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
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&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
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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
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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
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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?
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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.
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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.
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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
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(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).
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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.
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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.
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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)
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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.
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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
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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.
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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.
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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/year18,000 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-
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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.
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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
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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
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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
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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.
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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.
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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).
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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.
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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,
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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
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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.
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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 20,000pounds,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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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- . ' 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.
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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
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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.
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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
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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\", *
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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:
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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
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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
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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
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* :" }'*-"- 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
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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
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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
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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
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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.
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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
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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)
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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.
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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.
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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
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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.
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Was tewater Discharge
Figure 4-3 Coal Preparation Flowsheet for Coarse & Intermediate-Grade Coal
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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
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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
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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.
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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
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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.
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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
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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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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