&EPA
United States
Environmental Protection
Agency
Office of Pollution October 1997
Prevention and Toxics EPA 745-B-97-014
Washington, DC 20460
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
GUIDANCE FOR PETROLEUM BULK STORAGE FACILITIES
(Version 1.0)
CONTENTS
Section 1. Introduction
Section 2. Section 313 Reporting Requirements ..................................... 2-1
Section 3. Making Threshold Determinations ......................................... 3-1
Section 4. Overall Section 3 13 Release Estimation ...... .................. . ........ 4-1
Sections. Calculating Release Estimations At Petroleum Bulk
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SECTION 313 EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT
GUIDANCE FOR PETROLEUM BULK STORAGE FACILITIES
Version 1.0
September 15,1997
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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
How to determine your SIC Code 2-3
How to Determine Your Number of Employees 2-4
CHEMICAL ACTIVITY THRESHOLDS : 2-5
Manufacture 2-5
Process 2-6
Otherwise use ,.... 2-7
EXEMPTIONS 2-10
SUPPLIER NOTIFICATION REQUIREMENTS 2-14
LISTED SECTION313 CHEMICALS 2-14
WHAT MUST BE REPORTED? 2-17
DOCUMENTING REPORTING EFFORTS 2-18
SECTION 3
MAKING THE THRESHOLD DETERMINATION 3-1
CONDUCTING THE THRESHOLD DETERMINATION 3-4
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 4-4
"NA" versus "0" , 4-5
REPORTING RELEASES INFORM R, PARTH 4-5
Fugitive or Non-Point Emissions 4-6
Stack or Point-Source Air Emissions 4-7
Wastewater Discharges 4-8
Underground Injection On-Site 4-9
Release to Land On-Site 4-10
Transfers in Wastes to Other Off-site Locations 4-10
On-site Waste Treatment Methods and Efficiency 4-11
On-site Energy Recovery Processes 4-12
On-site Recycling Processes 4-13
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Source Reduction and Recycling Activities 4-13
Quantity Released 4-13
Quantity Used for Energy Recovery On-site 4-13
Quantity Used for Energy Recovery Off-site 4-14
Quantity Recycled On-site 4-14
Quantity Recycled Off-site 4-14
Quantity Treated On-site 4-14
Quantity Treated Off-site 4-15
Quantity Released to the Environment as a Result of Remedial Actions,
Catastrophic Events, or One-time Events Not Associated with Production
Processes 4-15
SECTIONS
CALCULATING RELEASE ESTIMATIONS AT PETROLEUM BULK STATIONS
AND TERMINALS 5-1
LOADING/UNLOADING PETROLEUM PRODUCT 5-2
Loading Losses 5-3
Spills/Overfills 5-4
STORAGE OF PETROLEUM PRODUCT 5-4
Tanks 5-5
Equipment 5-8
MIXING OF PETROLEUM PRODUCT 5-11
TANK CLEANING AND EQUIPMENT MAINTENANCE 5-11
APPENDIX A
ALPHABETICAL LISTING OF SECTION 313 CHEMICALS A-l
APPENDIX B
BIBLIOGRAPHY B-l
APPENDIX C
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION B-l
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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 3-1
Table 3-2 Estimated Concentration Values of Section 313 Constituents in Crude Oil and
Petroleum Products 3-7
Table 3-3 Constituents in Petroleum Products That May Be Present Above De Minimis
3-9
Table 3-4 Estimated Quantities Required to Exceed the Processing Threshold for Several
Petroleum Products 3-12
Table 5-1 Marketing Terminal Average Emission Factors 5-9
LIST OF FIGURES
Figure 5-1: Petroleum Bulk Storage Terminal ; 5-2
Figure 5-2: Calculation of Equipment Leak Emissions ; 5-10
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
SECTION 1
INTRODUCTION
This guidance document has been prepared to assist petroleum bulk storage 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 m 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 petroleum bulk storage facilities (Standard Industrial
Classification (SIC) 5171), 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 has 10 or more full-time employees or the equivalent, and
• The facility manufactures (defined to include importing), or 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) buy may be 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 petroleum bulk storage
facilities and other amounts managed. Section 5 presents a detailed discussion of EPCRA Section
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
313 release and other waste management scenarios in the petroleum bulk storage industry and
covers developing estimates of releases and other waste management activities for several types of
operations commonly encountered by the petroleum bulk storage 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 list of Section 313 related materials and
relevant online information sources for petroleum bulk storage facilities.
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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
(40CFR
§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
Notification
(40CFR
§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 E 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 n 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.
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
EPCRA
Section
Reporting Requirements
Section 313
Toxic
Chemical
Release
Inventory
Reporting
(FormR)
(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 in 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 mo'dem
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.
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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
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 determining
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 n, Section 8 of Form R.
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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, where
business is conducted or where services or industrial operations are performed. A facility may
contain more than one establishment. For example, a refinery, bulk terminal, and warehouse
would be one facility if all three units were owned and operated by the same company, and are
located on the same 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.
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 until further notification is made.
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• 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 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 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.
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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:
• 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.
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• 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.
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, in 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.
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.
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• 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 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.
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• 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 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 Section 313
chemical from a waste stream and includes: (1) the reclamation of the Section 313 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
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or control devices or processes); and (2) the reclamation for reuse of an "otherwise used" Section
313 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 chemical is combusted for energy recovery, the facility should consider
the BTU value of the Section 313 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 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
chemicals that are constituents of that waste-derived fuel. An EPCRA Section 313 listed
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 in an on-site energy recovery unit (62 FR
23851).
EPA defines Treatment for destruction to mean the destruction of a Section 313 chemical in
waste such that the substance is no longer the Section 313 chemical subject to reporting under
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 in any device that is an industrial boiler or furnace. (See
40 CFR §372.3.) "Treatment for destruction" includes acid or alkaline neutralization if the
Section 313 chemical is the entity that reacts with the acid or base. "Treatment for destruction"
does not include: (1) neutralization of a waste stream containing Section 313 chemicals if the
Section 313 chemicals themselves do not react with the acid or base (See 40 CFR §372.3), (2)
preparation of a Section 313 chemical for disposal, (3) removal of Section 313 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 FR 23852).
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EPA defines Waste stabilization to mean any physical or chemical process used to either reduce
the mobility of hazardous constituents in 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 Section 313 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.)
Based on EPA's evaluation of facilities in SIC 5171, the Agency believes that petroleum storage
and distribution activities routinely involve or result in the manufacturing, processing, or
otherwise use of EPCRA Section 313 chemicals (62 FR 23834; May 1, 1997). Thresholds must
be calculated separately for manufacture, process, or otherwise use of the same chemical. If any
single activity threshold is met or exceeded, the facility must submit a Form R covering all
nonexempt activities. Petroleum bulk storage facilities often process Section 313 chemicals in
petroleum products as a result of repackaging, mixing, or blending the products. Petroleum bulk
storage 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.
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
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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. 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 in 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 listed 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 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
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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 requkements 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
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 FormR 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.
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
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Section 313 chemicals added during the reporting year must counted in threshold and release
and other waste management calculations.
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 maintaining 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
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.
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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
• 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.
LISTED SECTION 313 CHEMICALS
Appendk 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-
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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
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).
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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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• 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 in 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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• 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 spiffing, 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 E Reports;
• Monitoring records;
• Flowmeter data;
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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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SECTION 3
MAKING THE THRESHOLD DETERMINATION
Petroleum bulk stations and terminals in SIC 5171 include facilities engaged in the wholesale
distribution of liquid petroleum products and liquefied petroleum gases. Products handled by
these facilities include gasoline, diesel, fuel oil, kerosene, crude oil, naphtha, and lubricating oils.
Bulk storage stations and terminals have a bulk storage capacity of 10,000 gallons or more.
Facilities classified in SIC code 5172 are not subject to Section 313 reporting. Facilities in SIC
5172 include establishments primarily engaged in the wholesale distribution of petroleum and
petroleum products without bulk liquid storage facilities (i.e., storage capacity less than 10,000
gallons) such as packaged and bottled petroleum products distributors, truck jobbers, and others
marketing petroleum and its products at wholesale, but without bulk liquid storage facilities.1
If, during the reporting year, a facility usually classified in SIC code 5172 (such as a truck jobber)
stores greater than 10,000 gallons of petroleum product on-site, the facility becomes classified in
SIC code 5171 and is then subject to Section 313 reporting for the reporting year.
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 petroleum bulk storage facilities is shown in Table 3-1:
Table 3-1 Examples of Manufactured, Processed, and Otherwise Used Chemicals at
Petroleum Bulk Storage Facilities *
w" y'^r* f W* s&y&f Jt jE?J- *M UAM -£*"Al 1 1C fc- tfVt Jfr ^*^fo J.-K tafe^&rf-ft >e f£tf^ffi™&" "^^C". s "* "^V ff '•
M***to*9* ^#"«f^!*(*',, ', ^fpF^^WVi^a^l^^^^^" '^>«&,' . vrs&I^S
The term manufacture includes importing 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 petroleum product containing a Section 313 chemical from a foreign
supplier, then you have imported, and thus manufactured, the chemical when that shipment
arrives at the facility directly from a source outside of the United States.
•\*toW& >,<^£^&d&W!- „
• "/' S, «**t^IT?«3? ' Sf ,/
, ' ..*.... . ". *
Produced or imported for on-site
use/processing
'. ~.*.V. ^*~~"''^**fr*''.':L " 7 '- -: - \;l
May not occur in the petroleum bulk storage industry.
JU.S. Bureau of Census. 7992 Industry and Product Classification Manual, pp. 212-213.
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<4^>^l^E^
""*"•" ,A j$$$j^ "r'V-T7^
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
**"" ' -'Jfavuti** .,^"*'^ ~,j
Import of crude oil to be stored and/or processed prior to
distribution off-site.
May not occur in the petroleum bulk storage industry.
May not occur in the petroleum bulk storage industry.
saBfflfe;#^3Ev.\ ~ :^/'^ $&^^#£Npi^i'T5T ",,»'- ; :^""" -
Repackaging is considered a type of processing, including any transfer of a Section 313
chemical from one container to another, regardless of the size or type of containers involved.
The transfer of Section 313 chemicals between trucks, bulk storage containers, and pipelines
for further distribution in commerce also 'constitutes repackaging. "Repackaging" refers to the
act of removing a Section 313 chemical from one container and placing it in another. Simply
relabeling a container that contains a Section 313 chemical without taking the material out of
the container does not constitute "processing" of the Section 313 chemical. For example, a
facility that receives drums of lubrication oil, relabels the drums, and sends the drums off-site
for further distribution in commerce without opening the drums and removing the oil is not
processing (i.e., repackaging) the Section 313 chemical(s) present in the oil.
The de minimis exemption may apply to Section 313 chemicals that are processed at a facility.
Section 313 chemicals that are below de minimis concentration levels in petroleum products
are not counted towards that processing threshold. If a facility inserts additives into fuel prior
to distribution off site, the Section 313 chemicals above de minimis in the agents or additives
must be counted towards the threshold, even if these chemicals are later present at below de
minimis concentrations in the fuel distributed off site.
Petroleum product that is not brought on site to be stored and redistributed off site does not
fall within the definition of processing. For example, a storage facility may send tanker trucks
to pick up gasoline from a refinery and transport it directly to the gasoline station without
bringing the fuel to be stored on site at the storage facility. The amount of fuel that is
transferred directly to the gasoline station is not counted towards the processing threshold.
&£•:?. v^tf £M^' '"T ""
As a reactant
As a formulation component
As an article component
Repackaging
f •"*? V-*1* •*i*"Mriic£ f '•
\ •• sm TrMriO-fff H-'TV?^' f t f fS " •*•*"•
May not occur in the petroleum bulk storage industry.
Blending of additives or other agents into gasoline and
aviation fuel prior to distribution into commerce.
May not occur in the petroleum bulk storage industry.
Transfer of gasoline from bulk storage tanks to tanker
trucks for further distribution in commerce.
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
" Otl&lP;t!^f5i^^ ^^^^C"' V-S-^ I
The use of an EPCRA Section 313 chemical in support activities such as cleaning and
equipment maintenance constitutes otherwise use of that chemical.
fu^- j^'jppif^:,/'* s*\
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
^w ^-..' £&' ^/i^^i^,^^^;^ j
May not occur in the petroleum bulk storage industry.
Application of lubricants for pump and valve operation.
Diesel used to clean tanks. :
* More complete discussions of the industry-specific examples can be found in Section 5 of this guidance manual.
Current EPCRA Section 313 guidance states that:
Storage by itself is not considered a manufacturing, processing, or otherwise use activity
under EPCRA Section 313. (However, amounts of Section 313 chemicals that are released
from the storage units must be considered for release or waste management reporting if the
threshold for the chemical has been exceeded elsewhere at the facility.)
EPCRA Section 327 exempts transportation or storage incidental to transportation from
Section 313. Materials that are under active shipping are exempt until the facility takes
possession or ownership of the materials. Any materials not under active shipping papers are
not exempt. Section 313 chemicals not contained in materials under active shipping papers,
e.g., chemicals remaining in tanks and chemicals used for clean out, are not exempt from
Section 313 reporting. Fugitive emissions from materials under active shipping papers are
also exempt. An establishment located at a facility that maintains a pipeline system that
transports exempt material remains subject to Section 313 reporting. The pipelines
themselves are not exempt, since Section 327 exempts only the material inside the pipes.
Section 313 chemicals undergoing a remediation activity are not being "manufactured,"
"processed," or "otherwise used;" therefore, are not considered toward these reporting
thresholds. These amounts may require consideration for release reporting for amounts
released or otherwise managed if a threshold for the Section 313 chemical is exceeded
elsewhere at the facility.
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
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.
Section 313 reporting is required if threshold quantities are exceeded. Separate thresholds apply
to the amount of the Section 313 chemical that is manufactured, processed, or otherwise used.
Your facility must report for any listed Section 313 chemical that is manufactured above 25,000
pounds, processed above 25,000 pounds, or otherwise used in excess of 10,000 pounds during
the course of the calendar year.
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,
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:
• 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
September 15, 1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
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 for the purpose of most
motor vehicle maintenance activities are exempt, as well as fuel 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.
• Structural component of the facility: This exemption covers Section 313 chemicals that are
incorporated into the structural components of the facility (e.g., metal in pipes) or that are
used to ensure or improve the structural integrity of a structure (e.g., paint). The facility is
not required to report the releases of Section 313 chemicals that result from "passive"
degradation (degradation or corrosion that occurs naturally in structural components of
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.
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 use 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.
Most activities performed by petroleum bulk storage facilities involve Section 313 chemicals
which are "processed." The repackaging, mixing, and blending of petroleum products constitute
processing. Because the de minimis exemption applies to amounts "processed," only quantities of
Section 313 chemicals at concentrations above de minimis must be applied to the 25,000 pound
threshold. In order to perform a comprehensive and accurate threshold determination, you must
first determine what Section 313 chemicals are present in the petroleum product, and then
determine which of those Section 313 chemicals are present above the de minimis level. Only the
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
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.
Section 313 chemical is considered for
threshold determination, not the entire
mixture. The concentration of the Section
313 chemical in the petroleum product
must be known in order to determine if a
threshold has been exceeded.
In addition, 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).
The best available information should be used to estimate the approximate concentration of the
chemical in the petroleum liquid. If you have data regarding chemical concentrations in the
petroleum liquid, use the data. If specific concentration data of Section 313 chemicals in
petroleum liquids are not available, you facility may use the default values provided in Tables 3-2
and 3-4. Table 3-2 lists a number of Section 313 chemicals that may be present in various
petroleum substances and the estimated concentration values of the constituents. If the facility
does not have any specific information of the content of Section 313 in the petroleum product,
Table 3-2 may be used to estimate concentration values of constituents. Because petroleum
products vary greatly in chemical composition and concentration, your facility should use the best
available information to determine threshold calculations. Table 3-3 lists the chemicals that may
be present above de minimis levels in various petroleum products. If there is no method to
estimate quantities of a Section 313 chemical on-site, a facility is not required to report on the
chemical.
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
Table 3-2 Estimated Concentration Values of Section 313 Constituents in Crude Oil and
Petroleum Products (Weight Percent)
Section 313
Chemical
Benzene
Biphenyl
Bromine
Chlorine
Cyclohexane
Ethylbenzene
n-Hexane
MTBEb
Naphthalene
Phenanthrene
PACs°
Styrene
Toluene
1,2,4-
Trimethyl-
benzene
Xylene
(mixed
isomers)
Antimony*
Arsenic"
Beryllium0
Cadmium8
Chromium4
Cobalt4
De
Minimis
Level*
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
1.0
1.0
0.1
0.1/1.0°
0.1/1.0 c
0.1/1.0 c
0.1/1.0 d
1.0
Crude
oil
0.446
N/A
N/A
N/A
0.700
0.346
2.463
N/A
0.219
N/A
4_0E-04
N/A
0.878
0.326
1.420
1.0MS
2.0 B-°5
2-() B-07
40 B-07
40 E-05
3.0E-M
Gasoline
(Various
Grades)
1.608
0.010
N/A
N/A
0.240
1.605
7.138
15.000
0.444
N/A
N/A
3.528
7.212
2.500*
7.170
N/A
N/A
N/A
N/A
N/A
N/A
No.2
Fuel Oil/
Diesel
Fuel
8.013-04
0.100
N/A
N/A
N/A
0.013
I.OB-M
N/A
0.550
0.125
N/A
N/A
0.032
1.000*
0.290
N/A
8.5B-°S
5.0 B-°s
2.1 E-°5
9 5 B-05
N/A
Jet
Fuel
(JP-4)
1.054
N/A
N/A
N/A
1.240
0.481
5.110
N/A
0.468
N/A
N/A
N/A
1.854
N/A
2.299
N/A
N/A
N/A
N/A
N/A
N/A
Ker-
osene
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.160
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Lubri-
cating
Oil
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
No. 6
Fuel
Oil
0.001
N/A
3.0 B-06
7.8 ^
N/A
2_2E-03
N/A
N/A
0.100
N/A
1.130
N/A
0.006
N/A
0.013
i.oE-°s
6.0 ^
N/A
N/A
4.5 B"07
1.5 E-°5
Aviation
Gasoline
0.515
N/A
N/A
N/A
N/A
0.432
3.000
N/A
0.100
N/A
N/A
N/A
7.327
N/A
2.204
N/A
N/A
N/A
N/A
N/A
N/A
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
Section 313
Chemical
Copper*
Lead
Compounds
Manganese*
Mercury*
Nickel*
Selenium*
Silver*
Zinc
Compounds
De
Minimis
Level*
1.0
1.0
(organic)
0.1
(inorg.)
1.0
1.0
0.1
1.0
1.0
1.0
Crude
Oil
4.0 «*
N/A
N/A
6.0E-°*
5.5B-°3
4.0 "«
N/A
N/A
Gasoline
(Various
Grades)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
No.2
Fuel Oil/
Diesel
Fuel
5.6 B-M
N/A
2.1 B-°s
40 E-05
3.38 ^
N/A
N/A
N/A
Jet
Fuel
(JP-4)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ker-
osene
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Lubri-
cating
Oil
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.000
No. 6
Fuel
Oil
3.0 B-°5
N/A
0.005
5.0 ^
3.8B-°3
Q Q B-OS
2.0 E-°8
N/A
Aviation
Gasoline
N/A
0.14-
(organic)
N/A
N/A
N/A
N/A
N/A
N/A
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendices B and
H, "Memorandum from Patrick B. Murphy, Radian/RTP to James F. Durham, EPAICPB Concerning Petroleum Refinery
Liquid HAP and Properties Data, August 10,1993," and "Memorandum from Paul C. Bailey, Jr., API/Washington, DC
to James F. Durham, EPAICPB Concerning Revised Estimates of Heavy Petroleum Product Liquid Constituents,
December 23,1993"
N/A - Concentration data not available based on data sources reviewed
* The de minimis concentration values for the metals is for the metal compound.
" Lead compounds and n-Hexane concentration for Aviation Gasoline 100 (Exxon-MSDS).
* Concentrations updated with comments received from API.
* Constituents are most likely metal compounds rather than the elements. Elements are listed in this table because
concentration data are for only the metals occurring in the fuel. Concentrations for metal compounds would be
somewhat higher depending on the metal compound. For threshold determination, if the weight of the compound is not
known, facilities may use the weight of the lowest metal compound likely to be present.
k MTBE maybe present to enhance octane in concentrations from 0-15%.
c The de minimis level for inorganic compounds is 0.1; for organic compounds is 1.0.
* The de minimis level for chromium VI compounds is 0.1; for chromium HI compounds is 1.0.
• The petroleum products may contain one or more of the following chemicals under the polycyclic aromatic compounds
(PACs) category: benzo(a)anthracene, benzo (b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranthene,
benzo(rst)pentaphene, benzo(a)phenanthrene, benzo(a)pyrene, dibenz(a,h)acridine, dibenz(a,j)acridine,
dibenzo(a4i)anthracene, 7H-Dibenzo(c,g)carbazole, dibenzo(a,e)fluoranthene, dibenzo(a,e)pyrene, dibenzo(a,h)pyrene,
dibenzo(a,l)pyrene, 7,12-dimethylbenz(a)anthracene, indeno[l,2,3-cd]pyrene, 5-methylchrysene, 1-nitropyrene. For
No. 6 fuel oil, the value given is for benzo(a)anthracene.
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
Facilities in SIC 5171 may engage in mixing and blending of petroleum products prior to
distribution off site in commerce, which constitutes processing. Blending operations may consist
of mixing refined motor fuel with oxygenated compounds such as methanol, ethanol, or methyl
tertiary butyl ether (MTBE). However, blending operations usually occur at the petroleum
refinery. The blending agents may constitute up to 20% of the fuel. These compounds are mixed
into the fuel to increase octane rating and reduce vehicle emissions.
Table 3-3 Constituents in Petroleum Products That May Be Present Above De Minimis
Benzene
Cyclohexane
Ethylbenzene
MTBE
n-Hexane
PACs
Styrene
Toluene
1,2,4-
Trimethylbenzene
Xylene
(mixed isomers)
Zinc Compounds
Crude
Oil
/
/
/
Gasoline
(Various
Grades)
/
/
/
/
/
/
/
/
No. 2 Fuel
Oil/ Diesel
Fuel
/
Jet
Fuel
(JP-4)
/
/
/
/
/
Lubricating
Oil
•
,
•
/
No. 6
Fuel
Oil
/
Aviation
Gasoline
/
/
/
/
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendices B
and H, "Memorandum from Patrick B. Murphy, RadianlRTP to James F. Durham, EPAICPB Concerning Petroleum
Refinery Liquid HAP and Properties Data, August 10,1993," and "Memorandum from Paul C. Bailey, Jr.,
API/Washington, DC to James F. Durham, EPAICPB Concerning Revised Estimates of Heavy Petroleum Product
Liquid Constituents, December 23,1993". Table reflects updated information from comments received on guidance
document for 1,2,4-Trimethylbenzene content in gasoline.
More commonly, facilities may process Section 313 chemicals by adding proprietary additive
packages to motor fuels prior to distribution off-site. Facilities that perform mixing activities
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
must consider the Section 313 chemicals present above de minimis concentrations in the agents
and additives towards the 25,000 threshold for processing, even if the concentration of the
additives or agents in the final product distributed off site falls below the de minimis concentration
level
Petroleum bulk stations and terminals may also exceed the threshold for manufacturing,
processing, or otherwise using a Section 313 chemical. The facility may manufacture a Section
313 chemical by importing a petroleum product that contains Section 313 chemicals. Section 313
chemicals present in the petroleum product must be counted towards the 25,000 pound threshold
for manufacturing.
In addition, you must determine what Section 313 chemicals are subject to the otherwise use
threshold. Materials used in tank and pipe maintenance such as cleaners and lubricants may
contain Section 313 chemicals. These chemicals, if above de minimis concentration levels, must
be applied to the 10,000 pound threshold for otherwise use.
In order to determine whether or not a
threshold for a Section 313 chemical has ^ ^
been exceeded, the facility must compile
all available information. Under EPCRA
Section 313, facilities are required to use
whatever is available to them that would
assist them in making the most accurate
estimates where required. MSDSs,
inventory/shipping data, and process
knowledge can be used in determining the
amount of chemicals manufactured,
processed, and otherwise used at
petroleum bulk storage facilities.
Threshold determinations are made based
on the best available information within
your facility. EPCRA does not require a facility to install new monitoring equipment or conduct
additional sampling activities.
STEP FOUR
Gather data needed for calculations of
threshold determination, including:
• Inventory Data
• Consumption Information
• Supplier Notification
• Sampling and Analysis Data
MSDS
• Analysis of Waste Products
• Permits
Threshold determinations are made based on the best available information in your possession.
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. Though, in general, the following methods should be
employed to determine the appropriate concentrations to use in threshold determinations:
September 15, 1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
If the extract concentration is known (e.g., 33.0% toluene), use it.
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.
• If only the upper bound is known (e.g.,
<5% toluene or 0-5% 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 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.
In summary, petroleum bulk stations and terminals may exceed the threshold for manufacturing,
processing, or otherwise using a Section 313 chemical. The facility may manufacture a Section
313 chemical by importing a petroleum product that contains Section 313 chemicals.
Petroleum bulk stations and terminals engage in activities that process Section 313 chemicals in
petroleum products. The facility must determine what listed Section 313 chemicals are present
above de minimis in petroleum products in order to determine if the processing threshold has been
exceeded for each Section 313 chemical in the petroleum product. An estimate of how much
gasoline (as well as other petroleum products) must be processed to exceed the 25,000 pound
threshold for certain constituents is found in Table 3-4. The amount of product that would
exceed that threshold varies depending on the concentration of the constituents in the product.
The facility may also process listed Section 313 chemicals that are present in additives
incorporated into petroleum products.
Petroleum bulk stations and terminals also engage in activities such as equipment maintenance
that involve the "otherwise use" of listed Section 313 chemicals in cleaners and lubricants.
September 15,1997
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PETROLEUM BULK STORAGE FACILITIES
Table 3-4 Estimated Quantities Required to Exceed the Processing Threshold for Several
Petroleum Products
Product
Gasoline
(Various
Grades)
No. 6 Fuel Oil
Crude Oil
No. 2 Fuel
OiJ/Diesel Fuel
Lubricating Oil
Aviation Gas
Jet Fuel (JP-4)
Section 313
Chemicals That May
Be Present Above De
Minimis
Benzene
Ethylbenzene
MTBE
n-Hexane
Styrene
Toluene
1 ,2,4-Trimethylbenzene
Xylene (mixed isomers)
Benz(a)anthracene
(PACs)
Benzene
n-Hexane
Xylene (mixed isomers)
1 ,2,4-Trimethylbenzene
Zinc Compounds
Benzene
n-Hexane
Toluene
Xylene (mixed isomers)
Benzene
Cyclohexane
n-Hexane
Toluene
Xylene (mixed isomers)
Concentration
(weight percent)
1.608
1.605
15.000
7.138
3.528
7.212
2.500
7.170
1.130
0.446
2.463
1.420
1.000
1.000
0.515
3.000
7.327
2.204
1.054
1.240
5.110
1.854
2.299
Quantity of Product
Required to Meet the
25,000-lb Threshold for
Processing (Gallons)
258,389
258,872
27,699
58,208
117,769
57,611
166,196
57,948
276,549
794,526
143,873
249,548
357,143
351,865
831,940
142,816
58,475
194,396
380,359
323,305
78,454
216,234
174,379
September 15,1997
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PETROLEUM BULK STORAGE FACILITIES
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313.Appendices Band
H,"'Memorandum from Patrick B. Murphy, RadianlRTP to James F. Durham, EPAICPB Concerning Petroleum
Refinery Liquid HAP and Properties Data, August 10,1993," and "Memorandum from Paul C. Bailey, Jr.,
API/Washington, DC to James F. Durham, EPAICPB Concerning Revised Estimates of Heavy Petroleum Product
Liquid Constituents, December 23,1993"
Updated information from comments received on guidance document for 1,2,4-Trimethylbenzene in gasoline and No. 2
fuel oil/Diesel fuel; information updated for n-Hexane in aviation gasoline from Exxon MSDS.
September 15, 1997
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PETROLEUM BULK STORAGE 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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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.
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 requked 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.
• Direct measurement (basis of estimate code = M; entered in Part n 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,
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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 an indication that reportable chemical is below detection is not equivalent to stating
that the chemical is not 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 assuming a concentration of
5mg/l).
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.
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 n, Sections 5 and 6) - Release
information derived from facilities or processes similar to yours can be used to estimate
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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 calculations. 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 n, 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
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
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"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 aggregate 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 n, Section 8.9 of the Form R).
For example, if nitric acid is involved in 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, Sectibn 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 H
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.
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 in release reporting.
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,
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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
n, 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 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
Tables 4-1 and 4-2)
Clearinghouse for Inventories and Emission
Factors (CHIEF)
CHEF is designed to provide access to tools for estimating
emissions of air pollutants and performing air emission
inventories. It serves as EPA's central clearinghouse for the
latest information on air emission inventories and emission
factors. Emission estimation data bases, newsletters,
announcements and guidance on performing inventories will
be included in CHIEF. Tools for estimating emissions such
as AP-42, WATERS, CHEMDAT8, and TANKS can be
downloaded from this bulletin board system. CHIEF is
located on the world wide web at
http://www.eDa.gov/tta/chief/.
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 wastewater treatment (WWT)
tanks; aerated impoundments, which include aerated surface
impoundments and aerated WWT tanks; disposal
impoundments, which include nonaerated 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
httD://www.eDa.gov/ttn/chief/software.html#water8
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SOCMI emission factors (listed in Table
4-3)
Facility-specific emission factors
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 AND TANKS
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 httD://www.eDa.gov/ttn/chief/software.html#water8.
Stack or Point-Source Air Emissions (Part n, 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
• 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:
• Air emission inventories
• Air permit applications
• Process and production data
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 the world wide web at
httD://www.eDa.gov/ttn/chief/tanks.html.
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• Emission factors from EPA and commercial models
• Engineering calculations
Wastewater Discharges (Part n, 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 n, Section 6.1 of
Form R. Because the release estimation approach is similar for both types of wastewater
discharges, they are discussed here together.
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 direct discharge
permit, or a POTW indirect discharge 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 n, Section 6.1 of Form R.
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 a reportable
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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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.
Discharges of listed acids may be
reported as zero if all discharges
have been neutralized to pH 6 or
above. If wastewater containing a
listed acid is discharged below pH
6, then releases of the acid must be
calculated and reported. For more
information on calculating such
discharges of acids, see EPA's
Estimating Releases of Mineral
Acid Discharges Using pH
Measurements (EPA745/F-97-003,
June 1991).
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:
''"»*» i
>/', , •
3/1/96
9/8/96
Coaeeatrafta*
' fttgft
1.0
0.2
Flow
• mom
1.0
0.2
''''Sfec&alle
8.33 Ibs.
0.332 Ibs.
Annual Calculation:
8.33 Ibs. + 0.332 lbs./2 days x 365 days/year = 1580.82 Ibs/yr
Underground Injection On-Site (Part EL, Section 5.4 of Form R)
A facility that has an underground injection well for waste disposal is regulated by Safe Drinking'
Water Act (SDWA) permits. The permit(s) usually require measurements of the waste volume
and analyses of some generalized waste parameters including concentrations of various
constituents. When the constituents for which the permit requires analyses include reportable
Section 313 chemicals, releases via underground injection can be calculated by multiplying the
volume of waste injected by the concentration of the chemical in the waste. Facilities must report
amounts of Section 313 chemicals injected into Class I wells (Part n, Section 5.4.1 of Form R)
and amounts injected into Class n-V (Part II, Section 5.4.2 of Form R).
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Release to Land On-Site (Part H, 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 n, 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 n, 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 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 H, 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
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Estimating Releases for Accidental Losses
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 n,
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 H, 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;
• Efficiency of the waste treatment
method or sequence in destroying
or removing the Section 313
chemical; and
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 included in release estimates. 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), provide 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
glycol ether to be mixed into fuel as an additive. While
unloading on a windless overcast day, a 55 gallon drum
containing glycol ether is 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 glycol ether from the concrete pad is
transferred offsite for disposal. How would these releases
be reported on the Form R? The density of glycol ether is
8.6 pounds per gallon, and the vapor pressure is 0.10 mm
Hg at 68° F.
Quantity spilled = 55 gal x 8.6 IbsJgal = 473 Ibs.
Amount spilled onto pad = 473 x 90% = 425.7 Ibs.
Amount spilled onto soil = 473x10%= 473 Ibs.
Air emissions of glycol ether 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
(430 pounds) is transferred offsite and should be reported
in Sections 6.2, and the total amount spilled onto the soil
(50 pounds) should be reported in Section 5.5.4, other
disposal.
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• 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 7 A 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 (513) 569-7610.
Additional information can be obtained by calling the ATTIC Hotline at (513) 569-7272.
On-site Energy Recovery Processes (Part n, 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.
On-site Recycling Processes (Part H, Section 7C of Form R)
In Section 7C, methods used to recycle the Section 313 chemical in wastes are reported.
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Source Reduction and Recycling Activities (Part n, 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 H, 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 n, 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 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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Quantity Used for Energy Recovery Off-site (Part n, Section 8.3 of Form R)
The quantity reported in Section 8.3 is the quantity reported in Section 6.2 for which energy
recovery codes are reported. Section 6.2 energy recovery codes are M56 and M92. If a quantity
is reported in Section 8.8, subtract any associated off-site transfers for energy recovery:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
Quantity Recycled On-site (Part n, 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
in 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 H, Section 8.5 of Form R)
The quantity reported in Section 8.5 must be the same as the quantity reported in Section 6.2 for
which recycling codes are reported. Section 6.2 recycling codes are M20, M24, M28, and M93.
If a quantity is reported in 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 H, Section 8.6 of Form R)
Waste treatment in 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 in 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 in Section 8.6.
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PETROLEUM BULK STORAGE FACILITIES
Quantity Treated Off-site (Part n, 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 n, 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 not associated with
production processes are not reported in Part n, Section 8.8 nor Sections 8.1 through 8.7 of
FormR.
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SECTION 5
CALCULATING RELEASE ESTIMATIONS AT PETROLEUM BULK STATIONS AND
TERMINALS
In Section 4, the tools and techniques available for estimating releases to the environment and
reporting disposition of wastes (including transfers off-site, land disposal, underground injection,
and wastewater discharges) were discussed. This section provides guidance on how petroleum
bulk stations and terminals should report these releases and waste dispositions on Form R.
Typical operations and the resulting wastes and releases are discussed.
Petroleum and petroleum products are managed in marketing facilities known as bulk stations and
terminals. These terminals are widespread and diverse with varying degrees of complexity.
Product lines include: crude oil, motor gasoline, diesel, heating fuel, aviation jet fuel, asphalt, and
liquid petroleum hydrocarbons.
Petroleum bulk stations and terminals should evaluate their activities on a site-specific basis. This
guidance is a starting point for considering possible releases and estimation methods. Developing
accurate and comprehensive release estimates requires the consideration of all possible release
pathways. While differing in some respects, all petroleum bulk terminals share the fundamental
operating characteristics diagramed in Figure 5-1.
The primary activity at petroleum bulk terminals is the bulk storage (ie., greater than 10,000
gallons) and transfer of petroleum products prior to further distribution in commerce. The
petroleum products enter the facility in bulk quantities via pipeline, rail car, tank truck, or vessel,
depending on the location of the facility. While on site, the petroleum is stored in large storage -
tanks and then subsequently dispensed into tanker trucks, rail cars, or pipelines to be distributed in
commerce. The facility also may engage in mixing or blending of the petroleum products prior to
distribution off-site.
In addition, releases from operations in which petroleum product is not brought on site to be
stored and redistributed off site are not subject to Section 313 reporting. For example, a storage
facility may send tanker trucks to pick up gasoline from a refinery and transport it directly to the
gasoline station without bringing the fuel to be stored on site at the storage facility. The releases
from these types of transfers are not reported on the storage facility's Form R.
The following operations, common to many petroleum bulk terminals, may result in releases
containing Section 313 chemicals.
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Waste
Petroleum
Produd/
WastewBler
StodtfPcW Air Bressons
> \ Waste/
Recovered
Product Tank
Manifold' Equipment
Maintenance Waste/
Wastewater
Tank Cleaning
Waste/
Wastewater
Note: Patrdeum entering and leaving the fadlitytedtBcted through a purparKinwifoldsysternasindcatedbythedouble-arrcwved
lines.
Figure 5-1: Petroleum Bulk Storage Facility
LOADING/UNLOADING PETROLEUM PRODUCT
Some potential releases or waste generation sources associated with the loading and unloading of
petroleum products are:
• Fugitive emissions during loading/unloading of petroleum product (§5.1)
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• Spills or leaks of petroleum product (§5.5)
• Waste petroleum product sent off-site for further waste management (§6.2)
• Recycling of recovered petroleum product on-site (§7C).
Petroleum bulk terminals receive petroleum products primarily through pipeline, rail car, tank
truck or directly from a barge if the terminal is located along a shoreline. A facility is responsible
for reporting releases and other waste management information for Section 313 chemicals that
occur during loading or unloading of a transportation vehicle, including trucks, railcars, ships, and
airplanes provided certain activity thresholds have been exceeded for that chemical. Releases of a
Section 313 chemical from a transportation vehicle that occur while the vehicle is still under
"active shipping papers" is exempt from Section 313 requirements (EPCRA Section 327).
However, once the facility takes possession of the petroleum product (e.g., signing shipping
papers), the facility becomes responsible for reporting releases of a Section 313 chemical,
including those that occur during loading or unloading of a transportation vehicle while the
vehicle is on property owned or operated by the facility.
Loading Losses
Loading losses are the primary source of evaporative emissions from rail tank car, tank truck, and
marine vessel operations. These releases are reported as fugitive air emissions in Section 5.1 of
the Form R. Loading losses occur as organic vapors in "empty" cargo tanks are displaced to the
atmosphere by the liquid being loaded into the tanks. These vapors are composed of vapors
formed in the empty tank by evaporation of residual product from previous loads, vapors
transferred to the tank as product is being unloaded, and vapors generated in the tank as the new
product is being loaded. The quantity of evaporative losses from loading operations depends on
parameters such as the physical and chemical characteristics of the previous and new cargo and
the method of loading and unloading the previous and new cargo.
The principal methods of cargo carrier loading are splash loading, submerged fill pipe loading, and
bottom loading. In the splash loading method, the fill pipe dispensing the cargo is lowered only
part way into the cargo tank. Significant turbulence and vapor/liquid contact occur during splash
loading and result in high levels of vapor generation and loss. In submerged fill pipe loading, the
fill pipe extends almost to the bottom of the cargo tank. In the bottom loading method, a
permanent fill pipe is attached to the cargo tank bottom In both of these submerged loading
methods, liquid turbulence is controlled which results in much lower vapor generation.
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The use of vapor recovery equipment can reduce loading emissions. Vapor recovery equipment
captures organic vapors that are displaced during loading operations and either pipes the
recovered product to a storage unit or to a thermal oxidation unit where the vapor is combusted.
Chapter Five, Section Two, of Compilation of Air Pollutant Emission Factors (AP-42) and
Section Three of Estimating Releases and Waste Treatment Efficiencies For the Toxic Chemical
Release Inventory Form (EPA 560/4-88-002, December 1987) provide detail information on the
calculation of total VOC vapor emissions during the transportation and marketing of petroleum
liquids.
Spills/Overfills
Another common release of petroleum product is the spilling of petroleum product during loading
and unloading cargo tanks or spills that occur during storage tank loading.
Spills may occur at hose/nozzle connections or as a result of line ruptures and valve failures.
While tank trucks and rail cars usually do not have catchment devices, the areas used for their
loading and offloading are normally equipped with some type of secondary containment designed
to hold the contents of at least one tank truck or rail car. New storage tanks and truck/trailer
tanks often have overfill alarms and cutoff devices; however, these may fail. Older tanks may not
be similarly equipped; therefore, operational procedures must be carefully followed to preclude
the inadvertent overfilling of these tanks. Air emissions from spills are reported in Section 5.1 as
fugitive emissions. Spilled product that is recovered and sent to an on-site unit for recycling is
reported in Section 7C. Spilled material remediated and sent off-site for disposal is reported in
Section 6.2 as an off-site transfer. Spills that remain on the pad or secondary containment is
reported in Section 5.5. More guidance on calculating releases from spills can be found in Section
Six of Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form (EPA 560/4-88-002, December 1987).
STORAGE OF PETROLEUM PRODUCT
Some potential releases or waste generation sources associated with the storage and distribution
of petroleum product are:
• Fugitive emissions from equipment leaks (§5.1)
« Point source emissions from storage tanks (§5.2)
• Leaks, drips, and accidental releases from tanks and equipment (§§5.1, 5.3, 5.5.4, and/or
6.1)
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Recovery of spilled petroleum product on site (§7C)
Waste petroleum product sent off site for further waste management (§6.2).
Tanks
Petroleum bulk stations and terminals typically store large quantities of fuel on site. Emissions
from storage tanks are a result of evaporative losses during storage (known as breathing losses or
standing storage losses) and evaporative losses during filling and emptying operations (known as
working losses). Under EPCRA Section 313, storage tank emissions are reported as stack or
point air emissions on the Form R in Section 5.2. Storage tanks may have a capacity up to 80,000
barrels (i.e., 3.2 million gallons; one barrel equals 42 gallons). These tanks have roofs to control
the vapor level and a seal to minimize water entering the tank. A series of pipes are connected to
the tank for product transport and for water that is drained out of the tank. There are four
common tank designs used for storing petroleum products: fixed roof (vertical and horizontal),
external floating roof, domed external (or covered) floating roof and internal floating roof. A
brief description of each tank is provided below.
(1) Fked Roof Tanks
This type of tank consists of a cylindrical steel shell with a permanently affixed roof, which may
vary in design from cone- or dome-shaped to flat. Losses from fixed roof tanks are caused by
changes in temperature, pressure, and liquid level. Fixed roof tanks are either freely vented or
equipped with a pressure/vacuum vent.
Horizontal fixed roof tanks are constructed for both above-ground and underground service and'
are usually constructed of steel, steel with a fiberglass overlay, or fiberglass-reinforced polyester.
Horizontal tanks are generally small storage tanks with capacities of less than 40,000 gallons.
Horizontal tanks are constructed such that the length of the tank is not greater than six times the
diameter to ensure structural integrity. Horizontal tanks are usually equipped with pressure-
vacuum vents, gauge hatches and sample wells, and manholes to provide access to these tanks. In
addition, underground tanks may be cathodically protected to prevent corrosion of the tank shell.
The potential emission sources for above-ground horizontal tanks are the same as those for
vertical fixed roof tanks. Emissions from underground storage tanks are associated mainly with
changes in the liquid level in the tank. Losses due to changes in temperature or barometric
pressure are minimal for underground tanks because the surrounding earth limits the diurnal
temperature change, and changes in the barometric pressure result in only small losses.
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(2) External Floating Roof Tanks
A typical external floating roof tank (EFRT) consists of an open-topped cylindrical steel shell
equipped with a roof that floats on the surface of the stored liquid. The floating roof consists of a
deck, fittings, and rim seal system. With all types of external floating roof tanks, the roof rises
and falls with the liquid level in the tank. External floating decks are equipped with a rim seal
system, which is attached to the deck perimeter and contacts the tank waU. The purpose of the
floating roof and rim. seal system is to reduce evaporative loss of the stored liquid. Some annular
space remains between the seal system and the tank wall The seal system slides against the tank
wall as the roof is raised and lowered. The floating deck is also equipped with fittings that
penetrate the deck and serve operational functions. The external floating roof design is such that
evaporative losses from the stored liquid are limited to losses from the rim seal system and deck
fittings (standing storage loss) and any exposed liquid on the tank walls (withdrawal loss).
(3) Internal Floating Roof Tanks
An internal floating roof tank (IFRT) has both a permanent fixed roof and a floating roof inside.
There are two basic types of internal floating roof tanks: tanks in which the fixed roof is
supported by vertical columns within the tank, and tanks with a self-supporting fixed roof and no
internal support columns. The deck in internal floating roof tanks rises and falls with the liquid
level and either floats directly on the liquid surface (contact deck) or rests on pontoons several
inches above the liquid surface (noncontact deck). The majority of aluminum internal floating
roofs currently in service have noncontact decks. Both contact and noncontact decks incorporate
rim seals and deck fittings for the same purposes previously described for external floating roof
tanks. Evaporative losses from floating roofs may come from deck fittings, nonwelded deck
seams, and the annular space between the deck and tank wall. In addition, these tanks are freely
vented by circulation vents at the top of the fixed roof. The vents minimize the possibility of
organic vapor accumulation in the tank vapor space in concentrations approaching the flammable
range.
(4) Domed External Floating Roof Tanks
Domed external (or covered) floating roof tanks have the heavier type of deck used in external
floating roof tanks as well as a fixed roof at the top of the shell like internal floating roof tanks.
Domed external floating roof tanks usually result from retrofitting an external floating roof tank
with a fixed roof. This type of tank is very similar to an internal floating roof tank with a welded
deck and a self supporting fixed roof. As with the internal floating roof tanks, the function of the
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PETROLEUM BULK STORAGE FACILITIES
fixed roof is not to act as a vapor barrier, but to prevent precipitation from accumulating on the
floating roof. The type of fixed roof most commonly used is a self supporting aluminum dome
roof, which is of bolted construction. Like the internal floating roof tanks, these tanks are freely
vented by circulation vents at the top of the fixed roof. The deck fittings and rim seals, however,
are identical to those on external floating roof tanks. In the event that the floating deck is
replaced with the lighter IFRT-type deck, the tank would then be considered an internal floating
roof tank.
Emissions from petroleum in storage occur because of evaporative loss of the liquid during its
storage and as a result of changes in the liquid level. External and internal floating roof tanks are
emission sources because of evaporative losses that occur during standing storage and withdrawal
of liquid from the tank. Standing storage losses are a result of evaporative losses through rim
seals, deck fittings, and/or deck seams.
A number of equations used to calculate total VOC losses in pounds per year from storage tanks
can be found in AP-42, Chapter 7, Section 7.1.3. The program TANKS, mentioned in Section 4
of this manual, can also aid in calculating emissions from storage tanks. The total losses from
storage tanks are equal to the sum of the standing storage loss and working loss. Variables such
as tank design, liquid temperature, and wind velocity are taken into account when determining
standing storage loss and working loss. The emission equations for fixed-roof tanks in AP-42
were developed for vertical tanks; however, the equations can also be used for horizontal tanks by
modifying the tank parameters as specified in AP-42.
Once the total volatile organic compound (VOC) loss is calculated, you can then determine the
emission rate of each constituent in the vapor. In general, the emission rate for individual
components can be estimated by'multiplying the weight fraction of the constituent in the vapor by
the amount of total VOC loss. The weight fraction of the constituent in the vapor can be
calculated using the mole fraction and the vapor pressure of the constituent (equations found in
AP-42). The weight percent can also be obtained from the SPECIATE database. The
SPECIATE data base contains organic compound and particulate matter speciation profiles for '
more than 300 source types. The profiles attempt to break down the total VOC or particulate
emissions from a particular source into the individual compounds. The SPECIATE database can
be downloaded from the world wide web at http://www.epa.gov/ttn/chief/software.htmltfspeciate.
Releases of petroleum product may occur as a result of tank failure. Federal regulations require
that storage tanks be outfitted with secondary containment. The secondary containment, typically
a bermed area, must be large enough to carry 110-150% of the capacity of the tank and hold it for
a period of 72 hours. Petroleum product that has spilled or leaked into the containment area may
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be reported in Section 7C if recovered and reinserted into the product tank, reported in Section
6.2 if sent off-site as for further waste management, and/or reported in Section 5.5 if the spill
remains on the pad or containment area.
Water may condense inside the tank and will naturally fall to the bottom of the tank. The water
layer settles on the bottom of the tank and is drained from the tank periodically and managed as
wastewater. This wastewater may contain benzene, cyclohexane, ethylbenzene, toluene, 1,2,4-
trymethylbenzene, and xylene. The wastewater from the tank is either drained and discharged or
is dkected to a tank for subsequent fuel recovery. In addition, precipitation often accumulates in
the secondary containment and must be drained as often as necessary depending on the weather.
This wastewater also may be drained to water ditches or oil/water separators regulated by the
state. Reportable Section 313 chemicals present in wastewater that is discharged off-site is
reported in Section 5.3 or Section 6.1. Reportable Section 313 chemicals present in wastewater
that is sent through a fuel recovery system is reported in Section 7C.
There also will be fugitive emissions from flanges and valves associated with the tank. These
emissions are discussed below.
Equipment
Emissions will also occur from equipment leaks at petroleum bulk stations and terminals. Integral
to the distribution system is equipment such as pumps, valves, connectors, loading arms,
compressors, drains, and meters. The pump-manifold area is a system of valves, pumps, and
piping that direct the petroleum product to various units. In general, product entering and leaving
the facility will pass through this system. Emissions from equipment leaks are reported in Section
5.1 for fugitive or non-point air emissions. The document, Protocol for Equipment Leak
Emission Estimates (EPA-453/R-95-017) provides further guidance on estimating emissions from
equipment leaks. That document details four approaches to estimating total organic emissions
from equipment leaks in the petroleum industry. One approach, the average emission factor
approach, allows the use of average emission factors developed by EPA in combination with unit-
specific data including the number of each type of component in a unit, the service each
component is in, the toxic organic compound (TOC) concentration of the stream (and volatile
organic compound (VOC) or hazardous air pollutant (HAP) concentrations if speciation is to be
performed), and the time period each component was in that service. Table 5-1 provides average
emission factors for petroleum marketing terminals.
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Table 5-1 Marketing Terminal Average Emission Factors
Equipment Type
Service
Emission Factor
(kg/hr/source) for total
organic compounds (TOC)
Valves
Pumps
Others (compressors and
others)8
Fittings (connectors and
flanges)b
Gas
Light Liquid
Gas
Light Liquid
Gas
Light Liquid
Gas
Light Liquid
1.3E-05
4.3E-05
6.5E-05
5.4E-04
1.2E-04
1.3E-04
4.2E-05
8.0E-06
Source: Protocol for Equipment Leak Emission Estimates, November 1995
" The "other" equipment type should be applied for any equipment type other than fittings, pumps, or valves
b "Fittings" were not identified as flanges or non-flanged connectors; therefore, the fitting emissions were estimated by
averaging the estimates from the connector and the flange correlation equations.
The general equation for estimating TOC mass emissions from an equipment leak using average
emission factors is:
where:
= F * WF * N
TOC
JTOC
the
emission range of TOC from all equipment in the stream of a given equipment
type (kg/hr) (this result would then be multiplied by 2.2 Ib/kg to convert
value to pounds)
average emission factor for the equipment type (kg/hr/source)
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WFTOC = average weight fraction of TOC in the stream
N = number of pieces of equipment
And the equation for determining the emissions of a specific VOC in a mixture from equipment is:
where:
= ETOC*(WPX/WPTOC)
WPX =
WPTOC =
The mass emissions of organic chemical "x" (kg/hr)
The TOC mass emissions from the equipment (kg/hr)
The concentration of organic chemical "x" in the equipment in weight percent
The TOC concentration in the equipment in weight percent.
Figure 5-2 provides an example of calculating emissions from equipment leaks.
Figure 5-2: Calculation of Equipment Leak Emissions
At a petroleum storage facility, gasoline passes through a system containing 100
connectors. The gasoline contains 85 weight percent TOC. The gasoline is in contact
with the connectors in the system for 8000 hours during the year. The weight percent
of toluene in the gasoline is 5.6%. The emissions of TOC would be calculated as:
ETOC = FA * WFroc * N * (Number of hours in contact during the year)
= (0.000008 kg/hr/connector) (0.85) (100) (8000 hrs/year)
= 5.44 kg/year of TOC from connectors
The emissions of toluene from the connectors would be calculated as:
Ex =ETOC*(WPX/WPTOC)
= 5.44 kg/year * (0.056/0.85)
= 0.3584 kg/year of toluene from connectors
This figure would then be multiplied by 2.2 Ibs./kg to convert to Ibs./year: 0.7885
Ibs./year of toluene released through the connectors.
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Equipment failure may also result in leaks and discharges of petroleum product. As with spills of
petroleum that may occur at other parts of the facility, the petroleum product may be recovered
and reinserted in the storage tank, cleaned up with absorbent and sent off site for further waste
management, and/or may remain in the environment on site.
MIXING OF PETROLEUM PRODUCT
Mixing operations may occur anywhere at the facility. Section 313 chemicals involved would
include the components in fuel and the additives. Large facilities may store large containers of
additives, and fugitive emissions may occur from these containers. Accidental spills of additives
may occur as well. Releases from mixing operations may be reported as fugitive emissions in
Section 5.1, as releases to the environment on site in Section 5.5, as disposal off-site in Section
6.2, and/or as recycled in Section 7C if the product is recovered. In addition, Section 313
chemicals in wastewater discharges related to spills should be reported in Sections 5.3 and/or 6.1.
TANK CLEANING AND EQUIPMENT MAINTENANCE
Some potential releases or waste generation sources associated with petroleum storage facility
maintenance are:
• Discharge of non-hazardous wastewaters (§5.3 or §6.1)
• Fugitive emissions from wastewater accumulated on site and during tank roof landings (§5.1)
• Wastes sent off-site for further waste management (§6.2)
• On-site waste treatment (§7A)
• Recovery of petroleum in wastewater or sludge on site (§7C).
Tanks are cleaned if there is a change in service (e.g., from crude oil to gasoline), if the tank will
undergo an upgrade, and prior to any significant internal inspections. API recommends that
storage tanks be cleaned and inspected for leaks every 10 years. Large tanks are inspected
infrequently, generally only every 10-20 years unless there are compelling circumstances for more
frequent cleanings. Accumulated contaminants and heavy compounds settle in tank bottoms
during normal storage, resulting in sludge. Storage of refined petroleum products may not result
in heavy accumulation of sludge.
Emissions of Section 313 chemicals from tank cleaning or other activities that occur at the facility
must be considered for release or other waste management reporting provided a threshold has
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been exceeded elsewhere at the facility for that chemical. During cleaning operations, the tanks
are drained down to remove and recover all product possible. Fugitive emissions may occur
during tank roof landings. The remaining residue consists of a liquid and a solid phase. The liquid
is primarily wastewater with small amounts of hydrocarbon. If the wastewater is treated prior to
discharge, then the treatment of the wastewater would be reported in Section 7 A. Section 313
chemicals in wastewater discharged to an on-site body of water or to a POTW is reported in
Section 5.3 or Section 6.1 of the Form R. The rest of the residue consists of sludge composed of
a mixture of sediments, heavier products, such as waxes and asphalt, and corrosion products, such
as rust and scale, which can be recycled on site or sent off site. Sludge sent off site for further
waste management is reported as an off-site transfer in Section 6.2. If the sludge is recycled on
site, the tanks are washed with hot diesel and/or water. This mixture is vacuumed from the tank
and sent to either a filter press or centrifuge to separate the hydrocarbons, water, and solids. The
hydrocarbons are recovered, and water and other solid waste are disposed. The recovery of the
hydrocarbons is reported as on-site recycling in Section 7C of the Form R. The disposal of water
and solids are reported as transfers off-site in Sections 5.3, 6.1, and/or 6.2. Section 313
chemicals potentially released consist of the constituents in the products and/or tank construction
materials. The Section 313 chemicals potentially present in tank sludges include benzene,
cadmium, and chromium. In addition, any fugitive emissions from tank cleanings are reported in
Section 5.1.
Secondary containment of the storage tanks and loading racks may collect rainwater runoff
contaminated with petroleum and other constituents from equipment cleaning operations, leaks,
and spills. The composition of this waste is highly variable. Fugitive emissions may occur from
wastewater that is accumulated on site in secondary containment, sumps, or impoundments.
Programs such as WATERS or CHEMDAT8 can aid in determining fugitive emissions from these
units. The wastewater may be reported as a discharge to an on-site body of water in Section 5.3
or a discharge to a POTW in Section 6.1. If the wastewater is treated prior to discharge, then the
treatment of the wastewater would be reported in Section 7A. If petroleum is recovered from the
wastewater, the Section 313 chemical recovered will be reported in Section 7C.
Amounts of leaked or spilled petroleum product that are immediately cleaned up and directly
reused within the same reporting year are not subject to release reporting, provided that the
material is not treated prior to reuse.
Section 313 chemicals undergoing a remediation activity are not being "manufactured,"
"processed," or "otherwise used;" therefore, they are not considered toward the reporting
thresholds. However, these amounts may require consideration for release reporting for amounts
released or otherwise managed if a threshold for the Section 313 chemical is exceeded elsewhere
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at the facility. For example, a facility that is remediating soil and groundwater contaminated with
lead must report the amounts of lead released, managed on-site, or transferred off-site only if the
facility elsewhere manufactures, processes, or otherwise uses lead in amounts exceeding the
applicable thresholds.
Releases that occur during the reporting year must be included in release reporting calculations.
If soil and/or groundwater contamination from a current leaking unit is discovered, the release
must be reported. Amounts of Section 313 chemicals in contaminated soil and/or groundwater
that have resulted from a previous leaking unit which no longer exists are not included in the
calculations for release reporting.
September 15,1997
5-13
-------
-------
TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
APPENDIX A
ALPHABETICAL LISTING OF SECTION 313 CHEMICALS
September 15,1997
A-l
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE 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
812-044
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
42244-6
354-234
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
10845-2
10347.54-3
2556-36-7
76441-0
10646-7
123-91-1
104494
624-18-0
3173-72-6
82-28-0
35691-65-7
354-25-6
CHEMICAL NAME
l-(3-Chloroallyl)-3,5,7-triaza-l-azoniaadainantane chloride
l,l,l,2-Tetiachloro-2-flaoroethane(HCFC-121a)
1,1,1 ,2-tetrachloroethane
1 ,1 ,1 -Trichloroethane (Methyl chloroform)
1 ,1 ,2,2-Tetrachloro-l -fiuoroethane (HCFC-121)
1 , 1 ,2,2-Tetrachloroethane
1 , 1 ,2-Trichloroethane
l,l-Dichloro-l,2,2,3,3-pentafluoropropane(HCFC-225cc)
1 ,1 -Dichloro-1 ,2,2-trifiuoroethane (HCFC-1 23b)
l,l-Dichloro-l,2,3,3,3-pentafluoropropane(HCFC-225eb)
1,1-Dichloro-l -fiuoroethane (HCFC-141b)
1,1-Dimethyl hydrazine
1 ,1 -Methylene bis(4-isocyanatocyclohexane)
1,2,3-Trichloropropane
1 ,2,4-Trichlorobenzene
1 ,2,4-Trimethylbenzene
1,2-Butylene oxide
l,2-Dibromo-3-chloropropane (DBCP)
1,2-Dibromoethane (Ethylene dibromide)
1 ,2-Dichloro-l ,1 ,2,3,3-pentafluoropropane (HCFC-225bb)
1 ,2-Dichloro-l , 1 ,2-trifluoroethane (HCFC-1 23a)
l,2-Dichloro-l,l,3,3,3-pentafluoropropane(HCFC-225da)
l,2-Dichloro-l,l-difluoroethane(HCFC-132b)
1 ,2-Dichlorobenzene
1,2-Dichloroethane (Ethylene dichloride)
1 ,2-Dichloroethylene
1 ,2-Dichloropropane
1,2-Diphenylhydrazine (Hydrazobenzene)
1 ,2-Phenylenediamine
1,2-Phenylenediamine dihydrochloride
l,3-Bis(methy]isocyanate)cyclohexane
1,3-Butadiene
l,3-Dichloro-l,l,2,2,3-pentafluoropropane(HCFC-225cb)
l,3-Dichloro-l,l,2,3,3-pentafluoropropane(HCFC-225ea)
1 ,3-Dichlorobenzene
1 ,3-Dichloropropylene
1,3-Phenylene diisocyanate
1 ,3-Phenylenediamine
1 ,4-Bis(methylisocyanate)cyclohexane
1,4-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
l-Chloro-l,l,2,2-tetrafluoroethane(HCFC-124a)
De
Minim is
Cone
1
1
1
1
1
1
1
1
1
1
1
0.1
1
0.1
1
1
1
0.1
0.1
1
1
1
1
1
0.1
1
1
0.1
1
1
1
0.1
1
1
1
0.1
1
1
1
1
0.1
0.1
1
1
0.1
1
1
Appx
vra
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
September 15,1997
A-2
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
75-68-3
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
39156^1-7
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
117-79-3
52-51-7
2837-89-0
75-88-7
532-27-4
110-80-5
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
l-Chloro-l.l-difluoroethane (HCFC-142b)
1-Nitropyrene
2,2,4-Trimethylhexamethylene diisocyanate
2,2-Dichloro-l,l,l,3,3-pentafluoropropane (HCFC-225aa)
2,2-Dichloro-l,l,l-trifluoroethane(HCFC-123)
2,3,5-Trimethylphenylmethylcarbamate
2,3-Dichloro-l,l,l,2,3-pentafluoropropane(HCFC-225ba)
2,3 -Dichloropropene
2,4,4-Trimethylhexamethylene diisocyanate
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-Dinitrophenol
2,4-Dinitrotoluene
2,4-Dithiobiuret
2,4-DP
2,6-Dimethylphenol
2,6-Dinitro toluene
2,6-Xylidine
2-Acetylaminofluorene
2-Aminoanthraqu inone
2-Bromo-2-nitropropane-l ,3-diol (Bronopol)
2-Chloro-l ,1 ,1 ,2-tetrafluoroethane (HCFC-1 24)
2-Chloro-l,l,l-trifluoroethane(HCFC-133a)
2-Chloroacetophenone
2-Ethoxyethanol
2-Mercaptobenzothiazole (MET)
2-Methoxyethanol
2-Methy]]actonitrile
2-Methylpyridine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
3,3-Dichloro-l,l,l,2,2-pentafluoropropane(HCFC-225ca)
3,3'-Dichlorobenzidine
3,3'-Dichlorobenzidinedihydrochloride
3,3'-Dichlorobenzidine sulfate
3,3'-Dimethoxybenzidine
1
1
1
1
1
1
1
1
1
1
0.1
1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1
0.1
0.1
0.1
1
1
1
1
1
1
0.1
1
1
0.1
0.1
0.1
1
0.1
1
1
1
1
1
1
1
1
0.1
1
1
0.1
0.1
0.1
0.1
X X
X X
X X U240
X
X X U081
X X U101
X X P048
X X U105
X P049
X X U106
X X U005
X U359
X P069
X U191
X
X U171
X U073
X U091
September 15, 1997
A-3
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
91-93-0 3,3-Dimethoxybenzidine-4,4'-diisocyanate
20325-40-0 3,3'-Dimethoxybenzidine dihydrochloride (o-Dianisidine
dihydrochloride)
111 984-09-9 3,3-Dimethoxybenzidine hydrochloride (o-Dianisidine
hydrochloride)
91-97-4 3,3-Dimethyl-4,4'-diphenylene diisocyanate
119-93-7 3,3-Dimethylbenzidine (o-Tolidine)
612-82-8 3,3-Dimethylbenzidinedihydrochloride (o-Tolidine
dihydrochloride)
41766-75-0 3,3-Dimethylbenzidine dihydrofluoride (o-Tolidine
dihydrofluoride)
460-35-5 3-Chloro-l,l,l-tcifluoropropane (HCFC-253fb)
563-47-3 3-Chloro-2-methyl-l-propene
542-76-7 3-Chloropropionitrile
55406-53-6 3-Iodo-2-propynyl butylcarbamate
101-80-4 4,4'-Diaminodiphenyl ether
4128-73-8 4,4-Diisocyanatodiphenyl ether
80-05-7 4,4-lsopropylidenediphenol
101-14-4 4,4'-Methylenebis(2-<:hloroaniIine} (MBOCA)
101-61-1 4,4'-Methylenebis(N,N-dimethyl)benzenamine
101-77-9 4,4-Methylenedianiline
139-65-1 4,4-Thiodianiline
534-52-1 4,6-Dinitro-o-cresol
60-09-3 4-Aminoazobenzene
92-67-1 4-Aminobiphenyl
60-11-7 4-Dimethylaminoazobenzene
75790-84-0 4-Methyldiphenylmethane-3,4-diisocyanate
92-93-3 4-Nitrobiphenyl
100-02-7 4-Nitrophenol
3697-24-3 5-Methylchrysene
99-59-2 5-Nitro-o-anisidine
99-55-8 5-Nitro-o-toluidine
57-97-6 7,12-Dimethylbenz(a)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
71751-41-2 Abamectin [Avermectin Bl]
30560-19-1 Acephate (Acetylphosphoramidothioic acid O,S-dimethyl
ester)
75-07-0 Acetaldehyde
60-35-5 Acetamide
75-05-8 Acetonitrile
98-86-2 Acetophenone
62476-59-9 Acifluorfen, sodium salt [5-(2-Chloro4-
(trifluoromethyl)phenoxy)-2-nitrobenzoic acid, sodium salt]
107-02-8 Acrolein
79-06-1 Acrylamide
79-10-7 Acrylic acid
107-13-1 Acrylonitrile
15972-60-8 Alachlor
116-06-3 Aldicarb
309-00-2 Aldrin [1,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
hexachloro-1,4,4a,5,8,8a-hexahydro-
(l.alpha.,4.alpha.,4a.beta.,5.alpha.,8.alpha.,8a.beta.)-]
107-18-6 Allyl alcohol
0.1
0.1
0.1
0.1
0.1
1
0.1
1
1
0.1
1
1
0.1
0.1
0.1
0.1
1
0.1
0.1
0.1
1
0.1
1
1
1
X
U095
X
X
X
X
X
X
X
X
X
X
X
X
X
X
P027
U158
P047
U093
U170
U181
U094
1
1
0.1
0.1
1
1
1
1
0.1
1
0.1
1
1
1
X X
X
X X
X X
X X
X
X
U001
U003
U004
POOS
U007
U008
U009
P070
P004
POOS
September 15,1997
A-4
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
107-05-1
107-11-9
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
7440^1-7
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
AHyl chloride
Allylamine
alpha-Hexachlorocyclohexane
alpha-Naphthylamine
Aluminum (fume or dust)
Aluminum oxide (fibrous form)
Aluminum phosphide
Ametryn(N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-l,3,5,-
triazine-2,4-diamine)
Amitraz
Amitrole
Ammonia
Anikzine[4,6-Dichloro-N-(2-chlorophenyl)-l,3,5-triazin-2-
amine]
Aniline
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazine(6-Chloro-N-ethyl-N'-(l-methylethyl)-l,3,5-tiiazine-
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)fiuoranthene
Benzo(rst)pentaphene
Benzoic trichloride (Benzotrichloride)
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
beta-Naphthylamine
beta-Propiolactone
Bifenthrin
Bjphenyl
Bis(2-chloro-l -methylethyl)ether
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) adipate
Bis(chloromethyl) ether
Bis(tributyltin) oxide
1
1
1
0.1
1
1
1
1
1
0.1
1
1
1
1
1
0.1
0.1
O.ls
1
1
1
1
1
1
0.1
0.1
1
1
1
0.1
0.1
0.1
1
1
1
1
1
0.1
1
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
U167
P006
U011
U012
U018
U017
U019
U021
U022
U064
U023
P028
P015
U168
U027
U024
U025
P016
September 15,1997
A-5
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
10294-34-5
7637-07-2
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
744043-9
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
Boron trichloride
Boron trifluoride
Bromacil (5-Bromo-6-methyl-3-(l -methylpropyl)-2,4-
(lH,3H)-pyrimidinedione)
Bromacil, lithium salt (2,4-(lH,3H)-Pyrimidinedione, 5-
bromo-6-methyl-3 (I-methylpropyl), lithium salt)
Bromine
Bromochlorodifluoromethane (Halon 1211)
Bromoform (Tribromomethane)
Bromomethane (Methyl bromide)
Bromotrifluoromethane (Halon 1301)
Bromoxyntt(3,5-Dibromo-4-hydroxybenzonitrile)
Bromoxyniloctanoate (Octanoic acid, 2,6-dibromo-4-
cyanophenyl ester)
Brucine
Butyl acrylate
Butyraldehyde
C.L Acid Green 3
C.L Acid Red 114
C.L Basic Green 4
C.L Basic Red 1
C.L Direct Black 38
C.L Direct Blue 21 8
C.L Direct Blue 6
C.I Direct Brown 95
C.L Disperse Yellow 3
C.L Food Red 15
C.LFbodRed5
C.L Solvent Orange 7
C.L Solvent Yellow 14
C.L Solvent Yellow 3
C.L Solvent Yellow 34 (Auramine)
C.L Vat Yellow 4
Cadmium
Calcium cyanamide
Captan [lH-Isoindole-l,3(2H)-dione, 3a,4,7,7a-tetrahydro-2-
[(trichloromethyl)thio]-]
Carbaryl [1-Naphthalenol, methylcarbamate]
Carbofuran
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Carboxin(5,6-Dihydro-2-methyl-N-phenyl-l,4-oxathiin-3-
carboxamide)
Catechol
Chinomethionat (6-Methyl-l ,3-ditniolo[4,5-b]quinoxalin-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)-carbonyl]-amino]sulibnyl]benzoate)
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0.1
1
1
0.1
0.1
0.1
0.1
1
1
0.1
1
1
1
0.1
1
0.1
1
1
1
1
1
0.1
1
1
1
1
1
0.1
0.1
1
X X U225
X X U029
X P018
X U014
X X
X X
X X
X X P022
X X U211
X X U036
September 15, 1997
A-6
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
7782-50-5
10049-04-4
79-11-8
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
7440^7-3
7440-48-4
7440-50-8
8001-58-9
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
2172546-2
1134-23-2
110-82-7
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
Chlorine
Chlorine dioxide
Chloroacetic acid
Chlorobenzene
Chlorobenzilate [Benzeneacetic acid,4-chloro-.a!pha.-(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-tetra
chloro-]
Chlorotrifluoromethane (CPC-13)
Chlorpyrifos methyl (O,O-DimethytO-(3,5,6-trichloro-2-
pyridyl)phosphorothioate)
ChlorsuIfuron(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-Dichloroethenyl)-2,2-
dimethylcyclopropanecarboxylic acid, cyano(4-fluoro-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
1
1
1
1
1
1
1
0.1
1
0;1
1
1
1
1
1
1
1
0.1
0.1
1
0.1
1
1
1
1
0.1
1
1
1
1
1
1
1
1
1
1
1
0.1
1
0.1
1
X X U037
X X
X
X X U044
X X U045
X U046
X X U210
X X
U051
X U052
X U053
U055
U096
X X
U056
X
X X U028
X U062
X U221
September 15,1997
A-7
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
334-88-3
226-36-8
224-42-0
5385-75-1
192-654
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
Diazomethane
Dibenz(a,h)acridine
Dibenz(aj)acridine
Dibenzo(a,e)fluoianthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)anthracene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
Dibenzofuran
Dibromotetrafluoroethane (Halon 2402)
Dibutylphthalate
Dicamba (3,6-Dichloro-2-methyoxybenzoic add)
Dichloran (2,6-Dichloro-4-nitroaniline)
Dichloro-1 , 1 ,2-trifluoroethane
Dichlorobenzene (mixed isomers)
Dichlorobromomethane
Dichlorodifluoromethane (CFC-12)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene chloride)
Dichloropentafluoropropane
Dichlorophene(2,2'-Methylenebis(4-chlorophenol)
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotrifluoroethane
Dichlorvos [Phosphoric acid, 2-dichloroethenyl dimethyl ester]
Diclofop methyl (2-[4-(2,4-Dichlorophenoxy)
phenoxylpropanoic acid, methyl ester)
Dicofol [Benzenemethanol, 4-chloro-.alpha.-4-chlorophenyl)-
.alpha.-(trichloromethyl)-]
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
Diethylphthalate
Diethylsulfate
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
1
1
' 1
1
1
1
1
1
0.1
1
1
1
0.1
1
1
1
1
0.1
1
1
1
0.1
1
1
0.1
0.1
1
0.1
0.1
1
1
1
1
0.1
1
1
0.1
1
1
1
1
1
U063
X X U069
X
X
X X U075
X X U080
X U085
U088
X U090
X P044
X X U102
X U103
U092
X j, U097
P020
X
September 15,1997
A-8
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
2164-07-0
136-45-8
138-93-2
330-54-1
2439-10-3
106-89-8
13194-48-4
140-88-5
541-41-3
759-94-4
100414
74-85-1
107-21-1
75-21-8
96-45-7
151-564
75-34-3
52-85-7
60168-88-9
13356-08-6
66441-23-4
72490-01-8
3951541-8
55-38-9
51630-58-1
14484-64-1
69806-504
2164-17-2
7782414
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
7644-8
87-68-3
118-74-1
77474
Dipotassium endothaH (7-Qxabicyclo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium salt)
Dipropyl isocinchomeronate
Disodium cyanodithioimidocarbonate
Diuron
Dodine (Dodecylguanidine monoacetate)
Epichlorohydrin
Ethoprop (Phosphorodithioic acid O-ethyl S,S-dipropyl ester)
Ethyl acrylate
Ethyl chloroformate
Ethyl dipropylthiocarbamate (EPTC)
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethyleneimine (Aziridine)
Ethylidene dichloride
Famphur
Fenarimol(.alpha-(2-CMorophenyl)-.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-DimethylO-[3-methyl4-(methylthio) phenyl]
ester, phosphorothioic acid)
Fenvalerate (4-Chloro-alpha-(l-methylethy])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-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
Fluva]inate(N-[2-Chloro4-(trifluoromethyl)phenyl]-DL-
va]ine(+)-cyano(3-phenoxyphenyl)methyl ester)
Folpet
Fomesafen(5-(2-Chloro4-(trifluoromethyl)phenoxy)-N
methy]su]fonyl)-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-l H-indene]
Hexachloro-1 ,3-butadiene
Hexachlorobenzene
Hexachlorocyclopentadiene
1
1
1
1
1
0.1
1
0.1
1
1
1
1
1
0.1
0.1
0.1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0.1
1
1
1
0.1
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
September 15,1997
A-9
-------
TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
67-72-1 Hexachloroethane
1335-87-1 Hexachloronaphthalene
70-30-4 Hexachlorophene
680-31-9 Hexamethylphosphoramide
51235-04-2 Hexazinone
67485-29-4 Hydramethylnon (Tetrahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-(trifluorDmethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-propeny]idene]hydrazone)
302-01-2 Hydrazine
10034-93-2 Hydrazine sulfate
7647-01 -0 Hydrochloric acid
74-90-8 Hydrogen cyanide
7664-39-3 Hydrogen fluoride
123-31-9 Hydroquinone
35554-44-0 Imazalil (l-[2-(2,4-Dichlorophenyl)-2-(2-propenyloxy)ethyl]-
IH-imidazole)
193-39-5 Indeno[l,2,3-cd]pyrene
13463-40-6 Iron pentacarbonyl
78-84-2 Isobutyraldehyde
465-73-6 fcodrin
25311-71-1 Isofenphos (2-t[Ethoxyl{(l-methylethyl)amino]
phosphinothioyl]oxy] benzoicacid 1-methylethyl ester)
4098-71-9 Isophorone diisocyanate
67-63-0 Isopropyl alcohol (mfg-strong acid process)
120-58-1 Isosafrole
77501-63-4 Lactofen (5-(2-Chloro-4-{trifluoromethyl)phenoxy)-2-nitro-2-
ethoxy-l-methyl-2-oxoethyl ester)
7439-92-1 Lead
58-89-9 Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-
,(l.alpha>2.alpha.,3.beta.,4.alpha.,5.alpha.,6.beta.)-]
330-55-2 Linuron
554-13-2 Lithium carbonate
108-39-4 m-Cresol
99-65-0 m-Dinitcobenzene
108-38-3 m-Xylene
121-75-5 Malathion
108-31-6 Maleic anhydride
109-77-3 Malononitrile
12427-38-2 Maneb [Carbamodithioic acid, 1,2-ethanediylbis-, manganese
complex]
7439-96-5 Manganese
93-65-2 Mecoprop
7439-97-6 Mercury
150-50-5 Merphos
126-98-7 Methacrylonitrile
137-42-8 Metham sodium (Sodium methyldithiocarbamate)
67-56-1 Methanol
20354-26-1 Methazole (2-(3,4-Dichlorophenyl)-4-methyl-l,2,4-
oxadiazolidine-3,5-dione)
2032-65-7 Methiocarb
94.74-6 Methoxone ((4-Chloro-2-methylphenoxy) acetic acid)
(MCPA)
1
1
1
0.1
1
1
0.1
0.1
1
1
1
1
1
1
1
1
1
1
1
1
1
0.1
0.1
1
1
1
1
1
1
1
1
1
1
0.1
1
1
1
1
1
1
1
0.1
X X U131
X U132
X
X
X
X X
X
X
X
X
X
X
X*
X*
X
X
X
X
X
X
X
X
X
X
U133
P063
U134
U137
P060
U141
U129
U052
U239
U147
U149
U151
U154
September 15,1997
A-10
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
3653-48-3
7243-5
96-33-3
79-22-1
78-93-3
60-344
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
900642-2
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
872-504
92442-5
759-73-9
684-93-5
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
454940-0
59-89-2
16543-55-8
100-754
142-59-6
300-76-5
91-20-3
7440-02-0
1929-824
7697-37-2
Methoxone sodium salt ((4-Chloro-2-methylphenoxy) acetate
sodium salt)
Methoxychlor [Benzene, l,l'-(2,2,2-trichloroethy]idene)bis [4-
methoxy-]
Methyl acrylate
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobntyl ketone
Methyl isocyanate
Methyl isothiocyanate (bothiocyanatomethane)
Methyl methacrylate
Methyl parathion
Methyl tert-butyl ether
Methylene bromide
Methylenebis(phenyKsocyanate) (MSI)
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)-lH-
1 ,2,4-triazole-l -propanenitrile)
N,N-Dimethy]anJ]ine
N,N-Dimethy]forinamide
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)pyjidine)
Nitric acid
0.1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0.1
1
1
1
1
0.1
1
1
0.1
1
1
1
1
0.1
0.1
0.1
0.1
0.1
0.1
1
0.1
0.1
0.1
0.1
1
1
1
0.1
1
1
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
U247
U156
U159
P068
U138
U161
P064
U162
P071
U068
U031
U176
U177
U172
Ulll
U174
P082
P084
U179
U165
September 15,1997
A-ll
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
139-13-9
98-95-3
1836-75-5
51-75-2
55-63-0
27314-13-2
90-04-0
134-29-2
95-48-7
528-29-0
95-53-4
636-21-5
9547-6
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
10642-3
123-63-7
191042-5
56-38-2
1114-71-2
4048742-1
76-01-7
87-86-5
57-33-0
79-21-0
59442-3
52645-53-1
85-01-8
108-95-2
Nitrilotriacetic acid
Nitrobenzene
Nitrofen [Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
Nitrogen mustard [2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
Norflurazon(4'-Chloro-5-(methylamino)-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-(Dipropylamino)-3,5-dinitrobenzenesulfonamide)
Osmium tetroxide
Oxydemeton methyl (S-(2-(Ethylsulfinyl)ethyl) O,O-dimethyl
ester phosphorothioic acid)
Oxydiazon(3-[2,4-Dichloro-5-(l-methylethoxy)phenyl]-5-
(l,l-dimethylethyl)-l,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<1 -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
0.1
1
0.1
0.1
1
1
0.1
0.1
1
1
0.1
0.1
1
1
1
1
1
1
1
1
1
0.1
0.1
1
0.1
1
1
1
1
1
1
1
1
1
1
1
1
0.1
1
1
1
1
1
1
X X U169
X
X P081
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
September 15,1997
A-12
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
26002-80-2
57-41-0
75^4-5
7803-51-2
7664-38-2
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
114-26-1
115-07-1
75-56-9
75-55-8
110-86-1
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
Phenothrin(2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester)
Phenytoin
Phosgene
Phosphine
Phosphoric acid
Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl (O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O,O-dimethyl phosphorothioate)
Polychlorinated biphenyls (PCBs)
Polymeric diphenylmethane diisocyanate
Potassium bromate
Potassium dimethyldithiocarbamate
Potassium N-methyldithiocarbamate
Profenofos(O-(4-Bromo-2-chlorophenyl)-O-ethyl-S-
propylphosphorothioate)
Prometryn(N)N1-Bis(l-methylethyl)-6-methylthio-l,3,5-
triazine-2,4-diamine)
Pronamide
Propachlor (2-Chloro-N-(l -methylethyl)-N-pheny]acetamide)
Propane sultone
Propanil(N-(3,4-Dichlorophenyl)propanamide)
Propargite
Propargyl alcohol
Propetamphos (3-
[(Ethylamino)methoxyphosphinothioyl]oxy]-2-butenoicacid,
1-methylethyl ester)
Propiconazole(l-[2-(2,4-Dichlorophenyl)-4-propyl-l,3-
dioxo]an-2-yl]-methyl-lH-l,2,4,-tria/ole)
Propionaldehyde
Propoxur [Phenol, 2-(l-methylethoxy)-, methylcarbamate]
Propylene (Propene)
Propylene oxide
Propyleneimine
Pyridine
Quinoline
Quinone
Quintozene (Pentachloronitrobenzene)
Quizalofop-ethyl (2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid ethyl ester)
Resmethrin ([5^(Pheny]methyl)-3-furanyl]methyl 2,2-
dimethyl-3-(2-methyl-l-propenyl)cyclopropanecarboxylate])
S,S,S-Tributyltrithiophosphate (DBF)
Saccharin (manufacturing)
Safrole
sec-Butyl alcohol
Selenium
1
0.1
1
1
1
1
1
1
1
1
1
0.1
1
0.1
1
1
1
1
1
1
0.1
1
1
1
1
1
1
1
1
0.1 ,
0.1
1
1
1
1
1
1
1
0.1
0.1
1
1
X P095
X P096
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
X X U203
X X
September 15,1997
A-13
-------
TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
74051-80-2
7440-22-4
122-34-9
26628-22-8
1982-69-0
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
Sethoxydim (2-[l-(Ethoxyimino) butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-cyclohexen-l-one)
Silver
Simazine
Sodium azide
Sodium dicamba (3,6-Dichloro-2-methoxybenzoic acid,
sodium salt)
Sodium dimethyldithiocarbamate
Sodium fluoroacetate
Sodium nitrite
Sodium o-phenylphenoxide
Sodium pentachloiophenate
Styrene
Styrene oxide
Sulfuric acid
Sulfuryl fluoride (Vikane)
Sulprofos (O-EthylO-[4-
(methylthio)phenyl]phosphorodithioic acid S-propyl ester)
Tebuthiuron (N-[5H[1 ,1 -Dimethylethyl)-! ,3,4-thiadiazol-2-yl)-
N,N'-dimethylurea)
Temephos
Terbacil (5-Chloro-3-(l,l-dimethylethyl)-6-methyl- 2,4
(lH,3H)-pyrimidinedione)
tert-Butyl alcohol
Tetrachloroethylene (Perchloroethylene)
Tetrachlorvinphos [Phosphoric acid, 2-chloro-l -(2,3,5-
trichlorophenyl) ethenyl dimethyl ester]
Tetracydine hydrochloride
Tetramethrin (2,2-Dimethyl-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)-lH-benzimidazole)
Thioacetamide
Thiobencarb (Carbamic acid, diethylthio-, S-(p-chlorobenzyl))
Thiodicarb
Thiophanate-methyl
Thiophanate ethyl ([1,2-Phenylenebis (iminocarbonothioyl)]
biscarbamic acid diethyl ester)
Thiosernicarbazide
Thiourea
Thiram
Thorium dioxide
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Tolnene-2,6-diisocyanate
Toluene diisocyanate (mixed isomers)
Toxaphene
trans-l,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)
1
1
1
1
1
1
1
1
0.1
1
0.1
0.1
1
1
1
1
1
1
1
0.1
1
1
1
1
1
0.1
1
1
1
1
1
0.1
1
1
1
1
0.1
0.1
0.1
0.1
0.1
1
1
X X
P105
X
X P058
X X
X X
X U218
X X
X X
X PI 16
X U219
X U244
X X U220
X U223
X X P123
X
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
2303-17-5
68-76-8
101200-48-0
1983-10-4
2155-70-6
52-68-6
76-02-8
79-01-6
75-69-4
57213-69-1
121-44-8
1582-09-8
26644^6-2
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
7440-66-6
12122-67-7
TriaBate
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)^nethylamino)carbonyl)amino)sulfonyl)-, methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
Trichlorfon [Phosphonic acid, (2,2,2-trichloro-l-
hydroxyethyl)-,dimethyl ester]
Trichloroacetyl chloride
Tricnloroethylene
Trichlorofluoromethane (CFC-1 1)
Triclopyr triethylammonium salt
Triethylamine
Trifluralin [Benezeneamine, 2,6-dinitro-N,N-dipropyl-4-
(trifluoromethyl)-]
Triforine (N,N'-[1 ,4-Piperazinediylbis(2,2,2-
trichloroethylidene)] bisformamide)
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2,3-dibromopropyl) phosphate
Trypan blue
Urethane (Ethyl carbamate)
Vanadium (fume or dust)
Vinclozolin(3-(3,5-Dichlorophenyl)-5-ethenyl-5-methyl-2,4-
oxazolidinedione)
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
Xylene (mixed isomers)
Zinc (fume or dust)
Zineb [Carbamodithioic acid, 1,2-ethanediylbis-, zinc
complex]
1
1
1
1
1
1
1
0.1
1
1
1
1
1
1
1
0.1
0.1
0.1
1
1
0.1
0.1
0.1
1
1
1
1
X X
X X U228
X X U121
X
X X U235
X U236
X U238
X
X X U043
X X U078
X U239
X
as mixed isomers (sum)
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
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 (ie., 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 in which case the 0.1
percent de minimis concentration applies. The de minimis concentration for each category
is provided in parentheses.
Chemical Categories
Antimony Compounds (1.0)
Includes any unique chemical substance that contains antimony as part of that
chemical's infrastructure.
Arsenic Compounds (inorganic compounds: 0.1; organic compounds: 1.0)
Includes any unique chemical substance that contains arsenic as part of that
chemical's infrastructure.
Barium Compounds (1.0)
Includes any unique chemical substance that contains barium as part 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 part of that
chemical's infrastructure.
Cadmium Compounds (0.1)
Includes any unique chemical substance that contains cadmium as part of that
chemical's infrastructure.
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TRI FORM R GUIDANCE DOCUMENT
Chlorophenols(O.l)
PETROLEUM BULK STORAGE FACILITIES
Where x = 1 to 5
Chromium Compounds (chromium VI compounds: 0.1; chromium III compounds: 1.0)
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 part 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 l,3-Bis(methylisocyanate)cyclohexane
10347-54-3 l,4-Bis(methylisocyanate)cyclohexane
2556-36-7 1,4-Cyclohexane diisocyanate
134190-37-7 Diethyldiisocyanatobenzene
4128-73-8 4,4-Diisocyanatodiphenyl ether
75790-87-3 2,4'-Diisocyanatodiphenyl sulfide
91-93-0 3,3'-Dimethoxybenzidine-4,4'-diisocyanate
91-97-4 3,3'-Dimethyl-4,4'-diphenylene diisocyanate
139-25-3 3,3'-Dimethyldiphenylmethane-4,4'-diisocyanate
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
822-06-0 Hexamethylene- 1 ,6-diisocyanate
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
15646-96-5 2,4,4-Trimethylhexamethylene diisocyanate
Ethylenebisdithiocarbamic 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 part 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
OR1 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 part 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 part of that
chemical's infrastructure.
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
Nickel Compounds (0.1)
Includes any unique chemical substance that contains nickel as part of that
chemical's infrastructure.
Nicotine and salts (1.0)
Includes any unique chemical substance that contains nicotine or a nicotine salt as
part of that chemical's infrastructure.
Nitrate compounds (water dissociable; reportable only when in aqueous solution) (1.0)
Polybrominated Biphenyls (PBBs) (0.1)
(10-x)
Where x = 1 to 10
Polychlorinated alkanes (CIO to CIS) (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 C13H16C112.
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
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
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(aj)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
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 part of that
chemical's infrastructure.
Silver Compounds (1.0)
Includes any unique chemical substance that contains silver part of that chemical's
infrastructure.
Strychnine and salts (1.0)
Includes any unique chemical substance that contains strychnine or a strychnine salt
as part of that chemical's infrastructure.
Thallium Compounds (1.0)
Includes any unique chemical substance that contains thallium as part 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 part of that chemical's
infrastructure.
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
APPENDIX B
BIBLIOGRAPHY
Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition.Volume 12. "Fuel
Resources." John Wiley & Sons, Inc. New York, NY. 1994.
Science Applications International Corporation. SIC Code Profile 50 and 51: Wholesale
Trade-Durable and Nondurable Goods. April, 1997.
U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Protocol for Equipment Leak Emission Estimates. EPA-453/R-95-017. November 1995.
Office of Management and Budget, Standard Industrial Classification Manual, 1987.
U.S. Bureau of Census. 7992 Industry and Product Classification Manual.
U.S. Environmental Protection Agency. Economic Analysis of the Final Rule to Add
Certain Industry Groups to EPCRA Section 313. April 1997.
U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Compilation of Air Pollutant Emission Factors, 5th Edition, Volume I: Stationary Point
and Area Sources (AP-42). EPA 450-AP-425ED. 1995.
U.S. Environmental Protection Agency, Office of Air Quality Pknning and Standards.
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form. EPA 560/4-88-002. December 1987.
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT PETROLEUM BULK STORAGE FACILITIES
APPENDIX C
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION
Ordering information for the foEowing documents, in addition to Toxic Chemical Release
Inventory Reporting Form R and Instructions, 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 HI List of
Lists). EPA 550-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
September 15,1997
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TRI FORM R GUIDANCE DOCUMENT
PETROLEUM BULK STORAGE FACILITIES
CHEMDAT8/WATER8
www.epa.gov/ttn/cMef/software.htrnlftwater8
Clearinghouse for Inventories and Emission Factors (CHIEF)
www.epa.gov/ttn/chief7
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.cherautah.edu/msds
SPECIATE
•' www.epa.gov/ttn/chief/software.htmlftspeciate
TANKS
www.epa.gov/ttn/chief/tanks.html
TOXNET
www.nlranih.gov/pubs/factsheets/toxnetfs.html
TRI homepage
www.epa.gov/opptintr/tri
September 15, 1997
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