United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
EPA745-B-00-012
April 2000
&EPA Emergency Planning and Community Right-
To-Know Act Section 313 Reporting Guidance
for the Leather Tanning and Finishing
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Industry
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT vi
OVERVIEW vii
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 2-6
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 2-17
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 3-5
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for
Each EPCRA Section 313 Chemical and Chemical Category 3-8
3.2.1 Concentration Ranges for Threshold Determination 3-12
3.2.2 Evaluation of Exemptions 3-13
3.2.2.1 DeMinimisExemption 3-14
3.2.2.2 Articles Exemption 3-17
3.2.2.3 Facility-Related Exemption 3-19
Laboratory Activity Exemption 3-19
3.2.2.4 Activity-Related Exemptions (Otherwise Use
Exemptions) 3-19
3.2.3 Additional Guidance on Threshold Calculations for Certain
Activities 3-21
3.2.3.1 Reuse Activities 3-21
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TABLE OF CONTENTS (Continued)
Page
3.2.3.2 Remediation Activities 3-22
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 3-23
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 Quantities
from Leather Tanning and Finishing Operations 4-30
4.2.1 Beamhouse Operations 4-31
4.2.2 Tanyard Operations 4-37
4.2.3 Retanning, Coloring and Fatliquoring 4-42
4.2.4 Finishing Operations 4-45
4.2.5 Wastewater Treatment 4-49
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TABLE OF CONTENTS (Continued)
Appendix A EPCRA SECTION 313 GUIDANCE RESOURCES
Appendix B BASIC CALCULATION TECHNIQUES
Appendix C LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING
Appendix D EPCRA SECTION 313, GUIDANCE FOR REPORTING AQUEOUS
AMMONIA
Appendix E UNIT CONVERSION FACTORS
Appendix F EXCERPT FROM: LIST OF CHEMICALS WITHIN THE GLYCOL ETHERS
CATEGORY
Appendix G EMISSIGN FACTORS AND GUIDANCE FOR ANHYDROUS AMMONIA
FROM THE LEATHER INDUSTRIES OF AMERICA
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LIST OF TABLES
Page
2-1 SIC Codes Covered by EPCRA Section 313 Reporting 2-4
2-2 EPCRA Section 313 Chemicals and Chemical Categories Reported by
Leather Tanning and Finishing Facilities 2-9
2-3 Activity Categories 2-11
2-4 Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals 2-13
3-1 Reporting Thresholds 3-8
3-2 Definitions and Examples of Manufacturing Subcategories 3-10
3-3 Definitions and Examples of Processing Subcategories 3-11
3-4 Definitions and Examples of Otherwise Use Subcategories 3-12
3-5 EPCRA Section 313 Reporting Threshold Worksheet 3-26
3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet 3-27
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
IV
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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 Activity Types for EPCRA
Section 313 Chemicals and Chemical Categories 4-5
4-3 Process Flow - Beamhouse Operations 4-34
4-4 Process Flow - Tanyard Operations 4-38
4-5 Process Flow - Retanning, Coloring, and Fatliquoring Operations 4-43
4-6 Process Flow - Finishing Operations 4-46
4-7 Process Flow - Wastewater Treatment 4-50
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ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of Leather Industries of America, Inc. and Garden State Tanning, Inc. 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. Special
thanks go to Dr. Nicholas Cory, Technical Director, Leather Industries of America, Inc.; and Mr.
Chris Ehret and Mr. Chuck Carbaugh of Garden State Tanning, Inc. for their hard work.
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OVERVIEW
This document supersedes the booklet entitled Title III Section 313 Release
Reporting Guidance, Estimating Chemical Releases from Leather Tanning and Finishing, dated
February 1988. It is intended to assist establishments and facilities performing leather tanning
and finishing 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 (U.S. EPA's) interpretive
guidance on various issues specific to leather tanning and finishing
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.
It is recognized that not all leather tanning and finishing establishments will have
all unit operations described in this document. However, each of the unit operations discussed
are common operations found in leather tanning and finishing establishments covered by EPCRA
Section 313 and PPA Section 6607 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.
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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?
• 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 chemicals. 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.
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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;
• 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 EPCRA Section 313 chemical and chemical category release
and other waste management activities.
The second part of Chapter 4 is organized by five major groupings. These
subsections describe the typical leather tanning and finishing unit operations where EPCRA
Section 313 chemicals and chemical categories are used: beamhouse operations; tanhouse
operations; retanning, coloring, and fatliquoring operations; finishing operations; and wastewater
treatment. The commonly used EPCRA Section 313 chemicals and chemical categories, process
descriptions, release and other waste management activity estimates, example calculations, and
common problems are presented.
This document includes examples and common errors applicable to leather
tanning and finishing operations. These examples are based on information identified during
voluntary site surveys of facilities that have filed EPCRA Section 313 reports in the past,
discussions with representatives of the Leather Industries of America, Inc. and Garden State
Tanning, Inc., and on questions received by the EPCRA Hotline.
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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
leather tanning and finishing facilities 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 leather tanning and finishing 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 Leather Tanning and
Finishing. 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 leather tanning and finishing
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 leather tanning and finishing 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 (1999 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.
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EPCRA Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2,
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 Leather Industries of America, Inc. and staff from Garden State
Tanning, Inc. provided input on common problems specific to leather tanning and finishing
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 surveys of facilities that have filed EPCRA Section 313 reports in the past.
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Selected issues and guidance addressing these common problems are presented throughout this
document as applicable.
The TRIForms and Instructions also 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 and 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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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)?
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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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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.
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
Leather tanning and finishing facilities are typically classified in SIC Code 3111.
You should determine the SIC Code(s) for your facility, based on the activities performed 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.
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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
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.
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Example - Primary SIC Code
A facility has two establishments. The first, a general automotive repair service, is in SIC Code 7537. SIC Code
7537 is not a covered SIC Code. However, the second EPCRA Section 313 establishment, a metal products paint
shop, is in SIC Code 3479, which is a covered SIC Code. The facility also determines the product is worth
$500/unit as received from the establishment in the non-covered SIC Code and the value of the product is
$l,500/unit after processing by the establishment in the covered SIC Code. The value added by the establishment
in the covered SIC Code is more than 50% of the product value; therefore, the primary SIC Code is 3479, a
covered SIC Code. Thus, the establishment is covered by EPCRA Section 313 reporting and the entire facility is
subject to reporting.
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 Chapter 3). Warehouses on the
same site as facilities in a covered SIC Code are also subject to reporting. Likewise, warehouses
that qualify as auxiliary facilities of covered facilities also must report, 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
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
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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 for the facility (including paid leave and overtime) should be
counted in determining if the 20,000-hour criterion has been met.
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.
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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 and 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
chemical or chemical category for addition or deletion from the list, U.S. EPA must consider the
chemical'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
2-2 lists the EPCRA Section 313 chemicals and chemical categories reported for leather tanning
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and finishing operations in 1995. This list is not intended to be all inclusive and should only be
used as a guide.
Table 2-2
EPCRA Section 313 Chemicals and Chemical Categories Reported by Leather
Tanning and Finishing Facilities
Chemicals
Ammonia (anhydrous and 10% of aqueous)
Butyl acrylate
Butyl alcohol
Certain glycol ethers
Chlorine
Chromium
Chromium compounds
Di (2-ethylhexyl) phthalate
Ethylbenzene
Formaldehyde
Formic acid
Hydrochloric acid (acid aerosols)
Manganese
Manganese compounds
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
N-Methyl-2-pyrrolidone
Naphthalene
Nitrate compounds (only in water and water dissociable)
Sulfuric acid (acid aerosols)
Toluene
Triethylamine
Xylene (mixed isomers)
Zinc compounds
Process
Wastewater Treatment
Finishing
Finishing
Finishing
Wastewater Treatment
Tanning
Tanning
Finishing
Finishing
Synthetic Retanning
Coloring
Pickling
Wastewater Treatment
Wastewater Treatment
Finishing
Finishing
Finishing
Finishing
Finishing
Synthetic Retanning
Wastewater Treatment
Pickling
Finishing
Finishing
Finishing
Finishing/Retanning
Ref: 1995 TRI database for SIC Code 3111.
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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 use1. 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 incorporated into a product for distribution 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 2-3.
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Table 2-3
Activity Categories
Activity
Category
Definition
Threshold1
(Ib/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical or chemical
category. Manufacture also applies to an EPCRA Section 313 chemical or chemical
category 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 or chemical category 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 chemical category, or a mixture or trade
name product containing an EPCRA Section 313 chemical or chemical category, for
distribution in commerce. For example, the addition of EPCRA Section 313 listed
pigments to paint 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 or 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 paint 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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COMMON ERROR - Coincidental Manufacture
The coincidental manufacture of an EPCRA Section 313 chemical or chemical category is frequently overlooked.
For example, in the treatment of wastewater, ammonia and nitrate compounds may be coincidentally
manufactured. Wastewater from leather tanning and finishing facilities typically contains large quantities of
proteinaceous materials, which often cause coincidental manufacture of ammonia and nitrate compounds. The
amounts of these compounds created in the wastewater treatment process must be estimated and included in the
manufacturing threshold determination (see Appendices C and D, respectively, for EPCRA Section 313 reporting
guidance for nitrate compounds and ammonia).
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.
Example - Relabeling
You buy a mixture in small containers that contains an EPCRA Section 313 chemical or chemical category.
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 or
chemical category 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 and chemical categories that you manufactured in the kit toward manufacturing and processing
threshold determinations.
Example - Treatment of Wastes from Off Site
A covered 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. The quantity of chemical B
should be counted towards the manufacturing threshold. However, the facility disposed of Chemical B on site
and waste received from off site for treatment for destruction, disposal, or stabilization is considered to be
otherwise used. Therefore, the amount of Chemical B must also be considered in the otherwise use threshold
determination. Thus, the reporting threshold for Chemical B has also been exceeded and all release and other
waste management activities for Chemical B must be reported.
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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 or chemical category 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 thresholds are listed in
Table 2-4.
Table 2-4
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 2-4 (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
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from eligibility for the alternate threshold of 1 million pounds (see Section 2.9) and eliminated
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.
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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
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 or chemical category cannot exceed 500 pounds per year. The
"reportable amount" is defined as the sum of the on-site amounts released
(including disposal), treated, combusted for energy recovery, and recycled,
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 or chemical
category 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 or chemical category and processes
150,000 pounds of the same chemical or chemical category 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
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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
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 or
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 or chemical category by submitting an unsanitized version to a state agency or
tribal government that does not require an unsanitized version.
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More information on trade secret claims, including contacts for individual state's
submission requirements, can be found in the TRI Forms and Instructions.
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 use 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.
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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,
• 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;
Formulation sheets;
Purchase records from suppliers;
Inventory data;
Material Safety Data Sheets (MSDSs);
National Pollutant Discharge Elimination System (NPDES)/State Pollutant
Discharge Elimination System (SPDES) permits and monitoring reports;
New Source Performance Standards (NSPS);
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;
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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 and 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, chemical categories, compounds, 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 and 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.
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Review the lists to be sure each chemical and chemical category is shown by its
correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical
found in leather tanning and finishing operations is formic acid. Formic acid (Chemical
Abstracts Service (CAS) Registry No. 64-18-6) has several synonyms including aminic acid,
formylic acid, methanoic acid, and hydrogen carboxylic acid. It must be reported on Form R (or
Form A), Item 1.2, by its EPCRA Section 313 chemical name, formic acid. 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 and chemical category on the EPCRA
Section 313 chemical and chemical category list, you should be aware of the chemicals and
chemical categories typically used in leather tanning and finishing operations. As a guide, the
EPCRA Section 313 chemicals and chemical categories reported by leather tanning and finishing
facilities, and the processes they are typically used in, for reporting year 1995 are listed in
Table 2-2.
COMMON ERROR - Glvcol Ether Reporting
You should be sure to check the EPCRA Section 313 definition of glycol ethers. Some leather tanning facilities
incorrectly report chemicals in this category.
One of the most commonly reported chemical categories by leather tanning facilities, SIC Code 3111, in 1995
was Certain Glycol Ethers. However, based on information from the Leather Industries of America, many of the
commonly used glycol ethers in the leather tanning industry do not fit the EPCRA Section 313 definition of the
Certain Glycol Ethers category. This high level of reporting may be the result of assuming that any glycol ether
must be reported.
Note that for EPCRA Section 313 purposes, the members of the certain glycol ethers category are glycol ethers
derived from ethylene glycol, diethylene glycol, and triethylene glycol. This category does not contain glycol
ethers based on propylene glycol, dipropylene glycol, or tripropylene glycol.
Also note that there are two chemicals, 2-Methoxyethanol (CAS Registry No. 109-86-4) and 2-Ethoxyethanol
(CAS Registry No. 110-80-5) that are on the individual chemical list and the CAS number list (40 CFR 372.65(a)
and (b)). Threshold determinations should be made for each of these chemicals individually and separately from
the Certain Glycol Ethers category. See Appendix F for clarification on glycol ethers.
A computerized spreadsheet may be helpful in developing your facility's chemical
and chemical category list and performing threshold calculations. The spreadsheet could show
the chemical, chemical category or chemical mixture with corresponding component
O O
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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 and 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 (NSPS);
Inventory records;
Air and water discharge permits;
Individual manufacturing/operating functions; and
Receipts or manifests associated with the transfer of each EPCRA Section
313 chemical and 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 and chemical category on your
spreadsheet:
The mixture name and associated EPCRA Section 313 chemical and
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).
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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. 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 and 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 and chemical categories are:
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 and chemical categories that are present in small
quantities of bulk solutions. For example, a common chemical used in leather tanning and finishing 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.
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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-
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
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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 D).
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.
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 sprays hydrochloric acid "manufactures" hydrochloric acid aerosol
and should include this quantity in the manufacturing threshold
determination.
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 a solvent should not report for isopropyl alcohol.
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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 (see Appendix C).
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 sprays sulfuric acid
"manufactures" sulfuric acid aerosol and should include this quantity in
the manufacturing threshold determination. U.S. EPA has published
guidance for acid aerosols in Guidance for Reporting Sulfuric Acid., EPA
745-R-97-007.
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
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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.
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
lrThese reporting thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds
applicable to PBT chemicals.
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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 EPCRA 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.
Example - Xylene Isomers
Leather tanning and finishing 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 to be "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 or 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
Produced or
imported for on-site
use/processing
Produced or
imported for
sale/distribution
Produced as a
byproduct
Produced as an
impurity
Definition
A chemical or chemical category that is produced or
imported and then further processed or otherwise used at the
same facility.
A chemical or chemical category that is produced or
imported specifically for sale or distribution outside the
manufacturing facility.
A chemical or chemical category 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. EPCPxA
Section 313 chemicals or chemical categories produced and
released as a result of waste treatment or disposal are also
considered byproducts.
A chemical or chemical category 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.
Examples in Leather
Tanning and Finishing
Operations*
Sodium dichromate
Ammonia (From hide
deamination), nitrate
compounds, chromium
shavings and buffings
dusts
*More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
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Table 3-3
Definitions and Examples of Processing Subcategories
Processing Activity
Subcategory
Definition
Examples in Leather Tanning
and Finishing Operations*
Reactant
A natural or synthetic chemical or chemical
category used in chemical reactions for the
manufacture of another chemical substance or
product. Examples include feedstocks, raw
materials, intermediates, and initiators.
Chromium, copper, and cobalt
compounds, formaldehyde,
methylene diphenyl diisocyanate,
and toluene diisocyanate
Formulation component
A chemical or chemical category 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 or chemical category that becomes
an integral component of an article distributed
for industrial, trade, or consumer use.
Chromium, o-phenylphenol,
ammonium salts, chromium,
copper and cobalt based dyes,
dibutyl phthalate, n-methyl-2-
pyrrolidone
Repackaging only
A chemical or chemical category 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.
*More complete discussions of the industry-specific examples can be found in Chapter 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 Leather Tanning
and Finishing 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 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.
Formic acid, toluene
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.
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.
Chlorine, chlorine dioxide
*More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Example - Chemical Processing Aid
A spray painting operation uses toluene as the carrier solvent. Ideally all the solvent would evaporate, however,
studies have shown 1% of the applied solvent remains on the workpiece. Since the function of the solvent is to
improve the application of the paint 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 workpiece, it would be
considered processed, as is the case for pigments, binders, and other paint components intended to remain with
the workpiece.
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,
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the exact concentration of an EPCRA Section 313 chemical or chemical category in a mixture or
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%. 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%.
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 or chemical category 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 Section 2.6). 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
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that occur after the de minimis concentration has been equaled or exceeded are subject to
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 that is 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 category
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.
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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 at or
above the de minimis concentration:
8,000,000 x (0.0125 - 0.0099) - (0.0125 - 0.0025)
The average concentration of manganese that is not exempt (at or 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)
= 23,400 pounds
= 23,400 pounds manganese (which is below the processing threshold)
In this example, because the 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 (at or 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 (at or 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)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold)
The exemption does not apply to EPCRA Section 313 chemicals and 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
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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
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 of more than 0.5 pound of the
EPCRA Section 313 chemical or chemical category in a reporting year from 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
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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
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.
Example - Articles Exemption
If an article, as part of a coating pre-treatment operation, is subjected to an etching process that removes a portion
of an EPCRA Section 313 metal from the surface that is not recycled or reused, this process would constitute a
release and negate the article exemption if the total release is greater than 0.5 Ib for the reporting year. For
example, a copper plate is cleansed by dipping in a sulfuric acid solution. Some of the copper reacts with the acid
to form copper sulfate and the used cleaning solution is discharged to a POTW. This process is considered a
release of the copper and, if the release from all like articles is greater than 0.5 pound per year, the plate has lost
its article exemption.
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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
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 leather finishing facility has a research laboratory that tests various leather tanning and finishing formulations
containing EPCRA Section 313 chemicals and chemical categories by applying these formulations to leather
samples being considered for car seat use by an automobile manufacturer. 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 determination 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 and chemical
categories used in these activities do not need to be included in a facility's threshold
determination (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.
3-19
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Personal use of items. Examples are foods, drugs, cosmetics, and other
personal items including those items within the facility such as in a facility
operated cafeteria, store, or infirmary. Office supplies such as correction
fluid are also exempt.
Example - Personal Use Exemption
Aqueous ammonia used to clean a cafeteria grill is exempt from threshold
determinations and release and other waste management calculations.
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.
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 cars, trucks,
forklifts, locomotives, and aircraft. Note that this exemption applies to the
OTHERWISE USE of the EPCRA Section 313 chemical and chemical
category. 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. The amount used for the latter purpose would be
subtracted from the facility total BEFORE the facility total is compared to the activity
threshold. 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.
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Example - Process Equipment Chemical Use
Lubricants containing EPCRA Section 313 chemicals and 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 air or water
drawn from the environment or municipal sources Included are
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.
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 or chemical category was present as it was drawn from the environment.
The facility does not need to consider the EPCRA Section 313 chemical or chemical
category 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 and 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
3-21
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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.
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 and 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 otherwise 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.
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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 quantity recycled or
reused 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 and 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).
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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.
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. 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 worksheet that may be helpful when conducting your
threshold determinations. Table 3-6 illustrates how the work sheet can be used for the following
example:
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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).
3-25
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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
Ob)
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
(C) 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.
lrThese activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals.
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Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet
Facility Name: XYZ Leather Tanning Corp.
EPCRA Section 313 Chemical or Chemical Category: Xvlene (mixed isomers)
CAS Registry Number: 1330-20-7
Reporting Year: 1998
Date Worksheet Prepared: May 1. 1999
Prepared By: A.B. Galloway
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
Ob)
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
(Aj) 0 Ib.
Processed
(Bj) 0 Ib.
Otherwise Used
(CO 0 Ib.
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.]
lrThese activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals.
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Appendix A
EPCRA SECTION 313 GUIDANCE RESOURCES
-------
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 and
chemical categories from leather tanning and finishing 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 leather tanning and finishing. 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
Releases and Other Waste
Management Activity
Quantities
Figure 4-1. Release and Other Waste Management Activity Calculation Approach
-------
For EPCRA Section 313 purposes, "sources" means the streams or units that
generate the release and other waste management activity (such as process vents, container
residue, or spills) and "types" means 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 • Process discharge stream;
releases; • Process vents;
Air pollution control devices • Pumps;
(e.g., baghouses, electrostatic • Recycling and energy
precipitators, and scrubbers); recovery byproducts;
Clean up and housekeeping • Relief valves;
practices; • Stock pile losses;
Combustion byproducts; • Storage tanks;
Container residues; • Storm water runoff;
Fittings; • Tower stacks;
Flanges; • Transfer operations;
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Treatment sludge; • Waste treatment discharges.
Volatilization from process
or treatment; and
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 or chemical categories are
coincidentally manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals
and chemical categories typically used in the operations common to leather tanning and finishing.
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:
• 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
• Evaporative losses from solvent cleaning tanks, surface
impoundments, and spills; and
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
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 7C and 8.4)
Receiving Streams
(Part II, Sections
5. 3 and 8.1)
Underground Injection
I, Sections
and 8.1)
POTW
(Part II, Sections
6.1 and 8.1,or8.7)
Land on site (landfill,
land treatment,
surface impoundment)
(Part II, Sections
5.5 and 8.1)
Figure 4-2. Possible Release and Other Waste Management Activity Types1
for EPCRA Section 313 Chemicals and Chemical Categories
1 Sections refer to 1 999 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.
• Emissions from any other fugitive or non-point source.
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 paint
booths are often channeled through vapor recovery systems and/or air
pollution control devices. These 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
4-5
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associated with EPCRA Section 313 reporting, some state air quality
agencies consider ventilation systems to be a stack or point source.
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
4-6
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example, even if the chemical or chemical category is eventually
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
pigments used in coloring operations. Waste containing these pigments
may be present in spent filters or other waste generated from coloring
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
4-7
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must report the disposition of the waste solvent as appropriate. If the
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 or chemical categories 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 performed 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
discussion in 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 a study of liquid 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. No testing was conducted for residual solids
in this study. If data or site-specific knowledge is available to estimate the
quantity of solid residual in containers, it should be considered. If no data
are available, U.S. EPA believes an estimate of 1% residual solid is
reasonable.
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 Oile
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 or chemical category 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.
4-10
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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 %
[continued o
7A.le
Yes No
X
n next page]
4-11
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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.
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:
'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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§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal
only) - §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
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 and are considered to be
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
4-13
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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
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
4-14
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treatment includes physical removal from a waste stream. To
estimate the quantity treated, you should determine if operating
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 because of 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 leather tanning and
finishing 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. EPA has identified
four basic methods that may be used to develop estimates (each method has been assigned a code
that must be included when reporting). The methods and corresponding codes are:
4-16
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• 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.
4-17
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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
• New Source Performance Standards
• Outfall monitoring data
• pH for acids and bases
• POTW pretreatment standards
• RCRA permit
• Stack monitoring data
• 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 regulations. 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 is
available or if you believe the monitoring data are not representative, you must decide if another
estimation method would give a more accurate result.
4-18
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Example - Monitoring Data
Data from the on-site wastewater treatment facility indicate that the annual average concentration of chromium in
the discharge is 8 mg/L. The wastewater treatment facility processed 1.5 million gallons of water in the reporting
year. The treated wastewater is discharged to an off-site POTW. The amount of chromium transferred off site to
the POTW is estimated as follows:
Amount of chromium transferred
=(8 mg/L) x - - x - - x - - x (! 50o ooo gal/yr)
1,000 mgj ( 453.59 gj ( 0.2642 galj
= 100 Ib/yr
The 100 pounds per year of chromium transferred to the POTW should be reported in Part II, Sections 6.1 and
8.1 of the 1999 Form R.
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,
when nitrogen sources are used in biological wastewater treatment
systems, nitrate compounds and additional ammonia may be coincidentally
manufactured.
4-19
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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 leather coloring operation, for example,
pigments in the paint may leave the operation as part of the product (the
coating), in air emissions from a paint spray booth, and on paint spray
booth filters sent for disposal.
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 and chemical categories. It is typically most useful for otherwise used
chemicals or chemical categories 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.
Example - Mass Balance
A facility otherwise uses a volatile EPCRA Section 313 chemical as a refrigerant and adds 20,000 pounds to the
refrigeration system (to make up for system losses). The chemical is released to the air from relief vents, during
system filling operations, and from leaks in valves and fittings. During system maintenance, the lines are bled
directly into water and the system is vented to the air. Monitoring data of the wastewater, including chemical
concentrations and wastewater throughput, indicate that 1,200 pounds of the chemical were discharged to the
wastewater. 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 released to wastewater (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 in leather tanning and
finishing operations are classified as otherwise used. 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 releases 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 releases and other waste management quantities. Examples
applicable to leather tanning and finishing include triethylamine (CAS Registry No. 121-44-8) and some glycol
ethers.
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 factors, you should determine which is the 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
used must be reported in Column B as Code "O" - Engineering Calculations. Each chapter in
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Volume I covers a major industry or source category. Of special interest to leather tanning and
finishing facilities are Chapter 4: Evaporation Loss Sources (in particular Sections 4.2, Surface
Coating; and 4.3, Wastewater Collection, Treatment, and Storage), Chapter 6: Organic Chemical
Process Industry (in particular Section 6.18, Benzene, Toluene, and Xylenes), Chapter 7: Liquid
Storage Tanks, and Section 9.15, Leather Tanning..
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 Clearing House 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 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 No. 6 fuel oil is consumed:
0.024 to 0.061 Ib formaldehyde generated/103 gal No. 6 fuel oil fired.
Assuming a facility met reporting requirements for formaldehyde, the facility operating a boiler using No. 6 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. 6 fuel oil is used during a reporting year, the amount of
formaldehyde generated would be between:
(0.024 lb/103 gal) x (1,000,000 gal) and (0.061 lb/103 gal) x (1,000,000 gal)
= 24 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. 6 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 and 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 toluenel
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 leather coloring process uses 10,000 gallons per year of a paint that is 3% xylene by volume. All of the xylene
in the paint is assumed to evaporate during the coating operation. The coloring process is equipped with a fume
collection hood that captures 80% of the paint vapors. The remaining 20% of the paint vapors are assumed to be
released as fugitive air emissions. The collection hood routes the paint 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 paint)
(10,000 gal/yr paint) 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 coloring operations
2. The amount of xylene released as fugitive air emissions
(2,152 Ib/yr) x (0.20; twenty percent released as fugitive air emissions)
430 Ib/yr
This should be reported in Part II, Section 5.1 and 8.1 of the 1999 FormR.
3. The amount of xylene released as stack air emissions
(2,152 Ib/yr) x (0.80, eighty percent capture efficiency) x (1.0 - 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 worksheet 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 or chemical category in the treated waste stream,
and the concentration of the EPCRA Section 313 chemical or chemical category in the influent to
treatment. You should report treatment methods that do not actually destroy or remove the
chemical or chemical category 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
Facility Name:
Release and Other
Waste Management Quantity Estimation Worksheet
Date Worksheet Prepared:.
Prepared by:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
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, 8.6, 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 Quantities from
Leather Tanning and Finishing Operations
Leather tanning and finishing converts raw hides and skins into leather that has
thermal stability, is soft and flexible, and non-putrescible. Current leather tanning and finishing
operations involve many chemical and mechanical operations. The processes involved in leather
tanning and finishing will be discussed in five major groupings; detailed process flow diagrams
are presented in the subsequent discussion on each set of unit operations.
• Beamhouse operations - receiving and storage of hides, soaking,
unhairing, reliming, deliming, and bating;
• Tanyard operations - pickling, tanning, wringing, sorting, trimming,
siding, splitting, and shaving;
• Retanning. coloring and fatliquoring operations:
• Finishing operations - setting out, drying, conditioning, staking, dry
milling, buffing, finishing, plating, grading, and measuring; and
• Wastewater treatment - pre-treatment and treatment.
For discussion purposes, some of the individual process steps have been combined. Not all
leather tanning facilities will have all operations and facilities may vary in the sequence of
operations. You should analyze the process flow in your facility and prepare a site-specific
process flow diagram showing the individual operations present in your facility.
In 1995 the five EPCRA Section 313 chemicals and chemical categories most
commonly reported by facilities in SIC Code 3111 were chromium compounds, formic acid,
ammonia, certain glycol ethers, and chromium. Table 2-2 provides a complete list of EPCRA
Section 313 chemicals and chemical categories commonly reported by SIC Code 3111 facilities
in 1995.
Typical sources of release and other waste management activities of EPCRA
Section 313 chemicals and chemical categories in leather tanning facilities include wastewater
from several of the wet operations such as unhairing, deliming, tanning, wringing and sorting,
retanning, coloring, and fatliquoring. Various dry operations such as buffing and finishing
release air pollutants in dust form, while processes involving solvents may release volatile
organic chemicals (VOCs) and other chemicals to the air through evaporation. Scraps and
shavings from trimming, siding, splitting, shaving, buffing and finishing activities may contribute
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to solid wastes, along with shipping container residues. On-site wastewater treatment systems
that are typically observed at these facilities generate sludge that may contain EPCRA Section
313 chemicals or chemical categories.
Release and other waste management activity types for EPCRA Section 313
chemicals and chemical categories include stack and fugitive air, wastewater discharge either
direct to a receiving stream or off site to a POTW, and land or off-site disposal of solid wastes.
4.2.1 Beamhouse Operations
In a typical tannery, beamhouse operations begin when the raw hides are received
(generally fresh (green) hides are transported to the tannery in a refrigerated truck). They are
normally placed in a large, cool, well-ventilated storage facility. The hides usually have been
cured with a concentrated salt (sodium chloride) solution to prevent putrefaction. The hides are
sorted, weighed and assembled in packs for further processing. When the hides are ready for
processing they are soaked to remove the salt and restore the moisture. Wetting agents and
bactericides are typically added in the soaking step. After soaking, hair, epidermis, and soluble
proteins are removed from the hides by chemical and sometimes mechanical means. The final
step in the beamhouse operations is to remove residual unhairing chemicals and any remaining
non-leather making substances from the hides in the bating process. (Ref: Leather Facts, Third
Edition. New England Tanners Club, Peabody, MA. 1994.)
Anhydrous ammonia is a prevalent EPCRA Section 313 chemical in this industry.
There are two sources of aqueous ammonia in beamhouse operations. The first source is the
proteins removed in the soaking and unhairing steps which can be converted to ammonia. The
second source is the addition of ammonia salts, ammonium chloride and ammonium sulfate, in
the deliming step. In both cases the ammonia that is generated is considered to be the result of
the coincidental manufacturing of ammonia. Both operations take place in water and the
resulting ammonia would thus be considered aqueous ammonia as described in the U.S. EPA
publication, EPA 745-R-95-012, Emergency Planning and Community Right-to-Know, EPCRA
Section 313, Guidance for Reporting Aqueous Ammonia, (see Appendix D)
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Total aqueous ammonia is the sum of the two forms of ammonia, anhydrous
ammonia (NH3) and ammonium ion (NH4+). The amount of each form of ammonia found in a
solution of ammonia is a function of the pH and temperature of that solution.
The First Source of Ammonia - Unhairing and Liming
The high pH typically found in the unhairing and liming water solutions, pH
-12.0-12.6, will result in the predominant manufacture of aqueous ammonia in this step. A small
portion of aqueous ammonia involved in the process is released to the atmosphere as anhydrous
ammonia. The following information is quoted from the above ammonia guidance publication.
"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...
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 the aqueous ammonia released or transferred."
The Second Source of Ammonia-Addition of Ammonia Salts
The following information is quoted from the above ammonia guidance
publication.
"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 a facility dissolves a water dissociable salt in water that facility has
manufactured aqueous ammonia and 10 percent of the total aqueous ammonia manufactured
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from these salts is to be included in the manufacturing threshold determinations under the
ammonia listing."
For additional guidance please see the copy of the complete ammonia guidance
publication included as Appendix D to this document and the example in this section.
Step 1: Prepare a Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-3.
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Raw Hides
I
Receiving &
Storage
Soaking
Unhairing
& Liming
Ammonia
^ Fugitive Air
>• Discharge to Receiving Stream
>• Discharge to POTW
Reliming
Deliming
Ammonia ^|"
Discharge to Receiving Stream
Discharge to POTW
Bating
T
To Tanyard Operations
Figure 4-3. Process Flow - Beamhouse Operations
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The leather tanning industry typically uses only four bactericides: o-phenylphenol;
2-(thiocyanomethylthio)benzothiazole; diiodomethyl-p-tolyl sulfone; and
l,2-benzisothiazolin-3-one. Of those, the only EPCRA Section 313 chemical is o-phenylphenol,
a synonym for 2-phenylphenol, CAS Registry No. 90-43-7. Anhydrous ammonia may be
generated by the deamination of hide substances during unhairing, and ammonium sulfate and
ammonium chloride salts are used in deliming (see Appendix D for guidance on reporting for
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ammonia). Careful control of pH in beamhouse operations ensures that hydrogen sulfide is not
generated.
Typical sources of EPCRA Section 313 chemicals and chemical categories are
process wastewaters, evaporation of volatile compounds such as ammonia, and residues in
"empty" shipping containers.
Step 3: Identify Release and Other Waste Management Activity Types
Types of release and other waste management activities include wastewater
discharges, either direct to a receiving stream or indirect to a POTW, which may contain
bactericides and aqueous ammonia; fugitive emissions from volatilization (typically, only
anhydrous ammonia is expected); and on-site or off-site management of container residues,
which may result in the release or management of wastes that contain EPCRA Section 313
chemicals or chemical categories to on-site or off-site disposal, treatment, energy recovery, or
recycling, as appropriate. Note that if your facility has tannery-specific information that suggests
some of the ammonia remains in the finished product, this amount is not reportable as part of a
release or otherwise waste managed quantity; however, this information will be useful for the
mass balance approach to determine this quantity.
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
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. Pre-treatment permit compliance monitoring may provide information on
wastewater concentrations discharged to POTWs. Appendix B provides an example using
NPDES data for estimating the quantity of an EPCRA Section 313 chemical or chemical
category directly discharged in wastewater (the concepts of this example also apply to indirect
discharge to a POTW). The ammonia will partition itself between the wastewater and the sludge
during the treatment process. Amounts in each will be determined by analysis.
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The releases and waste management activities associated with anhydrous
ammonia are of particular concern for leather tanning and finishing operations, specifically
during hide deamination where anhydrous ammonia will be generated (and the subsequent
treatment of process water). Site-specific emission factors, or other standardized emission
factors for the industry, may be combined with estimates of the anhydrous ammonia that is
generated from the process, and the amount of anhydrous ammonia purchased to estimate the
fugitive air release and the discharges in wastewater. Appendix G presents emissions factors for
the hide deamination process from Leather Industry of America.
If EPCRA Section 313 chemicals or chemical categories are present in any
materials brought on site in containers, the liquid residues in empty shipping containers can be
estimated using the factors in Table 4-1. For dry materials a residue factor of 1% can be used if
actual data are not available (see Section 4.1.3.g for a complete discussion on container residue).
Example - Fugitive Anhydrous Ammonia Release Calculation
In this example the amount of anhydrous ammonia that is coincidentally manufactured and the amount released as
fugitive air emissions and discharged to a POTW in a leather tanning facility is estimated. Per engineering
judgement, the amount of ammonia generated is estimated to be 0.15% of the raw hide weight. Also, studies
indicated that approximately 3% of the ammonia generated at this facility will be volatilized and released to air.
Finally, it is known that 7% of the total ammonia generated and purchased remains with the final product.
A leather tanning facility receives an average of 15,000 brine-cured hides per week. Each brine-cured, pre-
fleshed hide weighs approximately 65 pounds. The facility operates 50 weeks per year. In addition, the facility
purchased and used 150,000 pounds of ammonia for deliming, neutralization, and dyeing. Using the ammonia
generation value of 0.15% of the raw hide weight, the total annual generation of ammonia is calculated to be:
Total ammonia generated:
= (15,000 hides/wk) x (50 wk/yr) x (65 Ib/hide) x (0.0015, 0.15%)
= 73,125 pounds ammoniaperyear
The total amount of ammonia dissolved in water is the amount generated plus the amount purchased:
= 73,125 pounds + 150,000 pounds
= 223,125 pounds peryear
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Amount Released to Air:
Per the assumed emission factor, 3% of the ammonia generated and purchased will volatilize as an air emission.
You must determine whether all, or some of this quantity should be partitioned between fugitive and stack air
releases. For this example, it is assumed that 100% of the air release is fugitive:
= (223,125 pounds) x (0.03, 3% factor)
= 6,694 pounds per year
The fugitive air releases of ammonia will occur primarily in the beamhouse because of the high pH, a range of
12.2 to 12.5, at which the unhairing operations are conducted. The addition of ammonium salts in the deliming
step rapidly drops the pH to around 8.5 and the release of ammonia to the atmosphere decreases to essentially
zero. Also, because of the pH at which typical wastewater treatment plants operate, pH near 7, there are expected
to be minimal if any fugitive air release of ammonia if an on-site wastewater treatment plant was used.
The fugitive air releases should be reported in Part II, Section 5.1 and included in Section 8.1 of the 1999 Form
R.
Amount Discharged to POTW:
7% of the ammonia generated and purchased remains with the final product. Using a mass balance approach, this
amount combined with the quantity released to air (calculated above) should be subtracted from the total
ammonia with the remainder being the quantity sent to the POTW.
Quantity remaining with product:
= (223,125 pounds) x (0.07, 7% factor)
= 15,619 pounds peryear
Quantity sent to POTW:
= (total ammonia generated and purchased) - (air emissions) - (ammonia in product)
= (223,125 pounds) - (6,694 pounds) - (15,619 pounds)
= 200,813 pounds peryear
This is the quantity of ammonia in solution that will be discharged to the POTW. As detailed in U.S. EPA's
guidance for reporting ammonia for EPCRA Section 313 (Appendix D), 10% of the aqueous ammonia is
considered to be reportable. Therefore, the quantity that should be reported in Part II, Section 6.1 (quantity
discharged to a POTW) and included in Section 8.7 (quantity treated off site) is:
= (200,813 pounds) x (0.01, 10%)
= 2,008 pounds per year
4.2.2 Tanyard Operations
The actual tanning of leather takes place in the tanyard operations. Salt and acid
are added in the pickling step to provide the low pH environment that will prepare the hides to
accept the tanning chemicals in the next step (note that some facilities consider deliming and
salting to be included as the first step, prior to pickling, of tanyard operations). Tanning converts
the hides into a stable, non-putrescible material. The industry commonly uses the chrome
tanning method in which the chrome tanning agent is introduced into a revolving drum
4-37
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containing the hides floating in brine. Following the application of the tanning chemicals the
excess moisture is removed, perimeter areas are trimmed to remove the less desirable material,
and the thickness is adjusted to uniform dimension suitable for the desired end use of the finished
leather (Ref: Leather Facts, Third Edition. New England Tanners Club, Peabody, MA. 1994).
Step 1: Prepare a Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-4.
From
Beamhouse
Operations
Pickling
1
r
Tanning
1
Wringing, Sorting
Trimming, Siding
Splitting, and Shav
Unfixed
Agents ! *" Discharge to Receiving Stream
'- +• Discharge to POTW
Container [ *• Off-Site Recycling
Residue fci to n r.-t nicnnc^l
' *• Off-Site Disposal
^_^ i > Fugitive Air
1 Chromium ] „.".,.
' Dust i *• Stack Air
' ] > On-Site Disposal
L ». off-Site Disoosal
To Retanning, Coloring, and
Fatliquoring Operations
Figure 4-4. Process Flow - Tanyard Operations
4-38
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The predominant EPCRA Section 313 chemicals and chemical categories
involved in tanyard operations are chromium and chromium compounds used in the tanning step
and formic acid used in the pickling step. Solutions of sulfuric acid and hydrochloric acid are
also used in pickling; however, only the acid aerosol forms of sulfuric and hydrochloric acids are
reportable (see Sections.1). Other EPCRA Section 313 chemicals that may be processed or
otherwise used include tetrachloroethylene, to degrease oil-tanned skins, and formaldehyde,
occasionally used as a pretannage. The latter has been largely replaced with glutaraldehyde.
There is also the possibility of coincidentally manufacturing anhydrous ammonia during pickling
and tanning operations.
Typical sources of EPCRA Section 313 chemicals and chemical categories are
process wastewaters, evaporation of volatile compounds, dust particles from trimming and
shaving operations, and residues in "empty" shipping containers.
Step 3: Identify Release and Other Waste Management Activity Types
Types of releases and other waste management activities include direct and
indirect wastewater discharges, which may contain aqueous ammonia, chromium, aluminum, or
formaldehyde; fugitive emissions from evaporation of any volatile EPCRA Section 313
chemicals or chemical categories; fugitive and stack emissions of dust containing chromium; and
on-site or off-site management of container residues and any dust collected in air pollution
control devices, which may result in the release or management of wastes that contain EPCRA
Section 313 chemicals or chemical categories to on-site or off-site disposal, treatment, energy
recovery, or recycling, as appropriate.
Note that any EPCRA Section 313 chemical or chemical category sent through a
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
4-39
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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.
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
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. Example 6 in Appendix B provides an example using NPDES data for estimating
the quantity of an EPCRA Section 313 chemical directly discharged in wastewater (the concepts
of this example also apply to indirect discharge to a POTW).
Volatile EPCRA Section 313 chemicals and chemical categories, not intended to
remain with the product, e.g., tetrachloroethylene used as a degreasing agent, can be assumed to
be 100% released as either fugitive or stack emissions, as appropriate, after subtracting any
potential container residue. Liquid residues in the shipping containers can be estimated using
the factors in Table 4-1. For dry materials a residue factor of 1% can be used if actual data are
not available (see Section 4.1.3.g for a complete discussion on container residue).
See Section 4.2.1 and Appendix D for a more detailed discussion of ammonia, if
applicable.
Example - Chromium Release and Other Waste Management Activities
In this example mass balance and engineering calculation methods are used to estimate the release and other
waste management quantities of chromium.
On January 1 of the reporting year your facility had in its inventory three hundred and fifty, 5 5-gallon steel drums
containing a 15% (on the basis of Cr2 O3) solution of chromium sulfate. During the year your facility purchased
2,250 drums and on 31 December 600 drums remained in the inventory. The solution is poured out of the open-
top drums, and the "empty" drums returned to the supplier to be refilled and sold again to your facility. The
solution has physical properties, including density, similar to water.
[continued on next page]
4-40
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[continued from previous page]
Threshold Determination
The first step is to determine if your facility has exceeded the processing threshold of 25,000 pounds per year for
EPCRA Section 313 reporting. To do so, calculate the amount of chromium compound, in the form of the 15%
solution of chromium sulfate, processed by your facility during the reporting year. If other facility operations use
chromium compounds such as certain pre-metallized dyes, you must include that amount in any threshold
determinations and release and other waste management quantity estimates. Keep in mind that it is the weight of
the metal compound that is used for the threshold determination, while only the weight of the parent metal is
estimated in the release and other waste management calculations.
The amount of chromium compound used at the facility during the reporting year is:
(350 + 2,250 - 600 drums) x (55 gal/drum) x (8.34 Ib/gal, density of water) x
(0.15, 15%Cr2O3)
= 137,610 pounds chromium compound (as Cr2O3).
This exceeds the 25,000 pounds per year threshold for reporting the processing of an EPCRA Section 313
chemical or chemical category. Thus, you must now determine the quantities of chromium released and or
otherwise waste managed. The atomic weight of chromium is 52, the atomic weight of oxygen is 16, and the
molecular weight of Cr2 O3 is 152.
The amount of chromium processed at the facility is:
(137,610 pounds Cr compound) x (104/152, weight of chromium/weight of Cr2O3)
= 94,154 pounds chromium.
Now you must determine how to calculate the estimates for the release and other waste management activity
quantities to be reported. Consider the ways in which chromium leaves your facility:
• As a component of the final product, including the product itself and the leather dusts, shavings,
and other scraps generated in the manufacture of the final product;
• In the residue in the "empty" shipping containers returned to the supplier; and
• In the liquid effluent and sludge solids from the wastewater treatment plant.
Leather product
Based on process knowledge, you estimate that 80% of the chromium is taken up into the leather:
(0.80) x (94,154 Ib/yr total Cr) = 75,323 pounds of chromium.
You also estimate that 5% by weight of the leather is lost in the form of dust and scraps in finishing the leather.
The dust and scraps are sold to a fertilizer manufacturer for direct reuse. Thus, the entire amount of chromium
taken up in the leather, 75,323 pounds, is sold in commerce. You do not have to report it on the Form R.
"Empty" shipping containers
According to Table 4-1, an average of 0.034% of a liquid with water characteristics remains as the residue in an
open-top steel drum, unloaded by pouring. The amount of chromium returned to the supplier in the "empty"
drums can be estimated as:
(0.00034) x (94,154 Ib/yr total Cr) = 32 pounds of chromium returned to the supplier.
[continued on next page]
4-41
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[continued from previous page]
If you know that the drums are refilled and returned to you without being cleaned or otherwise managed, your
facility should not report this amount as a release or other waste management activity on the Form R. However, if
they are cleaned, this quantity should be reported as being sent off site for disposal, treatment, energy recovery, or
recycling, as appropriate.
The liquid effluent from your facility wastewater treatment plant discharges directly to a receiving stream while
the sludge from the plant is disposed on site in a RCRA Subtitle C landfill. The SPDES permit for the effluent
requires monitoring for, among other items, flow and chromium concentration. The flow was 150,000,000
gallons for the reporting year and the chromium content averaged 0.75 ug/L.
Wastewater treatment plant
The amount of chromium in the liquid effluent is:
(150,000,000 gal/yr) x (0.75 ug/L Cr concentration) x (10E-9 kg/ug) x (2.2 Ib/kg) x (3.78 L/gal)
= 0.9 pounds chromium in the liquid effluent.
This quantity should be reported in Part II, Sections 5.3 and 8.1 of the 1999 FormR.
You can now use a mass balance to determine the amount of chromium in the wastewater treatment plant sludge:
(94,154 Ib total Cr) - (75,323 Ib Cr in leather) - (32 Ib Cr in residue) - (0.9 Ib Cr in effluent)
= 18,798.1 pounds chromium in sludge.
This should be reported in Part II, Sections 5.5.1A and 8.1 of the 1999 Form R.
Note that this quantity is also the amount that was removed from the wastewater stream in your on-site wastewater
treatment system. Therefore, Part II, Sections 7 and 8.6 should also be completed. The quantity reported in
Section 8.6 should be the amount actually destroyed and for the purposes of EPCRA Section 313 reporting metals
cannot be destroyed. Therefore, you must complete Section 7 (with the appropriate removal efficiency of 100%
in this case) and enter zero in Section 8.6 as the quantity destroyed (see the example for On-Site Treatment in
Section 4.1.3 for further discussion).
4.2.3 Retanning, Coloring and Fatliquoring
Retanning, coloring, and fatliquoring make the physical properties of the leather
match the desired end use of the finished product. In the retanning process several tanning
agents may be combined to achieve a certain leather quality. Dyes may be added to achieve the
desired color. The fatliquoring process involves the use of oils and waxes to lubricate the
collagen fibers to produce the flexibility and softness needed for the final leather product (Ref:
Leather Facts, Third Edition. New England Tanners Club, Peabody, MA. 1994).
4-42
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Step 1: Prepare a Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-5.
" Discharge to Receiving Strean
•• Discharge to POTW
•-*• Off-Site Recycling
--»• On-Site Disposal
-->• Off-Site Disposal
• Discharge to Receiving Strean
• Discharge to POTW
>• Fugitive Air
Crust Leather To
Finishing Operations
' Dyes and Pigments - may include chromium, copper or cobalt, compounds;
C.I. Acid Green 3 and C.I. Acid Red 114
Figure 4-5. Process Flow - Retanning, Coloring, and
Fatliquoring Operations
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
lanyard operations may use the following EPCRA Section 313 chemicals and
chemical categories: formaldehyde, formic acid, sulfuric acid (only an EPCRA Section 313
chemical in acid aerosol form), chromium compounds, copper compounds, cobalt compounds, 2-
phenylphenol, C.I. Acid Green 3, C.I. Acid Red 114, and xylene.
4-43
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Resins such as melamine, used to retan leather, may contain formaldehyde.
Synthetic tanning agents may also contain formaldehyde used to polymerize sulfonated phenols
to synthesize the syntans. While a residual amount of free formaldehyde is sometimes present in
these products, the formaldehyde usually combines with the leather, rather than being released.
A minority of tanners may still occasionally use formaldehyde as a retanning agent (e.g. chamois
producers), but the industry has phased out its use and replaced it with alternatives, such as
glutaraldehyde.
Chromium compounds can also be found in the mineral tanning agents and the
pre-metallized dyes. The pre-metallized dyes may sometimes also be based on copper or cobalt.
Most of the dye is absorbed into the leather. Other EPCRA Section 313 chemicals include
2-phenylphenol which functions as a fungicide in these operations; the two dyes, C.I. Acid Green
3 and C.I. Acid Red 114, which are not commonly used in leather manufacturing facilities but
may be used by some facilities for coloring processes; and xylene, which may be used as a
solvent for the application of silicone and fluorocarbon polymers in the fatliquoring operation.
Typical sources of EPCRA Section 313 chemicals and chemical categories are
process wastewaters, fugitive air emissions from evaporation of volatile compounds, and
residues in "empty" shipping containers.
Step 3: Identify Release and Other Waste Management Activity Types
Types of release and other waste management activities are similar to those
presented in beamhouse and tanyard operations. They include direct or indirect discharges to a
receiving stream or to a POTW; fugitive air emissions from evaporation of any volatile materials
such as xylene used as a solvent; and on-site or off-site management of container residues, which
may result in the release and other waste management of EPCRA Section 313 chemicals or
chemical categories to on-site or off-site disposal, treatment, energy recovery, or recycling, as
appropriate.
4-44
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Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
After identifying the sources and types of EPCRA Section 313 chemicals and
chemical categories, the method(s) used to estimate the quantities released or otherwise managed
as waste from retanning, coloring, and finishing operations are identical to those previously
discussed.
Monitoring data gathered for on-site wastewater treatment plant operating permits
and/or NPDES permit requirements can generally provide flow data and wastewater
concentrations that can be used to estimate quantities of EPCRA Section 313 chemicals and
chemical categories directly discharged to receiving streams or indirectly discharged to POTWs.
Volatile EPCRA Section 313 chemicals and chemical categories, not intended to
remain with the product, e.g., xylene used as a solvent, can be assumed to be 100% released as
either fugitive or stack emissions, as appropriate after subtracting any potential container residue.
2-butoxyethanol, propoxyethanol, and diethylene glycol monomethyl ether are examples of
certain glycol ethers that may also be applicable. Liquid residues in shipping containers can be
estimated using the factors in Table 4-1. For dry materials a residue factor of 1% can be used if
actual data are not available (see Section 4.1.3.g for a complete discussion on container residue).
4.2.4 Finishing Operations
Finishing operations may be comprised of several steps designed to achieve the
desired end use physical properties and dimensions of the final leather. The steps may include
achieving the proper level of residual moisture, mechanical softening, smoothing/buffing the
surface and imparting the desired grain pattern, grading, and measuring and cutting patterns to fit
customer specifications (Ref: Leather Facts, Third Edition. New England Tanners Club,
Peabody, MA. 1994).
4-45
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Step 1: Prepare a Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-6.
From Retanning,
Coloring, and
Fatliquoring Operations
Conditioning,
Staking, Dry Milling,
and Buffing
' ^ Fugitive Air
Chromium !
Dust I K Stack Air
i ^-On-site Disposal
L >. off-Site Disposal
Plating, Grading
& Measuring
Solvents
Plastizicers .
& Crosslinkers^; * Fugitive Air
'—-K Stack Air
> Off-Site Recycling
»-On-Site Disposal
^- Off-Site Disposal
Finished Leather
Product
Glycol ethers
Triethylamine
Methyl ethyl ketone
Methyl isobutyl ketone
Toluene
Xylene
Naphthalene
Methyl alcohol (methanol)
Ethyl alcohol
N-methyl-2-pyrrolidone
Propoxyethanol
Butoxyethanol
Plasticizers
Dibutyl phthalate and other phthalates
N-methyl-2-pyrrolidone
Cross Linkers
Methyl diphenyl diisocyanate
Toluene diisocyanate
Hexamethylene-1,6-diisocyanate
Figure 4-6. Process Flow - Finishing Operations
4-46
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Leather dust containing chromium may be generated in some of the unit
operations during finishing. Formaldehyde may be used to crosslink casein-based finishing
formulations in the production of glazed leather. The other EPCRA Section 313 chemicals and
chemical categories that may be used in finishing operations serve as solvents, plasticizers, or
crosslinkers, and are listed in the process flow diagram. According to the Leather Industries of
America, a range of leather finishing formulations use propylene glycol and other glycol ethers
based on propylene glycol, which are not included in the Certain Glycol Ether category as
defined in EPCRA Section 313; however, other glycol ethers used by the leather industry are
included in the Certain Glycol Ether category. You should review the EPCRA Section 313
guidance presented in Appendix F if any glycol ethers are used at your facility.
Typical sources of EPCRA Section 313 chemicals and chemical categories
include the generation of dusts containing chromium or chromium compounds; evaporation of
volatile compounds, particularly solvents and plasticizers used in the final finishing steps; and
residues in "empty" shipping containers.
Step 3: Identify Release and Other Waste Management Activity Types
Typically, fewer release and other waste management types are expected during
finishing operations, compared to other processes. The expected types include fugitive and stack
air releases of dusts and any volatile materials, and on-site or off-site management of container
residues and any dusts collected in air pollution control devices, which may result in the release
and other waste management of EPCRA Section 313 chemicals or chemical categories to on-site
or off-site disposal, treatment, energy recovery, or recycling, as appropriate. Note that any
EPCRA Section 313 chemical or chemical category sent through a 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
4-47
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to another chemical or it is not HC1 or H2SO4 acid aerosols. The capture efficiency of the unit
should be reported in Section 7A and the quantity captured should be reported in Sections 6
and/or 8 depending on the final disposition of the chemical or chemical category. Wastewater is
not typically generated in finishing operations.
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 finishing operations are very volatile. One can
assume that all of the applied amount will evaporate and 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 activities. Potential container
residue quantities can be estimated as discussed in Section 4.1.3(g). The total amount released
can be estimated using a mass balance approach based on purchasing records and beginning and
end-of-year facility inventory amounts.
If dust containing EPCRA Section 313 chemicals or chemical categories is
generated (typically chromium) it may be collected in a fabric filter (baghouse). If so, quantities
of chromium passing through the baghouse should be estimated as stack emissions, and the
quantity collected should be reported based on the method used to manage the waste dust. Also,
use of the baghouse (an air pollution control device) is considered on-site treatment. Therefore,
Part II, Section 7A and 8.6 of the 1999 Form R should be completed as appropriate. Section
4.1.3(h) presents an example for on-site treatment.
Dusts and trim scraps are typically sold and weighed and the chromium
concentration is expected to be the same as in the finished product. If sold, this quantity does not
have to be reported, but should be considered in mass balance calculations when determining
releases and other waste management quantities. If disposed or otherwise managed as waste, the
quantity of EPCRA Section 313 chemical or chemical compound should be reported or
approximated with estimates based on the mass disposed multiplied by the concentration.
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4.2.5 Wastewater Treatment
Many leather tanning facilities operate their own wastewater treatment plants,
some with direct discharge to receiving streams and some with indirect discharge to a POTW.
The incoming wastewater is characterized by high biochemical oxygen demand (BOD) and total
suspended solids (TSS) content. In many cases the chromium and other heavy metals are
removed by pre-treatment using high pH liquors from beamhouse operations to precipitate the
metals. Direct discharge permits (NPDES/SPDES) or POTW influent specifications typically
establish limits for chromium, sulfides, pH, nitrates, BOD, and TSS.
Step 1: Prepare a Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-7.
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Wastewater
Pretreatment
Sludge- ,
Chromium
Compounds
^
—> On-Site Disposal
—> On-Site Treatment
—^Off-Site Disposal
—>• Off-Site Treatment
Wastewater
Treatment
Plant
Volatiles
-> *• Fugitive Air
Water-
Ammonia
Nitrate Compounds
Chromium Compounds
Discharge to Receiving Stream
> Discharge to POTW
On-Site Disposal
Sludge- r—
Chromium ]
Compounds i >• On-Site Treatment
] > Off-Site Disposal
L ^ Off-Site Treatment
Figure 4-7. Process Flow - Wastewater Treatment
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Manganese sulfate, phosphoric acid, ammonia, chlorine, chlorine dioxide,
chromium, and chromium compounds are some of the EPCRA Section 313 chemicals and
chemical categories found in leather tanning and finishing wastewater treatment operations. The
wastewater treatment system may use manganese sulfate as a catalyst for sulfide oxidation, while
phosphoric acid may be used as a nutrient source in the biological treatment process. Both would
be classified as otherwise used under EPCRA Section 313. Chromium and chromium
compounds from the facility process operations may pass through the system and are found in the
wastewater effluent and sludges. Ammonia and nitrate compounds can be coincidentally
manufactured in biological treatment systems when proteins break down. Ammonia may also be
added as a metabolic nitrogen source for the microbes. Chlorine and chlorine dioxide are used
for effluent disinfection.
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Typical sources of EPCRA Section 313 chemicals and chemical categories are
treatment system effluents, evaporation of volatile compounds, and residues in "empty" shipping
containers.
Step 3: Identify Release and Other Waste Management Activity Types
Types of release and other waste management activities include direct discharge
to receiving streams, indirect discharges to POTWs, fugitive air emissions from evaporation of
any volatile materials, and on-site or off-site management of container residues (typically
phosphoric acid and treatment system nutrients) and sludges, which may result in the release or
management of wastes that contain EPCRA Section 313 chemicals or chemical categories to on-
site or off-site disposal, treatment, energy recovery, or recycling, as appropriate.
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
As discussed in Step 4 of previous sections (and in example 6 of Appendix B),
monitoring data gathered for direct discharge permits and POTW influent specifications can
provide flow data and concentrations of EPCRA Section 313 chemicals and chemical categories
in the wastewater entering and leaving the wastewater treatment system. Also, liquid residues in
shipping containers can be estimated using the factors in Table 4-1. For dry materials a residue
factor of 1% can be used if actual data are not available (see Section 4.1.3.g for a complete
discussion on container residue).
The quantity of anhydrous ammonia that is coincidentally manufactured should be
applied to both the 25,000-pound manufacturing threshold as well as the 10,000-pound otherwise
use threshold (assuming it is consumed as a metabolic nitrogen source). However, beginning
with reporting year 1994, U.S. EPA revised the ammonia listing as follows: "ammonia (includes
anhydrous ammonia and aqueous ammonia from water dissociable salts and other sources; 10%
of total aqueous ammonia is reportable under this listing)." Appendix D contains the U.S. EPA
published guidance for reporting ammonia and ammonium salts.
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COMMON ERROR - Reporting
A common error in wastewater treatment is the failure to report the ammonia that may be coincidentally
manufactured as a byproduct during the treatment process. Other reportable chemicals also may be coincidentally
manufactured during such treatments depending upon the chemicals present.
U.S. EPA has also provided guidance on reporting for the nitrate compounds
category. This guidance is presented in Appendix C.
The quantity of phosphoric acid or any other EPCRA Section 313 chemical that is
added as a nutrient should be applied to the 10,000-pound otherwise use activity threshold. If
any threshold is exceeded, an EPCRA Section 313 report should be completed. However, if the
pH of the effluent from the wastewater treatment system is between 6 and 9, U.S. EPA considers
the mineral acid to be neutralized and zero discharge to the POTW or receiving stream should be
reported. Please note that even if all release and other waste management quantities are zero, an
EPCRA Section 313 report must still be completed. In such instances, you may be eligible to
complete an alternate certification statement (Form A).
Finally, emission factors for volatile EPCRA Section 313 chemicals from
wastewater treatment plants are available in Chapter 4.3 of AP-42.
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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.
Data Quality Checks to Prevent Common Reporting Errors on Form R/A (EPA 745-R-98-012).
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-98-004).
A-l
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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,
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.
A-2
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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.
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/By-products (EPA 745-B-00-014)
Electricity Generating Facilities. January 1999 (EPA 745-B-99-003)
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 Industry. April 2000 (EPA 745-B-00-012)
Metal Working and Electroplating Operations. April 2000 (EPA 745-B-00-015)
Metal Mining Facilities. January 1999 (EPA 745-B-99-001)
Monofilament Fiber Manufacture (EPA 745-B-00-013)
Pulp. Paper, and Paperboard Production (EPA 745-B-00-010)
Petroleum Terminals and Bulk Storage Facilities. January 1999 (EPA 745-B-99-006)
Presswood & Laminated Wood Products Manufacturing
Printing Industry. April 2000 (EPA 745-B-00-005)
RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities. January 1999 (EPA 745-B-99-
004)
Rubber and Plastics Manufacturing. April 2000 (EPA 745-B-00-017)
Semiconductor Manufacture. July 1999 (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 Operations (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.
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)
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)
A-5
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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
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.
Kirk Othmer - Encyclopedia of Chemical Technology. Latest Edition, John Wiley & Sons, New
York.
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.
Sax, N.I. and R. J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van
Nostrand Reinhold Company, New York.
A-6
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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
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( 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
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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
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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
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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
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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
LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING
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United States
Environmental Protection
Agency
Office of Pollution Prevention and
Toxics
Washington, DC 20460
Revised May 1996
EPA 745-R-96-004
TOXICS RELEASE INVENTORY
List of Toxic Chemicals Within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting
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 Chemicals within the Water Dissociable Nitrate Compounds Category C-3
1.4 De Minimis Concentrations C-3
Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category C-4
2.1 Chemicals within the Water Dissociable Nitrate Compounds Category C-4
2.2 Determining Threshold and Release Quantities for Nitrate Compounds C-4
2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid C-5
2.3.1 Estimating Nitric Acid Releases C-6
2.3.2 Estimating Treatment Efficiencies for Nitric Acid
Neutralization C-8
2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid C-9
2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment . . C-10
Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category C-l 1
C-l
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Section 1. Introduction
On November 30, 1994 EPA added 286 chemicals and chemical categories, which
include 39 chemicals as part of two delineated categories, to 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. These additions are described at 59 FR 61432, and are
effective January 1, 1995 for reports due July 1, 1996. Six chemical categories (nicotine and
salts, strychnine and salts, polycyclic aromatic compounds, water dissociable nitrate compounds,
diisocyanates, and polychlorinated alkanes) are included in these additions. At the time of the
addition, EPA indicated that the Agency would develop, as appropriate, interpretations and
guidance that the Agency determines are necessary to facilitate accurate reporting for these
categories. This document constitutes such guidance for the water dissociable nitrate compounds
category.
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
thresholds quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
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.
C-2
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EPCRA Section 313 requires threshold determinations for chemical categories to
be based on the total of all chemicals in the category manufactured, processed or otherwise used.
For example, a facility that manufactures three members of a chemical category would count the
total amount of all three chemicals manufactured towards the manufacturing threshold for that
category. When filing reports for chemical categories, the releases are determined in the same
manner as the thresholds. One report is filed for the category and all releases are reported on this
form.
Section 1.3 Chemicals Within the Water Dissociable Nitrate Compounds Category
EPA is providing a list of CAS numbers and chemical names to aid the regulated
community in determining whether they need to report for the water dissociable nitrate
compounds category. The list includes individual chemicals within the water dissociable nitrate
compounds category. If a facility is manufacturing, processing, or otherwise using a chemical
which is on this list, they must report this chemical. However, this list is not exhaustive. If a
facility is manufacturing, processing, or otherwise using a water dissociable nitrate compound,
they must report the chemical, even if it does not appear on the list.
Section 1.4 De Minimis Concentrations
The water dissociable nitrate compounds category is subject to the one percent de
minimis concentration. Thus, mixtures that contain members of this category in excess of the de
minimis should be factored into threshold and release determinations.
C-2
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Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category
Note: for the purposes of reporting under the nitrate compounds category, water
dissociable means that the nitrate ion dissociates from its counterion when in solution.
Section 2.1 Chemicals within the Water Dissociable Nitrate Compounds Category
Chemicals within the nitrate compounds category are only reportable when in
aqueous solution. All water dissociable nitrate compounds are included in the nitrate compounds
category, including ammonium nitrate. Specifically listed EPCRA Section 313 chemicals are
not included in threshold determinations for chemical categories such as the water dissociable
nitrate compounds category. Specifically listed toxic chemicals are subject to their own
individual threshold determinations. As of December 1, 1994, ammonium nitrate (solution) is
not an individually listed chemical on the EPCRA Section 313 list. However, ammonium nitrate
is still subject to reporting under the nitrate compounds category. In addition, the aqueous
ammonia from the dissociation of ammonium nitrate when in aqueous solution is subject to
reporting under the ammonia listing.
Section 2.2 Determining Threshold and Release Quantities for Nitrate Compounds
The total nitrate compound, including both the nitrate ion portion and the
counterion, is included in the nitrate compounds category. When determining threshold amounts,
the total weight of the nitrate compound is to be included in all calculations. However, only the
nitrate ion portion is to be included when determining the amount of the chemicals within the
nitrate compounds category that is released, transferred, or otherwise managed in wastes.
Example 1: In a calendar year, a facility processes 100,000 pounds of ammonium nitrate
(NH4NO3), in aqueous solution, which is released to wastewater streams then transferred to a
POTW. The quantity applied towards threshold calculations for the nitrate compounds
category is the total quantity of the nitrate compound or 100,000 pounds. Since this quantity
exceeds the 25,000 pound processing threshold, the facility is required to report for the nitrate
compounds category. Under the nitrate compounds category, only the weight of the nitrate ion
portion of ammonium nitrate is included in release transfer calculations. The molecular
weight of the ammonium nitrate is 80.04 and the weight of the nitrate ion portion is 62.01 or
77.47 percent of the molecular weight of ammonium nitrate. Therefore, the amount of nitrate
ion reported as transferred to the POTW is 77.47 percent of 100,000 pounds or 77,470 pounds
(reported as 77,000 pounds). The aqueous ammonia from ammonium nitrate is reportable
under the EPCRA Section 313 listing for ammonia. For determining thresholds and
calculating releases under the ammonia listing, see the separate directive, Guidance for
Reporting Aqueous Ammonia (EPA document #745-R-95-0003, July 1995).
C-4
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Example 2: In a calendar year, a facility manufactures as by-products 20,000 pounds of
sodium nitrate (NaNO3) and 10,000 pounds of calcium nitrate (Ca(NO3)2), both in aqueous
solutions, and releases these solutions to wastewater streams. The total quantity of nitrate
compounds manufactured by the facility is the sum of the two chemicals, or 30,000 pounds,
which exceeds the manufacturing threshold quantity of 25,000 pounds. The facility therefore
is required to report for the nitrate compounds category. By weight, the nitrate ion portion is
72.96 percent of sodium nitrate and is 75.57 percent of calcium nitrate. Of the 20,000 pounds
of the sodium nitrate in solution, 72.96 percent or 14,592 pounds is nitrate ion, and similarly,
of the 10,000 pounds of the calcium nitrate in solution, 75.57 percent or 7,557 pounds is
nitrate ion. The total nitrate ion in aqueous solution released by the facility is the sum of the
nitrate ion in the two solutions or 22,149 pounds (reported as 22,000 pounds).
Section 2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid
Nitric acid is an individually listed chemical on the original EPCRA Section 313
list and is reported as a separate chemical if the manufacture, process, or otherwise use thresholds
are exceeded. The partial or complete neutralization of nitric acid results in the formation of
nitrate compounds which are reported as chemicals within the nitrate compounds category if their
manufacture, process, or otherwise use thresholds are exceeded.
Mineral acids such as nitric acid may be present in aqueous waste streams that are
sent to on-site neutralization or are discharged to a publicly owned treatment works (POTW) or
other off-site treatment facility. As stated in the Toxic Chemical Release Inventory Reporting
Form R and Instructions document (revised 1993 version, EPA 745-K-94-001), on-site acid
neutralization and its efficiency must be reported in Part II, section 7 A of Form R (waste
treatment methods and efficiency section). For purposes of reporting on Form R, EPA considers
a waste mineral acid at a pH 6 or higher to be 100 percent neutralized (water discharges to
receiving streams or POTWs are reported as zero). The nitrate compounds produced from the
complete neutralization (pH 6.0 or above) of nitric acid are reportable under the nitrate
compounds category and should be included in all threshold and release calculations. Two Form
R reports would be required if the manufacture, process or otherwise use thresholds are exceeded
for nitric acid and for the nitrate compounds category.
If the nitric acid treatment efficiency is not equal to 100 percent (pH is less than
6), the amount of the acid remaining in the waste stream which is released to the environment on-
site or off-site must be reported in Part n of Form R. The nitrate compounds produced from the
partial neutralization of nitric acid are reportable under the nitrate compounds category and
should be included in all threshold and release calculations. Two reports would again be
required if the manufacture, process or otherwise use thresholds are exceeded for nitric acid and
for the nitrate compounds category.
C-5
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Section 2.3.1 Estimating Nitric Acid Releases
The pH of the waste stream can be used to calculate the amount of nitric acid in
the stream and the efficiency of neutralization. The pH is a measure of the acidity or alkalinity of
a waste stream and can be obtained readily using a pH meter or pH sensitive paper. The pH scale
itself varies from 0 to 14.
The total nitric acid concentration (ionized and un-ionized) in pounds per gallon
can be calculated by using the pH value of the solution, the molecular weight and ionization
constant of the acid, and appropriate conversion factors. The total acid concentration for nitric
acid for different pH values is listed in Table 1. The calculation of mineral acid concentrations
and the derivation of Table 1 are discussed in a separate directive, Estimating Releases for
Mineral Acid Discharges Using pH Measurements., and an addendum to this directive.
The procedure outlined in this guidance document for calculating the quantity of
nitrate compounds formed from the complete or partial neutralization of nitric acid can be used if
nitric acid is the only mineral acid in a solution. In addition, the calculation of nitric acid
releases using only pH measurements is a rough estimate. The subsequent calculation of nitrate
compound releases is therefore also only a rough estimate. The estimates can be made for a
waste stream with a steady pH below 6 or for one whose pH temporarily drops to below pH 6.
Facilities should use their best engineering judgement and knowledge of the solution to evaluate
how reasonable the estimates are.
Example 3: In a calendar year, a facility transfers 1.0 million gallons of a solution containing
nitric acid (HNO3), at pH 4, to a POTW. Using Table 1 (next page), a pH of 4 corresponds to
a concentration of 0.0000520 Ibs HNO3/gallon of solution. The weight of HNO3 transferred
can be estimated using the equation:
Transfer of HNO3 = (Concentration of HNO3) x (effluent flow rate)
Substituting the example values into the above equation yields:
Transfer of HNO3 = 0.0000520 Ibs/gal HNO3 x 1,000,000 gal solution/year = 52 Ibs/year
Example 4: A facility had an episodic release of nitric acid (HNO3) in which the waste stream
was temporarily below pH 6. During the episode, the wastewater (pH 2.0) was discharged to a
river for 20 minutes at a rate of 100 gallons per minute. Using Table 1, a pH of 2.0 for HNO3
represents a concentration of 0.0052000 Ibs HNO3/gallon of solution. The amount of the
HNO3 released can be estimated using the following equation:
Release of HNO3 = (concentration of HNO3) x (effluent flow rate)
Substituting the example values in the above equation:
Release of HNO3 = 0.0052000 Ibs/gal x 100 gal/min x 20 min
= 10 Ibs
C-6
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Table C-l
Nitric Acid Concentration Versus pH
pH
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
Nitric Acid Concentration
(Ibs/gallon)
0.5200000
0.3300000
0.2100000
0.1300000
0.0830000
0.0520000
0.0330000
0.0210000
0.0130000
0.0083000
0.0052000
0.0033000
0.0021000
0.0013000
0.0008300
pH
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
4.8
5.0
5.2
5.4
5.6
5.8
6.0
Nitric Acid Concentration
(Ibs/gallon)
0.0005200
0.0003300
0.0002100
0.0001300
0.0000830
0.0000520
0.0000330
0.0000210
0.0000130
0.0000083
0.0000052
0.0000033
0.0000021
0.0000013
0.0000008
0.0000005
Section 2.3.2 Estimating Treatment Efficiencies for Nitric Acid Neutralization
Nitric acid solutions that are neutralized to a pH of 6 or above have a treatment
efficiency of 100 percent. If nitric acid is neutralized to a pH less than 6, then the reportable
treatment efficiency is somewhere between 0 and 100 percent. It is possible to estimate the
neutralization treatment efficiency using nitric acid concentration values directly from Table 1 in
the equation given below. The concentrations correspond to the pH values before and after
treatment.
(I-E)
Treatment efficiency = —;—X 100
where:
I
E
Acid concentration before treatment; and
Acid concentration after treatment.
C-7
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Example 5: A nitric acid (HNO3) waste stream of pH 2.4 is neutralized to pH 4.6. Using
Table 1, the initial nitric acid concentration is 0.0021000 mol/liter and the final concentration
is 0.0000130 mol/liter. Substituting these values into the equation for treatment efficiency:
(0.0021000-0.0000130)
Treatment Effunency = - - x 100
= 99.4 percent
For strong acids only (including nitric acid), the net difference in pH before and
after treatment can be used to estimate the treatment efficiency since pH is directly proportional
to the acid concentration. For example, a pH change of one unit results in a treatment efficiency
of 90 percent, whether the pH change is from pH 1 to pH 2 or from pH 4 to pH 5. Table 2
summarizes treatment efficiencies for various pH changes (the pH change is the difference
between the initial pH and the pH after neutralization). In the table, some pH changes result in
the same treatment efficiency values due to rounding to one decimal place.
-------
Table C-2
Nitric Acid Treatment Efficiencies for Various pH Changes
pH Unit Change
1.0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
Treatment Efficiency
(%)
90.0
92.1
93.7
95.0
96.0
96.8
97.5
98.0
98.4
98.7
pH Unit Change
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
3.0
Treatment Efficiency
(%)
99.0
99.2
99.4
99.5
99.6
99.7
99.8
99.8
99.8
99.9
99.9
Example 6: If a nitric acid (HNO3) waste stream of pH 2 is treated to pH 4, the pH change is 2
units. Using Table 2 above, the treatment efficiency is given as 99.0 percent.
Section 2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid
The nitrate compounds produced from the complete neutralization (pH 6.0 or
above) or partial neutralization (pH less than 6) or nitric acid are reportable under the nitrate
compounds category if the appropriate threshold is met and should be included in all threshold
and release calculations. In order to determine the quantity of a nitrate compound generated and
released, the quantity of nitric acid released must be known (or calculated from the equations
used in Examples 3 and 4 above) as well as the nitric acid treatment efficiency (calculated from
the equations used in Examples 5 and 6 above).
The neutralization of nitric acid will most likely result in the generation of
monovalent nitrate compounds (such as sodium nitrate and potassium nitrate). The quantity of
these compounds formed in kilomoles will be equal to the quantity of the nitric acid neutralized
in kilomoles. If divalent nitrate compounds are formed (such as calcium nitrate), the quantity of
these compounds formed in kilomoles will be equal to one-half the quantity of the nitric acid
neutralized in kilomoles. Similarly, if trivalent nitrate compounds are formed (such as iron (HI)
nitrate), the quantity formed of these compounds in kilomoles will be equal to one-third the
quantity of the nitric acid neutralized in kilomoles. Note: to calculate the releases of nitrate
compounds generated from the neutralization of nitric acid, the molecular weight of the nitrate
compound formed must be used. Molecular weights of some of the individual chemicals within
the water dissociable nitrate compounds category are given in Table 3.
C-9
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Example 7: In a calendar year, a facility transfers 50,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid treatment efficiency is 95 percent, and the nitrate
compound formed as a result of the treatment is sodium nitrate (NaNO3). The quantity of
nitric acid transferred that is neutralized (generating sodium nitrate) is 95 percent of 50,000
pounds or 47,500 pounds. The molecular weight of nitric acid is 63.01 kg/kmol, and the
molecular weight of sodium nitrate is 84.99 kg/kmol. 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 example values into the above equation yields:
Kilograms HNO3 neutralized = 47,500 Ibs x 0.4536 kg/lb = 21.546 kg
Kilomoles HNO3 neutralized = 21,546 kg H- 63.01 kg/kmol = 341.9 kmol
The quantity of sodium nitrate generated in kilomoles is equal to the quantity of nitric acid
neutralized (341.9 kmol). The quantity of sodium nitrate generated in kilomoles is converted
first to kilograms then to pounds using the following equations:
Kilograms NaNO3 generated = (kmol NaNO3) x (MW of NaNO3 in kg/kmol)
Pounds NaNO3 generated = (kg NaNO3) x (2.205 Ibs/kg)
Substituting the values into the above equation yields:
Kilograms NaNO3 generated = 341.9 kmol x 84.99 kg/kmol = 29,058 kg
Pounds NaNO3 generated = 29,058 kg x 2.205 Ibs/kg = 64,073 pounds
(reported as 64,000 pounds)
The 64,000 pounds of sodium nitrate generated is the quantity used to determine whether
thresholds have been met or exceeded. The quantity of nitrate ion released is calculated as in
Example 1 above.
Section 2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment
If a facility treats wastewater on-site biologically, using the activated sludge
process, for example, the facility may be generating nitrate compounds as by-products of this
biological process. The nitrate ion generated from this process will be associated with various
countedons (e.g., sodium ion, potassium ion). In the absence of information on the identity of
the counted on, a facility should assume for the purposes of EPCRA Section 313 threshold
determinations that the counterion is sodium ion.
C-10
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Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report for the water dissociable
nitrate compounds category. If a facility is manufacturing, processing, or otherwise using a
chemical which is listed below, they must report this chemical. However, this list is not
exhaustive. If a facility is manufacturing, processing, or otherwise using a water dissociable
nitrate compound, they must report this chemical, even if it does not appear on the following list.
Table C-3
Listing by CAS Number and Molecular Weight of Some of the Individual
Chemicals within the Water Dissociable Nitrate Compounds Category
Chemical Name
Aluminum nitrate, nonahydrate
Ammonium nitrate
Cerium (III) ammonium nitrate, tetrahydrate
Cerium (IV) ammonium nitrate
Barium nitrate
Beryllium nitrate, trihydrate
Cadmium nitrate
Cadmium nitrate, tetrahydrate
Calcium nitrate
Calcium nitrate, tetrahydrate
Cerium (III) nitrate, hexahydrate
Cesium nitrate
Chromium (III) nitrate, nonahydrate
Cobalt (II) nitrate, hexahydrate
Copper (II) nitrate, trihydrate
Copper (II) nitrate, hexahydrate
Dysprosium (III) nitrate, pentahydrate
Erbium (III) nitrate, pentahydrate
Gadolinium (III) nitrate, hexahydrate
Gallium nitrate, hydrate
Iron (III) nitrate, hexahydrate
Iron (III) nitrate, nonahydrate
Molecular Weight*
213.00
80.04
486.22
548.23
261.34
133.02
236.42
236.42
164.09
164.09
326.13
194.91
238.01
182.94
187.56
187.56
348.51
353.27
343.26
255.73
241.86
241.86
CAS Number
7784-27-2
6484-52-2
13083-04-0
10139-51-2
10022-31-8
7787-55-5
10325-94-7
10022-68-1
10124-37-5
13477-34-4
10294-41-4
7789-18-6
7789-02-8
10026-22-9
10031-43-3
13478-38-1
10031-49-9
10031-51-3
19598-90-4
69365-72-6
13476-08-9
7782-61-8
C-ll
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Table C-3 (Continued)
Chemical Name
Lanthanum (III) nitrate, hexahydrate
Lead (II) nitrate
Lithium nitrate
Lithium nitrate, trihydrate
Magnesium nitrate, dihydrate
Magnesium nitrate, hexahydrate
Manganese (II) nitrate, tetrahydrate
Neodymium (III) nitrate, hexahydrate
Nickel (II) nitrate, hexahydrate
Potassium nitrate
Rhodium (III) nitrate, dihydrate
Rubidium nitrate
Samarium (III) nitrate, hexahydrate
Scandium (III) nitrate
Scandium (III) nitrate, tetrahydrate
Silver nitrate
Sodium nitrate
Strontium nitrate
Strontium nitrate, tetrahydrate
Terbium (III) nitrate, hexahydrate
Thorium (IV) nitrate
Thorium (IV) nitrate, tetrahydrate
Yttrium (III) nitrate, hexahydrate
Yttrium (III) nitrate, tetrahydrate
Zinc nitrate, trihydrate
Zinc nitrate, hexahydrate
Zirconium (IV) nitrate, pentahydrate
Molecular Weight*
324.92
331.21
68.95
68.95
148.31
148.31
178.95
330.25
182.70
101.10
288.92
147.47
336.37
230.97
230.97
169.87
84.99
211.63
211.63
344.94
480.06
480.06
274.92
274.92
189.39
189.39
339.24
CAS Number
10277-43-7
10099-74-8
7790-69-4
13453-76-4
15750-45-5
13446-18-9
20694-39-7
16454-60-7
13478-00-7
7757.79-1
13465-43-5
13126-12-0
13759-83-6
13465-60-6
16999-44-3
7761-88-8
7631-99-4
10042-76-9
13470-05-8
13451-19-9
13823-29-5
13470-07-0
13494-98-9
13773-69-8
131446-84-9
10196-18-6
13986-27-1
*For hydrated compounds, e.g., aluminum nitrate, nonahydrate, the molecular weight excludes the weight of the hydrate portion.
For example, the same molecular weight is provided for aluminum nitrate, nonahydrate and aluminum nitrate.
C-12
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Appendix D
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 D-2
1.1 Who Must Report D-2
1.2 Thresholds D-2
1.3 Chemical Sources of Aqueous Ammonia D-3
1.4 De Minimis Concentrations D-3
Section 2. Guidance for Reporting Aqueous Ammonia D-4
2.1 Determining Threshold and Release Quantities for Ammonia D-4
2.2 Chemical Sources of Aqueous Ammonia D-5
2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous
Ammonia
in Water D-5
2.2.2 Reporting of Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate) D-6
2.2.3 Reporting of Aqueous Ammonia Generated from the Dissociation
of Ammonium Nitrate D-7
Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia . . D-10
D-l
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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.
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.
D-2
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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.
D-3
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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
using the pH and temperature of the solution. The weight of total aqueous ammonia can be more
D-4
-------
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:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium salt) x 100
D-5
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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.
D-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.
D-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).
D-8
-------
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 + 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).
D-9
-------
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 D-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
D-10
-------
Table D-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
Ammonium cyanoaurate, monohydrate
(Ammonium tetracyanoaurate, monohydrate)
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
319.07
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
5.337
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
14323-26-3
D-ll
-------
Table D-l (Continued)
Chemical Name
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)
Ammonium iron sulfate
(Ammonium ferrous sulfate)
(Diammonium iron disulfate)
(Diammonium ferrous disulfate)
Molecular
Weight*
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
286.05
NH3
Equivalent
Wt%
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
11.91
CAS Number
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
10045-89-3
D-12
-------
Table D-l (Continued)
Chemical Name
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 />aramolybdate, 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)
Ammonium phosphate
(Ammonium biphosphate)
(Ammonium phosphate, hydrogen)
(Ammonium phosphate, dihydrogen)
(Ammonium orthophosphate, dihydrogen)
(Ammonium phosphate, monobasic)
Molecular
Weight*
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
115.03
NH3
Equivalent
Wt%
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
14.80
CAS Number
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
7722-76-1
D-13
-------
Table D-l (Continued)
Chemical Name
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)
Ammonium sulfamate
(Ammonium amidosulfate)
(Ammonium amidosulfonate)
Ammonium sulfate
(Diammonium sulfate)
Molecular
Weight*
132.06
83.03
99.03
216.15
91.11
369.74
155.15
115.04
178.15
301.51
152.15
114.12
132.13
NH3
Equivalent
Wt%
25.79
20.51
17.20
7.879
18.69
13.82
10.98
29.61
19.12
5.648
22.39
14.92
25.78
CAS Number
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
7773-06-0
7783-20-2
D-14
-------
Table D-l (Continued)
Chemical Name
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)
Ammonium tin bromide
(Ammonium bromostannate (IV))
(Ammonium hexabromostannate (IV))
(Diammonium hexabromostannate)
Molecular
Weight*
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
634.19
NH3
Equivalent
Wt%
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
5.371
CAS Number
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
16925-34-1
D-15
-------
Chemical Name
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*
367.48
197.95
276.00
1,779.2
3,058.6
119.16
243.27
NH3
Equivalent
Wt%
9.269
17.21
12.34
5.743
5.568
14.29
14.00
CAS Number
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.
D-16
-------
Appendix E
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
E-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
E-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
kilocalories per hour per meter per °C
Btu per hour per foot per °F
watts per meter-kelvin
Btu per hour per foot per °F
1.731
1.488
0.5778
1.163
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
Concentration (in water solution)
parts per million (ppm)
milligrams per liter
milligrams per cubic meter
grams per cubic centimeter
grams per cubic centimeter
milligrams per liter
ppm
grams per cubic centimeter
milligrams per cubic meter
pounds per cubic foot
1
1
IxlO'9
IxlO9
62.42
E-3
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To Convert
CONVERSION FACTORS (Continued)
To Multiply By
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 arm-cubic centimeters per gram mole-kelvin
62.361 millimeters mercury liter per gram mole-kelvin
E-4
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Appendix F
EXCERPT FROM: LIST OF CHEMICALS WITHIN THE
GLYCOL ETHERS CATEGORY
-------
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
May 1995
EPA 745-R-95-006
TOXICS RELEASE INVENTORY
List of Toxic Chemicals within the Glycol Ethers
Category
Section 313 of the Emergency Planning and Community Right-to-Know Act (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 F-2
Section 2. CAS Number List of Some Chemicals within the Glycol Ethers Category .... F-5
Section 3. CAS Number List of Some Mixtures That Contain Glycol Ethers within
the Category F-160
Section 4. CAS Number List of Some Oligomeric or Polymeric Chemicals That
Might Contain Glycol Ether Components within the Category F-162
F-l
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Section 1. Introduction
On June 28, 1994, EPA promulgated a final rule (published in the Federal Register July 5,
1994) modifying the definition of the glycol ethers category on the list of toxic chemicals under
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA),
42 U.S.C. 11001 et.seq. The effect of this modification, which is described at 59 FR 34386, is
that many high molecular weight glycol ethers were excluded from the category. As described in
the final rule, this modification was made retroactive for the 1993 reporting year for reports due
July 1, 1994. This modification is also effective for all subsequent reporting years. As part of
this modification and as the result of public comment, EPA changed the category name at 40
CFR 372.65(c) from 'glycol ethers' to 'certain glycol ethers.' However, this document will refer
to the constituents of this category simply as glycol ethers. At the time of the modification, EPA
indicated that the Agency would work with the public and the regulated community to develop,
as appropriate, interpretations and guidance that the Agency determines are necessary to facilitate
accurate reporting for the modified glycol ethers category. This document constitutes such
guidance.
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.
Thresholds
Thresholds are specified amounts of toxic chemicals manufactured, processed, or
otherwise 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.
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, the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
F-2
-------
EPCRA section 313 requires threshold determinations for chemical categories to be based
on the total of all chemicals in the category manufactured, processed, or otherwise used. For
example, a facility that manufactures three members of a chemical category would count the total
amount of all three chemicals manufactured towards the manufacturing threshold for that
category. When filing reports for chemical categories, the releases are determined in the same
manner as the thresholds. One report is filed for the category and all releases are reported on this
form.
Glycol Ethers Category Definition
The glycol ethers category is defined by the following formula:
R - (OCH2CH2)n - OR'
where:
n = 1,2, or 3;
R = Alkyl C7 or less, or phenyl or alkyl substituted phenyl;
R' = H or alkyl C7 or less, or
OR' consisting of a carboxylic acid ester, sulfate, phosphate, nitrate, or
sulfonate.
Chemicals that meet this category definition are reportable.
EPA is providing three lists of CAS numbers and chemical names to aid the regulated
community in determining whether they need to report for the glycol ethers category. Section 2
(pages 5 to 159) lists individual chemicals that meet the definition of the EPCRA section 313
'certain glycol ethers' category. This list consists only of chemicals that have been assigned CAS
numbers and, thus, is not exhaustive. If a facility manufactures, processes, or otherwise uses, in
greater than threshold quantities, a glycol ether that meets the category definition, whether or not
that chemical is on the list, they must report the chemical.
Section 3 (pages 160 to 161) lists chemical mixtures which contain glycol ethers that
meet the definition of the EPCRA section 313 'certain glycol ethers' category. EPA has tried to
make this list as complete as possible; however, not all mixtures that contain reportable glycol
ethers will necessarily appear on this list. If a facility manufactures, processes, or otherwise uses
a mixture which includes components, in greater than threshold quantities, that meet the
definition of the EPCRA section 313 'certain glycol ethers' category, they must report the glycol
ether component(s) that meet the category definition.
Section 4 (pages 162 to 180) lists oligomeric and polymeric chemicals (for the category
formulae, R - (OCH2CH2)n - OR', n is unspecified) that might contain a glycol ether component
(n = 1, 2, or 3). EPA has tried to make this list as complete as possible; however, not all
oligomeric or polymeric chemicals that might contain glycol ethers will necessarily appear on
this list. If a facility manufactures, processes, or otherwise uses an oligomeric or polymeric
chemical that contains components, in greater than threshold quantities, that meet the definition
F-3
-------
of the EPCRA section 313 'certain glycol ethers' category, they must report the glycol ether
component(s) that meet the category definition.
Ethylene Glycol Ethers versus Propylene Glycol Ethers
The members of this category are glycol ethers derived from ethylene glycol, diethylene
glycol, and triethylene glycol. This category does not contain glycol ethers based on propylene
glycol, dipropylene glycol, or tripropylene glycol.
Individually Listed Glycol Ethers
There are two chemicals, 2-methoxyethanol (CAS number 109-86-4) and 2-ethoxyethanol
(CAS number 110-80-5) that are on the individual chemical list and CAS number lists (40 CFR
37265(a) and (b)). Threshold determinations should be made for each of these chemicals
individually and separately from the glycol ethers category.
De Minimis Concentrations
The glycol ethers category is subject to the one percent de minimis concentration. Thus,
mixtures that contain members of this category at concentrations in excess of one percent should
be factored into threshold and release determinations.
F-4
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Appendix G
EMISSION FACTORS FOR ANHYDROUS AMMONIA FROM THE
LEATHER INDUSTRIES OF AMERICA
-------
The use of actual measurements is encouraged; however, the Leather Industries of
America (LIA) have provided some typical emission factors and related data that may be
reasonable in lieu of monitoring data. This information is presented in the table below.
G-l
Emission Factors and Typical Throughput Parameters for Anhydrous
Ammonia Estimates
Parameter
Total anhydrous ammonia generated during
hide deamination
Fugitive air release of anhydrous ammonia
from hide deamination
Ammonia discharged to water
Ammonia remaining in commercial product
(as the ammonium ion, not reportable)
Factor
0.15% of the weight of brine-cured, pre-
fleshed hide
0.10% of the weight of fresh ("green") hide
3% of total ammonia generated and purchased
90% of total ammonia generated and
purchased (of which 10% is reportable as
anhydrous ammonia)
7% of total ammonia generated and purchased
G-l
-------
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.
Acid aerosol (see sulfuric acid and hydrochloric acid) 3-6, 3-7
Activity
Chemical use, subcategories 3-10 to 3-12
Exemption (see Exemptions)
Thresholds (see Threshold)
Air emissions
Fugitive or non-point 4-4, 4-26, 4-35, 4-36, 4-39, 4-44, 4-47
Stack or point source 4-5, 4-23, 4-26, 4-39, 4-47
Article exemption (see Exemptions)
Automated toxic chemical release inventory software (ATRS) 2-16
Bactericides 4-31, 4-34, 4-35
Bating 4-30, 4-31, 4-34
Beamhouse operations 4-30, 4-31
Brine-cured hides 4-36, 4-38
Buffing 3-10, 4-30, 4-45, 4-46
Chemical-specific
Acid aerosols 3-6, 3-7
Ammonia 2-9, 2-11,2-12, 3-5, 3-10, 3-20, 4-19, 4-30 to 4-37,
4-39, 4-40, 4-51, 4-52, Appendix D, Appendix G
Formic acid 2-9, 3-2, 3-12, 4-30, 4-39, 4-43
Glycol ethers 2-9, 3-2, 4-30, 4-45, 4-47, Appendix F
Hydrochloric acid 3-6
Hydrogen sulfide 4-35
Nitrate compounds 2-9, 3-7, 3-10, Appendix C
Sulfuric acid 3-7
Chemical processing aid 3-12
Chrome tanning 4-37, 4-38
Coloring operations 2-9, 4-7, 4-20, 4-24, 4-30, 4-42 to 4-45
Combustion 3-16, 3-17, 4-3, 4-10, 4-12 to 4-14, 4-23
For energy recovery off-site 4-13, 4-14
For energy recovery on-site 4-13
Common errors
Assuming a threshold is exceeded 3-24
Coincidental manufacturing 2-12
Direct reuse vs. recycling 4-14
Double counting 4-16
Exempt activities 3-14
Glycol ether reporting 3-2
Mass balance for otherwise used chemicals 4-21
index-i
-------
INDEX (Continued)
Mixture components 3-4
Reporting 4-52
Shipping container residue 4-8
Threshold determination for recirculation 3-9
Treatment efficiencies 4-19
Zero release and other waste management quantities 3-24
Conditioning 4-30, 4-46
Container residue 4-8 to 4-10, 4-35, 4-39, 4-43, 4-46, 4-51
Example, container residue 4-10
De minimis (see Exemptions)
Example, de minimis 3-15
Example, de minimis concentration ranges 3-16
Deamination 3-10, 4-34 to 4-36
Deliming 4-30 to 4-31, 4-34 to 4-36
Disposal 2-11, 4-6 to 4-8, 4-12
Land, on-site 4-6, 4-7
Land, off-site 4-7, 4-8, 4-12 to 4-16
Documentation (see Recordkeeping)
Double counting 4-16
Common error, double counting 4-16
Dry milling 4-30
Drying 4-30
Dyes 3-11, 4-42, 4-43, 4-44
Emission factors 4-16 to 4-18, 4-21 to 4-23, B-6
Example, emission factors 4-23, B-6
Employee equivalent calculation 2-6
Example, calculating employees 2-7
Energy recovery (see Combustion for energy recovery)
Engineering calculation 4-16 to 4-18, 4-23 to 4-25, 4-36, 4-40, B-l
Example, engineering calculations 4-24
EPCRA hotline 1-2, 1-5
Establishment 2-1, 2-5, 2-6
Example, primary SIC code 2-6
Examples
Articles exemption 3-18
Chemical processing aid 3-12
Chemicals in process water 3-21
Chromium release and other waste management activities 4-40
Container residue 4-10
De minimis 3-15
De minimis concentration ranges 3-16
Emission factors 4-23
Employee equivalent calculation 2-7
Engineering calculation 4-24
index-ii
-------
INDEX (Continued)
Form A threshold 2-17
Fugitive anhydrous ammonia releases calculation 4-36
Laboratory activity exemption 3-19
Mass balance 4-20
Monitoring data 4-19
Motor vehicle exemption 3-20
On-site waste treatment 4-11
Personal use exemption 3-20
Primary SIC code 2-6
Process equipment exemption 3-21
Relabeling 2-12
Threshold determination 3-9
Threshold worksheet 3-25
Treatment of wastes from off site 2-12
Xylene isomers 3-9
Exemptions 3-13 to 3-21
Activity-related 3-19 to 3-21
Article 3-17 to 3-18
De minimis 3-14 to 3-17, C-3, D-3
Drawn from environment 3-21
Evaluation of 3-13
Facility-related 3-19
Grounds maintenance 3-19
Janitorial 3-19
Laboratory 3-19
Motor vehicle 3-20
Personal use, example 3-20
Structural components 3-20
Vanadium 3-7
Facility
Auxiliary facility 2-5
Covered facility 2-5
Multi-establishment facilities (see Establishments)
Pilot plant 2-6
Facility-related exemption (see Exemption)
Fatliquoring operations 4-30, 4-42 to 4-45
Finishing operations 2-9, 4-45 to 4-48
Form A 1-4, 2-1, 2-17, 3-22
Example Form A threshold 2-17
Form R 1-3 to 1-5, 2-1, 2-16, 4-4 to 4-16, 4-25 to 4-29
Fresh hides 4-31
Grading 4-30, 4-46
Hides 4-30, 4-31, 4-34, 4-36 to 4-38
Impurity 2-11, 3-10, 3-15
index-iii
-------
INDEX (Continued)
Laboratory exemption (see Exemption)
Leather Industries of America vi, Appendix G
Manufacture/Manufacturing 2-11, 3-6, 3-10
Byproduct 3-10
Coincidental manufacture 2-12, 3-20, 4-36
Manufacturing subcategories 3-10
Mass balance 4-16 to 4-21
Example, mass balance 4-20
Methods (see Reportable amount estimate methods)
Mixture 3-1 to 3-3, 3-9, 3-14 to 3-16, 3-25
Monitoring data 4-16 to 4-19, B-l
Example, monitoring data 4-19
Motor vehicle exemption (see Exemption)
MSDS 3-3, 3-4, 3-13
Otherwise use 2-11, 3-12
Common error, mass balance for otherwise used chemicals 4-21
Owner/operator 1-3
PBT chemicals 2-13 to 2-15
Penalties 1-4
Pickling 2-9, 4-30, 4-37, 4-38
Pilot plant (see Facility)
Plating 4-30, 4-46
Point source (see Air emissions)
POTW 4-7, 4-10, 4-11, 4-15, 4-16, 4-18, 4-28, 4-34, 4-37, 4-43
Pre-fleshed hides 4-36
Process/processing 2-11, 3-11
Process equipment 3-20
Example, process equipment chemical use 3-21
Process water 3-21
Example, chemicals in process water 3-21
Processing subcategories 3-11
Qualifiers 3-5
Recordkeeping 2-19
Recycling 3-9, 3-23, 4-12, 4-14, 4-38, 4-43, 4-46
Off-site 4-14
On-site 4-12, 4-14
Relabeling, example 2-12
Release Chapter 4
Accidental 4-15
Estimates (steps to calculate) 4-1, 4-16
Sources 4-3, 4-34, 4-39, 4-43, 4-47, 4-50
Types 4-4, 4-35, 4-39, 4-44, 4-47, 4-51
Reliming 4-30
index-iv
-------
INDEX (Continued)
Remedial actions/remediation 3-22, 4-15
Repackaging 2-12, 3-11
Reportable amount 2-17
Reportable amount estimate methods 4-16 to 4-25
Emission factors 4-21
Engineering calculations 4-23
Mass balance 4-19
Monitoring data/records 4-18
Reporting criteria 2-2
Retanning operations 2-9, 4-30, 4-43 to 4-45
Reuse 3-9, 3-21
Setting out 4-30
Shavings 4-30
Siding 4-30, 4-38
Soaking 4-30, 4-31
Sorting 4-30, 4-38
Sources (see Release)
Splitting 4-30, 4-38
Staking 4-30
Standard Industrial Classification (SIC) 2-4
Primary SIC code 2-6
Tanning 2-9, 4-30, 4-38
Tanning agents 4-38, 4-43
Tanyard operations 4-30, 4-37 to 4-42
Technically qualified individual 3-19
Threshold worksheet 3-8, 3-25 to 3-27
Thresholds 3-8
Common error, threshold determination 3-9
Example, Form A threshold 2-17
Threshold determination Chapter 3, 3-23
Threshold worksheet 3-25 to 3-27
Total annual reportable amount (see Reportable amount)
Trade secret 2-18
Transfers 4-7, 4-13 to 4-16, 4-38, 4-43, 4-46, 4-50
Treatment efficiency 4-10, 4-11, 4-19
Treatment for destruction
On-site 4-10 to 4-14
Off-site 4-14
Trimming 4-30, 4-38
Types (see Release)
Unhairing 4-30 to 4-32, 4-34
Waste management Chapter 4
Waste treatment (see Treatment for destruction)
Common error, treatment efficiencies 4-19
index-v
-------
INDEX (Continued)
Example, chromium release and other waste management activities 4-40
Example, on-site waste treatment 4-11
Waste treatment operation 2-9, 4-49 to 4-52
Wastewater discharge 4-6
Wastewater treatment 4-49
Wringing 4-30, 4-48
index-vi
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