United States
Environmental Protection
Agency
Office of Pollution October 1997
Prevention and Toxics EPA 745-B-97-016
Washington, DC 20460
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
GUIDANCE FOR ELECTRICITY GENERATING FACILITIES
(Version 1.0)
CONTENTS
Section 1. Introduction.
Section 2. Section 313 Reporting Requirements
Section 3. Making Threshold Determinations
Section 4. Overall Section 313 Release Estimation.
Section 5. Calculating Release Estimations At Electricity Generating
Facilities
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SECTION 313 EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT
GUIDANCE FOR ELECTRICITY GENERATING FACILITIES
Version 1.0
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TABLE OF CONTENTS
SECTION 1
INTRODUCTION 1-1
SECTION 2
SECTION 313 REPORTING REQUIREMENTS 2-1
WHO MUST REPORT? 2-1
Reduced Reporting 2-2
What is aFacffity? 2-2
How to Determine Your SIC Code 2-3
How to Determine Your Number of Employees 2-4
CHEMICAL ACTIVITY THRESHOLDS 2-4
Manufacture 2-5
Process 2-6
Otherwise use 2-7
EXEMPTIONS 2-11
SUPPLIER NOTIFICATION REQUIREMENTS 2-14
LISTED SECTION 313 CHEMICALS 2-15
WHAT MUST BE REPORTED? 2-17
DOCUMENTING REPORTING EFFORTS 2-18
SECTION 3
MAKING THE THRESHOLD DETERMINATION 3-1
CONDUCTING THE THRESHOLD DETERMINATION 3-3
SECTION 4
OVERVIEW OF SECTION 313 RELEASE ESTIMATION 4-1
GENERAL CONCEPTS 4-1
Release Estimation 4-1
Reasonable Estimates: Significant Figures and Use of Range Codes 4-4
"NA" versus "0" 4-5
REPORTING RELEASES INFORM R, PART H 4-5
Fugitive or Non-Point Emissions 4-6
Stack or Point-Source Air Emissions (Part n, Section 5.2 of Form R) 4-8
Wastewater Discharges 4-8
Underground Injection On-Site 4-10
Release to Land On-Site 4-10
Transfers in Wastes to Other Off-site Locations 4-11
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On-site Waste Treatment Methods and Efficiency 4-12
On-site Energy Recovery Processes 4-13
On-site Recycling Processes 4-13
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 4-15
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 ESTIMATION AT ELECTRICITY GENERATING
FACILITIES 5-1
Fuel Storage and Preparation 5-3
Coal 5-3
Oil 5-4
Water Treatment 5-5
Boiler Water Treatment 5-5
Cooling Water Treatment 5-7
Combustion Waste 5-9
Fly Ash, Bottom Ash, and Boiler Slag 5-9
Air Emissions • • • • 5-12
Hue Gas Desulfurization 5-18
Plant Maintenance 5-20
Boiler Cleaning 5-20
Other Plant Maintenance 5-22
APPENDIX A A-l
APPENDIX B
BIBLIOGRAPHY B-l
APPENDIX C
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION C-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 at Coal and
Oil-fired Electricity Generating Facilities 3-1
Table 3-2 Total Constituent Concentrations of Section 313 Chemicals in Coal 3-10
Table 3-3 Chemical Concentrations of Select Section 313 Metal Compound Constituents of Coal
and Tons of Coal Needed to Manufacture 25,000 Lbs. of the Metal Compound .3-11
Table 3-4 Concentrations of Section 313 Constituents and their Compounds Found In No. 6 Fuel
Oil and Tons of Oil Needed To Manufacture 25,000 Lbs. of the Chemical 3-12
Table 3-5 Emission Factors For Hydrochloric Acid and Hydrogen Fluoride Manufactured During
Coal Combustion 3-13
Table 3-6 Emission Factor and Triggering Thresholds For Formaldehyde Manufactured During
Combustion of Coal and No. 6 Fuel Oil 3-14
Table 4-1. SOCME Average Emission Factors 4-7
Table 5-1 Total Constituent Concentrations of Elements in Coal Combustion Residuals 5-9
Table 5-2 Section 313 Metal Emission Factors for Fuel Combustion 5-17
Table 5-3 Emission Factors for Various Organic Compounds from Controlled Coal
Combustion 5-17
Table 5-4 Concentrations of Certain Trace Metals in FGD Sludge Solids and Liquors 5-19
LIST OF FIGURES
Figure 5-1 Process for Generating Electricity at Electricity Generating Facilities 5-2
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SECTION 1
INTRODUCTION
This guidance document has been prepared to assist coal and oil-fired electricity generating
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 DI 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 toxic chemicals in their communities and on
releases and other waste management activities of toxic 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 electricity generating facilities (Standard Industrial
Classification (SIC) codes 4911, 4931 and 4939 (limited to facilities that combust coal and/or oil
for the purpose of generating electricity for distribution in commerce) are now required to
evaluate their chemical use and management activities to determine potential reporting
responsibilities under EPCRA Section 313. Combustion of coal or oil for on-site support
purposes (such as heating the facility), for testing or operation of emergency backup power
systems (meaning systems designed to supply power to the facility itself in the event of an
emergency), or for start-up purposes (i.e., to heat the boiler to an operational temperature prior to
switching to the primary fuel) will not subject facilities to the EPCRA Section 313 reporting
requirements, provided such combustion of coal or oil does not itself generate power for
distribution in commerce.
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:
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• 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,
• The facility must have 10 or more full-time employees (or the total hours worked by all
employees is greater than 20,000 hours), and
• The facility manufactures (defined to include importing), processes, or otherwise uses any
Section 313 chemical in quantities greater than the established threshold in the course of a
calendar year.
For each Section 313 chemical or chemical category, covered facilities must report the total
annual releases, both routine and accidental, to all environmental media; and other on-site waste
management activities, including quantities recycled, combusted for energy recovery and treated
for destruction, and off-site transfers for disposal, waste treatment, energy recovery and recycling.
This information is submitted on the Toxic Chemical Release Inventory (TRI) Reporting Form,
which is called the "Form R." (As discussed in the following chapter, facilities meeting certain
conditions are eligible to report using an abbreviated Form A.)
The annual Form R or Form A reports are submitted to EPA headquarters and to a state
designated agency, usually a State Emergency Response Commission (SERC) 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.
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Facility owners or operators who viblate 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 determin4tions regarding the manufacture, processing, and otherwise
use of Section 313 chemicals. Sect Jon 4 covers general concepts relating to reporting and release
estimating, and provides potential dkta sources for determining releases at coal and oil-fired
electricity generating facilities and cither amounts managed. Section 5 presents a detailed
discussion of EPCRA Section 3131 jslease and other waste management scenarios in the coal and
oil-fired electricity generating industry and covers developing estimates of releases and other
waste management activities for several types of operations commonly encountered by the coal
and oil-fired electricity generating iiidustry. 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 bibliography; of relevant EPA documents used to help electricity
generating facilities in complying w^th EPCRA Section 313. Appendix C provides relevant online
information sources.
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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 n Form and includes a description of any
type of hazard the material may pose, the quantities stored, general storage locations, and
type of storage. The reports for each calendar year are due on or before March 1 of the
following year. Most states require or request that facilities submit the more detailed Tier
II reporting form or a state-issued version of that form. In addition, some states have
established lower activity thresholds and require more detailed or additional information.
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EPCRA
Section
Reporting Requirements
Section
313: Toxic
Chemical
Release
Inventory
Reporting
(FormR)
(40CFR
§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 aM 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 faculties 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
modem via the Internet or the National Library of Medicine's TOXNET on-line
system.
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SECTION 2
SECTION 313 REPORTING REQUIREMENTS
WHO MUST REPORT?
A facility is subject to the provisions of the Section 313 reporting requirements if it meets all three
of the following criteria:
The facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except 1241),
or 20-39 (manufacturing facilities), or 4911 (limited to facilities that combust coal and/or
oil for the purpose of generating power for distribution in commerce), 4931 (limited to
facilities that combust coal and/or oil for the purpose of generating power for distribution
in commerce) and 4939 (limited to facilities that combust coal and/or oil for the purpose
of generating power for distribution in commerce), or 4953 (limited to facilities regulated
under RCRA subtitle C), or 5169, or 5171, or 7389 (limited to facilities primarily
engaged in solvent recovery services on a contract or fee basis) hereafter "covered SIC
codes";_and,
• Facility must have 10 or more full-time employees (or the total hours worked by all
employees is greater than 20,000 hours), and
• The facility manufactures (defined to include importation), or processes, or otherwise uses
any Section 313 chemical in quantities greater than the established threshold in the course
of a calendar year.
Instructions regarding how to determine the facility SIC code, employee threshold, or activity
follows; for additional detail please consult the Toxic Chemical Release Inventory Reporting
Form R and Instructions, a document published annually by EPA.
In addition, pursuant to Executive Order (EO) 12856 signed by the President on August 3,1993,
Federal facilities are required to determine the applicability of the EPCRA Section 313 reporting
requirements regardless of the facility's SIC codes. Federal facilities that have 10 or more full
time employees or the equivalent and manufacture, process, or otherwise use listed Section 313
chemicals at or above established thresholds are subject to EPCRA Section 313 reporting.
Federal facilities were required to begin reporting no kter than reporting year 1994; their first
Form R or Form A reports were due by July 1,1995.
The amount of the chemical released to the environment does not affect the need to report. Even
if there are no releases of a listed Section 313 chemical, a facility must report if it meets the
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requirements regarding SIC code, number of employees, and activity threshold. A threshold
determination must be made individually for each Section 313 chemical.
Thresholds are based on operation year, this includes partial year reporting and reporting by a
facility that is going through closure. The facilities should consider the portion of the year for
which they operated to determine the actual employee hours worked as well as threshold
determination and release reporting.
Reduced Reporting
On November 30,1994, EPA published a final rule (59 FR 61488) that provides an alternative
reporting option to qualifying facilities. Eligible facilities wishing to take advantage of this
alternative reporting option may report on a simplified two page form referred to as Form A and
do not have to use FormR. 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 H, Section 8 of FormR.
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
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business is conducted or where services or industrial operations are performed. A facility may
contain more than one establishment. For example, a coal/oil-fired electricity generating
establishment, a hydroelectric generating station and a co-generation plant 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.
• 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.
Please note: The North American Industrial Classification System that appeared in the Federal Register on
April 9,1997 will replace the 1987 Standard Industrial Classification System (SIC). Regulatory entities, including
EPA, will take steps to adopt the new classification system over the next few years. In the meantime, facilities should
consider their activities in relation to the 1987 SIC code system.
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• 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.
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
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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 coal mining is irrelevant. Listed EPCRA
Section 313 chemicals coincidentally manufactured by a facility must be factored into
threshold determinations and release calculations.
• Manufactured Activities and Definitions
• Produced or imported for on-site use/processing
A chemical that is produced or imported and then further processed or
otherwise used at the same facility.
• Produced or imported for sale/distribution
A chemical that is produced or imported specifically for sale or distribution outside
the facility.
• Produced as a by-product
A chemical that is produced coincidentally during the production,
processing, otherwise use, or disposal of another chemical substance
or mixture and, following its production, is separated from that other
chemical substance or mixture. Section 313 chemicals produced and
released as a result of waste treatment for disposal are also
considered byproducts.
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• 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.
• 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.
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• 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
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other types of treatment 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/lb.,
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 BTU/lb. 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
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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).
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 the electricity generating industry, the Agency believes electricity
generating activities routinely involve or result in the manufacturing, processing, or otherwise use
of EPCRA Section 313 chemicals (62 FR 23834, May 1,1997). The term manufacture includes
the coincidental manufacture of a chemical, such as a byproduct or impurity, from the
manufacturing, processing, otherwise use or waste management of another chemical substance or
mixture. Thresholds must be calculated separately for manufacture, process, or otherwise use of
the same chemical. If any single threshold is exceeded for a listed Section 313 chemical, the
facility must submit a Form R covering all nonexempt activities. Facilities generating electricity
via the combustion of coal or oil 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 tank or boiler cleaning, non-motor vehicle equipment maintenance, and purification.
Chemicals involved in these support activities are classified under the otherwise use category.
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EXEMPTIONS
Section 313 provides for exemptions from reporting for specific "processing" or "otherwise use"
activities. The instructions provided in Toxic Chemical Release Inventory Reporting Form R
and Instructions should be reviewed carefully before proceeding. The following discussion
summarizes the exemption instructions. A facility does not have to consider amounts of listed
Section 313 chemicals involved in any of these processing or otherwise use activities when
determining if activity thresholds have been exceeded or when estimating environmental releases.
Limited exemptions apply to manufacturing activities. For example, manufacturing a Section
313 chemical for research and development purposes and manufacturing as an impurity below
a specified level in a product distributed beyond the facility both can be exempt. The EPA's
Toxic Chemical Release Inventory Questions and Answers, Revised 1990 Version [EPA
560/4/91-003 (will be revised in near future)] and the Toxic Release Inventory Reporting Form
R and Instructions also contain information about these exemptions. (See Appendix B for
ordering information.)
• The de minimis exemption allows facilities to disregard certain minimal concentrations of
chemicals in mixtures or trade name products they "process" or "otherwise use" in making
threshold determinations and release and other waste management determinations. 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
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the Section 313 chemical in that stream are exempt from EPCRA section 313 reporting. It is
possible to meet an activity (e.g., processing) threshold for a Section 313 chemical on a
facility-wide basis, but not be required to calculate releases or other waste management
quantities associated with a particular process because that process involves only mixtures or
trade name products containing the Section 313 chemical below the de minimis level.
Once a Section 313 chemical concentration is above the appropriate de minimis
concentration, threshold determinations and release and other waste management
determinations must be made, even if the chemical later falls below de minimis level in the
same process stream. Thus, all releases and other quantities managed as waste which occur
after the de minimis level has been exceeded are then subject to reporting. If a Section 313
chemical in a mixture or trade name product above de minimis is brought on-site, the de
minimis exemption never applies.
The de minimis concentration level is consistent with the OSHA Hazard Communication
Standard requirements for development of Material Safety Data Sheets (MSDSs). The de
minimis level is 1.0 percent except if the Section 313 chemical is an OSHA-defined
carcinogen. The de minimis level for OSHA-defined carcinogens is 0.1 percent. For mixtures
or other trade name products that contain one or more members of a listed Section 313
chemical category, the de minimis level applies to the aggregate concentration of all such
members and not to each individually. The list of Section 313 chemicals in the publication
Toxic Chemical Release Inventory Reporting Form R and Instructions for the current
reporting year contains the de minimis values for each of the Section 313 chemicals and
chemical categories.
Materials that are processed or used as articles - Quantities of a listed Section 313
chemical contained in an article do not have to be factored into threshold or release
determinations when that article is processed or otherwise used at your facility. An article is
defined as a manufactured item that is formed to a specific shape or design during
manufacture, that has end-use functions dependent in whole or in part upon its shape or
design during end-use, and that does not release a Section 313 chemical under the normal
conditions of the processing or use of that item at the facility.
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.
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The article exemption applies to the normal processing or otherwise use of an article. It does
not apply to the manufacture of an article. Thus, Section 313 chemicals processed into
articles manufactured at a facility must be factored into threshold and release determinations.
A closed item containing Section 313 chemicals (e.g., a transformer containing PCBs) that
does not release the Section 313 chemicals during normal use is considered an article if a
facility uses the item as intended and the Section 313 chemicals are not released. If a
facility services the closed item (e.g., a transformer) by replacing the Section 313
chemicals, the Section 313 chemicals added during the reporting year must counted in
threshold determinations.
Materials that are structural components of the facility - Chemicals present in materials
used to construct, repair, or maintain a plant building are exempt from the activity thresholds.
For example, solvents and pigments present in paint used to coat the structural components of
a building would be exempt from threshold determinations.
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
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applies only to sampling and analysis, research and development, and quality assurance and
quality control activities. The exemption does not apply to the use or production of listed
Section 313 chemicals in pilot-plant operations and laboratories for distribution in commerce
(e.g., specialty chemicals) and laboratory support services.
• Materials as they are drawn from the environment or municipal sources - Chemicals
contained in intake water (used for processing or non-contact cooling) or in intake air (used
either as compressed air or for combustion) are exempt from the activity thresholds.
• Property owners - Property owners that merely own real estate on which a facility covered
by Section 313 is located and have no business interest in the operation of that facility (e.g., a
company owns an industrial park) are exempt for Section 313 reporting. The operator of that
facility, however, is subject to reporting requirements.
SUPPLIER NOTIFICATION REQUIREMENTS
Because manufacturers reporting under Section 313 must know the Section 313 chemical
composition of the products they use to be able to accurately calculate releases, EPA requires
some suppliers of mixtures or trade name products containing one or more of the listed Section
313 chemicals to notify their customers of the identity of the chemical in the mixture or the trade
name product. This requirement has been in effect since January 1,1989.
A facility must comply with the Section 313 supplier notification requirements if it owns or
operates a facility which meets all of the following criteria.
• The facility is in SIC codes 20-39,
• The facility manufactures, imports, or processes a Section 313 chemical, and
• 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).
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The supplier notification requirements do not apply to TRI chemicals that are themselves
wastestreams or are constituents of wastestreams.
LISTED SECTION 313 CHEMICALS
Appendix A to this document contains an alphabetical listing of the chemicals subject to
Section 313 reporting at the time of publication of this document, including their de minimis
concentrations. EPA publications Common Synonyms for Section 313 Chemicals (EPA
745-R-95-008) and Consolidated List of Chemicals Subject to Reporting Under the Act (Title III
List of Lists) (EPA-550-B-96-015) may also be useful references when reviewing the chemicals at
your facility for Section 313 coverage.
The list of Section 313 chemicals is amended frequently. Users of this guidance document or
other documents listing Section 313 chemicals are cautioned that changes may have occurred to
the list of Section 313 chemicals since publication of the original list or addition of the chemical
through administrative action. The list of Section 3.13 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,
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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).
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
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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.
• 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;
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• Off-site locations to which you shipped wastes containing the chemical and the quantities of
the chemical sent to those locations;
• Information on source reduction activities; and
• Treatment methods used for wastes containing the chemical and estimates of their efficiency
for the reportable Section 313 chemical.
A release is defined under EPCRA Section 329(8) as any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the
environment of any listed Section 313 chemical. The definition of release includes the
abandonment or discarding of barrels, containers, and other closed receptacles. Separate release
estimates must be provided for releases to air, water, and land (e.g., deep well injection, surface
impoundment, permitted landfill).
DOCUMENTING REPORTING EFFORTS
Sound recordkeeping practices are essential for accurate and efficient TRI reporting. EPA
requires that facilities keep a copy of each Form R or Form A report filed for at least three years
from the date of submission (40 CFR §372.10). These reports will also be of use to facilities
in subsequent years when completing future Form R or Form A reports. EPA also requires
that facilities maintain those documents, calculations, worksheets, and other forms upon which
they relied to file Form R or Form A reports. EPA may request this supporting documentation
from the facility, for example, to conduct data quality reviews of present or past Form R or Form
A submissions.
Supporting documentation, organized by year, that a facility should maintain may include, if
applicable:
• Previous years' Forms Rs and Form As;
• Section 313 Reporting Threshold Worksheets (a sample worksheet is given in the Toxic
Chemical Release Inventory Reporting Form R and Instructions document;
• Engineering calculations and other notes;
• Purchase records from suppliers;
• Inventory data;
• EPA (NPDES) permits and monitoring reports;
• EPCRA Section 312, Tier H Reports;
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• Monitoring records;
• Flowmeter data;
• RCRA Hazardous Waste Generator's Report;
• Pretreatment reports filed by the facility with the local government;
• Invoices from waste management companies;
• Manufacturer's estimates of treatment efficiencies;
• RCRA Manifests; and
• Process diagrams.
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SECTION 3
MAKING THE THRESHOLD DETERMINATION
A separate Toxic Chemical Release Inventory Reporting Form must be submitted for each listed
chemical that is "manufactured," "processed," or "otherwise used" above an activity threshold at
your facility, assuming the SIC code and employee criteria are met. See Table 3-1 for illustrative
examples of these threshold activities.
Table 3-1 Examples of Manufactured, Processed, and Otherwise Used Chemicals at Coal
and Oil-fired Electricity Generating Facilities *
The coincidental manufacturing of EPCRA Section 313 reportable chemicals that directly result
from the combustion of coal and oil are subject to the manufacturing activity threshold. All
chemicals that are manufactured during the combustion process are byproducts separate from
the product (power generation). Because the de minimis exemption does not apply to a Section
313 chemical manufactured at the facility as a byproduct that does not remain in the primary
product distributed by the facility, metal compounds which were manufactured during
combustion are not subject to the de minimis exemption. The entire weight of a metal
compound manufactured during combustion must be applied toward the 25,000 pound
threshold, not just the weight of the parent metal.
During combustion, if an elemental metal is converted to a metal compound; if a metal
compound is converted to an elemental metal; or if one metal compound is converted to
another metal compound (even if it is within the same Section 313 metal compound category);
then manufacturing has occurred. The quantity of the Section 313 metal or metal compound
manufactured must be counted towards the 25,000 pound threshold. The question is not
whether a metal's valence state has changed, but whether a new metal or metal compound was
created. In these circumstances, the de minimis exemption does not apply because a Section
313 chemical was manufactured as a byproduct of the combustion process. There may be cases
in which a metal compound is not changed at all during combustion. For example, if beryllium
oxide in coal remains as beryllium oxide after combustion, a metal compound has not been
manufactured. In this example, the de minimis exemption could be used, because the Section
313 chemical was otherwise used.
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', <&*&$ty/''i^/'^'' -i
Produced or imported for on-site
use/processing
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
i>- v^ ^ffj|fe>, ^v****
'- '- -, '"f,'"^* ™r: '^"'mmm&m ;, . *LvV -- * ' '"''- "'-.: I
Maintenance chemicals, coal or limestone containing
Section 313 chemicals imported into the customs territory
of the United States.
May not occur in the electricity generating industry.
Hydrogen fluoride or hydrochloric acid or sulfuric acid
aerosol emissions in the stream leaving the boiler and in the
stack gas during the combustion of feed coal.
The coincidental manufacturing of metal compounds
during the combustion of coal and oil, such as, oxides of
copper and manganese.
May not occur in the electricity generating industry.
i^Mv*SPw^*#5^Ji™*^w&-™«*RSS^ •, - •. r&»,}z!,f,..!?. ITJ.^».%*^,':. .
The recovery of a listed Section 313 chemical from a mixture for further distribution in
commerce is processing of that chemical Solvent recovery, metal recovery, and other
reclamation of Section 313 chemicals manufactured as a byproduct or otherwise used by the
facility (e.g., flue gas desulfurization byproducts used to produce gypsum), that result in a
product that is further distributed beyond the facility should be considered in your threshold
determination for processing activities.
„ M^mij ' '• >
As a reactant
As a formulation component
As an article component
Repackaging
,,LL/ """-' '" '" ^, 3&s®WBi$8&"'" ^ , ,„ ,,,,s~,*\
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
Facilities may repackage and process fly ash resulting from
combustion, for purposes of distribution in commerce.
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; ^;;4^7^:;>r";^ -*'"v-^ - "~ ~:j
When combusted for energy production, all constituents of coal and oil are subject to the
otherwise use activity threshold because the constituents are not incorporated into the product
(the energy produced) and, therefore, the de minimis exemption applies for this activity.
Hence, chemicals present in coal and oil below de minimis levels would not be subject to
reporting under the otherwise use activity.
The use of EPCRA Section 313 Section 313 chemicals in support activities such as cleaning,
maintenance, and purification constitutes otherwise use of that chemical.
The use of a Section 313 chemical to treat another chemical constitutes otherwise use.
l^'^^A^^''^'
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
'pjffip8$^&%i£*j£sf * ,f &/?ff $'•$ * •+ * •*' "> f'
•."'"',,, ' ' ,,/'"' '""/y' *$WP&9: '*"*• "",'»",,""* \
May not occur in the electricity generating industry.
Metal used to maintain power lines within the facility.
Combustion of coal or oil containing Section 313
chemicals above the de minimis level.
Ethylene glycol sprayed on coal to prevent freezing.
Thiourea used as an inhibitor in cleaning solution for
removal of scale deposits and metals from tube walls.
* More complete discussions of the industry-specific examples can be found in Section 5 of this guidance manual.
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.
The primary function of coal and oil-fired electricity generating faculties is to generate electricity
for distribution in commerce. Most activities performed by electricity generating facilities may
involve Section 313 Section 313 chemicals that are "manufactured" (such as the coincidental
manufacture of metal compounds during combustion activities), or "otherwise used" (such as the
use of chemicals for intake water treatment, neutralization of waste stream, or in equipment
cleaning). Aside from coincidental manufacturing, the combustion of coal or oil constitutes
otherwise use.
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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, N — —'
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
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 pknt 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
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"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.
A de minimis exemption applies only to
Section 313 chemicals in mixtures or trade
name products manufactured as impurities
or processed or otherwise used in mixtures
or trade name products. This exemption
does not apply to chemicals that are
manufactured as byproducts nor does it
apply to chemicals in wastes that are
processed or otherwise used.
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.
To perform a comprehensive and accurate
activity threshold analysis, the facility
should first determine what Section 313
chemicals (such as metals and metal
compounds) are present in the fuel (coal or
oil) and then identify and quantify the
metal compounds that are produced during
and after the combustion process. As to
the latter analysis, the facility need to
determine which of the chemicals are
present below de minimis, because none of
the chemicals manufactured remain in the primary product (Le. thermally generated electricity) as
impurities and therefore are not eligible for the de minimis exemption (an impurity is the residual
amount of chemical remaining in a final product for distribution in commerce). Next, the facility
should determine what other Section 313 chemicals are otherwise used, such as chemicals used in
water treatment, waste management and plant maintenance. Section 313 chemicals above de
minimis levels in coal or oil must be included in the otherwise use threshold determination.
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
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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 FormR 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 combustion process involves the coincidental manufacturing of Section 313 reportable
chemicals (metals, metal compounds, and formaldehyde), usually as a result of oxidation.
Electricity generating facilities should closely examine what metals and metal compounds are
manufactured during combustion.
The elemental metals aluminum, vanadium, and zinc (with the qualifier "fume or dust") are
considered manufactured when they are converted from a non-fume or non-dust form to a fume
or dust form. This may occur during the combustion of fuel. Notice that this qualifier of fume or
dust applies only to the elemental form of aluminum, vanadium, and zinc.
If the Section 313 chemicals were manufactured as a result of the combustion process, determine
if the 25,000 pounds threshold for "manufacturing" activities is met. For threshold determinations
for Section 313 metal compound categories, the entire weight of the metal compound must be
applied towards the threshold, not just the weight of the metal itself. However, only the quantity
of the parent metal released or otherwise managed is reported.
Finally, some waste treatment activities will involve the conversion or reaction of chemicals to
produce a new Section 313 chemical, such as occurs with chemical oxidation or chemical
precipitation.
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:
STEP FOUR
Gather data needed for calculations of
threshold determination, including:
• Inventory Data
• Consumption Information
• Supplier Notification
• Ore Sampling and Analysis Data
MSDS
• Analysis of Waste Products
• Permits
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• If the exact concentration is known (e.g., 33.0% toluene), use it.
• If only the upper bound is known (e.g., <5% toluene), use it (e.g., 5% toluene).
• If only the concentration range is known (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=110% 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 determining threshold quantities and
release and other waste management
quantities of Section 313 reportable metals
and metal compounds coincidentally
manufactured from the combustion of coal
and oil or from treatment to remove
sulfates and ash-forming materials, it is not
necessary to measure the change in
valence state of the metals. These
determinations can be performed by either
estimating or measuring the metal
compounds that are created after the
combustion process. Calculations are to v
be based on readily available data. These
data may include monitoring data collected pursuant to other laws and regulations, and, if no such
data exist, then calculations should be based on reasonable estimates. Data on what occurs to
metal constituents in coal during the combustion process suggest that most, if not all metals, are
present as some form of metal compound that does not usually survive combustion. Therefore, if
no data are available which identify specific metal compounds being produced, a facility may
assume that the metals in the coal are converted to the lowest weight metal oxide possible. This
engineering assumption can be used in determining the threshold quantities of all metals in coal or
STEP FIVE
Calculate the quantity of each chemical
manufactured, processed and otherwise
used, in pounds, to determine whether the
activity threshold has been exceeded. The
Form R must be completed for each
chemical otherwise used in excess of 10,000
pounds and for each chemical processed in
excess of 25,000 pounds, for each chemical
manufactured in excess of 25,000 pounds.
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fuel oil. It is unlikely that using this estimation method would cause any facility that is not
exceeding thresholds to report because at least some, if not many, of the metal compounds
manufactured as a result of combustion will be heavier than the lowest weight metal oxide.
The best available information should be used to estimate the approximate concentration of the
chemical in the coal or fuel oil If you have data regarding chemical concentrations in the coal or
fuel oil, use the data. If specific concentration data of Section 313 chemicals in coal or fuel oil are
not available, your facility may use the default values provided in Tables 3-2, 3-3, and 3-4. Table
3-2 lists concentrations of Section 313 metals typically found in different types of coal. Unless
the facility has information to support use of the low or mid concentration values, the facility
should calculate threshold determinations using the highest concentration values in Table 3-2,
Tables 3-3, and 3-4 list concentrations of metals and metal compounds typically found in coal and
No. 6 fuel oil, and based on these concentrations, the amount of coal or oil one needs to consume
to manufacture 25,000 pounds of the metal compound. To calculate the amount of Section 313
metal compounds manufactured during combustion using the assumption that metals will be
converted to the lowest weight metal oxide possible, facilities must know the amount of elemental
metal in the coal. The one exception to using metal oxides for determining threshold quantities
may be mercury. Data indicate that most mercury remains volatilized as elemental mercury after
combustion rather than converted to a metal compound. Therefore, the weight of the metal,
rather than that of the metal oxide, can be used in threshold determinations, and this amount then
applied towards the manufacture activity threshold for mercury.
Unlike metals that can form new compounds subject to the activity threshold for manufacturing,
chemical components of fuel oil that are burned for combustion are subject to the activity
threshold for otherwise use. Benzo(a)anthracene, a member of the polycyclic aromatic compound
chemical category, is found in No. 6 fuel oil at a concentration of 1.13 weight percent, which is
above the de minimis concentration. Thus, approximately 110,619 gallons of No. 6 fuel oil are
needed to exceed the 10,000 pound threshold for otherwise use. 1,2,4 Trimethylbenzene is found
in No. 2 fuel oil and diesel oil at a concentration of 1.0 weight percent. Thus, approximately
142,857 gallons of No. 2 Fuel Oil or Diesel Oil are needed to exceed the otherwise use threshold
for 1,2,4 Trimethylbenzene. Other organics are not expected to be present at or above de
minimis concentrations.
Combustion of coal and fuel oil may result in emissions of hydrochloric acid (HC1) in aerosol
form, hydrogen fluoride (HF), sulfuric acid, and/or formaldehyde. If aerosol forms of
hydrochloric or sulfuric acid are produced during or after combustion and are present in the flue
gas, the amount produced must be applied to the manufacturing threshold. In the absence of
better data, facilities can use the HC1 and HF emission factors presented in Table 3-5. Use the
emission factor that corresponds to the type of coal being combusted. If a facility combusts a
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mixture of coal types, and knows the mixture ratio, it may apply this ratio to the emission factors
in Table 3-5. Facilities that do not know the type of coal they use should assume the coal is
bituminous or subbituminous, since these types are commonly used. The factors in Table 3-5 are
more appropriate than AP-42 factors, which are averages of factors for each type of coal. Table
3-6 lists emission factors of formaldehyde produced during the combustion of coal and No. 6 fuel
oil, and based on these emission factors, the amount of coal or fuel oil one needs to consume to
manufacture 25,000 pounds of the chemical. In the absence of better information, the emission
factors in these tables can be used to calculate threshold determinations. For guidance on
calculating the amount of sulfuric acid manufactured during combustion, refer to: Emergency
Planning and Community Right-to-Know Act-Section 313: Guidance for Reporting Sulfuric
Acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle
size), EPA, August 1997.
An example of how to determine the quantities of Section 313 chemicals manufactured is given in
the box on the following page.
Calculating Thresholds for Hydrochloric Acid and Selenium
A facility combusts 1 million tons of subbituminous coal in the reporting year. What quantity
of selenium compounds and HC1 (aerosol) are manufactured?
Hydrochloric Acid:
The HCl emission factor for subbituminous coal is 1.9 Iblton coal (see Table 3-5).
1.9 Ib HCllton coal x 1,000,000 tons coal = 1,900,000 pounds HCl
Therefore, 1.9 million pounds of HCl are manufactured and the 25,000 pound threshold has
been exceeded. Form R reporting for HCl (aerosol) is required.
Selenium Compounds:
Based on the high-end concentration of selenium in Table 3-2, the emission factor for
selenium oxide (SeO2) is 11.2 ug/g (see Table 3-3), or 2.24 x 10'2 Ib SeO2lton coal.
2.24 x 10'2 Ib SeOJton coal x 1,000,000 tons of coal = 22,400 pounds ofSeO2 emitted.
Therefore, 22,400 pounds of selenium compounds are manufactured and the 25,000 pound
threshold was not exceeded. Form R reporting for selenium compounds is not required.
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•. f f fffff'fj'fj'f ffff f //•" •v
Tabfe 34, Tsta! Coastitttemt Cajic&mtrationS afBeelioa '313 O««nieate In Coal
Element Cw^nfertiQBS N Blfferenf Types of Coal {micr^r^ms/gr^m of ep$l)
Element
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
Lew "'
0.2
0.5
150
0
0
1.8
4
6
0.01
0.4
0.4
0.04
0
0
Mid ,„
7.1
53.25
200
3.25
305
93.4
111
93.5
0.81
52.2
4.2
0.06
640.5
2,800
High
14
106
250
6.5
610
185
218
181
1.6
104
8
0.08
1,281
5,600
Note: The mid range value is the average of low and high estimates provided in Table Vffl.2 from U.S. EPA, SIC
Code Profile 49: Electric, Gas, and Sanitary Services. Report Prepared by Science Applications International
Corporation. June 1996.
Note: The metals and concentrations in Table 3-2 are provided for elemental metal. In actuality, metals are
expected to be present in coal as metal compounds, and consequently, are expected to be at higher
concentrations than reported in the table. See Table 3-3 for these metal compound values.
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; faBle 3-3, €MiBiWc0»e«jtjtratiott!S of Select Sleetlom 313 Metal £0jnnp0un$ CoMtistoe&ts
of Coal a&d ttawMtf C&al Needed to Maiwfa^irfi&OOO Uj&T ot tTte Me6d ComptKind
Section 313
Metal/Metal
Compound (oxide)
^tTJiatMlFBe
Manuiactiirecl
Zinc/ZnO
ChromiunVCrO3
Barium/BaO2
Manganese/MnO2
Lead/PbO2
Copper/CuO
Arsenic/As2O5
Nickel/NiO
Antimony/Sb2O5
SeleniunVSeO2
BerylUum/BeO
Cadmiutn/CdO
Mercury/HgO
Cobalt/CoO
Silver/AgO
Metal
Concentration
Cmicrograms/gram)
^" l»€oal *
<
5,600
610
250
181
218
185
106
104
14
8
1.7
6.5
1.6
0.15
0.08
Metal Compound
Concentration
(mierograms/grarrt)
IfeGoal
6971
1,173
308.3
286.4
251.7
231.6
162.6
132.3
18.6
11.2
4.72
7.43
1.73
0.19
0.09
Approximate Tons
of Coal Needed To
Be Ceatsumed to
Maim&eture 25^00
L^ of the Metal
Compound
1,800
10,700
40,500
43,600
49,700
54,000
76,900
94,500
670,000
1,116,100
2,647,500
1,682,400
7,225,400
65,791,000
138,888,900
Source: Adapted from Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313,
Appendix D, Table D-2 (based on high-end concentration values) and Appendix E, Table E-3.
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Table 3-4 Concentratloiis of Section 3B Constituents at*d ftoir Coppoiwds Found lit
No. 6 Fuel OH and ?$> of tbe Metal
Compound
(assuming 8
Ifes}gall0tt dfeMfty
forNo^FwlOm
158,000
262,000
10,831,000
36,500,000
33,291,000
65,790,000
98,870,000
56,277,000
944,149,000
140,503,000
2,301,136,000
1,444,539,000
53,571,429,000
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix E,
Table E-6.
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Table 3-5 Ettrission Factors For UCI m$ HF Manufactured During Combustion of
f*ft*h? "' ""•''•••• ' ^^ ' ^ S% "" ""
* v. s-- s s •••>•> --X---V--- V-*M
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Table 3-5 Emission Factor For H€l antf HF Ma«ttfactttre
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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 section-by-section discussion of
release and waste management reporting requirements 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 required to report on that chemical.
Release estimates can be developed by combining all available data with assumptions concerning
the fate of each chemical in the process. There are four general methods for developing a release
estimate. These methods may be used together or in sequence in developing release estimates.
• Direct measurement (basis of estimate code = M; entered in Part II Sections 5 and 6) -
These are estimates based on actual monitoring of the concentration of a chemical. The
chemical's concentration in the waste stream multiplied by the flow rate or volume of the
waste stream and its density yields the mass of the chemical released. Direct measurement is
typically used to estimate releases via wastewater, solid waste, and hazardous waste, in part,
to ensure compliance with applicable environmental regulations. Although this estimation
method should yield the most accurate results, only rarely are sufficient data available for
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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. If the reportable Section 313 chemical is known
to be present, a concentration equivalent to half the detection limit should be used in
subsequent calculations of release estimate quantities (i.e., if the limit of detection is 10
mg/1, release calculations should be performed using a concentration of 5 mg/1). If the
reportable Section 313 chemical is not known to be present in the waste, then 0 percent
can be assumed.
Mass balance (basis of estimate code = C entered in Part n, 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
calculated. 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 II, Sections 5 and 6) - Release
information derived from facilities or processes similar to yours can be used to estimate
releases. Emission factors come in two forms. The first expresses releases as a ratio of the
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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
world wide web at 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 n, 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 aggre-gate release was
less than 0.5 pounds, report zero. However, if you report zero releases, a basis of estimate must
be provided. If use of the Section 313 chemical began in the reporting year, enter "NA" as the
production ratio or activity index (Part II, Section 8.9 of the Form R).
For example, if nitric acid is involved 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 n, Section 5.4.1 and 5.4.2 of Form R. Also, if the facility did
not use the Section 313 chemical in the previous year, the facility would have no basis to develop
a production ratio or activity index, "NA" would be checked in Part II, Section 8.9 of Form R.
REPORTING RELEASES IN FORM R, PART 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 management activity. After releases to air, amounts cleaned up and disposed of off-
site, amounts recycled, and amounts released to water are considered, then the amount remaining
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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
5-2,5-3, and 5-4)
• SOCMI emission factors (listed in Table 4-
1)
• 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.
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
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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Table 4-1. SOCMI AVERAGE EMISSION FACTORS*
f **
Equipment type „, ,-, - *
Valves
Pump seals*
Compressor seals
Pressure relief valves
Connectors
Open-ended lines
Sampling connections
Jteryiee* " " i
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
AH
All
AH
Emission fact&r&ai)|^|fcr/ssoKreB):::
0.0131
0.00887
0.00051
0.0438
0.0190
0.502
0.229
0.00403
0.0037
0.033
*Protocolfor Equipment Leak Emission Estimates (EPA, EPA-453/R-95-017)
a These factors are for total organic compound emissions.
b The light liquid pump seal factor can be used to estimate the leak rate from agitator seals.
c "Gas" is material in a gaseous state at operating conditions, "Light liquid" is material in a liquid state in which the sum of the
concentration of individual constituents with a vapor pressure over 0.3 kilopascals (kPa) at 20 ° C is greater than or equal to 20 weight
percent, and "Heavy liquid" is material that is not defined as a gas or light liquid.
Example Fugitive Emission Calculation Using SOCMI Emission Factors
A process has 100 flanges (connectors) which are in contact with a mixture containing
50% benzene (by weight) during 8000 hours of the year. What are the fugitive emissions
of benzene from this process?
Emission = emission factor x # of valves x concentration of chemical x # of hours
Emission = 0.00403 Ib/hr/source x 100 sources x 50% benzene x 8000 hours
Emission = 1612 pounds of benzene
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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
• 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 n, 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.
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
http://www.eDa.gov/tln/cMef/tarfcs.htrnl.
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.epa.gov/ttn/chief/software.htmlwater#8.
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A facility that discharges or has the potential to discharge water containing regulated wastes must
operate under the terms of Federal, State, and/or local permits, such as a NPDES 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 II, 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).
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:
3/1/96
9/8/96
1.0
0.2
.: ..... mmm..
1.0
0.2
Daily
8.33 Ibs.
0.332 Ibs.
Annual Calculation:
(8.33 Ibs. + 0.332 lbs.)/2 days x 365 days/year = 1580.82 Ibs/yr
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Underground Injection On-Site (Part n, 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 H-V (Part BE, Section 5.4.2 of Form R).
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 n, 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 n, 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 n, 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 (ie., 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. Releases to land on-
site/other disposal includes spills, leaks, or "unintentional" disposal, such as metal dust that is
deposited onto soiL Incident logs or spill reports can provide useful information.
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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 energy recovery. Unless
the facility had additional information on
the fate of the reportable Section 313
metal in this waste, the facility must
assume the metal is being disposed and
should report the quantity sent off-site
accordingly in Part II, Sections 6.2 and 8.1
of Form R.
Even wastes that were minimally
processed, such as wastes that were
repackaged, such as small containers
removed from a lab pack that were not
otherwise opened or managed, may need
to be reported if the article exemption (as
discussed in Section 2) is not applicable.
Estimating Releases for Accidental Losses
Leaks, spills, and drips from the loading and transfer of
chemicals received at the facility should be considered
and reported in your release estimates. Data concerning
specific incidents (such as notification reports or incident
logs) should be used to estimate releases. Equations found
in Section 6 of EPA's Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemical Release
Inventory Form (EPA 560/4-88-002, December 1987),
provides guidance on calculating releases from chemical
spills or leaks, including liquid discharges, fraction of
discharge flashed, vaporization, two-phase discharges, and
gas discharges.
EXAMPLE: A facility uses more than 10,000 pounds of
ethylene glycol during the year to prevent freezing of coal
piles. While unloading on a windless overcast day, a
malfunction occurs and onsite personnel visually estimate
that 50 gallons of ethylene glycol are spilled. Most of the
spill remains on the pad, however, an estimated ten
percent flows off the pad and onto the soil. Absorbent
material used to remove the ethylene glycol from the
concrete pad is transferred offsite for disposal. How
would these releases be reported on the Form R? The
density of ethylene glycol is 9.3 pounds per gallon, and the
vapor pressure is 0.06 mm Hg at 68° R
Quantity spilled = 50 galx93 IbsJgal = 465 Ibs.
Amount spilled onto pad = 465 x 90% = 418.5 Ibs.
Amount spilled onto soil = 465 xlO% = 46.6 Ibs.
Air emissions of ethylene glycol are expected to be
negligible due to the low vapor pressure and
environmental conditions, provided response and cleanup
are immediate. Therefore, the total amount spilled onto
the concrete pad (418.5 pounds) is transferred offsite and
should be reported in Sections 6,2, and the total amount
spilled onto the soil (46.6 pounds) should be reported hi
Section 5.5.4, other disposal.
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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
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.
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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 n, Section 7C of Form R)
In Section 7C, methods used to recycle the Section 313 chemical in wastes are reported.
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
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used as they relate to the reportable Section 313 chemical. A quantity must be reported in
Section 8.2 when a method of on-site energy recovery is reported in Section 7B and vice versa.
Two conditions need to be met to report the combustion of a Section 313 chemical as energy
recovery: the chemical (1) must have a heat of combustion high enough to support combustion
(e.g., 5,000 BTU per pound or greater), and (2) must be combusted in a unit equipped with an
energy recovery device, such as a waste heat boiler. Note that "NA" should be reported for
Section 313 chemicals which are Halons (e.g., CFCs) and metals that do not have a heat of
combustion sufficient to sustain combustion.
Quantity Used for Energy Recovery Off-site (Part TL, 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 H, 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)
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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.
Quantity Treated Off-site (Part H, 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.
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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.
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 II, Section 8.8 nor Sections 8.1 through 8.7 of
FormR.
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SECTION 5
CALCULATING RELEASE ESTIMATION AT ELECTRICITY GENERATING
FACILITIES
In Section 4, the tools and techniques available for estimating releases to the environment and
reporting of disposition of wastes (including transfers off-site, land disposal, underground
injection, and wastewater discharges) were discussed. This section provides guidance on how
electricity generating facilities report these releases and waste dispositions on the FormR.
Typical operations and the resulting wastes and releases are discussed.
Electricity generating facilities should evaluate their activities on a site-specific basis. This
guidance is a starting point for considering possible releases and evaluating estimation methods.
Developing accurate and comprehensive release estimates requires the consideration of all
possible release pathways.
While differing in some important respects, all conventional steam electricity generating stations
rely on the same basic mechanism, as presented in Figure 5-1. Fuel is ignited and burned within a
boiler chamber composed of thousands of feet of water-filled tubes. The heat of combustion
heats the water in the boiler tubes, creating high temperature and high pressure steam The steam
passes through turbines causing the turbine blades to rotate and a shaft connected to the turbine
blades drives electric generators, yielding electric power. In this fashion, the chemical energy of
the fossil fuel is converted to heat energy through combustion, then to mechanical energy in the
turbines, and finally to electrical energy in the generators. Transmission lines, substations, and
switching stations channel generated electricity to various customers.
This section discusses certain operations, common to many electric power generating stations,
which may result in releases containing Section 313 chemicals. These operations are: fuel
storage and preparation, water treatment, combustion waste management, flue gas
desulfurization, and plant maintenance.
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Oxidation Stage
,
Chemlcaft
Added
FGD Sludge
Coil Run-off
OH Filtrate
Water
Treatment
Demlnerallzer
> Electricity
Chemicals
Added
Chemicals
Added
Watt*
Wastt Chemicals
Addid
Watte Cooling Water
Slowdown
Figure 5-1 Process for Generating Electricity at Electricity Generating Facilities
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Fuel Storage and Preparation
Examples of Potential SeettoJi 31$ Otfauieals Itaralved ifc
Fuel $toi«8*«it0 Preparation
Compounds of: antimony, arsenic, beryllium, cadmium,
chromium, copper, lead, manganese, mercury, nickel,
selenium, silver, thallium
Ethylene glycol
Section 313 chemicals in oil
-* ;•*<*- Source '"'
•,•,•:,;., ' "•
Coal pile
Prevention of coal pile
freezing
Filtration
Coal
Electricity generating facilities typically store large quantities of coal onsite. Many tons of coal
are commonly stored onsite at coal-fired generating plants to maintain up to 90 days worth of
coal. Releases, for example air emissions from fuels in storage, must be considered for reporting.
Coal stored in exposed piles may be subject to rainfall, snowfall, spraying for dust control, and
underground streams that surface under the piles. Thus, on-site storage may result in-coal pile
run-off. Moisture and air may react with metallic sulfides in the coal to produce sulfuric acid,
which dissolves inorganic salts in the coal pile. Depending on a variety of factors, various
amounts of metals and metal compounds may be present in the resulting coal pile runoff. Metal
compounds that form during reactions in the coal pile are considered "manufactured" and are not
eligible for the de minimis exemption. Therefore, quantities of metal compounds or other
Section 313 chemicals manufactured in the coal pile must be counted towards the manufacturing
threshold of 25,000 pounds. (For a complete discussion on the manufacture of metal
compounds, refer to the discussion in Section 3 of this document). If two or more different
compounds within the same metal compound category are manufactured, the total weight of
all these compounds must be counted towards the threshold determination for that metal
compound category.
Arsenic, chromium, copper, manganese, and nickel are commonly found in coal pile runoff. In
addition low concentrations of antimony, cadmium, beryllium, lead, selenium, and thallium may
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also be present. All of these Section 313 metals could be present in elemental anoVor compound
form. Traces of mercury and silver also may be found in the runoff.
Some potential releases or waste generation sources associated with coal storage and preparation
are:
Fugitive emissions during transfer of coal to boiler (§5.1)
Fugitive emissions of ethylene glycol from coal pile (§5.1)
Spills or leaks of ethylene glycol (§5.5)
Stormwater runoff (§5.3)
Coal pile runoff (§5.3 or §6.1)
Disposal of material settled from coal pile runoff, on-site (§5.5), or transferred off-site
(§6.2).
Oil
Oil-fired facilities often maintain storage capacity for 60 to 120 days worth of oil to ensure
continuous operation of the boiler. Oil is stored in large tanks and delivered under pressure to the
boiler's burners after filtration of sediment and contaminants. The filtered material may contain
Section 313 chemicals and be disposed on or off-site.
Some potential releases or waste .generation sources associated with oil storage and preparation
are:
Fugitive and/or point source emissions from storage and transfers of lighter oils (§5.1 or
§5.2)
Accidental releases due to tank failure (§5.1, §5.3, and/or §5.5.4)
Leaks and drips (§5.5)
Disposal of solids (residuals, sediments) from oil, on-site (§5.5) or transferred off-site
(§6.2).
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Water Treatment
Examples of Potential Section 313 Cfeeftiiqals Invoked in
Water Treatment
Bromine, chlorine, chlorine dioxide
Bromoform, chloroform
Ammonia, chromium compounds, hydroquinone, hydrazine,
and zinc
Nitrate compounds
Copper, manganese, zinc
Source
*.
Anti-biofouling agents in
boilers and cooling towers
Manufactured from reactions
with biofouling agents and
intake water
Anti-corrosion agents in
boilers and cooling towers
Manufactured in cooling
tower
Demineralizer regenerant
Electricity generating facilities use large amounts of water for two separate purposes. First,
boiler water is used to generate steam which will drive the blades of a turbine. This water must be
treated prior to entering the boiler to prevent fouling and scaling within the boiler. Once it has
passed through the turbine, the "dead" steam is sent to a condenser, where large volumes of
cooling water are used to remove heat from the steam, condense it, and pump it back into the
boiler. Chemicals used for treatment of cooling water may be different from those used to treat
steam generation water. Similarly, the resulting wastes differ, and therefore cooling water
treatment and boiler water treatment are discussed separately.
Boiler Water Treatment
Water used to produce steam is drawn from municipal or other sources and treated to remove
dissolved gases, suspended solids, and dissolved chemical salts prior to placement in the boiler.
These materials can cause corrosion, erosion, and scaling of boiler components. Clarification and
filtration are common methods of removing suspended solids in the feedwater. The filter media is
periodically backwashed to remove the solids that have accumukted, producing a sludge that is
typically disposed in onsite kndfills, or codisposed in ash ponds. Section 313 chemicals present in
water drawn from the environment or from municipal sources are exempt from both threshold
determinations and release reporting. Therefore, sludges from clarification and filtration are only
reportable if Section 313 chemicals were used (e.g., coaguknts) to treat the boiler water.
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After clarification and filtration, boilers with high drum pressures typically require
demineralization of the water to remove any dissolved solids. Demineralization is commonly
accomplished with ion exchange resins that replace dissolved cations with hydrogen ions, and
anions with hydroxide ions. Demineralization may be repeated until the ion exchange resins are
saturated with removed material and must be regenerated by passing a strong acid (commonly
sulfuric acid) or a strong base (caustic) over the resin beds. Regeneration produces a potentially
corrosive waste stream containing mineral salts, excess regenerant chemicals (e.g., sulfuric acid in
solution), copper, zinc, manganese, and other chemicals. Chemicals originating from municipal
sources that are present in demineralization wastes are exempt from reporting.
The demineralization waste stream may be neutralized in tanks and discharged along with other
liquid waste streams, or co-disposed with ash in on-site ponds or surface impoundments, from
which wastewaters may be discharged to a POTW or water body. Alternatively, facilities may
send this waste stream offsite for treatment and disposal.
Condensate and make-up water may also be polished in fixed bed or powdered resin polishers.
Fixed bed polishers are regenerated in the same manner as demineralizers, while powdered resin
polishers are not regenerated and the resin is discarded as a slurry wastestream. Electricity
generating facilities may also use reverse osmosis to treat boiler water. These facilities may
dispose of the resulting brine on or off-site, or discharge it to a POTW or water body.
Water condensate exiting the condensers may also be treated by passing it through a deaerator
heater before it is directed to feed pumps and returned to the boiler. The deaerator adds heat to
the water, and removes dissolved oxygen and other noncondensable gases, by scrubbing the
condensate with steam, thereby improving the water quality. The resulting gases exit through a
vent line.
After passing through the deaerator, Section 313 chemicals such as hydrazine and hydroquinone
may be added to the water to remove any remaining oxygen. Quantities of chemicals used for
treatment must be applied to the otherwise use threshold. Regardless of how boiler feedwater is
purified, some impurities remain. As water is recirculated through the steam cycle, these
impurities begin to concentrate in the boiler. Also, the added Section 313 chemicals may undergo
decomposition or react with other chemicals in the boiler. To prevent excessive concentration of
corrosion or scaling agents within the boiler, a portion of the boiler water, called blowdown, must
periodically be removed and replaced with make-up water. The blowdown may contain Section
313 chemicals added to the feedwater and boiler (such as hydrazine, hydroquinone, zinc and
chromium compounds, and ammonia), their reaction products, and traces of copper, nickel and
other metals. Metals or other Section 313 chemicals in blowdown that originated from municipal
water sources are exempt for release reporting. Blowdown may be reused to sluice (transport)
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ash to a disposal or treatment site, or as cooling water in cooling towers, vented to the
atmosphere, or sent to ash ponds where it may be discharged after materials have settled out.
Some potential releases or waste generation sources associated with boiler water treatment are:
Chemical and waste holding tanks (fugitive and/or point source emissions, §5.1 and/or
§5.2)
Deaerator vents (point-source air emissions, §5.2)
Demineralizer regenerant wastes directed into on-site ash impoundments for disposal
(§5.5)
Demineralizer regenerant wastes directed to a settling pond then discharged (§5.3 or §6.1)
Boiler blowdown co-disposed in surface impoundment (5.5)
Condensate polisher wastewater discharge (§5.3 or §6.1)
Boiler blowdown water discharge (§5.3 or §6.1)
Sludges generated from coagulation and filtration of feedwater co-disposed in ash ponds
or landfills on-site ( §5.5) or transferred offsite (§6.2)
Cooling Water Treatment
The expansion of high pressure steam drives the blades of a turbine, and a generator then converts
the turbine's mechanical energy into electrical energy. This creates a large volume of low
pressure "dead" steam, which must be condensed to allow the efficient pumping of the resultant
water back into the high-pressure boiler. It is condensed by transferring heat to cooling water in a
heat exchanger called the condenser. This cooling water required to discard waste heat creates
the largest volume waste stream of this industry.
Shell and tube condensers are typically used to cool the steam. Large amounts of cooling water
circulate through the inside of thousands of condenser tubes, and steam passing over the tubes
condenses and is collected for recycling. Cooling water passing through the tubes of the
condenser is heated as it condenses the steam, and a constant flow of chilled water is required to
maintain the efficiency of the condenser. The chilled cooling water is supplied in either one of
two ways: once through or recirculated. Once-through cooling water is withdrawn from the
water body source, passed through the condenser, and returned to its source. Following the
condenser, once-through cooling water is sometimes passed through a pond or canal in order to
lower its temperature before final discharge. A recirculated cooling water system is used when
the water supply is inadequate to support a once-through cooling system, when there may be
undesirable thermal effects in the receiving water, or when regulations so dictate. After cooling
water has been passed through the condenser, the heat picked up is transferred to the atmosphere
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by means of cooling towers, cooling ponds, or spray canals, and is then recirculated back to the
condenser. Wastes produced in once-through cooling systems differ from those produced in
reckculating systems and are discussed separately.
Once-through reckculating systems draw water from large or rapid rivers, oceans, bays and large
lakes. In saltwater applications (or other situations where the total dissolved solids content of
cooling water is high), anticorrosion agents such as zinc compounds may also be added to the
intake stream to prevent damage to the cooling system. Unless the intake water has high
concentrations of suspended solids, low temperatures, or other characteristics that limit
biofouling, biocides (such as chlorine, bromine, or chlorine dioxide) may be injected into the
cooling system or added to cooling ponds to prevent biofouling of equipment. Reactions between
these chemical additives and the intake water may result in the formation of Section 313
compounds, including chlorinated organics such as chloroform or bromoform. Once it has passed
through the condenser, the cooling water may be pre-cooled in a pond or canal prior to final
discharge to a receiving water body.
Reckculating cooling water systems use cooling towers to remove heat via evaporation, leaving a
liquid with concentrated impurities, which may deposit scale on tower basins or condenser tubes,
reducing heat transfer efficiency. As a result of these impurities, the need for anti-corrosion and
anti-biofouling agents discussed above is even more important than in once-through cooling
systems. To prevent scaling, some of the impurity-filled water is periodically removed and fresh
water is pumped in. The discharged water, or blowdown, may contain nitrate compounds,
biofouling agents and anti-corrosion agents and thek reaction products. Contaminants originating
from intake water or ambient ak are exempt from both threshold determinations and release
reporting; therefore, facilities need only report releases of Section 313 chemicals in blowdown
that were added to, or manufactured as byproducts in cooling water. Blowdown may be placed in
a surface impoundment where much of the liquid evaporates or is discharged, and the remaining
sludge is dredged and co-disposed in an on-site landfill or sent off-site for disposal. The
blowdown may also be used to sluice ash for disposal in on-site landfills or surface
impoundments. Solid precipitates which accumulate at the base of cooling towers must also be
periodically be removed for disposal in onsite landfills. This material may reflect treatment
chemicals discussed above.
Some potential releases or waste generation sources associated with cooling water treatment are:
• Chemical and waste holding tanks emissions (fugitive and/or point source emissions, §5.1,
and/or §5.2)
• Blowdown wastewater discharge (§5.3 or §6.1)
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Cooling tower blowdown water used to sluice ash to on-site surface impoundment (5.5)
Cooling tower sludge land disposed on-site (§.5.5).
Combustion Waste
Examples of Potential Section MS Qietnkatg in
Combustion Wastes
Compounds or elemental forms of antimony, arsenic, barium,
beryllium, cadmium, chromium, cobalt, copper, lead,
manganese, mercury, nickel, selenium, silver, zinc
•• sS S w?V -'-.V
Source
Coincidentally manufactured
during combustion
Fly Ash, Bottom Ash, and Boiler Slag
Coal combustion and to a much lesser extent, oil combustion, generates considerable amounts of
both fly ash and bottom ash. Bottom ash is unburned matter that collects at the bottom of the
boiler, and is present mainly at facilities combusting coal. Very little bottom ash is produced from
oil combustion. Fly ash is a fine, light ash borne in flue gas, collected by mechanical ash collectors
and particulate control devices such as electrostatic precipitators, baghouses, or wet scrubbers.
Fly ash is produced in both oil and coal combustion. Some facilities may produce boiler slag,
bottom ash particles in a molten state.
Facility specific information (e.g., from suppliers or testing) can be used to estimate amounts of
Section 313 metals in combustion wastes, provided the source of the information is documented.
The best available information should be used to estimate the approximate concentration of the
metal in ash byproduct. Typical concentrations of metals in ash byproducts from the combustion
of coal are presented in Table 5-1. In the absence of better information, these values can be used
as a basis for estimating quantities released during coal combustion.
Table 54 Total CoMtiWMt CoMeatratfojis of Wtenmtti Jw Coal Comfcttstlon ResMuate
Element Concenti^tions in Different MatMals (ppni)
Element (units)
Antimony
Arsenic
Barium
Fly Ash
131
6,300
13,800
Bottom Asb
10
168
9,360
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Table 5*1 To&l Constitwnt Caiiceiatmiions of J^snienj& in '$$$& G&nfiMstign MMxs^...
Eleta^ttt CoftCeMmtiOtt&ift X)ii^eM Materials (ppm)
Element (units)
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
IfcrAsfc
130
900
2,200
2,120
3,000
12
4,300
134
36
1,180
3,500
Bottom Asfe
10
5,820
932
1,082
1,940
4.2
2,939
14
9.9
537
1,796
Source: EPRI, Inorganic and Organic Constituents in Fossil Fuel Combustion Residues.
Fly and bottom ash may be managed separately or together in landfills or wet surface
impoundments. If managed wet, both fly and bottom ash may be sluiced and sent to one or more
impoundments for temporary storage or permanent disposal Bottom ash may be periodically
dredged from a pond and dewatered prior to sale. Bottom or fly ash may also be sold for use in
the construction industry (e.g., as concrete stabilizers or roadfill) or for metals recovery (e.g.,
vanadium recovery from oil combustion ash). Ash ponds may discharge to a treatment basin for
settling and/or pH control prior to permitted discharge. Many operators recycle ash pond water
back to the ash transport/sluice system.
If managed dry, fly ash may be pneumatically transferred to ash storage silos. From here, the ash
may be conditioned with water prior to landfill disposal, or loaded on trucks for use elsewhere at
the facility, or for sale (e.g., concrete stabilizer for on-site construction).
Because the de minimis exemption does not apply to a Section 313 chemical manufactured at the
facility that does not remain in a product distributed by the facility, metal compounds in ash which
were manufactured during combustion are not eligible for the de minimis exemption if the ash is
managed as a waste. If a Form R is required for a metal compound category, then all non-
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exempt releases must be reported on Form R.
However, only the weight of the EPCRA Section
313 metal itself, not the weight of the entire metal
compound, is used to report quantities released and
transferred off-site for waste management.
If the ash is distributed in commerce to be used as a
raw material by an off-site entity, the amounts of
Section 313 chemicals contained in the ash
"product" are considered "processed". In this case,
the amounts of Section 313 chemicals distributed in
commerce do not need to be reported on the Form
R. Furthermore, the de minimis exemption applies
to amounts processed. Therefore, releases and
other waste management of reportable Section 313
chemicals present at concentrations below de
minimis and generated from processing ash are
exempt.
Off-Site Transfers of Wastes to A
Facility Owned and Operated By The
Electricity Generating Facility
Some electricity generating facilities
dispose of solid wastes that the facility
generated at off-site disposal facilities
that the generating facility owns and
operates. The generating facility is
required to report the quantities of
reportable Section 313 chemicals in the
wastes sent for off-site disposal in Part
H, Section 6.2 and Section 8.1. The
generating facility is not required to
report on releases that occur at any off-
Applicable codes for treatment of ash are P13 (Sludge Dewatering), Pll (Settling/Clarification),
F83 ( Thermal Drying/Dewatering) (Part II, Section 7A). The quantity of a Section 313 chemical
(except for metals and metal compounds) destroyed or chemically converted would be reported in
Part n, Section 8.6, Quantity treated on-site, of Form R.
Some potential releases or waste generation sources associated with ash waste management are:
Dust and particulate fugitive emissions from dry ash management (§5.1)
Discharge of water used to transport ash (§5.3 or §6.1)
Disposal of ash solids and slag in on-site landfills, or surface impoundments (§5.5) or off-
site mines, quarries, or waste management facilities (§6.2)
Note: Amounts of Section 313 chemicals in fly ash and bottom ash should be considered in
addition to amounts of the same chemicals released to the air (discussed in the following section).
The facility should consider amounts of metals managed as waste and potentially distributed in
product as a mass balance compared to amounts of the metal originally contained in the fuel.
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Air Emissions
Examples of Potential Section 313 Chemicals EetesiSed to
the Alt ' „ _5, V--
Compounds of metals such as arsenic, beryllium, cadmium,
chromium, lead, manganese, mercury, nickel, selenium, and
other TRI metals
Organic compounds such as formaldehyde, methanol,
polycyclic aromatics (e.g., naphthalene)
Hydrogen fluoride, hydrochloric acid (aerosol), sulfuric acid
(aerosol)
Source
Fuel combustion
Fuel combustion
Fuel combustion
The combustion of coal and oil at electricity generating facilities may result in the volatilization of
various Section 313 chemicals which become part of the flue gas. Amounts of these chemicals
not caught in paniculate control devices or in flue gas desulfurization (FGD) systems (discussed
later) may result in stack emissions of antimony, arsenic, barium, beryllium, cobalt, cadmium,
chromium, lead, manganese, mercury, nickel, selenium, zinc, formaldehyde, methanol, polycyclic
aromatics (such as naphthalene), and other Section 313 chemicals. Lead and lead compounds are
often emitted from boilers that are fired with used oil. To calculate the amount of metals emitted
to the air, only the weight of the parent metal must be considered. Section 313 chemicals which
form during combustion are considered "manufactured" and releases of these chemicals are not
subject to the de minimis exemption. For a complete discussion on the formation of metal
compounds during combustion, refer to Section 3 of this document. Combustion of coal may also
result in emissions of hydrochloric acid (HC1) in aerosol form, hydrogen fluoride (HP), chlorine,
and fluorine. If aerosol forms of hydrochloric acid are produced during or after combustion and
are present in the flue gas, the amount produced must be applied to the manufacturing threshold.
Releases of Section 313 chemicals to the air may be calculated using information from monitoring
data, air permits, and air permit applications. Emissions information from equipment vendors,
particularly emission performance guarantees or actual test data from similar equipment is another
potential source of information for release calculations.
In the absence of facility-specific data, emission factors can be used to estimate emissions of
Section 313 chemicals. AP-42 emission for metals and organic compounds are given in Tables 5-
2, and 5-3 respectively. These tables are specific to certain conditions (e.g., fuel type). To
estimate releases of HC1 and HF when no better data are available, assume the amount released is
the amount manufactured (calculated using the factors presented in Table 3-5, Section 3 of this
document) minus amounts removed by air control devices. Emission estimates will vary,
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Acid Aerosols
Both hydrochloric acid and sulfuric acid appear on the Section
313 list of chemicals with the following qualifier: "(acid
aerosols including mists, vapors, gas, fog, and other airborne
forms of any particle size)." This definition is broader than just
"aerosol" but the term "aerosol" is used as shorthand for the
lengthy definition.
Sulfuric acid (aerosol) is manufactured from the combustion
of coal and oil. For EPCRA Section 313, facilities are only
required to account for manufacture of chemicals that occurs
at the facility. Sulfur trioxide produced from combustion
reacts with water to form sulfuric acid (aerosol). The quantity
of sulfuric acid (aerosol) manufactured before the exhaust gas
leaves the stack must be included in threshold and release
calculations.
EPA will issue guidance concerning sulfuric acid (aerosol) in
the near future. This guidance will include information to
assist facilities in determining the quantity of sulfuric acid
(aerosol), if any, manufactured on site.
depending on the efficiency
of the air control device
(e.g., electrostatic
precipitator, baghouse,
scrubber). Emission factors
for other Section 313
chemicals and other
conditions are also available,
and can be found on the
word wide web, as detailed
in Section 4 of this
document. The fly ash
handling operations in most
modern electricity
generating facilities consist
of pneumatic systems or
enclosed and hooded
systems which are vented
through small fabric filters
or other dust control
devices. Therefore, the
fugitive particulate matter
emissions from these
systems are anticipated to be
minimal.
Fugitive emissions and stack emissions are reported in Sections 5.1 and 5.2, respectively, in Part
H of Form R.
Per AP-42, the Emission Factor Quality Ratings for Tables 5-2, and 5-3 are as follows:
A Excellent. Factor is developed from A- and B-rated source test data taken from many
randomly chosen facilities in the industry population. The source category population is
sufficiently specific to minimize variability.
B Above average. Factor is developed from A- or B-rated test data from a "reasonable number"
of facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a
random sample of the industry. As with an A rating, the source category population is sufficiently
specific to minimize variability.
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C Average. Factor is developed from A-, B-, and/or C-rated test data from a "reasonable
number" of facilities. Although no specific bias is evident, it is not clear if the facilities tested
represent a random sample of the industry. As with the A rating, the source category population
is sufficiently specific to minimize variability.
D Below average. Factor is developed from A-, B- and/or C-rated test data from a small
number of facilities, and there may be reason to suspect that these facilities do not represent a
random sample of the industry. There also may be evidence of variability within the source
population.
E Poor. Factor is developed from C- and D-rated test data, and there may be reason to suspect
that the facilities tested do not represent a random sample of the industry. There also may be
evidence of variability within the source category population.
Use of AP-42 Emission Factors
The general equation for emission estimation is:
E = AxEFx(l-ER/100)
where:
E = emissions,
A = activity rate,
EF = emission factor, and
ER= overall emission reduction efficiency, %.
ER is further defined as the product of the control device destruction or removal efficiency
and the capture efficiency of the control system. When estimating emissions for a long time
period (e. g., one year), both the device and the capture efficiency terms should account for
upset periods as well as routine operations. Note that some emission factors already
incoporate a removal efficiency term.
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Table 5-2 Section 313 Metal Emission Factors for Fuel Combustion
CONTROLLED CO AL COMBUSTION1
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Chromium (VI)
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Emission Factor
(lb/ton)b
1.8E-05
4.1E-04
N/A*
2.1E-05
5.1E-05
2.6E-04
7.9E-05
l.OE-04
N/A*
4.2E-04
4.9E-04
8.3E-05
2.8E-04
1.3E-03
Emission Factor
Rating
A
A
N/A*
A
A
A
D
A
N/A*
A
A
A
A
A
Source: AP-42 Chapter 1, External Combustion Sources.
The emission factors were developed from emissions data at eleven facilities
firing bituminous coal, fifteen facilities firing subbituminous coal, and from two
facilities firing lignite. The factors apply to boilers utilizing either venturi
scrubbers, spray dryer absorbers, or wet limestone scrubbers with an
electrostatic precipitator (ESP) or Fabric Filter (FF). In addition, the factors
apply to boilers using only an ESP, FF, or venturi scrubber. SCCs = pulverized
coal-fired, dry bottom boilers, 1-01-002-02/22, 1-02-002-02/22,
1-03-002-06/22; pulverized coal, dry bottom, tangentiaUy-fired boilers,
1-01-002-12/26, 1-02-002-12/26, 1-03-002-16/26; cyclone boilers,
1-01-002-03/23, 1-02-002-03/23, 1-03-002-03/23; and, atmospheric fluidized
bed combustors, circulating bed, 1-01-002-18/38, 1-02-002-18, and
1-03-002-18.
NO. 6 FUEL OIL COMBUSTION"
Average Emission
Factor"1 (lb/103 Gal)
5.25E-03
1.32E-03
2.57E-03
2.78E-05
3.98E-04
8.45E-04
2.48E-04
6.02E-03
1.76E-03
1.51E-03
3.00E-03
1.13E-04
8.45E-02
6.83E-04
Emission Factor
Rating
E
C
D
C
C
C
C
D
C
C
C
C
C
D
""Emission factor should be applied to coal feed, as fired.
To convert from Ib/ton to kg/Mg, multiply by 0.5.
"Data are for residual oil fired boilers, Source
Classification Codes (SCCs) 1-01-004-01/04.
dTo convert from lb/10* gal to kg/103 L, multiply by 0.12.
*N/A - data not available for this metal
September 26,1997
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
Table 5-3 Emission Factors for Various Organic Compounds
from Controlled Coal Combustion
Pollutant1"
Acetaldehyde
Acetophenone
Acrolein
Benzene
Benzyl chloride
Bromoform
Carbon disulfide
2-ChIoroacetophenone
Chlorobenzene
Chlorofonn
Cumene
2,4-Dinitrotoluene
Dimethyl sulfate
Ethyl benzene
Fonnaldehyde
Hexane
Methyl ethyl ketone
Methyl hydrazine
Methyl methacrylate
Methylene chloride
Phenol
Propionaldehyde
Tetrachloroethylene
Toluene
1 , 1 , 1 -Trichloroethane
Emission Factor"
(Ib/ton)
5.7E-04
1.5E-05
2.9E-04
1.3E-03
7.0E-04
3.9E-05
1.3E-04
7.0E-06
2.2E-05
5.9E-05
5.3E-06
2.8E-07
4.8E-05
9.4E-05
2.4E-04
6.7E-05
3.9E-04
1.7E-04
2.0E-05
2.9E-04
1.6E-05
3.8E-04
4.3E-05
2.4E-04
2.0E-05
Emission Factor Rating
C
D
D
A
D
E
D
E
D
D
E
D
E
D
A
D
D
E
E
D
D
D
D
A
E
September 26,1997
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TRIFORMR GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
Pollutant*
Styrene
Xylenes
Vinyl acetate
Emission Factor0
(Ib/ton)
2.5E-05
3.7E-05
7.6E-06
Emission Factor Rating
D
C
E
ouuiv^>. cu. -TX* v^uajjic* ±, i^Aiciiiai i^uiiiuusuuu ouurues. jraciois were oev *• ^ -"-"-to —»—**"""«" ~vw», xug»v
sites firing subbituminous coal, and from one site firing lignite. The emission factors are applicable to boilers using both wet limestone scrubbers or
spray dryers and an electrostatic precipitator (ESP) or fabric filter (FF). In addition, the factors apply to boilers utilizing only an ESP or EF. SCCs =
pulverized coal-fired, dry bottom boilers, 1-01-002-02/22,1-02-002-02/22,1-03-002-06/22; pulverized coal, dry bottom, tangentially-fired boilers,
1-01-002-12/26,1-02-002-12/26,1-03-002-16/26; cyclone boilers, 1-01-002-03/23,1-02-002-03/23,1-03-002-03/23; and, atmosphericfluidized
bed combustors, circulating bed, 1-01-002-18/38,1-02-002-18, and 1-03-002-18.
'Pollutants sampled for but not detected in any sampling run include: Carbon tetrachloride-2 sites; 1,3-Dichloropropylene- 2 sites;
N-nitrosodimethylamine- 2 sites; Ethylidene dichloride- 2 sites; Hexachlorobutadiene- 1 site; HexacMoroethane- 1 site; Propylene dichloride- 2 sites;
1,1,2,2-Tetracnloroethane- 2 sites; 1,1,2-Trichloroethane- 2 sites; Vinyl chloride- 2 sites; and, Hexachlorobenzene- 2 sites.
"Emission factor should be applied to coal feed, as fired. To convert from Ib/ton to kg/Mg, multiply by 0.5.
Flue Gas Desulfurization
^ Potential Section 313 Cttemicalsi from FGD
Metals and/or compounds of arsenic, barium, cadmium,
chromium, copper, cobalt, lead, manganese, mercury, nickel,
selenium, silver, zinc
SODffiCe
Present in flue
lime/limestone
gas or in
Another significant source of waste at electricity generating facilities is flue gas desulfurization
(FGD). FGD is commonly used to control sulfur dioxide emissions as required by the Clean Air
Act. Sulfur dioxide is produced during combustion when oxygen is combined with sulfur from
coal and can be removed by various types of FGD systems. Ninety five percent of FGD systems
used in electricity generating facilities are non-regenerable, meaning that they produce a waste for
disposal. These systems may be further categorized as wet scrubber or spray dry systems.
In wet scrubber FGD systems, the flue gas is passed through a lime solution or a milestone slurry,
where the calcium from the lime or limestone reacts with the sulfur dioxide in the flue gas to
produce various calcium compounds. A high percentage of metals may also be removed from the
flue gas as it passes through the lime or limestone, although volatile metals such as mercury and
selenium may pass through the FGD system. Section 313 metals such as arsenic, cadmium,
chromium, copper, cobalt, lead, manganese, mercury, nickel and selenium, silver, and zinc may be
found in limestone as metal carbonates (e.g., cobalt carbonate, manganese carbonate, or zinc
carbonate) or as other metal compounds (e.g., silver sulfide, copper sulfide). As the flue gas
passes through the FGD system, metal compounds from both the limestone and the flue gas may
September 26,1997
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
chemically convert to other metal compounds (such as sulfites and sulfates). Forced oxidation in
FGD systems may also convert one Section 313 metal compound to another, for instance zinc
sulfide may oxidize to zinc sulfate. The amount of a compound within a Section 313 metal
compound category produced as a result of chemical conversion, even if it is within the same
category, must be applied to the manufacturing threshold. Because the de minimis exemption
only applies to Section 313 chemicals manufactured at the facility as impurities that remain in a
product distributed by the facility, metal compounds coincidentally manufactured in FGD systems
are not subject to the de minimis exemption.
FGD systems result in a waste slurry of hydrated calcium sulfate, hydrated calcium sulfite, and
unreacted lime, which may be dewatered and/or stabilized with fly ash and disposed in
impoundments or landfills. The treatment technique and efficiency would be reported in Section
7A, Part H of Form R.
Dry non-regenerable FGD systems spray an alkaline solution into the flue gas to react with the
sulfur oxides. The water from the solution evaporates into the flue gas, leaving a dry powder,
which is collected by a particulate collector such as a baghouse. This method is most common at
facilities which burn low sulfur fuel The Section 313 considerations for wet and dry FGD
systems are the same. However, because wet scrubber systems result in the cooling of flue gases,
they cause the more volatile trace elements to condense from the vapor phase.
Several information sources may be used to calculate the amount of Section 313 chemicals in
FGD wastes. These sources include waste analyses, NPDES permits, and waste characterization
performed to meet state or other solid waste management requirements. The best available
information should be used to estimate concentrations of Section 313 chemicals in FGD sludge
solids and liquors. In the absence of facility specific data, the values presented in Table 5-4 may
be used to estimate concentrations. Table 5-4 shows concentrations of certain trace metals in
FGD sludge solids and liquors. Only the weight of the parent metal must be considered when
reporting releases of Section 313 metal compounds.
Table 5-4 Coneeittratiojis of Certain* Trace Metals in FOB Slwdge SolMs a»d Lictaors
Trace Element-
Arsenic
Boron
Cadmium
Chromium
Sftntite $oii
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
^ Table $-4 Concentrations i
"^^ Trace Ek&Mkt
Copper
Mercury
Lead
Selenium
jf CertauaB.Tm^. Metals IR F<$> ,
\ Sludge Solids (pprn)
340.0
6.0
290.0
60.0
Sludge Seiidsund Liquors
_SIii^e Liquors (ppm>
0.5
0.1
0.5
1 9
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization by
Electric Utilities, p.7.
Some potential releases or waste generation sources associated with FGD systems are:
« Fugitive and/or stack emissions of dry waste FGD material (§5.1, and/or §5.2)
• Discharge of water remaining after sludge dewatering (§5.3 or §6.1)
• Disposal of waste FGD material in on-site landfills, or surface impoundments (§5.5) or off-site
to mines, quarries, or waste management facilities (§6.2).
Plant Maintenance
X«-- ^-^^SKV&S.^,. -. f '•&„, ; •"*
Exa mples of Potential Section 313 Chemicals Associated
«>i- Bi4<-"-- _'•_ * . ' Vv-'5S"S$-
with Plant Maintenance
Ammoniated EDTA, ammoniated citric acid, formic acid
Hydrochloric acid (aerosol)
Ammonium bifluoride, thiourea
Chemicals in halogenated or non-halogenated solvents
, -*,£#****
\
Boiler cleaning agents
Manufactured during
evaporation of boiler
cleaning wastes
Inhibitor in boiler
Routine metals cleaning
Boiler Cleaning
In spite of the high-quality water used in modern boilers, boilers gradually accumulate scale and
corrosion products. Excessive corrosion or scale build-up on the water-side and fireside of
boilers reduces heat transfer across tube walls, which reduces efficiency and can eventually lead to
September 26, 1997
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TRJ FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
tube failure. Therefore, boilers require periodic cleaning. Boilers are also cleaned prior to start-
up to remove oil, grease, phosphates, nitrites, and suspended and dissolved solids.
High pressure jets of water, sometimes containing alkaline materials, are applied to the fireside
surface of the boiler surface to remove the build-up. The wastes are collected and pumped to ash
ponds or settling lagoons. Chemicals added to the water jet may be present in the waste.
To effectively remove scale deposits and
metals from the water side of the boiler, a
number of different cleaning chemicals
may be used. Hydrochloric acid is the
most commonly utilized cleaning solution;
ammoniated EDTA, ammoniated citric
acid, and formic acid are also used.
Ammonium bifluoride and thiourea may
be added as inhibitors to prevent attack of
tube walls. Depending on the cleaning
solution used, waterside boiler cleaning
waste may include copper, nickel,
chromium, zinc, ammonium sulfate,
ammonium carbonate, copper,
hydrochloric or other acids.
Wastes produced from boiler cleaning are
sometimes evaporated in the boiler. In
this case, if hydrochloric acid is the
cleaning solution, hydrochloric acid
aerosol may be manufactured.
Hydrochloric acid is only reportable for
purposes of Section 313 if it is in aerosol
form. If hydrochloric acid aerosol is
produced via evaporation, the quantity
produced would be applied to the 25,000
pound manufacturing threshold.
Reporting of Aqueous Ammonia
If a facility manufactures, processes, or
otherwise uses aqueous ammonia, the
quantity applied toward threshold
determinations for the ammonia listing is 10
percent of the total quantity of the aqueous
ammonia manufactured, processed, or
otherwise used. The quantity reported when
calculating the amount of ammonia that is
released, transferred, or otherwise used is 10
percent of the total quantity of aqueous
ammonia released or transferred. Aqueous
ammonia may be generated in solution from
the dissociation of ammonium salts in water.
Water dissociable ammonium salts are not
reportable in their entirety under the
ammonia listing; these salts are reportable to
the extent that they dissociate in water, and
only 10 percent of the total aqueous ammonia
that results when these salts dissociate is
reportable. If ammonium salts are purchased
neat or as solids by a facility, then placed in
water by that facility, the facility is
manufacturing aqueous ammonia.
Boiler cleaning wastes may be treated in
one or several treatment steps. Applicable codes to be reported in Part II, Section 7A of Form R
are PI 1 (Settling, clarification), P12 (Filtration), Cll (Neutralization), C01 (Chemical
Precipitation-lime or sodium hydroxide), P13 (Sludge Dewatering; non-thermal, P99 (other
treatment, e.g., solar evaporation).
September 26,1997
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
Wastes from waterside cleaning are sometimes incinerated. On-site incineration should be
reported in Section 7A, Part n of Form R, with the appropriate treatment code, while off-site
incineration is reported in Section 6.2, Part II of Form R. The quantity of a Section 313 chemical
destroyed or chemically converted would be reported in Part n, Section 8.6, Quantity treated on-
site, of Form R. Metals should not be reported in Section 8.6. If a waste containing a reportable
Section 313 chemical with a heating value at least 5,000 BTU per pound is combusted in the
boiler, then the quantities of that chemical that are combusted in the boiler would be reported in
Part n, Section 8.2, Quantity used for energy recovery on-site.
Other Plant Maintenance
Other plant maintenance wastes are produced from the cleaning of stacks, condensers,
economizers, feedwater pumps, heat exchangers, deaerators, feedwater heaters, and piping, and
may contain metal oxides and other Section 313 chemicals. Routine metals cleaning at power
plants typically involves halogenated and non-halogenated solvents. At some sites, spent solvents
are disposed as hazardous wastes, while at others they are burned in the boilers. These wastes
may be sent to on-site ponds, impoundments or landfills, and may be co-managed with
combustion wastes.
Floor and yard drain waste streams may be generated from rainfall, seepage from groundwater
sources, leachate, equipment cleaning operations and spills. The composition of this waste is
highly variable and may include coal dust, fly ash, oil, and detergents, and may be acidic if wastes
from air preheater or boiler fire-side washings are present.
Some potential releases or waste generation sources assockted with pknt maintenance are:
Releases from pipes equipment and valves during evaporation or burning of waste (fugitive
air emissions, (§5.1)
Evaporation from chemical or waste holding tanks (fugitive air emissions, §5.1)
Stack emissions of evaporated or burned waste (stack air emissions, §5.2)
Discharge of treated liquid waste (§5.3 or §6.1)
Disposal of wastes into ash ponds, landfills or impoundments (releases to land on-site, §5.5)
Disposal of wastes by a cleaning contractor (transfers to other off-site locations, §6.2).
September 26,1997
5-21
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
APPENDIX A
ALPHABETICAL LISTING OF TRI CHEMICALS
September 26,1997
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ELECTRICITY GENERATING FACILITIES
CAS No.
4080-31-3
354-11-0
630-20-6
71-55-6
354-14-3
79-34-5
79-00-5
13474-88-9
812-04-4
111512-56-2
1717-00-6
57-14-7
5124-30-1
96-18-4
120-82-1
95-63-6
106-88-7
96-12-8
106-93-4
422-44-6
354-23-4
431-86-7
1649-08-7
95,50-1
107-06-2
540-59-0
78-87n5
122-66-7
95,54-5
615-28-1
38661-72-2
106-99-0
507-55-1
136013-79-1
541-73-1
542-75-6
123-61-5
108-45-2
10347.54-3
2556-36-7
764-41-0
106-46-7
123-91-1
104-49-4
624-18-0
3173-72-6
82-28-0
35691-65-7
354-25-6
75-68-3
5522-43-0
16938-22-0
CHEMICAL NAME
l-(3-ChloroallyI)-3,5,7-triaza-l-azoniaadamantane chloride
l,l,l,2-Tetrachloro-2-fluoroethane(HCFC-121a)
1,1,1,2-tetrachloroethane
1 ,1 ,1-Trichloroethane (Methyl chloroform)
l,l,2,2-Tetrachloro-l-fluoroethane(HCFC-121)
1 , 1 ,2,2-Tetrachloroethane
1,1,2-Trichloroethane
l,l-Dkhloro-l,2,2,3,3-pentailuoropropane(HCFC-225cc)
l,l-Dichloro-l,2,2-trifluoroethane(HCFC-123b)
l,l-DicMoro-l,2,3,3,3-pentafluoropropane(HCFC-225eb)
l,l-Dichtoro-l-fluoroethane(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-Bntylene oxide
l,2-Dibromo-3-chloropropane (DBCP)
1,2-Dibromoethane (Ethylene dibromide)
l,2-Dichloro-l,l,2,3,3-pentafluoropropane(HCFC-225bb)
l,2-DicMoro-l,l,2-trifluoroethane(HCFC-123a)
l,2-Dichloro-l,l,3,3,3^entafluoropropane(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-^henylenediamine dihydrochloride
l,3-Bis(methy]isocyanate)cyclohexane
1,3-Butadiene
l,3-Dichloro-l,l,2,2,3-pentafluoropropane(HCFC-225cb)
l,3-DicMoro-l,l,2,3,3-pentafluoropropane(HCFC-225ea)
1,3-Dichlorobenzene
1,3-Dichloropropylene
1,3-Phenylene diisocyanate
1,3-Phenylenediamine
l,4-Bis(methy]isocyanate)cyclohexane
1,4-Cyctohexane diisocyanate
1 ,4-Dichloro-2-butene
1 ,4-Dichlorobenzene
1,4-Dioxane
1,4-Phenylene diisocyanate
1 ,4-Phenylenediamine dihydrochloride
1,5-Naphthalene diisocyanate
l-Amino-2-methylanthraquinone
l-Bromo-l-(bromomethyl)-l,3-propanedicarbonitrile
l-Chloro-l,l,2,2-tetrafluoroethane (HCFC-124a)
l-Chloro-l,l-difluoroethane (HCFC-142b)
1-Nitropyrene
2,2,4-'Wmethylhexamethylene diisocyanate
De
Minimis
Cone
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
Appx
VM
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 26,1997
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128903-21-9
306-83-2
2655-15-4
422-48-0
78-88-6
15646-96-5
95-95^
88-06-2
94-75-7
53404-37-8
1928-43-4
1929-73-3
94-80-4
2971-38-2
94-11-1
1320-18-9
2702-72-9
94-82-6
615-05-4
39156-41-7
95-80-7
120-83-2
75790-87-3
105-67-9
51-28-5
121-14-2
541-53-7
120-36-5
576-26-1
606-20-2
87-62-7
53-96-3
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
91-93-0
20325-40-0
111984-09-9
91-97-4
2,2-Dichloro-l,l,l,3,3-pentafluoropropane(HCFC-225aa)
2,2-Dichloro-l ,1 ,1 -trifluoroethane (HCFC-1 23)
2,3,5-Trimethylphenyl methylcarbamate
2,3-Dichloro-l,l,l,2,3-pentafluoropropane(HCFC-225ha)
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-Aminoanthraquinone
2-Bromo-2-nitropropane-l,3-diol(Bronopol)
2-Chloro-l,l,l,2-tetrailuoroethane(HCFC-124)
2-Chloro-l,l,l-trifluoroethane (HCFC-133a)
2-Chloroacetophenone
2-Ethoxyethanol
2-Mercaptobenzothiazole (MET)
2-Methoxyethanol
2-MethyHactonitrile
2-Methylpyiidine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
3,3-Dichloro-l,l,l,2,2-pentafluoropropane(HCFC-225ca)
3,3-Dichlorobenzidine
3,3 -Dichlorobenzidine dihydrochloride
3,3-Dichlorobenzidine sulfate
3,3'-Dimethoxybenzidine
3 ,3 '-Dimethoxybenzidine^^'-diisocyanate
3,3-Dimethoxybenzidine dihydrochloride (o-Dianisidine
dihydrochloride)
3,3'-Dimethoxybenzidine hydrochloride (o-Dianisidine
hydrochloride)
3,3'-Dimethyl-4,4'-diphenylene diisocyanate
1.0
1.0
1.0
1.0
1.0
1,0
1.0 X X
0.1 X X
1.0 X X
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1 X
1.0 XX
1.0
1.0 XX
1.0 XX
1.0 - X . . X
1.0 X
0.1
1.0
1.0 X X
0.1
0.1 X X
0.1
1.0
0.1
1.0
1.0
1.0 X
1.0
1.0
1.0 X
1.0 X
1.0 X
0.1 X
1.0
1.0
0.1 X
0.1
0.1
0.1 X
0.1
0.1
U240
,
U081
U101
P048
U105
P049
U106
U005
U359
P069
U191
U171
U073
U091
September 26,1997
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119-93-7
612-82-8
41766-75-0
460-35-5
563-47-3
542-76-7
55406-53-6
101-804
4128-73-8
804)5-7
101-14-4
101-61-1
101-77-9
139-65-1
534-52-1
60-09-3
92-67-1
60-11-7
75790-84-0
92-93-3
100-02-7
3697-24-3
99-59-2
99-55-8
57-97-6
194-59-2
71751-41-2
30560-19-1
75-07-0
60-35-5
75-05-8
98-86-2
62476-59-9
107-02-8
79-06-1
79-10-7
107-13-1
15972-60-8
116-06-3
309-00-2
107-18-6
107-05-1
107-11-9
319-84-6
134-32-7
7429-90-5
1344-28-1
20859-73-8
834-12-8
33089-61-1
3,3-Dimethylbenzidine (o-Tolidine)
3,3-Dimethylbenzidine dihydrochloride (o-Tolidine
dihydrochloride)
3,3-Dimethylbenzidine dihydrofluoride (o-Tolidine
dihydrofluoride)
3-Chloro-l,l,l-trifluoropropane (HCFC-253fb)
3-Chloro-2-methyl-l-propene
3-Chloropropionitrile
3-Iodo-2-propynyl butylcarbamate
4,4 -Diaminodiphenyl ether
4,4 -Diisocyanatodiphenyl ether
4,4-Isopropylidenediphenol
4,4-Methylenebis(2-chloroaniline) (MBOCA)
4,4'-Methylenebis(N,N-dimethyl)benzenamine
4,4'-Methylenediani]ine
4,4-Thiodianiline
4,6-Dinitro-o-cresol
4-Aminoazobenzene
4-Aminobiphenyl
4-Dimethylaminoazobenzene
4-Methyldiphenylmethane-3,4-diisocyanate
4-Nitrobiphenyl
4-Nitrophenol
5-Methylchrysene
5-N5tro-o-anisidine
5-Nitro-o-toluidine
7,12-Dimethylbenz(a)anthracene
7H-Dibenzo(c,g)carbazole
Abamectin [Avermectin Bl]
Acephate (Acetylphosphoramidothioic acid O,S-dimethyl ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
Acifluorfen, sodium salt [5-(2-Chloro-4-
(trifluoromemyI)phenoxy)-2-nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin [l,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-
hexachloro-l,4,4a,5,8,8a-hexahydro-
(l.alpha.,4.alpha.,4a.beta.,5.alpha,,8.a]pha,,8a.beta.)-]
Allyl alcohol
Allyl 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
0.1
0.1
0.1
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
0.1
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U095
P027
U158
P047
U093
U170
U181
U094
U001
U003
U004
P003
U007
U008
U009
P070
P004
POOS
U167
P006
September 26,1997
A-4
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
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^-
94-36-0
100-44-7
7440-41-7
91-59-8
57-57-8
82657-04-3
92-52^
108-60-1
111-91-1
111-44-4
103-23-1
542-88-1
56-35-9
10294-34-5
7637-07-2
314^0-9
53404-19-6
7726-95-6
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
Amitrole
Ammonia
Anilazine [4,6-DicMoro-N-(2-cMorophenyl)-l ,3,5-triazin-2-
amine]
Aniline
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazuie(6-Chloro-N-ethyl-N'-(l-niethylethyl)-l,3,5-triazine-
2,4-diamine)
Barium
Bendiocarb[2,2-Dimethyl-l,3-benzodioxol-4-ol
methylcarbamate]
Benflura]in(N-Butyl-N-ethyl-2,6-dinitro-4-(trifluoromethyl)
benzenamine)
Benomyl
Benz(a)anthracene
Benzal cMoride
Benzamide
Benzene
Benzidine
Benzo(a)phenanthrene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(rst)pentaphene
Benzoic trichloride (Benzotrichloride)
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
beta-Naphthylamine
beta-Propiolactone
Bifenthrin
Biphenyl
Bis(2-chloro-l-mefliylethyl)ether
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) adipate
Bis(chloromethyl) ether
Bis(rributyltin) oxide
Boron trichloride
Boron trifluoride
Bromacil(5-Bromo-6-methyl-3-(l-methy^)ropyl)-2,4-(lH,3H)-
pyrimidinedione)
Bromacil, lithium salt (2,4-(lH,3H)-Pyrimidinedione, 5-bromo-
6-methyl-3 (1-methylpropyl), lithium salt)
Bromine
Bromochlorodifluoromethane (Halon 1211)
Bromoform (Tribromomethane)
Bromomethane (Methyl bromide)
Bromotrifluoromethane (Halon 1301)
Bromoxynil (3,5-Dibromo-4-hydroxybenzonitrile)
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1
0.1
1,0 .
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
X
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
U011
U012
t
"~
U018
U017
U019
U021
U022
U064
U023
P028
P015
U168
U027
U024
U025
P016
U225
U029
September 26,1997
A-5
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
1689-99-2
357-57-3
141-32-2
123-72-8
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
28407-37-6
2602-46-2
16071-86-6
2832-40-8
81-88-9
3761-53-3
3118-97-6
842-07-9
97-56-3
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2
63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4
120-80-9
2439-01-2
133-90-4
57-74-9
115-28-6
90982-32-4
7782-50-5
10049-04-4
79-11-8
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
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 Black38
C.L Direct Blue 218
C.I Direct Blue 6
C.L Direct Brown 95
C.L Disperse Yellow 3
C.L Food Red 15
C.LFoodRed5
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 [!H-Isoindole-l,3(2H)-dione) 3a,4,7,7a-tetrahydro-2-
[(rrichloromethy])thio]-]
Carbaryl [1-Naphthalenol, methylcarbamate]
Carbofiiran
Carbon disulfide
Carbon tetrachloride
Carbonylsulfide
Carboxin (5,6-Dihydro-2-methyl-N-phenyl-l ,4-oxathiin-3-
carboxamide)
Catechol
Chinomethionat(6-Methyl-l,3-dithiolo[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]sulfonyl]ben2XDate)
Chlorine
Chlorine dioxide
Chloroacetic acid
Chlorobenzene
Chlorobenzilate [Benzeneacetic acid,4-chloro-.alpha,-(4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
Chlorodifluoromethane (HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
Chloropicrin
Chloroprene
Chlorotetrafluoroethane
Chlorothalonil [1,3-Benzenedicarbonitrile, 2,4,5,6-tetrachloro-]
1.0
1.0 X
1.0
1.0
1.0
0.1
1.0
1.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1 X
1.0
0.1 X X
1.0
1.0
1.0 X X
1.0 X X
1.0 X X
0.1 X X
1.0
1.0
1.0
1.0
1.0
0.1 X X
0.1
1.0
1.0
1.0
1.0
1.0 X X
1.0 X X
1.0
1.0 X
0.1 X X
1.0 X X
0.1 X
1.0
1.0 X X
1.0
1.0
P018
U014
P022
U211
U036
U037
U044
U045
U046
U210
September 26,1997
A-6
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
75-72-9
5598-13-0
64902-72-3
7440-47-3
7440-48-4
7440-50-8
8001-58-9
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6
21725-46-2
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
2303-164
25376-45-8
333-41-5
334-88-3
226-36-8
224-42-0
5385-75-1
192-65-4
53-70-3
189-64-0
191-30-0
132-64-9
124-73-2
84-74-2
1918-00-9
99-30-9
90454-18-5
25321-22-6
75-274
75-71-8
7543-4
75-09-2
Chlorotrifluoromethane (CFC-13)
Chlorpyrifos methyl (O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyridyl)phosphorothioate)
Chlorsulfuron (2-Chloro-N-[[(4-methoxy-6-methyl-l ,3,5-
triazin-2-yl)amino]carbonyl]benzenesulfonamide)
Chromium
Cobalt
Copper
Creosote
Cresol (mixed isomers)
Crotonaldehyde
Cumene
Cumene hydroperoxide
Cupferron [Benzeneamine, N-hydroxy-N-nitroso, ammonium
salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
CyfluthrintS-^-Dichloroethenyl)^-
dimethylcyclopropanecarboxylic acid, cyano(4-fluoro-3-
phenoxyphenyl)methyl ester)
Cyhalothrin(3-(2-Chloro-3,3,3-Jiifluoro-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-dunethyl-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)
DiaDate [Carbamothioic acid, bis(l-methylethyl)-S-(2,3-
dichloro-2-propenyl)ester]
Diaminotoluene (mixed isomers)
Diazinon
Diazomethane
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)anthracene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
Dibenzofuran
Dibromotetrafluoroethane (Halon 2402)
Dibutyl phthalate
Dicamba (3,6-Dichloro-2-methyoxybenzoic acid)
Dichloran (2,6-Dichloro-4-nitroanffine)
Dichloro-1 , 1 ,2-trifluoroethane
Dichlorbbenzene (mixed isomers)
Dichlorobromomethane
Dichlorodifluoromethane (CFC-12)
Dichlorofluoromethane (HCFC-21)
Dichloromethane (Methylene chloride)
1.0
1.0
1.0
0.1 X X
0.1
1.0
0.1
1.0 X
1.0 X
1.0
1.0
0.1
i.o :
1.0 X X
1.0
1.0
1.0
1.0
1.0
1.0 .X
1.0
1.0
1.0
0.1 XX
1.0 X
0.1 X
1.0
1.0
1.0
1.0
1.0
1.0 X X
1.0
1.0
1.0
0.1 X
1.0 X
1.0 X X
1.0
0.1 XX
U051
U052
U053
U055
U096
U056
U028
U062
U221
U063
U069
U075
U080
September 26, 1997
A-7
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
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
21644)7-0
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
100-41-4
74-85-1
107-21-1
75-21-8
96-45-7
151-56-4
75-34-3
52-85-7
60168-88-9
13356-08-6
Dichloropentafluoropropane
DicWorophene(2,2'-Methylenebis(4-chlorophenol)
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotrifluoroethane
Dichlorvos [Phosphoric acid, 2-dichloroethenyl dimethyl ester]
Diclofop methyl (2-[4-(2,4-Dichlorophenoxy)
phenoxy]propanoic acid, methyl ester)
Dicofol [Benzenemethanol, 4-chloro-.alpha.-4-chloropheny])-
.alpha.-{tricMoromethyl)-]
Dicyclopentadiene
Diepoxybutane
Diethanolamine
Diethatyl ethyl
DJethylphthalate
Diethylsulfate
Dfethyldiisocyanatobenzene
Diflubenznron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethqnn (2,3,-Dihydro-5,6-dimethyl-l,4-dithiin 1,1,4,4-
tetraoxide)
Dimethoate
Dimethyl chtorothiophosphate
Dimethyl phthalale
Dimethyl sulfate
Dimethylamine
Dimethylamine dicamba
Dimethylcarbamyl chloride
Dinitrobutyl phenol (Dinoseb)
Dinitrotoluene (mixed isomers)
Dinocap
Diphenamid
DJiphenylamine
Dipotassium endothall (7-Oxabicyclo(2.2.1)heptane-2,3-
dicarboxylic acid, dipotassium salt)
Dqoopyl isocinchomeronate
Disodium cyanodithioimidocarbonate
Diuron
Dodine (Dodecylguanidine monoacetate)
Epichlorohydrin
Ethoprop (Phosphorodithioic acid O-ethyl S,S-dipropyl ester)
Ethyl acrylate
Ethyl chloroformate
Ethyl dqiropylthiocarbamate (EPTC)
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethyleneimine (Aziridine)
Ethylidene dichloride
Famphur
Fenarimol (.a^)ha.-{2-Chlorophenyl)-.alpha.-4-chlorophenyl)-5-
pyrimidinemethanol)
Fenbutatin oxide (Hexakis(2-methyl-2- :
pheny]propyl)distannoxane)
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
0.1 X
1.0
1.0
0.1
0.1
1.0
0.1
0.1 X
1.0
1.0 X
1.0
1.0 X X
0.1 X
1.0
1.0
0.1 X
1.0
1.0
1.0
1.0
1.0 X
1.0
1.0
1.0
1.0
1.0
0.1 X
1.0
0.1
1.0
1.0 X X
1.0 X
1.0
1.0
0.1 XX
0.1 X
0.1 X
1.0 XX
1.0 XX
1.0
1.0
U085
U088
U090
P044
U102
U103
U092
U097
P020
U041
U113
U115
U116
P054
U076
P097
September 26,1997
A-8
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
66441-23-4
72490-01-8
39515-41-8
55-38-9
51630-58-1
14484-64-1
69806-50-4
2164-17-2
7782-41-4
51-21-8
69409-94-5
133-07-3
72178-02-0
50-00-0
64-18-6
76-13-1
76-44-8
87-68-3
118-74-1
77-47-4
67-72-1
1335-87-1
70-30-4
680-31-9
51235-04-2
67485-29-4
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554-44-0
193-39-5
13463-40-6
78-84-2
465-73-6
25311-71-1
4098-71-9
67-63-0
120-58-1
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-methyl-4-(methylthio) phenyl]
ester, phosphorothioic acid)
Fenvalerate (4-Chloro-alpha-(l-methylethyl)benzeneacetic acid
cyano(3-phenoxyphenyl)methyl ester)
Ferbam (Tris(dimethylcarbamodithioato-S,Sr)iron)
Fluazifop butyl (2-[4-[[5-(Trifluoromethyl)-2-pyridinyl]oxy]-
phenoxyjpropanoic acid, butyl ester)
Fluometuron [Urea, N,N-dimethyl-N'-[3-
(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
Fluva]inate(N-[2-Chloro-4-(trifluoromethyl)phenyl]-DL-
valine(+)-cyano(3-phenoxyphenyl)methyl ester)
Folpet
Fomesafen(5-(2-Chloro-4-(trifluoromethyl)phenoxy)-N
methylsulfonyl)-2-nitrobenzamide)
Formaldehyde
Formic acid
Freon 113 [Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
Heptachlor [1 ,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-tetrahydro-
4,7-methano-lH-indene]
Hexachloro-1 ,3-butadiene
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
Hexazinone
Hydramethylnon(Te1rahydro-5,5-dimethyl-2(lH)-
pyrimidinone[3-[4-(trifluoroniethyl)phenyl]-l-[2-[4-
(trifluoromethyl)phenyl]ethenyl]-2-propeny]idene]hydrazone)
Hydrazine
Hydrazine sulfate
Hydrochloric acid
Hydrogen cyanide
Hydrogen fluoride
Hydroquinone
IhiazaHl(l-[2-(2,4-Dichlorophenyl)-2-(2-propenyloxy)ethyl]-
IH-imidazole)
Ihdeno[l,2,3-cd]pyrene
Iron pentacarbonyl
Isobutyraldehyde
Isodrin
lsofenphos(2-[[Ethoxyl[(l-methylethyl)amino]
phosphinothioyl]oxy] benzoic acid 1-methylethyl ester)
Isophorone diisocyanate
Isopropyl alcohol (mfg-strong acid process)
Isosafrole
1.0
1.0
1.0
1.0
1.0
1.0 X
1.0
1.0
1.0 X
1.0
1.0
1.0
1.0
0.1 X
1.0 X
1.0 X
X X
1.0 X X
0.1 X X
1.0 X X
1.0 X X
1.0
1.0 X
0.1
1.0
1.0
0.1 X
0.1
1.0
1.0 X
1.0 X
1.0
1.0
1.0
1.0
1.0 X X
1.0
1.0
1.0
1.0 X X
P056
U122
U123
P059
U128
U127
U130
U131
U132
U133
P063
U134
U137
P060
U141
September 26,1997
A-9
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
77501-63-4
7439-92-1
58-89-9
330-55-2
554-13-2
108-39-4
99-65-0
108-38-3
121-75-5
108-31-6
109-77-3
12427-38-2
7439-96-5
93-65-2
7439-97-6
150-50-5
126-98-7
137-42-8
67-56-1
20354-26-1
2032-65-7
94-74-6
3653-48-3
12-43-5
96-33-3
79-22-1
78-93-3
60-34^
74-88-4
108-10-1
624-83-9
556-61-6
80-62-6
298-00-0
1634-04-4
74-95-3
101-68-8
101-68-8
9006-42-2
21087-64-5
7786-34-7
90-94-8
2212-67-1
1313-27-5
76-15-3
150-68-5
505-60-2
88671-89-0
Lactofen(5-(2-Chloio-4-(trJfluoromethyl)phenoxy)-2-nitro-2-
ethoxy-l-methyl-2-oxoethyl ester)
Lead
Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(l.alpha.,2.alpha.,3.beta.,4.alpha.,5.alpha.,6.beta.)-]
Linuron
Lithium carbonate
m-Cresol
m-Dinitrobenzene
m-Xylene
Malathion
Maleic anhydride
Malononitrile
Maneb [Carbamodithioic acid, 1,2-ethanediylbis-, manganese
complex]
Manganese
Mecoprop
Mercury
Merphos
Methacrylonitrile
Metham sodium (Sodium methyldithiocarbamate)
Methanol
Methazole (2-(3,4-Dichlorophenyl)-4-methyl-l ,2,4-
oxadiazolidine-3,5-dione)
Methiocarb
Methoxone ((4-Chloro-2-methylphenoxy) acetic acid) (MCPA)
Methoxone sodium salt ((4-Chloro-2-methy]phenoxy) acetate
sodium salt)
Methoxychlor Penzene, l,l'-(2,2,2-tricMoroethyldene)bis [4-
methoxy-]
Methyl acrylate
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate (Isothiocyanatomethane)
Methyl methacrylate
Methyl parathion
Methyl tert-butyl ether
Methylene bromide
Methylenebis(phenylisocyanate) (MBI)
Methylenebis(pheny]isocyanate) (MDI)
Metiram
Metribuzin
Mevinphos
Michler's ketone
Molinate (IH-Azepine-l carbothioic acid, hexahydro-S-ethyl
ester)
Molybdenum trioxide
Monochloropentafluoroethane (CFC-115)
Monuron
Mustard gas [Ethane, l,l'-thiobis[2-chloro-]
Myclobutanil (.alpha.-Butyl-.alpha.-{4-chlorophenyl)-lH-l ,2,4-
triazole-1 -propanenitrile)
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X*
X*
X
X
X
X
X
X
X
X
X
X
X
X
U129
U052
U239
U147
U149
U151
U154
U247
U156
U159
P068
U138
U161
P064
U162
P071
U068
September 26,1997
A-10
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
121-69-7
68-12-2
71-36-3
110-54-3
872-50-4
924-42-5
759-73-9
684-93-5
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
4549.40-0
59-89-2
16543-55-8
100-75-4
142-59-6
300-76-5
91-20-3
7440-02-0
1929-82-4
7697-37-2
139-13-9
98-95-3
1836-75-5
51-75-2
55-63-0
27314-13-2
90-04-0
134-29-2
95^8-7
528-29-0
95-53-4
636-21-5
95-47-6
2234-13-1
19044-88-3
20816-12-0
301-12-2
19666-30-9
42874-03-3
10028-15-6
104-94-9
95-69-2
106-47-8
104-12-1
120-71-8
106-44-5
100-25-4
100-01-6
156-10-5
N.N-Dimethylaniline
N,N-Dimethylformamide
n-Butyl alcohol
n-Hexane
N-Methyl-2-pyrrolidone
N-Methylolacrylamide
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitrosodi-n-butylamine
N-Nitrosodi-n-propylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylvinylamine
N-Nitrosomorpholine
N-Nitrosonornicotine
N-Nitrosopiperidine
Nabam
Naled
Naphthalene
Nickel
Nitrapyrin(2-Chloro-6-(trichloromethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
Nitrobenzene
Nitrofen [Benzene, 2,4-dichloro-l-(4-nitrophenoxy)-]
Nitrogen mustard [2-Chloro-N-(2-chloroethyl)-N-
methylethanamine]
Nitroglycerin
Norflurazon (4-Chloro-5-(methylamino)-2-[3-
(triflaoromethyI)phenyl]-3(2H)-pyridazinone)
o-Anisidine
o-Anisidine hydrochloride
o-Cresol
o-Dinitrobenzene
o-Toluidine
o-Toluidine hydrochloride
o-Xylene
Octachloronaphthalene
Oryza]in(4-(Dipropylamino)-3,5-dinitrobenzenesulfonamide)
Osmium tetroxide
Oxydemeton methyl (S-(2-{Ethy]su]finyl)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-Nitrosodiphenytamine
1.0
0.1
1.0
1.0
1.0
1.0
0.1
0.1
0.1
0.1
0.1
0.1
1.0
0.1
0.1
0.1
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
0.1
0.1
1.0
1.0
0.1
0.1
1.0
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
0.1
1.0
1.0
1.0
1.0
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
U031
U176
U177
U172
uni
U174
P082
P084
U179
U165
U169
P081
U052
U328
U222
U239
P087
P024
U239
P077
September 26, 1997
A-ll
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
106-50-3
106-42-3
123-63-7
1910-42-5
56-38-2
1114-71-2
40487-42-1
76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645^53-1
85-01-8
108-95-2
26002-80-2
57-41-0
75-44-5
7803-51-2
7664-38-2
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
p-Phenylenediamine
p-Xylene
Paraldehyde
Paraquat dichloride
Parathion [Phosphorothioic acid, O,O-diethyl-O-(4-nitrophenyl)
ester]
Pebulate (Butylethylcarbamothioic acid S-propyl ester)
Pendimethalin(N-(l-Ethylpropyl)-3,4-dimethyl-2,6-
dinitrobenzenamine)
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbital sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin(3-(2,2-Dichloroethenyl)-2,2-dimethylcyclopropane
carboxylic acid, (3-phenoxyphenyl)methyl ester)
Phenanthrene
Phenol
Phenothrin(2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (3-
phenoxyphenyl)methyl ester)
Phenytoin
Phosgene >
Phosphine
Phosphoric acid
Phosphorus (yellow or white)
Phthalic anhydride
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl (O-(2-(Diethy]amino)-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,N'-Bis(l-methylethyl)-6-methylthio-l,3,5-
triazine-2,4-diamine)
Pronamide
Propachlor(2-Chloro-N-(l-methylethyl)-N-phenylacetamide)
Propane sultone
Propanil(N-(3,4-Dichlorophenyl)propanamide)
Propargite
Propargyl alcohol
Propetamphos(3-[(Ethy]amino)methoxyphosphinothioyl]oxy]-
2-butenoic acid, 1-methylethyl ester)
Propiconazole (1 -[2-(2,4-Dichlorophenyl)-4-propyl-l ,3-
dioxoIan-2-yl]-methyl-lH-l,2,4,-triazole)
Propionaldehyde
Propoxur [Phenol, 2-{l-methylethoxy)-, methylcarbamate]
Propylene (Propene)
Propylene oxide
Propyleneimine
1.0
1.0 X*
1.0 X
1.0
1.0 X X
1.0 X X
1.0
1.0 X X
0.1 X X
1.0
1.0
1.0
1.0
1.0 X
1.0 X
1.0
0.1
1.0 X
1.0 X
1.0
1.0
1.0 X X
1.0
1.0
1.0
1.0
0.1 X
1.0
0.1
1.0 X
1.0 X
1.0
1.0
1.0 X X
1.0
0.1 X
1.0
1.0
1.0 X
1.0
1.0
1.0
1.0 X X
1.0
0.1
0.1 X
U239
U182
P089
U184
U188
P095
P096
U190
U192
U193
P102
P067
September 26,1997
A-12
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
110-86-1
91-22-5
106-51^
82-68-8
76578-14-8
10453-86-8
78-48-8
81-07-2
94-59-7
78-92-2
7782-49-2
74051-80-2
7440-22-4
122-34-9
26628-22-8
1982-69-0
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
Pyridine
Quinoline
Quinone
Quintozene (Pentachloronitrobenzene)
Quizalofop-ethyl(2-[4-[(6-Chloro-2-quinoxalinyl)oxy]phenoxy]
propanoic acid ethyl ester)
Resmethrin ([5-(Phenylrnethyl)-3-furanyl]methyl 2,2-dimethyl-
3 -(2-methyl-l -propenyl)cyclopropanecarboxy]ate])
S,S,S-Tributyltrithiophosphate (DBF)
Saccharin (manufacturing)
Saftole
sec-Butyl alcohol
Selenium
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 pentachlorophenate
Styrene
Styrene oxide
Sulfuric acid
Sulfuryl fluoride (Vikane)
Sulprofos (O-Ethyl O-[4-(methylthio)phenyl]phosphorodithioic
acid S-propyl ester)
Tebuthiuron(N-[5-(l,l-Dimethylethyl)-l,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]
Tetracycline hydrochloride
Tetramethrin(2,2-Dimethyl-3-(2-methyl-l-
propenyl)cyclopropanecarboxylic acid (1,3,4,5,6,7-hexahydro-
1 ,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)
Thiosemicarbazide
Thiourea
Thiram
Thorium dioxide
1.0 X X
1.0
1.0 X
1.0 X X
1.0
1.0
1.0
0.1 X
0.1 X X
1.0
1.0 X X
1.0
1.0 X X
1.0
1.0
1.0
1.0 X
1.0 X
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1 X X
1.0
1.0
1.0
1.0 X X
1.0
0.1 X
1.0
1.0 X X
1.0 X X
1.0
1.0 X
0.1 X
1.0 X
1.0
U196
U197
U185
U202
U203
P105
P058
U218
PI 16
U219
U244
September 26,1997
A-13
-------
TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
8001-35-2
10061-02-6
110-57-6
43121-43-3
2303-17-5
68-76-8
101200-48-0
1983-104
2155-70-6
52-68-6
76-02-8
79-01-6
75-69-4
57213-69-1
121-44-8
1582-09-8
26644-46-2
639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8
108-054
593-60-2
75-014
75-354
1330-20-7
7440-66-6
12122-67-7
Titanium tetrachloride
Toluene
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Toluene diisocyanate (mixed isomers)
Toxaphene
trans-l,3-Dichloropropene
trans-1 ,4-Dichloro-2-butene
Triadimefon(H4-Chlorophenoxy)-3,3-dimethyl-l-(lH-l,2,4-
triazol-l-yl)-2-butanone)
Triallate
Triaziquone [2,5-Cyclohexadiene-l,4-dione, 2,3,5-tris(l-
aziridinyl)-]
Tribenuron methyl (2<4-Methoxy-6-methyl-l,3,5-triazin-2-yl)-
methylamino)carbonyl)amino)sulfonyl)-, methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
Trichlorfon [Phosphonic acid, (2,2,2-trichloro-l-hydroxyethyl)-
,dimethyl ester]
Trichloroacetyl chloride
Trichloroethylene
Trichlorofluoromethane (CFC-11)
Triclopyr triethylammonium salt
Triethylamine
Trifluralin [Benezeneamine, 2,6-dinitro-N,N-dipropyl4-
(trifluoromethyl)-]
Triforine (N,N1-[l,4-Piperazinediylbis(2,2,2-
trichloroethylidene)] bisformamide)
Triphenyltin chloride
TriphenyMn 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 [Caibamodithioic acid, 1,2-ethanediylbis-, zinc complex]
1.0
1.0 X X
0.1
0.1
0.1 X
0.1 X X
0.1 X
1.0
1.0
1.0 X X
1.0
1.0
1.0
1.0
1.0
1.0
0.1 X X
1.0 X X
1.0
1.0 X
1.0
1.0
1.0
1.0
0.1 X X
0.1 X
0.1 X
1.0 X
1.0
0.1
0.1
0.1 X X
1.0 X X
1.0 X
1.0 X
1.0
U220
U223
P123
U228
U121
U235
U236
U238
U043
U078
U239
* as mixed isomers
September 26,1997
A-14
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING 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 (i.e., antimony,
nickel, etc.) as part of that chemical's structure.
Toxic chemical categories are subject to the 1 percent de minimis concentration
unless the substance involved meets the definition of an OSHA carcinogen 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.
September 26, 1997
A-15
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
Chlorophenols (0.1)
(5-x)
Where x = l to 5
Chromium Compounds (chromium VI compounds: 0.1; chromium EH compounds: 1.0)
Includes any unique chemical substance that contains chromium as pan 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 pan 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
822-06-0 Hexamethylene-l,6-diisocyanate
409 8-71-9 Isophorone diisocyanate
September 26,1997
A-16
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TRI FORM R GUIDANCE DOCUMENT
ELECTRICITY GENERATING FACILITIES
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)
R-(OCH2CH2)n-OR1
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 pan of that chemical's
infrastructure.
Manganese Compounds (1.0)
Includes any unique chemical substance that contains manganese as pan of that
chemical's infrastructure.
Mercury Compounds (1.0)
Includes any unique chemical substance that contains mercury as part of that
chemical's infrastructure.
Nickel Compounds (0.1)
Includes any unique chemical substance that contains nickel as pan of that
chemical's infrastructure.
Nicotine and salts (1.0)
Includes any unique chemical substance that contains nicotine or a nicotine salt as
pan of that chemical's infrastructure.
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Nitrate compounds (water dissociable; reportable only when in aqueous solution) (1.0)
Polybrominated Biphenyls (PBBs) (0.1)
(10-x)
Wherex = l 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
189-55-9 Benzo(rst)pentaphene
218-01-9 Benzo(a)phenanthrene
50-32-8 Benzo(a)pyrene
226-36-8 Dibenz(a,h)acridine
224-42-0 Dibenz(a,j)acridine
53-70-3 Dibenzo(a,h)anthracene
194-59-2 7H-Dibenzo(c,g)carbazole
5385-75-1 Dibenzo(a,e)fluoranthene
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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.
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APPENDIX B
BIBLIOGRAPHY
Electric Power Research Institute (EPRI), Inorganic Constituents in Fossil Fuel
Combustion Residuals. Volume I. August 1987.
Electric Power Research Institute (EPRI). Boiler Chemical Cleaning Waste Management
Manual. August 1992.
Kirk-Othmer Encyclopedia of Chemical Technology, 3rd Edition. "Power Generation".
Volume 20. John Wiley & Sons, Inc. New York, NY. 1996.
Office of Management and Budget, Standard Industrial Classification Manual, 1987.
Science Applications International Corporation. SIC Code Profile 49 Electric, Gas, and
Sanitary Services. 1996.
U.S. Environmental Protection Agency. Economic Analysis of the Final Rule to Add
Certain Industry Groups to EPCRA Section 313, Office of Pollution Prevention and
Toxics, 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 Solid Waste and Emergency Response.
Report to Congress on Wastes from the Combustion of Coal by Electric Utility Power
Plants. EPA 530-SW-88-002. 1988.
U.S. Environmental Protection Agency, Office of Water. Preliminary Data Summary for
the Steam Electric Point Source Category. EPA 821-R-96-010. July 1996.
U.S. Environmental Protection Agency, Office of Prevention, Pesticides and Toxic
Substances. The Effect of Combustion on Trace Metals in Coal and Oil Fuels for
Electric Generating Facilities. December 1996.
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U.S. Environmental Protection Agency, Office of Prevention, Pesticides and Toxic
Substances. The Release of Trace Metals From Limestone During Flue Gas
Desulfurization by Electric Utilities. March 1997.
U.S. Environmental Protection Agency, Office of Research and Development. Hydrogen
Chloride and Hydrogen Fluoride Emission Factors for the NAPAP Emission Inventory.
EPA 600/7-85-041. October 1985.
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APPENDIX C
SECTION 313 RELATED MATERIALS AND ELECTRONIC ACCESS TO
INFORMATION
Ordering information for the following documents can be obtained by calling the EPCRA
Hotline at 1-800-535-0202.
Common Synonyms for Section 313 Chemicals. EPA 745-R-95-008. March 1995.
Compilation of Air Pollutant Emission Factors, 5th Edition, Volume I: Stationary
Point and Area Sources (AP-42). EPA 450-AP-425ED. 1995.
Consolidated List of Chemicals Subject to Reporting Under the Act (Title III List of
Lists). 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
CHEMDAT8/WATER8
www.epa.gov/ttn/chief/software.htmlSwater8
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Clearinghouse for Inventories and Emission Factors (CHIEF)
www.epa.gov/ttn/chief/
Compilation of Air Pollutant Emission Factors (AP-42)
www.epa.gov/ttn/chieiyap42etc.html
EPA homepage
www.epa.gov
Federal Registers
www.epa.gov/EPA-TRI
MSDSs (Note: A number of organizations maintain databases that contain MSDS
information. The following is a short list of web sites with MSDS information.)
www.dehs.umn.edu/msds.html
www.nwfsc.noaa.gov/msds.html
www.chem.utah.edu/msds
SPECIATE
www.epa.gov/ttn/chief/software.htmWspeciate
TANKS
www.epa.gov/ttn/chief/tanks.html
TOXNET
www.nlm.nih.gov/pubs/factsheets/toxnetfs.html
TRI homepage
www.epa.gov/opptintr/tri
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