammonia generated from anhydrous ammonia in
water is given in Example 2.
Example 2: In a calendar year, a facility uses 30,000 pounds of anhydrous ammonia to
neutralize acids in a wastewater stream. The neutralized waste stream (containing aqueous
ammonia from dissociated ammonium salts) is then transferred to a POTW. The quantity to
be applied toward threshold determinations is the total quantity of anhydrous ammonia used in
the waste stream neutralization, or 30,000 pounds. The quantity of ammonia reported as
transferred is 10 percent of the total quantity of aqueous ammonia transferred, or 3,000
pounds.
Section 2.2.2 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate)
If the source of aqueous ammonia is the dissociation of ammonium salts in water,
total aqueous ammonia (calculated in terms of NH3 equivalents) is calculated from the weight
percent (wt%) of the NH3 equivalents of the ammonium salt. The NH3 equivalent wt% of an
ammonium salt is calculated using the following equation:
C-5
-------
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium salt) x 100
If the source of aqueous ammonia is a monovalent compound (such as ammonium chloride,
NH4C1, ammonium nitrate, NH4NO3, or ammonium bicarbonate (NH4HCO3), the NH3 equivalent
weight is equal to the MW of NH3 (17.03 kg/kmol). If divalent compounds are involved (such as
ammonium carbonate, (NH4)2CO3), then the NH3 equivalent weight is equal to the MW of NH3
multiplied by two. Similarly, if trivalent compound are involved, then the NH3 equivalent weight
is equal to the MW of NH3 multiplied by three.
Example 3:
The NH3 equivalent wt% of ammonium chloride is calculated as follows:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = (17.03)7(53.49) x 100
NH3 equivalent wt% = 31.84%
The NH3 equivalent wt% of ammonium carbonate is calculated as follows:
NH3 equivalent wt% = 2 x (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = 2 x (17.03)7(96.09) x 100
NH3 equivalent wt% = 35.45%
To aid the regulated community in reporting under the ammonia listing for
aqueous ammonia, the table of chemical sources of aqueous ammonium provided in Section 3 of
this document includes, in addition to CAS number, chemical name, and molecular weight, the
NH3 equivalent wt% of the commonly used, water dissociable ammonium salts listed in this
table.
Example 4: In a calendar year, a facility uses 100,000 pounds of ammonium chloride, NH4C1,
in aqueous solution which is released to wastewater streams, then transferred to a POTW. The
NH3 equivalent wt% of ammonium chloride is 31.84% (taken from Table 1 in Section 3 below
or calculated as in Example 3 above). The total quantity of aqueous ammonia present in
solution is 31.84% of the 100,000 pounds of ammonia chloride used, or 31,840 pounds. The
quantity applied towards threshold determinations for the ammonia listing is 10 percent of the
total quantity of aqueous ammonia present in solution, or 3,184 pounds. The quantity of
ammonia reported as released or transferred is 10 percent of the total quantity of aqueous
ammonia released or transferred, or 3,184 pounds.
C-6
-------
Example 5: In a calendar year, a facility uses 500,000 pounds of ammonium carbonate,
(NH4)2CO3, and 400,000 pounds of ammonium bicarbonate, NH4HCO3, in aqueous solution
which is released to wastewater streams, then transferred to a POTW. The NH3 equivalent
wt% of ammonium carbonate is 35.45%, and the NH3 equivalent wt% of ammonium
bicarbonate is 21.54% (taken from Table 1 in Section 3 below or calculated as in Example 3
above). The quantity of aqueous ammonia present in solution from ammonium carbonate is
35.45% of the 500,000 pounds of ammonia carbonate used, or 177,250 pounds. The quantity
of aqueous ammonia present in solution from ammonium bicarbonate is 21.54% of the
400,000 pounds of ammonia bicarbonate used or 86,160 pounds. The total quantity of
aqueous ammonia present in solution is 263,410 pounds. The quantity applied towards
threshold determinations for the ammonia listing is 10 percent of the total quantity of aqueous
ammonia present in solution, or 26,341 pounds. The quantity of ammonia reported as released
or transferred is 10 percent of the total quantity of aqueous ammonia released or transferred, or
26,341 pounds.
Section 2.2.3 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Nitrate
Some sources of aqueous ammonia may be reportable under other EPCRA
Section 313 category listings. Ammonium nitrate (solution) is relevant to reporting under the
ammonia listing to the extent that 10 percent of the total aqueous ammonia that results when
ammonium nitrate dissociates is reported when determining thresholds and calculating releases.
However, under the nitrate compound category listing, ammonium nitrate (and other mixed salts
containing ammonium and nitrate) must be reported in its entirety. When reporting ammonium
nitrate under this category listing, the total nitrate compound, including both the nitrate ion
portion and the ammonium counterion, is included when determining threshold quantities.
However, only the nitrate ion portion is included when determining the amount of ammonium
nitrate that is released, transferred, or otherwise managed in wastes. The calculations involved in
determining threshold and release quantities for reporting under the nitrate compound category
listing are described in a separate directive, List of Toxic Chemicals within the Water Dissociable
Nitrate Compounds Category and Guidance for Reporting (EPA document #745-R-95-002,
February 1995). Note: reporting ammonium nitrate under the ammonia listing and nitrate
compounds category listing is effective for the 1995 reporting year for reports due July 1, 1996.
C-7
-------
Example 6: In a calendar year, a facility uses 1,250,000 pounds of ammonium nitrate,
NH4NO3, in aqueous solution which is released to wastewater streams, then transferred to a
POTW. The NH3 equivalent wt% of ammonium nitrate is 21.28% (taken from Table 1 in
Section 3 below or calculated as in Example 3 above). The total quantity of aqueous ammonia
present in solution is 21.28% of the 1,250,000 pounds of ammonia chloride used, or 266,000
pounds. The quantity applied towards threshold determinations for the ammonia listing is 10
percent of the total quantity of aqueous ammonia present in solution, or 26,600 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 26,600 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February, 1995).
-------
Example 7: In a calendar year, a facility transfers 100,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid is neutralized with anhydrous ammonia, and
treatment efficiency is 95 percent (the nitrate compound formed as a result of the treatment is
ammonium nitrate, NH4NO3). The neutralized waste stream (containing aqueous ammonia
from dissociated ammonium nitrate) is then transferred to a POTW. The quantity of nitric acid
neutralized is 95 percent of 100,000 pounds or 95,000 pounds. The quantity of nitric acid
neutralized is converted first to kilograms then to kilomoles using the following equations:
Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)
Substituting the appropriate values into the above equations yields:
Kilograms HNO3 neutralized = 95,000 Ibs x 0.4536 kg/lb = 43,092 kg
Kilomoles HNO3 neutralized = 43,092 kg H- 63.01 kg/kmol = 683.9 kmol
The quantity of anhydrous ammonia used in kilomoles in the acid neutralization and the
quantity of ammonium nitrate generated in kilomoles from the neutralization are equal to the
quantity of nitric acid neutralized (683.9 kmol). The quantity of anhydrous ammonia used in
kilograms and pounds in the acid neutralization is calculated as follows:
Kilograms NH3 used = (kmol NH3) x (MW of NH3 in kg/kmol)
Pounds NH3 used = (kg NH3) x (2.205 Ibs/kg)
Substituting the appropriate values into the above equation yields:
Kilograms NH3 used = (683.9 kmol) x (17.03 kg/kmol) = 11,647 kmol
Pounds NH3 used = (11,647 NH3) x (2,205 Ibs/kg) = 25,682 pounds
The quantity reported applied towards threshold determinations for the ammonia listing is the
total quantity of anhydrous ammonia used in the acid neutralization, or 25,682 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 2,568 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February 1995).
C-9
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Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report under the ammonia listing
for aqueous ammonia. If a facility manufactures, processes, or otherwise uses, in aqueous
solution, a chemical which is listed below, they must report 10 percent of the total aqueous
ammonia that is the result of the dissociation of this chemical. However, this list is not
exhaustive. If a facility manufactures, processes, or otherwise uses, in aqueous solution, a water
dissociable ammonium compound, they must report 10 percent of the total aqueous ammonia that
is the result of the dissociation of the compound, even if the compound does not appear in the
following table.
Table C-l
Listing by CAS Number and Molecular Weight of
Some Chemical Sources of Aqueous Ammonia
Chemical Name
Ammonium acetate
Ammonium aluminum sulfate
(Ammonium aluminum disulfate)
Ammonium antimony fluoride
(Diammonium pentafluoroantimonate)
Ammonium arsenate
(Ammonium arsenate, hydrogen)
(Ammonium arsenate, dihydrogen)
Ammonium arsenate
(Diammonium arsenate)
(Diammonium arsenate, hydrogen)
(Diammonium arsenate, monohydrogen)
Ammonium arsenite
Ammonium azide
Ammonium benzenesulfonate
Ammonium benzoate
Ammonium bromate
Ammonium bromide
Ammonium cadmium chloride
(Ammonium cadmium trichloride)
Ammonium carbamate
Ammonium carbonate carbamate
Ammonium carbonate
(Diammonium carbonate)
Molecular
Weight*
77.08
237.14
252.82
158.97
176.00
124.96
60.06
175.20
139.15
145.94
97.94
236.81
78.07
157.13
96.09
NH3
Equivalent
Wt%
22.09
7.181
13.47
10.71
19.35
13.63
28.35
9.720
12.24
11.67
17.39
7.191
21.81
21.68
35.45
CAS Number
631-61-8
7784-25-0
32516-50-0
13462-93-6
7784-44-3
13462-94-7
12164-94-2
19402-64-3
1863-63-4
13843-59-9
12124-97-9
18532-52-0
1111-78-0
8000-73-5
506-87-3
C-10
-------
Table C-l (Continued)
Chemical Name
Ammonium carbonate, hydrogen
(Ammonium bicarbonate)
Ammonium cerium nitrate
(Ammonium hexanitratocerate)
(Ammonium hexanitratocerate (IV))
(Diammonium cerium hexanitrate)
Ammonium cerous nitrate
(Ammonium cerous nitrate, tetrahydrate)
Ammonium chlorate
Ammonium perchlorate
Ammonium chloride
Ammonium chromate
(Ammonium chromate (VI))
(Diammonium chromate)
Ammonium chromate
(Ammonium dichromate)
(Ammonium dichromate (VI))
(Ammonium bichromate)
(Diammonium dichromate)
Ammonium chromium sulfate
(Ammonium chromic sulfate)
Ammonium citrate
(Ammonium citrate, monohydrogen)
(Ammonium citrate, dibasic)
(Diammonium citrate)
(Diammonium citrate, hydrogen)
Ammonium citrate
(Ammonium citrate, tribasic)
(Triammonium citrate)
Ammonium cobalt sulfate
(Ammonium cobaltous sulfate)
Ammonium cupric chloride
(Ammonium chlorocuprate (II))
(Diammonium copper tetrachloride)
(Diammonium tetrachlorocuprate)
Ammonium cyanate
(Ammonium isocyanate)
Ammonium cyanide
Molecular
Weight*
79.06
548.23
486.22
101.49
117.49
53.49
152.07
252.06
265.17
226.19
243.22
289.14
241.43
60.06
44.06
NH3
Equivalent
Wt%
21.54
6.213
7.005
16.78
14.49
31.84
22.40
13.51
6.422
15.06
21.01
11.78
14.11
28.35
38.65
CAS Number
1066-33-7
16774-21-3
13083-04-0
10192-29-7
7790-98-9
12125-02-9
7788-98-9
7789-09-5
13548-43-1
3012-65-5
3458-72-8
13596-46-8
15610-76-1
22981-32-4
12211-52-8
C-ll
-------
Table C-l (Continued)
Chemical Name
Ammonium cyanoaurate, monohydrate
(Ammonium tetracyanoaurate, monohydrate)
Ammonium cyanoaurate
(Ammonium dicyanoaurate)
Ammonium ferricyanide
(Ammonium hexacyanoferrate (III))
(Triammonium hexacyanoferrate)
Ammonium ferrocyanide
(Ammonium hexacyanoferrate (II))
(Tetraammonium ferrocyanide)
(Tetraammonium hexacyanoferrate)
Ammonium fluoride
Ammonium fluoride
(Ammonium difluoride)
(Ammonium bifluoride)
(Ammonium fluoride, hydrogen)
(Ammonium difluoride, hydrogen)
(Ammonium bifluoride, hydrogen)
Ammonium fluoroborate
(Ammonium tetrafluoroborate)
Ammonium fluorogermanate (IV)
(Ammonium hexafluorogermanate (IV))
(Diammonium hexafluorogermanate)
Ammonium fluorophosphate
(Ammonium hexafluorophosphate)
Ammonium fluorosulfate
(Ammonium fluorosulfonate)
Ammonium formate
Ammonium gallium sulfate
Ammonium hydroxide
Ammonium iodide
Ammonium iridium chloride
(Ammonium chloroiridate (III))
(Ammonium hexachloroiridate)
(Triammonium hexachloroiridate)
Ammonium iron sulfate
(Ammonium ferric sulfate)
(Ammonium iron disulfate)
Molecular
Weight*
319.07
267.04
266.07
284.11
37.04
57.04
104.84
222.66
163.00
117.10
63.06
282.90
35.05
144.94
459.05
269.02
NH3
Equivalent
Wt%
5.337
6.377
19.20
23.98
45.98
29.86
16.24
15.30
10.45
14.54
27.01
6.020
48.59
11.75
11.13
6.330
CAS Number
14323-26-3
31096-40-9
14221-48-8
14481-29-9
12125-01-8
1341-49-7
13826-83-0
16962-47-3
16941-11-0
13446-08-7
540-69-2
15335-98-5
1336-21-6
12027-06-4
15752-05-3
10138-04-2
C-12
-------
Table C-l (Continued)
Chemical Name
Ammonium iron sulfate
(Ammonium ferrous sulfate)
(Diammonium iron disulfate)
(Diammonium ferrous disulfate)
Ammonium lactate
(Ammonium 2-hydroxypropionate)
Ammonium laurate
(Ammonium dodecanoate)
Ammonium magnesium sulfate
Ammonium malate
Ammonium malate, hydrogen
(Ammonium bimalate)
Ammonium molybdate
(Diammonium molybdate)
Ammonium molybdate
(Ammonium heptamolybdate)
(Ammonium molybdate, hydrate)
(Ammonium molybdate, tetrahydrate)
(Ammonium />oramolybdate, tetrahydrate)
Ammonium nickel chloride, hexahydrate
Ammonium nickel sulfate
(Ammonium nickel sulfate, hexahydrate)
(Ammonium nickel disulfate, hexahydrate)
(Diammonium nickel disulfate, hexahydrate)
Ammonium nitrate
Ammonium nitrate sulfate
Ammonium nitrite
Ammonium oleate
Ammonium oxalate
Ammonium palladium chloride
(Ammonium chloropalladate (II))
(Ammonium tetrachloropalladte (II))
(Diammonium tetrachloropalladate)
Ammonium phosphate
(Ammonium orthophosphate)
Molecular
Weight*
286.05
107.11
217.35
252.50
168.15
151.12
196.01
1,163.8
183.09
286.88
80.04
212.18
64.04
299.50
124.10
284.31
149.09
NH3
Equivalent
Wt%
11.91
15.90
7.835
13.49
20.26
11.27
17.38
8.780
9.301
11.87
21.28
24.08
26.59
5.686
27.45
11.98
34.27
CAS Number
10045-89-3
515-98-0
2437-23-2
14727-95-8
6283-27-8
5972-71-4
13106-76-8
12054-85-2
16122-03-5
7785-20-8
6484-52-2
12436-94-1
13446-48-5
544-60-5
1113-38-8
13820-40-1
10124-31-9
C-13
-------
Table C-l (Continued)
Chemical Name
Ammonium phosphate
(Ammonium biphosphate)
(Ammonium phosphate, hydrogen)
(Ammonium phosphate, dihydrogen)
(Ammonium orthophosphate, dihydrogen)
(Ammonium phosphate, monobasic)
Ammonium phosphate
(Ammonium phosphate, hydrogen)
(Ammonium orthophosphate, monohydrogen)
(Ammonium phosphate, dibasic)
(Ammonium orthophosphate, dibasic)
(Diammonium phosphate)
(Diammonium orthophosphate)
(Diammonium phosphate, hydrogen)
(Diammonium phosphate, monohydrogen)
(Diammonium orthophosphate, hydrogen)
Ammonium phosphinate
(Ammonium hypophosphite)
Ammonium phosphite
(Ammonium biphosphite)
(Ammonium phosphite, dihydrogen)
Ammonium picramate
Ammonium propionate
Ammonium rhodium chloride
(Ammonium chlororhodate (III))
(Ammonium hexachlororhodate (III))
(Triammonium rhodium hexachloride)
(Triammonium hexachlororhodate)
Ammonium salicylate
(Ammonium 2-hydroxybenzoate)
Ammonium selenide
Ammonium silicon fluoride
(Ammonium fluorosilicate)
(Ammonium hexafluorosilicate)
(Diammonium silicon hexafluoride)
(Diammonium fluorosilicate)
(Diammonium hexafluorosilicate)
Ammonium stearate
(Ammonium octadecanoate)
Ammonium succinate
(Diammonium succinate)
Molecular
Weight*
115.03
132.06
83.03
99.03
216.15
91.11
369.74
155.15
115.04
178.15
301.51
152.15
NH3
Equivalent
Wt%
14.80
25.79
20.51
17.20
7.879
18.69
13.82
10.98
29.61
19.12
5.648
22.39
CAS Number
7722-76-1
7783-28-0
7803-65-8
13446-12-3
1134-85-6
17496-08-1
15336-18-2
528-94-9
66455-76-3
16919-19-0
1002-89-7
2226-88-2
C-14
-------
Table C-l (Continued)
Chemical Name
Ammonium sulfamate
(Ammonium amidosulfate)
(Ammonium amidosulfonate)
Ammonium sulfate
(Diammonium sulfate)
Ammonium sulfate
(Ammonium bisulfate)
(Ammonium sulfate, hydrogen)
(Ammonium sulfate, monohydrogen)
Ammonium />ersulfate
(Ammonium peroxysulfate)
(Ammonium peroxydisulfate)
(Diammonium persulfate)
(Diammonium peroxydifulsite)
Ammonium sulfide
(Ammonium bisulfide)
(Ammonium sulfide, hydrogen)
Ammonium sulfide
(Ammonium monosulfide)
(Diammonium sulfide)
Ammonium sulfide
(Diammonium pentasulfide)
Ammonium sulfite, monohydrate
(Diammonium sulfite, monohydrate)
Ammonium sulfite
(Ammonium bisulfite)
(Ammonium sulfite, hydrogen)
Ammonium tetrachloroaurate (III), hydrate
Ammonium thiocarbamate
Ammonium thiocarbonate
(Diammonium trithiocarbonate)
Ammonium thiocyanate
(Ammonium isothiocyanate)
(Ammonium sulfocyanate)
(Ammonium rhodanate)
(Rhodanid)
Ammonium dithionate
Ammonium thiosulfate
(Ammonium hyposulfite)
(Diammonium thiosulfate)
Molecular
Weight*
114.12
132.13
115.10
228.19
51.11
68.14
196.39
116.13
99.10
356.82
94.13
144.27
76.12
196.19
148.20
NH3
Equivalent
Wt%
14.92
25.78
14.80
14.93
33.32
49.99
17.34
29.33
17.18
4.772
18.09
23.61
22.37
17.36
22.98
CAS Number
7773-06-0
7783-20-2
7803-63-6
7727-54-0
12124-99-1
12135-76-1
12135-77-2
7783-11-1
10192-30-0
13874-04-9
16687-42-6
13453-08-2
1762-95-4
60816-52-6
7783-18-8
C-15
-------
Chemical Name
Ammonium tin bromide
(Ammonium bromostannate (IV))
(Ammonium hexabromostannate (IV))
(Diammonium hexabromostannate)
Ammonium tin chloride
(Ammonium chlorostannate (IV))
(Ammonium hexachlorostannate (IV))
(Diammonium tin hexachloride)
(Diammonium hexachlorostannate)
Ammonium titanium fluoride
(Ammonium fluorotitanate (IV))
(Ammonium hexafluorotitanate (IV))
(Diammonium titanium hexafluoride)
(Diammonium hexafluorotitanate)
Ammonium titanium oxalate, monohydrate
(Diammonium dioxalatooxotitanate, monohydrate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Hexaammonium tungstate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Decaammonium tungstate)
Ammonium valerate
(Ammonium pentoate)
Ammonium zinc chloride
(Ammonium chlorozincate)
(Ammonium tetrachlorozincate)
(Diammonium tetrachlorozincate)
Molecular
Weight*
634.19
367.48
197.95
276.00
1,779.2
3,058.6
119.16
243.27
NH3
Equivalent
Wt%
5.371
9.269
17.21
12.34
5.743
5.568
14.29
14.00
CAS Number
16925-34-1
16960-53-5
16962-40-6
10580-03-7
12028-06-7
11120-25-5
42739-38-8
14639-97-5
*For hydrated compounds, e.g., ammonium sulfite, monohydrate, the molecular weight excludes the weight of the hydrate
portion.
C-16
-------
Appendix D
UNIT CONVERSION FACTORS
(From U.S. Coast Guard Commandant Instruction M.16465.12A)
-------
CONVERSION FACTORS
To Convert
To
Multiply By
Length
inches
inches
feet
feet
feet
feet
yards
yards
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
meters
meters
meters
nautical miles
millimeters
feet
inches
meters
yards
miles (U.S. statute)
feet
miles (U.S. statute)
feet
yards
meters
nautical miles
feet
yards
miles (U.S. statute)
miles (U.S. statute)
25.4
0.0833
12
0.3048
0.3333
0.0001894
3
0.0005682
5280
1760
1609
0.868
3.271
1.094
0.0006214
1.152
Area
square inches
square inches
square feet
square feet
square meters
square miles
square yards
square centimeters
square feet
square inches
square meters
square feet
square yards
square feet
6.452
0.006944
144
0.09290
10.76
3,097,600
9
Volume
cubic inches
cubic inches
cubic feet
cubic feet
cubic feet
cubic meters
liters
quarts (U.S. liquid)
U.S. gallons
U.S. gallons
U.S. gallons
barrels (petroleum)
Imperial gallons
milliliters
cubic centimeters
cubic feet
cubic inches
cubic meters
U.S. gallons
cubic feet
quarts (U.S. liquid)
liters
barrels (petroleum)
cubic feet
Imperial gallons
U.S. gallons
U.S. gallons
cubic centimeters
16.39
0.0005787
1728
0.02832
7.481
35.31
1.057
0.9463
0.02381
0.1337
0.8327
42
1.201
1
D-l
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Time
seconds
seconds
seconds
minutes
minutes
minutes
hours
hours
hours
minutes
hours
days
seconds
hours
days
seconds
minutes
days
0.01667
0.0002778
0.00001157
60
0.01667
0.0006944
3600
60
0.04167
Mass or Weight
pounds
pounds
pounds
pounds
tons (short)
tons (metric)
tons (long)
kilograms
tonnes (metric tons)
kilograms
short tons
long tons
metric tons
pounds
pounds
pounds
pounds
kilograms
0.4536
0.0005
0.000464
0.0004536
2000
2205
2240
2.205
1000
Energy
calories
calories
Btu (British thermal units)
Btu
joules
joules
Btu
joules
calories
joules
calories
Btu
0.003968
4.187
252.0
1055
0.2388
0.0009479
Velocity
feet per second
feet per second
feet per second
meters per second
meters per second
miles per hour
miles per hour
knots
knots
knots
pounds per cubic foot
grams per cubic centimeter
grams er cubic centimeter
kilograms per cubic meter
meters per second
miles per hour
knots
feet per second
miles per hour
meters per second
feet per second
meters per second
miles per hour
feet per second
grams per cubic centimeter
pounds per cubic foot
kilograms per cubic meter
grams per cubic centimeter
0.3048
0.6818
0.5921
3.281
2.237
0.4470
1.467
0.5148
1.151
1.689
0.01602
62.42
1000
0.001
D-2
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Pressure
ponds per square inch (absolute) (psia)
psia
psia
psia
pounds per square inch (gauge) (psig)
millimeters of mercury (torr)
millimeters of mercury (torr)
inches of water
kilograms per square centimeter
inches of water
kilograms per square centimeter
atmospheres
kilograms per square centimeter
atmospheres
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2) 6.895
atmospheres 0.0680
inches of water 27.67
millimeters of mercury (torr) 51.72
psia add 14.70
psia 0.01934
kN/m2 0.1333
psia 0.03614
millimeters of mercury (torr) 735.6
kN/m2 0.2491
atmospheres 0.9678
kN/m2 101.3
psia 14.22
psia 14.70
kN/m2 100
psia 0.1450
atmospheres 0.9869
atmospheres 0.009869
kilograms per square centimeter 1.020
Viscosity
centipoises
pounds per foot per second
centipoises
centipoises
poises
grams per centimeter per second
Newton seconds per square meter
pounds per foot per second 0.0006720
centipoises 1488
poises 0.01
Newton seconds per square meter 0.001
grams per centimeter per second 1
poises 1
centipoises 1000
Thermal Conductivity
Btu per hour per foot per °F
Btu per hour per foot per °F
watts per meter-kelvin
kilocalories per hour per meter per °C
kilocalories per hour per meter per °C
watts per meter-kelvin 1.731
kilocalories per hour per meter per ° C 1.488
Btu per hour per foot per °F 0.5778
watts per meter-kelvin 1.163
Btu per hour per foot per °F 0.6720
Heat Capacity
Btu per pound per °F
Btu per pound per °F
joules per kilogram-kelvin
calories per gram per °C
calories per gram per °C
joules per kilogram-kelvin
Btu per pound per °F
Btu per pound per °F
1
4187
0.0002388
1
D-3
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Concentration (in water solution)
parts per million (ppm)
milligrams per liter
milligrams per cubic meter
grams per cubic centimeter
grams per cubic centimeter
pounds per cubic foot
milligrams per liter
ppm
grams per cubic centimeter
milligrams per cubic meter
pounds per cubic foot
grams per cubic centimeter
1
1
IxlO'9
IxlO9
62.42
0.01602
Temperature
degrees Kelvin (°K)
degrees Rankine (°R)
degrees centigrade (°C)
degrees Fahrenheit (°F)
degrees centigrade (°C)
degrees Fahrenheit (°F)
degrees Rankine (°R)
degrees Kelvin (°K)
degrees Fahrenheit (°F)
degrees centigrade (°C)
degrees Kelvin (°K)
degrees Kelvin (°K)
1.8
0.5556
first multiply by 1.8, then add 32
first subtract 32, then multiply by
0.5556
add 273.2
add 459.7
Flow
cubic feet per second
U.S. gallons per minute
U.S. gallons per minute
cubic feet per second
448.9
0.002228
Universal Gas Constant (R)
8.314 joules per gram mole-kelvin
1.987 calories per gram mole-kelvin
1.987 Btu per pound mole per °F
10.73 psia-cubic feet per pound mole per °F
82.057 atm-cubic centimeters per gram mole-kelvin
62.361 millimeters mercury liter per gram mole-kelvin
D-4
-------
INDEX
The pages listed in bold text in the index correspond to the primary uses or definitions of the
associated term. Additionally, this index includes a list of primary purposes for examples and
common errors that are presented throughout the document.
Activity thresholds 2-10 to 2-13, 2-15, 2-17, 3-9 to 3-13, 3-25 to 3-27
Air emissions 4-4, 4-5, 4-20 to 4-22, 4-26, 4-38, 4-45 to 4-48, 4-50 to 4-55
Fugitive or non-point 4-4
Stack or point source 4-5
Air pollution control 4-3, 4-5, 4-46, 4-47, 4-49
Article exemption (see Exemptions)
Automated toxic chemical release inventory reporting software (ATRS) 2-16
Chemical-specific
Acid aerosols 3-6, 3-7, 4-47, 4-49
Ammonia 2-10, 3-5, 3-22, 4-20, 4-32, 4-37, 4-44, 4-48
Certain glycol ethers 2-9, 3-8, 3-9, 3-13, 4-32, 4-41, 4-42, 4-48
Hydrochloric acid 3-6, 3-17
Nitrate compounds 3-6, 4-20
Sulfuric acid 3-7, 4-47, 4-49
Chemical processing aid 3-13
Combustion 3-17, 3-21, 4-3, 4-10, 4-12, 4-13, 4-23
For energy recovery off-site 4-13
For energy recovery on-site 4-12
Common errors
Assuming a threshold is exceeded 3-24
Direct reuse vs. recycling 4-14
Double counting 4-16
Exempt activities 3-15
Mass balance for otherwise used chemicals 4-21
Metals in waste ink/solvents 4-46
Mixture components 3-4
Shipping container residue 4-8
Threshold determination for recirculation 3-10
Treatment efficiencies 4-19
Zero release and other waste management quantities 3-25
Container residue 4-3, 4-8, 4-9, 4-48-4-50, 4-54, 4-55
De minimis (see Exemptions) x, 2-14, 3-4, 3-14-3-17, 3-26, 3-28
Digital printing 4-32, 4-44
Disposal . . 2-11, 2-12, 2-17, 3-11, 4-6-4-8, 4-12, 4-14, 4-15, 4-20, 4-22, 4-27, 4-28, 4-37, 4-41,
4-46, 4-48, 4-49, 4-54
Documentation (see Recordkeeping)
Double counting 4-6, 4-16
Emission factors 4-17, 4-18, 4-21-4-23, 4-25, 4-49
Employee equivalent calculation 2-8
Index-1
-------
INDEX (Continued)
xi, 1-2 to 1-5,2-8,
viii, ix, 2-1, 2-2, 2-5, 2-6,
Energy recovery (see Combustion for energy recovery)
Engineering calculation
EPCRA hotline
Establishment
Examples
Chemical processing aid
Chemicals in process water
Container residue
De minimis
De minimis concentration ranges
Emission factors
Employee equivalent calculation
Engineering calculations
Form A threshold
Image carrier preparation
Imaging/film processing operations
Laboratory activity exemption
Mass balance
Monitoring data
Motor vehicle exemption
Multiple establishments
On-site waste treatment
Postpress operations (fugitive releases)
Printing operations (fugitive releases)
Printing operations (toluene)
Process equipment chemical use
Relabeling
Threshold determination
Threshold worksheet
Treatment of wastes from off site
Xylene isomers
Exemptions 3-14 to
Activity-related 3-20 to
Article 3-18 to
De minimis 3-15 to
Evaluation of
Facility-related 3-19 to
Grounds maintenance
Janitorial
Laboratory 3-19,
Motor vehicle
Structural components
Vanadium
4-23
2-15
2-19
3-13
3-22
4-10
3-16
3-16
4-23
. 2-8
4-24
2-17
4-42
4-38
3-20
4-20
4-19
3-21
. 2-2
4-11
4-55
4-50
4-51
3-21
2-11
. 3-9
3-25
2-11
3-10
3-22
3-22
3-19
3-18
3-14
3-20
3-20
3-20
3-20
3-21
3-21
. 3-7
Index-2
-------
INDEX (Continued)
Facility viii-x, 2-1, 2-2, 2-4 to 2-8, 2-17, 3-19
Auxiliary facility 2-6
Covered facility 2-5, 2-6
Pilot plant 2-6, 3-20
Flexography 4-32, 4-39, 4-43
Form A 1-4, 2-1, 2-2, 2-16 to 2-18, 3-2, 3-23
Form R 2-1, 2-2, 2-16, 3-2, 3-23, 4-5 to 4-7, 4-12 to 4-16
Gravure printing 4-22, 4-31, 4-39, 4-43
Imaging/film processing 4-30, 4-33-4-38
Impurity 2-12, 3-11, 3-15, 3-16
Letterpress 4-30, 4-33, 4-35, 4-39, 4-44, 4-46 to 4-48
Lithography 2-5, 4-30, 4-31, 4-35, 4-38, 4-42, 4-46 to 4-48
Manufacture/manufacturing
Byproduct 2-12, 3-11, 3-18
Coincidental manufacture 3-17, 3-18, 3-21
Manufacturing subcategories 3-11
Mass balance 4-17 to 4-21, 4-37, 4-41, 4-49, 4-50, 4-55
Methods (see Reportable amount estimate methods)
Mixture 3-3, 3-10, 3-15 to 3-17
Monitoring data 2-20, 4-17 to 4-19, 4-42
Motor vehicle exemption (see Exemption)
MSDS 2-20, 3-3, 3-14
Otherwise use 2-12, 3-9, 3-13, 3-20 to 3-22
Owner/operator 1-3
PBT chemicals 2-13 to 2-15
Penalties 1-4
Pilot plant (see Facility)
Point source (see Air emissions)
Post-press 4-30, 4-33, 4-34, 4-53 to 4-55
POTW 4-7, 4-15, 4-16, 4-18, 4-28, 4-41
Printing 2-5, 2-9, 4-22, 4-24, 4-30 to 4-35, 4-42 to 4-53
Process equipment 3-21
Process water 3-22
Processing (subcategories) 3-9, 3-12
Qualifiers 3-4 to 3-8
Recordkeeping 2-19
Recycling 3-10, 3-22, 3-23, 4-3, 4-7, 4-12, 4-14, 4-25, 4-27, 4-29
Off-site 4-14, 4-29, 4-46, 4-48, 4-54
On-site 3-10, 3-23, 4-12, 4-14, 4-25, 4-27
Release 4-1 to 4-16, 4-26 to 4-29
Accidental 4-3, 4-15
Sources 4-3, 4-34, 4-36, 4-40, 4-45, 4-46, 4-53, 4-54
Types 4-4 to 4-16, 4-34, 4-36, 4-40, 4-41, 4-45, 4-48, 4-53, 4-54
Index- "•
-------
INDEX (Continued)
Repackaging 2-10, 3-12
Reportable amount 1-4, 2-17, 2-18
Reportable amount estimate methods
Emission factors 4-18, 4-21 to 4-23
Engineering calculations 4-18, 4-23 to 4-25
Mass balance 4-17 to 4-21
Monitoring data/records 4-17 to 4-19
Reporting criteria 1-3, 2-2
Reuse 3-22, 4-14, 4-43
Screen printing 4-30, 4-32, 4-35, 4-39, 4-44, 4-45, 4-48
Sources (see Release)
Standard Industrial Classification (SIC) 2-2, 2-4 to 2-7
Primary SIC code 2-2, 2-6
Technically qualified individual 3-20
Trade secret 2-18
Transfers 4-7, 4-13 to 4-16
Treatment efficiency 4-10, 4-15, 4-47, 4-49
Treatment for destruction 2-11
Off-site 4-15, 4-28, 4-37, 4-41, 4-46, 4-48, 4-54
On-site .... 2-11, 3-11, 4-10, 4-11, 4-14, 4-19, 4-25, 4-27, 4-46, 4-48, 4-49, 4-52
Types (see Release)
Waste management 4-1 to 4-16, 4-26 to 4-29
Waste treatment (see Treatment for destruction)
Wastewater discharge 4-6, 4-16, 4-26
Index-4
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