SERA United States Environmental Protection Agency Office of Pollution Prevention and Toxics Washington, DC 20460 January 1999 EPA 745-B-99-002 EPCRA Section 313 Industry Guidance COAL MINING FACILITIES Section 313 of the Emergency Planning and Community Right-to-Know Act Toxic Chemical Release Inventory ------- ------- &EPA Office of Pollution United States Prevention and Toxics Environmental Protection Agency Washington, DC 20460 January 1999 EPA 745-B-99-002 EPCRA Section 313 Industry Guidance COAL MINING FACILITIES Section 313 of the Emergency Planning and Community Right-to-Know Act Toxic Chemical Release Inventory ------- ------- TABLE OF CONTENTS OVERVIEW iii Acknowledgment v Chapter 1 - Introduction 1-1 1.0 PURPOSE 1-1 1.1 Background on EPCRA 1-2 Chapter 2 - Reporting Requirements 2-1 2.0 PURPOSE 2-1 2.1 Must You Report? 2-1 2.2 Definition of "Facility" , 2-3 2.3 SIC Code Determination 2-4 2.4 Number of Employees 2-6 2.5 Manufacturing, Processing, and Otherwise Use of EPCRA Section 313 Chemicals 2-7 2.6 Activity Thresholds 2-8 2.7 How Do You Report? 2-10 2.8 FormR 2-10 2.9 Form A 2-11 2.10 Trade Secrets 2-12 2.11 Recordkeeping 2-13 Chapter 3 - EPCRA Section 313 Threshold Determinations 3-1 3.0 PURPOSE 3-1 3.1 Step 1. Determining which EPCRA Section 313 chemicals are manufactured (including imported), processed, or otherwise used 3-1 3.2 Step 2. Determining the quantity of each EPCRA Section 313 chemical manufactured (including imported), processed, or otherwise used 3-8 3.2.1 Concentration Ranges for Threshold Determination 3-43 3.2.2 Evaluation of Exemptions 3-45 3.2.2.1 Coal Extraction Activities Exemption 3-45 3.2.2.2 Laboratory Activities Exemption 3-47 3.2.2.3 De minims Exemption 3-47 3.2.2.4 Article Exemption 3-51 3.2.2.5 Exemptions That Apply to the Otherwise Use of EPCRA Section 313 Chemicals 3-52 3.2.3 Additional Guidance on Threshold Calculations for Certain Activities , 3-54 3.2.3.1 On-site Reuse Activities 3-54 3.2.3.2 Remediation Activities 3-55 ------- 3.3 Step 3. Determine which EPCRA Section 313 chemicals exceed a threshold 3-55 Chapter 4 - Estimating Releases and Other Waste Management Quantities 4-1 4.0 PURPOSE 4-1 4.1 General Steps for Determining Releases and Other Waste Management Activities 4-3 4.1.1 Step 1. Identify Potential Sources of Chemical Release and Other Waste Management Activities 4-3 4.1.2 Step 2. Prepare a Process Flow Diagram 4-4 4.1.3 Step 3. Identify On-Site Releases, Off-Site Transfers and On-Site Waste Management Activity Types 4-4 4.1.4 Step 4. Determine the Most Appropriate Method(s) to Develop the Estimates for Releases and Other Waste Management Activity Quantities and Calculate the Estimates 4-15 4.1.4.1 Monitoring Data or Direct Measurement (code M) 4-16 4.1.4.2 Mass Balance (code C) 4-17 4.1.4.3 Emissions Factors (code E) 4-19 4.1.4.4 Engineering Calculations (code O) 4-19 4.1.4.5 Estimating Releases and Other Waste Management Quantities 4-20 4.1.5 Other Form R Elements 4-24 4.1.5.1 Maximum Amount On-Site (Part n, Section 4.1 of Form R) . 4-24 4.1.5.2 Production Ratio or Activity Index (Part II, Section 8.9 of Form R) 4-24 4.1.5.3 Source Reduction (Part II, Sections 8.10 and 8.11 of Form R) 4-25 4.2 Calculating Release and Other Waste Management Estimates at Coal Mining Facilities 4-26 4.2.1 Coal Mining Overview 4-26 4.2.2 Fugitive Air Emissions, Section 5.1 of Form R 4-33 4.2.3 Stack or Point Source Air Emissions, Section 5.2 of Form R 4-34 4.2.4 Discharges to Receiving Streams or Water Bodies, Section 5.3 of Form R; and Discharges to Publicly Owned Treatment Works (POTWs), Section 6.1 of Form R 4-39 4.2.5 Disposal to Land On-site, Section 5.5 of Form R 4-42 4.2.6 Transfers Off-site, Section 6.2 of Form R 4-44 4.2.7 On-site Waste Management Methods, Section 7A, 7B, and 7C of Form R 4-45 4.2.8 Source Reduction and Recycling Activities 4-46 4.2.9 Source Reduction Activities 4-47 Appendix A - TRI Guidance Resources A-l 11 ------- OVERVIEW On May 1,1997, the U.S. Environmental Protection Agency (EPA) promulgated a final rule (62 FR 23834) adding several new industrial sectors to the list of facilities subject to the Emergency Planning and Community Right-To-Know Act (EPCRA) Section 313 reporting requirements. Facilities affected by this rule are subject to the annual reporting requirements beginning with activities conducted during the 1998 calendar year, with their first reports due by July 1,1999. This document supersedes the document entitled Section 313 Emergency Planning and Community Right-to-Know Act, Guidance for Coal Mining Recovery Facilities, dated October 1997. It is intended to assist establishments and facilities designated by Standard Industrial Classification (SIC) code 12 (except 1241) in making compliance determinations under the EPCRA Section 313 reporting requirements and preparing Form R(s) or the Form A.certification statement(s) as required. The EPCRA Section 313 program is commonly referred to as the Toxic Chemical Release Inventory (TRI) program. The principal differences in the new document include the following: • More detailed examples; • Additional interpretive guidance prepared by EPA on various issues specific to Coal Mining facilities; • Industry process issues not discussed in the earlier document; and • General format changes for program consistency. This document is designed to be a supplement to the Toxic Chemical Release Inventory Reporting Forms and Instructions (TRI Forms and Instructions), issued annually. It is organized to provide a step-by-step guide to compliance with EPCRA Section 313, starting with how you determine if your facility must report through completion of the Form R or Form A. While certain information provided hi this document may be used as a reference, specific information available to facilities, such as amounts of chemicals in mixtures and other trade name products used at the facility, may be more accurate and more appropriate for use in developing threshold determinations and estimating releases and other waste management amounts. Under EPCRA Section 313, facilities are instructed to use the best "readily available data", or when such data are not available, "reasonable estimates", in fulfilling their reporting requirements. This document is organized in the following manner. Chapter 1 serves as an introduction to TRI reporting and provides a brief background on the Emergency Planning and Community Right-to-Know Act and information on where to obtain additional compliance assistance. Chapter 2 begins with how to determine if your facility must report. This determination is based on your answers to a series of four questions: 1. Is your facility's primary SIC code on the EPCRA Section 313 list? 111 ------- 2. Does your facility employ ten or more full time equivalent employees? 3. Does your facility manufacture, process, or otherwise use any EPCRA Section 313 chemicals? 4. Does your facility exceed any of the activity thresholds for an EPCRA Section 313 chemical? If the answer to ANY ONE of the four questions above is "No" you are not required to submit an EPCRA Section 313 report. If you answer "Yes" to ALL four questions, the next step is deterrnining which form(s), Form R or Form A, your facility should file. Chapter 2 provides detailed information on the requirements for each kind of submission. Chapter 2 concludes with a discussion on how you address trade secrets in your reporting and the kinds of records you should be keeping to support your reporting. Chapter 3 discusses how you calculate the activity thresholds (manufacture, process, and otherwise use) for the EPCRA Section 313 chemicals. Information is provided on how you determine which EPCRA Section 313 chemicals your facility manufactures, processes, or otherwise uses and how you calculate the quantities of each. Detailed information is also provided on the various exemptions. Chapter 3 concludes with a discussion of how to determine which EPCRA Section 313 chemicals exceed a reporting threshold, including focused discussions on issues specific to coal mining faculties. Chapter 4 discusses how you calculate the release and other waste management amounts for those EPCRA Section 313 chemicals for which you must prepare a report. This chapter provides a step-by-step approach designed to minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical and any potential sources or types of releases and other waste management activities that your facility may conduct. This procedure consists of the following steps: • Identification of potential sources of EPCRA Section 313 chemicals released and otherwise managed as wastes; • Preparation of a detailed process flow diagram; • Identification of the potential types of releases and other waste management activities from each source; and • Determination of the most appropriate methods for estimating the quantities of listed EPCRA Section 313 chemical releases and other waste management activities. The main part of Chapter 4 is organized around activities common to coal mining facilities where EPCRA Section 313 chemicals are manufactured, processed, or otherwise used. A list of EPCRA Section 313 chemicals likely to be manufactured, processed, or otherwise used by coal mining facilities; process descriptions; guidance on thresholds determinations; release and other waste management estimation techniques; and problems these types of facilities are likely to face in complying with EPCRA Section 313 are also presented in this chapter. IV ------- This document includes examples of chemical management activities that coal mining facilities may conduct, illustrating how these activities should be considered for EPCRA Section 313 reporting purposes. This chapter also notes area where potential errors in reporting might be encountered generally by coal mining facilities, which are based on information from written comments received from industry representatives, as well as from comments made by participants in EPA-sponsored EPCRA workshops. ACKNOWLEDGMENT EPA would like to recognize the valuable contributions made by staff at Kennecott Energy and Thunder Basin Coal Company, whose industry insight and understanding of EPCRA Section 313 requirements have greatly assisted in increasing the utility of this document. Special thanks go to Bob Green, Environmental Manager at Kennecott Energy and Jere Fiore, Environmental Manager at Thunder Basin Coal Company. ------- ------- Chapter 1 - Introduction 1.0 PURPOSE The purpose of this guidance document is to assist facilities in SIC 12 (except 1241) comply with the reporting requirements of Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) and of Section 6607 of the Pollution Prevention Act of 1990 (PPA), commonly referred to as the Toxic Release Inventory (TRI). On May 1, 1997, EPA promulgated a rule (62 PR 23834) to require coal mining facilities, along with other industry groups, to be included on the list of facilities subject to the EPCRA Section 313 reporting requirements. The new facilities are subject to annual reporting requirements beginning with activities occurring in the 1998 calendar year, with the first reports due by July 1,1999. This document explains the EPCRA Section 313 and PPA Section 6607 reporting requirements (collectively referred to as the EPCRA Section 313 reporting requirements) and discusses specific release and other waste management activities encountered at many facilities in this industry. Because each facility is unique, the recommendations presented may have to be adjusted to the specific nature of operations at your facility. This document supersedes the document entitled Section 313 Emergency Planning and Community Right-to-Know Act, Guidance for Coal Mining Facilities, dated October 1997. The document is intended to supplement the Toxic Chemical Release Inventory Reporting Forms and Instructions (TRI Forms and Instructions) document which is updated and published annually by the U.S. Environmental Protection Agency (EPA). It is essential that you use the most current version of the TRI Forms and Instructions to determine whether (and how) you should report. Changes or modifications to TRI reporting requkements are reflected in the annual TRI Forms and Instructions and should be reviewed before compiling information for the report. The objectives of this manual are to: • Clarify EPCRA Section 313 requirements for industry; • Increase the accuracy and completeness of the data being reported by coal mining facilities; and • Reduce the level of effort expended by those facilities that prepare an EPCRA Section 313 report. While it is not possible to anticipate every potential issue or question that may apply to your facility, this document attempts to address those issues most prevalent or common to coal mining facilities. Facilities should also rely on EPA's Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Form document to assist in providing complete and accurate information for EPCRA Section 313 reporting. Additional discussion addressing specific issues can be found in EPA's current version of EPCRA Section 313 Questions and Answers. All of these documents are available on the EPA's TRI website 1-1 ------- (http://www.epa.gov/opptintr/tri) or by contacting the EPCRA Hotline at 1-800-424-9346. In the Washington, DC metropolitan area, call 703-412-9810. The EPCRA TDD Hotline number is 1- 800-553-7672 or 703-412-3323 for calls within the Washington, DC metropolitan area. 1.1 Background on EPCRA One of EPCRA's primary goals is to increase the public's knowledge of, and access to, information on both the presence and release and other waste management activities of EPCRA Section 313 chemicals in their communities. Under EPCRA Section 313, certain facilities (see SIC code discussion, Chapter 2.3) exceeding certain thresholds (see Chapter 2.5) are required to submit reports (commonly referred to as Form Rs or Form A certification statements) annually for over 600 EPCRA Section 313 chemicals and chemical categories and the amounts that enter an environmental medium or are otherwise managed as waste, even if there are no release or other waste management quantities associated with these chemicals. Chemicals are considered by EPA for inclusion on the EPCRA Section 313 list based on their potential for acute health effects, chronic health effects, and environmental effects. Chemicals may be added or deleted from the list. Therefore, before completing your annual report, be sure to check the most current list included with the TRI Forms and Instructions when evaluating the chemicals managed at your facility. Copies of the reporting package can be requested from the EPCRA Hotline, as indicated above, or from the Internet at http://www.epa.gov/opptintr/tri/report.htm. All facilities meeting the EPCRA Section 313 reporting criteria must submit either a Form R or Form A. A separate submission is required for each EPCRA Section 313 chemical or chemical category that is manufactured (including imported), processed, or otherwise used above the reporting threshold. Reports must be submitted to EPA and State or Tribal governments, on or before July 1, for activities in the previous calendar year. The owner/operator of the facility on July 1 of the reporting deadline is primarily responsible for the report, even if the owner/operator did not own the facility during the reporting year. However, property owners with no business interest in the operation of the facility, for example, owners of an industrial park who only have a real estate interest, are not responsible for any reporting requirements. EPCRA also mandates that EPA establish and maintain a publicly available database consisting of the information reported under Section 313, and applicable PPA information. This database, known as the Toxic Chemical Release Inventory (TRI), can be accessed through the following sources: • National Library of Medicine (NLM) TOXNET on-line system; • EPA's Internet site, http://www.epa.gov/opptintr/tri; • Envirofacts Warehouse Internet site, http.7/www.epa.gov/enviro/html/tris/tris_overview.html; • CD-ROM from the Government Printing Office (GPO); • Microfiche in public libraries; • Magnetic tape and diskettes from the National Technical Information Service; and • EPA's annual TRI data release materials (summary information). 1-2 ------- In addition to being a resource for the public, TRI is also used in the research and development of regulations related to EPCRA Section 313 chemicals. Alternative Submission (Form A) To reduce the burden for facilities that must comply with EPCRA Section 313, EPA has established an alternate threshold of one million pounds manufactured, processed, or otherwise used for facilities with total annual reportable amounts of 500 pounds or less of the EPCRA Section 313 chemical. Provided the facility does not exceed either the reportable amount or the alternate threshold, the facility may file a certification form (Form A) rather than a Form R. By filing the Form A, the facility certifies that it did not exceed the reportable amount or exceed the alternate threshold (see Chapter 2.9 for more detail). Note that the annual reportable amount includes the quantity of EPCRA Section 313 chemicals in all production-related waste management activities, not just releases (see the waste management discussion in Chapter 4 for more detail). Also, a covered facility must submit either a Form A or a Form R for each EPCRA Section 313 chemical exceeding an applicable reporting threshold even if there are no releases and other waste management quantities. Enforcement Violation of Section 313 reporting provisions may result in federal civil penalties of up to $27,500 per day. State enforcement provisions may also be applicable depending on the state's adoption of any "EPCRA Section 313-like" reporting regulations. Regulatory Assistance Resources The TRI Forms and Instructions also contain a discussion of common problems in completing the Form R. You are encouraged to read this section before filling out the Form R (or Form A) for your facility. If, after reading both the TRI Forms and Instructions and this guidance document, you still have questions about EPCRA Section 313 reporting, please contact the EPCRA Hotline at 1-800-424-9346 or 703-412-9810 for calls within the Washington, DC metropolitan area. The EPCRA TDD Hotline number is 1-800-553-7672 or 703-412-3323 for calls within the Washington, DC metropolitan area. Assistance is also available from the designated EPCRA Section 313 Coordinator in the EPA regional office and the EPCRA contact in your state (see the TRI Forms and Instructions for a current list of these contacts). Appendix A contains a list of additional reference sources. 1-3 ------- ------- Chapter 2 - Reporting Requirements 2.0 PURPOSE The purpose of this chapter is to help you determine whether you must prepare an EPCRA Section 313 submission(s) and, if so, what kind of a submission(s) you should prepare (Form R or Form A). This chapter presents the EPCRA Section 313 reporting requirements to help you determine whether these requirements apply to your facility. It also discusses the records that you must keep. The following terms and concepts are described in this chapter to help you understand the scope of Section 313 reporting and determine whether you need to report, including: • Definition of facility; • SIC code determination; • Employee determination; • Definitions of manufacture, process, and otherwise use; and • Determination of whether you exceed one of the thresholds. 2.1 Must You Report? How do you determine if your facility must prepare an EPCRA Section 313 report? This is decided by your answers to the following four questions (illustrated by Figure 2-1): 1) Is the primary SIC code(s) for your facility included in the list covered by EPCRA Section 313 reporting (see Chapter 2.3)? 2) Does your facility employ 10 or more full time employees or the equivalent (see Chapter 2.4)? 3) Does your facility manufacture (which includes importation), process, or otherwise use EPCRA Section 313 chemicals (see Chapter 2.5)? 4) Does your facility exceed any applicable thresholds of EPCRA Section 313 chemicals (25,000 pounds per year for manufacturing; 25,000 pounds per year for processing; or 10,000 pounds per year for otherwise use - see Chapter 2.6)? If you answered "No" to any of the four questions above, you are not required to prepare any submissions under EPCRA Section 313. If you answered "Yes" to ALL of the first three questions, you must perform a threshold determination for each EPCRA Section 313 chemical at the facility, and submit a Form R or Form A for each chemical exceeding a threshold. 2-1 ------- Figure 2-1: TRI Reporting Determination Diagram Is Your Facility in a Covered SIC Code with the necessary qualifiers? (See Chapter 2.3) Does Your Facility Have 10 or More Full- Time Employees or the Equivalent? (See Chapter 2.4) Does Your Facility Manufacture, Process, or Otherwise Use Any EPCRA Section 313 Chemicals? (See Chapter 2.5) YES V Does Your Facility Exceed Any of the Thresholds for a Chemical (after excluding quantities that are exempt from threshold calculations)? (See Chapter 2.6) YES AN EPCRA SECTION 313 REPORT IS REQUIRED FOR THIS CHEMICAL YES V NO NO NO NO STOP NO EPCRA SECTION 313 REPORTS REQUIRED FOR ANY CHEMICALS Is the amount manufactured, OR processed, OR otherwise used less than or equal to 1,000,000 pounds AND is the reportable amount less than or equal to 500 Ibs/yr? (See Chapters 2.7,2.8, and 2.9) YES FORM A or FORM R IS REQUIRED FOR THIS CHEMICAL NO FORM R IS REQUIRED FOR THIS CHEMICAL (FORM A CANNOT BE SUBMITTED) 2-2 ------- 2.2 Definition of "Facility" To understand the applicability of EPCRA Section 313, you must first understand how EPCRA defines a facility. The term "facility" is defined as "all buildings, equipment, structures, and other stationary items which are located on a single site or on contiguous or adjacent sites and which are owned or operated by the same person (or by any person which controls, is controlled by, or is under common control, with such person). A facility may contain more than one establishment" (40 CFR 372.3). An "establishment" is defined as "an economic unit, generally at a single physical location, where business is conducted, or services or industrial operations are performed" (40 CFR 372.3). EPA recognizes that some facilities have unique and separate activities ("establishments") taking place at the same facility, and for some of these facilities it may be easier and more appropriate for individual establishments to manage their chemical usage and management information separately. EPA provides for these cases and allows individual establishments at the same facility to report separately. However, for threshold determinations, quantities of EPCRA Section 313 chemicals manufactured, processed, or otherwise used in all establishments in that facility must be combined and considered together. Also, the combined releases and other waste management activities reported separately for each establishment must equal those for the facility as a whole. Example -Multiple Establishments . Your facility is cqmpjised'Of two different establishments, "with SIC codes covered by EPCRA Section 313, One establishment used' 3,000 pounds of an EPCRA Section 313 chemical for boiler cleaning during the year.! Another establishment used 8,000 pounds of the same chemical asra coolant during 'the same year. Both 2 ' activities constitute an ''otherwise use" of the'listed EPCRA Section 313 chemical (as presented in Section 2.5- and described in detail in Chapter 3) and together, the total quantity otherwise used at"the facility exceeded the ! 10,000 pound otherwise use threshold for the year. If jour facility "meets the employee threshold, you must file either a Form R or a Form A,for that chemical: EPA allows multi-establishment facilities to submit Form Rs •. from each establishment for an EPCRA Section 313 chemical isjhen thresholds have been exceeded at 1he *•*[ facility level Please note that Form A eligibility is also'made at the facility-lfvel, but only one* Form A can be submitted per, chemjca^for the entire facility. ,__'/<•"',, " •'' * -'V *!/ Contiguous and/or Adjacent Facilities. In defining the parameters of your facility, you must consider all buildings and other stationary items located on multiple contiguous or adjacent sites that are owned or operated by the same person for EPCRA reporting purposes. For example, an industrial park could contain a manufacturing company and a solvent recovery operation, both operated independently, but owned by the same parent company. Since the two establishments are contiguous or adjacent to each other, they are considered one "facility." The amount of each EPCRA Section 313 chemical manufactured, processed, or otherwise used and the number of employees must be aggregated for all of these contiguous or adjacent sites to determine whether the entire facility meets reporting thresholds. If a company's operations are carried out at two distinctly separate, physical sites that are not contiguous or adjacent, that company is operating two separate facilities for the purposes of EPCRA reporting. The company, therefore, must make SIC code, employee, threshold determinations, and if appropriate, release and other waste management estimates individually for each facility. 2-3 ------- If two establishments owned or operated by the same company are connected to each other by a piece of property that is owned by one of the establishments or the same parent corporation, or if they are separated by an easement (e.g., railroad tracks, public road, public catchment basin), they are still considered to be contiguous or adjacent and are therefore part of the same facility. Both "establishments" may report together as the same facility or they may report separately provided threshold determinations are based on activities at the entire facility and that the sum of the releases of the establishments reflects the total releases of the whole facility. Facility operations that are not connected to each other by a piece of property, that is commonly owned, controlled, or operated by the same person(s), are not considered contiguous and may be considered two separate facilities. However, if these operations are relatively near each other, they may be considered adjacent; in which case, they would be part of the same facility. 2.3 SIC Code Determination Facilities with the SIC codes presented in Table 2-1 are covered by the EPCRA Section 313 reporting requirements. For assistance in determining which SIC code best suits your facility, refer to Standard Industrial Classification Manual, 1987, published by the Office of Management and Budget. Table 2-1 SIC Codes Covered by EPCRA Section 313 Reporting SIC Code Industry Sectors SIC Codes 10 12 20 through 39 4911,4931, and 4939 4953 5169 5171 7389 Industry Metal Mining Coal Mining Manufacturing Electric and Other Services and Combination Utilities Refuse Systems Chemicals and Allied Products Petroleum Bulk Stations and Terminals Business Services Qualifiers Except SIC codes 1011, 1081, and 1094 Except SIC code 1241 None Limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce Limited to facilities regulated under RCRA Subtitle C None None Limited to facilities primarily engaged in solvent recovery services on a contract or fee basis Facilities in SIC code 12, except 1241 (contract mining), must prepare Form R and/or Form A submissions if they exceed the employee and chemical activity thresholds. While SIC code 1241 is not a covered SIC code, any contract mining activities that occur at a covered 2-4 ------- facility (e.g., coal mine) would be applied to the facility's employee and chemical activity thresholds. While you are currently required to determine your facility's reporting eligibility based on the SIC code system described above, it is important to be aware that the SIC code system will be replaced by a new system in the future. On April 9, 1997 (62 FR 17287), the Office of Management and Budget promulgated the North American Industrial Classification System (NAICS). NAICS is a new economic classification system that replaces the SIC code system as a means of classifying economic activities for economic forecasting and statistical purposes. The transition to the new NAICS may require statutory and/or regulatory actions. As a result, the SIC code system is still required to be used as the mechanism to determine your facility's reporting eligibility. EPA will issue notice in the Federal Register to inform you and other EPCRA Section 313 facilities of its plans to adopt the NAICS and how facilities should make their NAICS code determination. Primary SIC Code Determination. Assuming your facility has several establishments with different SIC codes that are owned or operated by the same entity, you will need to determine if your facility has a primary SIC code that is subject to EPCRA Section 313. Your facility is subject to EPCRA Section 313 reporting requirements if: • All the establishments have SIC codes covered by EPCRA Section 313; OR • The total value of the products shipped or services provided at establishments with covered SIC codes is greater than 50% of the value of the entire facility's products and services; OR • Any one of the establishments with a covered SIC code ships and/or produces products or provides services whose value exceeds the value of services provided or products produced and/or shipped by all of the other establishments within the facility on an individual basis. To determine the value of production or service attributable to a particular establishment, you can subtract the product or service value obtained from other establishments 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. Auxiliary Facilities. Some companies may own and/or operate a non-contiguous and non-adjacent facility that primarily supports a covered EPCRA Section 313 facility. These auxiliary facilities assume the SIC code of a covered facility that it directly supports. For example, an off-site warehouse that directly supports a covered coal mine (SIC code 1221) must assume the SIC code 1221 itself. For the purposes of EPCRA Section 313, auxiliary facilities must be engaged in performing support services for another facility or establishment within a covered facility. Therefore, if an auxiliary facility's primary function is to support/service a covered coal mining facility, the auxiliary facility may assume the SIC code of the main facility and may then be covered by the EPCRA Section 313 reporting requirements for purposes of the facility's SIC code. 2-5 ------- 2.4 Number of Employees Facilities must also meet or exceed the 10 or more full-time employees or equivalent criterion to be subject to EPCRA Section 313 reporting requirements. A full-time employee equivalent is defined as a work year of 2,000 hours. If your facility's staff (including contractors and certain other non-company personnel) work 20,000 or more hours in a calendar year, you meet the 10 or more full-time employee criterion. While many facilities may easily exceed this criterion, your facility may be small or highly automated and your on-site staff may be small. In these cases, in particular, you should carefully consider all personnel supporting your operations to determine if you meet the 10 or more full-time employee criterion. The following personnel and time should be included in your employee calculations: • Owners working at the facility; • Operations staff; • Clerical staff; • Temporary employees; • Sales personnel; • Truck drivers (employed by the facility); • Other off-site facility employees directly supporting the facility; • Paid vacation and sick leave; and • Contractor employees (excluding contract truck drivers). In general, if an individual is employed or hired to work at the facility, all the hours worked by that individual must be counted in determining if the 20,000 hour criterion has been met. 2-6 ------- Example - Calculating Employees : - , Your facility has four full-time employees working"2,000 hours/year in .the mine and three full-timer employees working 2-.000 hours/year in the preparation plant. There is also one full-time sales person and a delivery truck driver (employed by the facility) assigned to the plant? xeach working 2,000 hours/year but predominantly not at- the facility. The wastewatet treatment plant (WWTP)' (on-site and owned by^fie facility) is operated V .?• contractor who spent 1,000 hours working at th& plant during the.year. The hours of the employees and the ; WWTP contractor are tracked By controlled-access card reader (scan in/out).system. Finally, you built an ^r addition to the plant warehouse during Jhe'year,'using four contractor personnel who were dn site full time for- '^ six months (working on average of 1,000 hours-each based on invoices). Jou would calculate thKnumber of - full-time employee equivalents as follows: "? - '"* " -," *••" „ .- - - * Hours for your nine full-time employees~(&ur mining personnel, three.plant personnel, one ^ „ salesperson, and one delivery truck driver) for the yeatare: 9'employees x 2,000 hours/year—18,000 hours; ''.;'" • Hours for the wastewater treatmeiit plantToperator are: ' , , , X . - '. - I'.OOO hours* and " - * • Hours for the construction crew are: • - ' " 4 conttactors x 1,000 hours =4,000 hours. This is a total of 23,000 hours for me year, which-is above the 20,000 lioursifyear threshold; therefore, you meet the employee criterion. - » " '- - -' - "' POSSIBLE ERROR - Construction Workers , Remember to include construction contractors, even iflnvolved in non-process related construction activities (e.g,, office building renovations or constractipn) in your calculation/ -- * ' , V 2.5 Manufacturing. Processing, and Otherwise Use of EPCRA Section 313 Chemicals If you have determined that your facility meets the SIC code and employee threshold determinations, you must determine what EPCRA Section 313 chemicals are manufactured, processed, or otherwise used at your facility during the reporting year and whether an activity threshold was exceeded. This section of the chapter will introduce the terms and concepts behind this determination; whereas, Chapter 3 will take you through a detailed step-by- step process to determine whether you need to report for any EPCRA Section 313 chemicals. Identifying Chemicals. If you are in a covered SIC code and have 10 or more full-time employee equivalents, you must determine which EPCRA Section 313 chemicals are manufactured, processed, or otherwise used at your facility in excess of threshold quantities. To assist in doing this, you should prepare a list of all chemicals manufactured, processed, or otherwise used by all establishments at the facility, including the chemicals present in mixtures and other trade name products and managed in wastes received from off-site. This list should then be compared to the CURRENT list of EPCRA Section 313 chemicals found in the TRI Forms and Instructions document for that reporting year (available from the EPCRA Hotline, 1-800-424- 2-7 ------- 9346 or 703-412-9810 for calls within the Washington, DC metropolitan area, or at the website, http://www.epa.gov/opptintr/tri). In addition to the individually listed chemicals, the list of EPCRA Section 313 chemicals includes several chemical categories (discussed in detail in Chapter 3). You must include chemical compounds that are members included in any of these categories when evaluating activities at the facility for threshold determinations and release and other waste management calculations. Once you identify the EPCRA Section 313 chemicals and chemical categories at your facility, you must evaluate the activities involving each chemical or chemical category and determine whether any activity thresholds have been met. Note that chemicals are periodically added, delisted, or modified. Therefore, it is imperative that you refer to the appropriate reporting year's list. Also, note that a list of synonyms for EPCRA Section 313 chemicals can be found in the EPA publication Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community Right-To-Know Act (updated March 1995). 2.6 Activity Thresholds There are three activity thresholds for the EPCRA Section 313 chemicals defined in EPCRA Section 313: manufacturing (which includes importing), processing, and otherwise use. The activity thresholds are 25,000 pounds per year for manufacturing, 25,000 pounds per year for processing, and 10,000 pounds per year for otherwise use. These thresholds apply to each chemical individually. The determination is based solely on the quantity actually manufactured (including imported), processed, or otherwise used. Only the amounts of the listed EPCRA Section 313 chemical that meet activity definitions are considered towards threshold determinations. Any other amounts not considered to be manufactured, processed, or otherwise used are not considered toward threshold determinations. For example, EPCRA Section 313 chemicals that are brought on-site (excluding amounts imported) and stored for future use or disposal, but are not incorporated into a product for distribution or are not otherwise used on-site during the reporting year, are NOT considered towards any activity threshold for that reporting year. More detailed explanations of threshold activities (manufactured, processed, or otherwise used), with examples of each are found in Chapter 3. These terms are briefly defined in Table 2-2, with a detailed discussion to follow. 2-8 ------- Table 2-2 Activity Thresholds Activity Definition Threshold Manufacture To produce, prepare, import, or compound an EPCRA Section 313 chemical. "Manufacture" applies to an EPCRA Section 313 chemical that is produced coincidentally during the manufacture, processing, otherwise use, or disposal of another chemical or mixture of chemicals as a byproduct or impurity. Examples would be the production of ammonia or nitrate compounds in a wastewater treatment system or the creation of metal compounds during the combustion of coal. 25,000 Process The preparation of an EPCRA Section 313 chemical, after its manufacture, for distribution in commerce: (1) In the same form or physical state as, or in a different form or physical state from, that in which it was received by the person so preparing such chemical; or (2) As part of an article containing the EPCRA Section 313 chemical. For example, if you receive a mixture containing an EPCRA Section 313 chemical and package it, including transferring from a storage tank to a tank truck, and then distribute it into commerce, this chemical has been processed by your facility. 25,000 Otherwise Use Generally, use of an EPCRA Section 313 chemical that does not fall under the manufacture or process definitions is classified as otherwise use. An EPCRA Section 313 chemical that is otherwise used is not intentionally incorporated into a product that is distributed in commerce, but may be used instead as a manufacturing or processing aid (e.g., catalyst), in waste processing, or as a fuel (including waste fuel). For example, methanol used as a cleaning solvent is classified as otherwise used. Otherwise use means "any use of a toxic chemical contained in a mixture or other trade name product or waste, that is not covered by the terms "manufacture" or "process." Otherwise use of an EPCRA Section 313 chemical does not include disposal, stabilization (without subsequent distribution in commerce), or treatment for destruction unless the: 1) EPCRA 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) EPCRA Section 313 chemical that was disposed, stabilized, or treated for destruction that was manufactured as a result of waste management activities on materials received from off-site for the purposes of further waste management activities." 10,000 2-9 ------- There are some activities which do not meet the definitions of manufacture, process, or otherwise use. For instance, storage, relabeling, or redistribution of an EPCRA Section 313 chemical where no repackaging occurs does not constitute manufacturing, processing, or otherwise use of that chemical. This type of activity should not be included in threshold calculations. In addition, transfers of EPCRA Section 313 chemicals in waste for energy recovery, treatment, or disposal are not considered "distribution into commerce." Also, note that the threshold determinations for the three threshold activities (manufacturing, processing, and otherwise use) are mutually exclusive. That is, you must conduct a separate threshold determination for each threshold activity and if you exceed any threshold, all releases and other waste management activities of EPCRA Section 313 chemicals at the facility must be considered for reporting. Example - Storage r" ,„•-..,, s *"* y A coal mining facility applies ethylene glycol to prevent freezing of coal daring its preparation and storage on-site. The facility receives 30,000 pounds of ethylene glycol and places it in storage in the current reporting year. In the course of the reporting year» 9,000 pounds is removed from storage and is applied to coal. Is the otherwise use threshold exceeded? Because storage is not considered a reportable activity, only the amount actually applied to coal is considered otherwise used. Therefore, the facility has only otherwise used 9,000 pounds of ethylene glycol and the otherwise use threshold has not been exceeded. If, however, ethylene glycol is manufactured, processed, or otherwise used in excess of the applicable thresholds elsewhere at the facility, all release and gther waste management calculations must be completed for ethylene glycol including amounts that may result from Storage O/*tltJlft------- photocopying and reduces errors by means of automated validation procedures. The ATRS produces a certification letter with each validated submission (set of EPCRA Section 313 reports) which provides for an original signature to certify that the submission is accurate and correct. The ATRS is available free of charge from EPA's TRI website at http://www.epa.gov/opptintr/afr. The ATRS is available in both DOS and Windows versions. More information can be found in the TRI Forms and Instructions, EPA's TRI website, or by calling the ATRS User Support Hotline at (703) 816-4434. Each Form R must consist of two parts: Part I. Facility Identification Information. This part of the form provides general information to identify the facility, including the name and address of the facility, parent company information, and identification numbers used under reporting regulations. When submitting hard copies of Form R, this part may be photocopied and re-used for each Form R you submit, except for the signature which must be original for each Form R; and Part n. Chemical Specific Information. This part of the form provides chemical-specific information on the reportable activities, releases, other waste management estimates, and source reduction activities for the reporting year. This must be completed separately for each EPCRA Section 313 chemical or chemical category and not reused year to year even if reporting has not changed. Submission of incomplete Form Rs may result in an issuance of a Notice of Technical Error (NOTE), Notice of Significant Error (NOSE), or Notice of Non-compliance (NON). See the current TRI Forms and Instructions for more detailed information on completing and submitting the Form R. The ATRS has a validation program which helps to identify and eliminate many potential data entry errors. 2.9 Form A EPA developed the Form A, also referred to as the "Certification Statement," to reduce the annual burden for facilities with lesser amounts of EPCRA Section 313 chemicals released and/or otherwise managed as a waste, applicable beginning reporting year 1995 and beyond (59 FR 61488; November 30,1994). A facility must meet the following two criteria in order to use a Form A: • First, the amount of the chemical manufactured, processed, OR otherwise used cannot exceed 1,000,000 pounds. It is important to note that the quantities for each activity are mutually exclusive and must be evaluated independently. If the quantity for any one of the activities exceeds 1,000,000 pounds, a Form A cannot be submitted. • Second, the total annual reportable amount of the EPCRA Section 313 chemical cannot exceed 500 pounds per year. The "reportable amount" is defined as the sum of the on-site amounts released (including disposal), treated, recycled, and 2-11 ------- combusted for energy recovery, combined with the sum of the amounts transferred off-site for recycling, energy recovery, treatment, and/or release (including disposal). This total corresponds to the total of data elements, 8.1 through 8.7 in Part n of the Form R (explained in Chapter 4). Example - Form A Threshold As requested by its customers, a coal mining facility applies ethylene glycol to prevent coal freezing during '<•'' transport. This activity constitutes "processing" because the ethylene glycol is intentionally incorporated into the product for distribution into commerce. Over the course of the reporting year, the facility estimates that the quantity of ethylene glycol processed is 30,000 pounds, exceeding the 25,000-pound threshold. While the majority of the EPCRA Section 313 chemical remains with the coal that is distributed into commerce, the total reportable quantity of ethylene glycol (the sum of Sections 8.1 through 8.7 of the Form R) is 270 pounds due to spills on application to the product. Because the facility did not exceed the one million pound threshold for manufacturing, processing, or otherwise use of ethylene glycol and the facility's total reportable quantity of ethylene glycol does not exceed 500 pounds, the facility has the option of submitting a Form 'R or a Form A, The Form A Certification Statement must be submitted for each eligible EPCRA Section 313 chemical. The information on the Form A is included in the publicly accessible TRI database, however these data are marked to indicate that they represent certification statements rather than Form Rs. Note that separate establishments at a facility cannot submit separate Form As for the same chemical; rather, only one Form A per EPCRA Section 313 chemical can be submitted per facility. Like the Form R, Form A includes facility identification information. However, no release and other waste management estimations to any media are provided. You must simply certify that the total annual reportable quantity of the chemical or chemicals addressed in the Form A did not exceed 500 pounds and that amounts manufactured, or processed, or otherwise used did not exceed one million pounds. Once a facility has completed estimates to justify the submission of a Form A, there is a considerable time savings in using the Form A especially in subsequent years provided activities related with the chemical do not change significantly. It is strongly recommended that you document your initial rationale and reconfirm it every year to verify that you have not made any modifications to the process that would invalidate the initial rationale supporting submission of a Form A. 2.10 Trade Secrets EPCRA's trade secrets provision only applies to the EPCRA Section 313 chemical identity. If you submit trade secret information, you must prepare two versions of the substantiation form as prescribed in 40 CFR Part 350, published in the Federal Register on July 29,1988, (53 FR 28801) as well as two versions of the Form R. One set of forms should be "sanitized" (i.e., it should provide a generic name for the EPCRA Section 313 chemical identity). This version will be made available to the public. The second version, the "unsanitized" version, should provide the actual identity of the EPCRA Section 313 chemical and have the trade secret claim clearly marked in Part I, Section" 2.1 of the Form R or Form A. All other parts of the Form R or Form A must be filled out accordingly. 2-12 ------- Individual states may have additional criteria for confidential business information and the submittal of both sanitized and unsanitized reports for EPCRA Section 313 chemicals. Facilities may jeopardize the trade secret status of an EPCRA Section 313 chemical by submitting an unsanitized version to a state agency or Indian tribe that does not require an unsanitized version. More information on trade secret claims, including contacts for individual state's submission requirements, can be found in the most current version of the TRI Forms and Instructions. 2.11 Recordkeeping Complete and accurate records are absolutely essential to meaningful compliance with EPCRA Section 313 reporting requirements. Compiling and maintaining good records will help you to reduce the effort and cost in preparing future reports and to document how you arrived at the reported data in the event of an EPA compliance audit. EPA requires you to maintain records substantiating the Form R or Form A submission for a minimum of three years from the date of submission. Each facility must keep copies of the Form R or Form A along with all supporting documents, calculations, work sheets, and other forms that you use to prepare the Form R or Form A. EPA may request this supporting documentation during a regulatory audit. Specifically, EPA requires that the following records be maintained for a period of three years from the date of the submission of a report (summarized from 40 CFR 372.10): 1) A copy of each report that is submitted; 2) All supporting materials and documentation used by the person to make the compliance determination that the facility or establishment is a covered facility; 3) Documentation supporting the report that is submitted, including documentation supporting: Threshold determinations Employee threshold determinations (including timesheets); Claimed allowable exemptions; Calculations for each quantity reported as being released, either on or off site, or otherwise managed as waste; Activity use determinations, including dates of manufacturing, processing, or otherwise use; Basis of all estimates; , Receipts or manifests associated with transfers of waste to off-site locations; and Waste treatment methods, estimates of treatment efficiencies, ranges of influent concentrations to treatment, sequential nature of treatment steps, and operating data to support efficiency claims. 2-13 ------- 4) All supporting materials used to make the compliance determination that the facility or establishment is eligible to submit a Form A; 5) Documentation supporting the Form A, including: • Data supporting the determination that the alternate threshold applies; • Calculations of annual reporting amounts; and • Receipts or manifests associated with the transfer of each chemical in waste to off-site locations. Because EPCRA Section 313 reporting does not require additional testing or monitoring, you must determine the best "readily available data" to make reporting determinations. Alternatively, you may use "reasonable estimates" to make reporting determinations. The amount and type of data and records will vary from facility to facility. Examples of records that you should keep, if applicable, include the following: • Each Form R or Form A submitted; • Section 313 Reporting Threshold Worksheets (sample worksheets can be found in Chapter 3 of this document as well as in the TRI Forms and Instructions); • Engineering calculations and other notes; • Purchase records and MSDSs from suppliers; • Inventory and receipt data; • Analytical results and profiles for wastes received from off site; • NPDES/SPDES permits and monitoring reports; EPCRA Section 312, Tier E reports; • Monitoring records; • Air permits; • Flow measurement data; • RCRA hazardous waste generator's reports; • Pretreatment reports filed with local governments; • Invoices from waste management firms; • Manufacturer's estimates of treatment efficiencies; • CERCLA Reportable Quantity (RQ) reports; • EPCRA Section 304 follow-up release notifications; • RCRA manifests; and • Process flow diagrams (including emissions, releases and other waste management activities). 2-14 ------- Chapter 3 - EPCRA Section 313 Threshold Determinations 3.0 PURPOSE This chapter provides a step-by-step procedure for determining if any EPCRA Section 313 chemicals or chemical categories exceed a reporting threshold at your facility. Step 1) Determine if you manufacture (including import), process, or otherwise use any EPCRA Section 313 chemicals. Step 2) Determine the quantity of each EPCRA Section 313 chemical you manufacture (including import), process, or otherwise use. Step 3) Determine which EPCRA Section 313 chemicals exceed a threshold. 3.1 Step 1: Determining which EPCRA Section 313 chemicals are manufactured (including imported), processed, or otherwise used Compiling Chemical Lists. Compile lists of all chemicals, mixtures, other trade name products, and wastes at your facility. Coal mining facilities may find it helpful to generate a list of chemicals otherwise used at the facility, including purchased chemicals and chemicals received from off-site for waste management (e.g., chemicals in ash from electricity generating facilities). For those coal mines which combust coal or other fuels for thermal drying operations, preparing a list of chemicals manufactured during combustion will be useful. When developing the list of chemicals manufactured, refer to information your facility may have or have access to regarding specific chemical constituents and their concentrations, in combination with information found later in this chapter. For the otherwise use list, identify the name of each mixture or other trade name product or waste name or waste code (e.g., chemicals in ash received from off-site for on- site disposal) and write the names of all chemicals contained in each mixture or other trade name product or waste identified. Next, compare the individual chemicals on both lists to the current EPCRA Section 313 chemicals list found in the TRI Forms and Instructions (remember that chemicals may be periodically added and deleted and you should always use the most current instructions which contain an updated list of chemicals). Highlight the EPCRA Section 313 chemicals that are on your list. You must perform threshold determinations for these chemicals. Review the list to be sure each chemical is shown by its correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical used at a coal mining facility for pH control is ammonia. Ammonia (CAS No. 7664-41-7) has several synonyms, including ammonium amide and spirit of Hartshorn. It must be reported on Form R (or Form A), Item 1.2, by its EPCRA Section 313 chemical name, ammonia. Synonyms can be found in the U.S. EPA document Common Synonyms for Chemicals Listed Under Section 313 of the EPCRA (EPA 745- R-95-008) (updated March 1995). EPA's Automated TRI Reporting System (ATRS) has a pick list containing a complete list of EPCRA Section 313 chemicals and chemical category names and the corresponding CAS numbers and category codes which helps to simplify this reporting element. 3-1 ------- While every chemical and chemical category on the EPCRA Section 313 chemical list must be considered, certain chemicals are more likely than others to be encountered at coal mining facilities, while others may not. As a guide, chemicals that coal mining facilities may manufacture, such as during combustion, process, and/or otherwise use are provided in Table 3-1. While this is not a comprehensive list of all chemicals that may be manufactured, processed, or otherwise used at coal mining facilities, it is a starting point to assist the facility in identifying chemicals for threshold determinations. Table 3-1 Common Chemicals Manufactured, Processed, and Otherwise Used at Coal Mining Facilities EPCRA Section 313 Chemicals that Coal Mining Facilities May Manufacture During Combustion for Thermal Drying EPCRA Section 313 Chemicals that Coal Mining Faculties May Process - ^ - Antimony compounds Arsenic compounds Barium compounds Cadmium compounds Chromium compounds Copper compounds Lead compounds Manganese compounds Nickel compounds Selenium compounds Silver compounds Vanadium (fume or dust) Zinc compounds Mercury/Mercury compounds (Above metal compounds also may be otherwise used in ash received from off-site for reclamation) Hydrochloric acid (acid aerosols only) Hydrogen fluoride Formaldehyde Ozone Sulfuric acid (acid aerosols only) Ethylene Glycol EPCRA Section 313 chemicals in ash produced on-site for use in gypsum manufacturing or sent off-site for use in concrete manufacturing. EPCRA Section 313 Chemicals that Coal Mining Facilities May Otherwise Use Ammonia Benzene Chlorine Copper compounds Ethylene glycol Nickel compounds Zinc compounds (See also manufacturing list for chemicals that may be otherwise used when ash is received from off-site for reclamation) Use of Spreadsheets or Databases. A computerized spreadsheet or database may be helpful in developing your facility's chemical list and performing threshold calculations. The type of information useful as input in a spreadsheet or database includes the chemical name, mixture or other trade name product, or waste name with corresponding chemical component, 3-2 ------- concentrations, the CAS number, and the yearly quantity manufactured, processed, or otherwise used. The spreadsheet or database could also be designed to identify the total quantity by activity threshold (amounts manufactured, processed, and otherwise used) for each EPCRA Section 313 chemical in every mixture and other trade name product. Smaller facilities that do not have an established electronic method of tracking their chemical usage and waste managed, should consider developing a spreadsheet to assist them in their chemical management activities. Developing a spreadsheet will require an initial investment of time; however, the time and effort saved in threshold calculations in subsequent years can be significant. Such a system will also reduce the potential of inadvertently overlooking EPCRA Section 313 chemicals that are present in wastes received or mixtures purchased from off-site sources. EPCRA Section 313 Chemicals in Purchased Chemicals To develop the chemical list and identify the associated threshold activities for purchased chemicals you may want to consult the following: Material Safety Data Sheets (MSDS); Facility purchasing records; Inventory records; Individual manufacturing/operating functions; and Operation and process knowledge. For purchased chemicals, MSDSs are generally considered to be good sources of information for the type and composition of chemicals in mixtures and other trade name products. Coal mining facilities may receive MSDSs for any mixture or other trade name product purchased for use as fuel, equipment cleaning and maintenance, water treatment, froth flotation, or other operations. As of 1989, chemical suppliers of facilities in SIC codes 2000 through 3999 are required to notify customers of any EPCRA Section 313 chemicals present in mixtures or other trade name products that are distributed to facilities. The notice must be provided to the receiving facility and may be attached or incorporated into that product's MSDS. If no MSDS is required, the notification must be in a letter that accompanies the first shipment of the product to your facility. This letter must contain the chemical name, CAS number, and the weight or volume percent of the chemical (or a range) in the mixture or other trade name product. Beginning with the 1998 reporting year, seven new industries will be covered by most of the EPCRA Section 313 reporting requirements and, therefore, facilities in SIC codes 2000 through 3999 will be required to provide these new industries with this supplier notification information. While the new industries are not required to prepare supplier notifications for materials that they distribute, they are encouraged to pass along the notification to customers receiving these materials who may be subject to EPCRA Section 313. For more information on supplier notification requirements, see TRI Forms and Instructions, EPCRA Section 313 Question and Answers, Revised 1998 Version - Appendix A, Directive 9 (EPA-745-B-98-004) or Supplier Notification Requirements, (EPA- 560/4-91-006). Carefully review the entire MSDS for your purchased chemicals. Although MSDSs must list whether EPCRA Section 313 chemicals are present, the language and location of this 3-3 ------- notification is not currently standardized. Depending on the supplier, this information can be found in different sections of the MSDS. The most likely sections of an MSDS to provide information on identity and concentration of EPCRA Section 313 chemicals in purchased chemicals are: Hazardous components section; Regulatory section; Physical properties/chemical composition section; Labeling section; and Additional information section. Chemicals Manufactured During Combustion for Thermal Drying Some coal mining facilities may conduct thermal'drying of the coal product. This activity typically involves the combustion of coal or other fuel types. This combustion operation may result in the manufacture of several EPCRA Section 313 chemicals as byproducts. To identify the chemicals manufactured, you should use the best "readily available data". This information could include analytical data on fuels used and combustion equipment (e.g., stack emission testing, combustion tests), process knowledge, other facility derived data, information from industry associations and EPA sources, and information on chemicals releases or in wastes leaving the facility. This chapter will discuss many of the metals and metal compounds, acids, and organics that may be manufactured during combustion. EPCRA Section 313 Chemical List In order to identify which chemicals are EPCRA Section 313 chemicals, and (in some cases) the form in which they are reportable, you need to compare your list of chemicals managed at your facility to the current Section 313 list of chemicals. Appendix B contains the list of EPCRA Section 313 chemicals (as of RY 1998), and correlates the list with various RCRA lists, such as the list of hazardous constituents (40 CFR Part 261, Appendix VIE and the list of underlying hazardous constituents from the Land Disposal Restriction program (40 CFR Section 268.48). The most current list of EPCRA Section 313 chemicals can be found in the TRI Forms and Instructions document for the current reporting year. The following discussion is a brief overview of the EPCRA Section 313 list of chemicals, including a description of possible chemical qualifiers. The original list of EPCRA Section 313 chemicals and chemical categories was comprised from two lists developed by New Jersey and Maryland. EPA refined the list and anticipates changes to continue. The list can be modified by an EPA initiative or though a petition process. When evaluating a chemical for addition or deletion, EPA must consider potential acute and chronic human health effects and adverse environmental effects and the Agency publishes its findings and any regulatory action through the Federal Register. 3-4 ------- The EPCRA Section 313 chemical list includes individually listed chemicals and several chemical categories. If you meet the SIC code criterion and exceed the employee threshold, you must file a Form R or Form A for each EPCRA Section 313 chemical or chemical category manufactured, processed, or otherwise used above threshold quantities. When conducting threshold determinations for individually listed chemicals, simply compare the amount of that chemical manufactured, processed, or otherwise used, to each threshold quantity. If you exceed the threshold, you must file a Form R or Form A for that chemical. When determining thresholds for chemical categories, you must total the weights of all members of the category, and compare this sum to each activity threshold. It is important that you compare the amount of compounds in a category separately to each individual activity threshold (manufacturing, processing, or otherwise use). If you exceed any of the three activity thresholds for a chemical category, you must file a Form R or Form A for that chemical category. ' , ,-"'-'- Examples - Chemical Categories /•> ^ , Example 1 ArfaciHty otherwise uses 5,000 pounds of 'lf,3-bis(methyUsocyanate)-cyclohexai&e,' 3,000 pounds of 1,5-iiaphthalene diisocyanate, :and 3;000 pounds of 2,2,4;trimethylhexamethylene diisocyanate. All" three of these chemicals are tnembers of the diisocyanates category, an EPCRA Section 3 IS chemical • category. The facility otherwis& uses 11,000 pounds of diisocyanates; which exceeds the 10,000°pound ~! threshold-for ^otherwise use. The facility must file a ForntR or Form A for diisocyanates category. „,< -, Example, 2 A facility otherwise uses 6,000 pounds of zinc oxide, ntanufactufes 20,000€pounds,of zinc sulfate, and processes 18,000 pounds of zinc sulfide.^ All three compounds ate members of the zinc-" compounds category, an EPCRA Section 313 chemical category.* Because the facility^does not exceed the 'otherwise use, manufacturing, or processing thresholds, thejacility is not require^ to file a Form R or Form A" for'the zinc compound category. " "- -• - ".'- " ' ~ ,-v ~~f ~* <* ' Many of the EPCRA Section 313 chemical categories are metal compound categories (e.g., chromium compounds). Metal compound categories include any unique chemical substance that contains the metal as part of that chemical's infrastructure. When calculating thresholds for metal compound categories, you must consider the entire weight of the metal compound, not just the weight of the parent metal. However, if you exceed an activity threshold for a metal compound category and you are filing a Form R for that metal compound category, you need only use the weight of the parent metal when calculating quantities released or otherwise managed as waste. Elemental forms of metals (e.g., chromium) are also individually listed on the EPCRA Section 313 chemical list. You must make separate threshold determinations for the elemental metal and the metal compound category (e.g., chromium and chromium compounds). If you exceed thresholds for both the metal and metal compound category, you may submit separate Form Rs, or one Form R for both the metal and metal compound category. However, if both the metal and the metal compound qualify for Form A reporting, you must submit separate Form A certifications for the metal and metal compound category. , Several chemicals on the EPCRA Section 313 chemical list include qualifiers related to use or form. A few chemicals are reportable ONLY if manufactured by a specified process or in a specified threshold activity. For example, isopropyl alcohol is only reportable if it is manufactured using the strong acid process and saccharin is reportable only if it is manufactured. Some other 3-5 ------- chemicals are only reportable if present in certain forms. For example, only yellow or white phosphorus are reportable, while black or red phosphorus are not. Example - Lead and Lead Compounds A facility has determined that it needs to report under EPCRA Section 313 for both elemental lead and lead compounds. Can this facility file one Form R that takes into account both the releases and other waste management activities of lead and lead compounds, or is it required to report separately? , ^ *" If a covered facility exceeds thresholds for both the parent metal and compounds of that same metal, it is allowed to file one joint report (e.g.. one report for lead compounds and elemental lead). However, the report filed will indicate amounts of the metal compound. EPA allows this because the release and other waste management information reported in connection with metal compounds will be the total pounds of the parent metal released and otherwise managed as a waste. For data management purposes, EPA requires that the chemical category name and code be placed on the Form R (Sections 1.1 and 1.2) The qualifiers associated with these chemicals which may be applicable to the coal mining industries are presented below. A detailed discussion of the qualifier criteria can be found in the TRI Forms and Instructions. • Fume or dust - Three metals (aluminum, vanadium, and zinc) are qualified as "fume or dust forms only." This definition excludes "wet" forms such as solutions or slurries, but includes powder, particulate, or gaseous forms of these metals. For example, on-site disposal of a waste received from off-site containing elemental zinc metal needs to be considered hi threshold determinations if the zinc is in the form of a fume or dust. However, if zinc (fume or dust) are found during treatment of a zinc-containing waste stream, then these amounts would need to be considered toward the facility's manufacturing threshold. Additionally, the entire weight of all zinc compounds should be included in the threshold determination for zinc compounds. Keep in mind that most metals in most wastes are expected to be in the compound form. • Ammonia has the following qualifier: "ammonia (includes anhydrous ammonia and aqueous ammonia from water dissociable salts and other sources; 10% of total aqueous ammonia is reportable under this listing)." Aqueous ammonia is formed from the dissociation of ammonium salts (including ammonium sulfate, ammonium nitrate, and ammonium chloride) in water and is an EPCRA Section 313 chemical. You must determine the amount of aqueous ammonia generated from solubilizing these chemicals in water and apply it toward the threshold for ammonia. EPA has published guidance on reporting for ammonia, and ammonium salts in EPCRA Section 313 Question and Answers, Revised 1998 Version - Appendix A, Directive 8. Additionally, ammonium nitrate in aqueous solutions must be included in threshold determinations and release and other waste management calculations for the nitrate compounds category. (See below) 3-6 ------- Nitrate Compounds (water dissociable; reportable only in aqueous solution) - A nitrate compound is covered by this listing only when in water and if dissociated. Although the complete weight of the nitrate compound must be used for threshold determinations for the nitrate compounds category, only the nitrate ion portion of the compound must be considered for release and other waste management determinations. Nitrate compounds are manufactured during the neutralization of nitric acid and in biological treatment of wastewater. EPA has published guidance for these chemicals in Water Dissociable Nitrate Compounds Category and Guidance for Reporting (see Appendix A for more information). Phosphorus (yellow or white) - Only manufacturing, processing, or otherwise use of phosphorus in the yellow or white chemical forms require reporting. Black and red phosphorus are not subject to EPCRA Section 313 reporting. Asbestos (friable) - Asbestos only need be considered when it is handled in the friable form. Friable refers to the physical characteristic of being able to crumble, pulverize, or reduce to a powder with hand pressure. Aluminum oxide (fibrous) - Beginning with reports for calendar year 1989, aluminum oxide is only subject to threshold determination when it is handled in fibrous forms. EPA has characterized fibrous aluminum oxide for purposes of EPCRA Section 313 reporting as a man-made fiber that is commonly used in high- temperature insulation applications such as furnace linings, filtration, gaskets, joints, and seals. Sulfuric acid (acid aerosols) and hydrochloric acid (acid aerosols) - EPA delisted non-aerosol forms of sulfuric acid (CAS No. 7664-93-9) and hydrochloric acid (CAS No. 7647-01-0) from the EPCRA Section 313 chemical list beginning in the 1994 and 1995 reporting years, respectively. Threshold determinations and release and other waste management estimates now only apply to the aerosol forms. EPA considers the term aerosol to cover any generation of airborne acid (including mists, vapors, gas, or fog) without any particle size limitation. Sulfuric acid and hydrochloric acid (acid aerosols) are manufactured during the combustion of sulfur containing wastes (for sulfuric acid) and chlorine containing wastes (for hydrochloric acid). EPA has published guidance for sulfuric acid in Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size) (see Appendix A for more information). 3-7 ------- 3.2 Step 2: Determining the quantity of each EPCRA Section 313 chemical manufactured (including imported), processed, or otherwise used The next step is to determine the quantities manufactured (including imported), processed, and otherwise used for each EPCRA Section 313 chemical on your list (developed in Step 1). Table 3-2 lists the annual reporting thresholds for each of these threshold activities (Table 3-3 provides detailed definitions of subcategories for the manufacturing threshold activity). Table 3-2 Reporting Thresholds Activity Manufacturing (including importing) Processing Otherwise used Threshold More than 25,000 pounds per EPCRA Section 313 chemical More than 25,000 pounds per EPCRA Section 313 chemical More than 10,000 pounds per EPCRA Section 313 chemical For each EPCRA Section 313 chemical or chemical category during the reporting year, each threshold must be individually calculated; they are mutually exclusive and are not additive. Example -Threshold Determination If your facility manufacturers 22,000 pounds of an EPCRA Section 313 chemical and you also otherwise use 8,000 pounds of the same chemical, you have not exceeded either activity threshold and an EPCRA Section 313 report for that chemical is not required. However, if your facility manufactures 28,000 pounds per year of an EPCRA Section 313 chemical and otherwise uses 8,000 pounds of the same chemical, you have exceeded the / manufacturing threshold and all non-exempt releases and other waste management activities of thai chemical must be reported on the Form R, including those from the "otherwise use" activity. Additionally, you must also indicate on the Form R in Part H, Section(s) 3.1, 3.2, and 3.3, all non-exempt activities involving the reportable EPCRA Section 313 chemical. •_ •• Example -Threshold Determination The amount of the EPCRA Section 313 chemical that is actually manufactured (including the quantity imported), processed, or otherwise used, not the amount in storage or previously disposed, is the amount applied to the threshold determination. For example, your coal mining facility disposes of nickel compounds received in ash transferred from off-site in its on-site reclamation activities. The reclamation site contains hundreds of thousands of pounds of nickel compounds. Over the course of the reporting year, you dispose of an additional 5,000 pounds of nickel compounds in wastes received from off-site. In this example, only the 5,000 pounds that were disposed of in the current year count toward the "otherwise use" threshold. Therefore, unless you "otherwise use" more than 5,000 pounds elsewhere at the facility, the "otherwise use" threshold has not be,en exceeded, and you would not have to report for nickel compounds. 3-8 ------- Each of the threshold activities is divided into subcategories. As discussed in the TRI Forms and Instructions, you are required to designate EACH activity and subcategory that applies to your facility not only those for which a threshold was exceeded. Manufacturing Manufacturing means producing, preparing, importing, or compounding an EPCRA Section 313 chemical. While coal mining facilities may not intend to manufacture EPCRA Section 313 chemicals during their operations, combustion of coal or other fuels will produce certain EPCRA Section 313 chemicals that must be considered towards the manufacturing threshold. The facility will need to consider if EPCRA Section 313 chemicals are produced coincidentally during combustion (or any of your other operations), even if the chemical exists for only a short period of time, and later is destroyed by air control equipment such as sulfuric acid aerosol. The following discussion describes the various activities included under manufacturing (see Table 3-3), and other manufacturing threshold issues that are relevant to coal mining facilities. Table 3-3 Examples of Manufactured Chemicals Manufacturing Activity ' Subcategory ; Examples Produced or imported for on-site use/processing Importation of chemicals in mixtures used for such activities as froth flotation. Produced or imported for sale/distribution Importation of coal from coal mining facilities outside the customs territory of the U.S.A. for sale or distribution. Produced as a by-product The coincidental manufacturing of EPCRA Section 313 chemicals from the combustion of coal, such as thermal drying. Sulfuric acid aerosols formed during application of sulfuric acid as a conditioner for fine-grade coal. Produced as an impurity May not occur in concentrations above de minimis levels. The coincidental manufacturing of metal compounds during the addition of lime, sodium carbonate, or sodium hydroxide/sulfuric acid (as conditioners) to coal. *More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual. Coal Combustion By-Products from Thermal Drying. As a result of froth flotation and other activities, some coal mines will combust coal to thermally dry coal fines prior to distribution into commerce. Most commonly, the combustion of coal to operate these thermal dryers will result in the manufacture of new metal compounds (usually as a result of oxidation), acid aerosols, formaldehyde, and other organic compounds, or convert metal compounds to the parent metal. For example, current information estimates that mercury compounds found in coal 3-9 ------- convert to either divalent mercury or elemental mercury during combustion. At this point, the percent conversion of either form of mercury is unknown [Study of Hazardous Air Pollutant Emissions from Electricity Utility Steam Generating Units - Final Report to Congress, Volume 1, page 7-5, U.S. EPA, OAQPS (February 1998) 453/R-98-004a]. Therefore, while divalent mercury will readily combine to form a compound, EPA is allowing facilities to use the lower weight elemental form of mercury when making their threshold determinations. Manufacture of Metals and Metal Compounds During Combustion. During combustion, 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 EPCRA Section 313 metal compound category) then manufacturing has occurred, and the quantity of the EPCRA Section 313 metal or metal compound manufactured must be counted towards the 25,000 pound threshold. You must apply the entire weight of a metal compound manufactured during combustion toward the 25,000 pound threshold, not just the weight of the parent metal. There may be cases in which a metal compound is not changed at all during combustion. For example, beryllium oxide in coal may remain as beryllium oxide during ,„„, . , » -,.-« combustion. In this case, a beryllium How Do l Calculate Amounts of Metal compound has not been manufactured and no amounts of beryllium compounds would need to Compounds Manufactured During Combustion? In the absence of better facility-specific data, use Tables 3-4 and 3-6 to calculate amounts of metal compounds be considered toward the manufactured during coal combustion. - manufacturing threshold. To use the tables, simply look under the column titled "Approximate Tons of Coal Needed To Be Consumed to To calculate the amount of Section 313 metal compounds manufactured during combustion, facilities must first estimate the concentration of each metal present Form R of Fom A for ^ ^ compomd category For in the coal or other fuels used. example, if you combust more than 1,800 tons of coal during Manufacture 25,000 Lbs. of the Metal Oxide." For each metal compound, compare this value to the amount of fuel combusted at your facility during the reporting year. If the amount^ combusted exceeds the value in the table, you have exceeded., ~< the threshold for that metal compound, and you the reporting year, you must prepare a Form R or Form A for zinc compounds. These metals are likely to exist as metal compounds in the fuel. The best "readily available data" should be used to estimate the approximate concentration of the metal. If a facility has data regarding chemical concentrations in the fuel used by the facility, and the facility believes that this is the best "readily available data", then the facility should use this information.. If specific concentration data of EPCRA Section 313 chemicals in coal does not exist at your facility, there are several sources where the facility can find this concentration data. Examples include nationally assembled data such as the U.S. Geological Survey's (USGS) coal quality database (http://energy.er.usgs.gov/products/databases/CoalQual/) or Electrical Power Research Institute's (EPRI) PISCES database on coal constituents. As an alternative, if no other information is available, facilities can assume that most of these metal compounds convert to the lowest weight oxide possible. You may use the default 3-10 ------- values for metal and metal compound concentrations in coal provided in Table 3-4 or Table 3-6. When you have determined the concentration of metals and metal compounds in the fuel used, you must then determine the quantity of metals and metal compounds manufactured during combustion. In determining how much of a metal or metal compound the facility may actually manufacture during combustion, the facility may assume that most metal compounds convert to the lowest weight oxide. This information is also provided in Tables 3-4 and 3-6. These tables list concentrations of EPCRA Section 313 metals typically found in different types of coal, the associated pounds of metal oxide manufactured per ton of coal combusted, and as a quick reference, the estimated tons of coal needed to be consumed to manufacture 25,000 pounds of the corresponding metal oxide for each coal type [Table 3-4 was derived from data in Appendix D of the Study of Hazardous Air Pollutants Emissions from Utility Steam Generating Units, U.S. EPA, OAQPS (February 1998) 453/R-98-004a]. To support the facility's threshold calculations, the facility should document the type of coal it uses. While most coal mining facilities that conduct thermal drying will use their own coal product for fuel, some facilities may use other fuel types, such as fuel oil. For information on metal and metal compounds that may be produced from the combustion of other fuel sources, refer to Compilation of Air Pollutant Emission Factors (AP-42) or to EPA's EPCRA Section 313 Guidance for Electricity Generating Facilities. Table 3-4 Concentrations of EPCRA Section 313 Metals and their Compounds in Coal and Pounds of Metal Oxide Manufactured per Ton of Coal Combusted, by State and Coal Rank Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide Alaska (Subbituminous) , * — ; T , - Antimony/Sb2Oi Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl,O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/HgjO Nickel/NiO 1.9 3 0.5 0.15 20 5 53.93" 95b 5.4 88 0.07 10 4.6E-03 7.92E-03 2.78E-03 3.42E-04 5.24E-02 1.27E-02 NA NA 1.17E-02 2.27E-01 1.46E-04 2.56E-02 5.48 3.16 8.99 73.10 0.48 1.97 NA NA 2.14 0.11 171 0.98 3-11 ------- Section 313 Metal/ Lowest Weight Metal Oxide«ThatMayBe Manufactured from the Metal Selenium/SeO2 Alabama (Bituminous) Antimony/SbjOj Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 Arkansas (Lignite) Antimony/Sb2O3 Arsenic/As2O, Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO, Metal Concentration in Coal in Units of Micrograms/Gram 1.6 1.82 53 1.88 0.06 22.8 8.2 380" 127b 7 41 0.19 17.5 1.88 1.17 4.3 2.4 0.29 16.9 6 142b 63" 9.8 119 0.25 11.8 5 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted 4.51E-03 4.37E-03 1.40E-01 1.05E-02 1.37E-04 5.97E-02 2.08E-02 NA NA 1.51E-02 1.06E-01 3.95E-04 4.48E-02 5.30E-03 2.80E-03 1.12E-02 1.33E-02 6.61E-04 4.43E-02 1.52E-02 NA NA 2.12E-02 3.07E-01 5.20E-04 3.02E-02 1.41E-02 Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide 5.54 ;\ _ , / ' "-""-* 5.72 0.18 2.39 182.75 0.42 1.20 NA NA 1.65 0.24 63.26 0.56 4.72 - 8.90 2.20 1.87 37.81 0.56 1.64 NA NA 1.18 0.08 48.08 0.83 1.77 3-12 ------- Section 313 Metal/ Lowest Weight Metal Oxide8 That May Be Manufactured from the Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Arizona (Subbituminous) " .- •**, -_. ~N * - L — - - ' Cadmium/CdO Cobalt/CoO Chlorine/Cl2O Fluorine/FjO Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO;, 0.47 2.1 1;1 0.1 4.6 2.1 200" 79" 9 27 0.07 4.8 1.5 1.13E-03 5.55E-03 6.12E-03 2.28E-04 1.21E-02 5.33E-03 NA NA 1.94E-02 6.97E-02 1.46E-04 1.23E-02 4.23E-03 Colorado (Bituminous) , ,.-..,- Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl,O Fluorine/FjO Lead/PbO Nickel/NiO Selenium/SeO, 0.91 1.34 0.36 0.18 1.89 10.3 92.97" 98.78" 5.44 10.83 0.07 1.25 0.87 2.18E-03 3.54E-03 2.00E-03 4.10E-04 4.95E-03 2.62E-02 NA NA 1.18E-02 2.79E-02 1.46E-04 3.20E-03 2.45E-03 Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide • - 22.22 4.5 4.09 109.65 2.07 4.69 NA NA 1.29 0.36 172 2.03 5.91 , >-- ,"""" 11.5 7.07 12.49 60.92 5.05 0.96 NA NA 2.13 0.89 172 7.81 10.19 3-13 ------- Section 313 Metal/ Lowest Weight Metal Oxide1 That May Be Manufactured from the Metal Colorado (Subbitumlnous Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg,O Nickel/NiO Sclenium/SeO, Metal Concentration in Coal in Units of Micrograms/Gram 0.35 1.03 0.84 0.08 4.1 1.6 118b 99" 3.5 32 0.14 7.9 0.89 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted 8.35E-04 2.72E-03 4.67E-03 1.82E-04 1.07E-02 4.06E-03 NA NA 7.56E-03 8.26E-02 2.91E-04 2.02E-02 2.51E-03 Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide """ 30 9.2 5.35 137.06 2.33 6.15 NA NA 3.31 0.30 86 1.24 9.96 Illinois (Bituminous) * ~ = Antimony/SbjOj Arsenic/As,O, Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Huorine/F2O Lcad/PbO Manganese/MnO Mercury/HgjO Nickel/NiO Selenium/SeO, 0.82 6.78 1.31 0.98 12.66 3.19 1136.07" 84.14" 24.51 33.74 0.08 12.74 1.72 1.96E-03 1.79E-02 7.28E-03 2.23E-03 3.32E-02 8.10E-03 NA NA 5.29E-02 8.70E-02 1.66E-04 3.26E-02 4.85E-03 12.76 1.4 3.43 11.19 0.75 3.09 NA NA 0.47 0.29 150 0.77 5.15 3-14 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide Indiana (Bituminous) \ - * .."-I Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NIC Selenium/SeO2 Iowa (Bituminous) Antimony/SbO Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO ^elenium/SeQ. 1.4 10.1 2.82 0.49 15.4 5.2 1032.79" 65" 10.9 38 0.11 17.9 2.17 ,, > ; r1 - " >- ^ 2.3 12.0 1.88 14.0 12.10 10.00 1498.36 77.0 68.0 259.0 0.19 31.0 3.60 3.35E-03 2.67E-02 1.57E-02 1.12E-03 4.03E-02 1.32E-02 NA NA 2.35E-02 9.80E-02 2.29E-04 4.58E-02 6.12E-03 . - - 5.50E-03 3.17E-02 1.05E-02 3.19E-02 3.17E-02 2.54E-02 NA NA 1.47E-01 6.68E-01 3.95E-04 7.94E-02 1.02E-02 7.47 0.84 1.59 22.38 0.62 1.89 NA NA 1.06 0.25 109 0.55 4.09 -,' 4.55 0.79 2.39 0.78 0.79 0.98 NA NA 0.17 0.04 63.26 0.32 2.46 3-15 ------- Section 313 Metal/ Lowest Weight Metal Oxide1 That May Be Manufactured from the Metal Kansas (Bituminous) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 Kentucky (Bituminous) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO Fluorine/F2O Lead/PbO Manganese/MnO Mereury/HgjO Nickel/NiO Selenium/SeO, Metal Concentration in Coal in Units of Micrograms/Gram ..... . , , 0.85 25 1.47 10 10.1 15 2500" 64" 111 160 0.19 41 2.7 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide 2.03E-03 6.6E-02 8.17E-03 2.28E-02 2.65E-02 3.81E-02 NA NA 2.40E-01 4.13E-01 3.95E-04 1.05E-01 7.61E-03 12.3 0.38 3.06 1.10 0.94 0.66 NA NA 0.10 0.06 63.3 0.24 3.28 , 1.13 19.1 3.17 0.16 16.3 6.6 1139 86 10.6 32 0.15 17.5 3.83 2.7E-03 5.05E-02 1.76E-02 3.65E-04 4.27E-02 1.68E-02 NA NA 2.29E-02 8.26E-02 3.12E-04 4.48E-02 1.08E-02 9.26 0.50 1.42 68.53 0.59 1.49 NA NA 1.09 0.30 80 0.56 2.31 3-16 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Louisiana (Lignite) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/HgjO Nickel/NiO Selenium/SeO2 Maryland (Bituminous) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO-) Metal Concentration in Coal in Units of Micrograms/Gram *$ 3 ^ / 0.82 3.7 1.9 0.15 11.4 3.3 115" 83" 5.5 141 0.19 7.8 6 " , J ; 0.81 26 2.01 0.14 26.7 11 914" 107" 10 13 0.42 22 3.8 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted :, , - ,- - V-""' * 1.96E-03 9.75E-03 1.06E-02 3.42E-04 2.99E-02 8.38E-03 NA NA 1.19E-02 3.64E-01 3.95E-04 2.00E-02 1.69E-02 •V 1.95E-03 6.85E-02 1.12E-02 3.19E-04 7.00E-02 2.79E-02 NA NA 2.16E-02 3.35E-02 8.74E-04 5.63E-02 1.07E-02 Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide -V*" ^u^ " 12.76 2.56 2.37 73.10 0.84 2.98 NA NA 2.10 0.07 63.25 1.25 1.48 > - ' r 12.92 0.36 2.24 78.32 0.36 0.89 NA NA 1.16 0.75 28.62 0.44 2.33 3-17 ------- Section 313 Metal/ Lowest Weight Metal Oxide* That May Be Manufactured from the Metal Missouri (Bituminous) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO Fluorine/F2O Lead/PbO Manganese/MnO Mercury/HgjO Nickel/NiO Selenium/SeOj Metal Concentration in Coal in Units of Micrograms/Gram 1.6 10 2.01 0.8 12.2 6.7 1701.64" 60" 67 99 0.17 23 4.2 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide * s U* ™ 3.83E-03 2.64E-02 1.12E-02 1.82E-03 3.20E-02 1.70E-02 NA NA 1.45E-01 2.55E-01 3.54E-04 5.89E-02 1.18E-02 6.54 0.94 2.24 13.71 0.78 1.47 NA NA 0.17 0.10 70.07 0.42 2.11 Montana (Bituminous) Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/HgjO Nickel/NiO Selenium/SeO, 0.69 7 0.52 0.08 3.1 1.5 80" 104" 3 37 0.09 3.9 0.7 1.65E-03 1.85E-02 2.89E-03 1.82E-04 8.12E-03 3.81E-03 NA NA 6.48E-03 9.55E-02 1.87E-04 9.98E-03 1.97E-03 15.15 1.36 8.65 137.06 3.08 6.56 NA NA 3.86 0.26 133.55 2.50 12.66 3-18 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Metal Concentration in Coal in Unite of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Montana (Lignite),- -,---' • .. -„ " "--" r.U* Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 0.92 18 1.04 0.11 0.94 0.8 67" 159" 4.8 68 0.12 4 0.72 Montana (Subbituminous) -" ' --'•,*' Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO, 0.69 . 7 0.52 0.08 3.1 1.5 80" 104b 3 37 0.09 3.9 0.7 2.20E-03 4.75E-02 5.78E-03 2.51E-04 2.46E-03 2.03E-03 NA NA 1.04E-02 1.75E-01 2.50E-04 1.02E-02 2.03E-03 Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide *t !W<. >-N ™ -* /"Si;/- , -*-„•: „ .*,' 11.36 0.52 4.32 99.68 10.15 12.30 NA NA 2.41 0.14 100.2 2.44 12.31 **&* ^ ^ ~ '*' ,'''""*.--"' ' - - , " 1.65E-03 1.85E-02 2.89E-03 1.82E-04 8.12E-03 3.81E-03 NA NA 6.48E-03 9.55E-02 1.87E-04 9.98E-03 1.97E-03 15.16 1.36 8.65 137.06 3.08 6.56 NA NA 3.86 0.26 133.55 2.50 12.66 3-19 ------- Section 313 Metal/ Lowest Weight Metal Oxide" That May Be Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide North Dakota (Lignite) Antimony/SbjOj Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO FIuorine/FjO Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 0.58 8.4 0.82 0.11 7 2.7 110" 34" 3.73 86 0.13 4.1 0.79 1.39E-03 2.22E-02 4.56E-03 2.51E-04 1.83E-02 6.86E-03 NA NA 8.06E-03 2.22E-01 2.70E-04 1.05E-02 2.23E-03 18.04 1.12 5.48 99.68 1.36 3.65 NA NA 3.10 0.11 92.46 2.38 11.22 New Mexico (Subbituminous) * * Antimony/SbjOj Arsenic/AsjO3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O NickeVNiO Selenium/SeO, 1.07 1.8 2.7 0.16 6 2.65 95" 87" 31 45 0.06 4.6 1.94 2.56E-03 4.75E-03 1.50E-02 3.65E-04 1.57E-02 6.73E-03 NA NA 6.70E-02 1.16E-01 6.5E-05 1.18E-02 5.47E-03 9.78 5.26 1.67 68.53 1.59 3.71 NA NA 0.37 0.22 384.62 2.12 4.57 3-20 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Ohio (Bituminous) ' - ' Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 0.81 23.2 2.39 0.12 14.3 0.9 719" 92b 7.3 28.3 0.22 14.9 3.8 Oklahoma (Bituminous) , Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO, 0.69 24 0.86 0.1 15 6.2 267b 77b 10 74 0.17 17 1.8 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide -'^^J 'r-'v^' /< *~;^V: - V 1.94E-03 6.1E-02 1.33E-02 2.74E-04 3.75E-02 2.29E-03 NA NA 1.58E-02 7.30E-02 4.58E-04 3.81E-02 1.07E-02 1/1 "* /~ * t ff.lj'* *• ~ 1.65E-03 6.35E-02 4.78E-03 2.28E-04 3.93E-02 1.57E-02 NA NA 2.16E-02 1.91E-01 1.84E-04 4.35E-02 5.08E-03 12.92 0.40 1.88 91.37 0.67 10.94 NA NA 1 1.59 0.34 54.63 0.66 2.33 **. "~ "' ~ 15.16 0.40 5.23 109.65 0.64 1.59 NA NA 1.16 0.13 136.16 0.57 4.93 3-21 ------- Section 313 Metal/ Lowest Weight Metal Oxide1 That May Be Manufactured from the Metal Pennsylvania (Bituminous Antimony/Sb2O3 Arsenic/AsjO, Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/CljO Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide 1.23 32.1 2.45 0.1 20.1 7.9 1096b 78b 10.8 23.5 0.29 20.4 3.55 2.94E-03 8.45E-02 1.36E-02 2.28E-04 5.27E-02 2.01E-02 NA NA 2.33E-02 6.06E-02 6.03E-04 5.22E-02 l.OOE-02 Texas (Lignite) Antimony/Sb2O, Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/HgjO Nickel/NiO Selenium/SeO, 0.82 3.7 1.9 0.15 11.4 3.3 115" 83" 5.5 141 0.19 7.8 6 1.96E-03 9.75E-03 1.06E-02 3.42E-04 2.99E-02 8.38E-03 NA NA 1.19E-02 3.64E-01 3.95E-04 2.00E-02 1.69E-02 8'.50 0.30 1.84 109.65 0.47 1.25 NA NA 1.07 0.41 41.43 0.48 2.50 12.76 2.56 2.37 73.10 0.84 2.98 NA NA 2.10 0.07 63.26 1.25 1.48 3-22 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide Utah (Bituminous). , * '-'-•',' ..,'^-/^'-^'.V •*•- ' ' r' ' : Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 0.23 0.89 0.61 0.08 7.7 2.7 219.67" 57b 3.9 8 0.04 4.1 2 5.50E-04 2.35E-03 3.39E-03 1.82E-04 2.02E-02 6.86E-03 NA NA 8.42E-03 2.06E-02 8.32E-05 1.05E-02 5.64E-03 45.50 10.64 7.37 137.06 1.24 3.65 NA NA 2.97 1.21 300.48 2.38 4.43 Virginia (Bituminous) ', - -. ' - ,, " ~ c "<• », ,, Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO , , Cobalt/CoO Chlorine/CI2O , , Fluorine/F2Q , , , , Lead/PbO -.,,.,», Manganese/MnQ Mercury/Hg2O Nickel/NiO Selenium/SeO, 0.93 11 1.66 0.05 12.5 6.3 930" 74" 5.8 19 0.14 11.2 2.7 2.23E-03 2.91E-02 9.23E-03 1.14E-04 3.28E-02 1.60E-02 NA NA 1.25E-02 4.90E-02 2.91E-04 2.87E-02 7.61E-03 11.24 0.86 2.71 219.30 0.76 1.56 NA NA 2.00 0.51 85.91 0.87 3.28 3-23 ------- Section 313 Metal/ Lowest Weight Metal OxidVThatMayBe Manufactured from the Metal Metal Concentration in Coal in Units of Micrograms/Gram Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide '" ' ' •*" "" 5 Washington (Subbitumlnous) Antimony/SbjOj Arsenic/As2Oj Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO2 0.3 1.5 1.1 0.11 0.7 4.7 103.28" 14" 2.8 41 0.06 7.9 0.4 7.15E-03 3.96E-03 6.12E-03 2.51E-04 1.83E-03 1.19E-02 NA NA 6.05E-03 1.06E-01 1.25E-04 2.02E-02 1.13E-03 34.86 6.32 4.09 99.68 13.63 2.09 NA NA 4.13 0.24 200.32 1.24 22.16 West Virginia (Bituminous) Antimony/Sb2O3 Arsenic/As2O, Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/C!2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selenium/SeO, 0.93 10.6 2.78 0.1 15.3 7.2 1216" 58b 7.2 19.1 0.16 14.2 3.97 2.23E-03 2.8E-02 1.55E-02 2.28E-04 4.01E-02 1.83E-02 NA NA 1.56E-02 4.93E-02 3.33E-04 3.64E-02 1.12E-02 11.24 0.90 1.62 109.65 0.62 1.37 NA NA 1.61 0.51 75.12 0.69 2.23 3-24 ------- Section 313 Metal/ Lowest Weight Metal Oxide3 That May Be Manufactured from the Metal Wyoming (Subbituminous Antimony/Sb2O3 Arsenic/As2O3 Beryllium/BeO Cadmium/CdO Chromium/CrO Cobalt/CoO Chlorine/Cl2O Fluorine/F2O Lead/PbO Manganese/MnO Mercury/Hg2O Nickel/NiO Selp.ninm/Sp.O, Metal Concentration in Coal in Units of Micrograms/Gram \ " '" 0.73 0.69 0.18 0.13 2.82 0.87 118.3" 43.7b 2.07 5.65 0.08 2.17 nsi Pounds of Metal Oxide Manufactured per Ton of Coal Combusted Approximate Million Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide _„ t s „- »*• x * „ ^f,*-^ / ^. J •" „ * ' " " " ' ' j - " .; •£ < ~ 1.75E-03 1.82E-03 l.OOE-03 2.96E-04 7.39E-03 2.21E-03 NA NA 4.47E-03 1.46E-02 1.66E-04 5.56E-03 1 44F.-m 14.32 13.72 , 24.98 84.35 3.38 11.31 NA NA 5.59 1.72 150.24 4.50 17 ™ a. As discussed above, mercury compounds in coal may not convert to the lowest weight oxide, but may reduce to the elemental mercury. At this time, EPA does not require facilities to make threshold determinations based on the weight of mercury compounds, but instead allows facilities to use the lower weight of elemental mercury. b. These elements are not metals and subsequently do not produce metal oxides. They will produce hydrochloric acid (acid aerosols) and hydrofluoric acid, respectively. This is addressed elsewhere in the document. A significant percentage of bituminous coal from most Eastern and Midwestern locations undergo a "cleaning process" to meet customer specifications for heat, ash, and sulfur content. Based on findings in EPA's OAQPS study [Study of Hazardous Air Pollutant Emissions from Electricity Utility Steam Generating Units - Final Report to Congress (February 1998) 453/R- 98-004a], this cleaning process can affect the concentrations of some of the constituents in coal. In order to account for this, Table 3-5 has been included to provide "cleaning factors" to be used to adjust for this coal type taken from these locations that are subjected to a cleaning process. An example of how these cleaning factors may be used is provided immediately after Table 3-5. Note, based on the analysis used to develop information in Tables 3-4 and 3-5, it was identified that bituminous coal from Illinois and Colorado was not subject to cleaning processes; therefore, the factors in Table 3-5 should not be used for bituminous coal from these two states. 3-25 ------- Table 3-5 Coal Cleaning Factors for Bituminous Coals Constituent Antimony Arsenic Beryllium Cadmium Chromium Cobalt Chlorine Fluorine Lead Manganese Mercury Nickel Selenium Cleaning Factor 0.715 0.554 0.711 0.624 0.512 0.537 0.496 0.496 0.449 0.382 0.790 0.568 0.745 Example-Use of Coal Cleaning Factor- A coal mining facility burns bituminous coal from Alabama and Kentucky. The facility estimates that it has exceeded the manufacturing threshold for elemental mercury. Based on information obtained by the facility from the USGS Coal Quality Database, along with.. information provided in Tables 3-3 and 3-4 in this document, the facility estimates thatit manufactured approximately 32,000 pounds of elemental mercury from coal combustion. Based on the knowledge that the coal combusted had been cleaned prior to combustion, the facility recalculated the amount elemental mercury manufactured to be: 32,000 Ibs Hg x 0.790 (Coal Cleaning Factor for Hg) = 25,280 Ibs Hg manufactured. * Information on a few metals and metal compounds believed to be present in coal, and included in EPA's previous versions of the Coal Mining and Electricity Generating Facilities guidance documents, was not provided for coal types analyzed in the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units. Facilities should consider the specific information they have for the coal they use to determine whether or not these chemicals are present and at what concentrations. If the facility does not have additional information, they 3-26 ------- should consider information on those metals and metal compounds provided in Table 3-6 for purposes of threshold and release and other waste management calculations. As discussed above, there are several sources of information, such as the U.S. Geological Survey's Coal Quality database or EPRI's PISCES database, that provide amounts of constituents in coal types from various locations that may represent better information than that provided in Table 3-6. However, facilities are instructed to use their best "readily available data" when developing these estimates, and if the facility does not have better information, then Table 3-6 should be considered. One exception to the assumption that metal compounds in fuel convert to lowest weight metal oxides during combustion is mercury. Mercury likely exists as a compound in coal. Unlike other metal compounds in coal, mercury is not likely to convert to an oxide, but instead may convert to elemental mercury and be released in a gaseous state. In this case, elemental mercury is considered manufactured for threshold purposes. Unless facilities have information to indicate otherwise, they should assume that they manufacture elemental mercury during combustion, and apply the weight of the metal, rather than the metal oxide, toward the manufacturing threshold for mercury. If the facility does not have information on the concentration of mercury compounds in coal used, there are several sources of information to obtain this as previously discussed. Otherwise, EPA has provided default values in Table 3-4. Unless you have information indicating otherwise, assume that 100% of the mercury portion of the mercury compounds in the coal converts to elemental mercury. 3-27 ------- Table 3-6 Concentrations of Additional EPCRA Section 313 Metals and their Compounds in Coal and Pounds of Metal Oxide Manufactured per Ton of Coal Combusted EPCRA Section 313 Metal Constituents of Coal and the Estimates of the Corresponding Metal Oxide for Metals Not Present in Table 3-4 EPCRA Section 313 Metal/ Lowest Weight Metal Oxide That May Be Manufactured from the Metal Zinc/ZnO Barium/BaO Copper/Cu2O Silver/Ag,O Metal Concentration in Coal in Units ofMicrograms/ Gram 5,600 250 IBS 0.08 Oxide Factor 1.24 1.12 1.125 1.07 Pounds of Metal Oxide Manufactured per Ton of Coal Combusted 13.88 0.56 0.42 1.7E-04 Tons of Coal Needed To Be Consumed to Manufacture 25,000 Lbs. of the Metal Oxide 1,800 44,643 60,060 1.46E08 fsote: ine table consists or the lowest weight oxide per metal possible for the particular metal. The metal concentration for amounts in coal were 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. Quantities are given in short tons, where 1 short ton = 2,000 Ibs. Manufacture of Acid Aerosols During Combustion . During combustion of fuel, facilities may manufacture hydrochloric acid (HC1) aerosols, hydrogen fluoride (HF), and sulfuric acid aerosols. If aerosol forms of hydrochloric or sulfuric acid are produced, then amounts produced must be applied toward the manufacturing threshold for these EPCRA Section 313 chemicals. To estimate quantities of acid aerosols manufactured during combustion, facilities can use monitoring data, equipment specifications, air permits, and industry literature. In the absence of better data, facilities can use the HC1 and HF emission factors presented in Table 3-7. Use the emission factor that corresponds to the type of coal being combusted. If your facility combusts a mixture of coal types, and knows the mixture ratio, you may apply this ratio to the emission factors in Table 3-7. Facilities that do not know the type of coal they use should assume the coal is bituminous or subbituminous, since these types are most commonly used. The factors in Table 3-7 are considered more appropriate than AP-42 factors when the coal type is known. Emission Factors in AP-42 are averages for various types of coal. 3-28 ------- Example - Manufacture of Sulfuric Acid (Acid Aerosols) ••-% ~', f*t j ~;< A^ coal mining facility combusts coal for thermal drying of coal fines. As a result of the combustion operation, the fecffity emits sulfur dioxide (SO2), sulfur trioxide (SOj), and particulate sulfates through a point source. Once emitted, the sulfur trioxide readily reacts with water vapor (both in air and in flue ~ * gases that have exited the stack) to form a sulfurie add aerosol mist. For purposes ofJEPCRA Section 313, must the facility report on the manufacture of sulfur ic add? » - ' f 7 >., - No. The sulfurie acid aerosol formed in the chemical reaction of sulfur-trioxide and water that often occurs in s the air after releasing sulfur trioxide is not included in threshold .determinations. The facih'tyrowner/operafof". is not responsible for tracking orlep'biting on the formation of,an EPCRA Sectiotf313 chemical once a ' chemical is released from a facility .„ However, if the reaction of sulfur trioxide and water takes place prior to being emitted ^e.g., in the stack), the facility would be required.to factor,the quantity of sulfurie acid aerosol mist generated towards the manufacture threshold., Jf the threshold is exceeded, me facility owner/operator must report all releases and other waste management estimates of sulfurie acid aerosols from the facility. - _ For guidance on calculating the amount of sulfurie acid manufactured during combustion, refer to: Emergency Planning and Community Right-to-Know Act-Section 313: Guidance for Reporting Sulfurie Acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size), EPA, March 1998, available on EPA's website at http://www.epa.gov/opptintr/tri/. Table 3-7 Emission Factors For HC1 and HF Manufactured During Combustion of Coal Coal Type Anthracite Coal (pulverized coal and traveling grate stokers) Bituminous Coal (pulverized coal: wet and dry bottom, cyclone, spreader stoker, traveling grate (overfeed) stoker, pulverized coal: dry bottom (tangential firing, atmospheric fluidized bed)) Subbituminous coal (pulverized coal: wet and dry bottom cyclone, spreader stoker, traveling grate (overfeed) stoker, pulverized coal: dry bottom (tangential firing)), Lignite (pulverized coal, pulverized coal: tangential firing, cyclone, traveling grate (overfeed) stoker, spreader stoker) Emission factor3 HF 0.18 0.23 0.23 0.01 HC1 0.91 1.9 1.9 0.01 Source: Hydrogen Chloride and Hydrogen Fluoride Emission Factors for the NAPAP Emission Inventory, U.S. EPA, Office of Research and Development, 1985. a. Pound per ton of coal. 3-29 ------- Calculating Thresholds for Hydrochloric (Acid Aerosols) Acid and Selenium A facility in Alaska combusts 1 million tons of subbituminous coal in the reporting year. What quantity of selenium compounds and HC1 (acid aerosol) are manufactured? Hydrochloric Add fAcid Aerosols): The HC1 emission factor for subbituminous coal is 1.9 Ib/ton coal (see Table 3-7). 1.9IbHCl/ton coalx 1,000,000 tons coal =1,900,000pounds HC1 (acid aerosols) Therefore, 1.9 million pounds ofHCI (acid aerosols) are manufactured and the 25,000 pound threshold has been exceeded. Form R reporting for HC1 (acid aerosols) is required. Selenium Compounds: Based on the concentration estimates of selenium in Table 3-4, the emission factor for selenium oxide (Se6,) is 1.44 x 103 Ib SeO/ton coal • 1.44x 103Ib SeOz/ton coalx 1,000,000 tons of coal = 1,440pounds of SeO2 emitted. Therefore, 1,440 pounds of selenium compounds are manufactured and the 25,000 pound threshold was not Manufacture of Formaldehyde During Combustion. Table 3-8 lists emission factors of formaldehyde produced during the combustion of coal, No. 6 fuel oil, No. 2 fuel oil, and natural gas. Based on these emission factors, the amount of fuel consumed to manufacture more than 25,000 pounds of the EPCRA Section 313 chemical is also provided. In the absence of better information, the emission factors in these tables can be used to calculate threshold determinations. Table 3-8 Emission Factors and Triggering Thresholds For Formaldehyde Manufactured During Combustion Fuel Source Coal Natural Gas No. 2 Fuel Oil No. 6 Fuel Oil Emission Factor (unite of measure) 2.4e-04 Ib/ton 1.55e-01 lb/M-ft3 61 lb/Mgala 33 Ib/Mgal Combusted to Manufacture 25,000 Ibs. of Formaldehyde 104 Mtons 161,290M-ft3 410 Mgal 758 Mgal , external ^omousuon sources, Tablesl.4-4, 1.3-7,1.3-8, and 1.1-13. Note: M-ft3, Mgal and Mtons indicate millions of cubic feet, millions of gallons, and millions of tons, respectively. * Emission factor is the upper range for No. 2 fuel oil combustion. 3-30 ------- Fine Coal Conditioning Some mines may perform fine coal conditioning using sulfuric acid solutions to adjust pH to facilitate the flotation process. While the sulfuric acid is only reportable when in aerosol form, the use of sulfuric acid solutions may produce the aerosol form of the acid, which must be applied to the manufacturing threshold. For guidance on estimating the quantities for sulfuric acid aerosols produced, 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) mentioned earlier in this chapter. Coal Pile Runoff When stored in exposed piles, coal may be exposed to rainwater, snowfall, spraying for dust control, or underground streams, which may create an acidic leachate. Manufacture of metal compounds may result from the dissolution of metal compounds in a coal pile into stormwater runoff. The acidity of the leachate may increase the solubility of some metal compounds, thereby dissociating these compounds, removing them from the coal pile, and carrying them off in the runoff. Depending on various factors (pH, coal composition, temperature, and length of exposure), these compounds may or may not form new metal compounds in the runoff. For example, the facility may know that the copper present in the coal is in the form of copper oxide. During dissolution, copper oxide in runoff may be converted to copper hydroxide. Facilities must use the best "readily available data" to determine whether a new metal compound is created during reactions that take place in the coal pile or runoff. This may include monitoring data or discharge monitoring reports (DMRs). The quantity of metal compound created must be applied towards the 25,000 pound manufacturing threshold. In absence of better information, facilities should assume that the quantity of metals in coal pile run-off are not exempt (i.e., assume that a new metal compound has been manufactured). Typically, most facilities may have data on the concentrations of metals present but not on whether the metals are present as compounds and what conversions may or may not have taken place. The chemical formulas and conversions for the lowest weight oxides of metals typically found in coal are listed in Table 3-4. This quantity of lowest weight oxides could then be applied to calculating your manufacturing threshold for metal compounds. For threshold determinations, facilities may assume that the EPCRA Section 313 metal compound that has been manufactured is the lowest weight oxide. EPA recognizes that oxides are not formed in water, but is allowing facilities to make this assumption for simplicity and consistency with the combustion assumptions. Note that if a facility has better "readily available data," they are required to use it. 3-31 ------- A mining facility stores coal or ore outside. One or more EPCRA Section 313 chemicals are contained within the storage piles. Due to exposure and weathering influences, other EPCRA. Section 313 chemicals are manufactured in the storage piles and may subsequently run-off onto land or surface water. How should the facility consider the manufacturing of EPCRA Section 313 chemicals within a storage pile? Amounts of Section 313 chemicals known to be "manufactured" on-site from the, storage of raw materials,. mixtures, or other trade name products must be considered toward the "manufacturing" threshold for " those chemicals. The term "manufacture" means "to produce, prepare, import, or compound a toxic chemical." If the mining facility has knowledge that an EPCRA Section 313 chemical is "manufactured" on-site, the facility should count the amount of the EPCRA Section 313 chemical "manufactured" toward the "manufacturing" threshold. Importing. The "manufacture" threshold includes importing an EPCRA Section 313 chemical if the facility has caused the chemical to be imported. If your facility orders or enters into an agreement to obtain or accept an EPCRA Section 313 chemical (or a mixture or other trade name product or waste containing an EPCRA Section 313 chemical) from a source outside the customs territory of the United States (the 50 states, the District of Columbia, and Puerto Rico) then your facility has imported a EPCRA Section 313 chemical and amounts must be considered toward the manufacturing threshold. Note that if an entity other than the facility, such as a third party not directly associated with the facility (e.g., a chemical broker), ordered the chemical without specific direction from the facility, then that third party has "caused" the chemical to be imported, and the facility does not need to consider the EPCRA Section 313 chemical toward their manufacturing threshold. Imported chemicals, as well as any others that undergo a manufacturing activity, may also be subsequently processed and/or otherwise used, and amounts associated with these activities need to be applied to all appropriate threshold determinations. Processing Processing means preparing an EPCRA Section 313 chemical, or a mixture or other trade name product containing an EPCRA Section 313 chemical (usually the intentional incorporation of an EPCRA Section 313 chemical into a product) for distribution in commerce. Perhaps the most pivotal element of the processing definition is that the EPCRA Section 313 chemical must be prepared for distribution into commerce. If a material is produced or recovered for use on-site, the material has not been prepared for distribution into commerce, and thus is not counted towards the processing threshold (see the discussion of otherwise use for the applicability of chemicals used on-site). In addition, distribution into commerce does not only mean that the material must be sold to a customer. Distribution in commerce includes any distributive activity in which benefit is gained by the transfer, even if there is no direct monetary gain (e.g., intra- company transfers). The following table describes the subsections of processing for reporting purposes. 3-32 ------- Table 3-9 Examples of Processed Chemicals Processing Activity , As a reactant As a formulation component As an article component Repackaging for distribution into commerce \, Examples, ; > - May not occur in the coal mining industry. The addition of ethylene glycol to prevent freezing for transportation to an off-site location. Ash (from coal combustion, such as thermal drying) used directly in the manufacture of gypsum. Ash (from thermal drying) sent off-site for use in concrete manufacturing. Processing of Ore. A primary example of a processing activity likely to take place at coal mining facilities is the preparation of coal for distribution into commerce. Extraction of ore containing EPCRA Section 313 chemicals for subsequent distribution in commerce constitutes the "processing" of those listed chemicals. Amounts of materials that undergo a "processing" step as part of the faculty's preparation of a material for distribution in commerce are considered "processed." For example, metal compounds in the ore are considered process. These materials must be considered toward the facilities "processing" threshold even if the original compound, such as a metal compound that converts to another metal compound, no longer exists in its original form. This is because a portion of that original compound is incorporated into the product being prepared for distribution in commerce. Therefore, metal compounds in extracted ore are processed, even if they are later converted to different compounds. Keep in mind, however, that metal compounds in coal are expected to be present below de minimis levels and amounts of EPCRA Section 313 chemicals processed in concentrations below the de minimis levels are exempt from threshold determinations and release and other waste management calculations (see Chapter 3.2.2, Evaluation of Exemptions). Example - Distribution into Commerce * , ™ J _r*c~ £*" ~ m **" ? ,/* ^<- * & ^ " •* " If ore is extracted for ultimate distribution in commerce, are EPCRA Section 313 chemicals in ore that are not actually distributed during the reporting yea* considered to be processed for threshold determination purposes, since they were prepared for distribution during the reporting year? . " " ' ^* '"„*' :" N * /-. V", '': ' - ;«•" * r> f f J1 <, •» " * ^ *. •* "t -1 *. * "=*•• Yes. The total amounts of the EPCRA Section 313 chemicals contained in the ore are considered / toward the facility's processing threshold'in the year that the amounts undergo a processing step. For purposes of EPCRA Section 313 threshold determination,, extraction is considered a processing step t and all amounts .extracted for preparation of a product to be distributed in commerce are considered * "processed" in the year they are extracted. . - ^ - __- " ;" > ", *,, j/-* .'"-*-' Anti-freezing Agents. Depending on regional weather conditions, antifreezing agents are used to facilitate the movement of coal in cold climates. The application of EPCRA Section 313 3-33 ------- chemicals, such as ethylene glycol for the purposes of enhancing the product for the customer, is considered a processing activity and amounts must be applied to the processing threshold of 25,000 pounds. Alternatively, ethylene glycol may be sprayed on coal to prevent freezing during storage. Use of a chemical in this manner, to prevent freezing of coal on-site, must be applied to the otherwise use threshold of 10,000 pounds. Ash Management. Some coal mining facilities conduct thermal drying on-site that may create ash. The distribution of ash into commerce for direct reuse in concrete or gypsum manufacturing is considered a processing activity. Ash sent off-site for this type of activity, would be eligible for the de minimis exemption when considering amounts toward the processing threshold. A facility may also distribute ash off-site for recycling (e.g., vanadium recycling). Facilities that send ash off-site for recycling must also count amounts of EPCRA Section 313 chemicals in the ash towards their processing thresholds. However, amounts transferred off-site for this purpose would not be eligible for the de minimis exemption because these amounts are being managed as a waste. Transfers Off-site for Recycling. Amounts of EPCRA Section 313 chemicals sent off- site for recycling also must be considered toward the processing threshold of 25,000 pounds. Amounts of materials containing EPCRA Section 313 chemicals sent off-site for recycling are prepared for distribution into commerce. Materials sent off-site for recycling must undergo a recovery step and are, therefore, considered a waste and not eligible for the de minimis exemption. Wastes destined for off-site recycling are considered wastes sent off-site for further waste management, which are not eligible for the de minimis exemption and must be reported on the Form R in Sections 6 and 8. Transferring a waste which contains an EPCRA Section 313 chemical off-site for energy recovery is not considered processing, even if the waste has been blended with other wastes and repackaged. For example, a facility should not count EPCRA Section 313 chemicals in high carbon ash or spent solvents that are sent off-site for energy recovery toward their processing threshold. However, if a threshold for EPCRA Section 313 chemicals contained in these materials has been exceeded elsewhere at the facility, then these amounts would be reported as transferred off-site for energy recovery. Transfers Off-site for Direct Reuse. Amounts of EPCRA Section 313 chemicals sent off-site for direct reuse must be considered toward the processing threshold of 25,000 pounds. Materials are considered to be sent off-site for direct reuse if the materials are distributed into commerce and are going to be directly used in an operation or application without any recovery steps including the extraction of contaminants. Materials sent off-site for direct reuse are not reported on the Form R in Sections 6 and 8 as recycled or released because the materials are not considered wastes. Because materials sent off-site for direct reuse are not considered wastes, these materials may qualify for the de minimis exemption if any EPCRA Section 313 chemical in the material is below the de minimis level (see Chapter 3.2.2.3). EPCRA Section 313 chemicals in waste that are sent off-site for further waste management (e.g., disposal) are not considered to be reused. 3-34 ------- Otherwise Use "Otherwise use" is any use of an EPCRA Section 313 chemical that does not fall under the definitions of "manufacture" or "process." Chemicals otherwise used are not incorporated into a product that is distributed into commerce and includes such uses as a processing or manufacturing aid and for such ancillary uses as treating wastes. Otherwise use of an EPCRA Section 313 chemical also includes disposal, stabilization (without subsequent distribution in commerce), and treatment for destruction if the: (1) EPCRA 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) EPCRA Section 313 chemical that was disposed, stabilized, or treated for destruction that was manufactured as a result of waste management activities of materials received from off-site for the purpose of further waste management. The following discussion describes the subsections of the otherwise use threshold for reporting purposes (see Table 3-10). Table 3-10 Examples of Otherwise Used Chemicals Otherwise Use Activity Subcategory Examples As a chemical processing aid May include conditioners, additives for froth flotation and thickening/sedunentation, and flocculents for filtration drying. As a manufacturing aid Ethylene glycol sprayed on coal to prevent freezing during storage at the plant Ancillary or other use Ammonia used for pH control. The use of EPCRA Section 313 chemicals in support activities such as cleaning, maintenance, purification, or reclamation (e.g., pesticides, fertilizers). Ash containing EPCRA Section 313 chemicals used for mine reclamation/road aggregate. Ash containing EPCRA Section 313 chemicals received from off-site for disposal. * More complete discussions of the industry-specific examples can be found in Section 5 of this guidance document. Combustion. All EPCRA Section 313 chemicals contained in fuels combusted are considered otherwise used. For example, metal compounds contained in coal in addition to the high BTU organic compounds are considered otherwise used. This type of chemical use is 3-35 ------- eligible for the de minimis exemption and many of the EPCRA Section 313 chemicals contained in fuels commonly used exist in below de minimis concentrations. Facilities do not have to apply chemicals present in coal and oil that exist below de minimis levels towards the otherwise use activity threshold. Unless a facility has other information, they may assume that chemicals in coal are below de minimis levels. Other fuel types, however, may contain EPCRA. Section 313 chemicals above de minimis levels. In the absence of better facility-specific data, facilities may use this table to calculate threshold quantities for EPCRA Section 313 chemicals otherwise used in fuels. Froth Flotation. Some facilities produce a fine-grade coal which may require special cleaning techniques. Froth flotation is a technique that may be used by these facilities for cleaning their fine-grade coal. Flotation typically will be conducted using air, water, coal slurry, and flotation agents (e.g., collectors, activators, depressants, dispersants, or flocculents) specifically selected to recover the desired fine coal. Collectors (promoters), may include fuel oil and kerosene. Table 3-11 shows the EPCRA Section 313 chemical constituents typically present in collecting agents commonly used. Depressants may also be used, but these are not likely to contain EPCRA Section 313 chemicals. Froth activators function by reducing surface tension, thus allowing froth formation, however, these products are also not likely to contain EPCRA Section 313 chemicals. Table 3-11 Estimated Concentration Values of EPCRA Section 313 Constituents in Crude Oil and Petroleum Products (Weight Percent) Section 313 Chemical Benzene Biphenyl Bromine Chlorine Cycloheunc Ethylbenzene n-Hexanc MTBEk Naphthalene Pbenanthiene Phenol PACs- Slyrenc De Minimis Level* 0.1 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 0.1 0.1 Crude Oil 0.446 R 0.060" N/A N/A 0.700 0.346" 2.463" N/A 0.219" N/A 0.323 0.0004 N/A Gasoline (Various Grades) 1.608" 0.010" N/A N/A 0.240 1.605R 7.138" 15.00 0.444" N/A 0.055 N/A N/A« No.ZFuel Oil/ Diesel Fuel 8.0E-04* 0.100 N/A N/A N/A 0.013 A 1.0 A N/A 0.550 0.125 0.064 N/A 0.032" Jet Fuel CJP-4) 1.0* 0.120" N/A N/A 1.240 0.50 A 5.60 A N/A 0.468" N/A N/A N/A N/A Kerosene 0.004* 0.120" N/A N/A N/A 0.127 A 0.005 A N/A 0.733 R N/A 0.770 N/A N/A Lubri- cating Oil N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A No. 6 Fuel Oil 0.001 N/A 3.0E-06 0.0131" N/A 0.0022 N/A N/A 0.10 N/A N/A 1.13 N/A Aviation Gasoline 0.515" N/A N/A N/A N/A 0.432" 0.126" N/A 0.10" N/A N/A N/A N/A 3-36 ------- Chemical Toluene 1,2,4-Trimethyl- benzene Xylene Antimony Arsenic" Beryllium1 Cadmium11 Chromium' Cobalf Copper" Lead Compounds Manganese* Mercury" Nickel- Selenium" Silver" Zinc Compounds De Minimis Level* :. - - ' , . 1.0 1.0 1.0 0.1 0.1/1.0 c 0.1/1.0 c 0.1/1.0 ' 0.1/1.0 a 1.0 1.0 1.0 (organic) 0.1 (inorg.) 1.0 1.0 ' 0.1 1.0 1.0 1.0 Crude Oil 0.878R 0.326 1.420 R l.OE-05 2.0E-05 2.0E-07 4.0E-07 4.0E-05 0.0003 4.0E-05 N/A N/A 0.0006 0.0055 4.0E-05 N/A N/A Gasoline (Various Grades) 7.212R 2.501 7.170 R N/A N/A N/A N/A N/A N/A N/A N/A N/A ' N/A N/A N/A N/A Nb.2Fuei Oil/ Diesel Fuel 0.032* 1.0* 0.290A N/A 8.5 ^ 50 *M 2.i MS 95&05 N/A 5.6E-04 N/A 2.1E-05 4.0E-05 3.38E-04 N/A N/A N/A Jet Fuel 0P-4) 3.20A N/A 3.20 A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Kerosene 1.330 A N/A 0.31* N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Lubri- cating N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 1.0 No. 6 fuel Oil 0.006 N/A 0.013 l.OE-06 3.06E- 05" 2.7E-06" 2.0E-060 3.1E-05" 1.63E- 04D 3.0E-05 1.41E- 04D 3.5E-05" 9.2E-07" 2.6E-03" 9.5E-06" 2.0E-08 N/A Aviation Gasoline 7.327 N/A 2.204 N/A N/A N/A N/A N/A N/A 0.14- N/A N/A N/A N/A aid Pe'tote^ftoduS ™W------- reclamation are subject to the otherwise use threshold of 10,000 pounds. Examples of such materials include coal ash, fertilizer, non-exempt top soil, overburden, and waste rock. When mine reclamation activities occur simultaneously with, or as a result of, coal extraction activities, which involve materials containing EPCRA Section 313 chemicals, these chemicals are considered eligible for the coal mining extraction exemption, and the facility does not have to consider these amounts toward activity thresholds or release or other waste management calculations. For example, mines may conduct cast blasting operations in which overburden is displaced to gain access to a coal body. In this case, the overburden displaced to gain access to an extraction site, while possibly aiding in the backfilling or reclamation of a completed area, is considered covered by the coal extraction activities exemption and the amount of any EPCRA Section 313 chemicals that may be present in the overburden is exempt from threshold determinations and release and other waste management calculations. Likewise, topsoil, overburden, and waste rock recovered on-site that are otherwise displaced to gain access to a coal body, such as with the use of drag lines and haul trucks, are also eligible for the coal extraction activities exemption. Also, amounts of EPCRA Section 313 chemicals contained in these materials are exempt from threshold determinations and release and other waste management calculations, including disposal back into the area from which it came. Ash generated on-site or received from off-site may be applied to the land as backfill for mine reclamation or for pH control of the soil. Ash used in this manner is not considered analogous to a substitute material with a commercial value. This application of ash to the land is considered a waste management of the ash and therefore the EPCRA Section 313 chemicals contained in the ash are not eligible for the de minimis exemption. The application to land of mixtures and other trade name products, such as commercial fertilizers, in mine reclamation activities is also considered an otherwise use activity and the EPCRA Section 313 chemicals that may be present in these mixtures and other trade name products are eligible for the de minimis exemption. Example - Soil Reclamation A mining facility receives waste sewage sludge from off-site for use in soil reclamation. Is the application of sewage sludge to land considered an otherwise use? Are the EPCRA Section 313 chemicals used in the soil reclamation activity eligible for the de minimis exemption? The mine is otherwise using the EPCRA Section 313 chemicals contained in the waste sewage sludge as soil building material. However, because the EPCRA Section 313 chemicals contained in the waste sludge are being managed as a waste. The amounts of EPCRA Section 313 chemicals being otherwise used are not eligible for the de minimis exemption. In any case, it is important to note that if an activity threshold is exceeded and EPCRA Section 313 reporting is required, you must considered all non-exempt applications to land of 3-38 ------- reportable EPCRA Section 313 chemicals as releases to land (Section 5.5 of the Form R), including from mine reclamation activities. Other Activities. Otherwise use includes the use of EPCRA Section 313 chemicals in activities such as cleaning, maintenance, and pH control. The use of an EPCRA Section 313 chemical to treat another chemical constitutes an otherwise use. ; " , ,, "-y-' Example - Storage " ' / ' "\A-^ * " ;. Y~ * ' . "'•,,,'" "w A coal aainereceives a flotation agent containing an ERCRA Section 313 chemical in December of 1998, but does not use it until January of 1999. Is the ainbuht of 3EPQRA Section 313 chemical in the flotation agent considered for threshold determinations in the 1998 reporting yeaV? No, Storage in itself'of an EPCRA Section 313 chemicalis not considered a manufacturing, processing,' or otherwise u$s activity ,and, therefore', is notsubject to thresholddeterminations. However, the facility is required'tb include any amounts released orotherwise nianaged that occur during storage of the " ' EPCRA Section 313 chemical, provided a threshold has been exceeded elsewhere at the facility. When the EPCRA Section 313 chemical is-used in 1999, the'facility will include me amount of EPCRA i Other Examples of EPCRA Section 313 Chemicals that Coal Mining Facilities "Otherwise-Use" • High alloy metals used to replace worn parts in brakers or rollers (some of these uses may be in parts that are eligible for the article exemption, see Chapter 3.2.2.3); • Ammonia used for pH control or water treatment; • Chemicals in fuel used in any on-site equipment (other than motor vehicles eligible for the motor vehicle maintenance exemption), such as for belt lines (e.g., conveyors); • Chemicals in ash (or other wastes) that are received from off-site and disposed on- sife; • Chemicals in ash used for pH control of soil during mine reclamation; • Chemicals used to clean boilers and other equipment; • . Chemicals in materials that are used to maintain process equipment (e.g., lubricants, solvents); • Chemicals used to treat boiler make-up water, or cooling tower water (e.g., chlorine, chlorine dioxide, bromine); and • Chemicals used to treat wastes, such as coagulants, flocculents, or ammonia in sedimentation ponds. 3-39 ------- Waste Management Activities. 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. However, for calculating thresholds, the only quantity that should be applied to the otherwise use threshold are those that are treated for destruction, stabilized, or disposed on-site. Waste management does not include the storage, container transfer, or tank transfer of an EPCRA Section 313 chemical if no recycling, combustion for energy recovery, treatment for destruction, waste stabilization, or release of the chemical occurs at the facility (62 FR 23850; May 1,1997). Table 3-12 EPA Guidance Related to Waste Management Activities Waste Management Activity Description Recycling As referenced in the May 1, 1997, Federal Register and defined in the document, Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery, Treatment for Destruction, Waste Stabilization, and Release (April 1997), recycling means: (1) the recovery for reuse of an EPCRA Section 313 chemical from a gaseous, aerosol, aqueous, liquid, or solid stream; or (2) the reuse or the recovery for use of an EPCRA 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 EPCRA Section 313 chemical from a waste stream and includes: (1) the reclamation of the EPCRA Section 313 chemical from a stream that entered a waste treatment or pollution control device or process where destruction of the stream or destruction or removal of certain constituents of the stream occurs (including air pollution control devices or processes, wastewater treatment or control devices or processes, Federal or state permitted treatment or control devices or processes, and other types of treatment or control devices or processes); and (2) the reclamation for reuse of an "otherwise used" EPCRA Section 313 chemical that is spent or contaminated and that must be recovered for further use in either the original or any other operations. Combustion for energy recovery Combustion for energy recovery is interpreted by EPA to include the combustion of an EPCRA 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 © a spent or contaminated "otherwise used" material; and that (2) has a significant heating value and is combusted 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). If a reported toxic chemical is incinerated but does not contribute energy to the process (e.g., metal, metal compounds, and chloroflorocarbons), it must be considered treatment for destruction. In determining whether an EPCRA Section 313 chemical is combusted for energy recovery, the facility should consider the heating value of the EPCRA Section 313 chemical and not the heating value of the chemical stream. 3-40 ------- Treatment for destruction Means the destruction of an EPCRA Section 313 chemical in waste such that the substance is no longer the EPCRA Section 313 chemical subject to reporting. Treatment for destruction does not include the destruction of an EPCRA Section 313 chemical in waste where the EPCRA 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 EPCRA 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 EPCRA Section 313 chemicals if the EPCRA Section 313 chemicals themselves do not react with the acid or base (See 40 CFR §372.3), (2) preparation of an EPCRA Section 313 chemical for disposal, (3) removal of EPCRA 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. (Note: Amounts of metals CAN NOT be destroyed and therefore should not be reported as treated for destruction.) Waste stabilization Means 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 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 EPCRA Section 313 chemical. (See 40 CFR §372.3.) Disposal Disposal means any underground injection, placement in landfills/surface impoundments, land treatment, or other intentional land disposal. (See 40 CFR §372.3.) (See EPA document, Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery, Waste Stabilization and Release for further detail.,) Waste management activities conducted by a facility on EPCRA Section 313 chemicals in wastes generated on-site are not considered an otherwise use of that chemical. The otherwise use threshold applies to amounts disposed, stabilized (without subsequent distribution in commerce), or treated for destruction from wastes received from off-site or from chemicals generated from waste received from off-site. For example, Section 313 chemicals in ash received from an electricity generating facility for disposal must be applied to the otherwise use threshold. Because the Section 313 chemicals in the ash are being managed as waste, they are not eligible for the de minimis exemption. 3-41 ------- Example - Otherwise Use A facility captures leachate from a landfill, treats the leachate with an EPCRA Section 313 chemical, and then uses the treated leachate (which now contains the EPCRA Section 313 chemical) as,on-site irrigation water. Is the facility "otherwise using" the EPCRA Section 313 chemical in the irrigation water, and should the facility report the EPCRA Section 313 chemical as a release to land in Section 5J.4, Other Disposal? ' ' - ' "'^'" ' -~ , "^—/~-rf ••-«'•*« Yes. Use of EPCRA Section 313 chemicals contained in the treated leachate for irrigation purposes is considered an "otherwise use" and amounts of these chemicals contained in the treated leachate must be counted toward the "otherwise use" threshold. Any EPCRA Section 313 chemicals manufactured during the treatment of the leachate would also need to be considered toward the "manufacturing" threshold. The treated leachate, and EPCRA Section 313 chemicals contained in the treated leachate, are also considered a^waste and any "otherwise use" of EPCRA Section 313 chemicals contained in the treated leachate is not eligible for the de mlnimis exemption. The "otherwise use" of these chemicals for irrigation constitutes a release to land and would be reportable in Part n 5.5.4 Other Disposal. Special "Otherwise-Use" Activities to Consider for Coal Mining Facilities. • When considering what EPCRA Section 313 chemicals are managed during the year, you should consider not only the amount of each of those chemicals in wastes that are treated or disposed during the year, but also the amount of virgin EPCRA Section 313 chemicals used at the facility (e.g., to facilitate the treatment processes or for cleaning operations). These chemicals must be included in calculations of the otherwise use threshold. • EPCRA Section 313 chemicals used in support activities such as froth flotation, process-related equipment maintenance, and dewatering activities are also typically classified as "otherwise use" activities. • Any EPCRA Section 313 chemicals that a facility uses as processing or manufacturing aids or for treating waste are "otherwise used." • EPCRA Section 313 chemicals in materials used as fuel or for maintaining equipment operations, other than for maintaining motor vehicles, should be included in the threshold determination for "otherwise use" activities. • Any EPCRA Section 313 chemicals in materials used in waste management processes should also be included in the threshold determination for "otherwise use" activities. For example, any material that is used as feedstock in a recovery process, as auxiliary fuel in incineration, as a chemical in the treatment process (e.g., flocculation agents, acids), or as an additive to reclaimed materials prior to customer delivery should be included in the threshold determinations. 3-42 ------- - . ' Example - Timing" " "'„"•'-' '' " '". < ,\LX #*'-- . . ' \ - JV\'J'-/" ''"V/'", %" * A facility receives waste containing an EPCRA Section 313 chemical from off-site and disposes the waste on-site. Should the facility count the EPCRA. Section 313 chemicals in the waste towards the 'otherwise =i use' threshold upon receipt of the waste shipment (e.g., signing the hazardous waste manifest) or upon actual disposal? "'' - , - « . * *>< "• •>&}*# / \ "^.^•N ------- • If only the lower bound is specified and no information on other components is given assume the upper bound is 100% and calculate the mid-point as above. Even if the concentration of a chemical is known through engineering knowledge only, the facility is still required to consider the chemical for threshold determinations. For example, facility engineers may have knowledge that nitric acid is manufactured in an on-site incinerator. If there are no waste profiles or permit information specifically listing nitric acid, the facility must still consider the chemical for threshold determinations. This determination should be made based on their best "readily available data", be it process knowledge or other reasonable estimation techniques. When determining concentration information for wastes, it is important to understand that the de minimis exemption does NOT apply to wastes. If your waste profiles (or other information) indicate that there are chemicals present that are below the detection limit, you may still need to include those chemicals in your threshold determinations and release and other waste management calculations. If you have no information to indicate that the chemical exists in the waste stream, you may assume that the concentration is zero. However, if the facility has reason to believe that the EPCRA Section 313 chemical is present in the waste, you may use half of the detection limit for that chemical when making threshold determinations and release and other waste management calculations. Example - Average Concentration Is it appropriate for a coal mining facility to develop an average concentration for an EPCRA Section 313 chemical contained in many different shipments of ash received from off-site for disposal and then use that average as a basis of threshold determination? If so does EPA have a recommended approach for developing such an average? '•','"* EPCRA allows facilities to use best "readily available data" to provide information required under EPCRA Section 313. When data are not readily available, EPCRA allows facilities to use "reasonable estimates"of ihe amounts involved. A facility must use its best judgment to determine whether data are "readily available," Thus, with regard to use of average concentration levels, a facility must use its best judgment to decide Whether the raw data from which it might base any average concentration level are "readily available"* In any event, a facility should carefully document its decision making. For example, if a facility decides to use average concentration levels, it should document why the raw data from which the averages are based are not "readily ' available", how it arrived at any average concentration level used, and why the average concentration level is a "reasonable estimate"of the amount of the EPCRA Section 313 chemical in the waste stream., EPA does riot have a recommended approach for determining average concentration levels. 3-44 ------- 3.2.2 Evaluation of Exemptions EPCRA Section 313 provides facilities with certain exemptions: • Coal Extraction Activities Exemption; • Laboratory Activities Exemption; • De minimis exemption; • Exemptions that apply to the otherwise use of chemicals: routine janitorial/facility grounds maintenance; personal use exemption; structural component exemption; motor vehicle maintenance exemption; exemption for air or water drawn from the environment or municipal sources for certain uses. 3.2.2.1 Coal Extraction Activities Exemption EPA specifically exempted coal extraction activities from threshold determinations and release and other waste management calculations. As stated in (62 FR 23892), if an EPCRA Section 313 chemical is manufactured, processed, or otherwise used in extraction by facilities in SIC code 12, a person is not required to consider the quantity of the toxic chemical so manufactured, processed, or otherwise used when determining whether an applicable threshold has been met under §372.25 or §372.27, or determining the amounts to be reported under §372.30. EPA defines coal extraction, for purposes of determining which activities are eligible for the "extraction exemption" to mean the physical removal or exposure of ore, coal, minerals, waste rock, or overburden prior to beneficiation, and to encompass all extraction-related activities prior to beneficiation. EPA defines beneficiation as the preparation of ores to regulate size (including crushing and grinding) of the product, to remove unwanted constituents, or to improve the quality, purity, or grade of a desired product. In terms of identifying which coal mining activities are considered part of the coal extraction activities exemption under 40 CFR 372, EPA has made the following determinations: 3-45 ------- Coal Extraction Activities Exemption Applies Any use of explosives to remove ore is exempt from threshold determinations and release and other waste management reporting. Land disposal of materials including overburden, waste rock, ore, and oily water from underground coal extraction activities are considered part of extraction activities and therefore exempt from threshold and release and other waste management calculations. Reclamation activities occurring simultaneously with coal extraction activities (e.g., cast blasting). Use of EPCRA Section 313 chemicals for extraction- related maintenance of equipment. Coal Extraction Activities Exemption Does. Not Apply Crushing and screening of coal is not considered part of extraction and amounts of EPCRA Section 313 chemicals involved in these activities must be considered toward threshold determinations and release and other waste management calculations. Otherwise use of ash, waste rock, or fertilizer for reclamation purposes are not considered part of extraction; non-exempt amounts of Section 313 chemicals contained in these materials must be considered toward threshold determinations and , release and other waste management calculations (see: Chapter 3.2 - Reclamation). EPCRA Section 313 chemicals received in ash from off-site (e.g., from an electricity generating facility) and used as back-fill or structural support underground, must be considered toward the otherwise use threshold. ~" EPCRA Section 313 chemicals used to maintain belt lines and other stationary equipment used to transport coal to processing plants following extraction. Example - Coal Extraction Activities Exemption EPA provided a reporting exemption for coal extraction activities (62 FR 23833). Can a coal mining facility assume that all activities prior to beneficiation, or in other words all activities that take place before the coal enters a processing plant, are exempt under the extraction exemption? J - 1 & No. EPA has specifically exempted only coal extraction activities from EPCRA Section 313 reporting. EPA defines coal extraction, for purposes of determining which activities are eligible for the "extraction exemption" to mean the physical removal or exposure of ore, coal, minerals, waste rock, or overburden prior to beneficiation, and to encompass all extraction-related activities prior to beneficiation. EPA defines beneficiation as the preparation of ores~t6'regulaie size (including crushing and grinding) of the product, to remove unwanted constituents, or to improve tire quality, purity, or grade of a desired product Based on these definitions, certain non-extraction activities such as crushing, grinding, or screening may occur before coal enters a processing plant which are not exempt under the extraction exemption. 3-46 ------- 3.2.2.2 Laboratory Activities Exemption This exemption includes EPCRA Section 313 chemicals that are manufactured, processed, or otherwise used in a laboratory under the supervision of a technically qualified individual. This exemption may be applicable in such circumstances as laboratory sampling and analysis, research and development, and quality assurance and quality control activities. It does not include pilot plant scale or specialty chemical production. It also does not include laboratory support activities. For example, chemicals used to maintain laboratory equipment are not eligible for the laboratory activities exemption. Example - Laboratory Activities Exemption / _'*--/ N « , , - - - > . ^ If a facility takes a sample from its process stream to be tested in a laboratory for quality control purposes, are releases of an EPCRA Section 313 chemical from the testing of the sample in the laboratory exempt under the laboratory activities exemption? > • * * -:"-; •""" Yes, provided that the laboratory at the.coyered facility is under ihe direct supervision^ a technically qualified individual as provided in 40 CER 372.38(d). The-laboratoiy exemption applies to the "manufacture?' "process," or "otherwise use" of EPCRA^Section 313 chemicals and My, associated release and other waste-management amounts that take place in a qualifying laboratory. ' , „,; * " 3.2.2.3 DC Minimis Exemption If the amount of EPCRA Section 313 chemical(s) present in a mixture or other trade name product processed or otherwise used is below its de minimis concentration level, that amount is considered to be exempt from threshold determinations and release and other waste management calculations. (Note that this exemption does not apply to manufacturing, except for importation or as an impurity as discussed below.) Because wastes are not considered mixtures or other trade name products, the de minimis exemption cannot apply to wastes. The de minimis concentration for mixtures or other trade name products is 1%, except for OSHA-defmed carcinogens, which have a 0.1% de minimis concentration. If a mixture or other trade name product contains more than one member of a compound category, the weight percent of all members must be summed. If the total meets or exceeds the category's de minimis level, the de minimis exemption does not apply. Information may only be available that lists the concentration of chemicals in mixtures as a range. EPA has developed guidance on how to determine quantities that are applicable to threshold determinations and release and other waste management calculations when this range straddles the de minimis value. EPA has published several detailed questions and answers and a directive in the EPCRA Section 313 Q&A Document that may be helpful if you have additional concerns about the de minimis exemption. The TRI Forms and Instructions list each EPCRA Section 313 chemical and compound category with the associated de minimis value. The de minimis exemption also applies in limited circumstances to the manufacture of EPCRA Section 313 chemicals. In the specific case where EPCRA Section 313 chemicals are 3-47 ------- coincidentally manufactured in a product and remain in the product as an impurity which is then subsequently distributed in commerce, amounts of EPCRA Section 313 chemicals are eligible for the de minimis exemption. The de minimis exemption also applies to EPCRA Section 313 chemicals below the de minimis concentration in an imported mixture or other trade name product. The de minimis exemption, however, does not apply to EPCRA Section 313 chemicals that are coincidentally manufactured as byproducts that are separated from the product; nor does it apply to chemicals that are coincidentally manufactured as a result of treatment or other waste management activities, or to waste brought on site for waste management. Coal mining facilities which combust fuel for thermal drying must consider amounts of EPCRA Section 313 chemicals manufactured during combustion. Combustion may result in the coincidental manufacture of such EPCRA Section 313 chemicals as sulfuric acid aerosols, hydrochloric acid aerosols, hydrofluoric acid, and certain metals and metal compounds, as discussed earlier in this chapter. Since the de minimis exemption does not apply to the coincidental manufacture of chemicals as byproducts, the formation of these compounds in any concentration must be considered for threshold determinations and release and other waste management calculations. The de minimis exemption applies to materials otherwise used or processed, such as ash distributed into commerce for direct reuse. Example -Ash Distributed into Commerce An EPCRA Section 313 covered facility combusts coal in a combustion unit. The coal contains an EPCRA Section 313 chemical below de minimi's amounts. An ash containing the EPCRA Section 313 chemical is generated from the combustion of the coal. The ash which meets industry specification, is then sold to another facility for use in the manufacture of concrete. If the EPCRA Section 313 chemicals in the ash are below the appropriate de minimis concentration, are they eligible for the de minimis exemption? * i " The EPCRA Section 313 chemicals in the coal being combusted should be considered towards, the faeiiity's otherwise use threshold and this activity is eligible for the de minimis exemption. The EPCRA Section 313 chemicals that are manufactured as a result of the combustion process are by products and therefore not eligible for the de minimis exemption when determining whether the manufacturing threshold has been exceeded. The EPCRA Section 313 chemicals in the ash that is sold are considered processed. After combustion, when the facility is preparing the EPCRA Section 313 chemicals in ash for distribution in commerce, they are eligible lor"" the de minimis exemption. ' _ ' ~ -i\", * 3-48 ------- I?e Mfn/m/'s Exemption Applies «, A facUity distributes coal containing EPCRA Section 313 chemicals into commerce. This activity constitutes a processing activity, and the de minimis .exemption applies to amounts of EPCRA Section 313 chemicals in the coal distributed into commerce and to releases and other waste' management activities associated with this processing activity. 7 ; ' ~ " . - „ >*t ,, Because the facility receives the waste ash from off- site for purposes of further waste management the de minimis exemption does not apply, anil the facility must consider the amount of the EPCRA Section 313 chemical towards its^&erwjsfruse" T threshold. If the facility exceeds the threshold for an EPCRA^Section 313 chemical, they must report the amount of EPCRA Section 313 chemical , disposed on-site and any other releases and waste management activities on the Form R, ^. 7™" - A facility combusts coal for thermal drying. The de minimis exemption does not apply to the • •. manufacture of EPCRA Section 313 chemicals J(e«g., sulfuric acid, metal compounds, etc.) during " combustion. If the facility exceeds a threshold for any^EPCRA^ection 313 chemical, they jmust ' ', consider the amount of the EPCRA Section 313 chemical toward their release and other waste management calculations. ';: ~ , * Coal mines are likely to receive all of the ash they use for reclamation or otherwise use activities from off-site. It is expected that the electricity generating facility from which the coal mining facility receives their ash has determined the quantities of metals present in their ash. Additionally, coal mining facilities maintain contractual agreements with the electricity generating facilities to whom they supply coal which stipulate that the ash will be returned to the coal mine. These contracts may contain concentration data for metals and metal compounds contained in the ash and can be used in combination with the total ash received to calculate the quantities of metals and metal compounds otherwise used. If the coal mining facility does not have access to this type of data, it may use the default values presented in Table 3-13 presented below. 3-49 ------- Table 3-13 Total Constituent Concentrations of Elements in Coal and Coal Combustion Residuals Element Concentrations in Different Materials (p Element (units) Antimony Arsenic Barium Cadmium Chromium Copper Lead Manganese Mercury Nickel Selenium Silver Vanadium Zinc Coal 14 106 250 6.5 610 185 218 181 1.6 104 8 8 1,281 5,600 By Ash 131 6,300 13,800 130 900 2,200 2,120 3,000 12 4,300 134 36 1,180 3,500 pin) Bottom Ash 10 168 9,360 10 5,820 932 1,082 1,940 4.2 2,939 14 9.9 537 1,796 Source: Adapted from Electric Power Research Institute (EPRI). Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume 1.1987; and Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, April 1997, Appendix D, Table D-2. Note: If specific concentration data of Section 313 chemicals in the coal and coal combustion residues are not available, your facility may use the default values provided in this table to estimate concentration values of constituents. Once the de minimis level has been met or exceeded, the exemption no longer applies to that process stream, even if the concentration of the EPCRA Section 313 chemical in a mixture or other trade name product later drops below the de minimis level. All releases and other waste management activities are subject to reporting after the de minimis concentration has been equaled or exceeded, provided an activity threshold has been exceeded. 3-50 ------- Examole - De Miniittis A facility receives a Mxttire with jjnEl^CRA-Section 313 ehernicaTih a^qnceritratkm below the.cfe ntjnimjs concentration. Duriitg processing, the concentration of the EPCRA Section 313 cfeemigal exceeds its efe miniiflis level. "This f^ciiit^-iiwist consider amciuats towar------- resulting waste is recycled or reused, either on site or off site such that the release and other waste management of the EPCRA Section 313 chemical in all like articles does not exceed 0.5 pound, then the article exemption status is maintained. Also, if the processing or otherwise use of similar manufactured items results in a total release and other waste management of less than or equal to 0.5 pound of any individual EPCRA Section 313 chemical in a calendar year, EPA will allow this quantity to be rounded to zero and the manufactured items to maintain their article exemption. The 0.5 pound limit does not apply to each individual article; instead, it applies to the sum of releases and other waste management activities (except recycling) from processing or otherwise use of all like articles for each EPCRA Section 313 chemical contained in these articles. For additional information, refer to the EPCRA Section 313 Q&A document presents several specific questions and answers/discussion pertaining to the article exemption. 3.2.2.5 Exemptions that Apply to the Otherwise Use of EPCRA Section 313 Chemicals Some exemptions are limited to the "otherwise use" of an EPCRA Section 313 chemical. EPCRA Section 313 chemicals used in these activities do not need to be included in a facility's threshold determinations and release and other waste management calculations, provided thresholds are met elsewhere. The following otherwise use activities are considered exempt (see most current versions of the TRI Forms and Instructions and EPCRA Section 313 Question and Answers documents): • EPCRA Section 313 chemicals used in routine janitorial or facility grounds maintenance. Examples are bathroom cleaners and fertilizers and garden pesticides in similar type or concentration distributed in consumer products. Materials used to clean process-related equipment do not qualify for this exemption. • EPCRA Section 313 chemicals for personal use. Examples are foods, drugs, cosmetics, and other personal items including those items used in cafeterias and infirmaries. Example - Personal Use Exemption Ammonia used to clean a cafeteria grill is exempt from threshold determinations and release and other waste management calculations. Chlorine added to the water supply system to prepare potable water for consumption at the facility is also exempt under the personal use , exemption. .- - EPCRA Section 313 chemicals in structural components of the facility. This exemption applies to EPCRA Section 313 chemicals present in materials used to 3-52 ------- construct, repair, or maintain non-process related structural components of a facility. An example common to all facilities would be the solvents and pigments used to paint the administrative office buildings. Materials used to construct, repair, or maintain process-related equipment (e.g., storage tanks, reactors, and piping) are not exempt. EPCRA Section 313 chemicals used to maintain facility motor vehicles. This exemption includes the use of EPCRA Section 313 chemicals for the purpose of maintaining motor vehicles operated by the facility. Common examples include EPCRA Section 313 chemicals in gasoline, radiator coolant, windshield wiper fluid, brake and transmission fluid, oils and lubricants, batteries, cleaning solutions, and solvents in paint used to touch up the vehicle. Motor vehicles include cars, trucks, forklifts, locomotives, and aircraft. The use of EPCRA Section 313 chemicals to maintain belt lines and other non-motor vehicles is not eligible for this exemption. Note that this exemption applies only to the OTHERWISE USE of the chemical only. The coincidental manufacture of EPCRA Section 313 chemicals resulting from combustion of gasoline is not considered part of the exemption and any amounts of EPCRA Section 313 chemicals coincidentally manufactured should be considered as part of the manufacturing threshold. Example - Motor Vehicle Exemption ^facility purchases ethylene glyeol, and iises it on-site to prevent coal from freezing. Hie facility must include the amount of ethylene glycol used on the coal for threshold determinations and release'and other waste management calculations. Hie facility also uses ethylene glycol in antifreeze and in windshield washer fluid in vehicles operated by the facility. These amounts are eligible for the motor vehicle exemption. The facility would not be required to include Ihe'amount of ethylene glycol in the windshield washer fluid or anti- freeze used for motor vehicles when making its threshold determination or in its release and other waste management calculations. .- «,"/,' ' "• '- -1 This exemption does NOT apply to stationary equipment. The use of lubricants and fuels for stationary process equipment (e.g., pumps and compressors) and stationary energy sources (e.g., furnaces, boilers, heaters), are NOT exempt. Example - Use of Lubricants Lubricants containing EPCRA Section 313 chemicals used on facility vehicles or bit-site structural maintenance .activities that are not integral to the process are exempt activities. However, lubricants jised, to maintain Dumps and compressors,' which aid in facility process- related operations, are not exemptand the amount of the chemical in that lubricant should be, applied to the otherwise use threshold. - ,* . ^, , - -*< 3-53 ------- Example - Motor Vehicle Exemption Are EPCRA Section 313 chemicals used to maintain fleets of large earth-moving vehicles at mining facilities exempt from threshold determinations and release or other waste management reporting? Yes. EPCRA Section 313 chemicals used to maintain motor vehicles EPCRA Section 313 chemicals in certain ah* and water drawn from the environment or municipal sources. Included are EPCRA Section 313 chemicals present in process water and non-contact cooling water drawn from the environment or a municipal source, or chemicals present in compressed air or air used in combustion. Example - Chemicals in Process Water A facility uses river water for non-contact cooling purposes. The river water contains 100 pounds of an EPCRA Section 313 chemical. Amounts of the EPCRA Section 313 chemicals contained in the river water do not have to be cbnSjderecl for threshold determinations and\ release and other waste management calculations because the EPCRA Section 313 chemicals was present as it was drawn from the environment. 3.2.3 Additional Guidance on Threshold Calculations for Certain Activities This section covers two specific situations in which the threshold determination may vary from normal facility operations: reuse and remediation activities of EPCRA Section 313 chemicals. 3.2.3.1 On-site Reuse Activities Threshold determinations of EPCRA Section 313 chemicals that are reused at the facility are based only on the amount of the EPCRA Section 313 chemical that is added during the year, and not the total volume hi the system or the amounts reused. 3-54 ------- Example - Reuse Activities «;. A fecflity operates ft heat transfer urtit lhat contains 15,000 pounds of ethylene jjycol at fli^beginning of the year that was in use^iaprior years! The system is charged with 2,000 pounds$ ethyfene glycof during ,the reportingVear? The facility has therefore "otherwise used" onlyf 2,000 pounds of the Covered jfePCRA "Section 313 chemical within that particular reporting year. A facility reporting" for the-first time wojild consider only the amount of BSPCRA Secjtton 313 chemical that is;addeia"durmg)ts 'first.reportingyear towards its "qthenyise use" ihreshold'for that year. Jf, however, the entire^heatjransfer uiiit was recharged with 15,005 pounds of " " ethylene glycol during the year, the facility would consider the45,CftX>jpounds toward its otherwise tie threshold; and,exc|S|edingfteomelrwise-^semreshold,\hejrequireato>report. -;7; "!,^,,s J,' -i 3.2.3.2 Remediation Activities EPCRA Section 313 chemicals that are being managed at a remediation site (e.g., Superfund) are not considered manufactured, processed, or otherwise used, and therefore, these amounts are not included in the threshold determinations. However, if during remediation activities, an EPCRA Section 313 chemical is manufactured, then these amounts would have to be considered toward the manufacturing threshold. Additionally, if you, are conducting remediation for an EPCRA Section 313 chemical for which you have exceeded a threshold elsewhere at the facility, you must consider this activity in your release and other waste management calculations. In that case, you must report any release and other waste management of an EPCRA Section 313 chemical due to remediation in Part n, Sections 5 through 8, accordingly, of the Form R. Those quantities, however, would not be considered as part of the reportable amount for determining Form A eligibility because they are not considered part of normal production related activities. 3.3 Step 3: Determine which EPCRA Section 313 chemicals exceed a threshold The final step is to determine which chemicals exceed a threshold. At this point you should have: 1. Determined each EPCRA Section 313 chemical at your facility; 2. Determined the threshold activity for each EPCRA Section 313 chemical (manufactured, processed, or otherwise used) and calculated the quantity for each activity. Now, you must sum the usage for each chemical by category, subtract all exempt quantities, and compare the totals to the applicable thresholds. Each EPCRA Section 313 chemical exceeding any one of the activity thresholds requires the submission of a Form R. Provided you meet certain criteria you may be eligible to file a Form A rather than a Form R. 3-55 ------- POSSIBLE ERROR - What if Your Facility Has No Releases Waste Management Quantities of EPCRA Section 313 Chemicals? er . . If you meet aU reporting criteria and exceed anv threshold for an EPCRA Section 31 alchemical, you must file a Form R or Form A for that chemical, even if you have zero releases and no other waste management activities, Exceeding the chemical activity threshold, not the quantity released and otherwise managed as waste, determines whether you must report. Note that if the total annual reportable amount is 500 pounds or less, and you do not exceed one million pounds manufactured, processed, or otherwise used for that chemical, then you . are eligible to submit a Form A rather than a Form R for that chemical (see Chapter 2.9). ' • " Calculating the Manufacturing Threshold for Section 313 Chemicals in Wastes Coal mining facilities typically do not manufacture chemicals or products intentionally. However, these facilities may coincidently manufacture Section 313 chemicals during incineration, wastewater treatment, and other waste management operations. You will also need to consider whether EPCRA Section 313 chemicals are produced coincidentally, even if the chemical exists for only a short period of time, and later is destroyed by air control equipment. Most commonly, incineration may result in the manufacture of metal compounds (usually as a result of oxidation), acid aerosols, and other organic compounds, or convert metal compounds to the parent metal (e.g., mercury compounds in coal convert to elemental mercury). The following discussion describes how to calculate the manufacturing threshold for these situations. To calculate the amount of EPCRA Section 313 metal compounds manufactured during combustion of wastes, you will need to determine the concentration of each metal present in the waste being combusted. The best "readily available data" should be used to estimate the approximate concentration of the metal(s) in the waste. If you have data regarding chemical concentrations in the wastes (e.g., analytical data) and believe that is the best "readily available data", then you should use this information. If specific concentration data of the metals in the waste do not exist, you can assume that the metals will convert to the lowest weight metal oxide possible. During combustion, other EPCRA Section 313 chemicals could be manufactured, particularly acid aerosols. For instance, sulfuric acid aerosols could be produced depending on a variety of factors such as sulfur content of the waste. If you have specific data on the manufacture of acid aerosols, then use it. If data are not available, EPA has published guidance on calculating the amount of sulfuric acid aerosols manufactured during combustion, which could be applied to the combustion of wastes; Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size), EPA, March 1998, available on EPA's TRI website at http://www.epa.gov/opptintr/tri. To estimate the amount of EPCRA Section 313 chemicals manufactured during wastewater treatment, the Clean Water Act typically requires facilities to monitor some Section 313 chemicals. In particular, the facility's wastewater permit application may have more detailed, chemical-specific monitoring data. However, it is important to note how the chemical is monitored in relation to the EPCRA Section 313 chemical being evaluated. For example, 3-56 ------- wastewater permits may require monitoring for the nitrate ion, but the nitrogen compound category is calculated by the total weight of the nitrate compound. Calculating the Otherwise Use and Processing Thresholds for Section 313 Chemicals in Wastes To determine if a chemical exceeds the processing or otherwise use threshold, you must calculate the annual activity for that chemical. For EPCRA Section 313 chemicals in wastes, start with the amount of chemical in stored waste as of January 1, add the amount of the chemical in waste both received from off-site and generated on-site and any amounts that are manufactured during the treatment during that year, and subtract the amount remaining in storage on December 31. The waste manifests received from your customers will be an invaluable source for determining the quantities of different types of wastes managed by your facility, particularly in terms of classifying how various types and quantities undergo a treatment step or are disposed by your facility, for example, when determining if the otherwise use threshold has been exceeded. Calculating Thresholds for Section 313 Chemicals in Purchases For purchased chemicals, start with the amount of chemical at the facility as of January 1, add any purchases during the year and the amount manufactured (including imported), and subtract the amount remaining in the inventory on December 31. If necessary, adjust the total to account for exempt activities (see Chapter 3.2.2 for a discussion of exemptions). You should then compare the result to the appropriate threshold to determine if you are required to submit an EPCRA Section 313 report for that chemical. Keep in mind that the threshold calculations are independent for each threshold activity: manufactured, processed, and otherwise used. If more than one threshold activity applies, the amount associated with each activity is determined separately. Table 3-14 presents a worksheet that may be helpful when conducting your threshold determinations and Table 3-15 illustrates an example of how the work sheet can be used for the following example: : Example - Threshold Worksheet -..,"-" ~ *>', ~ >'"* i^'«.:> "- - :* , "S'^i-xV '--.- -(:• Your facility uses a total of 13,000 pounds of ethylene glycol in the canentiejportijng year. 8,00$pounds of the * ethylene glycol is used to prevent freezing of coal during storage on-'&ile.-, The'remmning 5,000 pounds of " ^ ethylene gly col is used as' antifreeze in maintenance tracks operated by the facility. Because the amount of ethylene glycol used as antifreeze foftrucks is eligible for the motor vehicle exemption, your facility has ' % otherwise used only 8,000 pounds of ethylene glycol. Therefore, you have not exceeded the'lp,00jd pound "^ threshold for otherwise use and you are not required to submit a Form K or Form A. ''"*•.' * ,; *V,,, 3-57 ------- a It P & 2 1 §< f e £ Ss OS B c3 5SJ I o Q •o •a ' 8" % I 2 £ 3-58 ------- ft »m» ( *'* IP H ^f >, 55 ** ,5 I {-> % i .59 BO a I 3 Q .0 J al o •a •a % 'i .P o a § •c g CO S3 2J= en 4-> U S C "** 5 'o i i < u 3-59 ------- ------- Chapter 4 - Estimating Releases and Other Waste Management Quantities 4.0 PURPOSE Once you have determined which EPCRA Section 313 chemicals have exceeded thresholds at your facility, as described in Chapter 3, you must then estimate amounts of these chemicals in wastes by particular waste management type (e.g., release to air, transfer off-site, etc.). To aid in making these calculations, this chapter is intended to help you in developing a systematic approach for conducting releases and other waste management calculations specific to coal mining facilities. This chapter has been divided into two parts. The first part provides a general approach to identifying sources of potential releases and other waste management activities, collecting data, and determining the most appropriate method(s) to develop estimates. Chapter 4.1 also provides insights into the requirements, recommended approaches, and other nuances associated with developing comprehensive and accurate estimates for reportable EPCRA Section 313 chemicals. To illustrate this approach, a diagram of a recommended steps for estimating quantities of reportable EPCRA Section 313 chemicals released or otherwise managed as wastes is provided in Figure 4-1. Chapter 4.2 of this chapter provides a focused discussion, along with examples, of methods and tools to use in calculating estimates of releases and other waste management activities specific to many coal mining facilities. In particular, section 4.2 provides specific examples and issues pertaining to common chemical use categories in the coal mining industry (Section 4.2). These chemical use categories are: Extraction Transportation, size regulation, and screening/classifying Coal cleaning, including froth flotation Coal drying (combustion) Storage Reclamation and ash management Facility and vehicle maintenance. 4-1 ------- fe-Sln •S.gg |?| HgQ 5. I • s il *k>k>i/k> I' f s o •a 4-2 ------- 4.1 General Steps for Determining Releases and Other Waste Management Activities You can develop release and other waste management estimates by completing these four basic steps. See Figure 4-1 for illustration of this four-step process. Step 1) Step 2) Step 3) Step 4) Identify potential sources of chemicals released or otherwise managed as waste. Prepare a process flow diagram. Identify on-site releases, off-site transfers, and other on-site waste management activity types. Determine the most appropriate method(s) to develop the estimates for releases and other waste management activity quantities and calculate the estimates. These steps are described in detail in the following sections. 4.1.1 Step 1. Identify Potential Sources of Chemical Release and Other Waste Management Activities The first step in release calculations is to identify all areas at your facility that could potentially release reportable Section 313 chemicals. Consider all potential sources at which reportable EPCRA Section 313 chemicals may be released and otherwise managed from each unit operation and process. Remember to include upsets and routine maintenance activities. Potential sources include the following: Relief valves; Pumps; Stacks; Volatilization from process or treatment; Fittings; Transfer operations; Flanges; Storage tanks; Stock pile losses; Waste treatment discharges; Process discharge stream; Container residues; 4-3 ------- • Recycling and energy recovery byproducts; • Accidental spills and releases; • Storm water runoff; • Clean up and housekeeping practices; • Treatment sludge; and • Combustion byproducts. Next, you must identify the reportable EPCRA Section 313 chemicals that are released and otherwise managed from each source. A thorough knowledge of the facility's operations and processes will be required to make an accurate determination of which chemicals are involved, including those EPCRA Section 313 chemicals that are coincidentally manufactured during these processes. 4.1.2 Step 2. Prepare a Process Flow Diagram Preparing a process flow diagram will help you calculate your releases by illustrating the life-cycle of the reportable EPCRA Section 313 chemical(s), as well as help you identify any sources of chemicals that are released and otherwise managed as waste at your facility that you might have missed in step 1. Depending on the complexity of your facility, you may want to diagram individual processes or operations rather than the entire facility. The diagram should illustrate how materials flow through the processes and identify material input, generation, and output points. By reviewing each operation separately, you can determine where EPCRA Section 313 chemicals are manufactured, processed, or otherwise used and the medium to which they will be released on-site, transferred off-site for further waste management, or otherwise managed as wastes on-site. 4.1.3 Step 3. Identify On-Site Releases, Off-Site Transfers and On-Site Waste Management Activity Types For each identified source of an EPCRA Section 313 chemical, you must examine all possible releases and other waste management activities. Figure 4-2 is a schematic of releases and other waste management activities as they correspond to individual data elements on the Form R. Remember to include both routine operations and accidents when identifying types of chemical management activities. This diagram, along with the following descriptions, can be used as a checklist to make sure all possible types of releases and other waste management activities have been considered. 4-4 ------- EPCRA Section 313 Chemical In Point Sources A Fugitive Emissions Operation (EPCRA Section 313 Chemicals Manufactured On-Site) Underground Injection on-site Receiving Streams POTWs Transfer Off-Site Recycling Energy Recovery Treatment Disposal Product Containing EPCRA Section 313 Chemical (Not Reported on Form R) Treatment On-si site Management Energy Recovery Recycling Land on-site (landfill, land treatment, surface impoundment, other disposal) Figure 4-2. Possible Release and Other Waste Management Types for EPCRA Section 313 Chemicals 4-5 ------- r a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) - Emissions to the air that are not released through stacks, vents, ducts, pipes, or any confined air stream. Examples include: • Equipment leaks from valves, pump seals, flanges, compressors, sampling connections, open-ended lines, etc.; • Releases from building ventilation systems, such as a roof fan in an open room; • Evaporative losses from solvent cleaning tanks, surface impoundments, and spills; and • Emissions from any other fugitive or non-point sources. b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) - All emissions to the air which occur through stacks, vents, ducts, pipes, or any confined air stream, including storage tank emissions and emissions from air pollution control equipment. Emissions released from general room air through a ventilation system are not considered stack or point releases for the purpose of EPCRA Section 313 reporting unless they are channeled through an air pollution control device. Instead, they are considered fugitive releases. You should note that some state air quality agencies consider ventilation systems without an attached pollution control device to be a stack or point source, and other agencies consider releases from storage tanks to be fugitive emissions. c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3 of Form R) - Direct wastewater discharges to a receiving stream or surface water body. Discharges usually occur under a National Pollutant Discharge Elimination System (NPDES) permit. d. Underground Injection On site to Class I Wells (Part II, Section 5.4.1 of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of Form R) Disposal into an underground well at the facility. These wells may be monitored under an Underground Injection Control (UIC) Program permit. RCRA Hazardous Waste Generator Reports may be a good source of information for wastes injected into a Class I well. Injection rate meters combined with waste profiles may provide the necessary information for all classes of wells. e. Releases to Land On Site (Part II, Section 5.5 of Form R) - All releases to land on site, both planned (i.e., disposal) and unplanned (i.e., accidental release or spill). The four predefined subcategories for reporting quantities released to land within the boundaries of the facility are: e(l). Landfill - The landfill may be either a RCRA permitted or a non-hazardous waste landfill. Both types are included if they are located on site. 4-6 ------- e(2). Land treatment/application farming - Land treatment is a disposal method in which a waste containing an EPCRA Section 313 chemical is applied to or incorporated into soil. Volatilization of an EPCRA Section 313 chemical due to the disposal operation must be included in the total fugitive air releases and/or should be excluded from land treatment/application farming to accurately represent the disposition of the EPCRA Section 313 chemical and to avoid double counting. Sludge and/or aqueous solutions that contain biomass and other organic materials are often collected and applied to farm land. This procedure supplies a nitrogen source for plants and supplies metabolites for microorganisms. EPA considers this operation to be land treatment/farming if it occurs on site. If a facility sends this material off site for the same purpose, it is considered to be a "transfer to an off site location, disposal" and should be reported under Part n, Sections 6.2 and 8.1 of the Form R. The ultimate disposition of the chemical after application to the land does not change the required reporting. For example, even if the chemical is eventually biodegraded by microorganisms or plants, it is not considered recycled, reused, or treated. e(3). Surface impoundment - A surface impoundment is a natural topographic depression, man-made excavation, or diked area formed primarily of earthen materials that is designed to hold an accumulation of wastes containing free liquids. Examples include: holding, settling, storage, and elevation pits; ponds; and lagoons. Ash disposed of in excavated area would also be reported here. You do not have to report quantities of an EPCRA Section 313 chemical that are released to a surface impoundment as part of a wastewater treatment operation in this section. However, if the sludge from the surface impoundment contains the EPCRA Section 313 chemical, then the EPCRA Section 313 chemical in the sludge must be estimated in this section unless the sludge is removed and subjected to another waste management activity. In that case, it should be reported for that activity, as appropriate. e(4). Other disposal - Releases to land that do not fit the categories of landfills, land treatment, or surface impoundment are classified as other disposal. This category also includes any spills or leaks of the EPCRA Section 313 chemical to land. 4-7 ------- f. Transfers Off Site to a Publicly Owned Treatment Works (POTW) (Part II, Section 6.1 of Form R) The amount of EPCRA Section 313 chemical in water transferred to an off site POTW. g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form R) All amounts of the EPCRA Section 313 chemical transferred off-site for the purposes of waste treatment, disposal, recycling, or energy recovery. Be sure to include quantities of the EPCRA Section 313 chemical in non-hazardous wastes (such as sanitary waste and facility trash) transferred off-site and metals in waste transferred off site for recycling. Any residual chemicals in "empty" containers transferred off-site would also be reported hi Section 6.2. EPA expects that all containers (bags, totes, drums, tank trucks, etc.) will have a small amount of residual solids and/or liquid. On-site cleaning of containers must be considered for EPCRA Section 313 reporting. If the cleaning occurs with a solvent (organic or aqueous), you must report the disposition of the waste solvent as appropriate. If the containers are sent off site for disposal or reclamation, you should report the EPCRA Section 313 chemical in this section.. h. On-Site Waste Treatment (Part II, Section 7A of Form R) All on-site waste treatment of reported EPCRA Section 313 chemicals. The information reported in Section 7A focuses on the treatment of the waste stream. The information includes: type of waste stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment methods or sequence; influent concentrations of the EPCRA Section 313 chemical; treatment efficiency of each method or sequence; and whether efficiency data are based on actual operating data. Metals or metal compounds in waste subjected to a combustion process are not destroyed but should still be reported as going through the treatment process, with a treatment efficiency of zero. 4-8 ------- Example - Qa-Site Waste Treatment •A *fir A process at the facility generates a wastewater stream containing anEPCRAjSestioii 313* chemical (chemical A). A seeonel process generates a wastewater stream contain1ng%wo I EPCRA Section 3'13; cKemjcals, a metalXchemical B) and a mineral acidXchemical C)*. " * Thresholds for aO three BPCRAjSection 313 cheriricalsjmve been exceeded ,and you are in the process of completing separate Forai Rs for each cfiemicai. '" ' f *. ^ t- ^ "w l^ N J ** a " •> f * *~ i, ~* •< *• -< '" •".<•(.* ^*- J „$\ t, """ ^ 1 :, * f f ' All wastewater streams are combined and sent to an op-site wastewater treatment system before being released to a POTW. This system consists of an^gil/water separator which removes 99% of chemical A; a neutralization tank" where the pHUs adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C), and a settling tank where 95% of the r" metal (chemical B) is removed front the water (and eventually landfilied off site). . "' Section ,7A should be completed slightly differently/or each chemical for which a Fprm R" must;be filed. The table-accompanying this example shows how Section 7A should'be - .complefed for each chemical.* -First, oireach Fprm R you should^ide'ntify the'type-jof wjaste „ stream in Section 7A4a as wastewater (aqueouV waste, code W)^. Nextr on each-Form R you should list the eoae-fofeeach of the. treatment steps that.are applied to the entire waste - stream, regardless of-whether the operation.affects.tii^jchemicaf for which you are " completing the Form R (for instance, the first four blocks of Section 7A Jb of all three Form Rs should show:, P19 (liquidjahase separation), Cll (neutralization), PI 1 - " (settiing/clarification), and NA (to signify the end of the treatment system). Note that - Section 7A.1J» is the only .section of thejForm R %at i§ npt chemical specific, if applies to the entire waste stream*emg treated. Section TAJc ofWch Forni R should show the ' ' concentration of the specific chemical in the influent to th^first'step'of the process (oil/water separation). For this example,* assume chemicals'A, B, and C are all present at h concentrations greaterthan 1%. Therefore,, code "1" should "be entered. Section 7A.ldi$also chemical specific. It applies to the efffciency^qf the entire system in destroying and/or-" removing the chemical ,for the Form R you are currently completing.' 99% should be entered whenTriing for chemical A, 95%"fbr chemical B,"and 10Q%,for chemical C. - Finally, yoa should report>hether the influent concentration and efficiency estimates are based on operating* data for each chemical,' as appropriate.'' ", - * „ * " ^ Chemical A 7A.la / W 7A.lb 1. P19 2, Cll 3, PH 4. NA 5. 6. ' - 8. 7A.lc 7A.ld 99 ' 7A.le% Yes No X - ' ' s-_ Chemical B 7A.la W 7A.lb 1., P19 2. C11 JA/lc 7AJd 95 % 7A.le No 4-9 ------- Example - On-Site Waste Treatment fcont.) Chemical C 7A.la W 7A.lb 1. P19 3. NA 4. 6. 8. 7A.lc 7A.ld 7A.le Yes' N Q JL — Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in Section 7A.ld refers to the amount of EPCRA Section 313 chemical destroyed and/or removed from the applicable waste stream. The amount actually destroyed should be reported in Section 8.6 (quantity treated on site). For example, when completing the FormR for chemical B you should report "0" pounds in Section 8.6 because the metal has been removed from the wastewater stream, but not actually destroyed. The quantity of chemical B that is ultimately land filled off site should be reported in Section 6.2 arid 8.1. However, when completing the Form R for chemical C you should report the entire quantity, in Section 8.6 because raising the pH to 7.5 will completely Destroy the mineral acid. L On-Site Energy Recovery (Part II, Section 7B of Form R) All on-site energy recovery of reported EPCRA Section 313 chemicals must be reported. EPA's view is that chemicals that do not contribute significant heat energy during combustion processes should not be considered for energy recovery. Therefore, only chemicals with a significant heating value (e.g., heating value high enough to sustain combustion) that are combusted in an energy recovery unit, such as an industrial furnace, kiln, or boiler can be reported for energy recovery. If an EPCRA Section 313 chemical is incinerated on-site but does not significantly contribute energy to the process (e.g., chlorofluorocarbons), it must be considered on-site waste treatment (see Chapter 4.1.3, h. above). Metal and metal compounds in a waste that is combusted cannot be considered combusted for energy recovery because metals do not have any heat value. j. On-Site Recycling (Part II, Section 7C of Form R) All on-site recycling methods used on EPCRA Section 313 chemicals must be reported. k. Source Reduction and Recycling Activities (Part II, Section 8 of Form R)2 Provide information about source reduction and recycling activities related to the EPCRA Section 313 chemical for which releases and other waste management ^The subsection 8.1 through 8.8 designation are those for the 1997 Form R. Please refer to the current reporting year's TRIForms and Instructions for any changes. 4-10 ------- activities are being reported. Section 8 uses some data collected to complete Part n, Sections 5 through 7. For this reason, Section 8 should be completed last. The relationship between Sections 5, 6, and 8.8 to Sections 8.1, 8.3, 8.5, and 8.7 are provided in equation forms below. k(l). Quantity Released (Part II, Section 8.1 of Form R) - The quantity reported in Section 8.1 is the quantity reported in all of Section 5 plus the quantity of metals and metal compounds reported as discharged off site to POTWs in Section 6.1 plus the quantity reported as sent off site for disposal in Section 6.2 minus the quantity reported in Section 8.8 that was released on-site or transferred off-site for disposal: Section 8.1 = Section 5 + Section 6.1 (metals and metal compounds) + Section 6.2 (disposal) - Section 8.8 (release or off-site disposal only) k(2). Quantity Used for Energy Recovery On-Site (Part II, Section 8.2 of Form R) - Estimate a quantity of the EPCRA 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 (unless the 7B code is related to a Section 8.8 activity). Test data from trial burns or other monitoring data may be used to estimate the quantity of the EPCRA Section 313 chemical combusted for energy recovery purposes. If monitoring data are not available, vendor specifications regarding combustion efficiency may be used as they relate to the reportable EPCRA Section 313 chemical. A quantity should be reported in Section 8.2 when a method is reported in Section 7B (unless the 7B code is related to a Section 8.8 activity). Combustion for energy recovery is interpreted by EPA to include the combustion of an EPCRA 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 © a spent or contaminated "otherwise used" material; and that (2) has a significant heating value and is combusted 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, May 1, 1997). If a reported EPCRA Section 313 chemical is incinerated but does not contribute energy to the process (e.g., metal, metal compounds, and chlorofluorocarbons), it must be considered treatment for destruction. In determining whether an EPCRA Section 313 listed chemical is combusted for energy recovery, the facility should consider the heating value of the EPCRA Section 313 chemical and not of the chemical stream. Note that "NA" should be reported for EPCRA Section 313 chemicals which are halogens, CFCs, halons, and metals. 4-11 ------- k(3). Quantity Used for Energy Recovery Off-Site (Part II, Section 8.3 of Form R) - The quantity reported in Section 8.3 is the quantity reported in Section 6.2 for which energy recovery codes are reported. If a quantity is reported in Section 8.8, subtract any associated off-site transfers for energy recovery: Section 8.3 = Section 6.2 (energy recovery) - Section 8.8 (off-site energy recovery) Combustion for energy recovery is interpreted by EPA to include the combustion of an EPCRA 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 © a spent or contaminated "otherwise used" material; and that (2) has a significant heating value and is combusted 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 PR 23891, May 1, 1997). If a reported EPCRA Section 313 chemical is incinerated but does not contribute energy to the process (e.g., metal, metal compounds, and chlorofluorocarbons), it must be considered treatment for destruction. In determining whether an EPCRA Section 313 listed chemical is combusted for energy recovery, the facility should consider the heating value of the EPCRA Section 313 chemical and not of the chemical stream. Note that "NA" should be reported for EPCRA Section 313 chemicals which are halogens, CFCs, halons, and metals. k(4). Quantity Recycled On-Site (Part II, Section 8.4 of Form R) - Estimate a quantity of the EPCRA Section 313 chemical recycled in wastes on-site. This estimate should be the quantity of the chemical recycled in the operation for which codes were reported in Section 7C (unless the 7C code is related to a Section 8.8 activity). A quantity should be reported in Section 8.4 when a method of on-site recycling is reported in Section 7C (unless the 7C code is related to a Section 8.8 activity). 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. k(5). Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) - The quantity reported in Section 8.5 will generally be the same as the quantity reported in Section 6.2 for which recycling codes are reported. If a quantity is reported in Section 8.8, subtract any associated off-site transfers for recycling: §8.5 = §6.2 (recycling) - §8.8 (off-site recycling) '4-12 ------- k(6). Quantity Treated On-Site (Part II, Section 8.6 of Form R) - Waste treatment in Section 8 is limited to the destruction or chemical conversion of the EPCRA Section 313 chemical in wastes. The quantities reported in Section 8.6 will be those treated in a subset of the operations for which codes were reported in Section 7A, where treatment can include physical removal of the EPCRA Section 313 chemical(s) from a waste stream. To estimate the quantity, you should determine if operating data exist which indicate a treatment (e.g., destruction or chemical conversion of EPCRA Section 313 chemical) efficiency and use that efficiency value combined with throughput data to calculate an estimate. Because metals cannot be destroyed or chemically converted into something other than the metal or metal compound, metals cannot be reported as treated in Sections 8.6 or 8.7. Note that conversion of a metal from one oxidation state to another (e.g., Cr(VI) to Cr(III) is not considered treatment in Section 8.6. If operating data are unavailable, use available vendor specifications. Section 7A must be completed if a quantity is entered into Section 8.6. k(7). Quantity Treated Off-Site (Part II, Section 8.7 of Form R) - This quantity reported in Section 8.7 must be the same as the quantity reported in Section 6.2 for which treatment codes are reported and quantities sent to a POTW as reported in Section 6.1 except for metal and metal compounds. If a quantity is reported in Section 8.8, subtract any associated off-site transfers for treatment: Section 8.7 = Section 6.1 (except metals and metal compounds) + Section 6.2 (treatment) - Section 8.8 (off-site treatment) Because metals cannot be destroyed or chemically converted into something other than the metal or metal compound, metals cannot be reported as treated in Sections 8.6 or 8.7. 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. k(8). Quantity Released to the Environment as a Result of Remedial Actions, Catastrophic Events, or One-Time Events Not Associated with Production Processes (Part II, Section 8.8 of Form R) - The purpose of this section is to separate quantities recycled, used for energy recovery, treated, or released (including disposal) that are associated with normal or routine production from those that are not. The quantity reported in Section 8.8 is the quantity of the EPCRA 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: 4-13 ------- r (1) Remedial actions; (2) Catastrophic events such as earthquakes, fires, or floods; or (3) One-time events not associated with normal or routine production processes. The quantity reported in Section 8.8 should not be included with quantities reported in Part II, Sections 8.1 through 8.7 of Form R, but should be included in Part n, Sections 5 and 6 of Form R as appropriate. The on-site waste management activities should also be reported in Section 7. 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 Sections 8.1 through 8.7 as appropriate. On-site releases and off-site transfers for further waste management resulting from remediation of an EPCRA Section 313 chemical or an unpreventable accident unrelated to production (such as a hurricane) are reportable in Section 8.8. On-site treatment, energy recovery, or recycling of EPCRA Section 313 chemicals 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 H, Section 8.8 nor Sections 8.1 through 8.7 of Form R. k(9) Prior Year Estimates (for Part II, Sections 8.1 - 8.7 of Form R). In several instances, the Form R prompts the facility for information from prior reporting years. In Section 8, Source Reduction and Recycling Activities, Column A of Sections 8.1-8.7 requests release and other waste management information from the prior reporting year. Because 1998 is the first year that coal mining facilities were required to collect data for EPCRA Section 313 reporting, you may enter "NA" in column A for Form Rs for RY 1998 only. In Section 8.9, you are required.to provide a production ratio or activity index to reflect either the ratio of current year's production to prior year's production or an index of the current year's activity to prior year's activity with respect to the reportable EPCRA Section 313 chemical. Because you were not required to collect data prior to 1998, recently added facilities as a result of the industry expansion rulemaking may also enter "NA" in Section 8.9 for Form Rs for RY 1998 only. 4-14 ------- POSSIBLE FRROR - Double Counting Releases and otfier waste management activities should not be inadvertently "dottble counted/' A single wastewater discharge should not be listed as both a release io'water (oh site) and a' discharge to PO1W (off site). Similarly, a^elease^to land shojild not beHsted as bothV : release to land (on site) and'f transfer to *an off-site landfill/Estimates of releases and other, waste management activitieslshould bejprepared for Sections Sjthrpugh 7 of tfieJFprm R For, flie most part, Section 8 relies on;th*e data collected to complete these previous sections. V - Therefore, Section Should be completed last. However, the data elements pf Section 8 (8.1 through 8.7) are mutually exclusive and care* should be taken to avoiH double counting: ' - ; ~ "'•'" " "' " ' "' ' • 4.1.4 Step 4. Determine the Most Appropriate Method(s) to Develop the Estimates for Releases and Other Waste Management Activity Quantities and Calculate the Estimates After you have identified all of the potential sources for release and other waste management activity types, you must next estimate the quantities of each reportable chemical released and otherwise managed as waste. EPA has identified four basic methods that may be used to develop estimates (each estimate has been assigned a code that must be identified when reporting). The methods and corresponding codes are: Monitoring Data or Direct Measurement (M); Mass Balance (C); Emission Factors (E); and, Engineering Calculations (O). Descriptions of these techniques are provided in Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Form. They are also briefly described below. EPA does not require you to conduct additional sampling or testing for Section 313 reporting; however, you are required to use the best "readily available data" or prepare "reasonable estimates". For example, emission factors or engineering calculations may not be the best "readily available data" when other data, such as stack testing, are available. For each reported amount, you are required to identify only the primary method used for each estimate. Based on site-specific knowledge and potential data sources available, you should be able to determine the best method for calculating quantities for each release and other waste management activity. Many potential sources of data exist for these (and other) methods of developing estimates. Table 4-2 presents potential data sources and the estimation methodology in which they are most likely to be used. 4-15 ------- Table 4-2 Potential Data Sources for Release and Other Waste Management Calculations DATA SOURCES Monitoring Data (M) • Stack monitoring data • Outfall monitoring data • Air permits • Industrial hygiene monitoring data • NPDES permits * POTWpretreatment standards • Effluent limitations • RCRA permit • Hazardous waste analysis • pH for acids • Continuous emission monitoring Emission Factors (E) AP-42 or other EPA emission factors Published facility or trade association chemical- specific emission factors Mass Balance (C) • Supply records • Hazardous material inventory • Air emissions inventory • Pollution prevention reports • Hazardous waste manifests • Spill event records Engineering Calculations (O) • Volatilization rates • Raoult's Law • Henry's Law • Solubilities • Non-published emission factors • Facility or trade association non chemical specific emission factors (e.g., SOCMI factors) Once estimation methods have been determined for all potential sources, releases and other waste management activities, an estimate for each reportable EPCRA Section 313 chemical can be developed corresponding to the data elements on Form R. 4.1.4.1 Monitoring Data or Direct Measurement (code M) Using monitoring data or direct measurements is usually the best method for developing estimates for chemical releases and other waste management activity quantities estimates. Your facility may be required to perform monitoring under provisions of the Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), or other regulations. If so, these data should be available for developing estimates. Data may have also been collected for your facility through an occupational health and safety assessment. If only a small amount of direct measurement data are available or if you believe the monitoring data are not representative, you must determine if another estimation method would give a more accurate result. 4-16 ------- * :" }'*-"- Example - Monitoring Data -Jl* ' '**'• -.",, ^ :< W -* -' •*/''* '" " " '!<"- 1 * - """A, •*"""*''' "" !^*', "~ Data fi$m the on^sfte wastewater treatment facility indicate thaTthe annual average concentration of copper in *- the POTW discharge is2 mg/L, The wastewater tre'atfnent facility processed 1.5 million gallons'of water in ^ * 1998. The treated wa&ewatefis disch^ged to an off-site POT^, jTfc» ampun| of copper transferred o^ site to - the PCXTW (for^art.n, Section 6li'of the.FormR) is estimatedjas fellows: " / » , -", "• * '/ P , , /i?,;' ,, -4*>w -"" -^ ' '* --^ *ri" , . > '* ' •"" ' ''' -Amount of* copper transferred** <' - "I '« i* j" i, •* '*' ,'j * / jt , \ *( J^f~ 4.1.4.2 Mass Balance (code C) A mass balance involves determining the amount of an EPCRA Section 313 chemical entering and leaving an operation. The mass balance is written as follows: where: Input + Generation = Output + Consumption Input refers to the materials (chemicals) entering an operation. For example, chlorine added to process water as a disinfectant would be considered an input to the water treatment operation. Generation identifies those chemicals that are created during an operation (manufactured, including coincidental manufacturing). For example, additional ammonia, sodium nitrite, or nitrate compounds may be coincidentally manufactured in biological wastewater treatment systems. 4-17 ------- Output means any avenue by which the EPCRA Section 313 chemical leaves the operation. Output may include on-site releases and other on-site waste management activities; transfers for treatment, disposal, energy recovery, or recycling; or the amount of chemical that leaves with the final product. In a solvent recovery operation, for example, the recovered solvent product and wastes generated from the process are outputs. Consumption refers to the amount of chemical that is converted to another substance during the operation (i.e., reacted). For example, phosphoric acid would be consumed by neutralization during wastewater treatment. The mass balance technique may be used for manufactured, processed, or otherwise used chemicals. It is typically useful for chemicals that are "otherwise used" and do not become part of the final product, such as catalysts, solvents, acids,' and bases. For large inputs and outputs, a mass balance may not be the best estimation method, because slight uncertainties in mass calculations can yield significant errors in the release and other waste management estimates. Example - Estimating Releases to Air Using Mass Balance •' • .: i, : t i *' «> A facility uses an EPCRA Section 313 chemical as a refrigerant in condensers to control air emissions and adds 20,000 pounds to the refrigeration system in 1998 (to make up for system losses).- The chemical is released to the air from relief vents, during system filling operations and from leaks in valves and fittings. During system maintenance, the lines are bled directly into water and the system is vented to the air. Monitoring data of the wastewater, including chemical concentrations and wastewater throughput, indicate that 1,2dO pounds of the chemical were discharged to the wastewater in 1998. The remaining losses are assumed to be fugitive air releases and are estimated as follows: * r „"•*•« .'•'... " „„,,.,,«, i,v Fugitive air releases of the EPCRA Section 313 chemical = Amount input Qbs/yr) - Amount released to wastewater (Ibs/yr) = 20,000 Ibs/yr-1,200 Ibs/yr - , '' ' = 18,8001bs/yr • > •- ,""' POSSIBLE ERROR * Mass Balances for Otherwise Used Chemicals '4" I -?" "* • "' If you arc performing mass balance to estimate the quantity for a particular data element, make sure you include all inputs and outputs as precisely as possible. If, for example, you identify all inputs properly, but you fail to Include all outputs, your estimate could be inaccurately inflated. Furthermore, if all inputs and outputs are identified, but are not precise, the estimate of the release in question could also be inaccurate. 4-18 ------- 4.1.4.3 Emissions Factors (code E) An emission factor is a representative value that attempts to relate the quantity of a chemical released with an associated activity. These factors are usually expressed as the weight of chemical released divided by a unit weight, volume, distance, or duration of the activity releasing the chemical (e.g., pounds of chemical released per pounds of product produced). Emission factors, commonly used to estimate air emissions, have been developed for many different industries and activities. You should carefully evaluate the source of the emission factor and the conditions for its use to determine if it is applicable to the situation at your facility. Many emission factors are available in EPA's Compilation of Air Pollutant Emission Factors (AP-42). The use of AP-42 emission factors is appropriate in developing estimates for emissions from boilers and process heaters. Equations are presented in AP-42 to calculate chemical specific emission factors for liquid material loading/unloading of transportation vehicles and storage tanks. AP-42 can be accessed at EPA's Technology Transfer Network (TTN) website: http://www.epa.gov/ttn/chief/ap42.html. It should be noted that, for purposes of EPCRA Section 313 reporting, the only estimates that can be reported as "emission factors (code E)" are published chemical-specific emission factors. : Example - Emission Factors Emission factors have been developed for air releases of fuel constituents and combustion products from thermal drying operations. This document (Table 3-8) lists an emission factor for, formaldehyde manufactured during combustion: t •> , > , 'X - ^ / 0.00024'Ibs formaldehyde generated/ton coal'combusted ' -" " ''" '"" J •-•«•- * - J A facility operating a boiler using coal for thermal drying could use^the above emission factor, to determine the amount ,of formaldehyde generated and subsequently released to the air (assuming no formaldehyde i$removed prior to release). If 1^000,000 tons of coM arelised during a reporting year, the amount of formaldehyde generated and released would be; ' '-. - - ". . • - -_,-.. > „ „ , - t '. ~ ~r " * *~ '„---••" /• „'''** (0.00024 lbs/ton)x (1,000,000 tons) =24Q Ibs of formaldehyde"" '' - \, •>*<'" ^ / "'' ">?:<" ~ ''• ' ' NOTE: In addition to these combustion bjr-produqts, there are other EPCRA Section 313 chemicals in-edal^that should be considered for EPCRA Section.313 reporting, - ' '^\[.,,,f-,'-' ~ '' 4.1.4.4 Engineering Calculations (code O) Engineering calculations are assumptions and/or judgements used to estimate quantities of EPCRA Section 313 chemicals released or otherwise managed. The quantities are estimated by 4-19 ------- using physical and chemical properties and relationships (e.g., ideal gas law, Raoult's law) or by modifying an emission factor to reflect the chemical properties of the EPCRA Section 313 chemical in question. Engineering calculations rely on the process parameters; you must have a thorough knowledge of the processes at your facility to complete these calculations. Engineering calculations can also include computer models. Several computer models are available for estimating emissions from landfills, wastewater treatment, water treatment, and other processes. Non-chemical-specific emission factors (e.g., SOCMI emission factors) and non-published emission factors also can be used as discussed in Section 4.1.4.3, but must be classified as "engineering calculations" for EPCRA Section 313 reporting. Example - Engineering Calculations : r - x ^i Stack monitoring data are available for xylene but you have exceeded a threshold'fpr toluene and must determine amount released or otherwise managed. Toluene is used in the same application as xylene at your facility. You can estimate the emissions of toluene by adjusting the monitoring data of xylene by a ratio of the vapor pressure for xylene to toluene. This example is an engineering calculation based on physical properties and process operation information: . - / From facility stack monitoring data, an estimated 200 Ibs, of xylene is released as air emissions during the " reporting year. Toluene is also present in the air emissions, but not monitored. The stack operates at approximately 1250C. Based on literature data, the vapor pressures at 125°C for toluene is 1.44 atmospheres'- and for xylene is 0.93 atmospheres. Using a ratio of the vapor pressures, the amount of toluene released as air emissions from the stack can be calculated: Xlbs/vr toluene = 200 Ibs/yr xylene X Ifas/yr toluene = 1.44 atm (vapor pressure of toluene) 0.93 atm (vapor pressure of xylene) (200 Ibs/vr xvlene) x (1.44 atm toluene) (0.93 atm xylene) Completing the calculation, the facility determines that 310 pounds of toluene were released as stack air emissions during the reporting year. 4.1.4.5 Estimating Releases and Other Waste Management Quantities Once all sources, types, and appropriate estimation methodologies have been identified, you can estimate the release and other waste management activity quantities for each, data element of the Form R. The recommended approach is that you estimate the amounts released from all sources at your facility by the data element on the form R (i.e., first estimate all fugitive emissions for a Section 313 chemical (Part n, Section 5.1), then estimate all stack air releases for a Section 4-20 ------- 313 chemical (Part n, Section 5.2), etc.). Table 4-3 presents a work sheet that may be helpful in compiling this information. If you submit a Form R, you must also enter on-site waste treatment information in Section 7A, including the code for each treatment method used, the treatment efficiency for the chemical in the treated waste stream, and the concentration of the chemical in the influent sent to treatment. You should report treatment methods that do not actually destroy or remove the chemical by entering "0" for removal efficiency. Similarly, on-site energy recovery methods and on-site recycling methods must be reported in Section 7B and 7C, respectively. 4-21 ------- Table 4-3 Release and Other Waste Management Quantity Estimation Worksheet Facility Name: Toxic Chemical or Chemical Category: CAS Number. Date Worksheet Prepared: Prepared by: Reporting Year: ON-SITE Release or Other Waste Management Activity Type Amount Qbs) FUGITIVE AIR Equipment Leaks Process Areas Evaporative Losses (spills, surface impoundments) Total = STACK AIR Process Vents Storage Tanks Control Device Stacks Other Total = Basis of Estimate Form R Element 5.1, (8.1 or 8.8) 5.1, (8.1 or 8.8) 5.1, (8.1 or 8.8) 5.1, (8.1 or 8.8) 5.2, (8.1 or 8.8) 5.2, (8. lor 8.8) . 5.2, (8.1 or 8.8) 5.2, (8.1 or 8.8) 5.2, (8.1 or 8.8) RECEIVING STREAM/WATER BODY DISCHARGE Stormwater Discharge On-Site Treatment Plant Discharge Total - 5.3, (8.1 or 8.8) ON-SITE UNDERGROUND INJECTION Underground Injection to Class I Wells Underground Injection to Class II -V Wells ON-SrrELAND Landfill Land Treatment/Application Farming Surface Impoundment Other Total = ON-SITE ENERGY RECOVERY ON-SITE RECYCLING ON-SITE TREATMENT 5.4, (8.1 or 8.8) 5.4, (8.1 or 8.8) 5.5, (8.1 or 8.8) 5.5,(8. 1,8.6, or 8.8) 5.5,(8.1or8.8) 5.5,(8.1 or 8.8) 8.2 8.4 8.6 4-22 ------- OFF-SITE " x < ,. -. ; Release or Other Waste Management Activity Type ^Amount flbs>£. Basis of Estimate Form R Data Element Off-Site Location (name) OFF-SITE DISPOSAL Solidification/Stabilization (metals and metal compounds only) Amount of metal and metal compounds to POTW Wastewater Treatment (excluding POTWs) metals and metal compounds only Underground Injection Landfill/Surface Impoundment Land Treatment Other Land Disposal Other Off-site Management OTHER AMOUNTS SENT OFF-SITE Amounts sent for storage Amounts sent for unknown waste management practice 6.2, (8.1 or 8.8) 6.1, (8. lor 8.8) 6.2, (8.1 or 8.8) 6.2, (8. lor 8.8) 6.2, (8.1 or 8.8) 6.2, (8. lor 8.8) 6.2, (8.1 or 8.8) 6.2, (8. lor 8.8) 6.2, (8. lor 8.8) 6.2, (8.1 or 8.8) OFF-SITE TREATMENT Solidification/Stabilization Incineration/Thermal Treatment Incineration/Insignificant Fuel Value Wastewater Treatment (to POTW excluding metals and metal compounds) Wastewater Treatment (Excluding POTW and metal and metal compounds) Transfer to Waste Treatment Jroker 6.2,(8.7 or 8.8) 6.2, (8.7 or 8.8) 6.2, (8.7 or 8.8) 6.1, (8.7 or 8.8) 6.2, (8.7 or 8.8) 6.2, (8.7 or 8.8) OFF-SITE ENERGY RECOVERY Off-site Energy Recovery Transfer to Energy Recovery Jroker OFF-SITE RECYCLING Solvents/Organics Recovery Metals Recovery Other Reuse or Recovery Acid Regeneration Transfer to Recycling Waste Jroker 6.2, (8.3 or 8.8) 6.2, (8.3 or 8.8) 6.2, (8.5 or 8.8) 6.2, (8.5 or 8.8) 6.2, (8.5 or 8.8) 6.2, (8.5 or 8.8) 6.2, (8.5 or 8.8) 4-23 ------- 4.1.5 OTHER FORM R ELEMENTS 4.1.5.1 Maximum Amount On-Site (Part II, Section 4.1 of Form R) In this section of the Form R, you are required to report the code that indicates the maximum quantity of the EPCRA Section 313 chemical present at your facility at any time during the reporting year. This estimate includes any amount of the chemical on-site in storage, in process vessels, hi treatment units, and in shipping containers. This calculation includes quantities of the EPCRA Section 313 chemical present in purchased chemicals and in wastes. When performing the calculation, use only the total amount of the chemical present at your site at any one time. For example, in March your facility receives a froth flotation mixture that contains 2,000 pounds of an EPCRA Section 313 chemical. By July, your facility uses 1,500 pounds of the chemical while the 500 pounds remain on-site. In July your facility receives another shipment containing 2,500 pounds of the same chemical. If you have no other sources of the EPCRA Section 313 chemical on-site, your maximum amount estimation is equal to 3,000 pounds for the reporting year (range code 03). These codes are provided in the TRI Forms and Instructions document. Example - Maximum Amount On-Site for Landfills „,- , >> M y$ How do coal mines that operate backfill operations using ash report the maximum amount of a chemical on-site? Does this data element take into account amounts of a chemical that have been disposed of in prior years. " ,,,' x ' " i '' ".. ' v- No. Coal mines do not have to count amounts of the EPCRA Section 313 chemical that it disposed of on-site in previous years. Wastes that are released to such management units as surface impoundments and landfills should be counted for the purposes of data element 4.1, Part H, of the Form R during the reporting year that they are disposed. - jmmmmmmmmfmmmfm^t 4.1.5.2 Production Ratio or Activity Index (Part H, Section 8.9 of Form R) For this data element, you are required to provide a ratio of reporting year production to prior year production or provide an "activity index" based on a variable other than production that is the primary influence on the quantity of the reported EPCRA Section 313 chemical recycled, used for energy recovery, treated, or disposed. The ratio or index must be reported to the nearest tenths or hundredth place (e.g., one or two digits to the right of the decimal point). Because the facilities added by the facility expansion rulemaking were not required to collect data until RY 1998, these facilities may enter "NA" in this data element regardless of whether the chemical existed at your facility in the previous year (i.e., RY 1997). In future years, however, coal mining facilities may only enter "NA" hi the production ratio or activity index data element if the EPCRA Section 313 chemical was not manufactured, processed, or otherwise used in the year prior to the reporting year for which a Form R is being submitted. 4-24 ------- You may choose either the production ratio or activity index depending on the chemical and how the chemical is used at your facility. The major factor in selecting whether to use a production ratio or activity index is typically a measure of which threshold activity applies. Typically, production ratio would apply to EPCRA Section 313 chemicals manufactured and processed by a faculty, while otherwise use activities would be best measured using an activity index. A key consideration in developing a methodology for determining a production ratio/activity index is that you should choose a methodology that will be least likely to be affected by potential source reduction activities. In most cases, the production ratio or activity index should be based on some variable of production or activity rather than on toxic chemical or material usage. For example, suppose you use an EPCRA Section 313 chemical as a cleaning solvent to perform tank washouts. Using a production ratio based on the amount of the product produced in the tanks between the prior and current reporting years may seem logical but may not take into consideration potential source reduction activities. As a result, an activity index may be more appropriate. In this instance, an activity index based on the number of tank washouts conducted would be more accurate in reflecting the potential source reduction activities that could be implemented for that chemical and/or activity. For example, a source reduction activity might include the facility deciding to modify the production process such that they would need to clean the process equipment less often and, therefore, use less cleaning solvent. The use of an activity index based on the number of equipment washings would better reflect the factors that influence the amount of solvent managed as a waste than would a production ratio based on the amount of product used in the washings. ~ * Example -Production Ratio * A coal 'mine facility applies ethylene glycol to their coal on-site to prevent freezing for on-site storage. The facility-estimates that it shipped 120,000 tons of coal in tfie~previous year during winter months in which an' - anti-freezing agent was typically applied and 150,000 tons for the current year. As a result, the production ratio for this EPCRA Section 313 chemical can be calculated by dividing the tons of coal shipped during winter months this year by tons of ,coal shipped(duringwintermonths last'year. . \< ^-, *" ,;" - ' ', , 150,500 tons (current reporting year) - ~ ,120,000 tons {previous reporting year) - , ; ,- «1.25 Production Ratio 4.1.5.3 Source Reduction (Part H, Sections 8.10 and 8.11 of Form R) The final two sections of the Form R are used for reporting any source reduction activities conducted at the facility. Section 8.10 asks whether there has been any source reduction at the facility during the current reporting year. If so, TRI Forms and Instructions provides a list of three-digit codes that the faculty must choose from to describe these source reduction activities. 4-25 ------- Source reduction activities do not include recycling, treating, using for energy recovery, or disposing of an EPCRA Section 313 chemical. Report in this section only the source reduction activities implemented to reduce or eliminate the quantities reported in Section 8.1 through 8.7. Under Section 8.11, check "yes" if You would like to attach any optional information on source reduction, recycling, or pollution control activities for the EPCRA Section 313 chemical at your facility. This information can be reported for the current reporting year, or for prior year activities. The Agency asks that you limit this information to one page that summarizes the source reduction, recycling, or pollution control activities implemented by your facility. 4.2 Calculating Release and Other Waste Management Estimates at Coal Mines This section discusses the most common releases and other waste management activities at coal mining facilities, and gives guidance for estimating these quantities. The discussion is organized by release or other waste management type, as follows: Fugitive Air Emissions Stack or Point Source Air Emissions Water Discharges Releases to Land On-site Waste Management Transfers Off-site Pollution Prevention Data Facilities must report all releases and other waste management quantities of any EPCRA Section 313 chemicals that exceed activity thresholds at the facility. As mentioned earlier in Chapter 4, process flow diagrams are a very useful way for facilities to identify all sources of releases and other waste management activities. Figures 4-3 and 4-4 present generic process flow diagrams for the beneficiation of coarse and intermediate grade coal and fine grade coal and illustrate common operations and release and other waste management outputs. 4.2.1 Coal Mining Overview Extraction. Coal extraction involves accessing and removing ore deposits from below the surface. Raw coal is generally obtained by surface, strip, or underground mining. During surface or strip mining, the overburden is removed to expose the coal deposits while underground mining involves creating a series of shafts and corridors to access the coal seam. EPA provided coal mining operations with an extraction exemption because coal extraction activities do not typically involve the presence or use of listed toxic chemicals in reportable concentration and very little additional information would be made available from their inclusion. As a result, the management of materials involved in coal extraction are exempt from threshold determinations and release and 4-26 ------- other waste management activities. For example, blasting agents used to break up the overburden and coal during the extraction process would be eligible for the extraction exemption, as would EPCRA Section 313 chemicals used to maintain drag lines, drills, electric shovels, and trucks during extraction. For example, materials that are removed during extraction (e.g., overburden) are exempt from threshold determinations and release and other waste management calculations. Overburden that is removed and placed in a pile that is subsequently disposed of as fill material is exempt from reporting because its disposal is exempt under the extraction exemption. As a point of clarification, some very similar materials may be involved in more than one activity. As a result, materials that may be exempt when associated with one activity may not be when used or otherwise managed during another. One example of this are belt lines that may be used to transport coal from underground mines. Chemicals used to maintain these belt lines during extraction are considered eligible for the extraction exemption. Belt lines may also be used after a crushing or sizing activity, which is not considered part of extraction; therefore, chemicals used to maintain belt lines not associated with extraction must be considered toward threshold determinations and release and other waste management calculations. Transportation. Although coal beneficiation plants are generally at or near coal mines, the coal still must be transported from the mine to the plant either by truck, rail, or conveyer system (belt lines) depending on distance and terrain. In addition, clean coal must be transported from the site after beneficiation. Coal Preparation. Coal preparation includes all the methods utilized to upgrade or clean the raw coal in order to improve the energy value and to remove non-coal impurities. The first step of coal preparation is often size reduction. This is often followed by screening/ classification, coal/impurity removal (cleaning), and drying. Activities are different depending on the coal particle sizes and not all plants conduct all activities. Some plants may only size and classify the coal while others may undertake all four stages. The run-of-mine coal must be crushed, ground and/or broken in order to prepare the coal for the washing process. Size reduction allows the plant to handle the coal more easily while at the same time helps to remove impurities by breaking the coal down into smaller pieces. This process is performed using large machines, such as rotary brakers and rollers and can be conducted either in the open or in enclosed structures. All crushing is considered beneficiation under EPCRA Section 313, regardless of where it occurs. While some size reduction activities occur inside mines during extraction, these activities are still considered part of the beneficiation process and are not eligible for the coal extraction activities exemption under EPCRA Section 313 reporting. Following size reduction, the raw coal is screened or classified. Screening is performed to match size specifications of cleaning equipment and also to meet market demand. Generally the coal is divided into three groups; coarse (>10 mm), intermediate (0.6-10 mm) and fine (<0.6 mm). Some plants, however, make only coarse and fine grade distinctions, or none at all. 4-27 ------- Was tewater Discharge Figure 4-3 Coal Preparation Flowsheet for Coarse & Intermediate-Grade Coal 4-28 ------- Screening LEfiENB Fugitive LH Point-source Screening Acids/_ Bases Additives Coarse Coal Processing Intermediate Coal Processing Conditioning Flocculents, etc. Discharge Disposal Filtration Dewatering Additives A Thickening/ Sedimentation (impoundment, etc.) Thermal Dewatering Flocculents, etc. Water/Ground Filtration Dewatering Wastewater Discharge Figure 4-4 Coal Preparation Flowsheet for Fine-Grade Coal 4-29 ------- Classification mechanisms used include screening through a mesh of perforated plates or metal wires/rods of fixed aperture. These activities can be carried out in open or enclosed structures and either wet or dry. The coal is now ready to be cleaned in house or transported to another facility. Coal Cleaning. At this stage, the coal is cleaned and impurities, such as sulfur and ash- forming elements, must be removed. The sulfur content in the run-of-mine coal can be in three forms: pyritic sulfur, sulfates, and organic sulfur. In the U.S., the total sulfur in coal is generally high but varies from 1-4 percent, with Eastern (Appalachian) coal having a higher percentage of sulfur than Western coal. There are two types of coal washing performed on intermediate and coarse coal: gravity concentration and dense medium separation. Some media used may contain EPCRA Section 313 chemicals that must be considered toward the facility's otherwise use threshold. These methods rely on differences in specific gravities between the coal and the refuse minerals. Gravity concentration methods used to clean coal include jigs, cyclones, shaking tables, and Reichert cones. A significant portion of coal preparation plants use jigs to separate coal from non-coal material. The majority of jigs process wet coal, but some pneumatic jigs are used. Like jigs, the shaking tables, cyclones, and Reichert cones rely on water flow and motion of the equipment to separate more dense impurities from the lighter coal. Another commonly used method is dense medium separation. This process usually occurs in a large, open tank, and pulverized magnetite in water is the preferred medium in industrial coal separation. The density of the medium is adjusted to lie between the dense inorganic matter and the less dense organic, combustible fraction of coal. As a result, the inorganic material sinks to the bottom of the tank and the organic coal floats to the top of the tank where it is skimmed from the tank. Fine coal cleaning involves chemical conditioning of the coal followed by flotation to recover clean coal. These steps remove the inorganics. Depending on the characteristics of the coal, some mines may perform fine coal conditioning using lime, sodium carbonate, sodium hydroxide, or sulfuric acid. Conditioning is used to adjust pH, so as to facilitate the flotation process. Froth flotation is a widely used method of flotation in coal preparation facilities and may contain EPCRA Section 313 chemicals above de minimis levels. Flotation typically will be conducted using air, water, coal slurry, and flotation agents (e.g., collectors, activators, depressants, dispersants, or flocculents) specially selected to recover the desired fine coal. Collectors (promoters), such as fuel oil and kerosene, cause adherence between the fine coal particles and the air bubbles. Depressants, including amyl xanthate, are used to depress or cause the inorganic impurities to sink to the bottom of the tank. Activators promote flotation in the 4-30 ------- presence of collecting agents. Pine oil is a common frother that stabilizes air bubbles by reducing surface tension, thus allowing froth formation. During froth flotation, the coal-water slurry is passed through a series of "rougher" and "cleaner" cells that are sparged with air from below. Particles in this slurry are preferentially wetted by various agents causing the hydrophobic coal particles to adhere to the surfaces of air bubbles. As the air bubbles rise to the surface, the coal shines are transported to the surface and are removed by skimming with a mechanical scraper, removing much of the flotation agent. Coal Drying. The purpose of drying is to remove excess moisture and prepare the cleaned coal for shipment. All cleaning operations utilizing water require some type of mechanical or thermal drying. Coarser coal is predominantly dried using mechanical methods including drying screens, and centrifuge drying. Generally, no EPCRA Section 313 chemicals are added during coarse coal drying. Several techniques are available to accomplish fine coal drying such as vacuum filtration and thermal drying. Vacuum filtration is used for drying the cleaned fines and of the tailings. Tailings drying is preceded by thickening (as'discussed earlier). Flocculents are frequently used as filter aids, but they are not likely to contain EPCRA Section 313 chemicals above de minimis levels. At this stage, the fine coal has been cleaned using froth flotation and perhaps dried using vacuum filtration. Due to the large surface area of the small particles, further drying is needed. Thermal drying is especially successful at drying fine particles. Generally, coal preparation plants reserve thermal drying as the final step for drying fine coal. This process involves combusting a portion of coal in furnaces to sufficiently dry the wet coal to marketable levels. If thermal drying is used, elaborate ash collection is required and the facility must be aware of all the wastes generated (see Chapter 3 for EPCRA Section 313 chemical manufacturing during coal combustion). Figure 4-5 presents a process flow diagram for thermal drying using a coal-fired furnace. Usually, the more coarse coal does not undergo as extensive drying process as the fines. More advanced techniques, including thermal drying, must be used with fines because they possess a greater surface area to volume ratio then more coarse coal. Extracted coal often will be stored in large coal piles. This storage will occur throughout the coal beneficiation operation as the coal is processed prior to distribution into commerce. Depending on regional weather conditions, ethylene glycol may be sprayed on coal to prevent freezing during storage and transit within the facility and to the customer off-site. 4-31 ------- LEGEND [J Point-source Air Scrubber Wastewater Fly Ash Collection (Cyclone) -* Fly Ash A (Fire Side) Boler (Coal Drying) Coal Run-off Oil Filtrate Bottom Ash Boiler Slag -••Wet Coal _+ Coal Product Boiler Slowdown Waste Figure 4-5 Furnace Used for Thermal Dewatering 4-32 ------- Coal is generally expected to contain EPCRA Section 313 chemicals in concentrations below current de minimis levels and, therefore, these chemicals are likely to be exempt from release and other waste management calculations. While the EPCRA Section 313 chemicals present in the coal are generally below de minimis and, therefore, likely to be exempt from processing activities, many of the chemicals used to prepare the coal for distribution into commerce and to maintain the facility's operations will exceed the applicable Activity thresholds and require calculation of releases and other waste management activities. 4.2.2 Fugitive Air Emissions, Section 5.1 of Form R Fugitive air emissions can occur from a number of sources. The primary air emissions sources for EPCRA Section 313 chemicals at coal mining facilities are discussed in the paragraphs below. Fugitive air emissions that take place during'extraction are eligible for the coal mining extraction exemption, and these amounts do not have to be considered toward threshold determinations and release and other waste management calculations. When dry mining processes are involved, fugitive paniculate matter may be appreciable during crushing and sizing activities, as well as transportation, from stock piles, and conveyor pour-offs. However, many facilities reduce the potential for fugitive emissions by using a wet process or by enclosing the process area and circulating the air through fabric filters. As previously mentioned, coal is generally expected to contain EPCRA Section 313 chemicals in concentrations below de minimis levels. Therefore, these chemicals are likely to be exempt from threshold determinations and release and other waste management calculations. If coal is transported by belt lines, the amount of EPCRA Section 313 chemicals released from materials used to maintain this belt must be reported on the Form R. Depending on the volatility of the chemical, it may volatilize to air and be reported as fugitive air emissions in Section 5.1 of the Form R. Depending on regional weather conditions, ethylene glycol may be sprayed on coal to prevent freezing in transport and storage. Fugitive air emissions from the application of these chemicals are possible due to overspray or volatilization. Based on the quantity of chemical used and given the low volatility of ethylene glycol, fugitive air emissions are expected to be low. Based on the quantity applied during the reporting year, an estimate could be derived using best engineering judgement. 4-33 ------- Flotation could generate fugitive air emissions of the various flotation agents along with releases to wastewater. Air emissions of volatile EPCRA Section 313 chemicals from wastewater treatment units could be estimated using one of several programs. One program is WATERS (described in the box). Other programs are available commercially. 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 useM'features such as the ability to link treatment units to form a treatment system, the ability to 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 Releases From Transportation Vehicles A facility is responsible for reporting releases and other waste management activities for an EPCRA Section 313 chemical that occur during loading or unloading of a transportation vehicle provided an activity threshold has been exceeded for that chemical. Releases of an EPCRA Section 3^13 chemical from a transportation vehicle that occur while the material is still under "active shipping papers" is considered to be in transportation and is not subject to EPCRA Section 313 requirements (EPCRA Section 327). For example, a facility shipping ash containing nickel oxide for direct reuse off site is not responsible for reporting releases once the shipping papers have been signed. The facility is responsible for reporting releases of EPCRA Section 313 chemicals, including those that occur during storage of the chemicals in the transportation vehicle while the vehicle is on property owned or operated by the facility, up until the point that the shipping papers have been signed. 4.2.3 Stack or Point Source Air Emissions, Section 5.2 of Form R Stack emissions occur primarily from the coal drying combustion stack sources, if applicable, and storage tanks. Each is discussed below. Stack Emissions from Combustion. Amounts of EPCRA Section 313 chemicals not caught in particulate control devices or hi flue gas desulfurization (FGD) systems exit as stack emissions. Some EPCRA Section 313 chemicals manufactured during fuel combustion include hydrogen fluoride, hydrochloric acid (acid aerosols), sulfuric acid (acid aerosols), numerous metal compound categories (e.g., selenium compounds), and formaldehyde. As previously discussed in Chapter 3, the amount of EPCRA Section 313 chemicals manufactured should be based on the best "readily available data" on constituents and associated concentrations of the coal or other fuel sources. Using specific data on the fuels combusted will be extremely useful in identifying the type and quantity of EPCRA Section 313 chemicals manufactured and ultimately released as stack emissions or otherwise managed as wastes. Releases of EPCRA Section 313 chemicals to the air may be calculated using a number of methods. It is the responsibility of each facility to determine the best data to use. The best data 4-34 ------- source would be facility-specific monitoring data if enough data were available to sufficiently characterize the emissions on an EPCRA Section 313 chemical-specific basis. Unfortunately, these types of data are rarely available. One of the best practical alternatives is emission factors for the particular type of fuel that is being combusted. This document presents many of these emission factors as default values to consider if no other data exist or are "readily available". Other sources, such as the Electrical Power Research Institute's (EPRI) PISCES database, provide emission factors and models to calculate air emissions, including stack emissions. When other data are not available, EPA has emission factors which can be applied in calculating stack emission estimates. EPA's Compilation of Air Pollutant Emission Factors (AP- 42) provides emission factors for many chemicals resulting from various combustion fuel sources, including coal. Table 4-4 presents AP-42 emission factors for metals released during combustion of coal. Table 4-5 presents emissions factors for various organic compounds during controlled coal combustion. These tables are specific to certain conditions (e.g., coal classification, boiler configuration). dse of AP-42 Emission factors The general equation for emission estimation is: ' E = Ax<"EFx(l-ER/100) -where: , ' <"•„ _ . -•* E = emissions, ~"~A = activity rate, EF = emission factor, and - r ER = overall_ emission reduction ' _ efficiency ,x %, 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 ther device and the'Capture efficiency terms.shonldaccount " for upset periods as well as routine operations; Note that - some emission factors'already incorporate a removal , Combustion of coal may also result in emissions of sulfuric acid (acid aerosol), hydrochloric acid (acid aerosol), and hydrogen fluoride (HF). The quantities of these chemicals must be applied to the manufacturing threshold (as discussed in Section 3 of this document). To estimate stack air emissions of these acids when no better data are available, assume the amount released is the amount manufactured minus amounts removed by air control devices. Efficiency estimates for air pollution control devices can be obtained from monitoring data, vendor specifications, and air permit applications. Note that chlorine (7782-50-5) and fluorine (7782-41-4) may also be formed. Facilities must use their best available information to estimate these quantities. 4-35 ------- Table 4-4 EPCRA Section 313 Metal Emission Factors for Combustion of Coal CONTROLLED COAL COMBUSTION" 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, 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, atmospheric fluidized bed combustors, circulating bed, 1-01-002-18/38, 1-02-002-18, and 1-03-002-18. *N/A - data not available for this metal 4-36 ------- Table 4-5 Emission Factors for Organic EPCRA Section 313 Chemicals from Controlled Coal Combustion Pollutant15 Acetaldehyde Acetophenone Acrolein Benzene Benzyl chloride Bromoform Carbon disulfide 2-Chloroacetophenone Chlorobenzene Chloroform Cumene 2,4-Dinitrotoluene Dimethyl sulfate Ethyl benzene Formaldehyde Hexane Methyl ethyl ketone Methyl hydrazine Methyl methacrylate Methylene chloride Phenol Propionaldehyde Tetrachloroethylene Toluene 1,1,1 -Trichloroethane Styrene Xylenes Emission Factor0 (Ib/ton) A „ * g 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 2.5E-05 3.7E-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 D C 4-37 ------- Pollutant13 Vinyl acetate Emission Factor* Ob/ton) 7.6E-06 Emission Factor Rating E * Source: AP-42 Chapter 1, External Combustion Sources. Factors were developed from emissions data from ten sites firing bituminous coal, eight sites firing subbituminous coal, and from one site firing lignite. The emission factors are applicable to boilers using both wet limestone scrubbers or spray dryeis and an electrostatic precipitator (ESP) or fabric filter (FF). In addition, the factors apply to boilers utilizing only an ESP or FF. 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, atmospheric fluidized bed combustofs, 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; Hexachloroethane-1 site; Propylene dichloride- 2 sites; 1,1,2,2-Tetrachloroethane- 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. AP-42: Emission Factor Quality Ratings for Tables 4-4 and 4-5 A Excellent. Factor is developed from A- and B-rated source test data taken from many randomly chosen facilities in the industry population. The source category population is sufficiently specific to minimize variability. , B Above average. Factor is developed from A- or B-rated test data from a "reasonable number" of facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with an A rating, the source category population is sufficiently specific to minimize variability. C Average. Factor is developed from A-, B-, and/or C-rated test data from a "reasonable number" of facilities. Although no specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with the A rating, the source category population is sufficiently specific to minimize variability. D Below average. Factor is developed from A-, B- and/or C-rated test data from a small number of facilities, and there may be reason to suspect that these facilities do not represent a random sample of the industry. There also may be Evidence of variability within the source population. ' ,/"'-" B 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. Storage Tanks. Coal mining facilities should consider point source air emissions from tanks that store materials containing volatile chemicals, such as flotation and conditioning agents. AP-42 provides detailed information on the calculation of air emissions during the storage and transfer of liquids. A number of equations used to calculate air emissions from storage tanks can be found in AP-42, Chapter 7. Total emissions from storage tanks are equal to the sum of the standing storage loss and TANKS3 The TANKS3 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 7. 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 TANKS3 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 TANKS3 program and manual can be downloaded from the world wide web at http://www.epa.gov/ttn/chief/tanks.html. 4-38 ------- working loss. Variables such as tank design, liquid temperature, and wind velocity are taken into account when determining standing storage loss and working loss. The emission equations for fixed-roof tanks in AP-42 were developed for vertical tanks; however, the equations can also be used for horizontal tanks by modifying the tank parameters as specified in AP-42. Many of these equations have been incorporated into computer models such as TANKS3 (See box on TANKS3 for more information). Once the total volatile organic compound (VOC) loss is calculated, you can determine the emission rate of each constituent in the vapor. In general, the emission rate for individual components can be estimated by multiplying the weight fraction of the constituent in the vapor by the amount of total VOC loss. The weight fraction of the constituent in the vapor can be calculated using the mole fraction and the vapor pressure of the constituent (equations found in AP-42). The weight percent can also be obtained from the SPECIATE database. The SPECIATE database contains organic compound and particulate matter speciation profiles for more than 300 source types. The profiles attempt to break down the total VOC or particulate emissions from a particular source into the individual compounds. The SPECIATE database can be downloaded from the world wide web at http://www.epa.gov/ttn/chief/software.htmliSspeciate. 4.2.4 Discharges to Receiving Streams or Water Bodies, Section 5.3 of Form R; and Discharges to Publicly Owned Treatment Works (POTWs), Section 6.1 of Form R Wastewaters discharged include process wastewater, coal pile run-off, and storm water. Each is discussed below. Process Wastewater. Process wastewater are generated at several operations at coal mines including the following: • Froth flotation results in wastewater streams containing coal and flotation agents. This could generate fugitive air emissions of the various flotation agents along with releases to wastewater. • Coal is often conveyed and managed in a wet state; dewatering the coal will result in wastewater that contains metal compounds and possibly other EPCRA Section 313 chemicals that were used in preparing the coal for distribution into commerce. • Coal washing and rinsing generates wastewater that may contain manufactured metal compounds. Flocculents used as filter aids during vacuum filtration that contain EPCRA Section 313 chemicals are reportable when released in wastewater to a receiving stream or POTW provided thresholds have been excluded. 4-39 ------- Example Calculation of Yearly Wastewater Discharge A facility has monitoring data on discharges to water of xylene, a listed BPCRA 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: Date 3/1 9/8 Concentratio n{mg/l) 1.0 0.2 Flow (MGD) 1.0 0.2 Daily ', Discharge 8.33 Ibs. 0.332ibs. Annual Calculation: (8.33 Ibs. + 0.332 lbs,)/2 days x 365 days/year = 1580,82 Ibs/yr 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 of some generalized wastewater parameters including concentrations of various constituents. In some cases, the constituent analyses required for permit compliance includes EPCRA Section 313 chemicals. In other cases, facilities may have conducted more detailed analysis of specific constituents in its wastewaters as part of its NPDES or POTW discharge applications. In these instances, releases can be calculated by multiplying the volume of wastewater released by the concentration of the chemical released. Otherwise, the facility should use their best "readily available data" in making these estimates as needed. See text box for an example calculation. 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 EPCRA Section 313 chemical hi pounds and should 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 chemical-specific monitoring data exist, process knowledge (or in some cases, mass balance) may be used 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 except for hydrochloric and sulfuric acid, which are 4-40 ------- only reportable in the aerosol form. For more information on calculating such discharges of acids, see EPA's Estimating Releases of Mineral Acid Discharges Using pH Measurements (EPA 745/F-97-003, June 1991). . ' "• ', -\-±' ,:'>•-?>' „ ~"f'-"--^,^'Vt'.-i"'-A'j' :.;*!- '::?;s-i"-s>-i-*!.-;- ^ffV-^-Tr^"''^---" . > .-" .,--':* : ^ — k,' ^r^61^"6^?6^^^^^"60^^^^ "\ " '0''^-: <"• ' ^ '* ^' - , -*£>, "^^ ' - "^ -!"-".^.^Os ~^^"""" -« s^s^*iT:u«^!f ti&ri?-'1^^1''* ^" "*" - -- rj-^-C^ ^" J* " ^ "5 s r"'< *• -"'*"„"- '" VC "" .* < -^ * x """f" ""- (-" ^^ ! = t.^*~M N/^ 'i"-^'"^ - ^-V^'ir" L V <""'^1 ""'< "^& """tx ^ \ 4'?^%^ X" *V ]F^ciIitiesni||a^ pse ammonia or amrtiQOtateH ci|aier^3toitig fcolier cleaning wfeeh reporting fel^es^ahi,' "***" """*" management activities of jmprnonia, rem^nbe^to report;dyyfO|«^en;t~pft&e total aMbunt^f , offlter waste" '' ' No releases to water of chlorine are typically expected. Chlorine reacts very quickly with water to form HOC1, Cl% and H+. Although this is an equilibrium reaction, at a pH above 4 the equilibrium shifts almost completely toward formation of these products. Therefore, essentially zero releases of chlorine to water are expected to occur under normal circumstances. Coal Pile Runoff. As discussed in Chapter 3, coal stored in exposed piles may be subject to rainfall, snowfall, spraying for dust control or to prevent freezing, which may create acidic leachate that flows in underground streams or that collect under the piles, forming runoff. The dissolution of the metal compounds typically found in coal may lead to the manufacture of metal compounds. As a result, on-site storage of coal may result in coal pile run-off containing reportable EPCRA Section 313 chemicals. If you believe that conditions exist at your facility that generate and/or release EPCRA Section 313 chemicals from coal piles, then you should include this as a source of making threshold determinations and release and other waste management calculations. In doing so you may apply data used for threshold determinations. If you believe that these releases result in releases to surface water, you may combine these data with data on the estimated quantity of runoff to derive an estimate of EPCRA Section 313 chemicals released. Storm Water Runoff. Storm water runoff at coal mining facilities may contain EPCRA Section 313 chemicals washed from outdoor materials such as coal or other raw materials, waste, and land features. You must report the amount of non-exempt EPCRA Section 313 chemicals in storm water runoff (including unchanneled runoff). If you do not have periodic measurements of storm water releases, but have chemical-specific monitoring data on the reportable EPCRA Section 313 chemicals, you should use these data to calculate the quantity discharged and the percent contribution from storm water to the overall water discharge estimate. See the current TRI Forms and Instructions document for guidance on calculating storm water runoff. 4-41 ------- 4.2.5 Disposal to Land On-site, Section 5.5 of Form R Coal mines dispose of reclamation wastes, tailings, combustion wastes, and other wastes. Accidental releases can also lead to Section 313 chemicals being disposed of to land on-site. Each of these are discussed below. Reclamation Wastes. The use of various materials for mine reclamation constitutes an otherwise use activity as outlined in Chapter 3 of this document. The direct application of these materials in the mine or on the land constitutes a release to land and may require reporting in Section 5.5 of the Form R. The disposal of overburden displaced to gain access to coal on-site, while possibly aiding in the backfilling or reclamation of a completed area, is considered covered by the coal extraction activities exemption, and the amount of any EPCRA Section 313 chemicals that may be present in the overburden is exempt from threshold determinations and release and other waste management calculations. However, ash either generated on-site or received from off-site for reclamation purposes is not eligible for the coal extraction activities exemption and must be considered toward the facility's release to land calculations. Additionally, quantities of EPCRA Section 313 chemicals in ash received from off-site for reclamation must also be considered toward the facility's otherwise use threshold because it is considered a waste received from off-site for the purposes of waste management. EPCRA Section 313 chemicals in wastes that are otherwise used must be considered towards threshold and release and other waste management calculations regardless of their concentrations (i.e., they are not eligible for the de minimis exemption). Tailings. After the flotation, tailings (hi a wastewater slurry) may be sent directly to a tailings impoundment or to a thickener. To accelerate settling and agglomeration, the thickening process may use chemicals hi addition to those used for froth flotation. Releases of thickening agents must also be reported on the Form R once the otherwise use threshold has been exceeded or another threshold has been exceeded elsewhere for that chemical. Some of these chemicals may be disposed with the tailings. After thickening, the tailings are then generally sent to a tailings impoundment. Combustion Wastes. Many coal mines dispose of coal ash containing EPCRA Section 313 chemicals on-site. Bottom or fly ash may be disposed hi on-site landfills, surface impoundments, ash ponds, or other waste management units. Some facilities may also dispose boiler slag (bottom ash particles in a molten state) containing EPCRA Section 313 chemicals. Facilities must report all non-exempt releases of EPCRA Section 313 chemicals in ash that are disposed on-site, regardless of their concentration, provided thresholds have been exceeded for these chemicals. Facility specific information, such as waste analyses and process knowledge, can be used to estimate amounts of EPCRA Section 313 chemicals in combustion wastes. In the absence of 4-42 ------- data determined to be better, facilities can use default values for concentrations of metals in ash, presented in Table 4-6. Table 4-6 Total Constituent Concentrations of Elements in Combustion Residuals Element Antimony Arsenic Barium Cadmium Chromium Copper Lead Manganese Mercury Nickel Selenium Silver Vanadium Zinc Fly Ash (ppm) 131 6,300 13,800 130 900 2,200 2,120 3,000 12 4,300 134 36 1,180 3,500 Bottom Ash (ppm) 10 168 9,360 10 5,820 932 1,082 1,940 4.2 2,939 14 9.9 537 1,796 Source: Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume 1, Critical Review, Battelle, Pacific Northwest Laboratory for EPRI, EA5176, August 1987. Other Wastes. Coal mines may also dispose of other wastes such as filtration and coagulation residues, settled materials, and ethylene glycol from coal pile runoff. To calculate quantities of EPCRA Section 313 chemicals in these wastes, facilities can use waste analyses, process knowledge, operating records, pollution prevention data, mass balance, or other sources provided it is determined to be the facility's best "readily available data". You must report the ultimate known disposition of an EPCRA Section 313 chemical in the reporting year. In other words, you may need to consider any cross-media transfers that may result from land disposal. If a waste has been disposed in a land disposal unit, but a portion of that waste volatilizes into the air or discharges to a surface water, the ultimate disposition of the report able EPCRA Section 313 chemical during the reporting year must be reported for the year 4-43 ------- in which the waste was disposed. Therefore, only the quantity that remains in a surface impoundment, ash pond, or other land disposal unit must be reported as a release to land, while the amount that is released to another media must be reported as released to that media. Accidental Releases to Land. Leaks, spills, and drips from the loading and transfer of materials or wastes 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. In calculating quantities related to accidental releases, you are required to report the ultimate disposition in the reporting year that the EPCRA Section 313 chemical(s) are released. For instance, releases to land (e.g., Other Disposal, Section 5.5.4 of Form R), would only include the quantity of spilled material that was not cleaned up as a response to the accident. Equations found in Section 6 of EPA's Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Form, provide guidance on calculating releases from chemical spills or leaks for determining how to partition amounts for different reporting elements, including liquid discharges, fraction of discharge flashed, vaporization, two- phase discharges, and gas discharges. Example - Seepage From a Landfill " i % ? If a facility in one of the new industries, which begins reporting for activities conducted in 1998, has information on the amount of seepage from a landfill in 1998, do they report this amount as a release to land, since they were not required to report the initial disposal to land in the previous year? No, facilities are required to report only the amounts which are disposed during the year in which they are disposed, provided certain thresholds have been meet- ~ and the facility does not conduct any further'activities involving amounts previously disposed., Amounts which move within the same media, such as seepage from a*'" ~ landfill to surrounding soils do not have to be included in release estimates in subsequent years. EPA requires reporting of the amount of EPCRA Section 313 chemical placed in an on-site landfill during the year. It is not necessary to estimate migration from the landfill in subsequent years, provided the facility does not conduct activities that further involve the EPCRA Section 313 chemical disposed. 4.2.6 Transfers Off-site, Section 6.2 of Form R. Coal mines do not generally send large amounts of waste off site. Two types of waste that could be sent off site and are discussed below. Hazardous Wastes. While most wastes from coal muiing operations will be disposed of on- site, some facilities may generate hazardous wastes, which must be sent off site for further waste Waste Management Codes for Metals : Metals and metal compounds hi wastewater sent off-site for treatment should be reported using code M62 - "Wastewater TreaoneTnt (Excluding POTW) - Metals and Metal Compounds Only". Similarly, metals in solids sent off-site for solidification or stabilization should be reported using code M41 - "Solidification/Stabilization - Metals and Metal Compounds Only". 4-44 ------- management. The quantity of the waste can be obtained from manifests and the composition can be obtained from analyses, waste profiles, or process knowledge. Scrap Metal. In crushing operations, a mine may use high alloy metals in their brakers or rollers. Due to the nature of the process, some parts of this machinery which are in contact with the coal will frequently break off or wear out. When this occurs, scrap metal is generated. If a threshold has been exceed for the elemental metal contained in the metal alloys otherwise used in its process activities, then the quantities of scrap metals generated and sent off-site will need to be reported in Section 6.2 of Form R. If the scrap metals are sent off-site for recycling, bills of lading will be useful in determining the total weight shipped off-site. " * --' SCRAKMETAi: -, v - ' <* J-' : "' ' s ** < -*- J, „' --, '/,„_' r< " If a covered facility sends metal scraps containing chemicals off-site to be remelted and subsequently reused, does it report the amount of EPCRA Section 313 chemical in, the metal as recycled off-site? . ~ \ '" ~, "-'' •-,' , Assuming no contaminants^arevremoved during the melting process, the chromium in the metal scraps is not'actually being recovered, but merely melted aad reused, Therefore, the , amount of EPCRA Section, 31lJ'chemica\in the metal scraps would not be reportable in ;Part H, Sections 6.2 or 8 of the^ormK/ However, because the'facility is repackagirig^and distributing the EPCRA Sectional 3 chemicals in "commerce, it should consider these;" ' 4.2.7 On-site Waste Management Methods, Section 7A, 7B, and 7C of Form R On-site waste management at coal mines may include waste treatment. Recycling of wastes and energy recovery from wastes is usually not performed at coal mines. On-site Treatment Methods, Section 7A of Form R Coal mines may treat wastes on-site using various methods. When completing a Form R for a chemical, you must report all treatment methods performed on the waste containing that chemical, regardless of its efficiency. For each treatment method, report the applicable code, given in the TRI Forms and Instructions document. The following are some examples of treatment methods that coal mines may use: • Tailing or other solid wastes may pass through several steps, including filtration (P12), sludge dewatering (P13), settling/clarification (Pll), and thermal drying/dewatering (F83). 4-45 ------- • Wastewater (such as coal pile runoff) may go through several treatment steps, including neutralization (Cl 1), settling/clarification (PI 1), filtration (P12), chemical precipitation - lime or sodium hydroxide (C01), sludge dewatering - non-thermal (P13), or other physical treatment (e.g., evaporation) (P99). • Some facilities incinerate (F99 and other F codes) wastes as part of the coal drying process. 4.2.8 Source Reduction and Recycling Activities, Section 8 In Chapter 4.1.3, the general method for developing Section 8 quantities was discussed in Chapter 4.1.3. Two examples of how to calculate Section 8 quantities are presented below in Table 4-7: Table 4-7 Example of Section 8 Reporting Section Metal Compounds Ammonia Section 8.1, Quantity released Fugitive and stack air emissions, releases to water and POTW, and off-site waste transfers for disposal 100% of fugitive and stack air emissions and 10% of the quantity released to water or land in aqueous form Section 8.2, Quantity used for energy recovery on-site Not applicable to these metal compounds that are products of combustion Not generally performed at coal mines Section 8.3, Quantity used for energy recovery off-site Not applicable to these metal compounds that are products of combustion Not generally transferred off site in wastes Section 8.4, Quantity recycled on-site Water decanted from tailings ponds are returned to the process may contain metal compounds Not generally performed at coal mines Section 8.5, Quantity recycled off-site Metal compounds not generally transferred off site in wastes from coal mines (elemental metals are separately listed) Not generally transferred off site in wastes 4-46 ------- Section 8.6, Quantity treated on-site Section 8.7, Quantity treated off-site Not possible to destroy metal compound Not possible to destroy metal compound Report quantity in waste that is neutralized (do not include the quantity used to neutralize) Not generally transferred off site in wastes 4.2.9 Source Reduction Activities, Section 8.10 Facilities have the opportunity to report source reduction actions initiated during the reporting year on the Form R, using codes listed in the TRI Forms and Instructions document. An example of a source reduction activity and a suggested code is given below. • Spraying coal piles with an anionic detergent to reduce bacterial oxidation of sulfide minerals, lowering the acidity of the pile, and decreasing the amount of EPCRA Section 313 chemicals in coal pile runoff. (W49: Other raw material modifications) 4-47 ------- ------- APPENDIX A REPORTING GUIDANCE DOCUMENTS General Guidance Air/Superfund National Technology Guidance Study Series, no date. Internet Availability: None Hardcopy Availability: NTIS Order Number: PB96-162-490 Chemicals in Your Community: A Guide to the Emergency Planning and Community Right-To- KnowAct, 1993. Internet Availability: http://www.epa.gov/swercepp/gen-pubs.html Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-550-K-93-003 Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community Right-To-Know Act, March 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-008 Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to- Know Act and Section 112(r) of the Clean Air Act, as amended (Title III List of Lists), November 1998. Internet Availability: http://www.epa.gov/swercepp/gen-pubs.html Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-550-B-98-017 The Emergency Planning and Community Right-to-Know Act: Section 313 Release Reporting Requirements, December 1997 (brochure). Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-K-97-002 A-l ------- EPCRA Section 313 Questions & Answers, Revised 1998 Version, December 1998. Internet Availability: http://www.epa.gov/opptintr/trl Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-B-99-004 Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements: Questions and Answers. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-011 Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery, Treatment for Destruction, Waste Stabilization and Release, April 1997. Internet Availability: None Hardcopy Availability: EPCRA Hotline Order Number: No order number Standard Industrial Classification Manual, 1987. Internet Availability: None (see http://www.epa.gov/tdbnrmrl/help/l_help7.htm for codes) Hardcopy Availability: NTIS Order Number: PB-87-100-012 Supplier Notification Requirements Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-560-4-91-006 Toxic Chemical Release Inventory Reporting Forms and Instructions (TRI Forms and Reporting Requirements), March 23, 1998 Internet Availability: http://www.epa.gov/opptintr/tri Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-K-98-001 A-2 ------- Toxic Chemical Release Reporting; Community Right-to-know; Final Rule, February 16, 1988 (53 FR 4500). Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: None Trade Secrets Rule and Form, July 29,1988 (53 FR 28772). Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: None Waste Analysis at Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes; A Guidance Manual, April 26,1994. Internet Availability: http://es.epa.gov/oeca/ore/red/wap330.pdf Hardcopy Availability: NTIS Order Number: PB94-963-603 Chemical-Specific Guidance Emergency Planning and Community Right-to-Know Section 313: Guidance for Reporting Aqueous Ammonia, July 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-012 Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals Within the Chlorophenols Category, November 1994. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-B-95-004 Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals, September 1996. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-B-96-002 A-3 ------- Guidance for Reporting Sulfuric Acid Aerosols (acid aerosols, including mists, vapors, gas, fog, and other airborne forms of any particle size), March 1998 Revision Internet Availability: http://www.epa.gov/opptintr/tri Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-97-007 List of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance for Reporting, May 1996. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-96-004 Toxics Release Inventory: List of Toxic Chemicals Within the Glycol Ethers Category and Guidance for Reporting, May 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-006 Toxics Release Inventory: List of Toxic Chemicals Within the Nicotine and Salts Category and Guidance for Reporting, February 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-004 Toxics Release Inventory: List of Toxic Chemicals Within the Polychlorinatd Alkanes Category and Guidance for Reporting, February 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-001 Toxics Release Inventory: List of Toxic Chemicals Within the Polycyclic Aromatics Compounds Category, February 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-003 A-4 ------- Toxics Release Inventory: List of Toxic Chemicals Within the Strychnine and Salts Category and Guidance for Reporting, February 1995. Internet Availability: None Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-95-005 Release Estimation Guidance General Data Quality Checks to Prevent Common Reporting Errors on FormR/Form A, August 1998. Internet Availability: http://www.epa.gov/opptintr/tri Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-745-R-98-012 Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Form, December 1987. Internet Availability: http://www.epa.gov/opptintr/tri Hardcopy Availability: NCEPI or EPCRA Hotline Order Number: EPA-560-4-88-002 Releases During Cleaning of Equipment, June 30,1986. Internet Availability: None Hardcopy Availability: Prepared by PEI Associates, Inc. for the U.S. Environmental Protection Agency, Office of Prevention, Pesticides & Toxic Substances, Washington, DC, Contract Bo. Order Number: 68-02-4248 Air Chemdat 8/Water 8: Air Emission Models for Waste and Wastewater (for Microcomputers), 1994 Internet Availability: http://www.epa.gov/ttn/chief/software.html#water8 Hardcopy Availability: NTIS Order Number: PB95-503595 A-5 ------- Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, ff* Edition (AP-42). Internet Availability: http://www.epa.gov/ttn/chief/ap42.html Hardcopy Availability: NCEPI Order Number: EPA-450-AP-425ED Protocol for Equipment Leak Emission Estimates, 1987. Internet Availability: http://www.epa.gov/ttnchiel/fyi.html Hardcopy Availability: NCEPI Order Number: EPA-423-R-95-017 Tanks 3: Tanks: Storage Tank Emission Estimation Software, Version 3.0 (for Microcomputers), March 1996 Internet Availability: http://www.epa.gov/ttn/chief/tanks.html Hardcopy Availability: NITS Order Number: PB97-500-755 Water Chemdat 8/Water 8: Air Emission Models for Waste and Wastewater (for Microcomputers), 1994 Internet Availability: http://www.epa.gov/ttn/chief/software.htmlttwater8 Hardcopy Availability: NTIS Order Number: PB95-503595 Information and Document Distribution Centers Enviro$en$e Information Network BBS modem: (703) 908-2092 User Support: (703) 908-2007 Internet Home Page: http://es.epa/gov/index.html A-6 ------- National Center for Environmental Publications and Information (NCEPI) P.O. Box 42419 Cincinnati, OH 45242 (800)490-9198 (513) 489-8695 (fax) Internet Home Page: http://www.epa.gov/ncepihom/index.html National Technical Information Service (NTIS) 5285 Port Royal Road Springfield, VA 22151 (800) 553-6847 (703) 605-6900 (fax) Internet Home Page: http://www.ntis.gov OPPT Pollution Prevention (P2) Internet Home Page: http://www.epa.gov/opptintr/p2home/index.html Pollution Prevention Information Clearinghouse (PPIC) Mail Code 3404 401 M Street, SW Washington, DC (202) 260-1023 (202) 260-0178 (fax) RCRA, Superfund & EPCRA Hotline (800) 424-9346 (outside the Washington, DC Area) (703) 412-9810 (inside the Washington, DC Area) TDD: (800) 553-7672 (outside the Washington, DC Area) (703) 412-3323 (inside the Washington, DC Area) RTK-Net 1742 Connecticut Avenue, NW Washington, DC 20009-1146 (202) 797-7200 Internet Home Page: http://www.rtknet.org A-7 ------- Technology Transfer Network (TTN) (919) 541-5384 (Help Desk) Internet Home Page: http://www.epa.gov/ttn EPA Toxic Release Inventory General Information and Guidance Internet Home Page: http://www.epa.gov/opptintr/tri U.S. Government Printing Office (GPO) (202) 512-1800 (202) 512-2250 (fax) Internet Availability: http://www.gpo.gov *For the latest list of industry-specific and other technical guidance documents, please refer to the latest version of the 'Toxic Chemical Release Inventory Reporting Forms and Instructions, Appendix H. A-8 -------