r/EPA
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
October 1997
EPA745-B-97-011
            EMERGENCY PLANNING AND COMMUNITY
                 RIGHT-TO-KNOW ACT SECTION 313
            GUIDANCE FOR METAL MINING FACILITIES
                              (Version 1.0)
                              CONTENTS

Section 1.   Introduction...	.,	1-1

Section 2.   Section 313 Reporting Requirements	 2-1

Section 3.   Making Threshold Determinations	 3-1

Section 4.   Overall Section 313 Release Estimation	 4-1

Section 5.   Calculating Release Estimations At Metal Mining Facilities. 5-1

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 SECTION 313 EMERGENCY PLANNING AND
    COMMUNITY RIGHT-TO-KNOW ACT

GUIDANCE FOR METAL MINING FACILITIES
                Version 1.0

               October 6,1997

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                           TABLE OF CONTENTS

SECTION 1
      INTRODUCTION	1-1

SECTION 2
      SECTION 313 REPORTING REQUIREMENTS  	:	2-1
      WHO MUST REPORT?	2-1
           Reduced Reporting	2-2
           What is a facility?  	2-2
           How to Determine Your SIC Code 	2-3
           How to Determine Your Number of Employees	2-4
      CHEMICAL ACTIVITY THRESHOLDS 	2-4
           Manufacture	2-5
           Process 	 2-5
           Otherwise use	2-7
      EXEMPTIONS 	2-11
      SUPPLIER NOTIFICATION REQUIREMENTS  	2-15
      LISTED SECTION 313 CHEMICALS	2-16
      WHAT MUST BE REPORTED? 	2-18
      DOCUMENTING REPORTING EFFORTS  		i	2-19

SECTION 3
      MAKING THE THRESHOLD DETERMINATION  .. . ,	3-1
      CONDUCTING THE THRESHOLD DETERMINATION	3-3

SECTION 4
      OVERVIEW OF SECTION 313 RELEASE ESTIMATION	4-1
      GENERAL CONCEPTS	4-1
           Release Estimation	4-1
           Reasonable Estimates: Significant Figures and Use of Range Codes  	4-6
           "NA" versus "0"	4-7
      REPORTING RELEASES IN FORM R, PART II	4-7
           Fugitive or Non-Point Emissions	4-8
           Stack or Point-Source Air Emissions  	4-10
           Wastewater Discharges 	4-10
           Underground Injection On-Site	4-12
           Release to Land On-Site 	4-13
           Transfers in Wastes to Other Off-site Locations	4-14
           On-site Waste Treatment Methods and Efficiency 	4-14
           On-site Energy Recovery Processes	4-15

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             On-site Recycling Processes  	4-16
             Source Reduction and Recycling Activities 	4-16
             Quantity Released  	4-16
             Quantity Used for Energy Recovery On-site	4-16
             Quantity Used for Energy Recovery Off-site 	4-17
             Quantity Recycled On-site	4-17
             Quantity Recycled Off-site  	4-17
             Quantity Treated On-site	4-17
             Quantity Treated Off-site	4-18
             Quantity Released to the Environment as a Result of Remedial Actions,
                   Catastrophic Events, or One-time Events Not Associated with Production
                   Processes 	4-18

SECTION 5
      CALCULATING RELEASE ESTIMATIONS AT METAL MINING FACILITIES  . 5-1
      BENEFICIATION	5-1
      COMMINUTION 	5-3
             Crushing	5-3
             Sorting and Sizing	5-3
             Grinding	 5-4
             Washing	5-6
      CONCENTRATION/CONDITIONING	5-6
             Physical  	5-6
                   Gravity Concentration	5-6
                   Magnetic Separation  	5-7
                   Electrostatic Separation	5-7
                   Filtration	5-7
                   Flotation	5-8
             Chemical Processes	5-10
                   Leaching	5-10
                         Heap Leaching	5-11
                         Tank and Vat Leaching 	5-12
                         Dump Leaching	5-14
                         In Situ Leaching	5-14
                         Bioleaching  	5-15
                   Solvent Extraction	5-15
                   Electrowinning  	5-16
                   Zinc Precipitation	5-18
                   Amalgamation	5-18
                   Activated Carbon Adsorption 	5-18
                   Ion Exchange	5-20

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            Heat Processes	5-20
                  Calcining	5-20
                  Roasting	5-20
                  Sintering	5-21
                  Autoclaving	5-21
                  Pelletizing and Briquetting 	5-21

APPENDIX A
      ALPHABETICAL LISTING OF SECTION 313 CHEMICALS 	 A-l

APPENDIX B
      LIST OF ACTIVITIES THAT FALL UNDER EACH SIC CODE
      IN MAJOR GROUP 10	B-l

APPENDIX C
      BIBLIOGRAPHY	C-l

APPENDIX D
      SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
      INFORMATION	 D-l

                               LIST OF TABLES

Table 1-1. Summary of Reporting Requirements Under EPCRA	1-4
Table 3-1. Examples of Manufactured, Processed, and Otherwise Used Chemicals
      at Metal Mines	3-1
Table 4-1.  SOCMI Average Emission Factors	4-9
Table 5-1. Beneficiation Processes	5-2
Table 5-2. Emission Factors for Metal Mining Operations 	5-5
Table 5-3. Common Copper Beneficiation Flotation Agents
      Containing Section 313 Chemicals  	5-9
Table 5-4. Common Lead/Zinc Benefication Flotation Agents
      Containing Section 313 Chemicals	5-9


                               LIST OF FIGURES

Figure 4-1. Schematic of Typical Copper Mining Extraction and Beneficiation
      Wastestreams  	4-3
Figure 5-1. Flotation Process 	5-8
Figure 5-2. Heap Leaching	5-11

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Figure 5-3. Heap Leaching with Zinc Precipitation	5-12
Figure 5-4. Vat Leaching  	5-13
Figure 5-5. Activated Carbon Adsorption 	5-18
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                                      SECTION 1
                                   INTRODUCTION

This guidance document has been prepared to assist metal mining facilities in complying with
the reporting requirements of Section 313 of the Emergency Planning and Community Right-to-
Know Act (EPCRA, Public Law 99-499, Title III of the Superfund Amendments and
Reauthorization Act of 1986, hereafter EPCRA Section 313) and Section 6607 of the Pollution
Prevention Act (PPA). This guidance document is intended for use along with the Toxic
Chemical Release Inventory Reporting Form R and Instructions document published annually by
the U.S. Environmental Protection Agency (EPA). For further assistance and to obtain copies of
the latest version of this instruction document, contact the EPCRA Hotline at 1-800-535-0202.
The other EPCRA reporting programs are summarized at the end of this section.

One of the primary goals of the EPCRA program is to increase the public's knowledge of, and
access to, information on both the presence of Section 313 chemicals in their communities and
on releases and other waste management activities of Section 313 chemicals into the
environment. Since 1987, certain facilities in the manufacturing sector have been reporting
information on releases and other waste management activities of Section 313 chemicals to EPA
and states throughout the United States. As  a result of an EPA rulemaking (62 FR 23834, May 1,
1997), certain additional industry groups, including metal mining facilities (Standard Industrial
Classification (SIC) Major Group 10, except 1011,1081, and 1094) are now required to evaluate
their chemical use and management activities to determine potential reporting responsibilities
under EPCRA Section 313.

Section 313 establishes annual reporting requirements for Section 313 chemicals provided that
certain activity thresholds are met. Section 313 includes a list of over 650 chemicals and
chemical categories. These chemicals and chemical categories were either originally selected by
Congress or were added by EPA through rulemaking.

The Section 313 reporting requirements apply to owners or operators of facilities which meet all
of the following three criteria:

       The facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except 1241),
       or 20-39 (manufacturing facilities), or 4911 (limited to facilities that combust coal and/or
       oil for the purpose of generating power for distribution in commerce), 4931 (limited to
       facilities that combust coal and/or oil for the purpose of generating power for distribution
       in commerce) and 4939 (limited to facilities that combust coal and/or oil for the purpose
       of generating power for distribution in commerce), or 4953 (limited to facilities regulated
       under RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily
       engaged in solvent recovery services on a contract or fee basis); and,
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•      The facility must have 10 or more full-time employees (or the total hours worked by all
       employees is greater than 20,000 hours), and

•      The facility manufactures (defined to include importing), processes, or otherwise uses
       any Section 313 chemical in quantities greater than the established threshold in the course
       of a calendar year.

For each Section 313 chemical or chemical category, covered facilities must report the total
annual releases, both routine and accidental, to all environmental media; and other on-site waste
management activities, including quantities recycled, combusted for energy recovery and treated
for destruction, and off-site transfers for disposal, waste treatment, energy recovery and
recycling. This information is submitted on the Toxic Chemical Release Inventory (TRI)
Reporting Form, which is called the "Form R." (As discussed in the following chapter, facilities
meeting certain conditions are eligible to report using an abbreviated Form A.)

The annual Form R or Form A reports are submitted to EPA headquarters and to a state
designated agency, usually a State Emergency Response Commission (SERC), or in some cases
a Tribal Emergency Response Commission (TERC), annually on or before July 1st for activities
occurring during the previous calendar year (e.g., July 1, 1999, for activities during the period
from January 1 to December 31, 1998).

EPCRA mandated that EPA establish and maintain a national TRI database to assist in research
and the development of regulations, guidelines, and standards related to Section 313 chemicals
and to make the TRI data available to the general public and any interested parties. The TRI
database is computer-accessible to anyone with a modem via the National Library of Medicine's
TOXNET on-line system.  The TRI data are also available through many other sources, including
EPA's Internet Web site; public libraries on microfiche; the Government Printing Office on CD-
ROM; and the National Technical Information Service on magnetic tape and individual state
diskettes.

Facility owners or operators who violate the Section 313 reporting provisions may be assessed
civil penalties of up to $25,000 per day for each violation. In addition, state enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.

This document is organized into several sections to provide quick reference. Section 2 presents
an overview of the Section 313 reporting requirements. Section 3 provides a detailed discussion
of how to make threshold determinations regarding the manufacture, processing, and otherwise
use of Section 313 chemicals. Section 4 covers general concepts relating to reporting and release
estimating, and provides potential data sources for determining releases at metal mining facilities
and other amounts managed. Section 5 presents a detailed discussion of EPCRA Section 313
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release and other waste management scenarios in the metal mining industry and covers
developing estimates of releases and other waste management activities for several types of
operations commonly encountered by the metal mining industry.  Finally, Appendix A provides
an alphabetical listing of the Section 313 chemicals and chemical categories subject to EPCRA
Section 313, the de minimis concentrations for each Section 313 chemical, and the RCRA status
of the chemical. Appendix B provides a table listing the efficiencies of RCRA treatment
technologies.  Appendix C provides a bibliography of relevant EPA documents used to help
metal mining facilities in complying with EPCRA Section 313.
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             Table 1-1. Summary of Reporting Requirements Under EPCRA
  EPCRA
  Section
                          Reporting Requirements
  Sections
  302 - 303
  Presence of
  Extremely
  Hazardous
  Substances
  (40 CFR
  §355.30)
If a facility has one or more "extremely hazardous substances" present on site in
quantities greater than Threshold Planning Quantities (TPQs) established by EPA, it
must notify its State Emergency Response Commission (SERC) and Local Emergency
Planning Committee (LEPC) that it is subject to the emergency planning requirements
of these sections. A facility representative must be designated to participate in the local
emergency planning process. The facility also must provide any information deemed
necessary for development or implementation of a local emergency plan.
  Section 304
  Emergency
  Notificatio
  n (40 CFR
  §355.40)
A facility must notify the LEPC and SERC immediately of the release of any "extremely
hazardous substance" (listed in 40 CFR Part 355, Appendices A and B) or any hazardous
substance under CERCLA (listed in 40 CFR 302.4), in amounts at or above the specified
Reportable Quantities that EPA establishes for each substance. The facility must follow
up this initial notification with a written statement providing details of the incident.
  Section 311
  Material
  Safety Data
  Sheet
  (MSDS)
  Reporting*
  (40 CFR
  §370.21)
A facility must submit to the LEPC, SERC, and local fire department a list of Material
Safety Data Sheets (MSDSs), or copies of MSDSs, for any "hazardous chemicals" (as
defined under the Occupational  Safety and Health Administration (OSHA) Hazard
Communication Standard) that are present on site in quantities greater than  10,000
pounds. A facility also must report any "extremely hazardous substances" (EHS) (as
defined under Section 302) that are present on site in quantities at or above the TPQ or
500 pounds, whichever is less.  Submissions are required within 90 days of the date
when new chemicals are first present at or  above  specified thresholds or  if new
information on previously reported chemicals  becomes available.  Some states have
established lower activity thresholds.
 Section 312
 Hazardous
 Chemical
 Inventory*
 (40 CFR
 §370.25)
A facility must submit to the LEPC, SERC, and local fire department certain information
for any "hazardous chemical" or EHS reportable under Section 311.  This information
is most commonly submitted on a Tier I or Tier II Form and includes a description of
any type of hazard the material may pose, the quantities stored, general storage locations,
and type of storage. The reports for each calendar year are due on or before March 1 of
the following year. Most states require or request that facilities submit the more detailed
Tier II reporting form or a state-issued version of that form. In addition, some states
have established lower activity thresholds and require  more detailed or additional
information.
        Facilities that are not subject to OSHA are not covered by EPCRA Sections 311 or 312.
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 EPCRA
 Section
                           Reporting Requirements
 Section
 313: Toxic
 Chemical
 Release
 Inventory
 Reporting
 (Form R)
 (40 CFR
 §372)
A facility in certain SIC codes meeting threshold requirements is required to report
annually amounts of listed Section 313 chemicals released or otherwise managed to
EPA and designated state agencies. Section 313 includes a list of over 650 chemicals
and chemical categories. Release reporting information is submitted on the Toxic
Chemical Release Inventory (TRI) Reporting Form, Form R.

The Section 313 reporting requirements apply to owners or operators of facilities
which meet all of the following three criteria:

•     Facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except
       1241), or 20-39 (manufacturing facilities), or 4911 (limited to facilities that
       combust coal and/or oil for the purpose of generating power for distribution in
       commerce), 4931 (limited to facilities that combust coal and/or oil for the
       purpose of generating power for distribution in commerce) and 4939 (limited
       to facilities that combust coal and/or oil for the purpose of generating power
       for distribution in commerce), or 4953 (limited to facilities regulated under
       RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily
       engaged in solvent recovery services on a contract or fee basis); and.

•     Facility must have 10 or more full-time employees (or the total hours worked
       by all employees is greater than 20,000 hours), and

•     Facility must manufacture (including importation), process, or otherwise use a
       listed Section 313 chemical hi excess of specific threshold quantities.

The threshold quantities for reporting under Section 313 are based on the amount of
the Section 313 chemical manufactured, processed, or otherwise used during the
calendar year.  Specifically, the thresholds are greater than 25,000 pounds if
manufactured, or 25,000 pounds if processed, or 10,000 pounds if otherwise used.

EPCRA mandated that EPA establish and maintain a national TRI database to assist
in research and the development of regulations, guidelines, and standards related to
Section 313 chemicals and to make the TRI data available to the general public and
any interested parties. The TRI database is computer-accessible to anyone with a
modem via the Internet or the National Library of Medicine's TOXNET on-line
system.	^^^
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                                      SECTION 2
                    SECTION 313 REPORTING REQUIREMENTS
WHO MUST REPORT?

A facility is subject to the provisions of the Section 313 reporting requirements if it meets all
three of the following criteria:

•      The facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except 1241),
       or 20-39 (manufacturing facilities), or 4911 (limited to facilities that combust coal and/or
       oil for the purpose of generating power for distribution in commerce), 4931 (limited to
       facilities that combust coal and/or oil for the purpose of generating power for distribution
       in commerce) and 4939 (limited to facilities that combust coal and/or oil for the purpose
       of generating power for distribution in commerce), or 4953 (limited to facilities regulated
       under RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily
       engaged in solvent recovery services on a contract or fee basis) hereafter "covered SIC
       codes": and.

•      Facility must have 10 or more full-time employees (or the total hours worked by all
       employees is greater than 20,000 hours), and

•      The facility manufactures (defined to include importation), or processes, or otherwise
       uses any Section 313 chemical in quantities greater than the established threshold in the
       course of a calendar year.

Instructions regarding how to determine the facility SIC code, employee threshold, or activity
follows; for additional detail please consult the Toxic Chemical Release Inventory Reporting
Form R and Instructions, a document published annually by EPA.

In addition, pursuant to Executive Order (EO) 12856 signed by the President on August 3, 1993,
Federal facilities are required to determine the applicability of the EPCRA Section 313 reporting
requirements regardless of the facility's SIC codes. Federal facilities that have 10 or more full
time employees or the equivalent and manufacture, process, or otherwise use listed Section 313
chemicals at or above established thresholds are subject to EPCRA Section 313 reporting.
Federal facilities were required to begin reporting no later than reporting year 1994; their first
Form R or Form A reports were due by July 1,1995.

The amount of the chemical released to the environment does not affect the need to report. Even
if there are no releases of a listed Section 313 chemical, a facility must report if it meets the
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requirements regarding SIC code, number of employees, and activity threshold. A threshold
determination must be made individually for each Section 313 chemical.

Thresholds are based on operation year, this includes partial year reporting and reporting by a
facility that is going through closure. The facilities should consider the portion of the year for
which they operated to determine the actual employee hours worked as well as threshold
determination and release reporting.

Reduced Reporting

On November 30,1994, EPA published a final rule (59 FR 61488) that provides an alternative
reporting option to qualifying facilities. Eligible facilities wishing to take advantage of this
alternative reporting option may report on a simplified two page form referred to as Form A and
do not have to use Form R. The rule entitled "TRI Alternate Threshold for Facilities with Low
Annual Reportable Amounts," provides facilities that otherwise meet EPCRA Section 313
activity thresholds the option of reporting on Form A, provided that they do not exceed 500
pounds for the total annual reportable amount (defined below) for that chemical, and that the
amounts manufactured, processed or otherwise used do not exceed 1 million pounds. As with
detennining an activity threshold to determine if the chemical activity has been exceeded,
facilities must evaluate each activity threshold separately; for example, a facility that
manufactures 900,000 pounds per year of a Section 313 chemical and processes 150,000 pounds
per year of a Section 313 chemical would still be eligible to use the Form A.

For the purpose of reporting on Form A, the annual reportable amount is equal to the combined
total quantities released (including disposed) at the facility, treated at the facility (as represented
by amounts destroyed or converted by treatment processes), recycled at the facility, combusted
for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-
site locations for the purpose of recycling, energy recovery, treatment, and/or disposal. These
quantities do not include amounts of the chemical accidentally released. These volumes
correspond to the  sum of amounts reported on Form R, as Part II column B of section 8, data
elements 8.1 (quantity released), 8.2 (quantity used for energy recovery on-site), 8.3 (quantity
used for energy recovery off-site), 8.4 (quantity recycled on-site), 8.5 (quantity recycled off-site),
8.6 (quantity treated on-site), and 8.7 (quantity treated off-site). See Section 4 of this document
for more guidance on completing Part II, Section 8 of Form R.

What is a facility?

Under EPCRA, a  "facility" is defined as all buildings, equipment, structures, and other stationary
items which are located on a single site or contiguous or adjacent sites and which are owned or
operated by the same person (or by any person which controls, is controlled by, or under
common control with such person).  An "establishment" is generally a single physical location,

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where business is conducted or where services or industrial operations are performed.  A facility
may contain more than one establishment. For example, a mine, mill, and smelter would be one
facility if all three units were owned and operated by the same company and are located on
contiguous or adjacent properties. A single facility therefore can be a multi-establishment
complex. Such a facility may submit reports that cover all its establishments, or the individual
establishments may report separately. However, for the purposes of determining thresholds, all
chemical activities for the entire facility must be considered.

How to Determine Your SIC Code**

Standard Industrial Classification (SIC) codes 10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39 (manufacturing facilities), 4911, 4931 and 4939 (limited to facilities that combust
coal and/or oil for the purpose of generating power for distribution in commerce), 4953 (limited
to facilities regulated under RCRA subtitle C), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvent recovery services on a contract or fee basis) are covered under
section 313 of EPCRA. The first two digits of a 4-digit SIC code define a major business sector,
while the last two digits denote a facility's specialty within the major sector. A facility should
determine its own SIC code(s), based on its activities on-site  and the "Standard Industrial
Classification Manual 1987." In some cases, a state agency or other organization may have
assigned SIC codes on a different basis than the one used in the SIC Manual. For the purposes of
TRI reporting, state assigned codes should not be used if they differ from ones assigned using the
SIC Manual.                                                 '

Your facility may include multiple establishments that have different SIC codes. In order to
determine which SIC code best represents the facility, the facility should calculate the value of
the products or services produced or provided at/by or shipped from each establishment within
the facility and then use the following rule to determine if your facility comes within the covered
SIC codes, and the SIC code criterion is met.

•   If the total value of the products or services shipped, produced or provided at establishments
    in "covered" SIC codes is greater than 50 percent of the value of the entire facility's products
    and services, the entire facility comes within the covered  SIC codes, and the SIC code
    criterion is met.

•   If any one establishment in the specified set of SIC codes produces, provides or ships
    products or service whose value exceeds the value of products and services produced or
        Please note: The North American Industrial Classification System that appeared in the Federal Register
on April 9, 1997 will replace the 1987 Standard Industrial Classification System (SIC). Regulatory entities,
including EPA, will take steps to adopt the new classification system over the next few years. In the meantime,
facilities should consider their activities in relation to the 1987 SIC code system.
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    shipped by all other establishments within the facility, the facility comes within the covered
    SIC codes, and the SIC code criterion is met.

The value of production or service attributable to a particular establishment may be isolated by
subtracting the product or service value obtained from other establishments within the same
facility from the total product or service value of the facility. This procedure eliminates the
potential for "double counting" production or service in situations where establishments are
engaged in sequential production activities at a single facility.

How to Determine Your Number of Employees

A "full time employee," for the purpose of Section 313 reporting, is defined as 2,000 work hours
per year. The number of full time employees is dependent only upon the total number of hours
worked by all employees during the calendar year for that facility and not the number of persons
working. To determine the number of full time employees working for your facility, add up the
hours worked by all employees during the calendar year including contract employees and sales
and support staff, and divide the total by 2,000 hours. In other words, if the total number of
hours worked by all employees is 20,000 hours or more, your facility meets the ten employee
threshold.

Facilities may have contract workers present at times to conduct maintenance and service
operations, including equipment, motor vehicle, and building maintenance, construction, and
operating processes and waste management activities (e.g., remediation). The hours of all these
contract workers count toward the employee threshold for reporting under Section 313. In
addition, the hours worked by professionals (e.g., those on salary, that do not clock in or out)
also count towards the facility's's employee threshold. Employees that perform activities which
routinely occur off-site such as truck drivers, but who are based at the facility are also counted
towards the employee threshold.  Routine activities performed at the facility by outside personnel
such as contract drivers that are not based at the facility are not counted towards the employee
threshold.

CHEMICAL ACTIVITY THRESHOLDS

Section 313 requires a facility that meets the SIC code and employee criteria to submit Form R
reports for any listed Section 313 chemical or chemical category that it manufactures in annual
quantities greater than 25,000 pounds, processes in annual quantities greater than 25,000 pounds,
or otherwise uses in annual quantities greater than 10,000 pounds (40 CFR §372.3). These
thresholds (manufacture, process, or otherwise use) will be referenced throughout this document
as "activity thresholds."  Chemicals must be evaluated in association with one or more of these
three categories when determining whether an activity threshold has been exceeded.  These
categories are:
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   Manufacture - "Manufacture" means to produce, prepare, compound, or import a listed
   Section 313 chemical. Import is defined as causing the Section 313 chemical to be imported
   into the customs territory of the United States. If you order a listed Section 313 chemical (or
   a mixture containing the chemical) from a foreign supplier, then you have imported the
   chemical when that shipment arrives at your facility directly from a source outside of the
   United States. By ordering the chemical, you have "caused it to be imported," even though
   you may have used an import brokerage firm as an agent to obtain the Section 313 chemical.
   If the importation was directed by the parent company, then the facility receiving the
   chemical is not considered to have imported the chemical.

   The term manufacture also includes coincidental production of a listed chemical (e.g., as a
   byproduct or impurity) as a result of the manufacture, processing, otherwise use, or waste
   management of other chemical substances. The fact that the coincidental manufacturing of
   these byproducts is not the primary purpose of the facility is irrelevant.  Listed EPCRA
   Section 313 chemicals coincidentally manufactured by a facility must be factored into
   threshold determinations and release calculations.

   Manufactured Activities and Definitions

   Produced or imported for on-site use/processing
            A chemical that is produced or imported and then further processed or
            otherwise used at the same facility.
   •   Produced or imported for sale/distribution
            A chemical that is produced or imported specifically for sale or
            distribution outside the facility.
   •   Produced as a by-product
            A chemical that is produced coincidentally during the production,
            processing, otherwise use, or disposal of another chemical substance or
            mixture and, following its production, is separated from that other
            chemical substance or mixture. Section 313 chemicals produced and
            released as a result of waste treatment for disposal are also considered
            byproducts.
   •   Produced as an impurity
            A chemical that is produced coincidentally as a result of the
            manufacture, processing, or otherwise use of another chemical but is
            not separated and remains primarily in the mixture or product with that
            other chemical.
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•  Process - "Process" means the preparation of a listed Section 313 chemical, after its
   manufacture, for distribution in commerce.  Processing is usually the intentional
   incorporation of a Section 313 chemical into a product.  Processing includes preparation of
   the Section 313 chemical in the same physical state or chemical form as that received by your
   facility, or preparation that produces a change in physical state or chemical form.  The term
   also applies to the processing of a mixture or other trade name product that contains a listed
   Section 313 chemical as one component. Processing activities include use of Section 313
   chemicals as  reactants, hi formulations, and as article components, and repackaging.
   Processing may also include the recycling of a Section 313 chemical for distribution in
   commerce. For example, if a facility receives a waste containing a Section 313 chemical
   from off-site, stabilizes, and repackages the waste in one calendar year and then distributes
   the repackaged waste into commerce in the following year. The facility would count the
   amount of the Section 313 chemical stabilized as being processed in the year it was treated.

   The extraction and subsequent distribution in commerce of ore containing EPCRA Section
   313 chemicals constitutes "processing" of those listed chemicals. For the purposes of the
   processing definition, EPA defines extraction to mean the physical removal or exposure of
   ore, coal, minerals, waste rock, or overburden prior to beneficiation, and encompasses all
   extraction-related activities prior to beneficiation.  Extraction does not include
   beneficiation (including coal preparation) mineral processing, in situ leaching or any
   further activities. (See 40 CFR §372.3.) Removal of waste rock to gain access to an ore
   body does not constitute processing and therefore these amounts are not considered
   toward threshold determinations. Disposal and other releases (e.g., during transport)
   of TRI chemicals contained in waste rock may be reportable if thresholds are exceeded
   for the chemical .elsewhere at the facility.

   Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
   313 chemical occurs does not constitute processing of the Section 313 chemical.

•  Processed Activities and Definitions
   •   As a reactant
            A natural or synthetic chemical used in chemical reactions for the
            manufacture of another chemical substance, or product. This includes,
            but is not limited to, feedstocks, raw materials, intermediates, and
            initiators.
   •   As a formulation component
            A chemical added to a product (or product mixture) prior to further
            distribution of the product that acts as a performance enhancer during
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            use of the product. Examples of Section 313 chemicals used in this
            capacity include, but are not limited to, additives, dyes, reaction
            diluents, initiators, solvents, inhibitors, emulsifiers, surfactants,
            lubricants, flame retardants, and rheological modifiers.
   •   As an article component
            A chemical that becomes an integral component of an article
            distributed for industrial, trade, or consumer use.
   •   Repackaging
            Processing or preparation of a Section 313 chemical (or product
            mixture) for distribution in commerce in a different form, state, or
            quantity. This includes, 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.

   Otherwise use - Any use involving a listed Section 313 chemical at a facility that does not
   fall under the definitions of 'manufacture" or "process" is an otherwise use of that chemical.
   A chemical that is otherwise used by a facility is not incorporated into a product distributed
   in commerce and includes use of the  Section 313 chemical as a chemical processing aid or as
   a manufacturing aid or for ancillary uses such as treating wastes. Otherwise use of a Section
   313 chemical does not include disposal, stabilization (without subsequent distribution in
   commerce), or treatment for destruction unless:

       (1)   The Section 313 chemical that was  disposed, stabilized, or treated for destruction
            was received from off-site for the purposes of further waste management, or

       (2)   The Section 313 chemical that was  disposed, stabilized, or treated for destruction
            was manufactured as a result of waste management activities on materials received
            from off-site for the purpose of further waste management.

   Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
   313 chemical occurs does not constitute the otherwise use of the Section 313 chemical.

   The difference between "processing" and "otherwise use" is important because these
   activities are subject to different activity thresholds. Because beneficiation of ore is
   preparation of its constituents, any beneficiation of ore containing Section 313 chemicals
   (e.g., copper in copper ore) is considered processing if there is subsequent distribution in
   commerce. Processing  implies incorporation; for the purposes of EPCRA Section 313, a
   constituent Section 313 chemical is "processed" if ore is beneficiated for distribution in
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   commerce (e.g, sale of a metal concentrate).  This is true whether the Section 313
   chemical is the target metal or a non-target metal. For example, when copper ore
   containing traces of lead is beneficiated for distribution in commerce, both lead and copper
   are processed.  In contrast, "otherwise use" implies non-incorporation; the chemical is not
   intended to become part of a product.  For example, the use of sodium cyanide  to extract
   gold from gold ore represents an "otherwise use" of an EPCRA Section 313 chemical.

•  Otherwise Used Activities and Definitions

   •   As a chemical processing aid
            A chemical 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 of such Section 313 chemicals include, but are not
            limited to, process solvents, catalysts, inhibitors, initiators, reaction
            terminators, and solution buffers.
   •   As a manufacturing aid
            A chemical that aids the manufacturing process that 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, but are not limited to, process lubricants,
            metalworking fluids, coolants, refrigerants, and hydraulic fluids.
   •   Ancillary or other use
            A chemical that is used at a facility for purposes other than aiding
            chemical processing or manufacturing as described above. Examples
            of such Section  313 chemicals include, but are not limited to, cleaners,
            degreasers, lubricants,  fuels, and chemicals used for treating wastes.

For purposes of the otherwise use definition, EPA interprets waste management activities to
include recycling, combustion for energy recovery, treatment for destruction, waste stabilization,
and release, including disposal. Waste management does not include the storage, container
transfer, or tank transfer of a  Section 313 chemical if no recycling, combustion for energy,
treatment for destruction, waste stabilization, or release of the chemical occurs at the facility.
(See 62 FR 23 850)

For purposes of the otherwise use definition, EPA interprets waste management activities to
include recycling, combustion for energy recovery, treatment for destruction, waste stabilization,
and release, including disposal. Waste management does not include the storage, container
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transfer, or tank transfer of a Section 313 chemical if no recycling, combustion for energy,
treatment for destruction, waste stabilization, or release of the chemical occurs at the facility.
(See 62 FR 23850)

Recycling for the purposes of EPCRA Section 313 means the following: (1) the recovery for
reuse of a Section 313 chemical from a gaseous, aerosol, aqueous, liquid, or solid stream; or
(2) the reuse or the recovery for use of a Section 313 chemical that is a RCRA hazardous
waste as defined in 40 CFR Part 261.  Recovery is the act of extracting or removing the toxic
chemical from a waste  stream and includes: (1) the reclamation of the toxic chemical from a
stream that entered a waste treatment or pollution control device or process where destruction
of the stream or destruction or removal of certain constituents of the stream occurs (including
air pollution control devices or processes, wastewater treatment or control devices or
processes, Federal or state permitted treatment or control devices or processes, and other types
of treatment or control devices or processes); and (2) the reclamation for reuse of an
"otherwise used" toxic chemical that is spent or contaminated and that must be recovered for
further use in either the original or any other operations. (See EPA document, Interpretations
of Waste Management Activities: Recycling, Combustion for Energy Recovery, Waste
Stabilization and Release.)

Combustion for energy recovery is interpreted by EPA to  include the combustion of a Section
313  chemical that is (1) (a) a RCRA hazardous waste or waste fuel, (b) a constituent of a
RCRA hazardous waste or waste fuel, or (c) a spent or contaminated "otherwise used"
material; and that (2) has a heating value greater than or equal to 5,000 British thermal units
(BTU) per pound in an energy or materials recovery device. Energy or materials recovery
devices are boilers and industrial furnaces as defined in 40 CFR §372.3 (See 62 FR 23891).
In determining whether an EPCRA Section 313 listed toxic chemical is combusted for energy
recovery, the facility should consider the BTU value of the toxic chemical and not of the
chemical stream. If the heating value of the Section 313 chemical is below 5,000 BTU, the
chemical is being treated for destruction.  A facility that blends and subsequently distributes in
commerce a waste-derived  fuel "processes" EPCRA Section 313 listed toxic chemicals that are
constituents of that waste-derived fuel. In contrast, if subsequent to blending the waste-
derived fuel, that same facility combusts on-site the waste-derived fuel in an energy recovery
unit, the facility "otherwise uses" EPCRA Section 313 listed toxic chemicals that are
constituents of that waste-derived fuel. An EPCRA Section 313  listed toxic chemical that has
a heat value of less than 5,000 BTUs and that is a constituent of a waste-derived fuel is
"otherwise used" if that fuel is combusted hi an on-site energy recovery unit (62 FR 23851).

EPA defines Treatment for destruction to mean the destruction of a Section 313 chemical hi
waste such that the substance is no longer the toxic chemical subject to reporting under
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EPCRA Section 313. Treatment for destruction does not include the destruction of a Section
313 chemical in waste where the Section 313 chemical has a heat value greater than 5,000
British Thermal Units (BTU) and is combusted hi any device that is an industrial boiler or
furnace. (See 40 CFR §372.3.) "Treatment for destruction" includes acid or alkaline
neutralization if the toxic chemical is the entity that reacts with the acid or base.  "Treatment
for destruction" does not include: (1) neutralization of a waste stream containing toxic
chemicals if the toxic chemicals themselves do not react with the acid or base (See 40 CFR
§372.3), (2) preparation of a toxic chemical for disposal, (3) removal of toxic chemicals from
waste streams, and (4) activities intended to render a waste stream more suitable for further
use or processing, such as distillation or sedimentation. For example, neutralization of pure
nitric acid is considered treatment for destruction. In contrast,  neutralization of nitric acid
containing three percent lead is not considered treatment for destruction of the lead
component, because the lead has not reacted with the neutralizing agent (See 62 PR 23852).

EPA defines Waste stabilization to mean any physical or chemical process used to either
reduce the mobility of hazardous constituents hi a  hazardous waste or eliminate free liquid as
determined by a RCRA  approved test method (e.g., Test Method 9095).  A waste stabilization
process includes mixing the hazardous waste with  binders or other materials and curing the
resulting hazardous waste and binder mixture.  Other synonymous terms used to refer to this
process are  "stabilization," "waste fixation," or "waste solidification."  (See 40 CFR §372.3.)

Release is defined by EPCRA Section 329(8) to mean any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping,  or disposing into the
environment (including the abandonment or discarding of barrels, containers, and other closed
receptacles) of any toxic chemical. (See 40 CFR §372.3.)

Disposal is defined by EPCRA to mean any underground injection, placement in
landfills/surface impoundments,  land treatment, or other intentional land disposal.  (See 40
CFR §372.3.)


Beneficiation means the preparation of ores to regulate the size (including crushing and
grinding) of the product, to remove unwanted constituents, or to improve the quality, purity,
or grade of a desired product.  (See 40 CFR §372.3.) This definition is broad and includes,
all activities mining facilities considered to be beneficiation under the Resource Conservation
and Recovery Act (RCRA) definition of beneficiation found at 40 CFR §261.4(b)(7), which
states:
       "...beneficiation of ores and minerals is restricted to the following activities:
       Crushing; grinding; -washing; dissolution; crystallization; filtration; sorting;

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       sizing; drying; sintering; pelletizing; briquetting; calcining to remove -water
       and/or carbon dioxide; roasting, autoclaving, and/or chlorination in
       preparation for leaching (except where the roasting (and/or autoclaving and/or
       chlorination)/leaching sequence produces a final or intermediate product that
       does not undergo further beneficiation or processing); gravity concentration;
       magnetic separation; electrostatic separation; flotation; ion exchange; solvent
       extraction; electrowinning; precipitation; amalgamation; and heap, dump,  vat,
       tank, and in situ leaching."

Additional activities that occur to prepare ores through regulating the size of the product,
removing unwanted constituents, or improving the quality, purity, or grade of a desired
product are considered beneficiation for the purposes of EPCRA Section 313 reporting.

EPA believes that "overburden" and "waste rock" constitute two separate and discernable
types of waste (62 PR 23859).

Overburden is  the unconsolidated material that overlies a deposit of useful materials or ores.  It
does not include any portion of ore or waste rock.  Overburden is specifically exempt from TRI
reporting. (See  40 CFR §372.38(h).)

Waste rock as described in the preamble, "generally considered that portion of the ore body that
is barren or submarginal rock or ore which has been mined but is not of sufficient value to
warrant treatment and is therefore removed ahead of the milling processes.  Waste rock is part of
the ore body and may, depending on economic conditions, become a valuable source of a
metal..." (62 FR 23859)

Based on EPA's evaluation of the metal mining industry, the Agency believes that metal mining
activities routinely involve or result in the manufacturing, processing, or otherwise use of
EPCRA Section 313 chemicals (62 FR 23834, May 1, 1997). The term manufacture includes the
coincidental manufacture of a chemical, such as a byproduct or impurity, from the
manufacturing,  processing, otherwise use or waste management of another  chemical substance or
mixture. Thresholds must be calculated separately for manufacture, process, or otherwise use of
the same chemical.  If any single threshold is exceeded for a listed Section 313 chemical, the
facility must submit a Form R covering all nonexempt activities.  Metal mining facilities will be
required to factor into their threshold determinations and reporting calculations the quantities of
EPCRA Section 313 chemicals used in support activities such as froth flotation, non-motor
vehicle equipment maintenance, and dewatering.  Chemicals involved in these support activities
are classified under the otherwise use category.
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EXEMPTIONS

Section 313 provides for exemptions from reporting for specific "processing" or "otherwise use"
activities. The instructions provided in Toxic Chemical Release Inventory Reporting Form R and
Instructions should be reviewed carefully before proceeding. The following discussion
summarizes the exemption instructions.  A facility does not have to consider amounts of listed
Section 313 chemicals involved in any of these processing or otherwise use activities when
determining if activity thresholds have been exceeded or when estimating environmental
releases.  Limited exemptions apply to manufacturing activities. For example, manufacturing a
Section 313 chemical for research and development purposes and manufacturing as an impurity
below a specified level in a product distributed beyond the facility both can be exempt. The
EPA's Toxic Chemical Release Inventory Questions and Answers, Revised 1990 Version [EPA
560/4/91-003 (will be revised in near future)]  and the Toxic Release Inventory Reporting Form
R and Instructions also contain information about these exemptions. (See Appendix B  for
ordering information.)

•  The de minimis exemption allows facilities to disregard certain minimal concentrations of
   chemicals in mixtures or trade name products they "process" or "otherwise use" in making
   threshold determinations and release and other waste management determinations.  Any
   Section 313 chemical in ore or waste rock that is at a level below de minimis concentration
   and remains below the de minimis concentration throughout the extraction process does not
   have to be factored into threshold or release determinations for amounts processed by the
   facility. The de minimis exemption does not apply to  the "manufacture" of a Section 313
   chemical except if that Section 313 chemical is "manufactured" as an impurity and remains
   hi the product distributed in commerce below the appropriate de minimis level. The de
   minimis exemption does not apply to a byproduct "manufactured" coincidentally as a result
   of "manufacturing," "processing," "otherwise use," or any waste management activities.

   This de minimis exemption applies solely to "mixtures" and trade name products. EPA's
   long-standing interpretation has been that "mixture" does not include waste. Therefore, the
   de minimis exemption cannot be applied to Section 313 chemicals in a waste even if the
   waste is being "processed" or "otherwise used."

   When determining whether the de minimis exemption  applies to a Section 313 chemical, the
   owner or operator should only consider the concentration of the Section 313 chemical in
   mixtures and trade name products in process streams in which the Section 313 chemical is
   undergoing a reportable activity. If the Section 313 chemical in a process stream is
   "manufactured" as an impurity, "processed," or "otherwise used" and is below the
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   appropriate de minimis concentration level, then the quantity of the Section 313 chemical in
   that process stream does not have to be applied to threshold determinations nor included in
   release or other waste management determinations. If a Section 313 chemical in a process
   stream meets the de minimis exemption, all releases and other waste management activities
   associated with the Section 313 chemical in that stream are exempt from EPCRA section 313
   reporting. It is possible to meet an activity (e.g., processing) threshold for a Section 313
   chemical on a facility-wide basis, but not be required to calculate releases or other waste
   management quantities associated with a particular process because that process involves
   only mixtures or trade name products containing the Section 313 chemical below the de
   minimis level.

   Once a Section 313 chemical concentration is above the appropriate de minimis
   concentration, threshold determinations and release and other waste management
   determinations must be made, even if the chemical later falls below de minimis level in the
   same process stream. Thus, all releases and other quantities managed as waste which occur
   after the de minimis level has been exceeded are then subject to reporting.  If a Section 313
   chemical in a mixture or trade name product above de minimis is brought on-site, the de
   minimis exemption never applies.

   The de minimis  concentration level is consistent with the OSHA Hazard Communication
    Standard requirements for development of Material Safety Data  Sheets (MSDSs). The de
   minimis level is 1.0 percent except if the Section 313 chemical is an OSHA-defined
    carcinogen. The de minimis level for OSHA-defined carcinogens is 0.1 percent.  For
    mixtures or other trade name products that contain one or more members of a listed Section
    313 Section 313 chemical category, the de minimis level applies to the aggregate
    concentration of all such members and not to each individually.  The list of Section 313
    chemicals in the publication Toxic Chemical Release Inventory Reporting Form R and
    Instructions for the current reporting year contains the de minimis values for each of the
    Section 313 chemicals and chemical categories.

    Materials that are processed or used as articles - Quantities of a listed Section 313
    chemical contained in an article do not have to be factored into threshold or release
    determinations when that article is processed or otherwise used at your facility.  An article is
    defined as a manufactured item that is formed to a specific shape or design during
    manufacture, that has end-use functions dependent in whole or in part upon its shape or
    design during end-use, and that does not release a Section 313 chemical under the normal
    conditions of the processing or use of that item at the facility.
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    If the processing or otherwise use of like articles results in a total release of less than 0.5
    pounds of a Section 313 chemical in a calendar year to all environmental media, EPA will
    allow this release quantity to be rounded to zero, and the manufactured items remain exempt
    as articles. EPA requires facilities to round off and report all estimates to the nearest whole
    number. 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.


    The article exemption applies to the normal processing or otherwise use of an article.  It does
    not apply to the manufacture of an article. Thus, Section 313 chemicals processed into
    articles manufactured at a facility must be factored into threshold and release determinations.

    A closed item containing Section 313 chemicals (e.g., a transformer containing PCBs) that
    does not release the Section 313 chemicals during normal use is considered an article if a
    facility uses the item as intended and the Section 313 chemicals are not released. If a facility
    services the closed item (e.g., a transformer) by replacing the Section 313 chemicals, the
    Section 313 chemicals added during the reporting year must counted in threshold
    determinations.


    Materials that are structural components of the facility - Chemicals present in materials
    used to construct, repair, or maintain a plant building are exempt from the activity thresholds.
    For example, solvents and pigments present in paint used to coat the structural components of
    a building would be exempt from threshold determination and release reporting.

    Materials used for janitorial or facility grounds maintenance - Chemicals present in
    materials used for routine or facility grounds maintenance are exempt from the activity
    thresholds.  Examples include bathroom cleaners, fertilizers, and garden pesticides in the
    same form and concentration commonly distributed to consumers. Chemicals used for
    equipment maintenance, such as the use of oil or cleaning solvents, are not exempt.

    Materials used with facility motor vehicles - Chemicals present in materials used for
    operating and maintainrng motor vehicles operated by the facility are exempt from the
    activity thresholds. Examples include gasoline, radiator coolant, and windshield wiper fluid
    used in equipment such as cars, trucks, forklifts, and tow motors.

    Personal items - Chemicals present in materials such as foods, drugs, cosmetics, or other
    personal items are exempt from the activity thresholds. Examples include materials used in
    the facility cafeteria and infirmary. Chemicals used for heating and air conditioning solely to
    provide comfort to personnel are also exempt from reporting.  If a building's temperature is
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   regulated to facilitate a process or treatment operation, the Section 313 chemicals used to
   heat or cool the building are not exempt. Units that supply both personal comfort and
   operational needs may be apportioned, if it is possible to separate them.

•  Laboratory materials - Chemicals used in certain laboratory activities that are conducted
   under the supervision of a technically qualified individual (as defined under 40 CFR
   §720.3(ee)) are exempt from the activity thresholds. The laboratory activities exemption
   applies only to sampling and analysis, research and development, and quality assurance and
   quality control activities. The exemption does not apply to the use or production of listed
   Section 313 chemicals in pilot-plant operations and laboratories for distribution in commerce
   (e.g., specialty chemicals) and laboratory support services.

•  Materials  as they are drawn from the environment or municipal sources - Chemicals
   contained in intake water (used for processing or non-contact cooling) or in intake air (used
   either as compressed air or for combustion) are exempt from the activity thresholds.

•  Property owners - Property owners that merely own real estate on which a facility covered
   by Section 313 is located and have no business interest in the operation of that facility (e.g., a
   company owns an industrial park) are exempt for Section 313 reporting. The operator of that
   facility, however, is subject to reporting requirements.

SUPPLIER NOTIFICATION REQUIREMENTS

Because manufacturers reporting under Section 313 must know the Section 313 chemical
composition of the products they use to be able to accurately calculate releases, EPA requires
some suppliers of mixtures or trade name products containing one or more of the listed Section
313 chemicals to notify their customers of the identity of the chemical in the mixture or the trade
name product.  This requirement has been in effect since January 1, 1989.

A facility must comply with the Section 313 supplier notification requirements if it owns or
operates a facility which meets all of the  following criteria.

•   The facility is in SIC codes 20-39,

•   The facility manufactures, imports, or processes a Section 313 chemical, and
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   •   The facility sells or otherwise distributes in commerce a mixture or trade name product
       containing the Section 313 chemical to either:


            A facility described in 40 CFR §372.22 (covered facility group), or
            A facility that then sells the same mixture or trade name product to a facility
            described in 40 CFR §372.22 (covered facility group).


The supplier notification requirements do not apply to TRI chemicals that are themselves
wastestreams or are constituents of wastestreams.
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LISTED SECTION 313 CHEMICALS

Appendix A to this document contains an alphabetical listing of the chemicals subject to Section
313 reporting at the time of publication of this document, including their de minimis
concentrations.  EPA publications Common Synonyms for Section 313 Chemicals (EPA 745-R-
95-008) and Consolidated List of Chemicals Subject to Reporting Under the Act (Title III List of
Lists) (EPA-550-B-96-015) may also be useful references when reviewing the chemicals at your
facility for Section 313 coverage.

The list of Section 313 chemicals is amended frequently. Users of this guidance document or
other documents listing Section 313 chemicals are cautioned that changes may have occurred to
the list of Section 313  chemicals since publication of the original list or addition of the chemical
through administrative action. The list of Section 313 chemicals  presented in the Toxic Chemical
Release Inventory Reporting Form R and Instructions for the current reporting year should
always be consulted as the most up-to-date source of currently listed Section 313 chemicals. For
the latest information on Section 313 chemical listings, contact the EPCRA Hotline at 1-800-
535-0202.

Some of the Section 313 chemicals have qualifiers included with their names. Reporting on
these chemicals are determined by the conditions specified in the qualifiers.  Chemicals that are
listed without parenthetic qualifiers are subject to reporting in all forms in which they are
manufactured, processed, or otherwise used. Descriptions of the  qualifiers are as follows:

•   Fume or dust - Three of the metals on the list of Section 313 chemicals (aluminum,
    vanadium, and zinc) contain the qualifier "fume or dust."  Fume or dust refers to dry forms of
    these metals, not to "wet" forms such as solutions or slurries. Thus, a facility should
    determine if, for example, it generated more than 25,000 pounds of "aluminum (fume or
    dust)."  Similarly,  there may be certain technologies in which one of these metals is
    processed in the form of a fume or dust to make other Section 313 chemicals or other
    products for distribution in commerce.  In reporting releases,  the facility would report only
    releases of the fume or dusts.
    EPA considers dusts to consist of solid particles generated by any mechanical processing of
    materials including crushing, grinding, rapid impact, handling, detonation, and decrepitation
    of organic and inorganic materials such as rock, ore, and metal. Dusts do not tend to
    flocculate, except under electrostatic forces. A fume is an airborne dispersion consisting of
    small solid particles created by condensation from a gaseous state, in distinction to a gas or
    vapor. Fumes arise from the heating of solids such as aluminum. The condensation is often
    accompanied by a chemical reaction such as oxidation. Fumes flocculate and sometimes

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    coalesce. Other metals, (e.g., such as lead or copper) are not limited by this qualifier and are
    subject to reporting in all forms (fume, dust, and wet).


    Manufacturing qualifiers -Two of the entries in the Section 313 chemical list contain a
    qualifier relating to manufacture. For isopropyl alcohol, the qualifier is "manufacturing -
    strong acid process". For saccharin the qualifier simply is "manufacturing." For isopropyl
    alcohol, the qualifier means that only facilities manufacturing isopropyl alcohol by the strong
    acid process are required to report. In the case of saccharin,  only manufacturers of the
    Section 313 chemical are subject to the reporting requirements. A facility that processes or
    otherwise uses either Section 313 chemical would not be required to report for those
    chemicals. In both cases, the facility is not required to provide  supplier notification because
    only the manufacturer, not the user, of the Section 313  chemical must report.

    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) - The qualifier for ammonia means  that anhydrous forms of ammonia are
    100 percent reportable and aqueous forms are limited to 10 percent of total aqueous
    ammonia. Therefore, when determining thresholds, releases, and other waste management
    quantities all anhydrous ammonia is included but only  10 percent of total aqueous ammonia
    is included. Any evaporation of ammonia from aqueous ammonia solutions is considered
    anhydrous ammonia and should be included in the appropriate  threshold and release
    determinations.


    Phosphorus (yellow or white) - The listing for phosphorus  is qualified by the term "yellow
    or white" This means that only manufacturing, processing, or otherwise use of phosphorus in
    the yellow or white chemical forms require reporting. Conversely, manufacturing,
    processing, or otherwise use of "black" or "red" phosphorus  does not trigger reporting.

    Asbestos (friable) - The listing for asbestos is qualified by the term "friable," referring to the
    physical characteristic of being able to be crumbled, pulverized, or reducible to a powder
    with hand pressure. Only manufacturing, processing, or otherwise use of asbestos in the
    friable form triggers reporting.


    Aluminum oxide (fibrous forms) - The  listing for aluminum oxide is qualified by the term
    "fibrous forms." Fibrous refers to a man-made form of aluminum oxide that is processed to
    produce strands or filaments which can be cut to various lengths depending on the
    application. Only manufacturing, processing, or otherwise use of aluminum oxide in the
    fibrous form triggers reporting.
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                METAL MINING FACILITIES
•  Hydrochloric acid and sulfuric acid (acid aerosols including mists, vapors, gas, fog, and
   other airborne forms of any particle size) - The qualifier for hydrochloric acid and sulfuric
   acid means that only aerosol forms of this chemical are reportable. Aqueous solutions are not
   covered by this listing, but airborne forms generated from aqueous solutions are covered.

•  Nitrate compounds (water dissociable; reportable only when in an aqueous solution) -
   The qualifier for the nitrate compounds category limits the reporting to nitrate compounds
   that dissociate in water, and thereby generate nitrate ions. For the purposes of threshold
   determinations, the entire weight of the nitrate compound must be included in all
   calculations. For the purposes of reporting releases and other waste management quantities,
   only the weight of the nitrate ion should be included in the calculations of these quantities.

WHAT MUST BE REPORTED?

If your facility is included in the specified set of SIC codes, has ten or more full-time employees
or the equivalent, and manufactures, processes, or otherwise uses one of the listed Section 313
chemicals hi amounts greater than the appropriate thresholds, you must report the following
information on Form R:

•  Name and location of your facility;

•  Identity of the listed Section 313 chemical (unless you claim its identity to be a trade secret);

•  Whether you manufacture, process, or otherwise use the  chemical any other way;

•  Maximum quantity of the chemical on-site at any time during the year;

•  Quantities of the chemical released during the year to environmental media, including both
   accidental spills and routine emissions;

•  Quantities of the chemical subject to on site waste management actions, including recycling,
   energy recovery, or waste treatment;

•  Off-site locations to which you shipped wastes containing the chemical and the quantities of
   the chemical sent to those locations;
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
•  Information on source reduction activities; and

•  Treatment methods used for wastes containing the chemical and estimates of their efficiency
   for the reportable Section 313 chemical.

A release is defined under EPCRA Section 329(8) as any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the
environment of any listed Section 313 chemical. The definition of release includes the
abandonment or discarding of barrels, containers, and other closed receptacles. Separate release
estimates must be provided for releases to air, water, and land (e.g., deep well injection, surface
impoundment, permitted landfill).

DOCUMENTING REPORTING EFFORTS

Sound recordkeeping practices are essential for accurate and efficient TRI reporting. EPA
requires that facilities keep a copy of each Form R or Form A report filed for at least three years
from the date of submission (40 CFR §372.10). These reports will also be of use to facilities in
subsequent years when completing future Form R or Form A reports.  EPA also requires that
facilities maintain those documents,  calculations, worksheets, and other forms upon which they
relied to file Form R or Form A reports.  EPA may request this supporting documentation from
the facility, for example, to conduct data quality reviews of present or past Form R or Form A
submissions.

Supporting documentation, organized by year, that a facility should maintain may include, if
applicable:

•  Previous years' Forms Rs and Form As;
•  Section 313 Reporting Threshold Worksheets (a sample worksheet is given in the Toxic
   Chemical Release Inventory Reporting Form R and Instructions document;
•  Engineering calculations and other notes;
•  Purchase records from suppliers;
•  Inventory data;
•  EPA (NPDES) permits and monitoring reports;
•  EPCRA Section 312, Tier II Reports;
•  Monitoring records;
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TRI FORM R GUIDANCE DOCUMENT
               METAL MINING FACILITIES
   Flowmeter data;
   RCRA Hazardous Waste Generator's Report;
   Pretreatment reports filed by the facility with the local government;
   Invoices from waste management companies;
   Manufacturer's estimates of treatment efficiencies;
   RCRA Manifests; and
   Process diagrams.
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TRI FORM R GUIDANCE DOCUMENT
              METAL MINING FACILITIES
                               SECTIONS
                 MAKING THE THRESHOLD DETERMINATION

A separate Toxic Chemical Release Inventory Reporting Form must be submitted for each listed
chemical that is "manufactured," "processed," or "otherwise used" above an activity threshold at
your facility, assuming the SIC code and employee criteria are met.  Current EPCRA Section 313
guidance for metal mining facilities is shown in Table 3-1:
    Table 3-1. Examples of Manufactured, Processed, and Otherwise Used Chemicals
                                 at Metal Mines *
f~ff- ;f * *, ;, / ^Htl^aipdeipP ^ *** -* «*?*" |
Byproducts or coincidental^ manufactured Section 313 chemicals are not subject to the de
minimis exemption and all quantities of such chemicals should be included in your threshold
determination for manufacturing of the new Section 313 chemical. This includes Section 313
chemicals manufactured in tailings impoundments.
If an elemental metal is converted to a metal compound, or if one metal compound is
converted to another metal compound, then a metal compound has been manufactured, even
if it is within the same Section 313 metal compound category. The quantity of the Section 313
metal compound manufactured must be counted towards the 25,000 pound threshold.
Activity
Produced or imported for on-site
use/processing
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
Examples ;
Conversion of copper sulfide to copper sulfate in the
leaching process.
Conversion of copper sulfate to copper (cathodes) in
electrowinning.
Sulfuric acid aerosols formed by spraying sulfuric acid
solutions in the leaching process.
Conversion of trace amounts of compounds of lead,
copper, nickel, or mercury to elemental forms in gold dore
shipped offsite as product.
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TRI FORM R GUIDANCE DOCUMENT
               METAL MINING FACILITIES

The recovery of a Section 313 chemical from a mixture for further distribution is processing
of that chemical. Metal recovery from metal bearing ores that result in a product that is sold
should be considered in your threshold determination for processing activities. Similarly,
Section 313 metals in tailings distributed in commerce for reclamation must be counted
towards the processing threshold.
' A.iMflVS'tv
**V1k*T Ik*^
As a reactant
As a formulation component
As an article component
Repackaging only
Examples
Zinc dust that is used to precipitate gold from pregnant
gold-cyanide solutions. Flotation reagents such as
benzene, arsenic compounds, chromium compounds, and
copper compounds, used in mineral beneficiation that
remain in the product.
May not occur in metal mining.
Copper cathodes produced from electrowinning
May not occur at a mining facility.
te^r : - - v > v?W<-\
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TRI FORM R GUIDANCE DOCUMENT
               METAL MINING FACILITIES
•  For threshold determinations, the concentration of metal compounds is determined by the
   total weight percent of the compound, not the parent metal.

•  If more than one Section 313 metal compound within a Section 313 metal compound
   category is present in the ore, the concentration is determined by the total weight percent of
   all  compounds within a specific listed Section 313 category. That concentration would be
   used to determine the applicability of the de minimis exemption and to calculate threshold
   determinations, if appropriate. Facilities should factor in variability of the metal compounds
   within the ore. Variability in an ore body is expected. In calculating the activity threshold,
   the facility should develop an average based on known information. If sampling normally
   conducted by the facility produces results of varying concentrations, these should be
   averaged for an overall average concentration. If the facility has more than one extraction
   point, and sampling yields consistent results per point of extraction but different results as
   compared to other points of extraction (e.g., one area above de minimis and one below), then
   the facility may develop an activity threshold estimate separately for each area sampled for
   purposes of determining reporting thresholds.

•  The Section 313 chemicals present in "overburden," the unconsolidated material that overlies
   a deposit of useful materials or ores, is exempt from threshold determinations and release
   calculations if processed or otherwise used by metal mining facilities within SIC code 10.

•  Waste rock is not considered overburden because it is considered a portion of the ore body
   and may, depending on economic conditions, become a valuable source of a metal or metal
   compound. Waste rock that is separated from the ore body and deposited on-site or
   transferred off-site for purposes of disposal or other waste management activities has not
   undergone an EPCRA Section 313 reportable activity, and therefore, amounts of Section 313
    chemicals contained in the waste rock do not have to be considered towards activity
   thresholds.

 CONDUCTING THE THRESHOLD DETERMINATION
 An activity threshold determination must
 be made individually for each Section 313
 chemical by each activity in which the
 chemical is manufactured, processed, or
 otherwise used at your facility.  The
 threshold determination is one criterion
 used to ascertain whether a Form R or Form A is required to be submitted.
               STEP ONE
Identify Section 313  chemicals  that  are
manufactured, processed or otherwise used.
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 TRI FORM R GUIDANCE DOCUMENT
                                                          METAL MINING FACILITIES
 The primary function of most mining facilities is the extraction and beneficiation of metal ore to
 produce a metal concentrate. The purpose of beneficiation is to concentrate the valuable metal in
 the ore by separating the valuable portion from the non-valuable, portion. The beneficiation
 method or methods used vary with mining operations and depend on ore characteristics and
 economic considerations and include flotation, leaching, solvent extraction, electrowinning and
 other methods. To perform a comprehensive and accurate threshold determination, the facility
 must determine (1) what Section 313 chemicals (such as metals and metal compounds) are
 present in the mined ore and at what concentrations, (2) what Section 313 chemicals (such as
 metals and metal compounds) that are present in the mined ore below de minimis concentrations
 are concentrated above de minimis at some point in the beneficiation process, and (3) what
                                              chemicals (flotation agents, leaching agents,
                                              cyanides, equipment maintenance chemicals,
                                              waste treatment chemicals, etc.) are otherwise
                                              used during the beneficiation activities.
          Sulfuric Acid Aerosols

 Sulfuric acid is only a Section 313 chemical
 when it exists as an acid aerosol including
 mists, vapors, fog, and other airborne species
 of any particle size.  Producing a sulfuric acid
 aerosol from liquid sulfuric acid is considered
 "manufacturing"    under  TRI.  In  some
 leaching operations, dilute sulfuric acid is
 sprayed or dripped onto the ore. This spraying
 or dripping may result in the manufacture of
 sulfuric acid in the aerosol form. Facilities
 should apply the total volume of acid in the
 spraying system during the reporting year to
 the threshold, rather than count all quantities
 of acid aerosol generated in the system.  Since
the acid aerosols are "manufactured" and then
 "otherwise used" hi these acid reuse systems,
the 10,000 pound "otherwise  use" threshold
would be the threshold that would first trigger
reporting from such systems. For example, if
a facility starts the year with 2,000 pounds of
sulfuric acid hi the  system,  and adds 500
pounds  during the  reporting year, 2,500
pounds  of sulfuric acid aerosol would be
applied  to the manufacturing  and otherwise
use threshold.
                                              Some processing activities will involve the
                                              conversion or reaction of chemicals to
                                              produce a new chemical, such as occurs with
                                              chemical oxidation or chemical precipitation.
                                              Mining facilities should closely examine their
                                              processes to determine whether a Section 313
                                              chemical are manufactured. (See box.)


                                              Carefully examine the Section 313 list of
                                              chemicals in Appendix A and check the list of
                                              Section 313 chemicals in the publication
                                              Toxic Chemical Release Inventory Reporting
                                              Form R and Instructions for the current
                                              reporting year to determine whether the list of
                                              chemicals has been updated.


                                              Any chemical purchased by facilities  for use
                                              as processing or manufacturing aids or for
                                              treating waste are considered "otherwise
                                              used".  In addition, EPCRA Section 313
                                              chemicals in materials purchased to be used as
                                              fuel or for maintaining equipment operations,
                                              other than for maintaining motor vehicles,
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TRI FORM R GUIDANCE DOCUMENT
                                                          METAL MINING FACILITIES
should be included in the threshold determination for "otherwise use" activities. Any EPCRA
Section 313 chemicals in materials purchased to be used in the waste management processes
should also be included in the threshold determination for "otherwise use" activities.
                                                        STEP TWO
                                          Identify "processing" and "otherwise use"
                                          activities that are subject to exemptions.
                                          Exclude  chemicals associated with these
                                          activities     from     your     threshold
                                          determination.
When performing your threshold
determinations, it is important to
remember that exemptions apply to
certain facility-related activities. These
exemptions were discussed in Section 2 of
this guidance document and may apply
only to certain "manufacturing,"
"processing," or "otherwise use"
activities. For the purposes of an activity
threshold analysis, the following areas should be examined closely to determine whether the TRI
chemicals subject to certain activities should be included in the activity threshold and reporting
calculations:

•  Overburden: The Section 313 chemicals present in "overburden," the unconsolidated
   material that overlies a deposit of useful materials or ores, are exempt from threshold
   determinations and release calculations if processed or otherwise used by metal mining
   facilities within SIC code 10.

•  Laboratories: Sampling and analysis, research and development (R&D), and QA/QC
   activities undertaken in laboratories are exempt if conducted under the supervision of a
   technically qualified individual. Pilot plants and support services, such as photo processing,
   waste water treatment, and instrument sterilization are not exempt. Wastes generated during
   sampling and analysis, R&D, and QA/QC activities in an on-site laboratory are exempt.

•  Motor vehicles: Use of products containing Section 313 chemicals used for maintaining
   motor vehicles operated by the facility are exempt, as well as the fuels used in those vehicles.

•  Routine janitorial or facility grounds maintenance: The routine maintenance exemption is
   intended to cover janitorial or other custodial or plant grounds maintenance activities using
   such substances as bathroom cleaners, or fertilizers and pesticides used to maintain lawns, in
   the same form and concentration commonly distributed to consumers. Equipment
   maintenance such as the use of oil or grease is not exempt.
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TRI FORM R GUIDANCE DOCUMENT
                                                         METAL MINING FACILITIES
    Materials as they are drawn from the environment or municipal sources- Chemicals
    contained in intake water (used for processing or non-contact cooling) or in intake air (used
    either as compressed air or for combustion) are exempt from the activity thresholds.
    However, EPCRA Section 313 chemicals manufactured from use of the air or water are not
    exempt and must be considered for the threshold determination.
                                                      STEP THREE
                                         Determine  whether TRI  chemicals  are
                                         present in mixtures or trade name products
                                         that are processed or otherwise used below
                                         the de minimis concentration threshold and
                                         eliminate from further consideration in your
                                         processing  and  otherwise use  threshold
                                         determination those chemicals  below de
                                         minimis, unless those chemicals are later
                                         concentrated.   Also  determine  whether
                                         chemicals are present as impurities below
                                         the de minimis concentration threshold in
                                         manufactured products and eliminate from
                                         further     consideration     in     your
                                         manufacturing  threshold  determination
                                         those chemicals below de minimis.
In making threshold determinations, it is
important that you keep in mind that a de
minimis exemption applies only to Section
313 chemicals in mixtures or trade name
products manufactured as impurities or
processed or otherwise used in mixtures
or trade name products. This exemption
does not apply to chemicals that are
manufactured as byproducts nor does it
apply to chemicals in wastes that are
processed or otherwise used.

Metal mining facilities should bear in
mind that metal beneficiation processes
concentrate metals and/or metal
compounds. In  instances where the ore as
mined did not contain Section 313
chemicals above the de minimis
concentration, concentrating the metal and/or the metal compounds could result in the metal
and/or the metal compound being present above the de minimis concentration. From the point at
which the metal and/or the metal compound meets or surpasses the de minimis concentration, the
metal should be included in your threshold determination and release estimates. For example,
metals may become concentrated in a tailings pond.

Section 313 chemicals present at less than 1 percent (<10,000 ppm) for chemicals that do not
meet the OSHA carcinogen standard or less than 0.1 percent (<1,000 ppm) for chemicals that do
meet the OSHA carcinogen standard do not have to be considered when making your threshold
determinations for processing or otherwise use.  Appendix A to this document contains the list of
Section 313 chemicals subject to reporting, along with the de minimis concentration associated
with the chemical. The list of Section 313 chemicals in the publication Toxic Chemical Release
Inventory Reporting Form R and Instructions for the current reporting year should also be
checked to determine whether the list of chemicals has been updated (e.g., changes in listed
chemicals and chemical categories, and de minimis levels).
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                  METAL MINING FACILITIES
Threshold determinations are made based
on the best available information in your
possession. Inventory data, consumption
information, and supplier notifications
can be used in determining the amount of
chemickls used for the purpose of making
a threshold determination. In general, the
type of data to be used in calculating
threshold determinations is shown below:
   Analysis prior to extraction,
   Analysis during/after beneficiation,
   Analysis during/after leaching,
   Volume determination, or
   Estimations.
               STEP FOUR
 Gather data  needed  for calculations
 threshold determination, including:

 •      Inventory Data
 •      Consumption Information
 •      Supplier Notification
 •      Ore Sampling and Analysis Data
        MSDS
 •      Analysis of Waste Products
 •      Permits
V	
 A
of
Where data are lacking and the metal mining facility has reason to suspect that a TRI chemical is
present, reasonable estimates should be made.  For example, a typical concentration may be
established based on best engineering judgement. Where the metal mining facility does not have
a reason to suspect that such a Section 313 chemical is present in a mixture, that mixture need
not be included in the threshold determination.

Further, tailings impoundments found  at mining operations perform a number of functions,
including the following:

    •    Removal of suspended solids by sedimentation
    •    Precipitation of heavy metals as hydroxides
    •    Permanent containment of settled tailings
        Stabilization of some  oxidizable constituents (e.g., thiosalts, cyanides, flotation reagents)
    •    Storage and stabilization of process recycle water
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 TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
   Sources of Information for Metal Compound
            Threshold Determinations

   Metal mining facilities should use the best
   available information for determining thresholds
   of metal compounds in ore. In the absence of
   recent data (such as current ore analysis),
   historical data such as those collected before or
   during the mine's first operations may provide
   reasonable estimates. Metal mining facilities
   that only know total elemental metal
   concentrations in ore, (i.e., do not know the
   specific compounds present in the ore), can use
   additional information to make a reasonable
   threshold determination. For example, if the
   facility has information indicating that the metal
   will naturally exist as a particular type of
   compound (e.g., copper sulfides) the facility can
  assume the metal exists as the lowest weight
  sulfide compound (e.g.,  CuS). If the facility
  has no information on the type of compound
  that is present (e.g., does not know if a non-
  target metal exists as a sulfide, oxide, carbonate,
  etc.), they may assume that the metal exists as
  the lowest weight oxide.

        Some or all of these functions can result
        in the manufacture of Section 313
        chemicals that are subject to reporting,
        such as the manufacture of a metal
        hydroxide that is a Section 313 chemical.
        Other chemicals may be added to the
        tailings impoundment to promote
        precipitation, stabilization, or oxidatipn.
        If these are Section 313 chemicals, they
        are "otherwise used" and should be
        considered in making threshold
        determinations, as discussed in this
        section, as well as release estimates, as
        discussed in Section 5.


        Threshold determinations are made based
        on the best available information in your
        possession. In general, the following
        methods should be employed to
        determine the appropriate concentrations
        to use in threshold determinations:


        •   If the exact concentration is known
           (e.g., 33.0% toluene), use it.
    If only the upper bound is known (e.g.,
    <5% toluene), use it (e.g., 5% toluene).

    If the concentration is know (e.g., 10-30%
    toluene), then use the midpoint (e.g., 20%
    toluene).

    If only the lower bound is known, assume
    the upper bound is 100%. Factor out
    other known constituents (e.g.,  10% water
                 STEP FIVE
   Calculate the quantity of each chemical
   manufactured, processed  and  otherwise
   used, in pounds, to determine whether the
   activity threshold has been exceeded. The
   Form  R must  be completed  for  each
   chemical otherwise used in excess of 10,000
   pounds and for each chemical processed in
   excess of 25,000 pounds, for each chemical
   manufactured in excess of 25,000 pounds.
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                 METAL MINING FACILITIES
    and >60%toluene), create a range (e.g., 60-90% toluene) and then use the midpoint (e.g., 75%
    toluene).

In cases where certain materials that have broad ranges or high upper bounds for multiple
constituents (e.g., %x+%y+%z=l 10% of mixture), the total components of a mixture should not
exceed 100%. In these instances, the best available information should be used to estimate the
approximate concentration of the chemicals in the material. However,  if a facility is aware that a
chemical is probably present in a mixture but has no information on its concentration in the
mixture, then they are not required to consider that chemical in its threshold determinations.
                             THRESHOLD DETERMINATIONS FOR
                                 ELEMENTS AND COMPOUNDS

   Many metals are Section 313 chemicals, and a mine that processes quantities of Section 313 metals in
   excess of the 25,000-pound per year threshold must complete a Form R for the metal and estimate releases if
   the concentrations of these metal ever meet or exceed the de minimis concentration during the beneficiation
   process. (See Appendix A for list of chemicals and de minimis concentrations) The metal in the ore can
   exist in its elemental form but more commonly exists in the compound state. Antimony compounds,.
   arsenic compounds, barium compounds*, cadmium compounds, chromium compounds, cobalt compounds,
   copper compounds*, lead compounds, manganese compounds, mercury compounds, nickel compounds,
   selenium compounds, silver compounds, thallium compounds, and zinc compounds are separate Section 313
   chemical categories distinct from the elemental form.

   Therefore, two separate and exclusive threshold determinations must be made — one for the elemental
   metal and one for total metal compounds. Threshold determinations for the metal compound categories
   require the calculation to be made on the cumulative weight of all metal compounds in that category that are
   in a mined ore. If the mined ore contains metal compounds at or above the de minimis concentration by
   weight on a compound basis or if the mined ore is beneficiated and the metal compounds are concentrated
   such that the total concentration of metal compounds is at or above the de minimis concentration, then
   releases of the parent metal only need to be estimated and reported from the point in the process in which the
   metal compounds first meet or exceed the de minimis level.  For mined ores containing more than one
   member of a listed Section 313 metal compound category, the de minimis level applies to the aggregate
   concentration of all members within the listed category, and not to each individually.

   Ore also may contain other metals or metal compound categories than the valued minerals. If the
   concentration of these other metals or metal compounds exceed the de minimis concentration, then releases of
   these metals also need to be reported.

   Compounds that contain metals from one or more different metal compound categories are counted
   towards the threshold for each category. For example, the entire weight of Cu3AsS4 (enargite) would be
   considered towards thresholds for both copper compounds and arsenic compounds.

   *See Appendix A for exceptions to the copper compounds and barium compounds categories.
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TRI FORM R GUIDANCE DOCUMENT
               METAL MINING FACILITIES
                                     SECTION 4
               OVERVIEW OF SECTION 313 RELEASE ESTIMATION

This section presents general guidelines for preparing Section 313 release estimates. It begins
with a discussion of general ideas on estimating chemical releases. A summary of errors that
commonly occur in Section 313 reporting follows.

GENERAL CONCEPTS

Release Estimation

A Form R or Form A must be completed for each Section 313 chemical that meets the applicable
activity thresholds. Each form requests facility specific information and identifies the chemical
for which thresholds were exceeded. Form A (the abbreviated report) includes a statement that
the facility did not exceed specified amounts while, the main components of Form R are
environmental release estimates to all media for the reportable chemical during the preceding
calendar year.  This includes all wastes containing the reportable Section 313 chemical that are
sent off-site from the facility for further waste management. Specifically, facility release
estimates must be made for the following release sources:

•  Releases to air from fugitive or non-point sources (Section 5.1)

•  Releases to air from stack or point sources (Section 5.2)

•  Releases to water directly discharged to a receiving stream (Section 5.3)

•  Releases in wastes that are injected underground (Section 5.4)

•  Releases to land on-site (Section 5.5)

•  Releases to water discharged to a publicly owned treatment works (POTW) (Section 6.1)

•   Wastes transferred off-site for recycling, energy recovery, waste treatment, or disposal
    (Section 6.2)
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TRI FORM R GUIDANCE DOCUMENT
                  METAL MINING FACILITIES
 Waste Rock

 As discussed in Section 3 of this document, waste rock
 that is separated from the ore body and deposited on-
 site or transferred off-site for purposes of disposal or
 other waste management activities has not undergone
 an  EPCRA  Section  313  reportable  activity,  and
 therefore, amounts of Section 313 chemicals contained
 in the waste rock do not have to be considered towards
 activity thresholds.

 However, because the waste rock has not undergone a
 reportable   activity  does   not  infer  that  waste
 management activities associated with the waste rock
 are exempt.  In the above description (where the waste
 rock is simply disposed of), amounts  of the EPCRA
 Section 313 chemicals in the waste rock  must be
 considered for release and other  waste management
 reporting (e.g., disposed to land on-site), provided that
 an activity threshold has been exceeded elsewhere at the
 facility.

 Additionally, because the waste rock has not undergone
 a "threshold activity", (i.e., "manufacture, process, or
 otherwise use") amounts of EPCRA Section 313
 chemicals further managed as waste are not eligible for
 the de minimis exemption.

 Amounts of EPCRA Section 313  chemicals in waste
 rock must be considered toward the "processing"
 threshold if the waste rock is distributed in commerce
 for beneficial reuse (e.g., as  roadfill),  or if the waste
 rock undergoes beneficiation (actually  no longer
    Development of accurate and comprehensive
    release estimates requires consideration of all
    possible release pathways. The threshold
    determination provides valuable information
    when beginning the release estimation
    process for a Section 313 chemical: each
    material containing a Section 313 chemical is
    identified.  For each of these materials, the
    facility should identify all potential release
    sources. A useful way to do this is to draw a
    process flow diagram that traces the
    material's path through the plant.  The
    process flow diagram should identify each
    major piece of equipment (including
    pollution control devices) through which the
    material passes, from its initial entry into the
    facility to its final disposition. The diagram
    should  also identify all potential release
    sources and pollution control equipment for
    the chemical.
       Underground Mines

       Waste rock that remains underground is
       reported as a release to land (Part II, Section
       5.5.4 of Form R - Other Disposal).  Fugitive
       emissions underground that are not released to
       the  air but  settle underground   are also
       reported as a release to land (Section 5.5.4 of
As a guide to better understanding releases,
Figure 4-1 presents the steps typically used in the copper mining industry, beginning with
extraction. Releases associated with extraction are reportable, with the exception of releases
from overburden, which are exempt under 40 CFR §372.38(h).  Overburden is the
unconsolidated material that overlies a deposit of useful materials or ores. Figure 4-1 presents
the extraction phase at the top, in tihe white box. Potential release pathways include disposal of
leach ore in leach dumps, disposal of waste rock in waste dumps, and releases to surface water.
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TRI FORM R GUIDANCE DOCUMENT
                    METAL MINING FACILITIES
Figure 4-1. Schematic of Typical Copper Mining Extraction and Beneficiation Wastestreams
                                      (PPT
                                       (IX) bnExchang*
                                       {A) Pregnant Solution
                                       {8} Bairen Solulkxi
                                       (C) Maka Up Water
                                       (0) Leach Circuit
                                         Thickener
                                       (E)
                       Watte Types
                   A. Watt* Dumps
                   B UuhOump
                   C. NPDESSurivxWitirOtschvga
                   D. Surfmca Water Run-off
                   E. LHch Circuit Sludges from SX/EW
                   F. Floatallon Circuit ClMnouts
                    (goneralty radalmed)
                   Q. Solid
                   H. NPOES TaBingi Olcchvg*
                    (limited In arid envfranmsnti)
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In the copper beneficiation process, crushing and grinding, flotation1, and leaching are used.
Figure 4-1 also presents the potential solid waste and water releases from these processes as well
as the points where on-site recycling or reclamation can occur.  In addition to land and water
releases and recycling activities shown, mines will have fugitive air emissions of fume and dust
(all particle sizes are included). These air emissions will be higher in dry operations than in wet
operations, and should also be considered in Section 313 reporting.  Mines can utilize process
flow diagrams, such as the one presented in Figure 4-1, to identify potential points of release of
Section 313 chemicals.  (The boxes which differentiate extraction and beneficiation in Figure 4-1
are for illustrative purposes only.  Any official determination of the RCRA status of a mining
activity should be obtained from the appropriate State or EPA Region.)

After you have identified all the potential release sources for a chemical, you can estimate
releases for each source.  Often, the starting point for a release estimate is chemical throughput
data, which are typically available from threshold determination calculations.

Given the chemical throughput quantities for a process, you must apply other data and
assumptions to complete the estimates.  This information includes process-specific data (e.g.,
scrubber efficiency) and any data developed for other environmentally oriented purposes (e.g.,
air and wastewater monitoring data, air and water permits and permit applications, RCRA
manifest data, monitoring data).

Section 313 does not require any new monitoring to be performed.  Facilities should use existing
data to calculate release estimates. The accuracy of a release estimate  is proportional to the
quantity and quality of the data used in its preparation. Situations may arise where estimates
based on one set of data contradict estimates based on another. In such cases, the facility should
document the rationale for using one data set (or method) versus another.  If a facility is aware
that a chemical is probably present but has no method to estimate releases or quantities on site,
then they are not required to report on that chemical.

Release estimates can be developed by combining all available data with assumptions concerning
the fate of each chemical in the process.  There are four general methods for developing a release
estimate.  These methods may be used together or in sequence in developing release estimates.
       1 Flotation is the process where particles of one or more minerals are preferentially wetted by various
agents causing the hydrophobic minerals to adhere to the surfaces of air bubbles. As the air bubbles rise to the
surface, the desired minerals are transported to the surface and are removed by skimming. See Chapter 5 for more
details.
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       Direct measurement (basis of estimate code = M; entered in Part II Sections 5 and 6) -
       These are estimates based on actual monitoring of the concentration of a chemical.  The
       chemical's concentration in the waste stream multiplied by the flow rate or volume of the
       waste stream and its density yields the mass of the chemical released.  Direct
       measurement is typically used to estimate releases via wastewater, solid waste, and
       hazardous waste, in part, to ensure compliance with applicable environmental regulations.
       Although this estimation method should yield the most accurate results, only rarely are
       sufficient data available for direct measurement data to be applied without also resorting
       to other techniques (e.g., engineering calculations, mass balance).  The frequency of the
       direct measurements should be taken into account when determining if monitoring data
       alone are sufficient for making a reasonable estimate. For example, if a facility has only
       gathered monitoring data once throughout the year, other methods may provide a more
       accurate estimate.

       Note that if a measurement indicates that a Section 313 chemical is below detection, this
       is not equivalent to stating that the chemical is not present. If the Section 313 chemical is
       known to be present, a concentration equivalent to half the detection limit should be used
       in subsequent calculations of release estimate quantities (i.e., if the limit of detection is 10
       mg/1, release calculations  should be performed during a concentration of 5 mg/1). If the
       Section 313 chemical is not known to be present in the  waste, then zero can be assumed.

       Mass balance (basis of estimate code = C entered in Part II, Sections  5 and 6) - These are
       estimates based on a knowledge of the quantity of a chemical entering and leaving a
       process. An imaginary boundary is first drawn around the process, and all streams
       entering or leaving the boundary are identified. Assuming the amount of the chemical in
       the process input streams is known, a facility could calculate the quantity in waste
       streams by difference. A facility would need to account for any accumulation or
       depletion of the chemical  within the mass balance boundary. The equation for mass
       balance is:

              Input + Generation - Output + Amount Reacted + Accumulation

       Using a mass balance to estimate a relatively small release of a chemical with a large
       throughput can lead to inaccurate, or even negative release estimates.  Even a small
       percentage error in a large throughput could amount to  a greater quantity than the release
       recalculated. When several large values each with their respective errors are used to
       calculate a small release, propagation of errors occurs which could yield a highly
       inaccurate value. Other techniques should be considered in these situations.
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       Mass balance estimates usually require engineering calculations or assumptions to be
       made (e.g., all usage results in air or water releases). These assumptions should be
       explicitly stated in the documentation and should be checked for reasonableness.

•      Emission factors (basis of estimate code = E entered in Part II, Sections 5 and 6) -
       Release information derived from facilities or processes similar to yours can be used to
       estimate releases. Emission factors come in two forms. The first expresses releases as a
       ratio of the amount of chemical released to facility throughput or production (e.g., 0.5
       pound of Chemical X released per every pound of Material Y used). The second provides
       a typical concentration of a chemical in a waste stream (e.g., 0.1 mg/L of Chemical Z in
       wastewater from scrubbers).  These factors, combined with process throughput or waste
       stream flow data, can be used as a basis for the release estimate.  Many emission factors
       are available in Compilation of Air Pollutant Emission Factors (AP-42). AP-42 can be
       accessed via the Internet at http://www.epa.gov/ttn/chief/ap42etc.html.  The basis of
       estimate code "E" can only be used for published Section 313 chemical-specific emission
       factors.

       The reliability of emission factors depends on the quality and quantity of data used in
       their derivation, plus the similarity of the process to which they are applied and the
       quality of raw materials for the process.

•      Engineering calculations and assumptions (basis of estimate code = O entered in Part
       II, Sections 5  and 6) - Estimates that do not fall into any of the above categories are
       considered engineering c.alculations. Typically, these estimates are based on standard
       engineering principles using properties of the chemicals involved, process data, or
       process knowledge. Example chemical properties include vapor pressure, solubility in
       water, and density. Example process parameters include temperature, pressure, and
       material flow rate.  Other examples of engineering calculations would be the use of
       general equipment emissions factors or non-published, facility-developed emissions
       factors.

Reasonable Estimates: Significant Figures and Use of Range Codes

EPA recommends that two significant figures be used when reporting release and off-site transfer
quantities in Part II, Sections 5 and 6 of Form R. Use of two significant figures may prevent
errors from being reported on Form R, because a small calculating error may not impact the final
reported quantity if the quantity is rounded to two significant figures.  If you have reason to
believe that your best estimate of a release quantity is particularly imprecise, you could use one
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significant figure or one of the range codes in reporting releases in Part II, Sections 5 and 6 of the
Form R, if applicable:

       Range Code A = 1 to 10 pounds
       Range Code B = 11 to 499 pounds
       Range Code C = 500 to 999 pounds

"NA" versus "0"


If you have no releases of a Section 313 chemical to a particular medium, report either "NA,"
not applicable, or "0," as appropriate. Report "NA" only when there is no possibility a
release could have occurred to a specific medium or off-site location.  If a release to a specific
medium or off-site location could have occurred, but either did not occur or the annual aggre-
gate release was less than 0.5 pounds, report zero.  However, if you report zero releases, a
basis of estimate must be provided. If use of the Section 313 chemical began in the reporting
year, enter "NA" as the production ratio or activity index (Part II,  Section 8.9  of the Form R).

For example, if nitric acid is involved hi the facility's processing activities but the facility
neutralizes the wastes to a pH of 6 or above, then the facility reports a "0" release for the
Section 313 chemical.  If the facility has no underground injection well, "NA"  would be
written in Part I, Section 4.10 and checked in Part II, Section 5.4.1 and 5.4.2 of Form R.
Also, if the facility did not use the Section 313 chemical in the previous year, the facility
would have no basis  to develop a production ratio or activity index, "NA" would be checked
in Part II, Section 8.9 of Form R.

REPORTING RELEASES IN FORM R, PART II

The following sections discuss the types of release reporting required on the Form R. Releases
must be partitioned into land and air releases and should not be inadvertently "double counted."
For example, a single wastewater discharge should not be listed as both a release to water (on-
site) and a discharge to a POTW (off-site), nor should a release to land be listed as a release to
both land (on-site) and a transfer to an off-site landfill. Also, subsequent releases from land
(such as a leak from an impoundment) to groundwater is included as a land release in the year the
leakage occurred. No reporting is required past the year in which it occurred,even if it leaches
out to ground water in the next year.
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It is important to note that historical releases are not included in release reporting. For example,
contamination around an underground storage tank (UST) is discovered, but there is no active
leak from the tank.  If you know that the contamination occurred during the reporting year (RY),
then report the leak as a release to land. However, if the leak did not occur during the RY, it
should not be included hi release reporting.

Metal mining facilities that close during the reporting year count all quantities of Section 313
chemicals manufactured, processed, or otherwise used during the entire reporting year. Similarly,
all quantities of Section 313 chemicals released or managed as waste during the reporting year
are reported in the appropriate section of the Form R.  Section 313 chemicals in waste rock,
tailings, or other wastes left on land are reported as releases to land (Part II, Section 5.5.4 of
Form R).

Finally, the amount of leaks or spills onto pads or containment areas should not automatically be
reported as released to land. The amount should be considered as treated or disposed depending
on type of disposal activity. After releases to air, amounts cleaned up and disposed of off-site,
amounts recycled, and amounts released to water are considered, then the amount remaining on
the pad is considered to be released to land.  Amounts spilled into containment that are directly
reused within the same reporting year without requiring treatment prior to reuse are not subject to
release reporting.

Fugitive or Non-Point Emissions (Part II, Section 5.1 of Form R)
Fugitive emissions can occur from almost any part of a facility's operation. Potential sources
include the following:
       Normal leakage of valves, pump
       seals, flanges, connectors, and
       other devices
       Sampling, Packaging, Loading,
       and unloading of chemicals
       Cleaning and maintenance
       activities such as blowing out pipes
       Containers of raw materials,
       intermediates, or wastes
       Storage piles and spills
       Evaporation from cooling towers,
       ponds, surface
TSCREEN and SHEAR

To  estimate  emissions  from  tailings  piles,  the
TSCREEN model can be used to correctly analyze
toxic emissions and their subsequent dispersion from
one of many different  types of possible releases,
including tailings piles.  The computer program
TSCREEN, A Model for Screening Toxic Air Pollutant
Concentrations, should be used in conjunction with the
"Workbook of Screening Techniques for Assessing
Impacts of Toxic Air Pollutants (Revised)"  (EPA,
1992a). With the use of these tools one can determine
the type of release and  the steps to  be followed to
simulate the release. TSCREEN can be downloaded
at http://www.epa. gov/scramOO 1.
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•      impoundments, and on-site wastewater management systems (including on-site sewers)
•     Drum residues

Where actual monitoring or measurement data are not available, data sources and calculation
methods that could be employed in estimating fugitive emissions include the following:

•     Industrial Hygiene monitoring data
      AP-42 Emissions Factors (listed in Table 5-2)
•     SOCMI emission factors (listed in Table 4-1)
•     Facility-specific emission factors, models
•     Mass balance (for volatile solvents)
•     EPA models such as WATERS for wastewater management systems
•     Data from a leak detection and repair (LDAR) program
•     Engineering calculations
      CHEMDAT8, TANKS, TSCREEN and SHEAR, etc

Additional models are provided on page 4-9 and in Appendix C.
                Table 4-1.  SOCMI AVERAGE EMISSION FACTORS*
Equipment type
Valves
Pump seals'3
Compressor seals
Pressure relief valves
Connectors
Service6
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
All
Emission factors* (Ibs/hr/source)
0.0131
0.00887
0.00051
0.0438
0.0190
0.502
0.229
0.00403
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Open-ended lines
Sampling connections
All
All
0.0037
0.033

*Protocol for Equipment Leak Emission Estimates (EPA, EPA-453/R-95-017)
a These factors are for total organic compound emissionsb The light liquid pump seal factor can be used to estimate the leak rate
from agitator seals
c "Gas" is material in a gaseous state at operating conditions, "Light liquid" is material in a liquid state in which the sum of the
concentration of individual constituents with a vapor pressure over 0.3 kilopascals (kPa) at 20 °C is greater than or equal to 20
weight percent, and "Heavy liquid" is material that is not defined as a gas or light liquid.
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Stack or Point-Source Air Emissions (Part II, Section 5.2 of Form R)
Point-source air emissions can occur from
numerous pieces of process equipment
throughout a facility. Potential sources
include the following:
•      Air pollution control devices such as
       scrubbers, condensers, baghouses,
       etc.
•      Storage tanks, process tanks, and
       waste tanks
•      Process vessels such as reactors and
       distillation columns

Where actual monitoring or measurement
data are not available, data sources and
calculation methods that could be employed
in estimating stack or point source emissions
include the following:
   TANKS
   The TANKS program is designed to estimate emissions
   of organic chemicals from several types of storage
   tanks.  The calculations are performed according to
   EPA's AP-42, Chapter 12. After the user provides
   specific information concerning a storage tank and its
   liquid contents, the system produces a report which
   estimates the chemical emissions for the tank on an
   annual or partial  year basis.   The user can  also
   determine individual component losses by using one of
   the specification options available in the program.

   The TANKS program relies on a chemical database of
   over 100 organic liquids and a meteorological database
   which includes over 250 cities in the United States;
   users may  add new chemicals and cities to these
   databases by providing specific information through
   system utilities. On-line help provides documentation
   and user assistance for each screen of the program. The
   TANKS program and manual can be downloaded from
       Air emission inventories
       Air permit applications
       Process and production data
       Emission factors from EPA and commercial models
       Engineering calculations
Wastewater Discharges (Part II, Section 5.3
and 6.1 of Form R)
Discharges to a stream or water body are
reported in Part II, Section 5.3 of Form R,
while transfers to Publicly Owned Treatment
Works  (POTWs) are reported in Part II,
Section 6.1 of Form R.  Because the release
estimation approach is similar for both types
of wastewater discharges, they are discussed
here together.
    WATERS

    A computer program,  WATERS,  is available for
    estimating the fate of organic compounds in various
    wastewater treatment  units,  including  collection
    systems, aerated basins, and other units. WATERS is
    written to run under DOS without the need to purchase
    other programs.  WATERS contains useful features
    such as the ability to link treatment units to form a
    treatment system, the ability for recycle among units,
    and the ability to  generate  and save site-specific
    compound properties. The WATERS program and
    users manual can be downloaded from the world wide
    web at http://www.epa. gov/ttn/
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A facility that discharges or has the potential
to discharge water containing regulated
wastes must operate under the terms of
Federal, State, and/or local permits, such as
a NPDES permit, or a POTW agreement.
The permit(s) or agreement usually require
measurements of the water volume and
monitoring and analyses of some
generalized wastewater parameters
including concentrations of various
constituents. In some cases, the constituent
analyses required for permit compliance
includes Section 313 chemicals. In these
instances, releases can be calculated by
multiplying the volume of wastewater
released by the concentration of the
chemical released. Releases discharged to a
POTW should be reported as off-site
transfers on Part II, Section 6.1 of Form R.
  CHEMDAT8

  Analytical models have been developed to estimate
  emissions of organic compounds via various pathways
  from wastewater and waste management units. Some
  of these  models  have  been  assembled  into  a
  spreadsheet called CHEMDAT8 for use on a PC. A
  user's guide for CHEMDAT8 is also available.  Area
  emission sources for which models are included in the
  spreadsheet are as follows: nonaerated impoundments,
  which include surface impoundments and open top
  WWT tanks; aerated impoundments, which include
  aerated surface impoundments and aerated  WWT
  tanks;  disposal impoundments, which include non-
  aerated disposal impoundments; land treatment; and
  landfills. These models can be used to estimate the
  magnitude  of  site air  emissions  for  regulatory
  purposes. The CHEMDAT8 program and manual can
  be downloaded from  the  world  wide web at
  http://www.epa.gov/ttn/chief/
  software.html#water8 .
Based on the concentration and wastewater
flow data available, an estimate of discharges to water can be calculated. Facilities should
calculate the daily average discharges of areportable Section 313 chemical in pounds and must
use those estimates to determine the annual discharge in pounds per year. Using the daily
concentration data available for the reportable chemical combined with the wastewater flow data
for each of the sampling dates, calculate an estimate of pounds per day for each sampling date.
After the calculations are made for each monitoring point (e.g., daily, monthly), the pounds
discharged are averaged to determine an average daily discharge amount which would be
multiplied by the number of days discharges were possible (e.g., 365 days a year).
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                                      Example Calculation of Yearly Wastewater
                                      Discharge

                                      A facility has monitoring data on discharges to water of xylene,
                                      a listed Section 313 chemical, and a Form R report is required.
                                      In this example, monitoring data on this chemical are only
                                      available for two days in the year. The daily quantities of pounds
                                      of xylene released for those two dates would then be divided by
                                      the number of sample dates to determine the daily average for the
                                      whole reporting year, which would be used to estimate the annual
                                      discharge of xylene in wastewater:
If no monitoring data exist, NPDES
permit applications or POTW
agreements may provide information
useful to estimating releases.
Otherwise, process knowledge (or in
some cases, mass balance) needs to
be utilized to develop an estimate.

Section 313 reporting rules consider
a waste stream containing a
reportable acid (e.g., nitric acid) with
a pH at 6 or above to be completely
neutralized. Thus, if listed acids have
been neutralized to pH at 6 or above
before discharge to water or POTW,
zero releases should be reported. Any
excursions below a pH of 6
potentially constitute release of a
reportable acid.  For more
information on calculating such
discharges of mineral acids, see
EPA's Estimating Releases of Mineral Acid Discharges Using pH Measurements (EPA 745/F-
97-003, June 1991). Note that sulfuric and hydrochloric acids are only reportable in aerosol
forms.
Date
3/1/96
9/8/96
Conceatratie
a (mg/1)
1.0
0.2
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 report amounts of Section 313 chemicals
 injected into Class I wells (Part II, Section
 5.4.1  of Form R) and amounts injected
 into Class II-V (Part II, Section 5.4.2 of
 Form R).

 Release to Land On-Site (Part II,
 Section 5.5 of Form R)

 In most circumstances involving the
 disposal of many Section 313 chemicals,
 land disposal is regulated by RCRA and
 state regulations.  In part II, Section 5.5,
 TRI is concerned with the total amount of
 the specified reportable Section 313
 chemical released to land, regardless of the
 potential for the chemical to leach from
 the disposed waste.

 On-site disposal includes disposal in an
 on-site RCRA Subtitle C landfill (Part II,
 Section 5.5.1 A of Form R), disposal in
 other on-site landfills (Part II, Section
 5.5. IB of Form R), disposal in a land
 treatment/application farming unit (Part II,
 Section 5.5.2 of Form R), and disposal in a
 surface impoundment (Part II, Section
 5.5.3 of Form R).  Data concerning these
 types of "intentional" on-site disposal are
 usually readily available because facilities
 are required to monitor the quantity of
 waste  and will have a waste profile that
 describes typical concentration ranges for
 waste  constituents. In some cases,
 concentrations of constituents in the waste
have been measured.  If on-site waste
treatment occurs prior to on-site land
disposal, the treatment efficiency and a mass balance can be conducted to determine the quantity
of a chemical that is land disposed.  For example, a facility can determine the amount of the
     Estimating Releases for Accidental Losses

 Leaks, spills, and drips from the loading and transfer of
 chemicals received at the facility should be considered
 and  reported  in your  release  estimates.   Data
 concerning specific  incidents (such as notification
 reports or incident logs) should be  used to estimate
 releases.  Equations found in Section 6 of EPA's
 Estimating Releases and Waste Treatment Efficiencies
 for the Toxic Chemical Release Inventory Form (EPA
 560/4-88-002, December 1987), provides guidance on
 calculating releases  from  chemical spills or  leaks,
 including liquid discharges,  fraction of discharge
 flashed, vaporization, two-phase discharges, and gas
 discharges.

 EXAMPLE: A facility uses more than 10,000 pounds
 of ethylene glycol during the year to prevent freezing
 of coal piles. While unloading on a windless overcast
 day, a malfunction occurs and onsite personnel visually
 estimate that 50 gallons of ethylene glycol are spilled.
 Most of the spill remains on the pad, however, an
 estimated ten percent flows off the pad and onto the
 soil. Absorbent material used to remove the ethylene
 glycol from the concrete pad is transferred offsite for
 disposal. How would these releases be reported on the
 FormR? The density of ethylene glycol is 9.3  pounds
 per gallon, and the vapor pressure is 0.06 mm Hg at 68°
 F.

 Quantity spilled = 50 gal x 9.3 Ibs./gal = 465 Ibs.
 Amount spilled onto pad = 465 x 90% = 418.5 Ibs.
 Amount spilled onto soil = 465 x 10% =46.6 Ibs.

 Air emissions of ethylene glycol are expected to be
 negligible due  to  the low  vapor pressure and
 environmental  conditions,  provided response and
 cleanup are immediate.  Therefore, the total amount
 spilled  onto the concrete  pad (418.5 pounds)  is
 transferred offsite and should be reported in Sections
 6.2, and the total amount spilled onto the soil  (46.6

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chemical present in the untreated waste, determine the efficiency of treatment in removing or
destroying the chemical in the waste, account for other releases (i.e., fugitive emissions, leaks,
spills, accidental releases, losses to air pollution control devices, etc.), and determine that the
remainder is the quantity of the chemical land disposed.

Releases to land on-site/other disposal (Part II, Section 5.5.4 of Form R) include the amount of
chemical released to land on  site not covered by any of the above categories and include spills,
leaks, or "unintentional" disposal,  such as metal dust that is deposited onto soil. Incident logs or
spill reports can provide useful information.

Transfers in Wastes to Other Off-site Locations (Part II, Section 6.2 of Form R)

Similar to on-site disposal, data concerning off-site waste transfers are usually readily available
because facilities are required to monitor the quantity of waste and either measure concentrations
of chemicals or develop a waste profile that describes typical concentration ranges.  Under
Section 313, off-site transfer estimates are based on the final, known disposition of the reportable
Section 313 chemical in the waste sent off-site for further waste management. For example, a
reportable Section 313 metal is contained in a waste solvent sent off-site for energy recovery
purposes. Even though the waste stream as a whole has a sufficient heat value to warrant energy
recovery, metals do not have a significant heat value and, therefore, cannot be combusted for
energy recovery. Unless the  facility had additional information on the fate of the reportable
Section 313 metal in this waste, the facility must assume the metal is being disposed and should
report the quantity sent off-site accordingly in Part II, Sections 6.2 and 8.1 of Form R.

Even wastes that were minimally processed, such as wastes that were repackaged, such as small
containers removed from a lab pack that were not otherwise opened or managed, may need to be
reported if the article exemption (as discussed in Section 2) is not applicable.

On-site Waste Treatment Methods and Efficiency (Part II, Section 7A of Form R)

In Section 7A, the following information must be reported:

•      General waste stream types containing the Section 313 chemical being reported;
•      Waste treatment methods or sequence used on all waste streams containing the Section
       313 chemical;
•      Range of concentration of the  Section 313 chemical in the influent at the first step in a
       waste treatment system;
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•      Efficiency of the waste treatment method or sequence in destroying or removing the
       Section 313 chemical; and
•      Indication of whether the efficiency estimate was based on actual operating data.

Report any waste treatment step through which the reportable Section 313 chemical passes
regardless of treatment efficiency. Report all non-identical parallel steps and all sequential steps.

Waste treatment for the purpose of Section 7A is defined as removal of the Section 313 chemical
from the waste through destruction, biological degradation, chemical conversion, or physical
removal. Note that this definition of waste treatment is broader than the definition used in Part II,
Section 8 of Form R (discussed later). Section 7A treatment efficiency is calculated as follows:
      percent efficiency = (input - output) x 100%
                             input

If your facility has a measurement of the pollutant concentration of input and output at the
treatment unit, these data should be used to calculate the treatment efficiency. If these
measurements are not available, data from literature or the equipment manufacturer can be used
for estimation purposes. Equipment manufacturer data on treatment efficiencies often represent
ideal operating conditions with an ideal waste matrix. Thus, you may want to adjust such data to
account for downtime, process upsets, and other less than optimum conditions during the year
that would result in lower efficiencies.

Estimates of treatment efficiencies by process for EPCRA Section 313 chemicals are available
from the ATTIC database via modem from ATTIC by calling data number (703) 908-2138.

On-site Energy Recovery Processes (Part II, Section 7B of Form R)

In Section 7B, methods used to combust the Section 313 chemical in wastes for energy recovery
are reported. Two conditions need to be met to report the combustion of a Section 313 chemical
as energy recovery: (1) the chemical must have a heat of combustion high enough to support
combustion (e.g., 5,000 BTU per pound or greater), and (2) must be combusted in a unit
equipped with an energy recovery device, such as a waste heat boiler.
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On-site Recycling Processes (Part II, Section 7C of Form R)

In Section 1C, methods used to recycle the Section 313 chemical in wastes are reported.

Source Reduction and Recycling Activities (Part II, Section 8 of Form R)

The following discussion for Sections 8.1 through 8.7 applies to the current reporting year (i.e.,
column B of Section 8 of the Form R).

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
reported as sent off-site for.disposal in Section 6.2 minus the quantity reported in Section 8.8 that
was released or transferred off site for disposal:

       §8.1 = §5 + §6.2 (disposal only) - §8.8 (release or off-site disposal only)

Section 6.2 disposal codes are M10, M71, M72, M73, M79, M90, M94, and M99. In addition,
EPCRA Section 313 listed metals in waste streams sent off-site to POTWs or other off-site
locations for treatment for destruction should be reported in Section 8.1, unless the facility has
knowledge that the metal is being recovered.

Quantity Used for Energy Recovery On-site (Part II, Section 8.2 of Form R)

Estimate a quantity of the Section 313 chemical in wastes combusted for energy recovery on-site.
This estimate should be the quantity of the chemical 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 Section 313 chemical combusted for energy recovery purposes.  If
monitoring data are not available, vendor specifications regarding combustion efficiency may be
used as they relate to the reportable Section 313 chemical.  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 a Section 313 chemical as energy
recovery: the chemical (1) must have a heat of combustion high enough to support combustion
(e.g., 5,000 BTU per pound or greater),  and (2) must be combusted in a unit equipped with an
energy recovery device, such as a waste heat boiler.  Note that "NA" should be reported for
Section 313 chemicals which are Halons (e.g., CFCs) and metals that do not have a heat of
combustion sufficient to sustain combustion.
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                METAL MINING FACILITIES
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 hi Section 6.2 for which energy
recovery codes are reported. Section 6.2 energy recovery codes are M56 and M92. If a quantity
is reported hi Section 8.8, subtract any associated off-site transfers for energy recovery:

       §8.3  = §6.2 (energy recovery) - §8.8 (off-site energy recovery)

Quantity Recycled On-site (Part II, Section 8.4 of Form R)

Estimate a quantity of the Section 313 chemical recycled in wastes on-site. This estimate should
be the quantity of the chemical 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
hi Section 7C and vice versa. To estimate this quantity, you should determine if operating data
exist which indicate a recovery efficiency and use that efficiency value combined with
throughput data to calculate an estimate. If operating data are unavailable, use available vendor
specifications.

Quantity Recycled Off-site (Part II, Section 8.5 of Form R)

The quantity reported hi Section 8.5 must be the same as the quantity reported in Section 6.2 for
which recycling codes are reported.  Section 6.2 recycling codes are M20, M24, M28, and M93.
If a quantity is reported hi Section 8.8, subtract any associated off-site transfers for recycling:

       §8.5  = §6.2 (recycling) - §8.8 (off-site recycling)

Quantity Treated On-site (Part II, Section 8.6 of Form R)

Waste treatment hi Section 8 is limited to the destruction or chemical conversion of the Section
313 chemical. The quantities reported in Section 8.6 will be those treated in a subset of the
processes for which codes were reported hi Section 7A, where treatment includes physical
removal from a waste stream. To estimate this quantity, you should determine if operating data
exist which indicate a treatment (e.g., destruction or chemical conversion of Section 313
chemical) efficiency and use that efficiency value combined with throughput data to calculate an
estimate. If operating data are unavailable, use available vendor specifications. Section 7A must
be completed if a quantity is  entered hi Section 8.6.
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                 METAL MINING FACILITIES
 Quantity Treated Off-site (Part II, Section 8.7 of Form R)


 The quantity reported in Section 8.7 must be the sum of the quantities reported in Section 6.2, for
 which treatment codes are reported, and the quantities reported in Section 6.1, which were sent to
 a POTW. Section 6.2 waste treatment codes are M40, M50, M54, M61, M69, and M95. If a
 quantity is reported in Section 8.8, subtract any associated off-site transfers for treatment:

       §8.7 = §6.1 + §6.2 (treatment) - §8.8 (off-site treatment).

 Because metals cannot be destroyed or chemically converted, metals cannot be reported as
 treated in Section 8. Quantities of metals reported in Section 6.1 and 6.2 as being treated should
 be reported in Section 8.1 (Quantity released), unless the facility has knowledge that the metal is
 being recovered.


 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 quantity reported in Section 8.8 is the quantity of the Section 313 chemical released directly
 into the environment or sent off-site for recycling, waste treatment, energy recovery, or disposal
 during the reporting year due to any of the following events:

       (1) Remedial actions
       (2) Catastrophic events such as earthquakes, fires, or floods
       (3) One-time events  not associated with normal or routine production processes

The quantity reported in Section 8.8 should not be included with quantities reported in Part II
 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. Releases and off-site transfers from remediation of a
Section 313  chemical or an unpreventable accident unrelated to production (such as a hurricane)
that cause a reportable Section 313 chemical to be released are reportable in Section 8.8.
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On-site treatment, energy recovery, or recycling of Section 313 chemicals in wastes generated as
a result of remedial actions, catastrophic events, or one-time events associated with production
processes are not reported in Part II, Section 8.8 nor Sections 8.1 through 8.7 of Form R.
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                METAL MINING FACILITIES
                                     SECTION 5
    CALCULATING RELEASE ESTIMATIONS AT METAL MINING FACILITIES
Mineral extraction is the process of accessing and removing ore from the ground. Depending on
the nature and location of the ore deposit, one of three general methods of extraction may be
employed. In surface mining, near-surface ore deposits are accessed by removing overlying rock
and soil to expose the ore. In deeper deposits, the ore may be accessed by constructing
horizontal tunnels and vertical shafts through which ore may be transported to the surface, in a
method called underground mining. Finally, some deposits may be soluble or easily melted, or
may occur as solution in their native form. These deposits may be extracted by using wells to
pump a solution into the ore deposit and then to remove the solution to the surface in a process
called solution mining.  Releases associated with extraction are reportable, with the exception
of releases from overburden, which are exempt under 40 CFR §372.38(h). Overburden is the
unconsolidated material that overlies  a deposit of useful materials or ores.

Once extracted from the mine, ore must pass through a variety of steps before the valued
minerals are separated from the host rock material.  Collectively called beneficiation, these steps
typically include crushing and grinding to reduce the size of the ore; physical, chemical, or
electrochemical methods to separate metals from host rock; and chemical or electrochemical
steps to concentrate the  metals. Following beneficiation, ores will be further processed by pyro-
metallurgical process, such as smelting or refining.

BENEFICIATION

The remainder of this section focusses on calculating releases from beneficiation activities at
metal mining operation  in SIC Codes  1021, 1031, 1041,1044, 1061, and 1099. The type and
concentration of the  target mineral and the nature of the host rock help to determine the
beneficiation methods required to separate and concentrate the metals.  As discussed earlier,
beneficiation is defined at 40 CFR §372.3, for the purposes of the TRI program, to mean
the preparation of ores to regulate the size (including crushing and grinding) of the
product, to remove unwanted constituents, or to  improve the quality, purity, or grade of a
desired product.

To help mining facilities better understand the EPCRA Section 313 reporting requirements, this
section presents a brief discussion of each of the activities specified in the definition of
beneficiation found in RCRA, along with a discussion of release pathways and release estimation
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               METAL MINING FACILITIES
techniques. Beneficiation is defined for the RCRA program (at 40 CFR §261.4(b)(7)) to include
the following activities:

       Crushing; grinding; -washing; dissolution; crystallization; filtration; sorting;
       sizing; drying; sintering; pelletizing; briquetting; calcining to remove water
       and/or carbon dioxide; roasting, autoclaving, and/or chlorination in preparation
       for leaching (except -where the roasting (and/or autoclaving and/or chlorina-
       tion)/leaching sequence produces a final or intermediate product that does not
       undergo further beneficiation or processing); gravity concentration; magnetic
       separation; electrostatic separation; flotation; ion exchange; solvent extraction;
       electro-winning; precipitation; amalgamation; and heap, dump, vat, tank, and in
       situ leaching.

The RCRA definition of beneficiation is used here as a guide only. Other activities
performed at mining facilities may be considered beneficiation for the purposes of TRI
reporting, and facilities must examine all on-site activities to determine whether the activity
is exempt from reporting. The steps shown in Table 5-1 are broken into discussions of
comminution and concentration/conditioning. Specific examples from mining operations are
presented to aid the reader and assist in clarifying the concepts.  Release estimations will be
unique for each facility depending upon the extraction activities and beneficiation techniques
used.

                            Table 5-1. Beneficiation Processes
Comminution
Crushing
Grinding
Sorting
Sizing




Concentration/Conditioning Processes
Physical
Gravity Concentration
Magnetic Separation
Electrostatic
Separation
Filtration



Chemical
Leaching
Flotation
Solvent Extraction
Electrowinning
Precipitation
Amalgamation
Carbon Adsorption
Ion Exchange
Heat
Roasting
Sintering
Autoclaving
Pelletizing
Briquetting
Calcining


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                METAL MINING FACILITIES
The beneficiation process begins with the comminution of ore (e.g., crushing, grinding, sorting
and sizing of extracted ore in preparation for further activities to recover valued minerals).
Following comminution, the ore may be subjected to one or more processes to concentrate or
condition the material to concentrate the target metal or metal compounds.  The following
sections describe these major processes used. Facilities utilizing unique or innovative processes
involving Section 313 chemicals subject to reporting, which are not described in this manual,
should consider all potential pathways for release of the  chemicals.

COMMINUTION


As part of the preparatory process, ores need to be transported from the excavation site to the
comminution site.  Based on the type of terrain, transportation can be by rubber-tired vehicle,
rail, train, or by conveyer.  Particulate emissions can be generated from specific transportation
activities, particularly during loading and unloading. For metals and metal compounds present in
ores at or above the de minimis levels, these particulate emissions should be reported as fugitive
emissions (Part II, Section 5.1 of Form R) provided an activity threshold is met or exceeded.
While the motor vehicle exemption applies to activities involving maintaining motor vehicles
operated by the facility, this exemption does not extend to releases from ores being transported in
the vehicles within the facility's boundaries.

Crushing

Crushing reduces the rock size from over 1 meter in diameter to approximately 10-25 mm in
diameter using compression and impact methods. Most crushing operations are dry  or use water
sprays to reduce dust emissions. Some mines use water-flush crushers.  In most mines, extracted
ores are transported to separate crushing operations, while some mines conduct the crushing
operations directly in the mines, whether underground or in an open pit.

Sorting and Sizing

The size of the crushed ore is regulated by size separators.  Grizzlies are typically used only for
very coarse material, while vibrating and shaker screens are more commonly used overall. To
facilitate further processing, the crushed ore is mixed with water to form a slurry.  Sorting and
sizing can result in the release of particulate matter. For metals and metal compounds present in
ores at or above the de minimis levels, these particulate emissions should be reported as fugitive
emissions (Part II, Section 5.1 of Form R) provided an activity threshold is met or exceeded.
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                   METAL MINING FACILITIES
Grinding

Grinding is the further size reduction of
crushed materials to allow the required
liberation of the ore metal. While the
specific method of liberation is
determined by the mineralogy of the ore
deposit and the prevailing economic
conditions, grinding is done  through
abrasion and impact in tumbling mills
using steel rods or balls, ceramic pebbles,
or large pieces of the ore itself.  The
tumbling mills  are lined with abrasion-
resistant materials to minimize wear of
the mill shell.  Liners and other media
(e.g., steel rods or balls, ceramic pebbles)
are replaced periodically and are mostly
composed of cast or rolled steel and
rubber. Grinding is a continuous
process, which is either wet or dry.  Wet
grinding is most common and is usually
the choice if subsequent processing is
wet.

In most cases, no chemicals that would
trigger TRI reporting are added to this
process.  Since crushing, grinding, and
milling generally does not result hi
concentration of any of the Section 313
metal constituents, these processes
should have no impact on the threshold
determination.  However, these
operations can result in air emissions
(dusts hi particular) that may be
reportable if the initial concentrations of
the Section 313 metal constituents meet      ^^~
or exceed the specified de minimis levels,
provided an activity threshold is met or exceeded.
Air  Emissions  from Preparation, Storage,  and
Transport

Crushing, grinding, and milling operations will result in
the release of fiime or dust. In general, a dry process will
create a dust (includes all particle sizes) and a wet
process creates a fume. Wet processes (i.e., those that
use wet ores or add water) are less likely to generate
appreciable dust emissions. Other mining operations,
such as drying of concentrates, storage, and transfer and
loading of mined materials or final product also will
result in generation of fume or dust.

Water sprays, with or without additives, are common for
transport, transfer points, and crushing. Other emissions
from mills may be are controlled through wet scrubbers
or baghouses. Scrubbers and baghouses will appreciably
reduce the fume and dust emissions to a constant outlet
concentration.  Many mines will have measured data
and/or  estimates  concerning  particulate  emissions
through the air permitting process.  Table 5-2 presents
particulate emission factors for metal  beneficiation
activities. (Although much less commonly used, dry
grinding processes that involve air conveying and air
classification usually use  dry  cyclones for efficient
product recovery. The emissions factors presented in
Table 5-2 are for  emissions  after product recovery
cyclones.) Mining operations can use either measured
data or the emission factors in Table 5-2 to estimate
releases of metals and metal compounds through fume
and dust. This can be accomplished by combining either
actual emissions data or emission factors shown in Table
5-2 with knowledge of the concentration of the metal in
the ore to estimate the quantity of parent metal released.

Using this information and the calculations presented
below, facilities can calculate reasonable estimates of
then- fugitive and stack ah- emissions (Part II, Sections
5.1 and 5.2) as well as estimate the efficiency of any air
control equipment to treat Section 313 chemicals (Part
II, Section 7A of Form R).
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                    Table 5-2. Emission Factors for Metal Mining Operations
Source
Low-moisture orec
Primary crushing (SCC 3-03-024-01)d
Secondary crushing (SCC 303-024-02)d
Tertiary crushing (SCC 3-03-024-03)"
Wet grinding
Dry grinding with air conveying and/or air classification (SCC 3-03-024-09)6
Dry grinding without air conveying and/or air classification (SCC 3-03-024-10)°
Drying—all minerals except titanium/zirconium sands (SCC 3-03-024-1 l)f
Drying-titanium/zirconium with cyclones (SCC 3-03-024-1 l)f
Material handling and transfer-all minerals except bauxite (SCC 3-03-024-04)8
Material handling and transfer-bauxite/alumina (SCC 3-03-024-04)s'h
High-moisture ore0
Primary crushing (SCC 3-03-024-05)d
Secondary crushing (SCC 3-03-024-06)d
Tertiary crushing (SCC 3-03-024-07)d
Wet grinding
Dry grinding with air conveying and/or air classification (SCC 3-03-024-09)°
Dry grinding without air conveying and/or air classification (SCC 3-03-024-10)"
Drying—all minerals except titanium/zirconium sands (SCC 3-03-024-1 l)f
Drying— titanium/zirconium with cyclones (SCC 3-03-024-1 l)f
Material handling and transfer-all minerals except bauxite (SCC 3-03-024-08)g
Material handling and transfer-bauxite/alumina (SCC 3-03-024-08)g-h
Filterable6-'
PM"

0.5
1.2
2.7
Neg
28.8
2.4
19.7
0.5
0.12
1.1

0.02
0.05
0.06
Neg
28.8
2.4
19.7
0.5
0.01
ND
RATING

C
D
E

C
D
C
C
C
C

C
D
E

C
D
C
C
C

PM-10

0.05
ND
0.16
Neg
26
0.31
12
ND
0.06
ND

0.01
0.02
0.02
Neg
26
0.31
12
ND
0
ND
RATIN
G

C

E

C
D
C
C
C


C
D
E

C
D
C

C

Source: AP-42. References:  Metallic Mineral Processing Plants - Background Information for Proposed Standards (Draft),
EPA Contract No. 68-02-3063, TRW, Research Triangle Park, NC, 1981; Telephone communication between E.G. Monnig,
TRW, Environmental Division, and R. Beale, Associated Minerals, Inc., May 17, 1982; Written communication from W.R.
Chalker, DuPont, Inc. to S.T. Cuffe, U.S. Environmental Protection Agency, Research Triangle Park, NC, December 21, 1981;
Written communication from P.M. Fournet, Kaiser Aluminum and Chemical Corporation, to S.T. Cuffe, U.S. Environmental
Protection Agency, Research Triangle Park, NC, March 5,1982. Factors represent uncontrolled emissions unless otherwise
noted; controlled emission factors are discussed in Section 11.24.3. All emission factors are in Ib/ton of material processed
unless noted.
"  PM emissions do not equate to quantity of listed chemical.  Such determinations require knowledge of the percent
   concentration of the target chemical in the ore. SCC = Source Classification Code. Neg = negligible.  ND = no data.
b  Filterable PM is that PM collected on or prior to the filter of an EPA Method 5 (or equivalent) sampling train.
c  Defined in Section 11.24.2.
d  Based on weight of material entering primary crusher.
e  Based on weight of material entering grinder; emission factors are the same for both low-moisture and high-moisture ore
   because material is usually dried before entering grinder.
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                   METAL MINING FACILITIES
f Based on weight of material exiting dryer; emission factors are the same for both high-moisture and low-moisture ores; SOX
  emissions are fuel dependent (see Chapter 1); NOX emissions depend on burner design and combustion temperature (see
  Chapter 1).
* Based on weight of material transferred; applies to each loading or unloading operation and conveyor belt transfer point.
h Bauxite with moisture content as high as 15 to 18% can exhibit the emission characteristics of low- moisture ore; use
  low-moisture ore emission factor for bauxite unless material exhibits obvious sticky, nondusting characteristics.
**Emission Factor Quality Ratings for Table 5-2 are as follows:
A Excellent. Factor is developed from A- and B-rated source test data taken from many randomly chosen facilities in the
industry population. The source category population is sufficiently specific to minimize variability.
B Above average. Factor is developed from A- or B-rated test data from a "reasonable number" of facilities. Although no
specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with an A rating, the
source category population is sufficiently specific to minimize variability.
C Average. Factor is developed from A-, B-, and/or C-rated test data from a reasonable number of facilities. Although no
specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with the A rating, the
source category population is sufficiently specific to minimize variability.
D Below average. Factor is developed from A-, B- and/or C-rated test data from a small number of facilities, and there may be
reason to suspect that these facilities do not represent a random sample of the industry. There also may be evidence of variability
within the source population.
E Poor. Factor is developed from C- and D-rated test data, and there may be reason to suspect that the facilities tested do not
represent a random sample of the industry. There also may be evidence of variability within the source category population.

Washing


Washing typically can  occur as part of a specific process, such as vat leaching or recovery of
copper through cementation. Washing and wash water residuals  are discussed as part  of the
processes where it may be used.  Other washing activities can include washing of muds from ore
prior to crushing and grinding. If Section 313 metals or metal compounds are present above the
de minimis threshold hi the ore, washing may result in the release of waters containing the metal
which should be reported as releases to water  (Part II, Section 5.3 of Form R).

CONCENTRATION/CONDITIONING

Following comminution, the reduced size ore is  further processed to concentrate or condition
the target metals in the ore.  Three primary techniques are used:  (1) physical; (2) chemical;
and/or (3) heat. Processes can be used alone or together hi series.  Each of these is  described
below.
Physical
Gravity Concentration
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The most common method of gravity concentration uses a slurry of ore and water that passes
over a series of riffles to catch the heavier gold and silver particles, but gold pans, sluices,
shaking tables, or jigs also can be used. For example, hi instances where gold or silver occurs
as larger particles in the ore, its high density relative to other minerals makes gravity a
practical means of concentration.  No Section 313 chemicals are likely to be involved hi this
operation as it is strictly a physical beneficiation method. However, if the de minimis
concentration for silver compounds is met or exceeded, any silver contained in discharged
tailings from the gravity process would have to be reported, provided an activity threshold is
met or exceeded.

Magnetic Separation

Magnetic separation employs the magnetic susceptibility of metals to affect separation.  Most
typically, magnetic separation is used to remove highly magnetic minerals, such as iron, but it
may also be used for removal of chromium and other metals or minerals.  In magnetic
separation, the ground ores pass over or under a magnetic field, causing the non-magnetic
materials to be removed first, followed at a second point by the magnetic materials.
Operations may be conducted on dry ore or wet slurries.  Magnetic separation is a physical
separation technique. No Section 313 chemicals are likely to be added to this operation.
However, if the de minimis concentration for a metal or metal compound is met or exceeded,
any metal or metal compound contained hi discharged tailings from the magnetic separation
process would have to be reported, provided an activity threshold is met or exceeded.

Electrostatic Separation
Electrostatic separation utilizes the differences in electrical conductivity, triboelectic effect, or
polarity between various minerals to affect separation of target metals from other materials. This
process is used in only limited situations. In this process, finely ground ore typically is passed
through an ion bombardment field hi a rotating grounded drum. Low conductivity materials
stick to the drum and high conductivity materials are thrown from the drum. No Section 3l3
chemicals are likely to be added to this operation as it is strictly a physical beneficiation method.
However, if the de minimis concentration for a metal or metal compound is met or exceeded, any
metal or metal compound contained in discharged tailings from the process would have to be
reported, provided an activity threshold is met or exceeded.
Filtration
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Water-borne ore fines will be allowed to settle, promoting separation of water and sludge. This
step, typically referred to as thickening, is then followed by filtration.  Filtration can be used to
dewater both slurries and tailings. Various types of filters can be used, including drum, plate and
frame, or belt filter. Filter aids may be used to improve filtration. Dewatering will result in the
generation of water, which can either be recycled on-site or discharged.  If an activity threshold
is met or exceeded, wastewater discharges would be reported either as discharges to stream or
water bodies (Form R, Part II, Section 5.3) or discharges to public owned treatment works (Form
R, Part II, Section 6.1) Non-product filter cake, filtrate, and spent filter cloths may be generated
and require further management. These releases may be reportable if, for example, they are
managed hi a landfill (Form R, Part II, Section 5.5.1).

Flotation

Flotation is the process where particles of one or more minerals are preferentially wetted by
various agents causing the hydrophobic minerals to adhere to the surfaces of air bubbles. As the
air bubbles rise to the surface, the desired minerals are transported to the surface and are
removed by skimming. Figure 5-1 provides an overview of the flotation process. This step
could also generate particulate and other chemical air emissions. Froth flotation, is the principal
separation technique for copper, lead, molybdenum, zinc, phosphate, and other metals. Flotation
typically will be conducted using ah-, water, the prepared ore, flotation agents specially selected
to recover the desired metal, and regulating agents (e.g., pH regulators, activators, depressants,
dispersants, or flocculants).

The product of flotation is a metal concentrate that is filtered to remove excess water and
flotation agents prior to transfer or sale to a smelting/refining operation. Beneficiation of
lead/zinc ores is primarily done through the use of flotation of sulfide ores. The flotation process
is comparable to flotation processes found at other types of metal mines, including copper.

Most flotation or regulating agents (e.g., pine oil, lime) do  not contain Section 313 chemicals
above de minimis concentrations, however some flotation agents could. Examples from the
copper industry are shown in Table 5-3 and examples from the lead/zinc industry are shown in
Table 5-4.  These lists are not exhaustive and a facility needs to review its own processes to
identify all reagents used.  MSDSs provided by the supplier should identify Section 313
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                      Feed
chemicals present in
the flotation agents
and the concentration
of the chemical. If a activity
threshold is exceeded
for any Section 313
chemical in a
flotation agent (e.g.,
10,000 pounds or
more of the Section
313 chemical are
otherwise used), a
Form R is required
for that chemical and
releases must be
estimated. Residual
flotation agents
would generally be
disposed of in the
tailings
impoundment.
                                            Re-grind
                      Reagents
Fugitive
Emissions
                                           Flotation Circuit
                                    vvvv
                                         Final Concentrate
                                                                          Tailings
                     Figure 5-1. Flotation Process
              Table 5-3. Common Copper Beneficiation Flotation Agents
                          Containing Section 313 Chemicals
Flotation Agent
Copper sulfate
Cresylic acid
Nokes reagent
Kerosene
Polyacrylamide
Sodium cyanide
Sodium ferrocyanide
Zinc sulfate
Section 313 Chemical
Copper compounds
Cresols
Arsenic compounds
Cyclohexane, naphthalene, benzene, xylene, and ethyl
benzene (all typically below de minimis)
Acrylamide (monomer)
Cyanide compounds
Cyanide compounds
Zinc compounds
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              Table 5-4.  Common Lead/Zinc Benefication Flotation Agents
                           Containing Section 313 Chemicals
Flotation Agent
Copper Sulfate
Cresylic Acid
Sodium Ferrocyanide
Sodium dichromate
Zinc Sulfate
Section 313 Chemical
Copper Compound
Cresols
Cyanide Compounds
Chromium compounds
Zinc Compounds
After the target minerals are separated, tailings (wastewater in a slurry) may be sent to a
thickener. The thickener process may also use chemicals to accelerate settling and
agglomeration. Some of these chemicals are disposed of either along with the tails or
separately. Water from the thickeners is often recycled to the mill.

The tailings are generally sent to a tailings impoundment. If the surface impoundment  is
intended for storage or holding without discharge, the surface impoundment is the final
disposal method, and quantities of Section 313 chemicals hi the tailings would be reported hi
Part n, Section 5.5.3 of Form R.  Quantities of the Section 313 chemical released to surface
impoundments that are used merely as part of a wastewater treatment process generally are not
reported as disposal in a surface impoundment. However, in this case, any seepage of the
Section 313 chemical from the impoundment that occurred during the reporting year would be
reported as a release to land on-site/other disposal (Part II, Section 5.5.4 of Form R). Also, if the
impoundment accumulates sludges containing the Section 313  chemical, you must include an
estimate for Section 5.5.3 unless the sludges are removed and otherwise disposed (in which case
they should be reported under the appropriate section of the Form R for the year in which they
were disposed, provided an activity threshold has been exceeded). In either case, Section 313
chemicals contained in discharges from surface impoundments to surface water would be
reported as a discharge to a receiving stream or water body (Part II, Section 5.3 of Form R).
Even those facilities subject to "zero discharge" requirements of 40 CFR Part 440, Subpart J
may have authorized discharges due to the stormwater exemption, and these would be
reportable as well.

Facilities must report on the final disposition of chemicals released during the reporting year. If,
for example, a facility released 1,000 pounds of a Section 313 chemical to land in 1998, of which
500 pounds migrated into the air or was discharged to water during 1998, the  facility would
October 6,1997
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TRI FORM R GUIDANCE DOCUMENT	METAL MINING FACILITIES

report 500 pounds released to land and 500 pounds released to air or water for 1998. The facility
does not, however, report amounts that are emitted or migrate from one media to another in
subsequent years. For example, if a facility disposes 1,000 pounds of a Section 313 chemical to
land in 1998, and 500 pounds of this is discharged to water in 1999, the facility reports 1,000
pounds released to land in 1998, and does not report the 500 pounds discharged to water in 1999
on the Form R.

Information on the facility's water balance and composition of its tailings water, solids, and
discharge can be used to calculate estimates of surface impoundment releases and waste
management activities.

Chemical Processes

Leaching

Leaching is a chemical technology that allows for recovery of metals from the ore.  This section
discusses five leaching processing used in the metal mining industry. Heap or tank/vat leaching
is the predominant method of beneficiating gold and silver where dilute solutions of sodium or
potassium cyanide are used as leaching agents to extract these precious metals from ore. In
copper mining,  dilute sulfuric acid is used as the leaching agent hi dump leaching processes.
Also copper is leached in situ by the introduction of lixiviants2 directly into the ore deposit via
injection wells, and metal-laden solution is recovered via production wells. Finally, bioleaching
uses microbes or bacteria to leach metals from low-grade sulfide ores.

Heap Leaching

In heap leaching, the leaching solution is applied directly to crushed or run-of-mine ore on open
heaps as shown in Figure 5-2. Such ore may be crushed, if necessary, but is not ground. A heap
is built on an impervious pad, usually with a synthetic liner, to control and collect the leach
solution. A typical heap leach cycle may last three months. Although the cyanide may be
applied at concentrations below 0.1 percent, solid cyanide salts usually are purchased in bulk,
and mixed with water to meet the desired concentration. In this case, there would be no de
minimis exemption for cyanide compounds.
       2Lixiviants aid in the separation of soluble and insoluble constituents by percolation.

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                METAL MINING FACILITIES
Following the heap leaching, the ore is rinsed with mine water or mill wastewater, with or
without chlorine or other chemicals, to remove most of the remaining cyanide solutions and
gold- and silver-cyanide complex. Following heap rinsing, the spent ore becomes waste.  The
spent ore is either left as is or, in the case of "on-off" heap leach pads, is disposed in dumps
similar to those used for waste rock. The spent ore will contain small quantities of waste water
from rinsing the ore, residual cyanide, and metal compounds including metal-cyanide complexes.
For non-exempt Section 313 chemicals (i.e., at or above de minimis levels) for which an activity
threshold has been exceeded, quantities remaining in the heap would be reported as released to
land on site (Part n, Section 5.5 of Form R) when the heap is closed.  Sometimes heap leaching
is performed in combination with zinc precipitation (discussed later) as shown in Figure 5-3.

Tank and Vat Leaching

The crushed and ground ore slurry can be further processed by tank or vat leaching.  For the
purposes of this document, no difference exists in the processes used in a tank- or vat-based
operation. Tank or vat leaching is typically a batch process, although continuous leaching
processes can be used.  For copper, vat leaching produces a pregnant leach solution (PLS)  of
sufficient copper concentration for electrowinning (30 to 50 kg/m3 of copper). If the iron content
of the solution is high, the PLS may be sent for solvent extraction prior to electrowinning. Gold
mining also uses vat leaching to recover gold.
                             Fugitive
                             Emissions
                                        Fugitive
                                        Emissions
                                     Sludge
                                     for disposal
                                     Sludge
                                     for disposal
                            Figure 5-2. Heap Leaching
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TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
Agitated vat leaching refers to the relatively rapid leaching of fine particles of ore or roaster
calcines with a strong sulfuric acid solution hi agitated tanks. The tanks are stirred or agitated
by mechanical devices or piped steam discharge. Compressed air is used in a similar method
of agitation in a pressurized tank operation. A pressurized operation is used in several
different types of autoclaves.
Some facilities at one time used chlorine to pre-treat the ore. This practice may no longer be hi
use.  If it is practiced, this activity would be considered otherwise use and reporting would be
required if 10,000 pounds or more are used in the reporting year. This process would be
expected to result in fugitive air emissions of chlorine (Part II, Section 5.1 of Form R).


As is shown in Figure 5-4, in the gold mining industry, fine ore is mixed with lime and cyanide
solution before it is sent
to leach tanks. As metals
are removed from ore in
vat leach circuits
Fugitive W
Emissions p
^. / i.i.

'Sodium
Cyanide
^Calcium Oxide or
Sodium Hydroxide
^
Barrc
Solut
^
^
'Chlorine '
	 ^^. Neutralization
X Sludges
C Processed Ore .^
J^
Fugitive
innin>iuiio
_^_ rugitlfe
aoaium c_ "^ Recovered
Cvanide ^ LSachina Water
\ 1 ^.1 Tank I
ap \ • |^ Pregnant ii olution


Make-Up ^ ^ ' 	 ^ la"




->-
FmurB1!^. Vat Leaching . _ A . . _ _,. '
•
•^ 	 Zinc Dust*
1 r

Filtration ^ Fil*°r flMrtanfi

*
Gold Precipitate


ngs

Figure 5-3. Heap Leaching with Zinc Precipitation
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
(recycle loops), a slurry of spent ore tailings is removed. Tailings slurry, typically discharged to
unlined or lined earthen dam impoundments, may contain residual cyanide, metal-cyanide
complexes, and dissolved metals. The residual metals content of the tailings as well as residual
cyanide levels must be reported if threshold levels have previously been met or exceeded.
Reporting amounts placed in surface impoundments is discussed previously in this section, under
the heading "Flotation".  The quantity and composition of the tailings is monitored to ensure the
efficiency of the leaching process. These data can be used to estimate the quantity of reportable
Section 313 chemicals discharged to land on site.  The metal-cyanide solution is sent to recovery,
typically by activated carbon, as described in the following section on recovery techniques.

After the tailings have settled, water can be recovered for reuse or treatment followed by
discharge.  Prior to wastewater discharge, cyanide may require destructive treatment. This
treatment would be reportable as on-site treatment (Part II, Section 8.6 of Form R). This
treatment can use a number of chemicals including, chlorine and ozone,  which are Section 313
chemicals. If chemicals are otherwise used above the 10,000-pound activity threshold, then a
Form R would be required for that chemical. In some cases, operators may employ cyanide
destruction technologies for detoxification of tailings slurry prior to discharge to disposal
impoundments, thus, reported releases may be minimal or zero.  Monitoring data to support
permit compliance should be available to determine if any releases to water (Part II, Section 5.3
of Form R) or discharges to surface impoundment (Part II, Section 5.5.3 of Form R) occurred
and to estimate the quantity of cyanide compounds treated (Part II, Section 8.6 of Form R).

Dump Leaching

In the dump leaching process, the crushed ore is treated by a leaching agent, typically dilute
sulfuric acid.  The sulfuric acid is dripped,  sprinkled, or sprayed onto the dump of ore. This
spraying could result in the manufacture of sulfuric acid in the aerosol form. Note that the de
minimis exemption does not apply to the manufacture of Section 313 chemicals. If greater than
25,000 pounds of sulfuric acid in the aerosol form are manufactured, then  the manufacturing
threshold has been exceed and a Form R report is required. Releases of sulfuric acid in the
aerosol form must be estimated and reported as well.

This leaching process results in the production of pregnant leach solution (PLS), a dilute solution
of copper sulfate, which may also contain other metals. While the goal is to collect all PLS for
copper recovery, some of the PLS may escape the collection system (e.g.,  through seepage).
Provided an activity threshold is met or exceeded, the copper (or other Section 313 chemicals) in
the lost PLS would be reported as released to land on-site: other disposal (Part II, Section 5.5.4
of Form R). The facility water balance and the PLS characterization should provide this
information. Releases to water could also occur during large storm  events. Some of the PLS may
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TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
also be lost to a nearby water body through drainage or storm water. Monitoring required by
NPDES permits may provide useful data to estimate these releases. The copper in this PLS
would be reported as discharged to a receiving stream or water body (Part II, Section 5.3 of Form
R). Once the leaching process is completed, the dump would cease to be a process unit and the
remaining copper (and/or other Section 313 chemicals) in the dump would be reported as being
released to land on site (Part II, Section 5.5 of Form R).


Barren solution (raffinate) is an acidic aqueous solution that has been stripped of copper but still
has some carryover of the organic extraction/diluent used in the solvent extraction operation.
The raffinate generated at hydrometallurgical plants is typically stored in ponds and recycled to
the dump leaching operation.

In Situ Leaching


Less commonly used, in situ leaching involves the removal of target metals directly from deep-
lying deposits of undisturbed ore or from porous or permeable deposits in disturbed ore through
in-ground leaching. Section 313 chemicals added to deposits for the purposes of in-situ leaching
should be reported as a releases to land on-site/other disposal (Part II, Section 5.5.4 of Form R)
provided an activity threshold is met or exceeded. Facilities are responsible only for reporting of
the final disposition of chemicals released during the reporting year. If, for example, 1,000
pounds of a  Section 313 chemicals were used during the year for in-situ leaching in  1998, this
amount need not be reported again in 1999.

Bioleaching


Microbial (or bacterial) leaching is appropriate for low-grade sulfide ores at dump, heap leach,
underground, and possibly in situ leaching operations. The organisms use atmospheric carbon
dioxide (CO2) for cell growth and oxidize ferrous iron and sulfides to obtain energy for growth.
Sulfuric acid is a product of the organism's metabolism. For example, for chalcopyrite (a copper
sulfide), the bacteria first oxidizes the ferrous iron to ferric iron. Ferric iron then chemically
oxidizes the sulfide. This bacteria can also assist in the oxidation of sulfur to sulfuric acid.
Sufficient dissolved .oxygen must be available during these oxidation reactions.  The other main
growth requirements are ammonia, nitrogen, phosphate, and a suitable temperature
(approximately 30°C) and acidity (approximate pH of 2.0).  Some metals, such as mercury,
silver, and (possibly) molybdenum, can retard or stop leaching by inhibiting or killing the
bacteria.  The chemical and biochemical reactions involved in microbial leaching of copper
ore/minerals are complex and facilities using this technology are best equipped to determine the
chemical conversions taking place.
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                METAL MINING FACILITIES
The de minimis exemption does not apply to the manufacture of Section 313 chemicals. If greater
than 25,000 pounds of sulfuric acid in the aerosol form are manufactured, then the manufacturing
threshold has been exceeded and a Form R report is required. Releases of sulfuric acid in the
aerosol form must be estimated.

Solvent Extraction

Solvent extraction typically is used to extract and concentrate valued minerals from the pregnant
leach solutions. In the copper industry, the pregnant leaching solution from dump leaching is
pumped to a solvent extraction plant, where it is mixed with an organic solvent in a mixer.  The
organic solvent consists of a chelating agent such as alkylated 8-hydroxyquinoline (not a Section
313 chemical) hi an organic diluent such as kerosene (containing many petroleum hydrocarbons,
including Section 313 chemicals such as benzene, xylenes, ethylbenzene). In the mixer, the PLS
is contacted with the organic solvent, forming a copper-organic complex. The PLS after it has
been stripped of the copper is referred to as barren leachate solution or raffinate and is
recirculated back to the leaching units. Sludge can accumulate in the solvent
extraction/electrowinning system and is land disposed periodically. Copper (or other Section 313
chemicals) hi the sludge would be reported as being released to land on site (Part II, Section 5.5
of Form R) provided an activity threshold is met or exceeded.

In the second stage, the loaded organic solution is stripped of the copper with concentrated
sulfuric acid solution to produce a solution of copper sulfate for electrowinning. Then the
mixture is allowed to separate in settling tanks, where the barren organic solution can be recycled
to the solvent extraction stage. The copper-enriched, strong electrolyte flows from the stripping
stages to the strong-electrolyte tanks, where it is pumped to the electrolyte filters for removal of
the entrained organics or solids. The clarified, strong electrolyte flows to electrolyte circulation
tanks, where it becomes electrolyte for the electrowinning tankhouse. Because the acid
electrolyte is heated, sulfuric acid in the aerosol form may be manufactured in this process as
well.  The de minimis exemption does not apply to the manufacture of Section 313 chemicals. If
greater than 25,000 pounds of sulfuric acid hi the aerosol form are manufactured, then the
manufacturing threshold has been exceeded and a Form R report is required. Releases of sulfuric
acid hi the aerosol form must be estimated.

The solvent extraction process generates a "sludge," or, as it is known hi the copper industry,
"crud" or "gunk." This sludge consists of a solids and a stabilized emulsion of organic and
aqueous solutions from solvent extraction. It is generated at the organic/aqueous interface in the
settlers and is periodically removed from the system, and centrifuged or otherwise treated to
remove the organics, which are returned to the solvent extraction circuit for reuse.  The
composition of the sludge may be monitored or a typical concentration may be available from a
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TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
waste profile.  This composition information along with the quantity of the sludge disposed on
site can be used to estimate the quantity of the reportable Section 313 chemicals (e.g., metals and
cyanide compounds) present in the sludge. These estimates would be reported as disposal to land
on site (Part II, Section 5.5 of Form R) provided an activity threshold is met or exceeded.

Electrowinning

Electro winning is used to remove metals from electrolyte solutions. Electric current is passed
through a tank and the target metal adheres to the anode or the cathode, enabling recovery.
In the copper industry, electrowinning uses anodes made of lead (a Section 313 chemical) or
stainless  steel (which typically contains chromium and nickel, both Section 313  chemicals, above
de minimis concentrations). Use of these anodes constitutes otherwise use. If more than 0.5
pounds of a Section 313 chemical from the anodes is released, and not recycled, over the course
of the reporting year, the article exemption could not apply to the anodes and the quantity of
Section 313 chemicals in the anodes added to the process during the reporting year would need to
be counted towards the threshold determination.

In the copper industry, the electrochemical reaction at the lead-based anodes produces oxygen
gas and sulfuric acid by electrolysis. Copper often is plated on thin-copper starting sheets. The
cathode copper is then shipped to a mill for fabrication. The spent acid is generally recycled and
pumped back to the leaching operation. A small amount of wastewater may be discharged as a
bleed stream to surface water (or the bleed stream may be reused elsewhere in the facility). If the
bleed stream is discharged, the copper (and possibly other reportable Section 313 chemicals) in
the bleed stream would be reported as released to water (Part II, Section 5.3 of Form R) provided
an activity threshold is met or exceeded.

Electrowinning also is used in the gold/silver industry.  In this case, the process starts with the
placement of concentrated solution in tanks that commonly contain steel wool to act  as a cathode.
A current is passed through the solution causing the gold/silver to exchange with iron.
Gold/silver on the cathode and any sludge in the tank is fluxed with various fluxing agents and
subsequently melted for casting as bullion. If the quantity of a Section 313 chemical used in this
process meets or exceeds the 10,000-pound otherwise use threshold, a Form R report for that
chemical would be required.

Sludge can accumulate in electrowinning tanks. Any sludge generated from this process that
contains  reportable Section 313 chemicals for which an activity threshold is met or exceeded
must be included in the Form R. The sludge is typically shipped off site for recovery of other
metals from the sludge.  Metals in this sludge may be reportable as off-site waste transfers for
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
recycling (Part II, Sections 6.2 and 8.5 of Form R) if thresholds for these metals have been
exceeded.

Spent electrolyte is generated during electrowinning activities. Historically, electrolyte is sent
through a stripping step and is subsequently discharged to a tailings pond.  Any reportable
Section 313 chemicals in the spent electrolyte disposed of in the tailings pond would need to be
reported as a release to land on site (Part II, Section 5.5 of Form R) provided an activity
threshold is met or exceeded.

Over time, electrolyte in the electrowinning cells becomes laden with soluble impurities and
copper. When this occurs, the solution is removed and replaced with pure electrolyte (to
maintain the efficiency of the solution and prevent coprecipitation of the impurities at the
cathode). Purification of the spent electrolyte is done by electrowinning in liberator cells.
Liberator cells are similar to normal electrolytic cells, but they have lead anodes in place of
copper anodes. The electrolyte is cascaded through the liberator cells, and an electric current is
applied.  For example, during copper electrowinning, copper in the solution is deposited on
copper starting sheets. As the copper in the solution is depleted, the quality of the copper deposit
is degraded. Liberator cathodes containing impurities (such as antimony) are returned to the
smelter to be melted and cast into anodes.  Purified electrolyte is recycled to the electrolytic cells.
Any bleed electrolyte usually is neutralized with mill tailings and disposed of in a tailings pond
(U.S. EPA 1994).  Any reportable Section 313 chemicals in the bleed electrolyte disposed of in
the tailings pond would need to be reported as a release to land on site (Part II, Section 5.5 of
Form R) provided an activity threshold is met or exceeded.

Zinc Precipitation

Zinc precipitation is well suited to gold ores containing large amounts of silver. The pregnant
solution is filtered, and dissolved oxygen is removed.  Metallic zinc dust is added to exchange
with the gold of the gold-cyanide complex. In some cases, cyanide and lead nitrate or lead
acetate is added to increase the reaction rate. Gold precipitates and is filtered from the solution
for smelting into dore (unrefined gold). Zinc dust, zinc compounds, lead compounds, and nitrate
compounds are listed Section 313 chemicals and if the use of any of these chemicals exceeds the
10,000 pound otherwise use threshold, then a Form R is required.

Amalgamation
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                 METAL MINING FACILITIES
Amalgamation is the technique of wetting metallic gold with mercury to form an alloy.  While
this process is not used in large-scale operations in the U.S., use of 10,000 pounds or more of
mercury and/or mercury compounds in a calendar year would require Form R reporting.

Activated Carbon Adsorption


Activated carbon adsorption is used to remove the desired metals from pregnant solutions, most
commonly in gold recovery. The metal is adsorbed onto the carbon and, after the carbon is
loaded with metals, the metal is desorbed. In gold beneficiation, the gold is removed with a
solution of cyanide and sodium hydroxide to form a concentrated pregnant solution. Figure 5-5
presents an overview of the activated carbon adsorption process.  Activated carbon can be
regenerated, and this activity can occur either on-site or off-site using a variety of different
means.  If the carbon is sent off-site for regeneration and contains any amount of cyanide (or
other reportable Section 313 chemical), this would be reported as an off-site transfer in Part II,
Section 6 of Form R and the appropriate part of Part II, Section 8 of Form R provided an activity
threshold is met or exceeded. For on-site regeneration, the common method employed is an acid
rinse using a hydrochloric and/or nitric acid solution. Nitric acid is a Section  313 chemical and
the quantity of nitric acid used would be applied to the otherwise use threshold. This process is
not likely to generate hydrochloric acid in the aerosol form, but if it did, the quantity of
hydrochloric acid aerosol would be applied to the "manufacture" and "otherwise use"
thresholds.  The resulting spent acid wash solutions are neutralized with high-pH tailings slurry,
dilute sodium hydroxide solution, or water. If the hydrochloric or nitric acids  are used at or above
the 10,000-pound otherwise use threshold, a Form R report is required  and the quantity
neutralized is reportable as on-site treatment (Part II,  Section 8.6 of Form R).  Following
neutralization, the wash water, which may contain silver or other Section 313  chemicals, is
disposed of in the tailings impoundment. This disposal of silver or other reportable Section 313
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
                                                           Fugitive
                                                           Emissions
                                      Barren
                                      Solution
         'Sodium Cyanide
                             Fugitive
                             Emissions
                            Spent Solution
                                  Loaded Carbon
                                       Spent
                                       Carbon
              (Gold solution to electrowinnlng
              or zinc precipitation plant.)
                  'Hydrochloric
                  or Nitric Acid
               •Constitutes Use of a Chemical
Figure 5-5. Activated Carbon Adsorption

chemical would be reported as a release to land on-site/surface impoundment (Part II, Section
5.5.3) provided an activity threshold is met or exceeded.

If the mine is using nitric acid to regenerate their carbon beds, a spent acid wash solution
containing nitric acid will be generated. Quantities of acid neutralized to a pH of 6 or above are
reported as zero, however, the facility could have pH exceedences, which must be reported if the
otherwise use threshold is exceeded.

After the carbon is regenerated, it is returned to the recovery system. The use and regeneration
process gradually decreases the performance of the carbon. Approximately 10 percent of the
carbon is lost during each process necessitating the addition of fresh carbon. The spent carbon
may contain cyanide, precious metals, or other Section 313 chemicals.  Generally, spent carbon
is sold as a product to facilities that then recover the precious metals. When sold as a product,
spent carbon shipped off site is not reportable as a release. If the spent carbon is transferred
offsite for disposal, however, the quantities of any Section 313 chemicals would be reported in
Part II, Section 6.2, of the Form R provided an activity threshold is met or exceeded.
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TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
Ion Exchange


Metals and metal compounds can be recovered from water-ore slurries using either anionie or
cationic resins in a packed column to effect recovery. Loaded resins are separated from the
remaining water-residue slurry, and the target metals are recovered from the resins. Wastewater
discharges would be reported either as discharges to stream or water bodies (Form R, Part II,
Section 5.3) or discharges to public owned treatment works (Form R, Part II, Section 6.1)
provided an activity threshold is met or exceeded. Non-recoverable resins may be generated and
require further management. These releases may be reportable if, for example, they are managed
in a landfill (For R, Part II, Section 5.5.1) provided an activity threshold is met or exceeded.
Heat Processes

Calcining


Calcining is a heat process used to remove excess water and carbon dioxide from ore slurries.  It
can also be used to oxidize aluminum hydroxide (A1(OH)3) precipitate to alumina or to dry
sulfide ore slurries prior to roasting.  (Kirk Othmer, 4th Ed., Vol. 16, 1995.) Ore is calcined in a
rotary kiln. Potential releases from calcining include calcines offgases, which contain airborne
particulate emissions (Form R, Part II, Section 5.2); and calcines residues, which are usually
collected and recycled back into the calcinator (Form R, Part II, Section 7C).

Roasting

Roasting can be used as a preparative step to reduce metal sulfides to metal oxides or sulfates,
thus improving the opportunity for recovery of the target metal.  Roasting involves heating
sulfide ores in air to convert them to  oxide ores. In effect, roasting oxidizes the sulfur in the ore
generating sulfur dioxide that can be captured and converted into sulfuric acid. Roasting
temperatures are dependent on the mineralogy of the ore, but range as high as several hundred
degrees Celsius. Sulfur dioxide (SO2) and sulfur trioxide (SO3) can be formed from this reaction.
Complete roasting may remove all sulfides, while incomplete roasting will result in the
conversion of excess sulfur.  Finally, water-soluble sulfates can be produced through a sulfated
roast. Sulfuric acid can be recovered from the produced sulfur dioxide and sulfur trioxide. This
recovery could result in the manufacture of sulfuric acid in the aerosol form. If the facility uses
this recovered sulfuric acid on-site, it must apply the amount used to the otherwise use threshold.
As discussed earlier, the de minimis exemption does not apply to the manufacture of Section 313
chemicals. If greater than 25,000  pounds of sulfuric acid in the aerosol form are manufactured,
October 6,1997
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
then the manufacturing threshold has been exceeded and a Form R report is required. Releases
of sulfuric acid in the aerosol form must be estimated.

Sintering

Concentrates of certain metals (e.g., lead, zinc) may also be sintered after metal recovery
operations and before smelting and refining. Sintering involves the partial fusion of ore concen-
trates into an agglomerated material suitable for processing operations.  The sinter material is
typically a crushed and graded structure of porous cellular solids.

Autoclaving

Autoclaving (pressure oxidation) is a relatively new technique that operates at lower
temperatures than roasting. Autoclaving uses pressurized steam to start the reaction and oxygen
to oxidize sulfur-bearing minerals. Heat released from the oxidation of sulfur sustains the
reaction.

Pelletizing and Enqueuing

Similar to sintering, pelletizing is the agglomeration of ores after comminution through balling in
a disk, drum, or cone and heating to a temperature of approximately 1300°C and briquetting is
agglomeration through formation in to briquettes.  During the heating, excess water is vaporized.
Pelletizing is found almost exclusively in the recovery of iron for blast furnaces and steelmaking
furnaces. Facilities that conduct iron mining (SIC Code 1011) are not subject to the reporting
requirements of EPCRA Section 313.
 October 6,1997
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            METAL MINING FACILITIES
                             APPENDIX A
          ALPHABETICAL LISTING OF SECTION 313 CHEMICALS
October 6, 1997
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TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
CAS No. <


4080-31-3
354-11-0
630-20-6
71-55-6
354-14-3
79-34-5
79-00-5
13474-88-9
812-04-4
111512-56-2
1717-00-6
57-14-7
5124-30-1
96-18-4
120-82-1
95-63-6
106-88-7
96-12-8
106-93-4
422-44-6
354-23-4
431-86-7
1649-08-7
95-50-1
107-06-2
540-59-0
78-87-5
122-66-7
95-54-5
615-28-1
38661-72-2
106-99-0
507-55-1
136013-79-1
541-73-1
542-75-6
123-61-5
108-45-2
10347-54-3
2556-36-7
764-41-0
106-46-7
123-91-1
104-49-4
624-18-0
3173-72-6
82-28-0
35691-65-7
354-25-6
75-68-3
DHEMICALNAME


-{3-Chloroallyl)-3,5,7'-triaza- 1-azoniaadamantane chloride
1,1,1 ,2-Tetrachloro-2-fluoroethane (HCFC- 1 2 1 a)
,1,1 ,2-tetrachloroethane
,1,1-Trichloroethane (Methyl chloroform)
, ,2,2-Tetrachloro-l-fluoroethane (HCFC-121)
, ,2,2-Tetrachloroethane
, ,2-Trichloroethane
, -Dichloro-l,2,2,3,3-pentafluoropropane (HCFC-225cc)
, -Dichloro-l,2,2-trifluoroethane (HCFC-123b)
, 1 -Dichloro-1 ,2,3,3,3-pentafluoropropane (HCFC-225eb)
, I -Dichloro-1 -fluoroethane (HCFC- 1 41 b)
,1 -Dimethyl hydrazine
, 1-Methylene bis(4-isocyanatocyclohexane)
,2,3-TrichIoropropane
,2,4-Trichlorobenzene
,2,4-Trimethylbenzene
,2-Butylene oxide
,2-Dibromo-3-chloropropane (DBCP)
,2-Dibromoethane (Ethylene dibromide)
,2-DichIoro-l , 1 ,2,3,3-pentafluoropropane (HCFC-225bb)
,2-Dichloro- 1 , 1 ,2-trifluoroethane (HCFC- 1 23a)
,2-Dichloro-l,l,3,3,3-pentafluoropropane(HCFC-225da)
,2-Dichloro-l , 1 -difluoroethane (HCFC- 1 32b)
,2-Dichlorobenzene
,2-Dichloroethane (Ethylene dichloride)
,2-Dichloroethylene
,2-Dichloropropane
,2-Diphenylhydrazine(Hydrazobenzene)
,2-Phenylenediamine
,2-Phenylenediaminedihydrochloride
,3-Bis(methylisocyanate)cyclohexane
,3-Butadiene
,3*Dichloro-l,l,2,2,3-pentafluoropropane(HCFC-225cb)
,3-Dichloro-l,l,2,3,3-pentafluoropropane(HCFC-225ea)
,3-Dichlorobenzene
,3-Dichloropropylene
,3-Phenylene diisocyanate
,3-Phenylenediamine
,4-Bis(methylisocyanate)cyclohexane
,4-Cyclohexane diisocyanate
1 ,4-Dichloro-2-butene
1 ,4-Dichlorobenzene
1 ,4-Dioxane
1 ,4-Phenylene diisocyanate
1 ,4-Phenylenediamine dihydrochloride
1,5-Naphthalene diisocyanate
1 -Amino-2-methylanthraquinone
l-Bromo-l-(bromomethyl)-l,3-propanedicarbonitrile
1 -Chloro-1 , 1 ,2,2-tetrafluoroethane (HCFC- 1 24a)
1 -Chloro- 1 , 1 -difluoroethane (HCFC- 1 42b)
De
Minimis
Cone
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1

1.0
1.0
1.0
1.0
0.1
0.1

.0
.0
0.1
.0
.0
.0
Appx
VIII



X
X

X
X




X

X
X


X
X




X
X

X
X






X
X




X
X
X







RCRA
UTS



X
X

X
X






X
X


X
X




X
X

X
X
X





X






X
X







RCRA
Code



U208
U226

U209
U227




U098





U066
U067




U070
U077

U083
U109






U071
U084




U074
U072
U108







October6,1997
A-2

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
5522-43-0
16938-22-0
128903-21-9
306-83-2
2655-15-4
422-48-0
78-88-6
15646-96-5
95-95-4
88-06-2
94-75-7
53404-37-8
1928-43-4
1929-73-3
94-80-4
2971-38-2
94-11-1
1320-18-9
2702-72-9
94-82-6
615-05-4
39156-41-7
95-80-7
120-83-2
75790-87-3
105-67-9
51-28-5
121-14-2
541-53-7
120-36-5
576-26-1
606-20-2
87-62-7
53-96-3
1 17-79-3
52-51-7
2837-89-0
75-88-7
532-27-4
1 10-80-5
149-30-4
109-86-4
75-86-5
109-06-8
88-75-5
79-46-9
90-43-7
422-56-0
91-94-1
612-83-9
64969-34-2
119-90-4
91-93-0
1-Nitropyrene
2,2,4-Trimethylhexamethylenediisocyanate
2,2-Dichloro- 1 , 1, 1 ,3,3-pentafluoropropane (HCFC-225aa)
2,2-Dichloro- 1,1,1 -trifluoroethane (HCFC- 1 23)
2,3,5-Trimethylphenylmethylcarbamate
2,3-Dichloro-l , 1,1 ,2,3-pentafluoropropane (HCFC-225ba)
2,3-Dichloropropene
2,4,4-Trimethylhexamethylenediisocyanate
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-D [Acetic acid, (2,4-dichloro-phenoxy)-]
2,4-D 2-ethyl-4-methylpentyl ester
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
2,4-D butyl ester
2,4-D chlorocrotyl ester
2,4-D isopropyl ester
2,4-D propylene glycol butyl ether ester
2,4-D sodium salt
2,4-DB
2,4-Diaminoanisole
2,4-Diaminoanisole sulfate
2,4-Diaminotoluene
2,4-Dichlorophenol
2,4'-Diisocyanatodiphenyl sulfide
2,4-Dimethylphenol
2,4-Dinitrophenpl
2,4-Dinitrotoluene
2,4-Dithiobiuret
2,4-DP
2,6-Dimethylphenol
2,6-Dinitrotoluene
2,6-Xylidine
2-Acetylaminofluorene
2-Aminoanthraquinone
2-Bromo-2-nitropropane-l ,3-diol (Bronopol)
2-Chloro- 1,1,1 ,2-tetrafluoroethane (HCFC- 1 24)
2-Chloro-l , 1 , 1-trifluoroethane (HCFC-1 33a)
2-Chloroacetophenone
2-Ethoxyethanol
2-Mercaptobenzothiazole (MBT)
2-Methoxyethanol
2-Methyllactonitrile
2-Methylpyridine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
3,3-Dichloro- 1,1,1 ,2,2-pentafluoropropane (HCFC-225ca)
3,3'-Dichlorobenzidine
3 ,3'-Dichlorobenzidine dihydrochloride
3,3'-Dichlorobenzidine sulfate
3,3'-Dimethoxybenzidine
3,3'-Dimethoxybenzidine-4,4'-diisocyanate
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0 X X
0.1 X X
1.0 X X
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1 X
.0 XX
.0
.0 XX
.0 XX
.0 XX
.0 X
0.1
.0
.0 XX
0.1
0.1 X X
0.1
1.0
0.1
.0
.0
.0 X
.0
.0
.0 X
.0 X
.0 X
Oil X
1.0
i.o
0.1 X
0.1
0.1
0.1 X











U240












U081

U101
P048
U105
P049


U106

U005





U359


P069
U191

U171


U073


U091

October 6,1997
A-3

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
20325-40-0
111984-09-9
91-97-4
119-93-7
612-82-8

41766-75-0

460-35-5
563-47-3
542-76-7
55406-53-6
101-80-4
4128-73-8
80-05-7
101-14-4
101-61-1
101-77-9
139-65-1
534-52-1
60-09-3
92-67-1
60-11-7
75790-84-0
92-93-3
100-02-7
3697-24-3
99-59-2
99-55-8
57-97-6
194-59-2
71751-41-2
30560-19-1

75-07-0
60-35-5
75-05-8
98-86-2
62476-59-9

107-02-8
79-06-1
79-10-7
107-13-1
15972-60-8
116-06-3
309-00-2


107-18-6
107-05-1
107-11-9
3,3'-Dimethoxybenzidine dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine hydrochloride (o-Dianisidine
hydrochloride)
3,3'-Dimethyl-4,4'-diphenylenediisocyanate
3,3'-Dimethylbenzidine(o-ToIidine)
3,3'-Dimethylbenzidine dihydrochloride (o-Tolidine
dihydrochloride)
3,3'-Dimethylbenzidine dihydrofluoride (o-Tolidine
dihydrofluoride)
3-Chloro-l , 1 , 1 -trifluoropropane (HCFC-253fb)
3-Chloro-2-methyl- 1 -propene
3-ChIoropropionitriIe
3-Iodo-2-propynyl butylcarbamate
4,4'-DiaminodiphenyI ether
4,4'-DiisocyanatodiphenyI ether
4,4'-IsopropylidenediphenoI
4,4'-MethyIenebis(2-chloroaniline)(MBOCA)
4,4'-Methylenebis(N.N-dimethyl)benzenamine
4,4'-MethylenedianiIine
4,4'-Thiodianiline
4,6-Dinitro-o-cresoI
4-Aminoazobenzene
4-AminobiphenyI
4-Dimethyiaminoazobenzene
4-Methyldiphenylmethane-3,4-diisocyanate
4-Nitrobiphenyl
4-Nitrophenol
5-MethyIchrysene
5-Nitro-o-anisidine
5-Nitro-o-toluidine
7, 1 2-Dimethy lbenz(a)anthracene
7H-Dibenzo(c,g)carbazole
Abamectin [Avermectin Bl]
Acephate (Acetylphosphoramidothioic acid O,S-dimethyl
ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
Acifluorfen, sodium salt [5-(2-Chloro-4-
(trifluoromethyl)phenoxy)-2-nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin [l,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
hexachloro-l,4,4a,5,8,8a-hexahydro-
(l.alpha.,4.alpha.,4a.beta.,5.alpha.,8.alpha.,8a.beta.)-]
Allyl alcohol
Allyl chloride
Allylamine
O.I
0.1

0.1
O.I

O.I

1.0
0.1
1.0
1.0
O.I
1.0
1.0
O.I
0.1
O.I
O.I
1.0
0.1
O.I
O.I
1.0
O.I
1.0

1.0
1.0


1.0
1.0

0.1
0.1
1.0
1.0
1.0

1.0
0.1
1.0
0.1
1.0
1.0
1.0


1.0
1.0
1.0


X






X
X



X



X

X
X


X


X







X
X


X
X

X

X
X


X
X











X



X



X

X
X


X


X







X



X
X

X






X



1 1095






l'()27




UI58



l'()47


1 1093


U170


11181
1 1094




1 1001

11003
U004


POOS
U007
U008
U009

P070
P004


P005


October 6,1997
A-4

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
319-84-6
134-32-7
7429-90-5
1344-28-1
20859-73-8
834-12-8

33089-61-1
61-82-5
7664-41-7
101-05-3

62-53-3
120-12-7
7440-36-0
7440-38-2
1332-21-4
1912-24-9

7440-39-3
22781-23-3

1861-40-1

17804-35-2
56-55-3
98-87-3
55-21-0
71-43-2
92-87-5
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
189-55-9
98-07-7
98-88-4
94-36-0
100-44-7
7440-41-7
91-59-8
57-57-8
82657-04-3
92-52-4
108-60-1
111-91-1
111-44-4
103-23-1
542-88-1
56-35-9
10294-34-5
7637-07-2
alpha-Hexachlorocyclohexane
alpha-Naphthylamine
Aluminum (fume or dust)
Aluminum oxide (fibrous form)
Aluminum phosphide
Ametryn (N-Ethyl-N'-(l -methylethyI)-6-(methylthio)-
1 ,3,5,-triazine-2,4-diamine)
Amitraz
Amitrole
Ammonia
Anilazine [4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-triazin-2-
amine]
Aniline
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazine (6-Chloro-N-ethy l-N'-( 1 -methylethyl)- 1,3,5-
triazine-2,4-diamine)
Barium
Bendiocarb [2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
Benfluralin(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl) benzenamine)
Benomyl
Benz(a)anthracene
Benzal chloride
Benzamide
Benzene
Benzidine
Benzo(a)phenanthrene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(rst)pentaphene
Benzoic trichloride (Benzotrichloride)
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
beta-Naphthylamine
beta-Propiolactone
Bifenthrin
Biphenyl
Bis(2-chloro- 1 -methylethyl)ether
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) adipate
Bis(chloromethyl) ether
Bis(tributyltin) oxide
Boron trichloride
Boron trifluoride
1.0
0.1
1.0
1.0
1.0
1.0

1.0
0.1
1.0
1.0

1.0
1.0
1.0
0.1
0.1
0.1

1.0
1.0

1.0

1.0

1.0
1.0
0.1
0.1







1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0

0.1
1.0
1.0
1.0

X


X



X



X

X
X



X
X



X

X

X
X






X


X
X
X



X
X
X

X



X











X
X
X
X



X
X



X

X

X











X
X




X
X






U167


P006



U011



U012












U018
U017

U019
U021

U022



U064
U023


P028
P015
U168



U027
U024
U025

P016



October 6, 1997
A-5

-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
314-40-9

53404-19-6

7726-95-6
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
1689-99-2

357-57-3
141-32-2
123-72-8
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
28407-37-6
2602-46-2
16071-86-6
2832-40-8
81-88-9
3761-53-3
3118-97-6
842-07-9
97-56-3
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2

63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4

120-80-9
2439-01-2

133-90-4
57-74-9

115-28-6
90982-32-4

7782-50-5
10049-04-4
79-11-8
Bromacil(5-Bromo-6-rnethyl-3-(l-methyIpropyl)-2,4-
(lH,3H)-pyrimidinedione)
Bromacil, lithium salt (2,4-(lH,3H)-Pyrimidinedione, 5-
bromo-6-methyl-3 (1-methylpropyl), lithium salt)
Bromine
Bromochlorodifluoromethane (Halon 121 1)
Bromoform (Tribromomethane)
Bromomethane (Methyl bromide)
Bromotrifluoromethane (Halon 1301)
Bromoxynil(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxynil octanoate (Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
Brucine
Butyl acrylate
Butyraldehyde
C.I. Acid Green 3
C.I. Acid Red 114
C.I. Basic Green 4
C.I. Basic Red 1
C.I. Direct Black 38
C.I. Direct Blue 21 8
C.I. Direct Blue 6
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 15
C.I. Food Red 5
C.I. Solvent Orange 7
C.I. Sol vent Yellow 14
C.I. Solvent Yellow 3
C.I. Solvent Yellow 34 (Auramine)
C.I. Vat Yellow 4
Cadmium
Calcium cyanamide
Captan [lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-tetrahydro-
2-[(trichIoromethyl)thio]-]
Carbaryl [l-Naphthalenol, methylcarbamate]
Carbofuran
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Carboxin (5,6-Dihydro-2-methyl-N-phenyl- 1 ,4-oxathiin-3-
carboxamide)
Catechol
Chinomethionat (6-Methyl-l ,3-dithiolo[4,5-b]quinoxaiin-2-
one)
Chloramben [Benzoic acid, 3-amino-2,5-dichloro-]
Chlordane [4,7-Methanoindan, 1,2,3,4,5,6,7,8,8-octachloro-
2,3,3a,4,7,7a-hexahydro-]
Chlorendic acid
Chlorimuron ethyl (Ethyl-2-[[[(4-chloro-6-
methoxyprimidin-2-yl)-carbonyI]-amino]sulfonyl]benzoate)
Chlorine
Chlorine dioxide
Chloroacetic acid
1.0

1.0

1.0
1.0
.0 XX
.0 XX
.0
.0
.0

1.0 X
.0
.0
.0
0.1
.0
.0
0.1
0.1
0.1
0.1
.0
.0
0.1
.0
.0
.0
0.1 X
1.0
0.1 X X
1.0
1.0

1.0 X X
1.0 X X
1.0 X X
0.1 X X
1.0
1.0

1.0
1.0

1.0
0.1 X X

0.1
1.0

1.0
1.0
1.0






U225
U029




P018
















U014







P022
U211







U036







October 6,1997
A-6

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
108-90-7
510-15-6

75-45-6
75-00-3
67-66-3
74-87-3
107-30-2
76-06-2
126-99-8
63938-10-3
1897-45-6

75-72-9
5598-13-0

64902-72-3

7440-47-3
7440-48-4
7440-50-8
8001-58-9
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6

21725-46-2
1 134-23-2
1 10-82-7
108-93-0
68359-37-5


68085-85-8


28057-48-9

533.74-4

53404-60-7

1163-19-5
13684-56-5
117-81-7
2303-16-4

25376-45-8
333-41-5
334-88-3
226-36-8
224-42-0
Chlorobenzene
Chlorobenzilate [Benzeneacetic acid,4-chloro-.alpha.-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
Chlorodifluoromethane (HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
Chloropicrin
Chloroprene
Chlorotetrafluoroethane
Chlorothalonil [1,3-Benzenedicarbonitrile, 2,4,5,6-
tetrachloro-]
Chlorotrifluoromethane (CFC-13)
Chlorpyrtfos methyl (O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate)
Chlorsulfuron(2-Chloro-N-[[(4-methoxy-6-methyl-l,3,5-
triazin-2-yl)amino]carbonyl]benzenesulfonamide)
Chromium
Cobalt
Copper .
Creosote
Cresol (mixed isomers)
Crotonaldehyde
Cumene
Cumene hydroperoxide
Cupferron [Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin(3-(2,2-DichIoroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, cyano(4-fiuoro-3-
phenoxyphenyl)methyl ester)
Cyhalothrin(3-(2-Chloro-3,3,3-trifluoro-l-propenyl)-2,2-
Dimethylcyclopropanecarboxylic acid cyano(3-
phenoxyphenyl) methyl ester)
d-trans-Allethrin [d-trans-Chrysanthemic acid of d-
allethrone]
Dazomet(Tetrahydro-3,5-dimethyl-2H-l,3,5-thiadiazine-2-
thione)
Dazomet, sodium salt (Tetrahydro-3,5-dimethyl-2H-l,3,5-
thiadiazine-2-thione, ion(l-), sodium)
Decabromodiphenyl oxide
Desmedipham
Di(2-ethylhexyl) phthalate (DEHP)
Diallate [Carbamothioic acid, bis(l-methylethyl)-S-(2,3-
dichloro-2-propenyl)ester]
Diaminotoluene (mixed isomers) .
Diazinon
Diazomethane
Dibenz(a,h)acridine
Dibenz(aj)acridine
1.0 X X
1.0 X X

1.0
1.0 X
0.1 X X
1.0 X X
0.1 X
.0
.0 XX
.0
.0

.0
.0

1.0

0.1 X X
0.1
1.0
0.1
1.0 X
1.0 X
1.0
1.0
0.1

.0
.0 X X
.0
.0
.0


1.0


1.0

1.0 X

1.0

1.0
1.0
0.1 X X
1.0 X

0.1 X
1.0
1.0


U037




U044
U045
U046

U210











U051
U052
U053
U055
U096




U056















U028
U062

U221




October 6,1997
A-7

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
5385-75-1
192-65-4
53-70-3
189-64-0
191-30-0
132-64-9
124-73-2
84-74-2
1918-00-9
99-30-9
90454-18-5
25321-22-6
75-27-4
75-71-8
75-43-4
75-09-2
127564-92-5
97-23-4
76-14-2
34077-87-7
62-73-7

51338-27-3

115-32-2

77-73-6
1464-53-5
111-42-2
38727-55-8
84-66-2
64-67-5
134190-37-7
35367-38-5
101-90-6
94-58-6
55290-64-7

60-51-5
2524-03-0
131-11-3
77-78-1
124-40-3
2300-66-5
79-44-7
88-85-7
25321-14-6
39300-45-3
957-51-7
122-39-4
2164-07-0

136-45-8
138-93-2
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)anthracene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
Dibenzofuran
Dibromotetrafluoroethane (Halon 2402)
Dibutyl phthalate
Dicamba (3,6-Dichloro-2-methyoxybenzoic acid)
Dich!oran(2,6-Dichloro-4-nitroaniline)
Dichloro-l,l,2-trifluoroethane
Dichlorobenzene (mixed isomers)
Dichlorobromomethane
Dichlorodifluoromethane (CFC-12)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene chloride)
Dichloropentafluoropropane
DichIorophene(2,2'-Methylenebis(4-chlorophenol)
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotrifluoroethane
Dichlorvos [Phosphoric acid, 2-dichloroethenyl dimethyl
ester]
Diclofop methyl (2-[4-(2,4-Dichlorophenoxy)
phenoxy]propanoic acid, methyl ester)
Dicofol [Benzenemethanol, 4-chloro-.alpha.-4-
chlorophenyl)-.alpha.-(trichloromethyl)-]
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Diethyl phthalate
Diethyl sulfate
Diethyldiisocyanatobenzene
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin (2,3,-Dihydro-5,6-dimethyl-l,4-dithiin 1,1,4,4-
tetraoxide)
Dimethoate
Dimethyl chlorothiophosphate
Dimethyl phthalate
Dimethyl sulfate
Dimethylamine
Dimethylamine dicamba
Dimethylcarbamyl chloride
Dinitrobutyl phenol (Dinoseb)
Dinitrotoluene (mixed isomers)
Dinocap
Diphenamid
Diphenylamine
Dipotassium endothall (7-OxabicycIo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium salt)
Dipropyl isocinchomeronate
Disodium cyanodithioimidocarbonate
1.0




1.0
1.0
1.0 X X
1.0
1.0
1.0
0.1 X
.0 X
.0 XX
.0
0.1 X X
.0
.0
.0
.0
O.I

1.0

1.0

1.0
0.1 X
1.0
1.0
0.1
0.1

1.0
0.1
0.1 X
1.0

1.0 X
1.0
1.0 X X
0.1 X
1.0
1.0
0.1 X
1.0
.0
.0
.0
.0 X
.0

.0
.0


U063




U069





U075

U080











U085


U088




U090


P044

U102
U103
U092

U097
P020








October 6,1997
A-8

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
330-54-1
2439-10-3
106-89-8
13194-48-4

140-88-5
541-41-3
759-94-4
100-41-4
74-85-1
107-21-1
75-21-8
96-45-7
151-56-4
75-34-3
52-85-7
60168-88-9

13356-08-6

66441-23-4

72490-01-8

39515-41-8

55-38-9

51630-58-1

14484-64-1
69806-50-4

2164-17-2

7782-41-4
51-21-8
69409-94-5

133-07-3
72178-02-0

50-00-0
64-18-6
76-13-1
76-44-8

87-68-3
118-74-1
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
Diuron
Dodine (Dodecylguanidine monoacetate)
Epichlorohydrin
Ethoprop (Phosphorodithioic acid O-ethyl S,S-dipropyl
ester)
Ethyl acrylate
Ethyl chloroformate
Ethyl dipropylthiocarbamate (EPIC)
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethyleneimine (Aziridine)
Ethylidene dichloride
Famphur
Fenarimol (.alpha.-(2-Chlorophenyl)-.alpha.-4-
chlorophenyl)-5-pyrimidinemethanol)
Fenbutatin oxide (Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
Fenoxaprop ethyl (2-(4-((6-Chloro-2-
benzoxazolylen)oxy)phenoxy)propanoic acid, ethyl ester)
Fenoxycarb (2-(4-Phenoxy-phenoxy)-ethyl]carbamic acid
ethyl ester)
Fenpropathrin (2,2,3,3-Tetramethylcyclopropane carboxylic
acid cyano(3-phenoxyphenyl)methyl ester)
Fenthion (O,O-Dimethyl O-[3-methyl-4-(methylthio)
phenyl] ester, phosphorothioic acid)
Fen valerate (4-Chloro-alpha-( 1 -methylethyl)benzeneacetic
acid cyano(3-phenoxyphenyl)methyl ester)
Ferbam(Tris(dimethylcarbamodithioato-S,S')iron)
Fluazifop butyl (2-[4-[[5-(Trifluoromethyl)-2-
pyridinyl]oxy]-phenoxy]propanoic acid, butyl ester)
Fluometuron [Urea, N,N-dimethyI-N'-[3-
(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
Fluvalinate(N-[2-Chloro-4-(trifluoromethyl)phenyl]-DL-
valine(+)-cyano(3-phenoxyphenyl)methyl ester)
Folpet
Fomesafen (5-(2-Chloro-4-(trifluoromethyl)phenoxy)-N
methylsulfonyl)-2-nitrobenzamide)
Formaldehyde
Formic acid
Freon 113 [Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
Heptachlor[l,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-tetrahydro-
4,7-methano- 1 H-indene]
Hexachloro- 1 ,3-butadiene
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
1.0
1.0
0.1
1.0

0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0

1.0

1.0

1.0

1.6

1.0

1.0

1.0
1.0

1.0

1.0
1.0
1.0

1.0
1.0

0.1
1.0
1.0


1.0
0.1
1.0
1.0
1.0
1.0
0.1


X U041


U113

X X
X


X X U115
X U116
X P054
X X U076
X X P097














X




X P056






X U122
X U123
X
X X P059

X X U128
X X U127
X X U130
X X U131

X U132

October 6, 1997
A-9

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
51235-04-2
67485-29-4



302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554-44-0

193-39-5
13463-40-6
78-84-2
465-73-6
25311-71-1

4098-71-9
67-63-0
120-58-1
77501-63-4

7439-92-1
58-89-9

330-55-2
554-13-2
108-39-4
99-65-0
108-38-3
121-75-5
108-31-6
109-77-3
12427-38-2

7439-96-5
93-65-2
7439-97-6
150-50-5
126-98-7
137-42-8
67-56-1
20354-26-1

2032-65-7
94-74-6

3653-48-3

72-43-5

96-33-3
Hexazinone
HydramethyInon(Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-(trifluoromethyI)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-
propenylidenejhydrazone)
Hydrazine
Hydrazine sulfate
Hydrochloric acid
Hydrogen cyanide
Hydrogen fluoride
Hydroquinone
Imazalil(l-[2-(2,4-Dichlorophenyl)-2-(2-
propenyloxy)ethyl]-l H-imidazole)
Indeno[l ,2,3-cd]pyrene
Iron pentacarbonyl
Isobutyraldehyde
Isodrin
Isofenphos(2-[[Ethoxyl[(l-methylethyl)amino]
phosphinothioyljoxy] benzoic acid l-methylethyl ester)
Isophorone diisocyanate
Isopropyl alcohol (mfg-strong acid process)
Isosafrole
Lactofen(5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-nitro-
2-ethoxy- 1 -methy 1-2-oxoethyl ester)
Lead
Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-
,(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,6.beta.)-]
Linuron
Lithium carbonate
m-Cresol
m-Dinitrobenzene
m-Xylene
Malathion
Maleic anhydride
Malononitrile
Maneb [Carbamodithioic acid, 1,2-ethanediyIbis-,
manganese complex]
Manganese
Mecoprop
Mercury
Merphos
Methacrylonitrile
Metham sodium (Sodium methyldithiocarbamate)
Methanol
Methazole(2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione)
Methiocarb
Methoxone ((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt ((4-Chloro-2-methylphenoxy)
acetate sodium salt)
Methoxychlor [Benzene, l,l'-(2,2,2-trichloroethylidene)bis
[4-methoxy-]
Methyl acrylate
1.0
1.0



0.1
0.1
.0
.0
.0
.0
.0


.0
.0
.0
.0

.0
.0
.0
.0

0.1
0.1

.0
.0
.0
.0
.0
.0
.0
.0
.0

1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0

1.0
0.1

0.1

1.0

1.0





X U133


X P063
X U134



U137


X X P060




X X U141


X X
X X U129



X* U052

X* U239

X U147
X U149




X X U151

X X
X
X U154


X X




X X U247


October 6, 1997
A-10

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
79-22-1
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
80-62-6
298-00-0
1634-04-4
74-95-3
101-68-8
101-68-8
9006-42-2
21087-64-5
7786-34-7
90-94-8
2212-67-1

1313-27-5
76-15-3
150-68-5
505-60-2
88671-89-0

121-69-7
68-12-2
71-36-3
110-54-3
872-50-4
924-42-5
759-73-9
684-93-5
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
4549.40-0
59-89-2
16543-55-8
100-75-4
142-59-6
300-76-5
91-20-3
7440-02-0
1929-82-4
7697-37-2
139-13-9
98-95-3
1836-75-5
51-75-2

55-63-0
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate (Isothiocyanatomethane)
Methyl methacrylate
Methyl parathion
Methyl tert-butyl ether
Methylene bromide
Methylenebis(phenylisocyanate)(MBI)
Methylenebis(phenylisocyanate)(MDI)
Metiram
Metribuzin
Mevinphos
Michler's ketone
Molinate (IH-Azepine-l carbothioic acid, hexahydro-S-
ethyl ester)
Molybdenum trioxide
Monochloropentafluoroethane (CFC-1 15)
Monuron
Mustard gas [Ethane, l,l'-thiobis[2-chloro-]
Myclobutanil (.alpha.-Butyl-.alpha.-(4-chlorophenyl)- 1 H-
1,2,4-triazole-l-propanenitrile)
N,N-Dimethylaniline
N,N-Dimethylformamide
n-Butyl alcohol
n-Hexane
N-Methyl-2-pyrrolidone
N-Methylolacrylamide
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosodi-n-butylamine
N-Nitrosodi-n-propylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
Nabam
Naled
Naphthalene
Nickel
Nitrapyrin(2-Chloro-6-(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
Nitrobenzene
Nitrofen [Benzene, 2,4-dichloro->l-(4-nitrophenoxy)-]
Nitrogen mustard [2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
.0
.0
.0
.0
.0
.0
.0
.0
1.0
1.0
1.0


1.0
1.0
1.0
0.1
1.0

1.0
1,0
1.0
0.1
1.0

1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
0.1
0.1

1.0
X
X
X
X

X

X
X

X






X




X








X
X
X
X
X
X

X
X
X
X


X
X



X

X

X

X

X
X


X
X

X






X









X





X
X
X

X

X

X


X
X



X




U156
U159
P068
U138
U161
P064

U162
P071

U068
















U031



U176
U177
U172
Ulll
U174
P082

P084


U179


U165




U169



P081
October 6,1997
A-ll

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
27314-13-2

90-04-0
134-29-2
95-48-7
528-29-0
95-53-4
636-21-5
95-47-6
2234-13-1
19044-88-3

20816-12-0
301-12-2

19666-30-9

42874-03-3
10028-15-6
104-94-9
95-69-2
106-47-8
104-12-1
120-71-8
106-44-5
100-25-4
100-01-6
156-10-5
106-50-3
106-42-3
123-63-7
1910-42-5
56-38-2

1114-71-2
40487-42-1

76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1


85-01-8
108-95-2
26002-80-2


57-41-0
75-44-5
7803-51-2
7664-38-2
Norflurazon(4-Chloro-5-(methylarnino)-2-[3-
(trifluoromethyl)phenyl]-3(2H)-pyridazinone)
o-Anisidine
o-Anisidine hydrochloride
o-Cresol
o-Dinitrobenzene
o-Toluidine
o-Toluidine hydrochloride
o-Xylene
Octachloronaphthalene
Oryzalin (4-(DipropyIamino)-3,5-
dinitrobenzenesulfonamide)
Osmium tetroxide
Oxydemeton methyl (S-(2-(Ethylsulfmyl)ethyl) O,O-
dimethyl ester phosphorothioic acid)
Oxydiazon(3-[2,4-Dichloro-5-(l-methylethoxy)phenyl]-5-
(1,1 -dimethylethyl)-! ,3,4-oxadiazol-2(3H)-one)
Oxyfluorfen
Ozone
p-Anisidine
p-Chloro-o-toluidine
p-Chloroaniline
p-Chlorophenyl isocyanate
p-Cresidine
p-Cresol
p-Dinitrobenzene
p-Nitroaniline
p-Nitrosodiphenylamine
p-Phenylenediamine
p-Xylene
Paraldehyde
Paraquat dichloride
Parathion [Phosphorothioic acid, O,O-diethyl-O-(4-
nitrophenyl) ester]
Pebulate (Butylethylcarbamothioic acid S-propyl ester)
Pendimethalin (N-(l -Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine)
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin(3-(2,2-Dichloroethenyl)-2,2-
dimethylcyclopropane carboxylic acid, (3-
phenoxyphenyl)methyl ester)
Phenanthrene
Phenol
Phenothrin(2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester)
Phenytoin
Phosgene
Phosphine
Phosphoric acid
1.0

0.1
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0

1.0
1.0

1.0

1.0
1.0
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0

1.0
1.0

1.0
0.1
1.0
1.0
1.0
1.0


1.0
1.0
1.0


0.1
1.0
1.0
1.0




X U052

X U328
X U222
X U239



X P087








X X P024


X* U239
X
X X P077


X* U239
X U182

X X P089

X X


X X U184
X X






X
X U188




X P095
X P096

October 6,1997
A-12

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
7723-14-0
85-44-9
1918-02-1
88-89-1
51-03-6
29232-93-7

1336-36-3
9016-87-9
7758-01-2
128-03-0
137-41-7
41198-08-7

7287-19-6

23950-58-5
1918-16-7

1120-71-4
709-98-8
2312-35-8
107-19-7
31218-83-4


60207-90-1

123-38-6
1 14-26-1
115-07-1
75-56-9
75-55-8
1 10-86-1
91-22-5
106-51-4
82-68-8
76578-14-8

10453-86-8


78-48-8
81-07-2
94-59-7
78-92-2
7782-49-2
74051-80-2

7440-22-4
122-34-9
26628-22-8
1982-69-0

Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl (O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethylphosphorothioate)
Polychlorinated biphenyls (PCBs)
Polymeric diphenylmethane diisocyanate
Potassium bromate
Potassium dimethyldithiocarbamate
Potassium N-methyldithiocarbamate
Profenofos(O-(4-Brorno-2-chlorophenyl)-O-ethyl-S-
propylphosphorothioate)
Prometryn (N,N'-Bis( 1 -methylethyl)-6-methylthio- 1,3,5-
triazine-2,4-diamine)
Pronamide
Propachlor (2-Chloro-N-(l -methylethyl)-N-
phenylacetamide)
Propane sultone
Propanil(N-(3,4-Dichlorophenyl)propanamide)
Propargite
Propargyl alcohol
Propetamphos (3-
[(Ethylamino)methoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester)
Propiconazole(l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxolan-2-yl]-methyl- 1 H- 1 ,2,4,-triazole)
Propionaldehyde
Propoxur [Phenol, 2-(l-methyiethoxy)-, methylcarbamate]
Propylene (Propene)
Propylene oxide
Propyleneimine
Pyridine
Quinoline
Quinone
Quintozene(Pentachloronitrobenzene)
Quizalofop-ethyl(2-[4-[(6-ChIoro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid ethyl ester)
Resmethrin ([5-(Phenylmethyl)-3-furanyl]methyl 2,2-
dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylate])
S,S,S-Tributyltrithiophosphate(DEF)
Saccharin (manufacturing)
Safrole
sec-Butyl alcohol
Selenium
Sethoxydim (2-[l-(Ethoxyimino) butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-cyclohexen- 1 -one)
Silver
Simazine
Sodium azide
Sodium dicamba (3,6-Dichloro-2-methoxybenzoic acid,
sodium salt)
1,0
1.0
1.0
1.0
1.0
1.0

0.1
1.0
0.1
1.0
1.0
1.0

1.0

1.0
1.0

0.1
1.0
1.0
1.0
1.0


1.0

1.0
1.0
1.0
0.1
0.1
.0
.0
.0
.0
.0

1.0


1.0
0.1
0.1
1.0
1.0
1.0

1.0
1.0
1.0
1.0


X X U190





X


X
X




X X U192


X U193


X P102






X X


X P067
X X U196

X U197
X X U185






X U202
XX U203

X X


X X

PI 05


October 6, 1997
A-13

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             METAL MINING FACILITIES
128-04-1
62-74-8
7632-00-0
132-27-4
131-52-2
100-42-5
96-09-3
7664-93-9
2699-79-8
35400-43-2

34014-18-1

3383-96-8
5902-51-2

75-65-0
127-18-4
961-11-5

64-75-5
7696-12-0


7440-28-0
148-79-8
62-55-5
28249-77-6

59669-26-0
23564-05-8
23564-06-9

79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
8001-35-2
10061-02-6
110-57-6
43121-43-3

2303-17-5
68-76-8

101200-48-0

1983-10-4
2155-70-6
Sodium dimethyldithiocarbamate
Sodium fluoroacetate
Sodium nitrite
Sodium o-phenylphenoxide
Sodium pentachlorophenate
Styrene
Styrene oxide
Sulfuric acid
Sulfuryl fluoride (Vikane)
Sulprofos (O-Ethyl O-[4-
(methylthio)phenyl]phosphorodithioic acid S-propyl ester)
Tebuthiuron (N-[5-(l , 1 -Dimethylethyl)- 1 ,3,4-thiadiazol-2-
yl)-N,N'-dimethylurea)
Temephos
Terbacil (5-Chloro-3-(l,l-dimethylethyl)-6-methyl- 2,4
( 1 H,3H)-pyrimidinedione)
tert-Butyl alcohol
Tetrachloroethylene(Perchloroethylene)
Tetrachlorvinphos [Phosphoric acid, 2-chloro-l-(2,3,5-
trichlorophenyl) ethenyl dimethyl ester]
Tetracycline hydrochloride
Tetramethrin (2,2-DimethyI-3-(2-methyl-l -
propenyl)cyclopropanecarboxylic acid (1,3,4,5,6,7-
hexahydro-l,3-dioxo-2H-isoindol-2-yl)methyl ester)
Thallium
Thiabendazole (2-(4-Thiazolyl)-l H-benzimidazole)
Thioacetamide
Thiobencarb (Carbamic acid, diethylthio-, S-(p-
chlorobenzyl))
Thiodicarb
Thiophanate-methyl
Thiophanate ethyl ([1,2-Phenylenebis
(iminocarbonothioyl)] biscarbamic acid diethyl ester)
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed isomers)
Toxaphene
trans-1 ,3-Dichloropropene
trans- 1 ,4-Dichloro-2-butene
Triadimefon (l-(4-Chlorophenoxy)-3,3-dimethyl-l-(lH-
l,2,4-triazol-l-yl)-2-butanone)
Triallate
Triaziquone [2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
Tribenuron methyl (2-(4-Methoxy-6-methyl-l,3,5-triazin-2-
yl)-methylamino)carbonyl)amino)sulfonyl)-, methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
1.0 X
1.0 X
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0

1.0

1.0
1.0

1.0
0.1 X X
1.0

1.0
1.0


1.0 X X
1.0
0.1 X
1.0

1.0 X X
1.0 X X
1.0

1.0 X
0.1 X
1.0 X
1.0
1.0
1.0 X X
0.
0.
0. X
0. XX
0. X
1.0
1.0

1.0 X X
1.0

1.0

1.0
1.0

P058
























U218






P116
U219
U244


U220


U223
PI 23











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                  METAL MINING FACILITIES
    52-68-6        Trichlorfon [Phosphonic acid, (2,2,2-trichloro-l-            1.0
                  hydroxyethyl)-,dimethyl ester]
    76-02-8        Trichloroacetyl chloride                               1.0
    79-01-6        Trichloroethylene                                    0.1       X     X       U228
    75-69-4        Trichlorofluoromethane(CFC-li)                       1.0       X     X       U121
    57213-69-1     Triclopyrtriethylammoniumsalt                        1.0
    121-44-8       Triethylamine                                       1.0       X
    1582-09-8      Trifluralin [Benezeneamine, 2,6-dinitro-N,N-dipropyl-4-      1.0
                  (trifluoromethyl)-]
    26644-46-2     Triforine(N,N'-[l,4-Piperazinediylbis(2,2,2-               1.0
                  trichloroethylidene)] bisformamide)
    639-58-7       Triphenyltin chloride                                 1.0
    76-87-9        Triphenyltin hydroxide                                1.0
    126-72-7       Tris(2,3-dibromopropyl) phosphate                      0.1       X     X       U235
    72-57-1        Trypanblue                                        0.1       X              U236
    51-79-6        Urethane (Ethyl carbamate)                            0.1       X              U238
    7440-62-2      Vanadium (fume or dust)                              1.0              X
    50471-44-8     Vinclozolin (3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-     1.0
                  2,4-oxazolidinedione)
    108-05-4       Vinyl acetate                                        0.1
    593-60-2.       Vinyl bromide                                       0.1
    75-01-4        Vinyl chloride                                       0.1       X     X       U043
    75-35-4        Vinylidene chloride                                   1.0       XX       U078
    1330-20-7      Xylene (mixed isomers)                               1.0              X       U239
    7440-66-6      Zinc (fume or dust)                                   1.0              X
    12122-67-7     Zineb [Carbamodithioic acid, 1,2-ethanediylbis-, zinc        1.0
                  complex]
                  * as mixed isomers (sum)
                                       Chemical Categories

      Section 313 requires reporting on the toxic chemical categories listed below, in addition
    to the specific toxic chemicals listed above.


      The metal compounds listed below, unless otherwise specified, are defined as including
    any unique chemical substance that contains the named metal (i.e., antimony, nickel, etc.)
    as part of that chemical's structure.


      Toxic chemical categories are subject to the 1 percent de minimis concentration unless
    the substance involved meets  the definition of an OSHA carcinogen hi which case the 0.1
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              METAL MINING FACILITIES
   percent de minimis concentration applies. The de minimis concentration for each category
   is provided hi parentheses.

   Chemical Categories

   Antimony Compounds (1.0)
          Includes any unique chemical substance that contains antimony as pan of that
          chemical's infrastructure.
   Arsenic Compounds (inorganic compounds: 0.1; organic compounds: 1.0)
          Includes any unique chemical substance that contains arsenic as pan of that
          chemical's infrastructure.
   Barium Compounds (1.0)
          Includes any unique chemical substance that contains barium as pan of that
          chemical's infrastructure.
          This category does not include: Barium sulfate CAS Number 7727-43-7
   Beryllium Compounds (0.1)
          Includes any unique chemical substance that contains beryllium as pan of that
          chemical's infrastructure.
   Cadmium Compounds (0.1)
          Includes any unique chemical substance that contains cadmium as pan of that
          chemical's infrastructure.
   Chlorophenols (0.1)
    Where x = 1 to 5
   Chromium Compounds (chromium VI compounds: 0.1; chromium IQ compounds: 1.0)
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METAL MINING FACILITIES
          Includes any unique chemical substance that contains chromium as part of that
          chemical's infrastructure.
   Cobalt Compounds (0.1)
          Includes any unique chemical substance that contains cobalt as pan of that
          chemical's infrastructure.
   Copper Compounds (1.0)
          Includes any unique chemical substance that contains copper as part of that
          chemical's infrastructure.
          This category does not include copper phthalocyanine compounds that are
          substituted with only hydrogen,  and/or chlorine, and/or bromine.
   Cyanide Compounds (1.0)
          X+CN~ -where X = H+ or any other group where a formal dissociation may occur.
          For example KCN or Ca(CN)2.
   Diisocyanates (1.0)
          This category includes only those chemicals listed below.
          38661-72-2   1,3-Bis(methylisocyanate)cyclohexane
          10347-54-3   l,4-Bis(methylisocyanate)cyclohexane
          2556-36-7    1,4-Cyclohexane diisocyanate
          134190-37-7  DiethyIdiisocyanatobenzene
          4128-73-8    4,4'-Diisocyanatodiphenyl ether
          75790-87-3   2,4'-Diisocyanatodiphenyl sulfide
          91-93-0      3,3'-Dimethoxybenzidhie-4,4'-diisocyanate
          91-97-4      3,3'-Dimethyl-4,4'-diphenylene diisocyanate
          139-25-3     3,3 '-Dimethyldiphenylmethane-4,4'-diisocyanate
          822-06-0     Hexamethy lene-1,6-diisocy anate
          4098-71-9    Isophorone diisocyanate
          75790-84-0   4-Methyldiphenylmethane-3,4-diisocyanate
          5124-30-1    1,1-Methylene bis(4-isocyanatocyclohexane)
          101-68-8     Methylenebis(phenylisocyanate) (MDI)
          3173-72-6    1,5-Naphthalene  diisocyanate
          123-61-5     1,3-Phenylene diisocyanate
          104-49-4     1,4-Phenylene diisocyanate
          9016-87-9    Polymeric diphenylmethane diisocyanate
          16938-22-0   2,2,4-Trimethylhexamethylene diisocyanate

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              METAL MINING FACILITIES
          15646-96-5   2,4,4-Trimethylhexamethylene diisocyanate
   Ethylenebisdithibcarbamic acid, salts and esters (EBDCs) (1.0)
          Includes any unique chemical substance that is or that contains EBDC or an EBDC
          salt or ester as pan of that chemical's infrastructure.
   Certain Glycol Ethers (1.0)
          Where n = 1, 2, or 3
          R = alkyl C7 or less; or
          R = phenyl or alkyl substituted phenyl;
          R1 = H, or alkyl C7 or less; or
          OR' consisting of carboxylic acid ester, sulfate, phosphate, nitrate, or sulfonate.
   Lead Compounds (inorganic compounds: 0.1; organic compounds 1.0)
          Includes any unique chemical substance that contains lead as pan of that
          chemical's infrastructure.
   Manganese Compounds (1.0)
          Includes any unique chemical substance that contains manganese as part of that
          chemical's infrastructure.
   Mercury Compounds (1.0)
          Includes any unique chemical substance that contains mercury as pan of that
          chemical's infrastructure.
   Nickel Compounds (0.1)
          Includes any unique chemical substance that contains nickel as pan of that
          chemical's infrastructure.
   Nicotine and salts (1.0)
          Includes any unique chemical substance that contains nicotine or a nicotine salt as
          pan of that chemical's infrastructure.
   Nitrate compounds (water dissociable; reportable only when in aqueous solution)  (1.0)
   Polybrominated Biphenyls (PBBs) (0.1)
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               METAL MINING FACILITIES
                                 (10-x)
   Where x = 1 to 10

   Polychlorinated alkanes (CIO to C13) (1.0, except for those members of the category that
   have an average chain length of 12 carbons and contain an average chlorine content of 60
   percent by weight which are subject to the 0. 1 percent de minimis)
          where x = 10 to 13;
          y = 3 to 12; and
          the average chlorine content ranges from 40-70% with the limiting molecular
          formulas C10H19C13 and C13H16Cli2.
   Polycyclic aromatic compounds (PACs) (0.1, except for benzo(a)phenanthrene and
   dibenzo(a,e)fluoranthene which are subject to the 1.0 percent de minimis)
          This category includes only those chemicals listed below.
          56-55-3      Benz(a)anthracene
          205-99-2     Benzo(b)fluoranthene
          205-82-3     Benzo(j)fluoranthene
          207-08-9     Benzo(k)fluoranthene
          189-55-9     Benzo(rst)pentaphene
          218-01-9     Benzo(a)phenanthrene
          50-32-8      Benzo(a)pyrene
          226-36-8     Dibenz(a,h)acridine
          224-42-0     Dibenz(a,j)acridine
          53-70-3      Dibenzo(a,h)anthracene
          194-59-2     7H-Dibenzo(c,g)carbazole
          5385-75-1    Dibenzo(a,e)fluoranthene
          192-65-4     Dibenzo(a,e)pyrene
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              METAL MINING FACILITIES
          189-64-0     Dibenzo(a,h)pyrene
          191-30-0     Dibenzo(a,l)pyrene
          57-97-6      7,12-Dimethylbenz(a)anthracene
          193-39-5     Indeno[l,2,3-cd]pyrene
          3697-24-3    5-Methylchrysene
          5522-43-0    1-Nitropyrene
   Selenium Compounds (1.0)
          Includes any unique chemical substance that contains selenium pan of that
          chemical's infrastructure.
   Silver Compounds (1.0)
          Includes any unique chemical substance that contains silver pan of that chemical's
          infrastructure.
   Strychnine and salts (1.0)
          Includes any unique chemical substance that contains strychnine or a strychnine salt
          as pan of that chemical's infrastructure.
   Thallium Compounds (1.0)
          Includes any unique chemical substance that contains thallium as pan of that
          chemical's infrastructure.
   Warfarin and salts (1.0)
          Includes any unique chemical substance that contains warfarin or a warfarin salt as
          part of that chemical's infrastructure.
   Zinc Compounds (1.0)
          Includes any unique chemical substance that contains zinc as pan of that chemical's
          infrastructure.
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                               METAL MINING FACILITIES
                                      APPENDIX B
              LIST OF ACTIVITIES THAT FALL UNDER EACH SIC CODE
                                  IN MAJOR GROUP 10
   Major group 10, metal mining, includes establishments primarily engaged in mining,
   developing mines, or exploring for metallic minerals (ores).  These ores are valued chiefly for
   the metals contained, to be recovered for use as such, or as constituents of alloys, chemicals,
   pigments, or other products.  This major group also includes all ore dressing and
   . beneficiating operations, whether performed at mills in conjunction with mines, or at mills,
   such as custom mills, operated separately from the mines served. These include mills that
   crush, grind, wash, dry, sinter, calcine, or leach ore, or perform gravity separation or flotation
   operations (U.S. OMB, 1987).

   When performed by operators of the properties, exploration under preliminary phases of
   operation should be classified according to the type of ore expected to be found. Exploration
   performed on a contract or fee basis is classified in Industry 1081 (U.S. OMB, 1987).
    1011  Iron ores:
Establishments primarily engaged in mining, beneficiating, or
otherwise preparing iron ores and manganiferous ores valued
chiefly for their iron content. This industry includes production of
sinter and other agglomerates except those associated with blast
furnace operations. Blast furnaces primarily engaged in producing
pig iron from iron ore are classified in Manufacturing Industry
3312. Not a covered facility as defined under 40 CFR 372.22.
   1021   Copper ores:
Establishments primarily engaged in mining, milling, or otherwise
preparing copper ores. This industry also includes establishments
primarily engaged in the recovery of copper concentrates by
precipitation and leaching of copper ore. Establishments primarily
engaged in the recovery of refined copper by leaching copper
concentrates are classified in Manufacturing, Major Group 33.
    1031  Lead and zinc
          ores:
Establishments primarily engaged in mining, milling, or otherwise
preparing lead ores, zinc ores, or lead-zinc ores.
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TRI FORM R GUIDANCE DOCUMENT
                               METAL MINING FACILITIES
    1041  Gold ores:
Establishments primarily engaged in mining gold ores from lode3
deposits or in the recovery of gold from placer deposits by any
method. In addition to ore dressing methods such as crushing,
grinding, gravity concentration, and froth flotation, this industry
includes amalgamation, cyanidation, and the production of bullion
at the mine, mill, or dredge site.
    1044  Silver ores:
Establishments primarily engaged in mining, milling, or otherwise
preparing silver ores. The production of bullion at the mine or mill
site is included.
    1061  Ferroalloy ores,   Establishments primarily engaged in mining, milling, or otherwise
          except vanadium: preparing ferroalloy ores, except vanadium. The mining of
                           manganiferous ores chiefly valued for their iron content is
                           classified in Industry 1011. Establishments primarily engaged in
                           mining vanadium ore are classified in Industry 1094, and those
                           mining titanium ore are classified in Industry 1099.
    1081  Metal mining
          services:
Establishments primarily engaged in performing metal mining
services
for others on a contract or fee basis, such as the removal of
overburden, strip mining for metallic ores, prospect and test
drilling, and mine exploration and development. Establishments
which have complete responsibility for operating mines for others
on a contract or fee basis are classified according to the product
mined rather than as metal mining services. Establishments
primarily performing hauling services are classified in Division E,
Transportation. Not a covered facility as defined under 40 CFR
372.22.
    1094  Uranium-radium- Establishments primarily engaged in mining, milling, or otherwise
           vanadium ores:  preparing uranium-radium-vanadium ores. Not a covered facility
                           as defined under 40 CFR 372.22.

    1099  Miscellaneous    Establishments primarily engaged in mining, milling, or otherwise
       3 A lode is defined as a vein of metal ore.
October 6,1997
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             METAL MINING FACILITIES
         metal ores, not   preparing miscellaneous metal ores, not elsewhere classified.
         elsewhere       Production of metallic mercury by furnacing or retorting at the
                         mine
         classified:       site is also included.
October 6,1997
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TRI FORM R GUIDANCE DOCUMENT
              METAL MINING FACILITIES
                                    APPENDIX C
                                   BIBLIOGRAPHY


   Encyclopedia of Chemical Technology. Kirk Othmer, 4th Ed., Vol 10 and 16, John Wiley &
   Sons, Inc. New York, NY. 1995.


   United States Department of the Interior, Bureau of Mines. Minerals Yearbook, Volume 1,
   1992.


   U.S. Environmental Protection Agency, Office of Solid Waste. Technical Resource
   Document:  Extraction and Beneficiation of'Ores and'Minerals, Volume 4, Copper. EPA
   530-R-94-031.  1994.


   U.S. Environmental Protection Agency. Office of Solid Waste. Technical Resource
   Document: Extraction and Beneficiation of Ores and Minerals. Volume 2.  Gold, EPA 530-
   R-94-013. 1994.


   U.S. Environmental Protection Agency. Office of Solid Waste, Special Waste Branch.
   Technical Report: Design and Evaluation of Tailings Dams. EPA 530-R-94-038. August,
   1994.


   U.S. Environmental Protection Agency. Office of Solid Waste. Technical Background
   Document: Identification and Description of Mineral Processing Sectors and Waste Streams.
   1996.


   U.S. Environmental Protection Agency. Economic Analysis of the Final Rule to Add Certain
   Industry Groups to EPCRA Section 313, Appendix H.


   U.S. OMB. Standard Industrial Classification Code Manual,  1987
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             METAL MINING FACILITIES
                                   APPENDIX D
       SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
                                 INFORMATION

   Ordering information for the following documents can be obtained by calling the EPCRA
   Hotline at 1-800-535-0202.

   Common Synonyms for Section 313 Chemicals. EPA 745-R-95-008. March 1995.


   Compilation of Air Pollutant Emission Factors, 5th Edition, Volume I: Stationary Point
   and Area Sources (AP-42). EPA 450-AP-425ED. 1995.

   Consolidated List of Chemicals Subject to Reporting Under the Act (Title III List of Lists).
   EPA550-B-96-015.


   Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
   Inventory Form.  EPA 560/4-88-002. December 1987.

   Estimating Releases of Mineral Acid Discharges Using pH Measurements. June 1991.

   Interpretations of Waste Management Activities: Recycling, Combustion for Energy
   Recovery, Waste Stabilization and Release. April, 1997.

   Protocol for Equipment Leak Emission Estimates. EPA 453/R-95-017. November 1995.

   Toxic Chemical Release Inventory Questions and Answers, Revised 1990 Version. EPA
   560/4/91-003.

   World Wide Web Resources

   Code of Federal Regulations, 40 CFR
   www.epa.gov/epacfr40

   CHEMDAT8/WATER8
   www. epa. go v/ttn/chief/software. html#water 8
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             METAL MINING FACILITIES
   Clearinghouse for Inventories and Emission Factors (CHIEF)
   www.epa.gov/ttn/chiefi'

   Compilation of Air Pollutant Emission Factors (AP-42)
   www.epa.gov/ttn/chief/ap42etc.html

   EPA homepage
   www.epa.gov

   Federal Registers
   www.epa.gov/EPA-TRI

   MSDSs (Note: A number of organizations maintain databases that contain MSDS
   information. The following is a short list of web sites with MSDS information.)
   www.dehs .umn.edu/msds .html
   www.nwfsc.noaa.gov/msds.html
   www.chem.utah.edu/msds

   SPECIATE
   www.epa.gov/ttn/chiefi'software.htnil#speciate

   TANKS
   www.epa.gov/ttn/chief/tanks .html

   TOXNET
   www.nlm.nih.gov/pubs/factsheets/toxnetfs.html

   TRI homepage
   www.epa.gov/opptintr/tri
October 6,1997
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