&EPA
United States
Environmental Protection Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
January 1999
EPA 745-B-99-003
EPCRA Section 313
Industry Guidance
        ELECTRICITY GENERATING FACILITIES
         .,,
         ป M *  r
                     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	....I.	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  	2-5
      2.4    Number of Employees  	> ;	^. <.	2-8
      2.5    Manufacturing, Processing, and Otherwise Use of EPCRA
             Section 313 Chemicals	:		2-9
       2.6    Activity Thresholds  	2-10
       2.7    How Do You Report?	2-12
       2.8    Form R .	2-12
       2.9    Form A.	2-13
       2.10   Trade Secrets	2-14
       2.11   Recordkeeping	2-15

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	 -  3-45
             3.2.2  Evaluation of Exemptions	3-47
                    3.2.2.1  Laboratory Activities Exemption 	3-47
                    3.2.2.2  De minimis Exemption	3-47
                    3.2.2.3  Article Exemption  	3-50
                    3.2.2.4  Exemptions That Apply to the Otherwise Use of EPCRA
                           Section 313 Chemicals	3-51
             3.2.3  Additional Guidance on Threshold Calculations for Certain Activities  3-53
                    3.2.3.1       On-site Reuse Activities 	3-53
                    3.2.3.2       Remediation Activities	3-53

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       3.3    Step 3. Determine which EPCRA Section 313 chemicals
                    exceed a threshold	3.54

Chapter 4 - Estimating Releases and Other Waste Management Quantities	4-1

4.0    PURPOSE	4_!
       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)	4-17
                   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)	4-20
                   4.1.4.5 Estimating Releases and Other Waste Management Quantities 4-21
             4.1.5  Other Form R Elements 	4-24
                   4.1.5.1 Maximum Amount On-Site (Part II, 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
             Electricity Generating Facilities	4-26
             4.2.1  Fugitive Air Emissions, Section 5.1 of Form R	4-28
             4.2.2  Stack or Point Source Air Emissions, Section 5.2 of Form R 	4-33
             4.2.3  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
             4.2.4  Disposal to Land On-site, Section 5.5 of Form R  	4-41
             4.2.5  Transfers Off-site, Section 6.2 of Form R	4-44
             4.2.6  On-site Waste Management Methods, Section 7A, 7B, and 7C of
                   Form R	4.45
             4.2.7  Source Reduction and Recycling Activities, Section 8 of Form R	4-46
             4.2.8  Source Reduction Activities, Section 8.10 of Form R	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 PR 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 Electricity Generating Facilities, dated October
1997. It is intended to assist establishments and facilities designated by Standard Industrial
Classification (SIC) codes 4911 (limited to facilities that combust coal and/or oil for the purpose
of generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for distribution in commerce), and 4939
(limited to facilities that combust coal and/or oil for the purpose of generating electricity for
distribution in commerce) 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
              electricity generating 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 in 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, use "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
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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?

       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 determining 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
electricity generating facilities.

       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;
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       •      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 electricity generating
facilities where EPCRA Section 313 chemicals are manufactured, processed, or otherwise used.
A list of EPCRA Section 313 chemicals likely to be managed by electricity generating 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.

       This document includes examples of chemical management activities, that electricity
generating facilities may conduct, illustrating how these activities should be considered for
EPCRA Section 313 reporting purposes. This chapter also notes areas where potential errors in
reporting might be encountered generally by electricity generating 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 members on the
 Electricity Generating Committee (EGC) made up of staff from Allegheny Power, Duquesne
 Light Company, FirstEnergy Corp., GPU Generation, PEPCO Energy Company, and PP&L, Inc.,
 as well as the Edison Electric Institute (EEI) whose industry insight and understanding of EPCRA
 Section 313 requirements have greatly assisted in increasing the utility of this document. Special
 thanks go to Michelle Duncan of EGC for coordinating their review.

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                              Chapter 1 - Introduction
1.0    PURPOSE
       The purpose of this guidance document is to assist facilities in SIC codes 4911 (limited to
facilities that combust coal and/or oil for the purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), and 4939 (limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution in commerce) in complying 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 FR 23834) including electricity generating facilities, along with other industry groups,
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 Electricity Generating 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 requirements 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 electricity
              generating facilities; and
        •      Reduce the level of effort expended by those facilities that prepare an EPCRA
              Section 313 report.
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        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
 electricity generating facilities. Facilities should also rely on EPA's Estimating Releases and
 Waste Treatment Efficiencies for the Toxic Chemical Release Inventory Form document to assist
 hi providing complete and accurate information for EPCRA Section 313 reporting. Additional
 discussion addressing specific issues can be found hi the 1998 EPCRA Section 313 Questions and
 Answers document. All of these documents are available on EPA's TRI website
 (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 Hotline TDD number is
 1-800-553-7672, or in the Washington, DC metropolitan area, call 703-412-3323.

 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 releases and 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:
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             National Library of Medicine (NLM) TOXNET on-line system;
             EPA's Internet site, http://www.epa.gov/opptintr/tri;
             Envirofacts Warehouse Internet site,
             http://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).
       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 hot 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 in the Washington, DC metropolitan area.
The EPCRA Hotline TDD number is 1-800-553-7672, or in the Washington, DC metropolitan
area, 703-412-3323. 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 with the necessary qualifiers 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)
                    ,YES
  Does Your Facility Have 10 or More Full-
    Time Employees or the Equivalent?

           (See Chapter 2.4)
                    YES
                   V
 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
                   \f
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). For a facility to be made up of more than one establishment, in part
requires that there are activities taking place that are recognized as uniquely different at the
facility. For example, at an electricity generating facility there may also exist a large parts and
maintenance shop which services haul trucks used to transport ash to off-site locations along with
other equipment.  The haul truck maintenance shop is uniquely different from the electricity
generating portion of the facility and may be properly classified by SIC code 7699 Miscellaneous
repair shops and related services. The electricity generating portion of the facility would
obviously be the primary economic activity in this scenario; thus, the facility as a whole would
likely be classified as SIC code 4911 Electric services, that is made up of two establishments SIC
codes 4911 and 7699.

       Conversely, in the case where an electricity generating facility has more than one type of
electricity generating unit, such as a coal fired unit located on the same property as a hydroelectric
generating unit, the facility would not be considered a multi-establishment facility because the two
types of units provide the same function (i.e., generating electricity) and are both classified as SIC
code 4911.

       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.
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                            Example - Multiple Establishments

 Your facility is comprised of two different establishments with SIC codes covered by EPCRA Section 313, a
 power plant and substation. The power plant used 8,000 pounds of an EPCRA Section 313 chemical for boiler
 cleaning during the year. The substation used 3,000 pounds of the same chemical for equipment maintenance
 during the same year. Both 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 your facility meets the
 employee threshold, you must file a Form R for that chemical. EPA allows multi-establishment facilities to
 submit Form Rs from each establishment for an EPCRA Section 313 chemical when thresholds have been
 exceeded at the facility level. Please note that Form A eligibility is also made at the facility-level, but only one
 Form A can be submitted per chemical for the entire facility.
       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.

       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.
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,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
/•-'-'": ": .-,V;-"'->Ti *T;7-"- VN: ^/-SIC^Cod^lndustrySectdK >.„":_; '"•' ' 'T -\ -'- -
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 codes 4911,4931, and 4939, that combust coal and/or oil for the purpose
of generating power for distribution in commerce must prepare Form R and/or Form A
submissions if they exceed the employee and chemical activity thresholds. There may be facilities
within SIC codes 4911,4931, and 4939 that will not have to report because they do not meet the
"limiting" criteria. For example, facilities that only combust natural gas are not subject
to EPCRA Section 313 reporting requirements.  However, facilities in SIC codes 4911,4931, or
4939 may combust coal or oil on-site for such limited uses as providing heat or electricity on-site,
and start-up activities provided such combustion of coal or oil is not for the purposes of
generating power for distribution in commerce, even if excess power is unavoidably generated
during testing and ultimately distributed in commerce. For example, existing regulations
governing nuclear facilities, such as those defined in 10 CFR ง50 Appendix A, require nuclear
reactors to maintain safety equipment to ensure that certain protective measures are operable in
the event that equipment may fail. These regulations specify that an on-site backup power source
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must be provided in such a way as to be independent of normal system power in order for safety
equipment to continue to function in the event that the nuclear portion fails or malfunctions.  This
type of use of coal and/or oil is not sufficient to bring a facility under the coverage of EPCRA
Section 313. However, if a facility intentionally generates excess power during testing operations
for the purpose of distributing power in commerce, the facility would be "covered."
                                    Example - SIC Code   ;

 An electricity generating facility produces power using coal and/or oil. Ail of the power generated at the
 facility is used to support a single facility within the same company that operates off-site from the -
 electricity generating facility. Is the electricity produced by the electricity generating facility considered
 to be distributed in commerce for purposes of determining tf the facility is "covered"?

 Yes. The electricity generating facility is classified within the SIC codes of 4911,4931, orj4939 and combusts
 coal and/or oil for purposes of generating power for distribution in commerce. Supplying electricity to a facility
 off-site is considered generating power for distribution in commerce even if the facility is within the company.
 For purposes of EPCRA Section 313 reporting, it does not matter that the sole user of the electricity produced by
 the electricity generating facility is part of the same company.                *             ซ,-
       If a facility within SIC codes 4911,4931, or 4939 combusts any amount of coal and/or oil
during the year for purposes of generating power for distribution into commerce, and the facility
meets or exceeds the employee and chemical activity threshold, they must prepare a Form R or
Form A. Because SIC codes 4911,4931, and 4939 include all types of electricity generating
facilities and other utilities, any generation of power for purposes of distribution into commerce
using coal and/or oil will subject the entire  facility, to TRI reporting, including combustion
operations for on-site support and testing purposes and non-coal and/or oil combustion
operations. For instance, if your facility is primarily a natural gas combustion facility but, because
of fluctuations in natural gas supplies, was  required to supplement natural gas combustion with
fuel oil combustion for several days during the reporting year, the entire facility would meet the
SIC code requirement. In this situation, the facility would need to assess all activities, including
the natural gas combustion operations, in conducting threshold determinations and release and
other waste management calculations.  Even though your primary power generation source may
not be coal and/or oil, any use of coal and/or oil for purposes of generating power for distribution
into commerce, is sufficient for meeting the facility's SIC code classification for EPCRA Section
313 purposes.
                                            2-6

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 -"  ^   U.  "=    '*"    -  "  "r"    Example - Coal/Oil  *"*".•-•    -   r      ฐ    *
  ~_  ^/^ ^                   ~ * _   ^  ,c,      ™ N   '  -•* —      /             ' x    j          ^
 Electricity generating facilities in SIC codes 4911,4931, or 4939 may combust a number of fuels for the
 purpose of generating power.  For purposes of EPCRA Section 313:   -. .; ,~<  ^              -     J

  -  ""-  •      Kerosene and pettoleum^coke are'consjdered oils. Facilitidsin'SICcodes4911,4931,or''
    -#          4939,5hat combust kerosene anct'petepleuiB coke for,the purpose of generating'power for'
 ->:  ,f  f-v  ,    distribution ia;commerc&ar6 subject to EPCI^V Section 313.              '; „         ^

        ซ  -"'   Non-hazardotis oil-contaminated debris is notjgonsidSfed ah oil. Facilities in SIC codes 4911,
          ' *•*•  493JI,,6r4939>thaf combust non-hazardous oil-contaminated Debris, and do not combust coal^
    Z  - ~	or oil, are.not subject to EPCRA Section 313."     -     -„ ~<      ,„ *   \            -|
       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
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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 electricity generating facility (SIC code 4911)
must assume the SIC code 4911 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 electricity generating 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 determination. Importantly, even if a facility supports one of the
covered facilities, it would STILL need to meet the SIC code qualifier of combusting coal and/or
oil for the purpose of generating power for distribution in commerce. For example, an  ash landfill
which directly supports a non-contiguous or non-adjacent electricity generating facility would be
classified as an auxiliary facility and assume the SIC code of the electricity generating facility, but
the landfill would not be covered because no combustion of coal and/or oil for purposes of
generating electricity for distribution into commerce occurred at the landfill.

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-tune 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).
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       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.
                              Example -Calculating Employees  '*-  ...      '*•-..';ff-*~*
                                    "-=,             '         3- _, ,   **•*'           ' ปr • ~ , "^
 Your facility has 7 full-time employees working 2,000 hours/year in the coal-fired power plant Therels also
 one full-time sales person and a delivery truck driver(employed by the facility) assigned to thejplaht, each!!
 working ,2,000 hours/year but predominantly onjthe road. Two,part-time employees, based at the facility, work •
 1,000 hours/year each to maintain the offrsite electricity distribution system. The wastewater treatment plant
 (pn-site and owned by the facility) is "operated by a contractor who spends an ayerage of two hoursrperfday and "
 five days per week at the plant/Finally,  you built an addition to the plant wai^house during the year,, using four
 contractor personnel who were on site full time for six months (working on average of 1,000 hours each), rYouซ
 would calculate the-number of full-time employee equivalents as follows:     ,~      -          '     ''/,*-

         •       Hours for your nine full-time employees (seven plant personnel, one^salesperson, and one
                delivery truck driver) fot the year are:    ^                        -  ,       ''   _    - '
                               9 employees x-2,000 hours/year = 18,000 hours;--              ^  f.>

         •       Hours for the electricity distribution maintenance crew are:       ~ <,',   ^     '.        '
                               2 employees x 1,000 hours/yearซ2,000 hours; and '   ~  ^'~    \   . '

         •       Hours for the wastewater treatment plant operator are:                   '         >bv-
                               2 hours/day x 5 days/week x 52 weeks/year = 520 hours; and ~-
                                                                  N  '               ,  **  '
         •       Hours for the construction crew are: '          *.                 ',- ,  !   "     '    ,
                               4 contractors x 1,000 hours = 4,000 hours.          -  -              ;

 This is a total of 24,520 hours for the year, which is above the 20,000 hours/year threshold; therefore, you meet
 the employee criterion.                                  ,      •     "',   ~  -__   ^   ;  ''  ' x" -_
                      POSSIBLE ERROR - Off-site Maintenance Crew

 Remember to include all employees based at your facility evejo if their primary activities are to maintain your
 power distribution system, both on-and off-site.   -     '.            ;     /',  *        ^  ./'"'"
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.
                                              2-9

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       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-
9346 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 waste management calculations. Once you identify the EPCRA
Section 313 chemicals at your facility, you must evaluate the activities involving each chemical
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, Tables 3-3, 3-15, and 3-16.  These terms are
briefly defined in Table 2-2, with a detailed discussion to follow.
                                          2-10

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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 wastes for energy
recovery, treatment, or disposal are not considered "distribution into commerce." For example, if
you receive an EPCRA Section 313 chemical in waste from off-site and repackage the waste and
send it to a landfill off-site, that activity should not be included in threshold determinations.

       Also, note that the threshold determinations for the three activities (manufacturing,
processing, and otherwise use) are mutually exclusive.  That is, you must conduct a separate
threshold determination for each 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.

                                         Table 2-2
                                   Activity Thresholds
   Activity
                           Definition
Threshold
 (Mปs/yr)
  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 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 material from a storage tank
to a tank truck and then distribute it into commerce, this chemical has been
processed by your facility.  	_^_	
                                                                                   25,000
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   Activity
                           Definition
Threshold
 ftbs/yr)
  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, the components
 of fuel are classified as otherwise used when the fuel is combusted on-site.

       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 was manufactured as a result of waste
       management activities on materials received from off-site for the
	purposes of further waste management activities."
  10,000
2.7    How Do You Report?

       You must file a report (Form R) for each EPCRA Section 313 chemical that exceeds a
threshold for manufacturing, OR processing, OR otherwise use (providing you meet the employee
and SIC code criteria).  As an alternative, you may file a Form A certification statement rather
than a Form R if you meet certain criteria as explained in Chapter 2.9. The TRI Forms and
Instructions contain detailed directions for the preparation and submittal of Form R and Form A
for each EPCRA Section 313 chemical for the reporting year.  The TRI Forms and Instructions
are sent to all facilities which submitted Form Rs or Form As the preceding year. However, if you
do not receive a courtesy copy or did not report in the preceding year, then copies of the TRI
Forms and Instructions can be requested from the EPCRA Hotline (1-800-424-9346) or obtained
from EPA's TRI website (http://www.epa.gov/opptintr/tri).

2.8    FormR

       If you are submitting a Form R, it is essential that you use the TRI Forms and Instructions
for the appropriate reporting year. EPA encourages the electronic submittal of the Form R, via
the Automated TRI Reporting System (ATRS).  Use of the ATRS saves time in data entry and
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)
                                            2-12

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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 hi 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
                                          2-13

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               sum of the on-site amounts released (including disposal), treated, recycled, and
               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    ;  .                -

  A covered electricity generating facility manufactures 800,000 pounds of copper compounds from combustion of
  coal, during the reporting year. Because the facility distributes all of its ash into commerce for direct reuse, the *
  total annual reportable amount of copper (the sum of Sections 8.1 through 8.7 of the Form R) is less than 500
  pounds. Because the facility did not exceed the one million pound threshold for manufacturing, processing or
  otherwise use and the facility's total reportabld quantity of copper does not exceed 500 pounds, the facility has
  the option of submitting either 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

                                           2-14

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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.

       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 time sheets);
                     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
                                           2-15

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                     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.

       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 source of information 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 II reports;
       •      Monitoring records;
       •      Air permits;
       •      Flow measurement data;
       •      RCRA hazardous waste generator's reports;
       •      Pretreatment reports filed with local governments;
       •      Invoices from waste management firms;
       •      Manufacturer's estimates of treatment efficiencies;
       •      CERCLA Reportable Quantity (RQ) reports;
       •      EPCRA Section 304 follow-up release notifications;
       •      RCRA manifests; and
       •      Process flow diagrams (including emissions,  releases and other waste management
              activities).
                                          2-16

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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)


       Step 2)


       Step 3)
                   Determine if you manufacture (including import), process, or
                   otherwise use any EPCRA Section 313 chemicals.

                   Determine the quantity of each EPCRA Section 313,chemical you
                   manufacture (including import), process, or otherwise use.

                   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, or other trade name
products, and wastes at your facility. Electricity generating facilities may find it helpful to create
two lists: one of purchased chemicals otherwise used at the facility or received from off-site for
further waste management, and one of chemicals manufactured during combustion.  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.  Next, compare the individual chemicals on both
lists to the current EPCRA Section 313 chemical 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). 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 created during combustion at an
electricity generating facility is sulfuric acid (acid aerosols). Sulfuric acid (CAS No. 7664-93-9)
has several synonyms, including dihydrogen sulfate and sulphuric acid. It must be reported on
Form R (or Form A), Item 1.2, by its EPCRA Section 313 chemical name, sulfuric acid (acid
aerosols). Synonyms can be found in EPA's 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  chemical and chemical category names and the corresponding CAS numbers and
                                          3-1

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 category codes.

       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 electricity
 generating facilities. As a guide, certain chemicals that electricity generating facilities may
 manufacture during combustion, process, and/or otherwise use are provided in Table 3-1. This is
 not a comprehensive list of all chemicals that may be manufactured, processed, and/or otherwise
 used at electricity generating facilities, but is merely a starting point for identifying chemicals for
 threshold determinations.  Facilities that distribute ash into commerce for direct reuse should also
 consider any chemicals in ash that are above de minimis levels when making threshold
 determinations.

       Information that is useful in performing threshold determinations and preparing your
 reports includes the following:

       •      Mixtures and other trade name products containing EPCRA Section 313
              chemicals;
       •      Associated CAS numbers;
       •      Throughput quantities; and
       •      Whether the chemical is manufactured, processed, or otherwise used at the facility
              (be sure to include quantities that are coincidentally manufactured and imported, as
              appropriate).

       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,
 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 waste, 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.
                                           3-2

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                                    Table 3-1
        Chemicals Commonly Manufactured, Processed, and Otherwise Used at
                          Electricity Generating Facilities
 IPCRA Section 313
 Chemicals that
 Electricity Generating
 Facilities May
 Manufacture During
 Combustion
EPfcRA Section 313    v'
Chemicals thatEtectricity
Generating Facilities May
-Process (in Ash for Direct
Reuse) J"  ...
EPCRA Section 313 Chemicals
that Electricity Generating
Facilities May Otherwise Use
 Antimony compounds
 Arsenic compounds
 Barium compounds
 Cadmium compounds
 Chromium compounds
 Copper compounds
 Formaldehyde
 Hydrochloric acid (acid
 aerosols)
 Hydrogen fluoride
 Lead compounds
 Manganese compounds
 Mercury/Mercury
 compounds
 Nickel compounds
 Selenium compounds
 Silver compounds
 Sulfuric acid (acid
 aerosols)
 Vanadium fume or dust
 Zinc compounds
Antimony compounds
Arsenic compounds
Barium compounds
Cadmium compounds
Chromium compounds
Copper compounds
Lead compounds
Manganese compounds
Mercury
Nickel compounds
Selenium compounds
Silver compounds
Vanadium fume or dust
Zinc compounds
Ammonia
Bromine
Chlorine
Chlorine dioxide
Copper compounds
Ethylene glycol
Formic acid
Hydrazine
Hydrochloric acid (acid aerosols)
PAC compounds
Thiourea
1,2,4 Trimethylbenzene
Zinc compounds
Chemicals Manufactured During Combustion
      Electricity generating facilities may manufacture several EPCRA Section 313 chemicals
during combustion. To identify the chemicals manufactured, you should use your best readily
available information. This information could include analytical data on fuel sources used and
combustion processes (e.g., fuel analyses, coal quality database, stack emission testing,
combustion tests, etc.), process knowledge, other facility derived data, information from industry
associations and EPA sources, and information on chemicals releases or other wastes leaving the
facility. This chapter will discuss many of the metals and metal compounds, acids, and organics
that are likely to be manufactured during combustion.
                                        3-3

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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.
Electricity generating facilities may receive MSDSs for any mixture or other trade name product
purchased for use as fuel, equipment cleaning and maintenance, water treatment, 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, 1998 EPCRA Section 313 Question and Answers, Appendix A,
Directive 9 (EPA-745-B-98-004) or Supplier Notification Requirements brochure, (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
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.
                                          3-4

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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. 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 through 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. The Agency publishes its
findings and any regulatory action through  the  Federal Register.

       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.

       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.
                                          3-5

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                              Example - Chemical Categories       ~

  Example 1      A facility otherwise uses 6,000 pounds of copper compound in equipment painting-bperation,
  manufactures 20,000 pounds of copper oxide as a combustion by-product, and processes 18,0(k) pounds of
  copper oxide in ash for reuse. All three compounds are members of the copper compounds category, an
  EPCRA Section 313 chemical category. Because the facility does not exceed the otherwise use, manufacturing,
  or processing thresholds, the facility is not required to file a Form R or Form A for the Copper compound
  category.
                          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
       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
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.

       The qualifiers associated with these chemicals which may be applicable to the electricity
generating industry 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 in 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.
                                            3-6

-------
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 1998
EPCRA Section 313 Question and Answers, - 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)
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,
pulverizes 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
add (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
                             3-7

-------
3.2
       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 (acid aerosols) 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 (acid aerosols) 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).

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 activities (Tables 3-3,3-14 and 3-
15 provide detailed definitions of subcategories for each 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   'y
                       	   ,'                                           ^~   *•*          /   '
 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
 gPQRA 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 that chemical
 must be reported on die Form R, including those from the "otherwise use" activity.  Additionally, you must also
       s on the Form R in Part II, Section(s) 3.1,3.2, and 3.3, all non-exempt activities involving the reportable
       :	'''1'	""'"f	'   l*                   ';      *   "    '     ~
                                            3-8

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                     POSSIBLE ERROR - Threshold Determination
 The amount of theJBPCRA Section 313 chemical mat is~actually manufactured (including the quantity;
 containing 15,000 pounds of anhydrous ammonia. To replace fugitive releases-and small Tosses |hatlpccur
 during use, you add 5,000 poundsljfanhydrquyammdnia to the cooling system!" In this>example, only the 5,000
 pounds that were added to the system count toward the "otherwise use" threshold.  Therefore, unless you  -„
 "otherwise use" more than 5,000 pounds elsewhere at the faciHtyj the "otherwise use" threshold of 10,000 >  ' *1
 pounds has not been exceeded and yoii would not hjave to^ep^rt for ammonia.            '   f'~  \  .
       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 electricity generating facilities may not intend to manufacture
EPCRA Section 313 chemicals during operations, combustion of various fuels will produce
certain EPCRA Section 313 chemicals that must be considered towards the manufacturing
threshold. You will also 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.  Most commonly,
electricity generating facilities manufacture new  metal compounds (usually as a result of
oxidation), acid aerosols, formaldehyde, and other organic compounds, or convert metal
compounds to the parent metal (e.g., mercury compounds in coal may reduce to elemental
mercury). The following discussion describes the various activities included under manufacturing
(see Table 3-3), and other manufacturing threshold issues that are relevant to electricity
generating facilities.
                                            3^9

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                                     Table 3-3
             Definitions and Examples of Manufactured Chemicals
Piviiuiuiacimuig .ncuyiiy
'"' Subcategory " '"'
Imported for on-site
use/processing
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
" •- -"' -"jaXaplHIfSS,, . '' :.'."; •:ฃ.;::•{': ?>?•<••
Fuels, maintenance chemicals, or limestone that may
contain EPCRA Section 313 chemicals imported into the
customs territory of the United States.
EPCRA Section 313 chemicals in fuel imported by a
facility and sent to other facilities, such as intra-company
transfers.
Hydrogen fluoride, hydrochloric acid (acid aerosols)
and/or sulfuric acid (acid aerosols) formed during the
combustion of coal, oil, or other fuels.
The coincidental manufacturing of metal compounds during
the combustion of coal and oil.
May not occur in the electricity generating industry.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this
guidance manual.

      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.  The same
is true if an elemental metal is converted to a metal compound, although this is not known to be
an issue in the combustion of coal, oil, or other fuel types common to electricity generating
facilities. 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 remains as beryllium oxide during combustion. In this case, a beryllium
compound has not been manufactured and no amounts of beryllium compounds would need to be
considered toward the manufacturing threshold.
                                        3-10

-------
   ' + ' Haw Bo I Calculate Amounts of Metal  ฃ/'*
 Compounds Manufactured During Combustion?
r>  -  t **•  "   ..<*'*'   --    .ฃ( --^  ---f^"'
    - jป      .       _        -%&<•*•       ^   ซ  -.
.%the absen&s ofrbetter facflit^%eeific.d8taป use Tables^-4 „  ~
 arid 5-5'to cj^culjfeamouafr bfmetal confounds  -. ^  ^4,1
                                           ~
       To calculate the amount of Section 313 metal compounds manufactured during
combustion, facilities must first estimate the concentration of each metal present in the coal, oil,
or other fuel. These metals are likely to exist as metal compounds in the fuel.  The best available
information should be used to
estimate the approximate
concentration of the metal in the fuel.
 If a facility has data regarding
chemical concentrations in the fuels
used by the facility, and the facility
believes that this is the best readily
available information, then the facility
should use this information. If
specific concentration data of
EPCRA Section 313 chemicals in
fuel does not exist at your facility,
there are several sources where the
facility can find this concentration
data.  Examples include
specifications of product content and
concentrations from the supplier,  as
well as nationally assembled data
such  as the U.S. Geological Survey's
(USGS) coal quality data base (http://energy.er.usgs.gov/products/databases/CoalQual/) or
Electrical Power Research Institute's (EPRI) PISCES data base 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 metal oxide possible. You may use the
default values provided in Tables 3-4 and 3-5 provided in this chapter.  Table 3-4 lists
concentrations of EPCRA Section 313 metals and organics typically found in crude oil and
petroleum products otherwise used by electricity generating facilities. Only the metals in Table 3-
4 would be considered in manufacturing threshold determinations. To support the facility's
threshold calculations, the facility should document the type of fuel it uses.  Table 3-5 also uses
the concentrations associated with coal type (by originating state) to show the estimated 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 3-5 was derived from data in Appendix D of the Study of
 Hazardous Air Pollutant Emissions From  Utility Steam Generating Units').
         table^/simply.lpokiitidCT the eolanSh titled  v  - "/ ,
 "Approximate' Tons of Coal Needed To Be Consumed.^;
cMaatrfactaee^S^OOOLbs: 'ofrflfe ltfet$ Oxide. "- For each metal
 compound, compjfe'tkis value to tfie amounfof fuel combusted
-at your facility-during rnelrepbrtirigyear.1 ff* 8ie amouri^"
 combusted exceeds the value in the.tablefyou have exceeded ^
 the threshold for that metal*compound, aad ygu must prepare a
:Form Itor Form A for,that metarpompound category."jF6r ^
 example, If you combust more than4,8tiQ tons of coal during ,
s the 'reporting year.'you must prepare aForm R or Form Alor
 zinc cojnpounds.   , ; ~, / '-    ."   "*'" _   -  v-I' * '   ":"~
                                            3-11

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                          Table 3-4
Estimated Concentration Values of EPCRA Section 313 Constituents
      in Crude Oil and Petroleum Products (Weight Percent)
EPCRA Section
313 Chemical
Benzene
Bfphenyl
Bromine
Chlorine
Cyclohexane
Eihylbcnzene
n-Hexane
MTBE*
Naphthalene
Phenanttutne
Phenol
PACs*
Slyrcnc
Toluene
1,2,4-Tiimelhyl-
benzene
Xylcnc
Antimony"
Arsenic'
Beryllium*
Cadmium*
Chromium*
Cobalt*
Copped
Lead Compounds
Manganese*
Mercury*
Nickel*
Selenium*
Silvo*
DeMinimls
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
1.0
1.0
1.0
0.1
0.1/1.0 c
0.1/1.0C
O.I/l.O'
0.1/1.0'
1.0
1.0
1.0 (organic)
0.1 (inorg.)
1.0
1.0
0.1
1.0
1.0
Crude Oil
0.446 R
0.060"
N/A
N/A
0.700
0.346"
Z463"
N/A
0.219"
N/A
0.323
0.0004
N/A
0.878 R
0.326
1.420"
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
Gasoline
(Various
Grades)
1.608R
0.010"
N/A
N/A
0.240
1.605"
7.138"
15.00
0.444"
N/A
0.055
N/A
N/AB
7.212"
2.50*
7.170"
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.ZFuel
Oil/ Diesel
Fuel
8.0E-04*
0.100
N/A
N/A
N/A
0.01 3 A
1.0*
N/A
0.550
0.125
0.064
N/A
0.032"
0.032*
1.0'
0.290*
N/A
8.5^
5.0""*
2.1 M5
9.5 M
N/A
5.6E-04
N/A
2.1E-05
4.0E-05
3.38E-04
N/A
N/A
Jet Fuel
CJP-4)
1.0A
0.120R
N/A
N/A
1.240
0.50 A
5.60*
N/A
0.468"
N/A
N/A
N/A
N/A
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
Kerosene
0.004 A
0.120"
N/A
N/A
N/A
0.127 A
0.005*
N/A
0.733"
N/A
0.770
N/A
N/A
1.330"
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
Lubri-
cating
Oil
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
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 D
N/A
0.0022
N/A
N/A
0.10
N/A
N/A
1.13
N/A
0.006
N/A
0.013
l.OE-06
3.06E-
05D
2.7E-060
2.0E-06"
3.1E-050
1.63E-
04"
3.0E-05
1.41E-
04"
3.5E-05"
9.2E-07D
2.6E-03"
9.5E-06"
2.0E-08
Aviation
Gasoline
0.515"
N/A
N/A
N/A
N/A
0.432"
0.126 R
N/A
0.10"
N/A
N/A
N/A
N/A
7.327
N/A
2.204
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.14-
(organic)
N/A
N/A
N/A
N/A
N/A
                            3-12

-------
EPCRA Section
313 Chemical
Zinc Compounds
Dt Minimis
Level*
1.0
Crude Oil
N/A
Gasoline
(Various
Grades}'
N/A
No.2Fuel
Oil/Diesel
Fuel
N/A
Jet Fuel
CJP-fl
N/A
Kerosene
N/A
Lubri-
cating
on
1.0
Nft.6
fuel Oil
N/A
Aviation
Gasoline
N/A
Unless otherwise noted, Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix B
"Composition of Crude Oil and Petroleum Products."
A American Petroleum Institute report prepared for Mr. Jim Durham, EPA (December 23,1993), regarding revised estimates of heavy petroleum
product liquid constituents that are listed as hazardous air pollutants (HAPs) under section 112 of the Clean Air Act Amendments (CAAA).
R Radian Corporation report prepared for Mr. James Durham, EPA (August 10,1993), regarding liquid HAP concentrations of various petroleum
products. ,
D Appendix D, Study of Hazardous Air Pollution Emissions from Electric Utility Steam Generating Units-Final Report to Congress, USEPA, OAQPS
(February 1998) 453/R-98-004b.
* The de minimis concentration values for the metals is for the metal compound.
" Lead compounds for Aviation Gasoline 100 (Exxon-MSDS).
* Concentrations updated with comments received from API.
' Constituents are most likely metal compounds rather than the elements. Elements are listed in this table because concentration data are for only the
metals occurring in the fuel.  Concentrations for metal compounds would be somewhat higher depending on the metal compound.  For threshold
determination, if the weight of the compound is not known, facilities may use the weight of the lowest metal compound likely to be present.
8 Data from EPA report prepared by Radian Co. for this constituent are considered suspect and are not recommended for use, based on discussion with
Jim Durham of EPA on November 30,1998.
b MTBE may be present to enhance octane in concentrations from 0-15% (industry practice, not sampling results).
c The de minimis level for inorganic compounds is 0.1; for organic compounds is 1.0.
d The de minimis level for chromium VI compounds is 0.1; for chromium III compounds is 1.0.
e The petroleum products may contain one or more of the following chemicals under the polycyclic aromatic compounds (PACs) category:
benzo(a)anthracene, benzo (b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranthene, benzo(rst)pentaphene, benzo(a)phenanthrene,
benzo(a)pyrene, dibenz(a,h)acridine, dibenz(aj)acridine, dibenzo(a,h)anthracene, 7H-Dibenzo(c,g)carbazole, dibenzo(a,e)fluoranthene,
dibenzo(a,e)pyrene> dibenzo(a,h)pyrene, dibenzo(a,l)pyrene, 7,12-dimethylbenz(a)anthracene, indeno[l,2,3-cd]pyrene, 5-methylchrysene, 1-
nitropyrene. For No. 6 fuel oil, the value given is for benzo(a)anthracene.
                                                       Table 3-5
 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) " ,,--'"""'-" . ' - - -' <- /'"ป"•
Antimony/SbjO,
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/HgiO
1.9
3
0.5
0.15
20
5
53.93b
95"
5.4
88
0.07
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
5.48
3.16
8.99
73.10
0.48
1.97
NA
NA
2.14
0.11
171
                                                           3-13

-------
Section 313 Metal/
Lowest Weight Metal
Oxide* That May Be
Manufactured from the
Metal
Nickel/NiO
Selenium/SeO2
Metal Concentration in
Coal in Units of
Micrograms/Gram
10
1.6
Pounds of Metal Oxide
Manufactured per Ton
of Coal Combusted
2.56E-02
4.51E-03
Alabama (Bituminous) ;
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl5O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/HgjO
Nickel/NiO
Selenium/SeO2
1.82
53
1.88
0.06
22.8
8.2
380"
127"
7
41
0.19
17.5
1.88
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
0.98
5.54
"">s> " „
5.72
0.18
2.39
182.75
0.42
1.20
NA
NA
1.65
0.24
63.26
0.56
4.72
Arkansas (Lignite) '',*',
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,
1.17
4.3
2.4
0.29
16.9
6
142b
63"
9.8
119
0.25
11.8
5
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
8.90
2.20
1.87
37.81
0.56
1.64
NA
NA
1.18
0.08
48.08
0.83
1.77
3-14

-------
Section 313 Metal/
Lowest Weight Metal
Oxide8 That May Be
Manufactured from the
Metal
Arizona (Subbituminous)
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nickel/NiO
Selenium/SeOj
Metal Concentration in
Coal in Unite of
Micrograms/Gram
-j'- "* • *y • ^
0.47
2.1
1.1
0.1
4.6
2.1
200"
79"
9
27
0.07
4.8
1.5
Pounds of Metal Oxide
Manufactured per Ton
of Coal Combusted
1 •-;;?-,,:i~.
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
*' :~~~ ':^J!f,^
22.22
4.5
4.09
109.65
2.07
4.69
NA
NA
1.29
0.36
, 172
2.03
5,91
Colorado (Bituminous) ,
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/FjO
Lead/PbO
Manganese/MnO
Mercury/Hg2O
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
11.5
7.07
12,49
60.92
5.05
0.96
. NA
NA
2.13
0.89
.172
7.81, .
10.19
3-15

-------
Section 313 Metal/
Lowest Weight Metal
Oxide1 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
Colorado (Subbituminous)
Antimony/Sb2O,
Arsenic/As2O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/HgjO
NickelyNiO
Selenium/SeO,
Illinois (Bituminous)
Antimony/Sb2O3
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/CljO
*luorine/F2O
Lead/PbO
vfanganese/MnO
Mercury/Hg2O
Nickel/NiO
Selenium/SeO,
0.35
1.03
0.84
0.08
4.1
1.6
118"
99"
3.5
32
0.14
7.9
0.89
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
30
92
5.35
137.06
2.33
6.15
NA
NA
3.31
0.30
86
1.24
9.96

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
3-16

-------
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
•sj- .; •- ,; SN?--
Indiana (Bituminous) - ป.•>-;* - -' --^
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
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
Selenium/SeO,
1.4
10.1
2.82
0.49
15.4
5.2
1032.79"
65b
10.9
38
0.11
17.9
2.17
,..'' ^
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
, < K- •' , „'
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
*f
-rf ~ ^
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
3-17

-------
Section 313 Metal/
Lowest Weight Metal
Oxide" That May Be
Manufactured from the
Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Kansas (Bituminous)
Antimony/Sb2Oi
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nickel/NiO
Selenium/SeOjj
0.85
25
1.47
10
10.1
15
2500"
64b
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
Kentucky (Bituminous) """V t ;c;,;
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Huorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nickel/NiO
Selenium/SeO,
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
3-18

-------
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/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
•- " ^ -"' *: ...^:>' ,-*,<-• :~" i& /* ซ---"-" -"
0.82
3.7
1.9
0.15
11.4
3.3
115b
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
12.76
2.56
2.37
73.10
0.84
2.98
NA
NA
2.10
0.07
63.25
1.25
1.48
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,
0.81
26
2.01
0.14
26.7
11
914"
107"
10
13
0.42
22
3.8
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
12.92
0.36
2.24
78.32
0.36
0.89
NA
NA
1.16
0.75
28.62
0.44
2.33
3-19

-------
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
Missouri (Bituminous) /x
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,
1.6
10
2.01
0.8
12.2
6.7
1701.64"
60"
67
99
0.17
23
4.2
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
-' ,
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
FIuorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
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
3-20

-------
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
Montana (Lignite) ; V
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
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
11.36
0.52
4.32
99.68
10.15
12.30
NA
NA
2.41
0.14
100.2
2.44
12.31
Montana (Subbituminous)
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Huorine/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
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
3-21

-------
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/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
0.58
8.4
0.82
0.11
7
2.7
110"
34b
3.73
86
0.13
4.1
...P.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/Sb2O3
Arsenic/As2O3
Beryllium/BcO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nickel/NiO
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
3-22

-------
Section 313 Metal/
Lowest Weight Metal
Oxide3 That May Be
Manufactured from the
Metal
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
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton
of Coal Combusted
' *'*.--."-' /i ^ - ' '
.,.-"-' ' s* •* *
0.81
23.2
2.39
0.12
14.3
0.9
719"
92"
7.3
28.3
0.22
14.9
3.8
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
_~ — -f * " --
12.92
0.40
1.88
91.37
0.67
10.94
NA
NA
1.59
0.34
54.63 .
0..66
2.33
v *• t/ '<&( ,ป•••'*' _ , ^ „ ' „
Oklahoma (Bituminous) "* " _ - .-, „ > * ;. : -" '
Antjmony/Sb2Oj,
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
267"
77"
10
74
0.17
17
1.8
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
15.16
0.40
5.23
109,65
0.64
1.59
NA
NA
1.16
0.13
136.16
0.57
4.93
3-23

-------
Section 313 Metal/
Lowest Weight Metal
Oxide1 That May Be
Manufactured from the
Metal
Pennsylvania (Bituminous
Antimony/Sb2O3
Arsenic/AsjOj
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/HgjO
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 - : ' ••':•••
1.23
32.1
2.45
0.1
20.1
7.9
1096"
78"
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
8.50
0.30
1.84
109.65
0.47
1.25
NA
NA
1.07
0.41
41.43
0.48
2.50
Texas (Lignite)
Antlmony/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,
0.82
3.7
1.9
0.15
11.4
3.3
115"
83b
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
12.76
2.56
2.37
73.10
0.84
2.98
NA
NA
2.10
0.07
63.26
1.25
1.48
3-24

-------
Section 313 Metal/
Lowest Weight Metal
Oxide3 That May Be
Manufactured from the
Metal
Utah (Bituminous)
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/FjO
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
- -"- <" - ^'S . , -;
0.23
0.89
0.61
0.08
7.7
2.7
219.67"
57"
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
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
' - -- =
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) , ' - •" -'- • * J- '
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,
0.93
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
3-25

-------
Section 313 Metal/
Lowest Weight Metal
Oxide* That May Be
Manufactured from the
Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Washington (Subbituminous)
Antimony/Sb2O3
Arsenic/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nicke]/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
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
.'"-"
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/As2O3
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
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
3-26

-------
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/Cl,O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury/Hg2O
Nickel/NiO
^Fป1fปniiitn/^!pO
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton
of Coal Combusted
XV - ~ s," *" f — Or- ~ ™
-' > -' <"_<***_ -;, -
0.73
0.69
0.18
0.13
2.82
0.87
118.3"
43.7"
2.07
5.65
0.08
2.17
0 51
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-0^
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
,rv , ,i"
14.32
13.72
24.98
84.35
3.38
11.3.1
NA
NA
5.59
1.72
150.24
4.50
17 38
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
Electric Utility Steam Generating Units - Final Report to Congress, February 1998), this
cleaning process can affect the concentrations of some of the constituents in coal. In order to
account for this, Table 3-6 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 3-6.  Note, based on
the analysis used to develop information in Tables 3-5 and 3-6, it was identified that bituminous
coal from Illinois  and Colorado was not subject to cleaning processes; therefore, the factors in
Table 3-6 should not be used for bituminous coal from these two states.
                                             3-27

-------
                                          Table 3-6
                     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

An electricity generating 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 Table 3-5 in this document,
the facility estimates that it 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.
                                            3-28

-------
       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
should consider information on those metals and metal compounds provided in Table 3-7 for
purposes of threshold determinations 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 3-7
and facilities are instructed to use their best "readily available" information when developing these
estimates. However, if the facility does not have better information, then Table 3-7 should be
considered.

                                        Table 3-7
   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 3-5
EPCRA Section
313 Metal/ Lowest
Weight Metal
Oxide That May
Be Manufactured
from the Metal
Zinc/ZnO
Barium/BaO
Copper/Cu2O
Silver/ Ag9O
Metal
Concentration
in Coal in Units
of Micrograms/
Gram
5,600
250
' 185
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
     *      /        \.  -        s...       . .         .
 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.
        One exception to the assumption that metal compounds in fuel convert to lowest weight
 metal oxides during combustion is mercury. Mercury exists as a compound in coal.   Current
 information estimates that mercury compounds found in coal convert to either divalent mercury or
 elemental mercury during combustion. At this point, the percent conversion of either form of
                                            3-29

-------
mercury is unknown. Therefore, while divalent mercury will readily combine to form a
compound, EPA is allowing facilities to use the lower weight elemental for of mercury when
making threshold determinations (Study of Hazardous Air Pollutant Emissions from Electricity
Generating Units - Final Report to Congress, February 199S).  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
that 100% of the mercury portion of the mercury compounds in the coal convert to elemental
mercury. In this case, you must 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 and
Table 3-5.

       Table 3-8 shows the estimated pounds of metal oxide manufactured per gallon of fuel oil
No. 6 combusted and the estimated gallons of fuel oil No. 6 needed to be consumed to
manufacture 25,000 pounds of the metal oxide. Table 3-9 shows the estimated pounds of metal
oxide manufactured per gallon of fuel oil No. 2 combusted and the estimated gallons of fuel oil
No. 2 needed to be consumed to manufacture 25,000 pounds of the metal oxide as a quick
reference for facilities.
                                          3-30

-------
                                   Table 3-8
     Concentrations of EPCRA Section 313 Metals and their Compounds
         in No. 6 Fuel Oil and Pounds of Metal Oxide Manufactured
                      per Gallon of Fuel Oil Combusted
EPCRA Section 313
Metal/ Lowest
Weight Metal
Oxide* That May
Be Manufactured
from the Metal
Manganese/MnO
Nickel/NiO
Lead/PbO
Cadmium/CdO
Copper/Cu2O
Cobalt/CoO
Selenium/SeO2
Beryllium/BeO
Arsenic/As2O3
Antimony/Sb2O3
Mercury/Hg*
Chromium/CrO
Silver/Ag2O
Metal
Concentration in
No. 6 Fuel Oil in
Units of
Micrograms/Gram
0.35
26.0
1.41
0.02
0.3
1.63
0.095
0.027
0.306
0.01
0.0092
0.31
0.0002
Pounds of Metal
Oxide
Manufactured per
Gallon of Fuel Oil
No. 6 Combusted
3.6E-06
2.6E-04
1.2E-05
1.8E-07
2.7E-06
1.7E-05
1.1E-06
6.0E-07
3.2E-06
9.6E-08
7.4E-08*
3.2E-06
2.0E-09
Approximate
Gallons of Oil
Needed To Be
Consumed to
Manufacture 25,000
Lbs. of the Metal
Oxide
6.9E+09
9.5E+07
2.1E+09
1.4E+11
9.3E+09
1.5E+09
2.3E+10
4.2E+10
7.7E+09
2.6E+11
3.4E+11
7.7E+09
1.5E+13
* Mercury compounds in coal are likely to convert to elemental mercury during combustion. Value represents
pounds of elemental mercury manufactured per gallon of fuel oil No. 6 combusted.
Note: Values are calculated based on a density of 8 Ib/gal for Fuel Oil No. 6
                                       3-31

-------
                                       Table 3-9
  Concentrations of EPCRA Section 313 Metals and their Compounds in No. 2
   Fuel Oil and Pounds of Metal Oxide Manufactured per Gallon of Fuel Oil
                                      Combusted
EPCRA Section 313
Metal/ Lowest Weight
Metal Oxide* That May
Be Manufactured from
the Metal
Copper/Cu2O
Nickel/NiO
Chromium/CrO
Mercury/Hg*
Manganese/MnO
Cadmium/CdO
Arsenic/As2O3
Beryllium/BeO
Metal Concentration in
No. 2 Fuel Oil in ppm
5.60
3.38
0.95
0.40
0.21
0.21
0.09
0.05
Pounds of Metal Oxide
Manufactured per
Gallon of Fuel Oil No. 2
Combusted
4.4E-05
3.0E-05
8.7E-06
2.8E-06
1.9E-06
1.7E-06
8.3E-07
9.7E-07
Approximate Gallons of
Fuel Oil Needed To Be
Consumed to
Manufacture 25,000
Lbs. of the Metal Oxide
5.7E+08
8.3E+08
2.9E+09
8.9E+09
1.3E+10
1.5E+10
3.0E+10
2.6E+10
* Mercury compounds in coal convert to elemental mercury during combustion. Value represents pounds of
elemental mercury manufactured per gallon of fuel oil No. 2 combusted.
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix
E, Table E

       Manufacture of Acid Aerosols During Combustion . During combustion of fuel, facilities
may manufacture hydrochloric acid (HC1) (acid aerosols), hydrogen fluoride (HF), and sulfuric
acid (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 3-10. 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 3-10. 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
3-10 are more appropriate than AP-42 factors, which are averages of factors for each type of
coal.
                                         3-32

-------
                  Example - Manufacture of SuHuric Acid (Acid Aerosols)             -

 An electricity generating facility combusts coal. As a result of thl combustion operation/the facility, emits
 sulfur dioxide (SO2), sulfur trioxide^SCy, and particulate sulfates through a poirit source. Once emitted,
 the sulfur trioxide readily reacts with water vapor (both in air and in flue gases) to form a^sulfuric acid
 mist For purposes of EPCRA Section 313, must the facility report on the manufacture of sulfuric acid
 (acid aerosols)? .-               *                         ~     _„*>'      ;*'-   ซN           /     '
                                       SX      ' '           •"'         ?'S        *~ N-       <
 No. The sulfuric acid formed in the chemical reaction of sulfur trioxide and~water that often occurs in the air /"
 after releasing sulfur trioxide is notincluded in threshold 'determinations. The facility owner/operator is not
 responsible for tracking or reporting on ^formation of a BRCRA* Section 313 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 facW the quantity of sulfuric acid mist generated towards
 the manufacture threshold." If the threshold istexceeded/the facility owner/operator must report all releases "and-
 other waste management estimates of sulfuric acid (acid aerosols) from flue facility:         ,  „
       For guidance on calculating the amount of sulfuric acid (acid aerosols) manufactured
during combustion, refer to: Emergency Planning and Community Right-to-Know Act-Section
313: Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size), EPA, March 1998, available on EPA's website at
http://www.epa.gov/opptintr/tri.
        Calculating Thresholds for Hydrochloric Acid (Acid AerosolsVand Selenium

 A facility in Wyoming combusts 1 million tons of subbitominous coal in the reporting year. What quantity of
 selenium compounds and HC1 (acid aerosols) are manufactured? "                "

 Hydrochloric Acid (Atid Aerosols):-"
  The HCl emission factor for subbituminous coal is'L9 Mton coal (see Table 3-10).'

  1.9 Ib HCl/ton coal x 1,000,000 tons coal = 1,900,000pounds HC1 (acid aerosols)       7

  Therefore, 1.9 million pounds of HCl are manufactured and the 25,000 pound thresholdhas been'exceeded.
  Form R reporting for HCl (acid aerosols) is required.;   .

  Selenium Compounds:                    „
  Based on the concentration of selenium in Table 3-5: the concentration factor forselenium oxide (SeO^ is 1.44
  x-lV3 Ib SeO;/ton coal. ,           „    ,<"„;/

  1.44 xlCT3lb SeO/ton coal x ltOOO,000 tons of coal = 1,440 pounds ofSeO2 produced.

  Therefore, 1,440 pounds of selenium compounds are manufactured and the 25,000 pound threshold was not
  exceeded. Form R reporting for, selenium compounds is not required.
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       Manufacture of Formaldehyde During Combustion. Table 3-11 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 3-10
 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
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                                      Table 3-11
                Emission Factors and Triggering Thresholds For
                Formaldehyde Manufactured During Combustion
Fuel Source
Natural Gas
No. 2 Fuel Oil
No. 6 Fuel Oil
Coal
Emission Factor
(units of measure)
1.55e-01 lb/M-ft3
61 Ib/MgaT
33 Ib/Mgal
2.4e-04 Ib/ton
Combusted to Manufacture 25,000 Ibs.
of Formaldehyde
161,290 M-ft3
410 Mgal
758 Mgal
104 Mtons
Source: AP-42, External Combustion Sources, Tables 1.4-4, 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.
a. Emission factor is the upper range for No. 2 fuel oil combustion.

       Manufacture During Flue Gas Desulfurization (FGD). Many electricity generating
facilities use various types of flue gas desulfurization (FGD) systems to remove sulfur dioxide
from flue gas.  In some cases, the flue gas passes through a limestone slurry, where calcium from
the limestone reacts with sulfur dioxide in the flue gas. This produces various calcium
compounds, and may result in the coincidental manufacture of metal compounds. EPCRA
Section 313 metal compounds may exist in limestone as metal carbonates (e.g., cobalt carbonate)
or as other metal compounds (e.g., silver sulfide).  As flue gas passes through the limestone
slurry, metal compounds in limestone may convert to other metal compounds, such as metal
sulfites or sulfates. The amount of a compound  within a EPCRA Section 313 metal compound
category produced as a result of chemical conversion must be applied to the manufacturing
threshold, even if the new metal compound is within the same compound category.

       To determine the identity and amount of metal compounds manufactured during FGD,
facilities should use the best "readily available data". This may include analyses of limestone or
lime solution, process knowledge, data on sulfur content of coal, literature about reactions that
take place in FGD systems and information about the composition of FGD wastes and flue gas
(see Chapter 4.2).  In the absence of better data,  facilities can  assume that all metal compounds in
limestone will  convert to either metal sulfites or  metal sulfates. The sulfate/sulfite ratio of FGD
waste is chiefly determined by the sulfur content of the coal burned and the use of forced sludge
oxidation. Lower sulfur content in coal generally produces a sludge high in sulfates, while coal
with a higher sulfur content will be high in sulfites. Forced oxidation converts sulfites in FGD
sludge to sulfates, improving the disposal properties of the sludge.  In the absence of better data,
facilities that combust low-sulfur western coal, or use a forced oxidation step (regardless of sulfur
content) should assume that metal compounds in limestone convert to metal sulfates. Table 3-12
provides concentrations of metals in limestone, and shows the amount of metal sulfate
manufactured per pound of limestone used. Facilities that combust high-sulfur eastern coal and
do not use a forced oxidation step should assume that metal compounds in limestone convert to
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metal sulfites. Table 3-13 provides concentrations of metals in limestone, and shows the amount
of metal sulfite manufactured per pound of limestone used.
                                   Table 3-12
    EPCRA Section 313 Metal Constituents of Limestone and the Estimated
   Pounds of Limestone Needed to Manufacture 25,000 Lbs. of Metal Sulfate
EPCRA Metal
Arsenic/As2(SO4)3
Barium/BaSO4
Cadmium/CdSO4
Chromium/CrSO4
Cobalt/CoSO4
Copper/Cu2SO4
Lead/PbSO4
Manganese/MnSO4
Mercury
Nickel/NiSO4
Selenium/Se(SO4)2
Silver/Ag2SO4
Zinc/ZnSO4
Concentration in
Limestone
(ppm)
2.5
2000
2
500
5
10
100
1100
1
20
.08
1
200
Pounds of Metal Sulfate per Ton
of Limestone Used (Western
Coal, or Any Coal with Forced
Oxidation Systems)
0.015
6.8
0.007
2.85
0.026
0.035
0.29
6.04
0.002
0.105
0.00055
0.003
0.99
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization by Electric Utilities,
Chemistry Report, OPPT, March 26, 1997.
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                                  Table 3-13
   EPCRA Section 313 Metal Constituents of Limestone and the Estimated
      Pounds of Metal Sulfite Manufactured per Ton of Limestone Used
EPCRA Metal
- " - \
, - •• **
Arsenic/As2(SO3)3
Barium/BaSO3
Cadmium/CdSO3
Chromium/CrSO3
Cobalt/CoSO3
Copper/Cu2SO3
Lead/PbSO3
Manganese/MnSO3
Mercury
Nickel/NiSO3
Selenium/Se(SO3)2
Silver/Ag2SO3
Zinc/ZnSO3
Concentration in Limestone
'::„ ; (ppm)
ฐS
/
* " ^ X
ฃ*
2.5
2000
2
500
5
10
100
1100
1
20
.08
1
200
Pounds of Metal Sulfite
Manufactured per Ton of
- /Limestone*Used
(Eastern Coal)
0.013
6.3
0.007
2.5
0.024
0.033
0.28
5.4
0.002
0.094
0.00048
0.003
0.89
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization by Electric Utilities,
Chemistry Report, OPPT, March 26, 1997.
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       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 listed 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 waste or chemical broker), ordered
the waste or 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 the 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.
                   Example - Importing that Qualifies as Manufacturing

 Fuel oil containing EPCRA. Section 313 chemicals above de minimis is produced in Mexico by an
 American owned company and is sent to the U.S. When the facility operating within the U.S. receives the
 fuel oil, has it manufactured the EPCRA Section 313 chemicals contained in the fuel oil?

 Yes, if the receiving facility either has a contract or agreement in place to receive "imported" fuel oil and is
 functioning as the importing facility. Amounts of EPCRA Section 313 chemicals received in the fuel oil must '
 be counted toward the "manufacturing" threshold.                              ,        „,     	
Processing

       Processing means preparing an EPCRA Section 313 chemical, or a mixture or other trade
name product containing an EPCRA Section 313 chemical, for distribution in commerce (usually
thought of as the intentional incorporation of an EPCRA Section 313 chemical into a product).
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. Distributed 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).

       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

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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.  Sending a commercial product fuel off site (for example, to a customer or
distribution center) is considered processing assuming that the facility sending the commercial fuel
off-site has blended and/or repackaged the fuel. 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
or other extraction of contaminants; for example, ash sent off-site for concrete manufacturing.
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 3.2.2.2).  EPCRA Section 313 chemicals in waste that are sent off-site for further waste
management, e.g., disposal are not considered to be reused.

       A primary example of a processing activity that may take place at electricity generating
facilities is preparing for distribution of ash into commerce for direct reuse or recycling. Facilities
that send ash off-site for direct reuse must count amounts  of EPCRA Section 313 chemicals in the
ash toward their processing thresholds. For example, some electricity generating facilities may
sell ash to construction companies for direct reuse in the manufacture of cement blocks. These
electricity generating facilities must apply  the amounts of EPCRA Section 313 chemicals in the
ash distributed into commerce towards the processing threshold. As another example, some
electricity generating facilities may send ash off-site for vanadium recycling. Facilities must apply
the amounts of EPCRA Section 313 chemicals in the ash toward the processing threshold.

       Table 3-14 describes the subsections of processing for reporting purposes.
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                                      Table 3-14
                Definitions and Examples of Processed Chemicals
[5JB86S8V.,
As a reactant
As a formulation component
As an article component
Repackaging for distribution into
commerce
^Bianiples - ' '",
":."** i "
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
Facilities may repackage fly ash resulting from combustion,
and distribute it into commerce for use in concrete
manufacturing.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.

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 3-15).
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                                      Table 3-15
             Definitions and Examples of Otherwise Used Chemicals
 As a chemical processing aid
                                                       • Examples
May not occur in the electricity generating industry.
 As a manufacturing aid
Metals used to maintain power lines within the facility.
 Ancillary or other use
Combustion of coal or oil containing EPCRA Section 313
chemicals above the de minimis level.
Metals used to maintain/replace process equipment.
Ammonia used in water treatment.
Ethylene glycol sprayed on coal to prevent freezing.
Thiourea used as an inhibitor in cleaning solution for
removal of scale deposits and metals from tube walls.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.

       Combustion. All EPCRA Section 313 chemicals contained in fuels combusted for energy
production are considered otherwise used.  However, this type of chemical use is eligible for the
de minimis exemption, and many of the EPCRA Section 313 chemicals contained in commonly
used fuels exist in below de minimis concentrations. As a result, 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 information indicating otherwise, 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. For example, No. 6 fuel oil may contain benzo(a)anthracene,
a member of the polycyclic aromatic compound chemical category, in concentrations above de
minimis levels. EPA has assembled information on EPCRA Section 313 chemicals in various fuel
types from a number of sources.  This information is provided in Table 3-4.  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.

       Other Activities. Otherwise use includes the use of EPCRA Section 313 chemicals in
activities  such as cleaning, maintenance, and water purification. The use of an EPCRA Section
313 chemical to treat another chemical constitutes otherwise use.

Other Examples of Chemicals that Electricity Generating Facilities "Otherwise-Use"

       •      Chemicals used to clean boilers, cooling towers, and other equipment;
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              Chemicals in materials that are used to maintain process equipment (e.g.,
              lubricants, solvents, condenser tubes);

              Chemicals used to treat boiler make-up water, or cooling tower water (e.g.,
              chlorine, chlorine dioxide, bromine);

              Chemicals used to prevent corrosion, (e.g., ammonia, hydroquinone, and
              hydrazine);

              Chemicals used to treat wastes, such as coagulants, or flocculants;

              Chemicals in fuel used in any on-site equipment (other than motor vehicles eligible
              for the motor vehicle maintenance exemption);

              Chemicals in ash (or other wastes) that is received from off-site and disposed on-
              site.
                           Example - Ash Received from Off-Site

 An electricity generating facility receives ash containing an EPCRA Section 313 chemical from other facilities
 (e.g., remote peaker units). The electricity generating facility disposes this ash and ash generated from its own
 operation, in its on-site landfill. The facility must consider the amount of the EPCRA Section 313 chemical in
 the ash received from off-site and disposed on-site as "otherwise used." However, ash generated on-site, and
 disposed of on-site is not considered "otherwise used." If the facility exceeds an activity threshold for the  ,
 EPCRA Section 313 chemical, it must report on the Form R all amounts disposed, regardless-of whether, the
 facility generated the ash on-site or received it from off-site; The EPGRA Section 313 chemicals in the ash are
 not eligible for the de minimis exemption                                                , >"
       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 quantities 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).
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                                          Table 3-16
             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 (c) 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 ง372.3 (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 chlorofluorocarbons), 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.	
 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 ง372.3.) "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 ง372.3), (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.)	
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  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
ง372.3.)
 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 ง372.3.)
 Disposal
Disposal means any underground injection, placement in landfills/surface
impoundments, land treatment, or other intentional land disposal. (See 40 CFR
ง372.3.)
(See EPA document, Interpretations of Waste Management Activities: Recycling, Combustion for Energy
Recovery, Waste Stabilization and Release for further detail.J

        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.
                                    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 5.5.4, Other
 Disposal?

 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 >yaste and any
 "otherwise use" of EPCRA Section 313 chemicals contained in the treated leachate is not eligible for the de
 minimis 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.                   „
                                               3-44

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           "'   ••' .-*•"    "   •" *"   Example-Timing - ~    -     „_--"<   -'" T
                  *               ^liiiimm itini	JF	'	'"	'"""   **     /    r~f  ^    ^

 ^facility receives waste containing a%lE(5RA Section SlAchemicai fromoff-site and disposes the waste
 6n-site. Should the fecffify count the EPCR%Section S13 chemicals in the waste towards the 'otherwise
 use' threshoid'upon receipt of the w^kshipment (e.g., signing the hazardous .waste manifest) or upon   ^
 actual disposal? ,,  ''   - >    -,-*-"  ,     --*'  '   "-     "  "V* ' ~ ~
             f**ซ-*'"t.f                    ~                  ~      ^ '  >.
 Thelacility must count me amount of the EPCRA Section 313, chemicS towards its otherwise'use threshold
 upon actual disposal of the waste. EPCRA Sectiptf-313 chemicals are applied toward the otoerwise use threshold
 upon the performance oMiose acfivMes, ^Ihe facility does not Otherwise use!', die EPCgA'Section 3JL3     s
 chemic4inihe waste received from off-site until the facility disposes the-waste.  ,_-,"	„-  " _ --   -3
3.2.1   Concentration Ranges for Threshold Determination

       You are required to use your best readily available information for estimating EPCRA
Section 313 threshold determinations and release and other waste managed calculations. In some
cases, the exact concentration of an EPCRA Section 313 chemical in a mixture, or other trade
name product or in a waste may not be known. In these cases, the waste profile, customer,
supplier, or MSDS may only provide ranges, or upper or lower bound concentrations.  EPA has
developed the following guidance on how to determine concentrations from this type of
information for use in threshold determinations:

       •      If exact concentration is provided, use it.

              If the concentration is provided as a lower and upper bound or as a range, you
              should use the mid-point in your calculations for the threshold determination.  For
              example, the waste profile states methanol is present in a concentration of not less
              than 20% and not more than 40%, or it may be stated as present at a concentration
              between 20 to 40%. You should use 30% methanol in your threshold calculations.

              If only the upper bound concentration is provided you must use this value in your
              threshold calculation.

              If only the lower bound concentration of the EPCRA Section 313 chemical is
               specified and the concentration of other components are given, subtract the other
               component values from 100%. The remainder should be considered the upper
               bound for the EPCRA Section 313 chemical and you should use the given lower
               bound to calculate the mid-point as discussed above. For example, the waste
               profile states that a solvent contains at least 50% MEK and 20% non-hazardous
               surfactants.  Subtracting the non-hazardous contents from  100% leaves 80% as the
               upper bound for MEK. The mid-point between upper (80%) and lower (50%)
               bounds is 65%, which is the value you should use in your threshold calculation.
                                           3-45

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        •      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
then- best readily available information, 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 that are below the detection limit, you may 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. 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.
                              Example - Average Concentration

 Is it appropriate for an electricity generating facility to develop an average concentration for an EPCRA
 Section 313 chemical contained in the different fuels used by the facility, 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 "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 the 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 avefage concentration
 levels, it should document why the raw data from which the averages are based are not readily available, howlt
 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 not have a
 recommended approach for determining average concentration levels.
                                            3-46

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3.2.2   Evaluation of Exemptions

       EPCRA Section 313 provides facilities with certain exemptions:

       •      Laboratory activities exemption;
       •      De minims exemption;
       •      Article exemption;
       •      Exemptions that apply to the otherwise use of chemicals: routine janitorial/facility
              grounds maintenance exemption; 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.

       These exemptions are described in detail below.

3.2.2.1         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

 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 covered facility is under the direct supervision of a technically qualified
 individual as provided in 40 CFR 372.38(d). The laboratory exemption applies to the "manufacture," "process,"
 ,or "otherwise use" of EPCRA Section 313 chemicals arid any associated release and other waste management
 "amounts that take place in a qualifying laboratory.,    •     , 	
 3.2.2.2
De 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
                                           3-47

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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, 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 1998 EPCRA Section 313 Questions and Answers 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
coincidentally manufactured in a product and remain in the product as an impurity which is then
subsequently distributed into 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 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 waste treatment or other
management activities, or to waste brought on site for waste management.  Electricity generating
facilities 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 (acid aerosols), hydrochloric acid (acid aerosols), hydrofluoric acid, and
certain metals  and metal compounds, as discussed earlier in this chapter.
                        Example -Ash Distributed into Commerce

 A covered facility combusts coal in a combustion unit The coal contains a EPCRA Section 313 chemical
 below de minimis amounts. During combustion, EPCRA Section 313 chemicals are manufactured. The
 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?

 The EPCRA Section 313 chemicals in the coal being combusted should be considered towards the facility'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 byproducts 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 for,
 the de minimis exemption.                                                                  - *
                                           3-48

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       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.
          De Minimis Exemption Applies

 A facility combusts coal and oil on-site to generate
 power for distribution into commerce. The cfe
 minimis exemption applies to the otherwise use
 threshold for the EPCRA Section 313 chemicals in
 the fuel that were otherwise used.
                      j a       ซ       ~"i /
 A facility otherwise uses EPCRA Section 313
 chemicals on-site to maintain and clean equipment,
 The de minimis exemption applies to threshold
 determinations and release and other waste/
 management activities for those chemicals
 otherwise used.    *     „_"'*'          "   ",

 A facility distributes ash (which meets-industry,
 specifications) containing  EPCRA Section 313
 chemicals into commerce for use in the
 manufacture of concrete.  This activity constitutes a
 processing activity, and the de minimis exemption
 applies to amounts of EPCRA Section 313
 chemicals in the ash distributed into commerce,
 and to releases and other waste management
 activities associated with this processing activity.
 De Minimis Exemption Does Not Apply      '  •
             /        t          ' '',    '-  *  '
A facility combusts coal and oil on-site to generate
 power for distribution into commerce. The die
 minimis exemption'does not apply to the
 manufacture of EPCRA Section 313 chemicals
 (e.g., sulfuric acid (acid aerosols), metal
 compounds, etc.) during combustion. If the facility
'exceeds a threshold, they must consider the amount
 of EPCRA Section 313 cKemical coinddentally
.manufactured toward the manufacturing threshold.
 They must also consider all releases and other
 waste management quantities that result from the
 manufacture of these compounds from combustion.
     ^          \ * / J ~
 A facility receives ash from off-site containing
 EPCRA Section 313 chemicals for, disposal.
 Because the facility receivesithe waste ash from off-
 site for purposes of further waste management, the
 de minimis exemption does not apply, and the*
 facility must consider the amount of the EPCRA
 Section 313 chemical towards its "otherwise use"
 threshold. If the facility exceeds the threshold, it
 must report the amount of EPCRA Section 313
 chemical disposed on-site, and any other releases
 and waste management activities on the Form R.

 EPCRA Section 313 chemicals in ash sent off-site
 for use as roadfiH, landfill, and in mining
 reclamation are being managed as a waste;
 therefore they are not eligible for the de minimis
 exemption. 	..	^	...
       Once the de minimis level has been met or exceeded, the exemption no longer applies to
that process stream, even if the concentration of the EPCRA Section 313 chemical in a mixture or
other trade name product later drops below the de minimis level. All releases and other waste
management activities are subject to reporting after the de minimis concentration has been
equaled or exceeded, provided an activity threshold has been exceeded.
                                             3-49

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                                   Example - De Minimis

 A facility receives a mixture with an EPCRA Section 313 chemical in a concentration below the de minimis
 concentration. During processing, the concentration of the EPCRA Section 313 chemical exceeds its de
 minimis level. This facility must consider amounts toward threshold determination and releases and other waste
 management activities that take place after the point in the process where the de minimis level is met or
 exceeded. The facility does not have to consider toward threshold determinations or release and other waste
 management estimates, activities that took place before the de minimis level was met or exceeded.
3.2.2.3       Article Exemption

       An article is defined as a manufactured item if each of the three criteria below applies:

       •      Is formed to a specific shape or design during manufacture;

       •      Has end-use functions dependent in whole or in part upon its shape or design; and

       •      Does not release an EPCRA Section 313 chemical under normal conditions of
              processing or otherwise use of the item at the facility.

       If you receive a manufactured item from another facility and process or otherwise use the
item without changing the shape or design, and your processing or otherwise use results in the
release of 0.5 pound or less of the EPCRA Section 313 chemical in a reporting year from all like
articles, then the EPCRA Section 313 chemical in that item is exempt from threshold
determinations and release and other waste management reporting.  The article exemption does
not apply to the manufacturing of items at your facility.

       The shape and design of a manufactured item can change somewhat during processing and
otherwise use activities as long as part of the item retains the original dimensions. That is, as a
result of processing or otherwise use, if an item retains its initial thickness or diameter, in whole
or in part, then it still meets the definition of article. If the item's basic dimensional characteristics
are totally altered during processing or otherwise use, the  item would not meet the definition,
even if there were no releases of an EPCRA 313 chemical from these manufactured items. As an
example, items that do not meet the definition would be items that are cold extruded, such as bar
stock that is formed into wire. However, stamping a manufactured item into pieces that are
recognizable as the original articles would not change the  exemption status as long as the
diameter and the thickness of the item remain unchanged.  For instance, metal wire may be bent
and sheet metal may be cut, punched, stamped, or pressed without losing the article status as long
as no change is made  in the diameter of the wire or tubing or the thickness of the sheet and, more
important, there are no releases of the EPCRA Section 313 chemical(s).

       Any processing or otherwise use of an article that results in a release above 0.5 pound per
year for each EPCRA Section 313 chemical for all like articles will negate the article  exemption.
                                           3-50

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Cutting, grinding, melting, or other processing of a manufactured item could result in a release of
an EPCRA Section 313 chemical during normal conditions of use and, therefore, could negate the
exemption as an article if the total release exceeds 0.5 pound in a year. However, if all of the
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 then: 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 1998 EPCRA Section 313 Questions and Answers
document presents several specific questions and answers/discussion pertaining to the article
exemption.

3.2.2.4        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 nor the associated release and other waste management calculations,
provided thresholds are met elsewhere. The following otherwise use activities are considered
exempt (see most current version of the TRI Forms and Instructions, and the 1998 EPCRA
Section 313 Questions and Answers document).

       •      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

               Amnionia used to clean ป, cafeteria grill is exempt from thresholdldetenninations 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.  ~~      ""'  „, .    •",   ,      ..  -"     _f	^	
                                          3-51

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EPCRA Section 313 chemicals in structural components of the facility. This
exemption applies to EPCRA Section 313 chemicals present in materials used to
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, and locomotives.  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 part of the
manufacturing threshold.
                    Example - Motor Vehicle Exemption

 A facility purchases ethylene glycol, and uses it qn-site to prevent coal from freezing.  The
 facility must include the amount of ethylene glycol used on the coal for threshold
 determinations and release and other waste management calculations. The facility also uses
 ethylene glycol in antifreeze and in windshield washer fluid in vehicles operated by the
 facility.  This amount is exempt under the motor vehicle exemption. The facility would not
 include the amount of ethylene glycol in the windshield washer fluid or anti-freeze when
 making its threshold determination or iin. its release and other waste management calculations;
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 on-site
 structural maintenance activities that are not integral to the process are exempt activities.
 However, lubricants used to maintain pumps and compressors, which aid in facility process-
 related operations, are not exempt and the amount of the chemical in that lubricant should be
 applied to the otherwise use threshold.
                             3-52

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               EPCRA Section 313 chemicals in certain air 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 considered for threshold determinations or
                releases or 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 in the system or the amounts reused.
                                 Example - Reuse Activities
                                                s                 ~ (     ?•>

 A facility operates a heat transfer unit that contains 15,000 pounds of ethylene glycol at the beginning;of the
 year that was in use in prior years.  The system is charged with 2-,000 pounds of ethylene'glycol during the
 reporting year. The facility has therefore "otherwise used" only 2,000 pounds of the covered EPCRA Section
 313 chemical within that particular reporting .year. A facility reporting for the first time would consider only
 the amount of EPCRA Section 313 chemical that is added during its first reporting year towards its "otherwise
 use" threshold for that year. If, however, the entire heat transfer unit was recharged with 15,000 pounds of
 ethylene glycol during the year, the facility would consider the 15,000 pounds toward its otherwise use threshold
 and, exceeding the otherwise use threshold; be required to jceport. \, **>
3.2.3.2
Remediation Activities
       EPCRA Section 313 chemicals undergoing remediation (e.g., Superfund) are not being
manufactured, processed, or otherwise used. Therefore, they are not included in the threshold
determinations.

       If you, however, are conducting remediation for an EPCRA Section 313 chemical that is
also being manufactured, processed, or otherwise used by the facility above an activity threshold
                                            3-53

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level, 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 activity threshold 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 activity, 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.
          POSSIBLE ERROR - What if Your FacOitv Has No Releases and Other
            Waste Management Quantities of EPCRA Section 313 Chemicals?

 If you meet all reporting criteria and exceed any threshold for an EPGRA Section 313 chemical, 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 Fuels

       Electricity generating facilities typically do not manufacture chemicals or products
intentionally. However, these facilities may coincidently manufacture Section 313 chemicals
during fuel combustion and, a certain degree, in 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 common to electricity generating facilities, fuel
combustion may result in the manufacture of metal compounds (usually as a result of oxidation),
or the conversion metal compounds to the parent metal (e.g., mercury compounds in coal convert
to elemental mercury). In addition, acid aerosols may be manufactured as a result of the
combustion of fuels The following discussion describes how to calculate the manufacturing
threshold for these situations.
                                           3-54

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       To calculate the amount of EPCRA Section 313 metal compounds manufactured during
combustion of fuels, you will need to determine the concentration of each metal present in the
waste being combusted. The best readily available information should be used to estimate the
approximate concentration of the metal(s) in the fuels used. From this information, you can
estimate amounts of metal or metal compounds and acid aerosols manufactured.  If you have data
regarding chemical concentrations in the fuels combusted (e.g., supplier information and/or
analytical data) and believe that is the best readily available information, then you should use this
information. If specific concentration data of the metals in the fuels do not exist, you can assume
that the metals will convert to the lowest weight metal oxide possible.  A more detailed
discussion can be found in Chapter 3.2 of this  document.    During combustion, other EPCRA
Section 313 chemicals could be manufactured, particularly acid aerosols. For instance, sulfuric
acid (acid aerosols) could be produced depending on a variety of factors such as sulfur content of
the fuels. 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 (acid
aerosols) manufactured during combustion; 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.

Calculating the Manufacturing Thresholds for Section 313 Chemicals in Wastes

       In electricity generating facilities, some waste management activities may result in the
manufacture of EPCRA Section 313 chemicals. For instance, wastewater activities may result in
the generation of EPCRA Section 313 chemicals. To estimate the amount of EPCRA  Section
313 chemicals manufactured during wastewater treatment, the Clean Water Act typically requires
facilities to monitor some EPCRA 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, wastewater permits may require monitoring for the nitrate ion, but
the nitrate compound category is calculated by the total weight of the nitrate compound in
aqueous solutions.

Calculating the Otherwise  Use and Processing Thresholds for Section 313 Chemicals in
Wastes

       To determine if a chemical exceeds the processing and/or otherwise use threshold, you
must calculate the annual activity usage of that chemical. For 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
or recovery process, 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, particularly in terms of classifying the types of otherwise
use activities the wastes may or may not have  undergone.
                                          3-55

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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 activity:
manufactured, processed, and otherwise used.  If more than one activity threshold applies, the
amount associated with each threshold is determined separately.

       Table 3-17 presents a worksheet that may be helpful when conducting your threshold
determinations and Table 3-18 illustrates an example of how the work sheet can be used for the
following example:
                              	Example - Threshold Worksheet

 Because your facility combusts coal to generate electricity for purposes of distribution into commerce, you are '
 required to consider the manufacture of EPCRA Section 313 chemicals as by-products'of combustion,  Using.the
 emission factor for hydrochloric acid (add aerosols), 1.9 pounds/tort for your coal'type, plus the amount of coal
 combusted (1.0 million tons) for the reporting year, you calculate the amount of hydrochloric acid (acid
 aerosols) produced to be 1.9 million pounds. Therefore, you would^have exceeded the 25,000 pound threshold
 for manufacture of hydrochloric acid (acid aerosols), and you would be required to submit a Form R. Because
 you manufactured more than one million pounds of the EPCRA Section 313 chemical, you cannot file a Form
 A.                          v                '                                -
                                            3-56

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  Chapter 4 - Estimating Releases and Other Waste Management Quantities
4.0
PURPOSE
       This chapter is intended to help you in developing a systematic approach for conducting
release and other waste management calculations specific to electricity generating facilities. 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 waste, by
particular waste management type (e.g., release to air, transfer off-site for waste management,
etc.).  To aid your facility in making these calculations, 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 with examples of methods and
tools to use in calculating estimates of releases and other waste management activities specific to
many electricity generating operations.
                                           4-1

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4-2

-------
4.1    General Steps for Determining Releases and Other Waste Management Activities

       You can develop release and other waste management estimates by completing these four
basic steps. See Figure 4-1 for illustration of this four-step process.
       Step 1)


       Step 2)

       Step 3)


       Step 4)
Identify potential sources of chemicals released or otherwise
managed as waste.

Prepare a process flow diagram.

Identify on-site releases, off-site transfers, and other on-site waste
management activity types.

Determine the most appropriate method(s) to develop the estimates
for releases and other waste management activity quantities and
calculate the estimates.
       These steps are described in detail in the following sections.

 4.1.1  Stepl:  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;
        •      Recycling and energy recovery byproducts;
        •      Accidental spills and releases;
        •      Storm water runoff;
        •      Clean up and housekeeping practices;
                                             4-3

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       •      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 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.
       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.
                                          4-4

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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.

       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.
                                    4-5

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I
               EPCRA Section 313
               Chemical In
                                       Point Sources
                                           A
               Fugitive Emissions
                     A
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-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
                                                         4-6

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             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 in evacuated areas 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.

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 EPCRA Section 313 chemicals 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.
                                    4-7

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       Any residual chemicals in "empty" containers transferred off-site would also be
       reported in 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 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 - On-Site Waste Treatment

A process at the facility generates a wastewater stream contalning'an EPCRA Section 313
chemical (chemical "AV A second process/gerierates a wastewater stream containing two
EPCRA Section's 13 Chemicals, "a metal (chemical B) and a-mineral acid (chemical C).    s
Thresholds^for all three EPCRA Sectidn 313 chemicals have beฃjfexceededxand you are in
4he process of completing separateTorm Rs for-each chemical?     ••
    "-     ?! N^\N    ™          ~~^  '          j$/  ~~        ^v           ''         ^
>41Lwastewater streams are combined*and sent to an on-site wastewater treatment system
before,beirig relea&f3 tcf a POTW. This system consists of an oil/water separator which
removes 99% of chemical.ฃ; a neutralization* tank where the pH is adjusted to 7?5; thereby
destroying JLOO% of the riujneraf acid (chemical C), and a sealing taik where 95% of the
metalf(chemical B) is removed from jhe wafer (and,eventually landfilled off site).
        -  *-  ff\   ซฃ'"   "•>•'"""     ,   ~   ~       "•*"      ""          - .-
Section 7A"shouId be completed slightly 'differently for each chemical for which a Form R
must be filed. The-table*accompahying this example'Shows'how Section 7A shojild be
completed for each chemicaL'' Ftat^-jpn each FormR you^shoulgViideritify%e type of waste
stream in Section 7A.la as-w^astewater (aqueous,,waste,\code ^. Next,*on each Form R you
shouldblocks*of Section'7A.lb of all three Form
Rs shoMd/how: P19 (liquid phase-separation), Cll (neutralization), Pll
X|ettling/ciarification), and NA,(to signify the end of the treatment system). Note that
Section/?A.4b"is'thetonly section of the Form R that is not chemical specific.' It applies to
. the'entire waste stream being treated^K Section 7A. Ic of.each Form R sho'uld show the
cpncentration of tie specific chemical in the} influent to the first step\>f the process
        \   S                                           4*
 also chemical specific. It applies to the efficiency of the entire system in destroying and/or
 removing the chemicaffor the Form R you are currently completing. 99%, should be
"entereii whensfiiing'for cheniical"A, 95% for chemical B,'and 100% for chemical C.
 Finally, you shojuld report whether the influent concentration and efficiency estimates are
 based on operating data for each cBemical, as appropriate.
                               4-9

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Example - On-Site Waste Treatment (cont.)

7A.la
W


7A.lb
3. Pll
6.
Chemical A
1. P19 2. Cll
4. NA 5.
7. 8.


7A.la
W

7A.lb
3. Pll
6.
7A.lc J
> I , '

7A.ld
99 %


7A.le
Yes No
X

Chemical B
1. P19 2. Cll
4. NA 5.
7. 8.


7A.la
W

7A.lb
3. NA
6.
7A.lc
1

7A.ld
' 95 %

7A.le
Yes No
X

Chemical G
1. P19 2. Cll
4. 5.
7. 8.

- 7A.lc
1

7A.ld
100 %

7A.le
Yes No
X

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 CJf BPCRA 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 Form R 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 infection 6.2 and 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.
I.      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
                                   4-10

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             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
             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 bums 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  (c) a
       2The subsection 8.1 through 8.8 designation are those for the 1997 Form R. Please refer to the current
reporting year's TRI Forms and Instructions for any changes.

                                          4-11

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       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.

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 (c) 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.

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
                            4-12

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       (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:

       ง8.5 = ง6.2 (recycling)  - ง8.8 (off-site recycling)

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 7 A, 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 metaji  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
                             4-13

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       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:

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

       The quantity reported in Section 8.8 should not be included with quantities
       reported in Part n, 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 II, 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
                             4-14

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                     management information from the prior reporting year. Because 1998 is
                     the first year that Electricity generating 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.
                          P0SSIBLE ERROR - Double Counting  ,    %

               Releases and other waste management activities ^should not be'inadvertently
               "double counted." - A single wastewater discharge sfioulcJ not beJisted as{
               both a release to water (on site) and a discharge4o POTW (off site).
               Similarly," a release to land sjiould not be listed as both a release to land~(on
               site) and a transfer to an ofPsite landfill: Estimates of releases and other
               waste management activities should be prepared for Sections "5 through-? of
               the Form R.  For the-mostpart, Section 8 relies on~the data collected to-
               complete these previous sections.. Therefore, Section 8 should* be completed
               last. "However; the data elements"of Section 8 (8.1 through "8/7) are mutually
               exclusive and care should tbe taken to avoid 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 information or
                                           4-15

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prepare reasonable estimates. For example, emission factors or engineering calculations may not
be the best readily available information 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 4-1 presents potential data sources and the estimation methodology in which they
are most likely to be used.

                                        Table 4-1
        Potential Data Sources for Release and Other Waste Management
                                       Calculations
                                     DATASOURCES
 Monitoring Data
Mass Balance (C)
        Stack monitoring data
        Outfall monitoring data
        Air permits
        Industrial hygiene monitoring data
        NPDES permits
        POTW pretreatment standards
        Effluent limitations
        RCRA permit
        Hazardous waste analysis
        pH for acids
        Continuous emission monitoring
       Supply records
       Hazardous material inventory
       Air emissions inventory
       Pollution prevention reports
       Hazardous waste manifests
       Spill event records
 Emission Factors (E)
        AP-42 or other EPA emission factors
        Published facility or trade association
        chemical-specific emission factors
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)
       Process knowledge	
       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.
                                           4-16

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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.
                                Example - Monitoring Data,
                       J         •-"          "      ^/                          /      /•     ~~
   x                            /               '"•'            /              ~      !">j!
 Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in
 the POTW discharge is 2 mg/L, 'The wastewater_treatraent facility processed 1,5 million gallons 6fs water in
 1997.  The treated wastewater is discharged to an off-site"POTW. The amount of copper transferred off site to
 me'PO^TWCforPartll.S^ectione.lofmeFbrm'^iSsestiraatedasfollQws:*         ,'   .
                                          j-      N    ^           /   * i   ~            ^
 Amount of copper transferred     ;       -                    x. -

            /   1 a   ^  (  i ;h  ^  ("  *1 r    ^'            -   -ป-.     ',  '!"
 .(a^/ijtf-it-lJ-l*.

 = 25lbs/yr
                       POSSIBLE ERROR - Treatment Efficiencies

 Vendor data on treatment efficiencies often represent ideal operating conditions. Thus, you should adjust such
 data to account for downtime.and process upsets during the actual reporting year- that would result in lower  „
 efficiencies. Remember that efficiencies reported by vendors are often general and may not apply to specific -
 chemicals or uses of the;equipment. For example^m incinerator or flare may be 99.99% efficient in  *
 combusting organic chemicals, but will have 'a zero percent efficiency in combusting metals.
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:
                            Input + Generation = Output + Consumption
                                            4-17

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r
              where:
                            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.

                            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

               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 1,200 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:

               Fugitive air releases of the EPCRA Section 313 chemical

                      = Amount input (Ibs/yr) - Amount released to wastewater (Ibs/yr)

                      = 20,000 Ibs/yr-1,200 Ibs/yr

                      = 18,800 Ibs/yr                                        '    ^          '-',''
                                                          4-18

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        *   TPOSSIBL^ ERROR^Mass Balances for OtherwiseOsedCheintcals '_*"   ;.-.

•'If you are performing inasง.-Balance toestiiriate4hฃ quantity for a particular data elemept, make sure you include
 all inputs and outputs asj^recisely^as possible,1 It, fot example^ you identify all inputs prppejrlyrbaVyoit fail .to*-''
 include all outputs, your estimate ซould beTtaaccii'ateJy inflatedrFiir^ermore, if aB-ihput^and outpjats .are0    ;
 identified, but are not p^ejsise;tthe_estiflpe ofithe release iri'questiott could'also be4naccurate. "'    ._   =.'-/ /t
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.
                                            4-19

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                                 Example - Emission Factors

  Emission factors have been developed for air releases of fuel constituents and combustion products from boiler
  operations.  AP-42 lists a range of formaldehyde emission factors when No. 6 fuel oil is consumed:

         0.024 to 0.061 Ibs formaldehyde generated/103 gallons No. 6 fuel oil fired.   r                 ,-.

  A facility operating a boiler using No. 6 fuel oil could use the above emission factor to determine the'amount of
  formaldehyde generated and subsequently released to the air. If 1,000,000 gallons of No. 6 fuel oil is used
  during a reporting year, the amount of formaldehyde generated would be between*
                                             • •                           a     *
         (0.024 lbs/103 gal) x (1,000,000 gallons) and (0.061 lbs/103 gal) x (1,000,000 gallons) = 24'and 61 Ibs
         of formaldehyde                                                              • iS

  The mid-point of these two values, 42.5 pounds, should be use in developing release estimates assuming that a
  threshold has been exceeded for formaldehyde.                                                  , „

  NOTE: In addition to combustion by-products, there are other EPCRA Section 313 chemicals in No. 6 fuel oil
  that should be considered for EPCRA Section 313 reporting.                -
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
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 operations 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.
                                             4-20

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                             Example - Engineering Calculations

 Stack monitoring data are available for xylene but you Kave exceeded a threshold for 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 oftoluene by adjusting the monitoringNdata.x>f 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  j
 approximately 125ฐC. Based on literature data, the vapor pressures at 125ฐC 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:       ~    '  ',
        X Ibs/vr toluene =
        " 200 Ibs/yr xylene

        X Ibs/yr toluene =
                1.44 arm (vapor pressure of toluene)
                0.93 'atm (vapor pressure of xylene)

                (200 Ibs/vr xylene) x (1.44-atm toluene)
                   '  -'' (0.93 atm xylene)
 Completing the calculation, the facility determines ttiat 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 II, Section 5.1), then estimate all stack air releases for a Section
313 chemical (Part II, Section 5.2), etc.).  Table 4-2 presents a work sheet that may be helpful in
compiling this information.

       If you submit a Form R, you must also enter on-site waste treatment information in
Section 7A, including the code for each treatment method used,  the treatment efficiency for the
chemical in the treated waste stream, and the concentration of the chemical in the influent sent to
treatment.  You should report treatment methods that do not actually destroy or remove the
chemical by entering "0" for removal efficiency. Similarly, on-site energy recovery methods and
on-site recycling methods must be reported in Section 7B and 7C, respectively.
                                              4-21

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               Table 4-2  Release and Other Waste Management
                         Quantity Estimation Worksheet
Facility Name:
Toxic Chemical or Chemical Category:
CAS Number:
Reporting Year:
Date Worksheet Prepared:
Prepared by:
ON-SITE , :
Release or Other Waste Management
Activity Type
Amount Qbs)
Basis of
Estimate
Form R Element
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses (spills, surface
impoundments)
Total =








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)
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =










5.2, (8.1 or 8.8)
5.2, (8.1 or 8.8)
5.2, (8.1 or 8.8)
5.2, (8. lor 8.8)
5.2, (8. lor 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-SITE LAND
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. lor 8.8)
5.5,(8. 1,8.6, or
8.8)
5.5,( 8.1 or 8.8)

5.5,(8.1 or 8.8)
8.2
8.4
8.6
                                       4-22

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OFF-SITE / ' . '/ i-s-'- • -- '-
Release or Other Waste
Management
Activity Type
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
, Amount (Ibs) *
Basis of
Estimate
Form R Data
Element

















OTHER AMOUNTS SENT OFF-SITE
Amounts sent for storage
Amounts sent for unknown
waste management practice




6.2, (8. lor 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, (8.1 or 8.8)

6.2, (8.1 or 8.8)
6.2, (8. lor 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
Broker












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-SiteJUJcation
(name)



















OFF-SITE ENERGY RECOVERY
Off-site Energy Recovery
Transfer to Energy Recovery
Broker
OFF-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Transfer to Recycling Waste
Broker
















6.2, (8.3 or 8.8)
6.2, (8.3 or 8.8)

6.2, (8.5 or 8.8)
6.2, (8.5 or 8.8)
6.2, (8.5 or 8.8)
6.2, (8.5 or 8.8)
6.2, (8.5 or 8.8)








4-23

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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, in treatment units, and in shipping containers.  This calculation includes 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 2,000 pounds of an EPCRA Section 313 chemical in a
mixture used for water treatment. This is the first shipment received during the reporting year.
Your facility uses all but 500 pounds of the chemical. In July, your facility receives another
shipment containing 2,500 pounds of the same chemical, and you do not receive any other
amounts of the chemical during the reporting year.  Provided this is your only use of the EPCRA
Section 313 chemical, your maximum amount on-site is 3,000 pounds (range code 03).
                    Example - Maximum Amount On-Site for Landfills

 How do facilities that operate landfills report 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.

 No. Facilities 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 n, of the Form R during the reporting year that they
 are disposed.                                                              '
4.1.5.2
Production Ratio or Activity Index (Part II, 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, Electricity
generating facilities may only enter "NA" in 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.

       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 applies.  Typically,
                                          4-24

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production ratio would apply to EPCRA Section 313 chemicals manufactured and processed by a
facility, 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 EPCRA Section 313 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 of the amount of the cleaning solvent used
between the prior and current reporting years may seem logical but may not take into
consideration potential source reduction activities such as product reformulation.  As a result, an
activity index may be more appropriate, such as the number of tank washouts conducted, which
would be more accurate in reflecting the potential source reduction activities that could be
implemented for that chemical and/or activity.
                                Example.- Production Ratio  . ^  ,

 A facility uses coal as its fuel for its electricity generating combustion units and exceedslhe manufacturing
 threshold for several EPCRA Section 313 metal compounds. The facility produces 100-megawatt-hours of
 electricity in the previous year. For the' current reporting year, the facility produces 120,megawatt-hours of
 electricity.  As a result, the production ratio for these EPCRA Section 313 metals would be calculated by
 dividing megawatt-hours produced from this year by megawatt-hours produced from last year.  *

                          - 120 megawatt - hours (current reporting year)
                          '100 megawatt"-hours (previous repoiting.year)

                                    = 1.20 Production Ratio  r   -
4.1.5.3
Source Reduction (Part II, 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 facility must choose from to describe these source reduction activities.
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.
                                           4-25

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4.2    Calculating Release and Other Waste Management Estimates at Electricity
       Generating Facilities

       This section discusses the most common releases and other waste management activities at
electricity generating 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 activities of any EPCRA
Section 313 chemicals that exceed activity thresholds at the facility, including those associated
with the combustion of fuels other than coal or oil (e.g., natural gas). While this  chapter is
designed primarily for electricity generating facilities that combust oil and/or coal for the purpose
of generating power for distribution in commerce, the release and other waste management
reporting issues may be relevant to all potentially reporting facilities.  In particular, facilities that
combust fuels, including coal or oil, will find the estimation techniques discussed in this chapter
(e.g., methods of calculating discharges to water) useful.

       As mentioned earlier in Chapter 4, process flow diagrams are a very useful way for
facih'ties to identify all sources of releases and other waste management activities. Figure 4-3
illustrates common  operations and releases and other waste management outputs at electricity
generating facilities. While differing in some important respects, most conventional electricity
generating facilities rely on the same basic mechanism. Fuel is ignited and burned within a boiler
chamber composed of thousands of feet of water-filled tubes.  The heat of combustion heats the
water in the boiler tubes, creating high temperature and high pressure steam The steam passes
through turbines causing the turbine blades to rotate and a shaft connected to the turbine blades
drives electric generators, yielding electric power.  In this fashion, the chemical energy of the
fossil fuel is converted to heat energy through combustion, then to mechanical energy in the
turbines, and finally to electrical energy in the generators. Transmission lines, substations, and
switching stations channel generated electricity to various customers. While Figure 4-3 is not
meant to represent all electricity generating facilities, it can be used as a starting point for creating
a facility-specific process flow diagram.
                                           4-26

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Oxidation Stage
i

   Chemicals
     Added
Flue Gas Desulfurization
-ปFGD Sludge
                           Fly Ash
                           Collection
                        -> Fly Ash
                                       Flue Gas
                                Boiler
                          *•"*ป
      Coal Run-off
       Oil Filtrate
                   Bottom Ash
                   Boiler Slag
                             Waste
                                   Boiler
                                 Slowdown


Water
Treatment
1


Demineralizer
i

                                                  Steam
                        Condensate
                                           Turbine
                                          Generator
                                                                 Condenser
                                                               Cooling Tower
              Waste
     Waste  Chemicals
             Added
        Waste Cooling Water
                 Slowdown
Figure 4-3  Process Flow Diagram at Electricity Generating Facilities
                                -> Electricity
                                                                 Chemicals
                                                                   Added
                                                                 Chemicals
                                                                  Added
                                                4-27

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4.2.1  Fugitive Air Emissions, Section 5.1 of Form R.

       Fugitive air emissions can occur from a number of sources. The primary fugitive emissions
sources for EPCRA Section 313 chemicals at electricity generating facilities are likely to be:

       •      Storage and handling of the fuels containing EPCRA Section 313 chemicals above
              de minimis levels;
       •      Handling and storage of ash containing EPCRA Section 313 metal compounds
              manufactured as by-products of fuel combustion; and
       •      Wastewater treatment and other sources, including cleaning operations and spills,
              containing EPCRA Section 313 chemicals
       Fuel. Fugitive emissions may occur
during storage and handling of fuels including
coal and oil.  Concentrations of EPCRA
Section 313 chemicals in these fuels will
greatly affect the need to determine if fugitive
emissions will have to be calculated for
handling activities during use of fuels. For
coal, the EPCRA Section 313 chemicals are
likely to be present in concentrations below
de minimis levels. During the otherwise use
of coal, EPCRA Section 313 chemicals below
de minimis levels do not have to be
considered toward threshold determinations
and release or other waste management
calculations.  (Note that any coincidental
manufacturing that occurs during combustion
must be considered because the de minimis
exemption does not apply to the manufacture
of a byproduct (see below)). Fuel oils may
have EPCRA Section 313 chemicals above
de minimis levels, and facilities should
consider fugitive emissions resulting from the
handling and storage of fuel oils, particularly
lighter oils. EPA's Protocol For Equipment
Leak Emission Estimates (EPA-453/R-95-017) presents a comprehensive discussion of how to
estimate equipment leaks, such as those from valves, seals, and connectors in fuel handling
equipment. This document is available at http://www.epa.gov/ttnchiel/fyi.html.  Four approaches
for estimating equipment leak emissions, in order of increasing refinement, are presented:

       •      Average emission factor approach;
       •      Screening ranges approach;
       •      EPA correlation approach; and
   Fugitive Emissions and the De minimis
                Exemption

EPCRA Section 313 chemicals in fuel, along with
other mixtures or other trade name products, that are
processed or otherwise used are eligible for the de
minimis exemption.

Fugitive emissions of EPCRA Section 313 chemicals
below de minimis levels in ash being prepared for
distribution into commerce for direct reuse (i.e.,
processed) are exempt from threshold determinations
and release or other waste management calculations.

EPCRA Section 313 chemicals manufactured during
combustion that are subsequently managed in ash as a
waste (e.g., disposal) are not eligible for the de minimis
exemption. Facilities must consider fugitive emissions
of these chemicals, that occur during transportation,
handling, disposal, or other activities associated with
ash, regardless of concentration because the de minimis
exemption generally does not apply to the manufacture
of EPCRA Section 313 chemicals.
                                           4-28

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       •      Unit-specific correlation approach.

       In general, the more refined approaches require more data and provide more accurate
emission estimates for a process unit.  Also, it is important to recognize in calculating estimates
for these sources, you may have already calculated these estimates as a result of separate
requirements under the Clean Air Act, particularly the Title V requirements.

       In the average emission factor approach and the screening ranges approach, emission
factors are combined with equipment counts to estimate emissions.  EPA has also developed
emission factors for the synthetic organic chemical manufacturing industry (SOCMI), refineries,
oil and gas production units, and petroleum marketing terminals. The SOCMI emission factors are
presented in Table 4-3. These average factors must be multiplied by the number of pieces of
equipment being considered and the length of time each piece of equipment is in service.  The
average emission factors vary depending on the service category (e.g., gas, light liquid, or heavy
liquid), and the total organic compound (TOC) concentration of the stream. To estimate
emissions with the EPA correlation approach,  measured concentrations (screening values) for all
equipment are individually entered into general correlations developed by the EPA. In the unit-
specific correlation approach, screening and leak rate data are measured for a select set of
individual equipment components and used to  develop unit-specific correlations. Screening values
for all components are then entered into these unit-specific correlations to estimate emissions.

                                        Table 4-3
                      SOCMI AVERAGE EMISSION FACTORS*
? A
Equipment type
Valves
Pump seals6
Compressor seals
Pressure relief valves
Connectors
Open-ended lines
Sampling connections
Service
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
All
All
All
Emission factors3 (Ibs/hr/source)
0.0132
0.00888
0.00051
0.0439
0.0190
0.503
0.229
0.00403
0.0037
0.0331
^Protocol for Equipment Leak Emission Estimates (EPA, EPA-453/R-95-017)
a These factors are for total organic compound emissions
b The light liquid pump seal factor can be used to estimate the leak rate from agitator seals

       The general equation for estimating TOC mass emissions from an equipment leak using
                                         4-29

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average emission factors is:
where:
                                        = FA*WFTOC*N
              =   emission range of TOC from all equipment in the stream of a given equipment
                     type (Ib/hr)
       FA     =   average emission factor for the equipment type (Ib/hr/source)
       WFTOC =   average weight fraction of TOC in the stream
       N     =   number of pieces of equipment

And the equation for determining the emissions of a specific VOC in a mixture or other trade
name product from equipment is:
where:
                          Eroc*(WP)/WPTOC)
       WP   =
   The mass emissions of organic chemical "x" (Ib/hr)
   The TOC mass emissions from the equipment (Ib/hr)
   The concentration of organic chemical "x" in the equipment in weight percent
=  The TOC concentration in the equipment in weight percent.
                        Calculation of Equipment Leak Emissions

   At an electricity generating facility, aviation gasoline passes through a system containing 100
   connectors from storage to the combustion unit. The aviation gasoline contains 85 weight percent
   TOC. The aviation gasoline is in contact with the connectors in the system for 8,000 hours during the
   year. The weight percent of toluene in the waste is 5.6% based on the facility's data. The emissions pf
   TOC would be calculated as:
                    c * N * (Number of hours in contact during the year)
                 = (0.00403 Ib/hr/connector) (0.85) (100) (8000 hrs/year)
                 = 2,740 Ib/year of TOC from connectors
   The emissions of toluene from the connectors would be calculated as:

   E*     =Eroc*(WPxAVPTOC)
                 = 2,740 Ib/year * (0.056/0.85)
                 = 181 Ib/year of toluene from connectors
This average emission factor approach is presented as an option for facilities with no data
concerning equipment leaks. As with all estimates derived for compliance with EPCRA Section
313, it is the facility's responsibility to choose the best method for estimating releases from
equipment leaks.
                                            4-30
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       Ash.  Facilities may generate fugitive emissions during management of dry ash or dry FGD
waste. The fly ash handling operations in most electricity generating facilities consist of pneumatic
systems or enclosed and hooded systems, which are vented through control devices. Therefore,
the fugitive particulate matter emissions from these systems are anticipated to be minimal.  You
should review readily available data at your facility to identify what fugitive emissions may occur
and to what extent those emissions can be quantified. For example, you may have permit
requirements in regards to particulate matter emissions and, as part of these permits, may have
facility-specific or other emission factors for particulate matter released during ash management.
Estimates for fugitive emissions may be derived by combining these data with data on the
measured or default concentrations of metal concentrations in ash, along with annual throughput
data.  In particular, it may be useful to review your permit applications, which may contain more
detailed analyses of the potential for fugitive air emissions related to ash management activities
and, in some cases, may contain actual monitoring data or facility-derived emission factors.
Facilities that do not have such data may use other sources, including engineering judgement to
estimate fugitive emissions.

       Wastewater Treatment.  Fugitive air emissions of volatile EPCRA Section 313
chemicals from wastewater treatment units
could be estimated using one of several
programs, such as CHEMDAT8 and
WATERS. Volatile chemicals can
evaporate from solid waste and non-volatile
chemicals can be released to the air via
particulate emissions (e.g., ash). One tool
that can be used to estimate emissions in
these situations is CHEMDAT8 (See box.)
Other programs  are available commercially.
                 WATERS  \    ' '   .'

A computer program, WATERS,-is available for
.estimating the fate of organic compounds in variotis
wastewater treatment units, including collection.
systems, aerated basins, and other units. WATERS is
written to run under DOS without the need to purchase
other programs. WATERS contains useful features
such-as the ability to link treatment-units to form a
"treatment system, the ability for recycle.among units,
ancrthe ability-to generate (and save site-sgecific
compound^properties. _TheWATERS program and users
manual can be downloaded from the world wide web at
http://www.epa.gov/tfii/cliief/software.htmlfwater8.
       Transfer and treatment operations
will result in fugitive air emissions, but
waste previously disposed of in landfills or
surface impoundments will also generate
emissions. These emissions need to be
considered in your release calculations as
well. These emissions will be dependent on the types and quantities of wastes placed in the landfill
or surface impoundments as well as the design and operating practices of the landfill.
                                            4-31

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                                         CHEMDAT8

 Analytical models have been developed to estimate emissions of organic compounds via various pathways from
 wastewater and waste management units. Some of these models have been assembled into a spreadsheet called
 CHEMDAT8 for use on a PC. A user's guide for CHEMDAT8 is also available: Area emission sources for
 which models are included in the spreadsheet are as follows: nonaerated impoundnients, which4nelude surface
 impoundments and open top wastewater treatment tanks; aerated impoundments, which include aerated surface
 impoundments and aerated WWT tanks; disposal impoundments, which include nonaerated disposal
 impoundments; land treatment; and landfills. These models can be used to estimate the magnitude of site air
 emissions for regulatory purposes.  The CHEMDAT8 program and manual can be downloaded from the world
 wide web at http://www.epa.gov/ttn/cMefiteoftware.htaltfwater8.
        Other Sources - Equipment. Storage. Spills. Leaks. Cleaning, etc.  Fugitive air
releases of EPCRA Section 313 chemicals can occur from equipment in use, leaks in valves and
fittings, losses during cylinder changeovers, and periodic process-related cleaning operations. For
small quantities of EPCRA Section 313 chemicals otherwise used, engineering judgment can be
used to estimate fugitive releases (e.g., based on the volume of the connecting hose and the
number of changeovers). If significant quantities of chemicals are handled, fugitive releases can
be estimated using the emission factors discussed previously in regards to the use of fuels.
                           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 313 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.
                                             4-32

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4.2.2  Stack or Point Source Air Emissions, Section 5.2 of Form R.

       Stack emissions of EPCRA Section 313 chemicals can occur from the combustion stack,
storage tanks, and plant maintenance activities. Each is discussed below.

       Stack Emissions from Combustion. Amounts of EPCRA Section 313 chemicals not
captured in particulate control devices or in 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
compounds in ash (e.g., barium 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, oil, 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 which should form the
basis of estimating amounts ultimately released as stack air emissions or otherwise managed as
wastes.

       Releases of EPCRA Section 313 chemicals to the stack air emission sources 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 source would be facility-specific monitoring data if enough data were
available to sufficiently characterize the
emissions on a 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
Electrical Power Research Institute's
(EPRI) PISCES database, provide
emission factors and models to calculate
air emissions,  including stack emissions.
         Use of AP 42 Emission Factors

; The general equation for emission estimation is:  '
    '-   E=sAxxEFx(l-ER/lGO)  -.  '-'     "  ___ ";_ .
 where:, - -  -*-   -"""-   /^X"  ~-N  ;"- ,'   !""  ~ _ :
   ^  '•" E, "ar emissions,  ,- -     _"
 _ _„   'A:—activity rate;,-" '  J,Y      ~' ," '~"**"~~
        EF ซ emission factor, and -     "- "  *
        Eiy= overall emission Deduction, . ,,/,.ป'
 *  v'  ^efficiency,  %*. C "','. -''_'   *-"  .  Y-...
 *  -             *•  ซ*'  ^   r  ^A. i

 Eg. is further defined as the product of the control device
 destruction or remoyjil efficiency and the capture    N"l
 efficiency of the control system. .When estimating      -> ป-  --7 "'  "  v     - v -'  "  *    ' V   -s  \,
        <    ^   ^    	* "	i	"v ^  1*4  * N ^
       When other data are not available,
EPA has emission factors which can be
applied in calculating stack air 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 and oil. Table 4-4 presents AP-42 emission
factors for metals released during combustion of coal and fuel oil No. 6. These factors are based
on a limited number of samples and may not reflect more accurate information available to the
facility for the particular type of coal combusted and pollution control devices used. Table 4-5
                                            4-33

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 presents emissions factors for various organic compounds during controlled coal combustion.
 Tables 4-6 and 4-7 show emission factors of metals and organic compounds (respectively)
 released during combustion of natural gas. These tables are specific to certain conditions

                                    Table 4-4
                  EPCRA Section 313 Metal Emission Factors
                      for Combustion of Coal and Fuel Oil No. 6
CONTROLLED COAL COMBUSTION3
EPCRA
Section 3 13
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.
NO.%FUEL OIL COMBUSTION'
Average
Emission
Factor" (lb/103
Gal)
5.25E-03
1.32E-03
2.57E-03
2.78E-05
3.98E-04
8.45E-04
2.48E-04
6.02E-03
1.76E-03
1.51E-03
3.00E-03
1.13E-04
8.45E-02
6.83E-04
Emission Factor
Rating
E
C
D
C
C
C
C
D
C
C
C
C
C
D
"Emission factor should be applied to coal feed, as fired.
To convert from Ib/ton to kg/Mg, multiply by 0.5.
T)ata are for residual oil fired boilers, Source
Classification Codes (SCCs) 1-01-004-01/04.
"To convert from lb/103 gal to kg/103 L, multiply by 0.12.
*N/A - data not available for this metal
                                       4-34

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                     Table 4-5
Emission Factors for Organic EPCRA Section 313 Chemicals
            from Controlled Coal Combustion
Pollutant6
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
Emission Factor0 flb/ton).
5.7E-04
1.5E-05
2.9E-04
1.3E-03
7.0E-04
3.9E-05
1.3E-04
7.0E-06
2.2E-05
5.9E-05
5.3E-06
2.8E-07
4.8E-05
9.4E-05
2.4E-04
6.7E-05
3.9E-04
1.7E-04
2.0E-05
2.9E-04
1.6E-05
3.8E-04
4.3E-05
2.4E-04
2.0E-05
2.5E-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
                         4-35

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Pollutant13
Xylenes
Vinyl acetate
Emission Factor0 (Ib/ton)
3.7E-05
7.6E-06
Emission
c
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 dryers 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 combustors, circulating bed, 1-01-002-18/38,1-02-002-18, and 1-03-002-18.
 'Pollutants sampled for but not detected in any sampling run include: Carbon tetrachloride- 2 sites; 1,3-Dichloropropylene- 2 sites-
 N-nitrosodimethylamine- 2 sites; Ethylidene dichloride- 2 sites; Hexachlorobutadiene-1 site; Hexachloroethane-1 site; Propylene dichloride- 2 sites;
 1,1 AZ-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.
                                                      Table 4-6
                        Emission Factors for EPCRA Section 313 Metals
                                      from Natural Gas Combustion •
EPCRA Section 313 Metal
Arsenic
Barium
Chromium
Cobalt
Copper
Lead
Manganese
Nickel
Vanadium
Average Emission Factor b (Ib/million ft J )
2.30E-04
2.40E-03
1.10E-03
1.20E-04
2.51E-04
2.71E-04
3.81E-04
3.61E-03
3.21E-03
Source Classification Codes 1-01-006-04.
v Based on data from one source test To convert from Ib/million ft3 to kg/million m3 .multiply by 16.0.
Emission Factor Rating: E
                                                          4-36

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                                           Table 4-7
                Emission Factors for Speciated Organic Compounds
                             from  Natural Gas Combustiona
, Organic Compound ;
Formaldehyde
Naphthalene
Phenanthrene
Toluene
Average Emission Factor (Ib/million ft ')
1.55E-01 "
2.40E-04 c
l.OOE-05 '
2.20E-03C
* Data are based on boilers that were both controlled and uncontrolled for criteria pollutant emissions.
Source Classification Codes 1-01-006-01,1-01-006-04. To convert from Ib/million ft3 to
kg/million m3, multiply by 16.0.
"References 31-36.
" Reference 32. Based on data from one source test.
Emission Factor Rating is E for all chemicals except formaldehyde, which is C.

(e.g., coal classification, boiler configuration).  AP-42 emission factors for other chemicals and
fuels are also available. For example, there are AP-42 emission factors for organic compounds
released from the combustion of residual oils (which include No. 6 fuel oil) and distillate fuels
(which include No.2 fuel oil), and for various chemicals released during the combustion of
liquefied petroleum gas, wood waste,  and waste. AP-42 can be found at
http://www.epa.gov/ttn/chief/ap42etc.html.
Combustion of coal may also result in
emissions of sulfuric acid (acid aerosols),
hydrochloric acid (acid aerosols), 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.

        Storage Tanks. Electricity generating
facilities should consider point source air
emissions from tanks that store materials
  AP-42: Emission Factor Quality Ratings
         Used in Tables 4-4 and 4-5
 A Excellent. ^Factor is developed from A-1
 source test data taken from many^randomly chosen
 facilities'ifithe industry,population. 'The'sourcfecategory
 population is sufficiently Specific to mnu'mize variability.
 B Above average. Factor iง developed-from A- or B-rated
 testjatafrom a "reasonable'number" of facifities.
 Although no specific bias is evident; it is not clear if the
 facilities testexTrepresent a random sample of the industry.
 As with an^A rating, the source category population %
 sufficiently specific to minimize variability.    . ^1 "1  -
 C -Average. Factor is developed from Aj^B-, and/or
 C-ratecttest data from a "reasonable number"_6f facilities.
 -Although no specific,bMS is evident, itjs not clear if the
^facilities tested represeitt a random sample.of the indusrryr-"
 Aslvrith the A rating, the spurce'category populatioiTif
 sufficieritly specific to minimize variabih%.
 J> Below average. Factor is developed from A?, B- and/or
, C-rated test data" from a small number of facilities, and^ •
 therelmay be reason, to^suspect that these facilities do not
 represent a random simple of thdindiistry. There also may,
 be evidence of variabili^vithin
-------
 containing volatile chemicals, such as Fuel oil No.2 and hydrazine. 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 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 then determine the
 emission rate of each constituent in the vapor.  In general, the emission rate for individual
 components can be estimated by multiplying the  weight fraction of the constituent in the vapor by
 the amount of total VOC loss. The weight fraction of the constituent in the vapor can be
 calculated using the mole fraction and the vapor pressure of the constituent (equations found in
 AP-42). The weight percent can also be obtained from the SPECIATE database. The
 SPECIATE data base contains organic compound and paniculate 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.html#speciate.
                                         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.
       Plant Maintenance. Facilities should not forget to consider stack or point source
emissions generated from periodic plant maintenance activities.  For example, facilities that
evaporate or incinerate boiler cleaning wastes should examine EPCRA Section 313 chemicals
generated from theses activities. Facilities can use air permit applications and associated materials
as well as process knowledge to estimate emissions from evaporation or incineration of boiler
wastes.
                                           4-38

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       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.
Facilities may discharge wastewater
resulting from various on-site
operations. The two main sources of
wastewater are ash transport water
and cooling water. Facilities may also
discharge miscellaneous plant
wastewater, water remaining after
FGD sludge dewatering, and
wastewater from periodic boiler and
equipment cleaning operations.
    Example Calculation of Yearly Wastewater
       .   i^-t-L-  :?  Discharge  ^   :--  ""-
~ fsJ-   ^S.       ~~         ฃ/     j     T:       •* "•*   *
A facility' has monitoring data qn discharges to water oฃ-xylene, a
EPCRA Section 3B,chemical/and'a1Form R report is .required.
In this example^ monitoring* data..on gjis" chemical are only^
available for two days iwthe^ear.  The daily quantities of poundl
of xylene^released for those two dates would then be divided byjhe
number of samplei;dates to determinerthe daily aye/agf, for jh&
; whole reporflng'year, which would be used toNestimate the annual
discharge of xyfene in wastewater: - --     ,   <•'*•
Date .
^••i
3/1
9/8 '
Concentration
: (me/I)
' =* 1.0 - /
" , 0.2 -
Flow
(MGD)
1.0
-0.2 .-
Daily!
- Discharge
8.33 Ife.
" 0.332 Ibs.
 Annual •Calculation:
 (8.33'lbs. + 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 information in making these estimates as needed.
See 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 in 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
                                           4-39

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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
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).
                     Reminder: Reporting of Aqueous Ammonia ?

 Facilities may use ammonia or ammoniated cleaners during boiler cleaning, \N(1hea reporting releases and
 other waste management activities of ammonia, remember to report only 10 percent of the total amountrof
 ammonia if released or managed in aqueous form.
       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 collect under the piles forming runoff. In addition
to the chemicals applied to the coal pile such as ethylene glycol, 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 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 electricity generating 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.
                                          4-40

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4.2.4  Disposal to Land On-site, Section 5.5 of Form R.
       Facilities dispose of combustion wastes (e.g., ash), FGD wastes, and other wastes on site.
Accidental releases can also lead to EPCRA Section 313 chemicals being disposed to land on-site.
Each of these is discussed below.

       Combustion Wastes.  Some electricity generating facilities dispose of large amounts of
ash containing EPCRA Section 313 chemicals on-site. Most electricity generating facilities
dispose of ash at sites that are not contiguous or adjacent to the facility. Bottom or fly ash may
be disposed in landfills, surface impoundments, 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
is disposed on-site, regardless of concentration, provided that thresholds have been exceeded for
these chemicals. Ash disposed in a landfill or otherwise applied to the land is considered a waste
management activity and must be reported.

       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
data determined to be better, facilities can use default values for concentrations of metals in ash,
presented in Table 4-8.

        Table 4-8 Total Constituent Concentrations of Elements in Combustion Residuals
Element
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Fly Ash (ppm)
131
6,300
13,800
130
900
2,200
2,120
3,000
12
4,300
134
36
1,180
Bottom Ash (ppm)
10
168
9,360
10
5,820
932
1,082
1,940
4.2
2.939
14
9.9
537
Oil Ash (ppm)
1,072
10,000
1,000
11
4,390
130,000
100,000
1,170
1
180,000
500
10
460,000
                                          4-41

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Element
Zinc
Fly Ash (ppm)
3,500
Bottom Ash (ppm)
1,796
Oil Ash (ppm)
100,000
Source: Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume 1,
Critical Review, Battelle, Pacific Northwest Laboratory for EPRI, EA5176, August 1987.

       Flue Gas Desulfurization (FGD) Wastes. Wet FGD systems result in a waste slurry of
hydrated calcium sulfate and sulfite, and unreacted lime, which may be dewatered and/or
stabilized with fly ash and disposed in impoundments or landfills.  Dry FGD systems spray an
alkaline solution into the flue gas to react with the sulfur oxides. The water from the solution
evaporates into the flue gas, leaving a dry powder, which is collected by a particulate collector
such as a baghouse, and often disposed on-site. Metal compounds coincidentally manufactured in
FGD systems must be considered toward threshold determinations and release and other waste
management calculations, and are not subject to the de minimis exemption.

       Several data sources may be used to calculate the amount of EPCRA Section 313
chemicals in FGD wastes. These sources include waste analyses, NPDES permits, and waste
characterization performed to meet state or other solid waste management requirements.  The
best "readily available" data should be used to estimate concentrations of EPCRA Section 313
chemicals in FGD sludge solids and liquors. In the absence of facility specific data, the values
presented in Table 4-9  may be used to estimate concentrations of certain trace metals in FGD
sludge solids and liquors. Only the weight of the parent metal must be considered when reporting
releases and other waste management activities of EPCRA Section 313 metal compounds.

          Table 4-9. Concentrations of Certain Trace Metals in FGD Sludge Solids and
                                        Liquors
Trace Element
Arsenic
Boron
Cadmium
Chromium
Copper
Mercury
Lead
Selenium
Sludge Solids
(ppm)
52.0
530.0
25.0
180.0
340.0
6.0
290.0
600
Sludge Liquors (ppm)
0.1
76.0
0.1
0.3
0.5
0.1
0.5
19
       Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization
by Electric Utilities, p.7.
                                          4-42

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       Other Wastes.  Electricity generating facilities may also dispose of other wastes such as
filtration and coagulation residues, demineralization regenerant products, brine from reverse
osmosis, slurries from polishers, blowdown from boilers and recirculating cooling water systems,
cooling tower sludges, solids from oil filtration and settled materials from coal pile runoff. To
calculate quantities of EPCRA Section 313 chemicals that may be present in these wastes,
facilities can use waste analyses, process knowledge, operating records, pollution prevention data,
mass balance or other readily available information sources.
       Note that 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 a portion
of that waste discharges to a surface
water, the ultimate disposition of the
reportable EPCRA Section 313 chemical
during the reporting year must be
reported for the year 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.    	
     „- Example - Seepage Prom a Landfill

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  acearequired 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
doesjidt"conduct: any jurther ^activities involving amounts
previously disposed. Amounts which move within the*same
media, such as seepage from a landfill to^surrouhding 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.
        Accidental Releases to Land.  Leaks, spills, and drips from the loading and transfer of oil
 and other materials received at the facility should be considered and reported in your release
 estimates. Data concerning specific incidents (such as notification reports or incident logs) should
 be used to estimate releases. In calculating quantities related to accidental releases, you are
 required to report the ultimate disposition in the reporting year of the EPCRA Section 313
 chemical(s) 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 which 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, including liquid discharges, fraction of discharge flashed,
 vaporization, two-phase discharges, and gas discharges.
                                            4-43

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4.2.5  Transfers Off-site, Section 6.2 of Form R.

       Electricity generating facilities may send wastes off-site for waste management. Most
commonly, combustion wastes will be sent off-site for disposal.  For example, electricity
generating facilities may send EPCRA Section 313 chemicals in ash off-site for disposal in a
landfill. Facilities must report the quantities of EPCRA Section 313 chemicals in these wastes in
Sections 6.2 and 8 of Form R. These amounts are reportable whether they are sent to a facility
within the same company, or to a different company.  For example, if an electricity generating
facility sends ash to a landfill owned by the same company that is on non-contiguous, non-
adjacent property (i.e., a separate facility), then the electricity generating facility must report those
amounts as transferred off-site if the ultimate disposition in the reporting year is for disposal.

       EPCRA Section 313 chemicals in
ash sent off-site for use in mining
reclamation or to be used as aggregate in
road construction are also considered
off-site transfers of wastes for disposal.
These uses of ash are not considered
analogous to using a substitute material
with a commercial value. You must
report amounts of EPCRA Section 313
chemicals in ash sent off-site for mining
reclamation or for use  as road aggregate
on the Form R. Because these chemicals
are being managed as a waste by the off-site
Waste Management Codes for Metals

Metals and metal compounds in wastewater sent off-site for
treatment should be reported using code M62 - "Wastewater
Treatment (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". These codes are considered disposal
codes for EPCRA Section 313 reporting purposes.
location, the de minimis exemption does not apply.
       The same methods discussed previously for estimating quantities disposed on-site can be
used to estimate amounts sent off-site for disposal. Wastes sent off-site that are regulated under
RCRA Subtitle C will also have waste analyses and waste profiles.

       Electricity generating facilities may also distribute ash into commerce for use in the
construction industry, or for metals recovery.  When ash is distributed in commerce to be directly
used by an off-site entity, the amounts of EPCRA Section 313 chemicals distributed in commerce
are not reported on the Form R. For example, an electricity generating facility that sells ash to a
construction facility who incorporates the ash directly into the manufacture of cement, does not
report quantities of EPCRA Section 313 chemicals in that ash on the Form R.  However, EPCRA
Section 313 chemicals sent off-site in waste for recycling; for example, oil combustion ash sent
off-site for vanadium recovery will undergo a waste management activity and should be reported
on the Form R as a transfer off-site for recycling in Sections 6.2 and 8.5 of Form R. Facilities
may use metal analyses of ash along with the quantities of the ash sent off-site for disposal or
recycling to calculate the pounds of the metal transferred off-site.
                                           4-44

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                            Example - Storage of Ash on Land

 Is ash placed on-site in a landfill waiting to be sold during construction season considered a release to
 land for the reporting year.prior to its transfer?            r                      /,ป--'

 Material that is placed in a landfill on site during a reporting yearddes^not have to be reported as a release to
 land on-site if the landfill was only" used for tempo!ary storage. EPA will consider the landfill usedtfor   ,,
 temporary storage if the facility routinely made.off-site transfers of material from the pile during that reporting
 year or the facility had a contract in place before the end of the reporting year to ^transfer (he material and"
 transferred the material containing EPCRA" Section 313 chemicals" off-site before that year's report was
 required or by My 1; whichever comes first.   -         -             "-           / •""
4.2.6  On-site Waste Management Methods, Section 7A, 7B, and 7C of Form R.

       On-site waste management at electricity generating facilities include treatment and energy
recovery. Recycling of wastes is not usually performed at electricity generating facilities.

       On-site Treatment Methods. Section 7A of Form R. Electricity generating facilities
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 electricity
generating facilities may use:

1 Ash or other solid wastes may pass through several steps, including filtration (P12), sludge
dewatering (P13), settling/clarification (Pll), and thermal drying/dewatering (F83).

2Facilities commonly treat flue gas using scrubbers (A03), electrostatic precipitators (A05), and
baghouses (A06).

       •      Wastewater (such as coal pile runoff, boiler cleaning wastewater, etc.) may go
              through several treatment steps, including neutralization (Cll),
              settling/clarification (Pll), 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) plant maintenance wastes, such
              as those from boiler cleaning.

       For metal compounds, the calculation of the reportable concentration and waste treatment
efficiency must be based on the weight of the parent metal, not on the weight of the metal
compounds.  Metals are not destroyed, only physically removed or chemically converted from one
form into another. The waste treatment efficiency reported must represent only physical removal
of the parent metal from the waste stream (except for incineration), not the percent chemical
                                            4-45

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conversion of the metal compound.  If a listed waste treatment method converts but does not
remove a metal (e.g., chromium reduction), the method must be reported with a waste treatment
efficiency of zero.

       All data available at your facility must be used to calculate waste treatment efficiency and
the influent concentration of the EPCRA Section 313 chemical. If data are lacking, estimates can
be made using best engineering judgement or other methods.

       On-site Energy Recovery Processes. Section 7B.  Facilities should only report energy
recovery methods used on EPCRA Section 313 chemicals in wastes. Therefore, combustion of
commercially available fuels, such as coal or oil, is not considered energy recovery under EPCRA
Section 313 or the Pollution Prevention Act. Coal tar, a by-product of destructive distillation in
the production of coke, is not a waste and, therefore, its combustion is not reportable in Section
7B (or Section 8) of Form R. As discussed in Chapter 4.1 of this document, facilities can only
report energy recovery of EPCRA Section 313 chemicals if they have a significant heating value
and are burnt on-site in a combustion unit that is integrated into an energy recovery system.

 4.2.7  Source Reduction and Recycling Activities, Section 8 of Form R.

 In chapter 4.1.3, the general method for developing Section 8 quantities was discussed. Two
examples of how to calculate Section 8 quantities  are presented below:
                                         4-46

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                      Table 4-10: Examples of Section 8 Reporting
--- Section
•x ~. f'/ ~ ^ is
' s t \"
Section 8.1, Quantity released
Section 8.2, Quantity used for
energy recovery on-site
Section 8.3, Quantity used for
energy recovery off-site
Section 8.4, Quantity recycled
on-site
Section 8.5, Quantity recycled
off-site
Section 8.6, Quantity treated on-site
Section 8.7, Quantity treated off-site
/Metal CompotradS'7^1
•5 **^ lJjfBr
Fugitive and stack air emissions,
releases to water and POTW, and
off-site waste transfers for disposal
Not applicable to these metal
compounds that are products of
combustion
Not applicable to these metal
compounds that are products of
combustion
Not generally performed at EGFs
Off-site waste transfers with
recycling codes
Not possible to destroy metal
compound
Not possible to destroy metal .
compound
- Siifiiric^i(Acid
Aerosols) and HC1 (Acid
* "Aerosols)
Fugitive and stack air emissions
(cannot release the aerosol in
liquid or solid form)
Not applicable to these acid
aerosols that are products of
combustion
Not applicable to these acid
aerosols that are products of
combustion
Not generally performed at EGFs
Not generally transferred off site in
aerosol form
Treated in scrubbers such as FGD
systems
Not generally transferred off site in
aerosol form
4.2.8  Source Reduction Activities, Section 8.10 of Form R.

Facilities have the opportunity to report source reduction actions initiated during the reporting
year on the Form R using codes listed in the Form R and Instructions. Some examples of source
reduction activities and suggested codes are given below.

       •      Reducing the frequency of boiler cleanings and, therefore, the amount of boiler
              cleaning wastes by tracking process chemistry and monitoring boiler cleanliness to
              determine more precisely the need for cleaning. (W13: Improved maintenance
              scheduling, recordkeeping, or procedures)

       •      Reducing the frequency of boiler cleanings and the amount of boiler cleaning
              wastes by applying a protective coating to the inside surfaces of boiler tubes to
              prevent accumulation of scale on tube surfaces. (W52: Modified equipment,
              layout or piping)

       •      Reducing the need for corrosion inhibitors in cooling towers by using inert
              construction materials, such as polyethylene and stainless steel, rather than carbon
              steel.  (W42: Substituted raw materials, or W58: Other process modifications)
                                           4-47

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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)
                             4-48

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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

EPCRA Section 313 Questions & Answers, Revised 1998 Version, December 1998.
Internet Availability:  http://www.epa.gov/opptintr/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
 Order Number: EPA-745-B-99-004
                                        A-l

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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

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
                                         A-2

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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

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
                                         A-3

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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

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 Form R/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
                                         A-4

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       Air

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

Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources,
5th 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: NTIS
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.htrnlttwater8
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

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

                                         A-5

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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

Technology Transfer Network (TTN)
(919) 541-5384 (Help Desk)
Internet Home Page: http://www.epa.gov/ttn

EPA Toxic Release Inventory General Information and Guidance
Internet Home Page: http://www.epa.gov/opptintr/tri

U.S. Government Printing Office (GPO)
(202)512-1800
(202) 512-2250 (fax)
Internet Availability: http://www.gpo.gov

*For the latest list of industry-specific and other technical guidance documents, please refer to the
latest version of the Toxic Chemical Release Inventory Reporting Forms and Instructions,
Appendix H.
                                         A-6

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