United States
          Environmental Protection
          Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
EPA745-R-98-011
September 1998
£EPA   EPCRA Section 313 Reporting Guidance
          for Food Processors
                              _..-"-"
                                   •

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                               TABLE OF CONTENTS
                                                                                Page

ACKNOWLEDGEMENT	v

OVERVIEW	 vi

Chapter 1 - Introduction  	  1-1

1.0          PURPOSE	  1-1
             1.1     Background on EPCRA  	  1-2

Chapter 2 - Reporting Requirements  	2-1

2.0          PURPOSE	2-1
             2.1     Must You Report? 	2-2
             2.2     SIC Code Determination	2-4
             2.3     Number of Employees	2-9
             2.4     Manufacturing, Processing, and Otherwise Use of EPCRA Section
                    313 Chemicals	2-10
             2.5     Activity Categories	2-12
             2.6     How Do You Report?	2-14
             2.7     Form R	2-14
             2.8     Form A	2-15
             2.9     Trade Secrets  	2-17
             2.10   Recordkeeping 	2-17

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/Imported, Processed, or Otherwise Used ....  3-7
                    3.2.1  Concentration Ranges for Threshold Determination	3-10
                    3.2.2  Evaluation of Exemptions  	3-11
                          3.2.2.1       De Minimis Exemption	3-12
                          3.2.2.2       Article Exemption  	3-15
                          3.2.2.3       Facility-Related Exemption	3-16
                          3.2.2.4       Activity-Related Exemptions  	3-16
                    3.2.3  Additional Guidance on Threshold Calculations for
                          Certain Activities	3-18
                          3.2.3.1       Reuse Activities	3-19
                          3.2.3.2       Remediation Activities	3-19
                          3.2.3.3       Recycling Activities  	3-20

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                         TABLE OF CONTENTS (Continued)

                                                                                Page

             3.3     Step 3.  Determine Which EPCRA Section 313 Chemicals
                    Exceed a Threshold	3-20

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

4.0          PURPOSE	4-1
             4.1     General Steps for Determining Releases and Other Waste Management
                    Activity Quantities  	4-3
                    4.1.1  Step 1: Prepare a Process Flow Diagram   	4-3
                    4.1.2  Step 2: Identify Potential Sources of Chemical Release
                          and/or Other Waste Management Activities	4-3
                    4.1.3  Step 3: Identify On-Site Releases, Off-Site Transfers and/or
                          On-Site Waste Management Activity Types	4-5
                    4.1.4  Step 4: Determine the Most Appropriate Method(s) to
                          Develop and Calculate the Estimates for Releases and Other
                          Waste Management Activity Quantities	4-16
                          4.1.4.1       Monitoring Data or Direct Measurement (code M-)l 8
                          4.1.4.2       Mass Balance (code C)	4-19
                          4.1.4.3       Emission Factors (code E)   	4-21
                          4.1.4.4       Engineering Calculations (code O)	4-22
                          4.1.4.5       Estimating Release and Other Waste Management
                                       Quantities	4-25
             4.2     Process Descriptions (Chemical Use Categories)	4-27
                    4.2.1  Water Treatment	4-27
                    4.2.2  Refrigerant Uses  	4-31
                    4.2.3  Food Ingredients	4-33
                    4.2.4  Reactants  	4-34
                    4.2.5  Catalysts	4-36
                    4.2.6  Extraction/Carrier Solvents	4-37
                    4.2.7  Cleaning/Disinfectant Uses  	4-39
                    4.2.8  Wastewater Treatment  	4-40
                    4.2.9  Fumigants	4-43
                    4.2.10 Pesticides/Herbicides	4-44
                    4.2.11 Byproducts or Impurities	4-45
                    4.2.12 Can Making/Coating	4-48

Appendix A   TRI GUIDANCE RESOURCES
Appendix B   BASIC CALCULATION TECHNIQUES
Appendix C   GUIDANCE FOR REPORTING AQUEOUS AMMONIA
Appendix D   LIST OF TOXIC CHEMICALS WITHIN THE WATER  DISSOCIABLE
             NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING

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                                  LIST OF TABLES

                                                                                Page

2-1          SIC Codes Covered by EPCRA Section 313 Reporting  	2-4

2-2          SIC and NAICS Codes for Food Processing Industries	2-5

2-3          EPCRA Section 313 Chemicals Commonly Encountered in Food
             Processing  	2-11

2-4          Activity Categories	2-12

3-1          Reporting Thresholds	3-7

3-2          Definitions and Examples of Manufactured Chemicals  	3-8

3-3          Definitions and Examples of Processed Chemicals  	3-9

3-4          Definitions and Examples of Otherwise Used Chemicals	3-10

3-5          EPCRA Section 313 Reporting Threshold Worksheet	3-22

3-6          Sample EPCRA Section 313 Reporting Threshold Worksheet  	3-23

4-1          Summary of Residue Quantities From Pilot-Scale Experimental Study  	4-9

4-2          Potential Data Sources for Release and Other Waste Management
             Calculations	4-18

4-3          Release  and Other Waste Management Quantity Estimation Worksheet  .... 4-26
                                          in

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                                LIST OF FIGURES

                                                                              Page

2-1          EPCRA Section 313 Reporting Decision Diagram 	2-3

4-1          Release and Other Waste Management Calculation Approach	4-2

4-2          Possible Release and/or Other Waste Management Types
             for EPCRA Section 313 Chemicals	4-6
                                         IV

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                               ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of the National Food Processors Association (NFPA) and the Food Industry Environmental
Council (FIEC). Without the insight provided by those in the industry with actual experience in
the fulfilling of the EPCRA Section 313 reporting requirements we would not have been able to
produce a document that we believe will be of great assistance to those who must prepare future
EPCRA Section 313 reports. Special thanks go to Mr. Rick Jarman, Senior Director of
Environmental  Affairs, NFPA, and Mr. Bob Garfield, Chairman of the Regulatory Working
Group of FIEC, for their hard work.

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                                     OVERVIEW

             This document supersedes the booklet entitled Section 313 Emergency Planning
and Community Right-to-Know Act, Guidance for Food Processors, dated June 1990. It is
intended to assist establishments and facilities designated by Standard Industrial Classification
(SIC) Major Group 20 in complying with the Emergency Planning and Community Right-To-
Know Act (EPCRA) Section 313 reporting requirements, the preparation of Form R or Form A.
The EPCRA Section 313 program is commonly referred to as the Toxic Chemical Release
Inventory (TRI).

             The principal differences in the new document include:

             •      More detailed examples;
             •      New EPCRA Section 313 regulations developed since  1990;
             •      U.S. Environmental Protection Agency's (EPA's) interpretive guidance on
                    various issues specific to the Food Processing industry;
             •      TRI issues regarding processes not discussed in the earlier document; and
             •      Input from the National Food Processors Association and the Food
                    Industry Environmental Council.

             This document is designed to be  a supplement to the annual issue of the Toxic
Chemical Release Inventory Reporting Forms and Instructions, (TRI Forms and Instructions). 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 and ending with guidance for estimating
releases and other waste management quantities.

             Chapter 1 introduces TRI reporting and provides a brief background on the
Emergency Planning and Community Right-to-Know Act.

             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:
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              •      Is your facility's primary SIC Code or corresponding North American
                    Industry Classification System (NAICS) Code on the EPCRA Section 313
                    list?
              •      Does your facility employ ten or more full time equivalent employees?
              •      Does your facility Manufacture, Process or Otherwise Use any EPCRA
                    Section 313 chemicals?
              •      Does your facility exceed any of the activity thresholds for an EPCRA
                    Section 313 chemical?

              If the answer to ANY ONE of the first three questions 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 to determine what kind of report you must prepare, a Form R or a Form A.
Chapter 2 provides detailed information on the requirements for each kind of report.

              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 (manufacture, process, and
otherwise use) thresholds 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:

              •      De Minimis Exemption;
              •      Article Exemption;
              •      Facility-Related Exemption; and
              •      Activity-Related Exemptions.

              Chapter 3 concludes with a discussion of how to determine which  EPCRA Section
313 chemicals exceed a reporting threshold.

              Chapter 4 discusses how you calculate the release and/or other waste management
amounts for those TRI 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
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EPCRA Section 313 chemical and any potential sources or types of releases and/or other waste
management activities.  This procedure consists of:

              •      Preparation of a detailed process flow diagram;
              •      Identification of potential sources of toxic chemicals released and/or
                    otherwise waste managed;
              •      Identification of the potential types of releases and/or other waste
                    management activities from each source; and
              •      Determination of the most appropriate methods for estimating the
                    quantities of listed toxic chemical releases and/or other waste management
                    activities.

              The main part of Chapter 4 is organized around twelve common activities in the
food processing industry where EPCRA Section 313 chemicals are used. The commonly used
EPCRA Section 313 chemicals, process descriptions, reporting thresholds, release and other
waste management estimates, and common problems are presented for each of the twelve
activities.

              This document includes examples and common errors applicable to the Food
Processing industry. These are based on information received from representatives of the
National Food Processors Association and the Food Industry Environmental Council, and on the
questions received by the EPCRA Hotline and identified during voluntary site surveys of facilities
that have filed EPCRA  Section 313 reports in the past.
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                              Chapter 1 - Introduction
1.0          PURPOSE
              The purpose of this guidance manual is to assist Food Processing facilities,
Standard Industrial Classification (SIC) Code 20, in complying with the reporting requirements of
EPCRA 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).  This industry
group includes facilities that produce meat products, dairy products, preserved fruits and
vegetables, grain mill products, bakery products, sugar and confectionery products, fats and oils,
beverages, and other miscellaneous food products.  This manual explains the EPCRA Section 313
reporting requirements and discusses specific release and other waste management activities
encountered at many facilities in this industry. Since each plant is unique, the recommendations
presented may have to be modified for your particular facility.

              This document supersedes the document entitled Section 313 Emergency Planning
and Community Right-to-Know Act, Guidance for Food Processors, dated June 1990. This new
document includes:

              •      More detailed examples;
              •      New EPCRA Section 313 regulations developed since 1990;
              •      U.S. Environmental Protection Agency's (EPA's) interpretive guidance on
                    various issues specific to the Food Processing industry;
              •      TRI issues regarding processes not discussed in the earlier document; and
              •      Input from the National Food Processors Association and the Food
                    Industry Environmental Council.

It is intended to supplement the Toxic Chemical Release Inventory Reporting Forms and
Instructions (TRI Forms and Instructions) document that is updated and published annually by
the U.S. Environmental Protection Agency (U.S. EPA). It is essential that you use the current
version of the TRI Forms and Instructions to determine if (and how) you should report.  Changes
or modifications to Toxic Chemical Release Inventory (TRI) reporting requirements are reflected
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in the annual TRI Forms and Instructions and should be reviewed before compiling information
for the report.

              The objectives of this manual are to:
                    Reduce the level of effort expended by those facilities that prepare an
                    EPCRA Section 313 report; and
                    Increase the accuracy and completeness of the data being reported by the
                    food processing industry.
              U.S. EPA cannot anticipate every potential issue or question that may apply to
your facility.  Therefore, this manual attempts to address those issues most prevalent or common
for the food processing industry. Used in conjunction with the most current TRI Forms and
Instructions and the Estimating Releases and Waste Treatment Efficiencies for the Toxic
Chemical Release Inventory Form (1998 version), facilities should be able to provide complete
and accurate information for EPCRA Section 313 reporting. Additional discussions on specific
issues can be found in U.S. EPA's current version of EPCRA Section 313, Questions and
Answers, which is available on the U.S. 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.

1.1           Background on EPCRA

              The following overview of the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA Public Law 99-499, Title III of the Superfund Amendments and
Reauthorization Act), specifically Section 313 of EPCRA, and Section 6607 of the Pollution
Prevention Act (PPA), will provide you with a basic understanding of the objectives and
requirements of this program, and will help you in completing your reports.

              One of the primary goals of EPCRA is to increase the public's knowledge of, and
access to, information on both the presence of toxic chemicals in their communities and on
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releases into the environment and other waste management activities of those chemicals. EPCRA
Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2,
Section 2.2) to submit annual reports (commonly referred to as Form Rs and Form As) on the
amounts of over 600 EPCRA Section 313 chemicals and chemical categories released and
otherwise managed. The chemicals on the EPCRA Section 313 list are selected based on the
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 in use at your facility. Copies of the reporting package can be requested from the
EPCRA Hotline, 1-800-424-9346.

              All facilities meeting the EPCRA  Section 313 reporting criteria must report the
annual releases and/or other waste management activities (routine and accidental) of EPCRA
Section 313 chemicals to all environmental media. A separate report is required for each listed
chemical that is manufactured (including imported), processed, or otherwise used above the
reporting threshold. The reports are submitted to U.S. 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 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) are exempt from reporting requirements.

              EPCRA also mandates that the U.S. EPA establish and maintain a publicly
available database system consisting of the information reported under EPCRA Section 313, and
applicable Pollution Prevention Act information.  This database, known as the Toxic Chemical
Release Inventory System (TRIS), can be accessed through the following sources:
                    National Library of Medicine (NLM) TOXNET on-line system;
                    U.S. EPA Internet site, http://www.epa.gov/opptintr/tri ;
                    Envirofacts Warehouse Internet site, http://www.epa.gov/enviro/html/tris ;
                    CD-ROM from the Government Printing Office;
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                    Microfiche in public libraries; and
                    Magnetic tape and diskettes from the National Technical Information
                    Service.
              Information identified by the submitter as trade secret in accordance with the
regulatory requirements is protected from public release. In addition to being a resource for the
public, TRIS is also used in the research and development of regulations related to EPCRA
Section 313  chemicals.

              To reduce the reporting burden for small businesses, the U.S. EPA 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 file a Form R. By filing the Form A the
facility certifies that they do not exceed the reportable amount or exceed the alternate threshold.

              Note that the annual reportable amount includes the quantity of toxic chemical in
all production-related waste management activities, not just releases (see the discussion in Section
2.8 for more detail). Also note that either a Form A or a Form R, but not both, must be submitted
for each EPCRA Section 313 chemical above any reporting threshold.

              Violation of EPCRA Section 313 reporting provisions may result in federal civil
penalties of up to $25,000 per day for each violation through January 30, 1997, and $27,500 per
day for violations after January 30, 1997 (61 FR 69360). State enforcement provisions may also
be applicable depending on the state's EPCRA Section 313 reporting regulations.

              Members of the National Food Processors Association and the Food Industry
Environmental Council provided input on the common problems specific to the food processing
industry that are encountered by those completing the Form R and Form A reports.  U.S. EPA
has combined this input with questions forwarded to the EPCRA Hotline and those questions
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identified during voluntary site surveys of facilities that have filed EPCRA Section 313 reports in
the past.  Selected issues and guidance are presented throughout this document as applicable.

              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 this manual, you still have questions about EPCRA Section 313
reporting, please contact the EPCRA Hotline at 1-800-424-9346.  Assistance is also available
from the designated EPCRA Section 313 Coordinator in the U.S. EPA regional office and the
EPCRA contact in your state (see the TRI Forms and Instructions for a current list of these
contacts).  Additional guidance is also available in the resources listed in Appendix A.
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                        Chapter 2 - Reporting Requirements

2.0           PURPOSE

              The purpose of this chapter is to help you determine if you must prepare an
EPCRA Section 313 report(s) and, if so, what kind of a report(s) should be prepared (Form R or
Form A).  This chapter presents the EPCRA Section 313 reporting requirements to help you
determine if these requirements apply to your facility. It also discusses the records that must be
kept.

              To understand the following discussion 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).

              U.S. EPA recognizes that for business reasons it may be easier and more
appropriate for multiple establishments at one facility to report separately.  However, the
combined quantities of EPCRA Section 313 chemicals manufactured, processed, or otherwise
used in all establishments in that facility must be considered for threshold determinations. Also,
the combined releases  and other waste management activities reported singly for each
establishment must equal those for the facility as a whole.

              Note that if a facility is comprised of more than one establishment, once an activity
threshold is met by the facility, providing the facility meets SIC Code and employee criteria,
releases and other waste management activities from all establishments at the facility must be
reported.
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                             Example - Multiple Establishments

 Your facility has several different establishments, all with SIC Codes covered by EPCRA Section 313. One
 establishment used 7,000 pounds of an EPCRA Section 313 chemical during the year to clean equipment. Another
 establishment purchased and used 4,000 pounds of the same chemical during the year as a food processing aid. Both
 activities constitute "otherwise use" of the listed toxic chemical (as presented in Section 2.5 and described in detail in
 Chapter 3) and the total for the facility exceeded the 10,000 pound otherwise use threshold for the year. Thus, if your
 facility meets the employee threshold, you must file one Form R for that chemical from your facility, or two Form Rs,
 one from each establishment. Please note that you may be eligible to file one Form A for the facility but you cannot
 file a separate Form A for each establishment.
2.1            Must You Report?


               How do you determine if your facility must prepare an EPCRA Section 313

report? Your answers to the following four questions will help you decide (illustrated by
Figure 2-1):
               1)      Is the SIC Code for your facility included in the list covered by EPCRA
                      Section 313 reporting (see Section 2.2)?

               2)      Does your facility employ 10 or more full time employees or their
                      equivalent (see Section 2.3)?

               3)      Does your facility manufacture (which includes importation), process, or
                      otherwise use EPCRA Section 313 chemicals (see Section 2.4)?

               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
                      Section 2.5)?
               If you answered "No" to any of the first three questions, you are not required to

prepare any Form R or Form A reports. If you answered "Yes" to ALL of the first three

questions, you must complete a threshold calculation for each EPCRA Section 313 chemical at

the facility, and submit a Form R OR Form A report for each chemical exceeding a threshold.
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 Is Your Facility's Primary SIC Code Included
      on the EPCRA Section 313 list?

            (See Section 2.2)
                   YES
Does Your Facility Have 10 or More Full-Time
       Employees or the Equivalent?

            (See Section 2.3)
                   YES
 Does Your Facility Manufacture, Process, or
   Otherwise Use Any EPCRA Section 313
              Chemicals?

            (See Section 2.4)
                   YES
    Does Your Facility Exceed Any of the
Thresholds for a Chemical (after excluding quantities
     that are exempt from threshold calculations)

            (See Section 2.5)
                   YES
  AN EPCRA SECTION 313 REPORT IS
    REQUIRED FOR THIS CHEMICAL
                   YES
                 T
NO
NO
NO
                                                              STOP
                    NO EPCRA
                                                        SECTION 313 REPORTS
                                                   REQUIRED FOR ANY CHEMICALS
NO
 A SECTION 313 REPORT IS NOT
REQUIRED FOR THIS CHEMICAL
 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 Section 2.8)
                   YES
                                                                   NO
               FORMA
                  OR
     FORM R IS REQUIRED FOR THIS
              CHEMICAL
          FORM R IS REQUIRED FOR THIS
         CHEMICAL (FORM A CANNOT BE
                  SUBMITTED)
           Figure 2-1 EPCRA Section 313 Reporting Decision Diagram
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2.2
SIC Code Determination
              Facilities with the SIC Codes presented in Table 2-1 are covered by the EPCRA
Section 313 reporting requirements.
                                        Table 2-1
               SIC Codes Covered by EPCRA Section 313 Reporting
SIC Code Major Groups
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
All SIC Codes
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
              Table 2-2 presents a listing of each SIC (and NAICS*) Code for the food

processing industry with brief descriptions. You should determine the SIC Code(s) for your

facility, based on the activities on site.  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.
*NAICS - North American Industry Classification System. The NAICS is replacing the SIC system. Dual systems will
be used for a transition period which began in 1997. The NAICS uses six digits (vs. four for the SIC) which allows for a
finer division of industries in a larger economy.  Additional information on the NAICS is available from the U.S. Census
Bureau on http://www.census.gov/epcd/www/naics.html.
                                            2-4

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                   Table 2-2
SIC and NAICS Codes for Food Processing Industries
SIC Code
2011
2013
2015
2021
2022
2023
2024
2026
2032
2033
2034
2035
2037
2038
2041
2043
2044
2045
2046
2047
2048
2051
2052
2053
2061
2062
2063
NAICS Code
311611
311612
311615
311999
311512
311513
311514
31152
311511
311422
311999
311421
311211
311423
311421
311941
311411
311412
311211
31123
31192
311212
311822
311211
311111
311119
311611
311812
311812
311821
311919
311813
311311
311312
311313
Description
Meat products
Sausages and other prepared meat products
Poultry slaughtering and processing
Creamery butter
Natural, processed, and imitation cheese
Dry, condensed, and evaporated dairy products
Ice cream and frozen desserts
Fluid milk
Canned specialities
Canned fruit, vegetables, preserves, jams, and jellies
Dried and dehydrated fruits, vegetables, and soup mixes
Pickled fruits and vegetables, vegetable sauces and seasonings, and salad
dressings
Frozen fruits, fruit juices, and vegetables
Frozen specialities, not elsewhere classified
Flour and other grain mill products
Cereal breakfast foods
Rice milling
Prepared flour mixes and dough
Wet com milling
Dog and cat food
Prepared feeds and feed ingredients for animals and fowls, except dogs and cats
Bread and other bakery products, except cookies and crackers
Cookies and crackers
Frozen bakery products, except bread
Cane sugar, except refining
Cane sugar refining
Beet sugar
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Table 2-2 (Continued)
SIC Code
2064
2066
2067
2068
2074
2075
2076
2077
2079
2082
2083
2084
2085
2086
2087
2091
2092
2095
2096
2097
2098
NAICS Code
31133
31134
31132
31134
311911
311223
311225
311222
311225
311223
311225
311225
311613
311711
311712
311222
311223
311225
31212
311213
31213
31214
312111
312112
31193
311942
311999
311711
311712
31192
311942
311919
312113
311823
Description
Candy and other confectionery products
Chocolate and cocoa products
Chewing gum
Salted and roasted nuts and seeds
Cottonseed oil mills
Soybean oil mills
Vegetable oil mills, except com, cottonseed, and soybean
Animal and marine fats and oils
Shortening, table oils, margarine, and other edible fats and oils not elsewhere
classified
Malt beverages
Malt
Wines, brandy, and brandy spirits
Distilled and blended liquors
Bottled and canned soft drinks and carbonated waters
Flavoring extracts and flavoring syrups, not elsewhere classified
Canned and cured fish and seafoods
Prepared fresh or frozen fish and seafoods
Roasted coffee
Potato chips, corn chips, and similar snacks
Manufactured ice
Macaroni, spaghetti, vermicelli, and noodles
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                                 Table 2-2 (Continued)
SIC Code
2099









NAICS Code
31134
31183
31192
111998
311423
311911
311941
311942
311991
311999
Description
Food preparations, not elsewhere classified









              Most food processing industry facilities are in SIC Major Group 20 and are
required to prepare a report (or reports) if they meet the employee and chemical activity
thresholds. Note that auxiliary facilities can assume the SIC Code of another covered facility if
the primary function is to service the covered facility's operations.  For the purposes of EPCRA
Section 313, auxiliary facilities are engaged in performing support services for another, primary
facility, or multiple establishments of a primary facility. In addition, auxiliary facilities perform an
integral role in the primary facility's activities. In general, the auxiliary facility's basic
administrative services (e.g., paperwork, payroll, employment) are performed by the primary
facility. Therefore, if an auxiliary facility's primary function is to support/service a food
processing facility with SIC Code 20, the auxiliary facility is also covered by the EPCRA
Section 313 reporting requirements. Warehouses supporting a food processing facility are an
example of auxiliary facilities that may assume SIC Code 20 and therefore, could be subject to
reporting.

              If your facility has more than one SIC Code (i.e., several establishments with
different SIC Codes are owned or operated by the same entity and are located at your facility),
you are subject to reporting requirements if:
                     All the establishments have SIC Codes covered by EPCRA Section 313;
                     OR
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               •       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, products produced and/or  shipped by any other
                      establishment within the facility.


The value added by a covered establishment determines whether it represents the primary SIC

Code for the facility.
                                 Example - Primary SIC Code

 A facility has two establishments. The first assumes SIC Code 0119 (cash grains, not elsewhere classified) that is
 not typically subject to EPCRA Section 313 reporting. However, the second establishment assumes SIC Code 204
 (Grain Mill Products) that is subject to reporting. The facility then determines that the grain product is worth
 $500/ton as received from the non-covered establishment and the value of the product is $ 1,500/ton after processing
 by the covered establishment.  The value added by the covered establishment (SIC Code 204) is more than 50% of
 the product value; therefore, the primary SIC Code is 204 and the entire facility is subject to reporting.
                    COMMON ERROR - Multi-Establishment Facilities

 Some "multi-establishment" food processing facilities overlook the fact that they may have to submit Form R or
 Form A reports for chemicals used in agricultural operations. For example, if the value of the products and services
 from a processing plant exceeds the value from a farming operation that is operated on an adjacent or contiguous site
 and owned by the same person or entity a Form R or Form A may be required for EPCRA Section 313 chemicals
 used on the farm.
               Ships and barges are not considered facilities for reporting under EPCRA
Section 313. For example, a fish processing factory  on a ship that moves to various locations

would not be subject to EPCRA Section 313 even though it may be in SIC Code 2091.  In this

example, releases and other waste management activities from the ship may not need to be

reported; however, those from the shipping terminal  should be considered (by the terminal if it

must report).


               A pilot plant within a covered SIC Code is considered a covered facility and is

subject to reporting, provided it meets the employee  and activity criteria. (Note that pilot plants
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are not eligible for the laboratory exemption, which is discussed in Chapter 3.) Warehouses on

the same site as facilities in a covered SIC Code are also subject to reporting, but stand-alone

warehouses that are auxiliary facilities and that do not assume a covered SIC Code as their

primary SIC Code are not subject to reporting.


2.3           Number of Employees


              If your facility meets SIC Code and activity threshold criteria, you are required to

prepare a Form R or Form A report if your facility has  10 or more full-time employees or the

equivalent. A full-time employee equivalent is defined as a work year of 2,000 hours.  If your

facility's employees aggregate 20,000 or more hours in a calendar year, you meet the 10 or more

employee criterion.


              The following should be included in your employee calculations:


              •      Owners;
              •      Operations/manufacturing staff;
              •      Clerical staff;
              •      Temporary employees;
              •      Sales personnel;
              •      Truck drivers (employed by the facility);
              •      Other non-manufacturing or off-site facility employees directly supporting
                     the facility;
              •      Paid vacation and sick leave; and
              •      Contractor employees (maintenance, construction, etc. but excluding
                     contracted truck drivers).


              In general, if an individual is employed or hired to work at the facility, all the hours

worked by that individual must be counted in determining if the 20,000 hour criterion has been

met.
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                               Example - Calculating Employees

 Your facility has six full-time employees working 2,000 hours/year in the plant manufacturing a food product.  You
 also employ two full-time sales people and a delivery truck driver that are assigned to the plant, each working
 2,000 hours/year but predominantly on the road or from their homes.  The wastewater treatment plant (on-site and
 owned by the facility) is operated by a contractor who spends an average of two hours per day and five days per week
 at the plant. Finally, you built an addition to the plant warehouse during the year, using four contractor personnel
 who were on site full time for six months (working an average of 1,000 hours each). You would calculate the
 number of full-time employee equivalents as follows:

         •      Hours for your nine full-time employees (six plant personnel, two salespeople, and one delivery
                truck driver) for the year are:
                       (9 employees) (2,000 hours/year) = 18,000 hours;

         •      Hours for the wastewater treatment plant operator are:
                       (2 hours/day) (5 days/week) (52 weeks/year) = 520 hours; and

         •      Hours for the construction crew are:
                       (4 contractors) (1,000 hours) = 4,000 hours.

 Your facility has a total of 22,520 hours for the year, which is above the 20,000 hours/year threshold; therefore, you
 meet the employee criterion.
          COMMON ERROR - Farm Workers and Part Time/Seasonal Workers

 Remember to include any part-time and seasonal employees in your calculation, including workers on an adjacent
 farm that is part of the facility.
2.4            Manufacturing. Processing, and Otherwise Use of EPCRA Section 313
               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. You should prepare a list of all chemicals used by
all establishments at the facility, including the chemicals found in mixtures and trade name

products. 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 (also

available from the EPCRA Hotline, 1-800-424-9346).  Once you identify the EPCRA Section 313

chemicals at your facility, you must evaluate the activities involving each chemical and determine

if any activity thresholds are met.
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             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 U.S. EPA publication Common
Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and Community
Right-To-Know Act.  Table 2-3 lists EPCRA Section 313 chemicals commonly reported for the
food processing industry and the process in which they are typically used.  This list is not intended
to be all inclusive and should only be used as a guide.
                                    Table 2-3
  EPCRA Section 313 Chemicals Commonly Encountered in Food Processing
Process
Water Treatment
Refrigerant Uses
Food Ingredients
Reactants
Catalysts
Extraction/Carrier
Solvents
Cleaning/Disinfectant
Uses
Wastewater Treatment
Fumigants
Pesticides/Herbicides
Byproducts
Can Making/Coating
Chemicals
Chlorine and chlorine dioxide
Ammonia, ethylene glycol, Freon 113, dichlorodifluoromethane, CFC-1 14, chlorodi-
fluoromethane
Phosphoric acid, various food dyes, various metals (e.g. zinc, copper, manganese,
selenium, metal compounds) and peracetic acid
Ammonia, benzoyl peroxide, chlorine, chlorine dioxide, ethylene oxide, phosphoric acid,
propylene oxide
Nickel and nickel compounds
n-Butyl alcohol, dichloromethane, n-hexane, phosphoric acid, cyclohexane, and tert-butyl
alcohol
Chlorine, chlorine dioxide, formaldehyde, nitric acid, phosphoric acid, and
1,1,1 -trichloroethane
Ammonia, hydrochloric acid aerosols, and sulfuric acid aerosols
Bromomethane, ethylene oxide, propylene oxide, and bromine
Various pesticides and herbicides (e.g., aldrin, captan, 2, 4-D, hydrazine, lindane, maneb,
parathion, zineb, malathion, atrazine, diazinon bromine, and naphthalene)
Ammonia, chloroform, methanol, hydrogen fluoride, and nitrate compounds
Various ink and coating solvents (e.g. glycol ethers, MEK, toluene, methyl isobutyl ketone,
xylene), various listed metals (e.g. manganese, nickel, chromium), and various metal
pigment compounds (e.g., many pigments contain copper, barium, chromium, zinc, or
lead)
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2.5
Activity Categories
               There are three activity categories for the listed chemicals defined in EPCRA
Section 313: Manufacturing (which includes importing), Processing, and Otherwise Use. The

activity thresholds which have been in effect since reporting year 1989 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 quantity of chemicals

stored on site or purchased is not relevant for threshold determinations.  Rather, the determination

is based solely on the quantity actually manufactured (including imported), processed, or

otherwise used. Therefore, EPCRA Section 313 toxic chemicals that are brought on site and

stored, but are not incorporated into a product for distribution or not otherwise used on site

during the reporting year, are not considered towards any activity thresholds.


               Expanded definitions, with examples, of each of the three activities are found in

Chapter 3, Tables 3-2, 3-3,  and 3-4. The terms are briefly defined in Table 2-4:
                                          Table 2-4
                                    Activity Categories
   Activity
   Category
                            Definition
Threshold
 (Ibs/yr)
 Manufacture
To produce, prepare, import, or compound a toxic chemical. "Manufacture"
also applies to a toxic chemical that is produced coincidentally during the
manufacture, processing, otherwise use, or disposal of another chemical or
mixture of chemicals as a byproduct, and a toxic chemical that remains in that
other chemical or mixture of chemicals as an impurity during the manufacturing,
processing, or otherwise use or disposal of any other chemical substance or
mixture. An example would be the production of ammonia or nitrate
compounds in a wastewater treatment system.
  25,000
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                                          Table 2-4 (cont.)
    Activity
   Category
                               Definition
Threshold
 (Ibs/yr)
 Process
 To prepare a listed EPCRA Section 313 chemical, or a mixture or trade name
 product containing an EPCRA Section 313 chemical, for distribution in
 commerce (usually the intentional incorporation of an EPCRA Section 313
 chemical into a product). For example, zinc compounds may be processed as an
 additive in dog food, and would have to be reported if you exceeded the
 reporting threshold.  Processing includes the preparation for sale to your
 customers (and transferring between facilities within your company) of a
 chemical or formulation that you manufacture.  For example, if you manufacture
 a chemical or product, package it, and then distribute it into commerce, this
 chemical has been manufactured AND processed by your facility.
  25,000
 Otherwise
 Use
 Generally, use of a listed EPCRA Section 313 chemical that does not fall under
 the Manufacture or Process definitions is classified as Otherwise Use. A listed
 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, n-butyl alcohol used as a carrier solvent for spices is
 classified as Otherwise Used.

 On May 1, 1997 U.S. EPA revised the interpretation of "otherwise use". The
 following new "otherwise use" definition becomes effective with the 1998
 reporting year (62 FR 23834, May  1, 1997):

        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 a toxic chemical
        does not include disposal, stabilization (without subsequent distribution
        in commerce), or treatment for destruction unless:

        1) The toxic chemical that was disposed, stabilized, or treated for
        destruction was received from off site for the purposes of further waste
        management; OR

        2) The toxic 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
                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.
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              Also, note that the threshold determinations for the three activity categories
(manufacturing, processing, and otherwise use) are mutually exclusive.  That is, you must conduct
a separate threshold determination for each activity category and if you exceed any threshold, all
releases and other waste management activities of EPCRA Section 313 toxic chemicals at the
facility must be considered for reporting.
                                   Example - Relabeling
 You buy a mixture in small containers which contains a listed toxic chemical. When it arrives you put your own label
 on each container and put the containers in a larger box with several other items you manufacture, and sell the larger
 box as a kit. The quantity of the EPCRA Section 313 chemical in the small containers should not be counted toward
 the processing (because you did not repackage the toxic chemical) or otherwise use thresholds, nor should it be
 counted toward the manufacturing activity threshold unless the small containers were imported.  However, you must
 consider other chemicals that you manufactured in the kit toward manufacturing and processing threshold
 determinations.
2.6           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). Provided you meet certain criteria you may file a Form A
rather than a Form R.  The TRI Forms and Instructions contain detailed directions for the
preparation and submittal  of Form R or Form A reports for each listed chemical for the reporting
year.  The TRI Forms and Instructions are sent to all facilities which submitted Form R or
Form A reports the preceding year.  However, if you do not receive a courtesy copy, you may
request copies of the TRI Forms and Instructions from the EPCRA Hotline (1-800-424-9346).

2.7           FormR

              Form R is the more detailed and more common report. If you are submitting a
Form R, it is essential that you use the TRI Forms and Instructions for the appropriate reporting
year.  U.S. EPA encourages the electronic submittal of the Form R, via the Automated Toxic
Chemical Release Inventory Reporting Software (ATRS). Use of the ATRS will save time in data
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entry and photocopying and reduce errors via on-line validation routines and use of pick lists.
The ATRS can be found on the Internet at:

             •      http://www.epa.gov/opptintr/atrs

The ATRS is available in both DOS and Windows versions.  More information can be found in
the TRI Forms and Instructions and by calling the ATRS User Support Hotline at (703) 816-
4434.

             The Form R consists of two parts:

             Part I. Facility Identification Information.  This part may be photocopied and re-
             used for each Form R you submit, except for the signature which must be original
             for each submission.
             Part II. Chemical Specific Information.  You must complete this part separately for
             each toxic chemical  or chemical category; it cannot be reused year to year even if
             reporting has not changed.

             Submission of incomplete Form Rs may result in 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.

2.8          Form A

             Form A, also referred to as the "Certification Statement," was developed to
reduce the annual reporting burden for facilities with minimal amounts of  EPCRA Section 313
chemicals released and/or otherwise managed as a waste (59 FR 61488, November 1994;
applicable beginning reporting year 1994 and beyond). The following two criteria must be met in
order to use a Form A:
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                     First, the amount of the chemical manufactured, processed, OR otherwise
                     used cannot exceed one million 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 listed chemical cannot
                     exceed 500 pounds per year. The "reportable amount" is defined as the
                     sum of the on-site amounts released (including disposal), treated, recycled,
                     and 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 on the 1997 version of the Form R.
                               Example - Form A Threshold

 Providing the combined annual reportable amounts from all activities does not exceed 500 pounds, a facility that
 manufactures 900,000 pounds of an EPCRA Section 313 chemical and processes 150,000 pounds of the same listed
 toxic chemical is eligible to use the Form A because the facility did not exceed the one million pounds for either
 activity, even though the total activity usage exceeds one million pounds.
              The Form A Certification Statement must be submitted for each eligible EPCRA

Section 313 chemical. The information on the Form A will be included in the publicly accessible

TRI database. 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/or other waste management estimations to any media are required. You must

simply certify that the total annual reportable quantity does not exceed 500 pounds.  Many

facilities have indicated that the initial time required to determine whether they qualify for

submitting a Form A is equivalent to the time needed to complete a Form R.  However, once your

facility has completed estimates to justify the submission of a Form A, a considerable amount of

time will be saved in subsequent  years.  It is strongly recommended that you document your initial

rationale and refer to it every year, to verify you have not modified a part of the process that

would invalidate the initial rationale.

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2.9           Trade Secrets

              If you submit trade secret information, you must prepare two versions of the
substantiation form as prescribed in 40 CFR Part 350 (see 53 FR 28801, July 29, 1988), as well as
two versions of the Form R (or Form A).  One set of forms should be "sanitized" (i.e., it should
provide a generic name for the toxic chemical identity). This version will be made available to the
public.  The second version, the "unsanitized" version, should provide the actual identity of the
toxic chemical and have the trade secret claim clearly marked in Part I, Section 2.1 of the Form R
or Form A.  The trade secrets provision only applies to the toxic chemical identity. 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 toxic chemicals. Facilities may
jeopardize the trade secret status of a toxic chemical by submitting an unsanitized version to a
state agency or tribal government 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 TRI Forms and Instructions.

2.10          Recordkeeping

              Complete, accurate, and preferably electronic 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 a U.S. EPA compliance
audit.  U.S. EPA requires you to maintain records substantiating the Form R or Form A
submission, for a minimum of three years.  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.  U.S. EPA may request this supporting documentation
during a regulatory audit.
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              Specifically, U.S. EPA requires that the following records must 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:

                     •       Claimed allowable exemptions;
                     •       Threshold determinations;
                     •       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 use;
                     •       The basis of all  estimates;
                     •       Receipts or manifests associated with transfers to off-site locations;
                            and
                     •       Waste treatment methods, 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 for all estimates.

Some facilities may have detailed  monitoring data and off-site transfer records that are used for
                                           2-18

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estimates while others may only use purchase and inventory records. Examples of records that

you should keep, if applicable, might include:
                    Each Form R or Form A submitted;
                    EPCRA 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 from suppliers;
                    Inventory data;
                    National Pollutant Discharge Elimination System (NPDES)/State Pollutant
                    Discharge Elimination System (SPDES) permits and monitoring reports;
                    EPCRA Section 312, Tier II reports;
                    Monitoring records;
                    Air permits;
             •      Flow measurement data;
             •      Resource Conservation and Recovery Act (RCRA) hazardous waste
                    generator's reports;
             •      Pretreatment reports filed with local governments;
             •      Invoices from waste management firms;
             •      Manufacturer's estimates of treatment efficiencies;
             •      Comprehensive Environmental Response, Compensation and Liability Act
                    (CERCLA) Reportable Quantity (RQ) reports;
             •      RCRA manifests; and
             •      Process flow diagrams (including emissions, releases, and other waste
                    management activities).
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           Chapter 3 - EPCRA Section 313 Threshold Determinations

3.0          PURPOSE

             This chapter provides a step-by-step procedure for determining if any EPCRA
Section 313 chemicals or chemical categories exceed a reporting threshold at your facility.
Threshold determinations are essentially a three step process:
             Step 1)       Determine if you manufacture/import, process, or otherwise use
                          any EPCRA Section 313 chemicals.
             Step 2)       Determine the quantity of each EPCRA Section 313 chemical you
                          manufacture/import, process, or otherwise use.
             Step 3)       Determine which EPCRA Section 313 chemicals exceed a
                          threshold.
3.1          Step 1 - Determining Which EPCRA Section 313 Chemicals are
             Manufactured (Including Imported). Processed, or Otherwise Used

             Compile lists of all chemicals, compounds, and mixtures at your facility. For
facilities with many different chemicals and mixtures it is often helpful to prepare two lists: one
with the pure (single ingredient) chemicals (including chemical compounds) and one with the
mixtures and trade name products.  On the second list, under the name of each mixture/trade
name product, write the names of all chemicals of which that product is comprised.  Next,
compare the chemicals on both lists to the current EPCRA Section 313 chemicals list found in the
TRI Forms and Instructions (remember that chemicals may be periodically added and deleted and
you should use the current instructions). Highlight the EPCRA Section 313 chemicals that are on
your list. You must perform threshold calculations 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 found in the food
processing industry is dichlorodifluoromethane.  Dichlorodifluoromethane (Chemical Abstract
Service (CAS) No. 75-71-8) has several synonyms including:  CFC-12; difluorodichloromethane;
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Freon 12.  It must be reported on Form R (or Form A), Item 1.2, by its EPCRA Section 313
chemical name, dichlorodifluoromethane. Synonyms can be found in the U.S. EPA document
Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the EPCRA (EPA 745-
R-95-008).

              The original list of chemicals subject to EPCRA Section 313 reporting was a
combination of chemical lists from New Jersey and Maryland. Refinements to the list have been
made and changes are anticipated to continue.  The list can be modified by U.S. EPA initiative or
industry or the public can petition U.S. EPA to modify the list. When evaluating a chemical for
addition or deletion from the list, U.S. EPA must consider potential acute and chronic human
health effects and adverse environmental effects. U.S. EPA reviews these petitions and initiates a
rulemaking to add or delete the chemical from the list, or publishes an explanation why it denied
the petition.

              While every chemical on the EPCRA Section 313  chemical list must be considered,
certain chemicals are typically used in the food processing industry. As a guide, the most
frequently reported EPCRA Section 313 chemicals for reporting year 1995 under  SIC Major
Group 20, and the processes they are typically used in, are listed in Table 2-3.

              A computerized spreadsheet may be helpful in developing your facility's chemical
list and performing threshold calculations.  The spreadsheet could show the chemical or chemical
mixture with corresponding component concentrations; the yearly quantity  manufactured,
processed, or otherwise used; and the CAS number. The spreadsheet could also be designed  to
identify the total quantity by activity category  (amounts manufactured, processed, and otherwise
used) for each EPCRA Section 313 chemical in every  mixture, compound, and trade name
product.

              An initial investment of time will be required to develop this spreadsheet; however,
the time and effort saved in threshold calculations in subsequent years will be significant. Such a
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system will also reduce the potential of inadvertently overlooking EPCRA Section 313 chemicals
that are present in mixtures purchased from off-site sources.

              To develop the chemical list and the associated activity categories you may want
to consult the following:
                    Material Safety Data Sheets (MSDSs);
                    Facility purchasing records;
                    Inventory records;
                    Air and water discharge permits; and
                    Individual manufacturing/operating functions.
              Useful information that is needed to prepare your reports and that you may want
to include for each chemical on your spreadsheet is:

              •      The mixture name and associated EPCRA Section 313 chemical names;
              •      The associated CAS numbers;
              •      The trade name for mixtures and compounds;
              •      The 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).

              MSDSs are an excellent source of information for the type and composition of
chemicals in mixtures, and are the best sources for determining whether you have purchased raw
materials that contain EPCRA Section 313 chemicals. As of 1989, chemical suppliers  of facilities
in SIC Major Groups 20 through 39 are required to notify customers of any EPCRA Section 313
chemicals present in mixtures or 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 mixtures or trade name
products. Beginning with the 1998 reporting year, seven new industries will be covered by most
of the EPCRA Section 313 reporting requirements, but will not be required to comply with most

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of the supplier notification regulations. For more information on supplier notification, see
EPCRA Section 313 Question and Answers, Revised 1997 Version -Appendix A, Directive 9
(EPA-745-B-97-008) or Supplier Notification Requirements (EPA-560/4-91-006).

              Carefully review the entire MSDS. Although new 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 could be found in different
sections of the MSDS.  Also, many EPCRA Section 313 chemicals are present as impurities or as
small components of mixtures. These quantities must also be considered in threshold
determinations unless the concentration is below the de minimis value (see Section 3.2.2.1).  In
some cases, if the chemical is present below de minimis concentration, it may be exempt. The
most likely sections of an MSDS to provide information on EPCRA Section 313 chemicals are:

              •      Physical properties/chemical composition section;
              •      Regulatory section;
              •      Hazardous components section;
              •      Labeling section; and
              •      Additional information section.

              Several chemicals on the EPCRA Section 313 chemical list include qualifiers
related to use or form.  Some chemicals are reportable  ONLY if manufactured by a specified
process or in a specified activity category. 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 is reportable, while black or red phosphorus is not.

              The qualifiers,  associated chemicals, and typical applicability to the food
processing industry are presented below.  A detailed discussion of the qualifier criteria can be
found in the TRI Forms and Instructions.
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Fume or dust - Three metals (aluminum, vanadium, and zinc) are qualified
with "fume or dust."  This definition excludes "wet" forms such as
solutions or slurries, but includes powder, particulate, or gaseous forms of
these metals.  For example, use of zinc metal as a food ingredient is
therefore not subject to reporting unless the zinc is in the form of a fume or
dust. However, the entire weight of all zinc compounds should be included
in the threshold determination for zinc compounds. Keep in mind that only
the metal portion of metal compounds is reported in the determination of
release and/or other waste management amounts.

Manufacturing qualifiers - Two chemicals that are widely used in food
processing, saccharin and isopropyl alcohol, contain qualifiers relating to
manufacture.  The qualifier for saccharin means that only manufacturers of
the chemical are subject to the reporting requirement. The qualifier for
isopropyl alcohol means that only facilities that manufacture the chemical
by the strong  acid process are required to report. Facilities that only
process or otherwise use these chemicals are not required to report. Thus,
a facility that  uses saccharin as a food ingredient or that uses isopropyl
alcohol as a solvent in inks or coatings does not need to include these
quantities in threshold or release calculations.

Solutions (ammonia, ammonium sulfate, and ammonium nitrate) - On
June 26, 1995, U.S. EPA deleted ammonium sulfate (solution) (CAS No.
7783-20-2) from the EPCRA  Section 313 toxic chemical list and qualified
the listing for ammonia  (CAS No. 7664-41-7). The ammonia listing was
modified by adding 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)".
The deletion of ammonium sulfate (solution) and the qualification of
ammonia are effective as of reporting year 1994. Therefore, ammonium
sulfate is no longer a reportable chemical under EPCRA Section 313.
However, aqueous ammonia that is formed from the dissociation of
ammonium salts (including ammonium sulfate) in water is reportable as is
the aqueous ammonia generated from the dissociation of ammonium nitrate
in water. You must determine the amount of aqueous ammonia generated
from solubilizing these chemicals and apply it toward the threshold for
ammonia. U.S.  EPA has published guidance on reporting for ammonia and
ammonium salts in EPCRA Section 313 Question and Answers, Revised
1997 Version - Appendix A, Directive 8. Additionally,  ammonium nitrate
must be included in threshold and release and other waste management
calculations for the nitrate compounds category.  U.S. EPA has published
guidance for these chemicals in Water Dissociable Nitrate Compounds
Category and Guidance for Reporting (Appendix D).
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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 portion of the compound must be
considered for release and other waste management determinations. One
issue recently raised by industry is how to report nitrate compounds in
wastewater and/or sludge that is applied to farms as a nitrogen source
(either on site or off site). Although the plants and microorganisms
ultimately degrade these chemicals, U.S. EPA does not consider this to be
a form of recycling or reuse. U.S. EPA's view is that the wastewater
and/or sludge is being managed and should be reported as being disposed
to land (either on site or off site as appropriate). See Appendix D for
additional discussion on nitrate compounds.

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 needs to be considered when it is
handled in the friable form.  Friable refers to the physical characteristics of
being able to crumble, pulverize, or reduce to a powder with hand
pressure.

Aluminum oxide (fibrous) - Beginning with reports for calendar year
1989, aluminum oxide is only subject to threshold determination when it is
handled in fibrous forms.  U.S. 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) - On June 26,  1995, U.S. EPA promulgated
a final rule delisting non-aerosol forms of sulfuric acid (CAS No. 7664-
93-9) from the EPCRA Section 313 toxic chemical list (effective for the
1994 reporting year). Therefore, threshold determinations and release and
other waste management estimates now only apply to the aerosol forms.
U.S. EPA considers the term aerosol to cover any generation of airborne
acid (including mists, vapors, gas, or fog) without any particle size
limitation.

Hydrochloric acid (acid aerosols)  - On July 25, 1996, US  EPA
promulgated a final rule delisting non-aerosol forms of hydrochloric acid
(CAS No. 7647-01-0) (effective for the  1995 reporting year). Therefore,
threshold determinations and release and other waste management

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                      estimates now only apply to the aerosol forms. U.S. EPA considers the
                      term aerosol to cover any generation of airborne acid (including mists,
                      vapors, gas, or fog) without any particle size limitation.


3.2           Step 2.  Determining the Quantity of Each EPCRA Section 313 Chemical
              Manufactured/Imported. Processed, or Otherwise Used
              The next step is to determine the quantities manufactured, processed, and
otherwise used for each EPCRA Section 313 chemical on your list.  Table 3-1 lists the reporting
thresholds for each of these activity categories (Tables 3-2 through 3-4 provide detailed
definitions of subcategories for each Activity Category).


                                         Table 3-1
                                  Reporting Thresholds
Activity Category
Manufacturing (including importing)
Processing
Otherwise used
Threshold
25,000 pounds per year
25,000 pounds per year
10,000 pounds per year
              Each threshold must be individually calculated; they are mutually exclusive and are
not additive.
                             Example -Threshold Determination

 If your facility manufactures 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 threshold, and an EPCRA Section 313 report for
 that chemical is not required. However, if your facility manufactures 28,000 pounds per year of an EPCRA
 Section 313 chemical and otherwise uses 8,000 pounds of the same chemical, you have exceeded the manufacturing
 threshold and ALL releases and other waste management activities of that chemical must be reported on the Form R,
 including those from the "otherwise used" activity.
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                       COMMON ERROR - Threshold Determination

 The amount of the EPCRA Section 313 chemical that is actually manufactured (including the quantity imported),
 processed, or otherwise used, not the amount in storage or in the system, should be the amount applied to the
 threshold determination. For example, your facility uses hexane to extract oil from soybeans in a reactor that holds
 50,000 pounds of hexane. Most of the hexane remains in the reactor and additional hexane is added only to replace
 fugitive releases and small losses that occur when removing the product. Over the course of a year, you add 5,000
 pounds of hexane to the reactor to replenish losses. 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 facility, the "otherwise use" threshold has not been exceeded and you would not have to report for
 hexane.
               Each of the activity categories is divided into subcategories.  As discussed in the
TRI Forms and Instructions, you are required to designate EACH category and subcategory that
applies to your facility. Detailed definitions, including descriptions of subcategories for each
activity and examples, are presented in Tables 3-2, 3-3, and 3-4.


                                           Table 3-2
               Definitions and Examples of Manufactured Chemicals
Manufacturing Activity
Subcategory
Produced or imported for
on-site use/processing
Produced or imported for
sale/distribution
Produced as a byproduct
Produced as an impurity
Definition
A chemical that is produced or imported and then further
processed or otherwise used at the same facility.
A chemical that is produced or imported specifically for
sale or distribution outside the manufacturing facility.
A chemical that is produced coincidentally during the
production, processing, or otherwise use of another
chemical substance or a mixture and is separated from that
substance or mixture. Toxic chemicals produced and
released as a result of waste treatment or disposal are also
considered byproducts.
A chemical that is produced coincidentally as a result of
the manufacture, processing, or otherwise use of another
chemical and remains primarily in the mixture or product
with that other chemical.
Examples in the Food
Processing Industry*
Chlorine dioxide
produced on site for
water treatment

Ammonia produced
through breakdown of
proteins in a wastewater
treatment system

 : More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
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                                              Table 3-3
                   Definitions and Examples of Processed Chemicals
    Processing Activity
        Subcategory
                  Definition
  Examples in the Food
  Processing Industry*
 Reactant
A natural or synthetic chemical used in chemical
reactions for the manufacture of another chemical
substance or product. Examples include feedstocks,
raw materials, intermediates, and initiators.
Ammonia used as a starter
component in the batch
process manufacture of
cheese

Propylene oxide reacted
with corn starch to produce
hydroxyalkyl starches
 Formulation component
A chemical that is added to a product or product
mixture prior to further distribution of the product
and acts as a performance enhancer during use of the
product. Examples include additives, dyes, reaction
diluents, initiators, solvents, inhibitors, emulsifiers,
surfactants, lubricants, flame retardants, and
rheological modifiers.
Zinc compounds used as
additives in dog food

Phosphoric acid used as an
ingredient in the preparation
of baking ingredients and
soft drinks

Food dyes
 Article component
A chemical that becomes an integral component of
an article distributed for industrial, trade, or
                             consumer use.
Pigments contained in inks
and coatings that are applied
to cans on site
 Repackaging only
A chemical that is processed or prepared for
distribution in commerce in a different form, state, or
quantity. May include, but is not limited to, the
transfer of material from a bulk container, such as a
tank truck, to smaller containers such as cans or
bottles.
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
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                                            Table 3-4
               Definitions and Examples of Otherwise Used Chemicals
   Otherwise Use Activity
        Subcategory
                              Definition
   Examples in the Food
   Processing Industry*
 Chemical processing aid
             A chemical that is added to a reaction mixture to aid
             in the manufacture or synthesis of another chemical
             substance but is not intended to remain in or become
             part of the product or product mixture. Examples
             include process solvents, catalysts, inhibitors,
             initiators, reaction terminators, and solution buffers.
Nickel catalyst used in the
hydrogenation of vegetable
oil

n-Butyl alcohol used as a
carrier solvent for spices

Chlorine used as a bleaching
agent for flour

Chlorine used for water
treatment

Solvents contained in inks
and coatings that are applied
on site
 Manufacturing aid
             A chemical that aids the manufacturing process but
             does not become part of the resulting product and is
             not added to the reaction mixture during the
             manufacture or synthesis of another chemical
             substance. Examples include process lubricants,
             metalworking fluids, coolants, refrigerants, and
             hydraulic fluids.
Ammonia used as a
refrigerant

Ethylene oxide used as a
bacteriocide during
processing of spices
 Ancillary or other use
             A chemical that is used for purposes other than
             aiding chemical processing or manufacturing.
             Examples include cleaners, degreasers, lubricants,
             fuels (including waste fuels), and chemicals used for
             treating wastes.	
Nitric acid used to clean
process equipment
Fumigants used to treat grain
products.
 : More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
3.2.1
Concentration Ranges for Threshold Determination
               You are required to use the best readily available information for all calculations in

EPCRA reporting; however, the exact concentration of an EPCRA Section 313 chemical in a

mixture or trade name product may not be known. The supplier or MSDS may only list ranges, or

upper or lower bound concentrations.  U.S. EPA has developed guidance on how to use

information in this situation for threshold determinations.
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             •      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 MSDS for the trade name product 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 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 MSDS 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%, the value you
                    should use in your threshold calculation.

             •      If only the lower bound concentration is specified and no information on
                    other components is given assume the upper bound concentration is 100%
                    and calculate the mid-point as above.

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

Note that there is special guidance for concentration ranges that straddle the de minimis value.
See Section 3.2.2.1 and the 7997 Q&A Document, Appendix A, Directive #2 for more
information regarding de minimis if applicable.
3.2.2         Evaluation of Exemptions


             When determining thresholds, you can exclude quantities of any EPCRA
Section 313 chemicals that are manufactured, processed, or otherwise used in exempt activities.

Exemptions are divided into four classes:
              1.     De Minimis Exemption;
              2.     Article Exemption;
              3.     Facility-Related Exemption; and
              4.     Activity-Related Exemptions.
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                         COMMON ERROR - Exempt Activities
 Quantities of EPCRA Section 313 chemicals used for exempt activities do not need to be included in your threshold
 calculations, even if they are used in a reportable activity elsewhere in the facility.
3.2.2.1        De Minimis Exemption

              If the amount of EPCRA Section 313 chemical(s) present in a mixture or 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). The de minimis concentration is 1%, except
for Occupational Safety and Health Administration (OSHA)-defined carcinogens, which have a
0.1% de minimis concentration. Note that if a mixture contains more than one member of a
compound category, the weight percent of all  members must be summed. If the total meets or
exceeds the category's de minimis level, the de minimis exemption does not apply.  U.S. EPA has
published several detailed questions and answers and a directive in the 7997 Q&A Document
(Q&As #210 through #228 and Appendix A, Directive #2) 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 to EPCRA Section 313 chemicals that are
coincidentally manufactured below the de minimis level as an impurity and subsequently
distributed in commerce. It also applies to listed toxic chemicals below the de minimis
concentration in an imported mixture or trade name product.

              Information may only be available that lists the concentration of chemicals in
mixtures  as a range. U.S. EPA has developed guidance on how to determine quantities that are
applicable to threshold determination, release, and other waste management calculations when this
range straddles the de minimis value.  In general, only the quantity of the EPCRA Section 313
chemical whose concentration exceeds the de  minimis must be considered. Therefore, U.S. EPA
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allows facilities to estimate the quantity below the de minimis and exclude it from further
consideration.
                            Examples - de minimis Concentration Ranges
 Example 1:

 A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1 .25% manganese. Manganese is subject to a 1% de
 minimis concentration exemption. The amount of mixture subject to reporting is the quantity containing manganese above the de
 minimis concentration:

                   (8,000,000)(1.25% - 0.99%)/(1.25% - 0.25%)

 The average concentration of manganese that is not exempt (above the de minimis) is:
 Therefore, the amount of manganese that is subject to threshold determination and release and other waste management estimates
 is:

                            (8,000,OOOY1.25%-0.99%)ir(1.25%+1.00%)l   -, ,„„      ,
                            -^ - '- - £ - J-\ p - J-\ = 23,400 pounds
                                 (1.25%-0.25%)     ][      (2)


                   = 23,400 pounds manganese
                   = 23,000 pounds with two significant figures (which is below the processing threshold)

 In this example, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was used to
 determine the amount below the de minimis concentrations.  If the information was available to one decimal place, 0.9 should be
 used, as in Example 2 below.

 Example 2:

 As in Example 1, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS states the mixture
 contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above de minimis) is:

                   (8,000,000) (1.2% - 0.9%)/(1.2% - 0.2%)

 The average concentration of manganese that is not exempt (above de minimis) is:

                   (1.2% + 1.0%)/(2)

 Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management estimates
                           (8.000.000)(1.2%-0.9%)     ..      =             ^
                                 (1.2%-0.2%)       [     (2)
                   = 26,400 pounds manganese
                   = 26,000 pounds with two significant figures
                    (which is above the processing threshold)
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              The exemption does not apply to listed 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, nor to waste brought on site for management. (Under EPCRA Section 313, U.S. EPA
does not consider waste to be a mixture.) For example, many facilities treat waste solvents by
incinerating them.  Combustion processes that use coal as the primary fuel source can result in the
coincidental manufacture of sulfuric and hydrochloric acid aerosols and metal compounds.  Since
the de minimis exemption does not apply to the coincidental manufacture of chemicals as
byproducts, the  formation of these compounds must be considered for threshold, release, and
other waste management calculations.
                                   Examples - de minimis
 Your facility purchases a food additive containing 0.8% Basic Green 4, a food dye. The quantity purchased qualifies
 for the de minimis exemption and does not need to be included in threshold determinations, release, or otherwise
 managed calculations since its concentration is less than 1 percent.
 Your facility uses a mixture containing 1.1% phosphoric acid and 0.6% manganese in processing.  The de minimis
 exemption would apply to manganese because the concentration is below 1%; however, it would not apply to
 phosphoric acid. All of the phosphoric acid must be included in threshold determinations, release, and other waste
 management calculations.
              Once the de minimis level has been equaled or exceeded, the exemption no longer
applies to that process stream, even if the toxic chemical later falls below the de minimis
concentration. All releases and other waste management activities are subject to reporting after
the de minimis concentration has been equaled or exceeded. The facility does not have to report
releases and/or other waste management activities that took place before the de minimis was
exceeded.
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3.2.2.2        Article Exemption

              An article is defined as a manufactured item that:

              •      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 article from another facility and process or
otherwise use it without changing the shape or design, and your processing does not result in the
release of more than 0.5 pound of the EPCRA Section 313 chemical in a reporting year, then the
EPCRA Section 313 chemical in that  article is exempt from threshold determinations and release
and other waste management reporting.

              The shape and design can be changed somewhat during processing and otherwise
use 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 article definition. If the item's basic dimensional characteristics are totally altered
during processing or otherwise use, the item would not meet the definition. As an example, items
that do not meet the definition would be items that are cold extruded, such as lead  ingots that are
formed into wire or rods. However, cutting a manufactured item into pieces that are recognizable
as the article 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 no releases occur.

              Any processing or otherwise use of an article that results in a release above 0.5
pound per year for each toxic chemical for all like articles also negates the exemption.  Cutting,
grinding, melting, or other processing of a manufactured item could result in a release of a toxic
chemical during normal conditions of use and, therefore, could negate the exemption as an article

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if the total exceeds 0.5 pound in a year.  However, if all of the resulting waste is recycled or
reused, either on site or off site so the release and/or other waste management of the listed
chemical does not exceed 0.5 pound, then the article's exemption status is maintained. Also, if
the processing or otherwise use of similar manufactured items results in a total release and/or
other waste management of less than or equal to 0.5 pound of any individual EPCRA Section 313
chemical to any environmental media in a calendar year, U.S. EPA will allow this quantity to be
rounded to zero and the manufactured items to maintain their article exemption.  The 0.5 pound
limit does not apply to each individual article, but applies to the sum of all releases and other
waste management activities from processing or otherwise use of like articles for each EPCRA
Section 313 chemical. The 7997 Q&A Document presents several specific questions and
answers/discussion pertaining to the article exemption.

3.2.2.3       Facility-Related Exemption

             Listed toxic chemicals that are manufactured, processed, or otherwise used in
laboratories are exempted from the  threshold determination (and subsequent release and other
waste management calculations).
                     Laboratory Exemption.  This exemption includes EPCRA Section 313
                     chemicals that are used under supervision of a technically qualified
                     individual.  It applies only to 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 laboratory exemption.
3.2.2.4        Activity-Related Exemptions

              Some exemptions apply to the "otherwise use" of a toxic chemical.  EPCRA
Section 313 chemicals used in these activities do not need to be included in a facility's threshold
determination (nor the associated release and/or other waste management calculations).  The
following activities are considered exempt:
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Materials used in routine janitorial or facility grounds maintenance
Examples are bathroom cleaners, fertilizers, and garden pesticides in similar
type or concentration distributed to consumers. Materials used to clean
process equipment do not meet this exemption. Pesticides and fertilizers
used in agricultural operations at a food processing facility are not exempt
under this category.

Personal use of items. Examples are foods, drugs, cosmetics, and other
personal items including those items used in cafeterias and infirmaries.
Office supplies such as correction fluid are also exempt.
                  Example - Personal Use Exemption

 Ammonia used to clean a cafeteria grill is exempt from threshold determinations and
 release and other waste management calculations.  Chlorine added to the water supply
 system to prepare potable water for consumption at the facility is also exempt under the
 personal use exemption.
Structural components of the facility  Exemptions apply to listed toxic
chemicals present in materials used to construct, repair, or maintain
structural components of a facility. An example common to all facilities
would be the solvents and pigments used to paint the buildings.  Materials
used to construct, repair, or maintain process equipment are not exempt.

Materials used with facility motor vehicles. This category  includes the
use of listed toxic chemicals for the purpose of maintaining motor vehicles
operated by the facility. Common examples include 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, some cranes, forklifts,
tow motors, locomotives, and aircraft. Note that this exemption applies to
the OTHERWISE USE of the chemical. The coincidental manufacture of
listed chemicals resulting  from combustion of gasoline is not exempt and
should be considered as part of the manufacturing threshold.
                 Example - Motor Vehicle Exemption

Methanol is purchased for use as a processing aid and as a windshield washer anti-freeze
in company vehicles.  The amount used for the latter purpose would be subtracted from the
facility total BEFORE the facility total is compared to the activity threshold. Even if the
facility still exceeds the otherwise use threshold, the amount in the anti-freeze is exempt
from release and other waste management reporting.
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                      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 - Process Equipment Chemical Use

                      Lubricants containing listed toxic 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 operations, are
                      not exempt and the amount of the chemical in the lubricant should be applied to the
                      otherwise use threshold.
                      EPCRA Section 313 chemicals in air or water drawn from the
                      environment or municipal sources.  Included are listed toxic chemicals
                      present in process water and non-contact cooling water drawn from the
                      environment or a municipal source, or chemicals present in air or
                      compressed air used in combustion.
                                      Example - Chemicals in Process Water

                      A facility uses river water for one of its processes. This water contains approximately 100
                      pounds of a listed chemical.  The facility ultimately returns the water that contains the
                      entire 100 pounds of the listed chemical to the river.  The chemical in the water can be
                      considered exempt because the listed toxic chemical was present as it was drawn from the
                      environment. The facility does not need to consider the chemical drawn with river water
                      for threshold determinations  or release and other waste management reporting.
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 listed toxic

chemicals.
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3.2.3.1        Reuse Activities

              Threshold determinations of listed toxic chemicals that are reused at the facility are
based only on the amount of the toxic chemical that is added during the year, not the total volume
in the system.  For example, a facility operates a refrigeration unit that contains 15,000 pounds of
anhydrous ammonia at the beginning of the year. The system is charged with 2,000 pounds of
anhydrous ammonia during the year. The facility has therefore "otherwise used" only 2,000
pounds of the covered toxic chemical and is not required to report (unless the facility has
additional "otherwise use" activities of ammonia that, when taken together, exceed the reporting
threshold). If, however, the whole refrigeration unit was recharged with  15,000 pounds  of
anhydrous ammonia during the year, the facility would exceed the otherwise use threshold, and be
required to report.

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.

              However, if a facility is undergoing remediation for an EPCRA Section 313
chemical and it is also being manufactured, processed, or otherwise used by the facility, the
facility may be subject to the reporting requirements. If a listed toxic chemical exceeds one of the
reporting thresholds by  other facility activities, all releases or other waste management activities
of that chemical must be reported, including releases or other waste management activities
resulting from remediation.

              Excavation of material already landfilled does not constitute a release or other
waste management activity for EPCRA Section 313 reporting purposes.  However, any release or
other waste management of a toxic chemical due to remediation must be  reported in Section 5 or
6 of the Form R and should be considered as part of the reportable amount for Form A, if the
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chemical exceeds any reporting threshold as a result of other manufacturing, processing, or
otherwise use activities elsewhere at the facility.  Routine activities (e.g., dredging a lagoon), even
if not performed every year, are not considered to be remedial actions.

3.2.3.3        Recycling Activities

              For on-site recycling and reuse systems, where the same EPCRA Section 313
chemical is recycled and reused multiple times, the recycled quantity should be counted only once
for threshold calculations.  (Please note that for reporting of waste management activities, the
quantity of the EPCRA Section 313 chemical should be counted every time it exits the recycling
unit.) EPCRA Section 313 chemicals recycled off site and returned to the facility should be
treated as newly purchased materials for EPCRA Section 313 threshold determination.

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 category for each listed toxic chemical
                    (manufactured, processed, or  otherwise used) and calculated the quantity
                    for each activity.

              Now, you must sum the usage for each chemical by category, subtract all exempt
quantities, and compare the totals to the applicable thresholds. Each EPCRA Section 313
chemical exceeding any one of the activity thresholds requires the submission of a Form R.
Provided you meet certain criteria you may  file a Form A rather than a Form R.
                                          3-20

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         COMMON ERROR - What if Your Facility Has No Releases and/or Other
             Waste Management Quantities of EPCRA Section 313 Chemicals?
 If you meet all reporting criteria and exceed any threshold for a chemical, you must file a Form R OR Form A for that
 chemical, even if you have zero releases and other waste management activities. Exceeding the chemical activity
 threshold, not the quantity released and/or otherwise managed as waste determines whether you must report.  Note
 that if the release and/or other waste managed quantity is 500 pounds or less you may be eligible to file the
 abbreviated Form A rather than a Form R (see Section 2.8).
               To determine if a chemical exceeds a reporting threshold, you must calculate the
annual activity usage of that chemical.  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 left in the inventory on December 31.  If necessary, adjust the total to
account for exempt activities (see Section 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 category:  manufactured, processed, and otherwise used.  If more
than one activity category applies, the amount associated with each category is determined
separately.

               Table 3-5 presents a work sheet that may be helpful when conducting your
threshold determinations.  Table 3-6 illustrates an example of how the work sheet can be used for
the following example:
                               Example - Threshold Worksheet
 Assume your facility purchases two mixtures that contain xylene in the applicable reporting year.  You purchased
 25,000 pounds of Mixture A (which is 50% xylene per the MSDS) and 110,000 pounds of Mixture B (which
 contains 20% xylene).  Further, you determine that you "process" the entire quantity of Mixture A, while you
 "process" only half of Mixture B and "otherwise use" the other half.  You do not qualify for any exempt activities.  In
 this example, you would have processed a total of 23,500 pounds of xylene (12,500 pounds from activities associated
 with Mixture A and 11,000 pounds from activities associated with Mixture B). You would also have otherwise used
 a total of 11,000 pounds (all from Mixture B). Therefore, you would not have exceeded the 25,000 pound threshold
 for processing; however, you would have exceeded the 10,000 pound threshold for otherwise use and would be
 required to submit a Form R or Form A.
                                              3-21

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                                            Table 3-5  EPCRA Section 313 Reporting Threshold Worksheet
       Facility Name:
       Toxic Chemical or Chemical Category:
       CAS Number:
       Reporting Year:

       Amounts of the toxic chemical manufactured, processed, or otherwise used.
                                                                                                        Date Worksheet Prepared:
                                                                                                        Prepared By:	
Mixture Name or Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source





Total Weight
(Ib)





Percent TRI
Chemical
by Weight





TRI Chemical
Weight
(in Ibs)





Amount of the Listed Toxic Chemical by Activity (in Ibs.):
Manufactured




(A) Ibs.
Processed




(B) Ibs.
Otherwise Used




(C) Ibs.
       Exempt quantity of the toxic chemical that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)





Fraction or Percent Exempt
(if Applicable)





Amount of the Toxic Chemical Exempt from Above (in Ibs.):
Manufactured




(A;) Ibs.
Processed




(Bj) Ibs.
Otherwise Used




(Cj) Ibs.
to
to
       Amount subject to threshold:
       Compare to threshold for EPCRA Section 313 reporting.
                                                                                                           Ibs.
Ibs.
                                                                                                   10.000 Ibs.          25.000 Ibs.

If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your records.
:t)	ibs.
 25.000 Ibs.

-------
                                     Table 3-6.  Sample EPCRA Section 313 Reporting Threshold Worksheet
      Facility Name: ABC Food Company
      Toxic Chemical or Chemical Category: Xvlene (mixed isomers)
      CAS Number: 1330-20-7
      Reporting Year:  1997

      Amounts of the toxic chemical manufactured, processed, or otherwise used.
Date Worksheet Prepared: May 1. 1998
Prepared By:  A.B. Callowav	
Mixture Name or Other Identifier
1. Mixture A
2. Mixture B
3.
4.
Subtotal:
Information
Source
MSDS
MSDS



Total Weight
(Ib)
25,000
110,000



Percent TRI
Chemical
by Weight
50%
20%



TRI Chemical
Weight
(in Ibs)
12,500
22,000



Amount of the Listed Toxic Chemical by Activity (in Ibs.):
Manufactured
—
—


(A) 0 Ibs.
Processed
12,500
11,000


(B) 23,500 Ibs.
Otherwise Used
—
11,000


(C) 11,000 Ibs.
      Exempt quantity of the toxic chemical that should be excluded.
Mixture Name as Listed Above
1. None
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)





Fraction or Percent Exempt
(if Applicable)





Amount of the Toxic Chemical Exempt from Above (in Ibs.):
Manufactured




(Aj) 0 Ibs.
Amount subject to threshold: (A-Aj) 0 Ibs.
Compare to threshold for EPCRA Section 313 reporting. 10.000 Ibs.
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R; retain it for your rec
Processed




(Bj) 0 Ibs.
Otherwise Used




(Cj) 0 Ibs.
(B-Bj) 23,500 Ibs. (C-Q) 1 1,000 Ibs.
25.000 Ibs. 25.000 Ibs.
ords.
to

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   Chapter 4 - Estimating Releases and Other Waste Management Quantities


4.0           PURPOSE


              This chapter is intended to guide the user in developing a systematic approach for

estimating quantities of EPCRA Section 313 chemicals released and otherwise managed from

food processing operations. Figure 4-1 diagrams a recommended approach for estimating

quantities of reportable EPCRA Section 313 chemicals.


              This chapter also includes common EPCRA Section 313 reporting and compliance

issues as they apply to the food processing industry. The general discussion (Section 4.1) is

followed by a presentation of specific examples and issues pertaining to twelve common chemical

use categories in the food processing industry (Section 4.2).  These chemical use categories are:
              •      Water treatment;
              •      Refrigerant uses;
              •      Food ingredients;
              •      Reactants;
              •      Catalysts;
              •      Extraction/carrier solvents;
              •      Cleaning/disinfectant uses;
              •      Wastewater treatment;
              •      Fumigants;
              •      Pesticides/herbicides;
              •      Byproducts; and,
              •      Can making/coating.
                          COMMON ERROR - Other Reporting

 The requirements for EPCRA Section 313 reporting are not mitigated in any way by exemptions for food products
 under other mechanisms such as regulations of the Food and Drug Administration (FDA) and OSHA. Also, you
 should remember that EPCRA has three separate chemical lists: the Section 302 "extremely hazardous substances,"
 the Section 311 "hazardous chemicals," and the EPCRA Section 313 "toxic chemicals." These lists are independent
 of one another. For example, OSHA excludes food products from its MSDS requirements. This exclusion exempts
 them from EPCRA Section 311 reporting, but it does not affect the EPCRA Section 313 requirements.
                                            4-1

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                                                                  STEP1: Prepare Process
                                                                         Flow Diagram
                                                                 STEP 2: Identify Reportable I
                                                                        Toxic Chemical    I
                                                              STEP 2: Identify Release and
                                                                     Other Waste Management
                                                                     Activity Sources
                                                       r
                                                   Source 1
                 Source 2
                                                                    STEPS: Define the
                                                                            Operation
                                                                                 I
                                                                              Source 3
                                                                     Identify Release and
                                                                     Other Waste Management
                                                                     Activity Types	
to
                                                                                                  I          I         I       I        I
Fugitive Point Discharge Underground   Land
  Air    Air     to       Injection    On-Site
              Waterbody
POTW  Transfer
      Off-Site for
                                                                                 Transfer
                                                                                Off-Site for
 Transfer
Off-Site for
 Transfer
Off-Site for
On-Site
Waste
On-Site
Energy
                                                                   Recycling   Energy Recovery  Treatment    Disposal Treatment Recovery
 On-Site
Recycling







I,



	 ^

1
STEP 4: Revii
Data
Estin
1
I

iw Available







* 	









STEP 4: Calculate Amounts of |
Releases and Other Waste 1
Management Activities |
                                     Figure 4-1 Release and Other Waste Management Calculation Approach

-------
4.1           General Steps for Determining Releases and Other Waste Management
              Activity Quantities

              Releases and other waste management activities can be determined by completing
the following four steps. See Figure 4-1 for illustration of the four-step process.

              Step 1)              Prepare a process flow diagram.
              Step 2)              Identify potential sources of chemicals released and/or other
                                  waste management activities.
              Step 3)              Identify on-site releases, off-site transfers, and/or on-site
                                  waste management activity types.
              Step 4)              Determine the most appropriate method(s) to develop and
                                  calculate the estimates for releases and other waste
                                  management activity quantities.

              These steps are described in detail in the following sections.

4.1.1          Step 1: Prepare a Process Flow Diagram

              Preparing a process flow diagram will help you to identify potential sources of
chemicals that are released and/or otherwise managed as waste at your facility. Depending on the
complexity of your facility, you may want to diagram individual processes or operations rather
than the entire facility. The diagram should  show how materials flow through the processes and
identify material input, generation, and output points. Looking at 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, transferred, or otherwise managed.

4.1.2          Step 2: Identify Potential Sources of Chemical Release and/or Other Waste
              Management Activities

              Once a process flow diagram has been developed, you must determine the
potential sources and which EPCRA Section 313 chemicals  may be released and/or otherwise
                                           4-3

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managed from each unit operation and process. Remember to include upsets and routine
maintenance activities.   Potential sources include:
              Relief valves;
              Pumps;
              Tower 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;
Treatment sludge; and
Combustion byproducts.
              Next, you must identify the EPCRA Section 313 chemicals that are released or

otherwise managed from each source.  A thorough knowledge of the facility operations and

processes is required to determine these chemicals. You should also consider whether any of the

EPCRA Section 313 chemicals are coincidentally manufactured at your facility. Table 2-3

identifies EPCRA Section 313 chemicals typically used in the 12 chemical use categories

(described in detail in Section 4.2) common to food processing operations.  This table can be used

as an aid in identifying which chemicals are found in your process. The list may not include all the

chemicals your facility uses that are subject to reporting, and it may include many chemicals that

you do not use.
                                           4-4

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4.1.3          Step 3: Identify On-Site Releases, Off-Site Transfers and/or 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 schematically represents the

possible releases and other waste management activities as they correspond to individual data

elements of the Form R.  Remember to include both routine operations and accidents when

identifying types. 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 source.

              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. Note that 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. However, you should note that some state air
                    quality agencies consider ventilation systems to be a stack or point source.
                    Check with your state agency.

              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 NPDES permit.
                                           4-5

-------
                   Point Sources
               Fugitive Emissions
Toxic Chemical In
Operation
                               T
                       Underground Injection

            Receiving Streams
                                                        Product Containing Toxic Chemical
                                                        Transfer Off Site for Recycling
                                                        Transfer Off Site for Energy Recovery
                                                        Transfer Off Site for Treatment
                                                        Transfer Off Site for Disposal
                                                        On-Site Treatment
                                                        On-Site Energy Recovery
                                                        On-Site Recycling
                      POTW
                                Land on site (landfill, land
                              treatment, surface impoundment)


          Figure 4-2. Possible Release and/or Other Waste Management Types
                           for EPCRA Section 313 Chemicals
                                          4-6

-------
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
       may provide information for all the well classes.

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:

       (1)     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. Leaks from landfills do not need to be reported as a
              release.

       (2)     Land  treatment/application farming - Land treatment is a
              disposal method in which a waste containing a toxic chemical is
              applied to or incorporated into soil. Volatilization of a toxic
              chemical  due to the disposal operation must be included in the total
              fugitive air releases and should be excluded from land
              treatment/application farming to avoid double counting.

              Sludge and/or aqueous solutions that contain biomass and other
              organic materials are often collected and applied to farm land. This
              procedure supplies a nitrogen source for plants and supplies
              metabolites for microorganisms. U.S. 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  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.

       (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.
                             4-7

-------
              You do not have to report quantities of a toxic chemical that are
              released to a surface impoundment as part of a wastewater
              treatment process in this section.  However, if the sludge from the
              surface impoundment contains the toxic chemical, then the toxic
              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.

       (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 disposal may include any spills or leaks  of the
              toxic 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 toxic chemical in water
       transferred to an off-site POTW.  Note that metals and metal compounds
       transferred to a POTW  must also be reported in Section 8.1.

g.      Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form R)
       - All off-site transfers containing the toxic chemical for the purposes of
       waste treatment, disposal, recycling, or energy recovery. Off-site transfer
       for disposal includes underground injection, landfill/surface impoundment,
       other land disposal and transfer to a waste broker. The amount transferred
       off site for disposal must also be reported in Section 8.1.

       Also reported in Section 6.2 would be any residual chemicals in "empty"
       containers transferred off site. U.S. 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 listed toxic chemical in this section.

       Actual  data and a knowledge of the unloading methods at your facility  can
       be used to estimate the quantity of residual chemicals in containers.
       However, U.S. EPA has developed guidance to assist facilities if no site-
       specific information is available. Table 4-1  provides results from
       experimentation on residue quantities left in drums and tanks when
       emptied.  These results  are presented as the mass percent of the vessel
       capacity, and are categorized based on unloading method, vessel material,
       and bulk fluid material properties such as viscosity and surface tension.
                             4-8

-------
                                            Table 4-1
     Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
                             (weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244 - 0.472
0.404
0.032-0.080
0.054
0.020-0.039
0.033
0.031 -0.042
0.038
0.024 - 0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266-0.458
0.403
0.026-0.039
0.034
0.016-0.024
0.019
0.033-0.034
0.034
0.020 - 0.040
0.033
Motor Oil6
1.97-2.23
2.06
1.70-3.48
2.30
0.677-0.787
0.737
0.328-0.368
0.350
0.100-0.121
0.111
0.133-0.191
0.161
0.112-0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment."  Prepared by PEI Associates, Inc., for the U.S. Environmental
Protection Agency, Office of Pesticides and Toxic Substances, Washington DC, Contract No. 68-02-4248. June 30,
1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid
materials. At viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on
this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 97 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactant solution viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
                                                 4-9

-------
The following example describes how the information in the table can be used to
estimate the quantity of an EPCRA Section 313 chemical in water that was used to
clean drums on site.
                         Example - Container Residue

 You have determined that a Form R for an EPCRA Section 313 chemical must be submitted.  The
 facility purchases and uses 1,000 steel drums that contain 55 gallons of a solution that contains
 10% of the chemical. Further, it is assumed that the physical properties of the solution are similar
 to water. The solution is pumped from the drums directly into a mixing vessel and the "empty"
 drums are triple-rinsed with water.  The rinse water is indirectly discharged to a POTW and the
 cleaned drums are sent to a drum reclaimer.

 In this example, it can be assumed that all of the residual solution in the drums was transferred to
 the rinse water. Therefore, the quantity transferred to the drum reclaimer should be reported as
 "zero."

 The quantity of residual  solution that is transferred to the rinse water can be estimated by
 multiplying the mean weight percent of residual water from pumping a steel drum by the weight of
 solution in the drum (density of solution multiplied by drum volume). If the density is not known,
 it may be appropriate to use the density of water (8.34 pounds per gallon):

                (2.29%) (8.34 pounds/gallon) (55 gallons/drum) (1,000 drums)
                = 10,504 pounds solution

 The concentration of the EPCRA Section 313 chemical in the solution is only 10%.

                (10,504 pounds solution) (10%) = 1,050 pounds

 Therefore, 1,050 pounds of the chemical are transferred to the POTW.
h.     On-Site Waste Treatment (Part II, Section 7A of Form R) - All on-site
       waste treatment of reported toxic 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,
       solid); treatment methods or sequence; influent concentrations of the toxic
       chemical; treatment efficiency of each method or sequence; and whether
       efficiency data is based on actual operating data. Metals and metal
       portions of metal compounds 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. Note that only the  metal
       portion of metal compounds should be reported in the Form R.  The
       following example illustrates how Section 7A should be completed for on-
       site treatment of a wastewater stream containing three EPCRA  Section 313
       chemicals.
                               4-10

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                               Example - On-Site Waste Treatment

A process at the facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical A). A
second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal (chemical B)
and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are in the process of
completing separate Form Rs for each chemical.

All wastewater streams are combined and sent to an on-site wastewater treatment system before being released to a
POTW. This system consists of an oil/water separator which removes 99% of chemical A; a neutralization tank
where the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C), and a settling tank where
95% of the metal (chemical B) is removed from the water (and eventually land filled off site).

Section 7A should be completed slightly differently when you file the Form R for each of the chemicals.  The table
accompanying this example  shows how Section 7A should be completed for each chemical.  First, on each Form R
you should  identify the type of waste stream in Section 7A. la as wastewater (aqueous waste, code W). Next,  on each
Form R you should list the code for each of the treatment steps that is applied to the entire waste stream, regardless of
whether the operation affects the chemical for which you are completing the Form R (for instance, the first four
blocks of Section 7A. Ib of all three Form Rs should show: PI 9 (liquid phase separation), C11 (neutralization), PI 1
(settling/clarification),  and N/A (to signify the end of the treatment system). Note that Section 7A. Ib is the only
section of the Form R that is not chemical specific. It applies to the entire waste stream being treated. Section 7 A. Ic
of each Form R should show the concentration of the specific chemical in the influent to the first step of the process
(oil/water separation).  For this example, assume chemicals A, B, and C are all present at concentrations greater than
1%.  Therefore, code "1" should be entered. Section 7A. Id is also chemical specific.  It applies to the efficiency of
the entire system in destroying and/or removing the chemical for the Form R you are currently completing. You
should enter 99% when filing for chemical A, 95% for chemical B, and 100% for chemical C. Finally, you should
report whether the influent concentration and efficiency estimates are based on operating data for each chemical, as
appropriate.
                                               Chemical A
7A.la
W

7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1

7A.ld
99 %

7A.le
Yes No
X
                                               Chemical B
7A.la
W

7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1

7A.ld
95 %

7A.le
Yes No
X
                                               Chemical C
7A.la
W

7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
1

7A.ld
100 %

7A.le
Yes No
X
                                                  4-11

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 Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
 Section 7A. Id refers to the amount of EPCRA Section 313 chemical destroyed and/or removed from the applicable
 waste stream. The amount actually destroyed should be reported in Section 8.6 (quantity treated on site). For
 example, when completing the 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 in Section 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. U.S. 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 that are
                      combusted in an energy recovery unit,  such as an industrial furnace, kiln, or
                      boiler can be reported for energy recovery.  If an EPCRA Section 313
                      chemical is incinerated on site but does not significantly contribute energy
                      to the process (e.g., chlorofluorocarbons), it must be considered on-site
                      waste treatment (see 4.1.3, h. above).  Metals and metal portions of metal
                      compounds will never be treated or combusted for energy recovery. Note
                      that only the metal portion of metal compounds should be reported in the
                      Form R.

               j.      On-Site Recycling (Part II, Section 7C of Form R) - All on-site
                      recycling methods used on listed EPCRA Section 313 chemicals.

               k.      Source Reduction and Recycling Activities (Part II, Section 8 of Form
                      R)1 - Provide information about source reduction and recycling activities
                      related to the EPCRA Section 313 chemical for which releases and/or other
                      waste management activities are being reported.  Section  8 uses some data
                      collected to complete Part II, 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.

                      (1)     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 Subsection 8.1 through 8.8 designation are for the 1997 Form R. Please refer to the current reporting year TRI
Forms and Instructions for any changes.

                                             4-12

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       the quantity reported in Section 8.8 that was released or transferred
       off site for disposal:

       Section 8.1 = Section 5 + Section 6.1 (metals and metal
       compounds) + Section 6.2 (disposal only) - Section 8.8 (release or
       off-site disposal only)

(2)     Quantity Used  for Energy Recovery On-Site (Part II,
       Section 8.2 of Form R) - Estimate the 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.  Test data from trial burns or other monitoring data may be
       used to estimate the quantity of the EPCRA Section 313 chemical
       combusted for energy recovery purposes. If monitoring data are
       not available, vendor specifications regarding combustion efficiency
       may be used as they relate to the reportable EPCRA Section 313
       chemical.  A quantity must be reported in Section 8.2 when a
       method of on-site energy recovery is reported in Section 7B and
       vice versa.  Two conditions need to be met to report the
       combustion of a EPCRA Section 313 chemical in waste as energy
       recovery: the chemical (1) must have a significant heating value  and
       (2) must be combusted in an energy recovery unit, such as a waste
       heat boiler, an industrial furnace, or a kiln.  If a toxic chemical
       which does not have a significant heating value (except metals and
       metal compounds) is combusted  for energy recovery on site, it must
       be considered on-site waste treatment (see  4.1.3.h).  Metal and
       metal compounds in a waste that is combusted or treated on site
       must be considered as on-site disposal because typically they will be
       ultimately  disposed.  Metals and metal portions of metal
       compounds will never be treated or combusted for energy recovery.
       Note that only the metal portion of metal compounds should be
       reported in the Form R. Also, note that  "NA" should be reported
       for EPCRA Section 313 chemicals which are halogens, CFCs, and
       metals.

(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)
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       Two conditions need to be met to report the combustion of a
       EPCRA Section 313 chemical in waste as energy recovery: the
       chemical (1) must have a significant heating value and (2) must be
       combusted in a energy recovery unit, such as a waste heat boiler, an
       industrial furnace, or a kiln. If a toxic chemical which does not
       have a significant heating value (except metals and metal
       compounds) is sent off site for energy recovery, it must be
       considered off-site waste treatment (see 4.1.3.g).  Metal and metal
       compounds sent off site for energy recovery or treatment must be
       considered sent off site for disposal because typically they will
       ultimately be disposed. Metals and metal portions of metal
       compounds will never be treated or combusted for energy recovery.
       Note that only the metal portion of metal compounds should be
       reported in the Form R. Also, note that "NA" should be reported
       for EPCRA Section 313 chemicals which are halogens, CFCs, and
       metals.

(4)     Quantity Recycled On-Site (Part II, Section 8.4 of Form R)  -
       Estimate the quantity of the EPCRA Section 313  chemical recycled
       in wastes on site.  This estimate should be the quantity of the
       chemical recycled in the process for which codes were reported  in
       Section 7C.  A quantity should be reported in Section 8.4 when a
       method of on-site recycling is reported in Section 7C and vice
       versa. To estimate this quantity, you should determine if operating
       data exist which indicate a recovery efficiency and use that
       efficiency value combined with throughput data to calculate an
       estimate. If operating data are unavailable, use available vendor
       specifications.

(5)     Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -
       The quantity reported in Section 8.5 must be the  same as the
       quantity reported in  Section 6.2 for which recycling codes are
       reported. If a quantity is reported in Section 8.8, subtract any
       associated off-site transfers for recycling:

       Section 8.5  = Section 6.2 (recycling) - Section  8.8 (off-site
       recycling)

(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 processes for which codes were reported in Section
       7A, where treatment includes physical removal from a waste
       stream.  To estimate the quantity treated, you should determine  if

                      4-14

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       operating data exist which indicate a treatment (e.g., destruction or
       chemical conversion of an 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 a metal
       compound, metals cannot be reported as treated in Sections 8.6 or
       8.7. Note  that conversion of a metal from one oxidation state to
       another (e.g., Cr(VI) to Cr(III)) is not considered treatment in
       Section 8.6. If operating data are unavailable, use available vendor
       specifications. Section 7A must be completed if a quantity is
       entered into Section 8.6.

(7)     Quantity Treated  Off-Site (Part II, Section 8.7  of Form R) -
       The quantity reported in Section 8.7 must be the same as the
       quantity reported in Section 6.2 for which treatment codes are
       reported plus quantities sent to a POTW as reported in Section 6.1,
       except for metals 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 a metal compound, metals cannot
       be reported as treated in Sections 8.6 or 8.7. Quantities of metals
       reported in Section 6.1 and 6.2 as being treated should be reported
       in Section  8.1 (Quantity Released) unless the facility has knowledge
       that the metal is being recovered.

(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
       disposed) that are associated with normal or routine production
       from those quantities 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:

       •       Remedial actions;
       •       Catastrophic events such as earthquakes, fires, or floods; or
       •       One-time events not associated with normal or routine
              production processes.
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                             The quantity reported in Section 8.8 should not be included with
                             quantities reported in Part II, Sections 8.1 through 8.7 of Form R,
                             but should be included in Part II, Sections 5 and 6 of Form R as
                             appropriate.

                             Spills that occur as a routine part of production operations and
                             could be reduced or eliminated by improved handling, loading, or
                             unloading procedures are included in the quantities reported in
                             Section 8.1 through 8.7 as appropriate.  Releases and off-site
                             transfers from remediation of a 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.
                                         COMMON ERROR - Double Counting

                              Releases and/or other waste management activities should not be inadvertently
                              "double counted." A single wastewater discharge should not be listed as both a
                              release to water (on site) and a discharge to POTW (off site). Similarly, a
                              release to land should not be listed as both a release to land (on site) and a
                              transfer to an off-site landfill. Estimates of releases and other waste
                              management activities should be prepared for Sections 5 through 7 of the Form
                              R. For the most part, 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 be taken to avoid double counting.
4.1.4          Step 4: Determine the Most Appropriate Method(s) to Develop and Calculate
               the Estimates for Releases and Other Waste Management Activity Quantities

               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.
U.S. EPA has identified four basic methods that may be used to develop estimates (each estimate
                                             4-16

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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. A more detailed discussion of selected calculation techniques is presented in
Appendix B. U.S. EPA does not require you to conduct additional sampling or testing for
EPCRA Section 313 reporting; however, you are required to use the best, readily available
information available to determine the method  that will result in the most accurate estimate. For
example, it may not be appropriate to use emission factors or engineering calculations if more
accurate data, such as  stack testing results, are  available. You are required to identify only the
primary method used for each estimation.

              Based on site-specific knowledge and potential data sources available, you should
be able to determine the best method for calculating each release and other waste management
activity quantity.

              Many potential sources of data exist for these (and other) methods of developing
estimates. Table 4-2 presents potential  data sources and the estimation methodology in which they
are most likely to be used.

              Once all potential sources, release and other waste management activity types and
estimation methods have been determined an estimate for each chemical can be developed
corresponding to the elements on Form R.
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                                         Table 4-2
        Potential Data Sources for Release and Other Waste Management
                                        Calculations
                                       DATA SOURCES
 Monitoring Data
 •   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

 Emission Factors
     AP-42 emission factors
     Facility or trade association derived chemical
     specific emission factors
                                  Mass Balance
                                  •   Supply records
                                  •   Hazardous material inventory
                                  •   Air emissions inventory
                                  •   Pollution prevention reports
                                  •   Hazardous waste manifests
                                  •   Spill event records
                                  Engineering Calculations
                                  •   Volatilization rates
                                  •   Raoult's Law
                                  •   Henry's Law
                                  •   Solubilities
                                  •   SOCMI or trade association emission factors
                                  •   Facility or trade association derived non-chemical
                                     specific emission factors.
4.1.4.1
Monitoring Data or Direct Measurement (code M)
              Using monitoring data or direct measurements is usually the best method for

developing chemical release and/or other waste management activity quantity estimates. Your

facility may be required to perform monitoring under provisions of the Clean Air Act (CAA),

Clean Water Act (CWA), RCRA, or other regulations. If so, 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 is available or if

you believe the monitoring data are not a representative sample, you must decide if another

estimation method would give a more accurate  result.
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                                   Example - Monitoring Data

 Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in the
 discharge is 2 mg/L.  The wastewater treatment facility processed 1.5 million gallons of water in 1997. The treated
 wastewater is discharged to an off-site POTW.  The amount of copper transferred off site to the POTW (for
 Section 6.1 of the Form R) is estimated as follows:

 Amount of copper transferred

                    = (2 mg/L) I	i	1  I ———1  |	1  (1,500,000  gal/yr)
                               ( 1,000 mgj  ( 453.59 g/  ( 0.2642 gal/
                 = 25 Ibs/yr
                         COMMON ERROR - Treatment Efficiencies

 Vendor data on treatment efficiencies often represent ideal operating conditions. You should adjust such data to
 account for downtime and process upsets during the year that would result in lower efficiencies.  Remember that
 efficiencies reported by vendors are often general and may not apply to specific chemicals. For example, an
 incinerator or flare may be 99.99% efficient in destroying organic chemicals, but will have a 0% efficiency in
 destroying metals.
4.1.4.2        Mass Balance (code C)


               A mass balance involves determining the amount of a toxic chemical entering and
leaving an operation.  The mass balance is written as follows:
                              Input + Generation = Output + Consumption
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.
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                      Generation identifies those chemicals that are created during an operation
                      (manufactured, including coincidental manufacturing). For example, when
                      nitrogen sources are used in biological wastewater treatment systems,
                      additional ammonia may be coincidentally manufactured.

                      Output means any avenue by which the toxic chemical leaves the operation.
                      Output may include on-site releases and other waste management activities
                      to the environment; transfers for treatment, storage, or disposal; or the
                      amount of chemical that leaves with the final product.  In a can coating
                      operation, for example, pigments in the paint may leave the operation as
                      part of the product (the coating on the can) and on paint spray booth filters
                      sent for disposal.

                      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 a neutralization during wastewater treatment.
               The mass balance technique may be used for manufactured, processed, or
otherwise used chemicals. It is typically most useful for "otherwise used" chemicals that 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 - Mass Balance

 A facility uses a volatile EPCRA Section 313 chemical as a refrigerant and adds 20,000 pounds to the refrigeration
 system in 1997 (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 1997.  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
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            COMMON ERROR - Mass Balances for Otherwise Used Chemicals
 Most reportable chemicals in the food processing industry are classified as "otherwise used" by the EPCRA Section
 313 definition.  Such chemicals rarely leave the facility with the product.  In these instances, all throughput may be
 lost during processing through on-site releases to air, water, or land, or it may be shipped off site in wastes.  Thus, the
 entire throughput is often reportable on Form R as releases or other waste management activities to various media.
 Be sure to consider the entire throughput in these circumstances and partition it as appropriate. A mass balance may
 be the best starting point from which to estimate the releases and other waste managed quantities.
4.1.4.3        Emission 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.

               Emission factors are available in U.S. 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 the following Internet site:

               •       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.
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                                  Example - Emission Factors

 Example 1:
 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.

 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:

                 (0.024 lbs/103 gal) (1,000,000 gallons) and (0.061 lbs/103 gal) (1,000,000 gallons)
                 = 24 and 61 Ibs of formaldehyde

 NOTE: No. 6 fuel oil contains other listed chemicals that should be considered for EPCRA Section 313 reporting.

 Example 2:
 The output from a fermentation process at a facility that produces red wine is 100,000 gallons per year (gal/yr) of
 fermented juice. AP-42 provides ann-butyl alcohol emission factor for this process of 5.5 x 10"5 pounds of n-butyl
 alcohol emitted per 1,000 gallons of fermented juice produced (5.5 x  10"5 lb/103 gal). Annual air emissions of n-
 butyl alcohol from this process are estimated as follows:

 The amount of n-butyl alcohol released to air

                        (100,000 gal/yr fermented juice) (5.5 x 10 "5 Ibs n-butyl alcohol/103 gal
                        fermented juice)

                        0.0055 Ibs/yr
4.1.4.4        Engineering Calculations (code O)
               Engineering calculations are assumptions and/or judgements used to estimate

quantities of listed toxic 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 toxic chemical in

question. Engineering calculations rely on the process parameters; you must have a thorough

knowledge of your facility operations 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.
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              Non-chemical-specific emission factors, Synthetic Organic Chemicals
Manufacturing Industry (SOCMI) emission factors, industry-determined emission factors for
processes or equipment, and site-specific emission factors also can be used as discussed in Section
4.1.4.3, but must be classified as "engineering calculations" forEPCRA Section 313 reporting.
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                                Example - Engineering Calculations

Example 1:
Stack monitoring data are available for xylene but you are required to report for toluene. Toluene is used in the same
application as xylene at your facility. You can estimate the emissions of toluene by adjusting the monitoring data of
xylene by a ratio of the vapor pressure for xylene to toluene. This example is an engineering calculation based on
physical properties and process operation information:

From facility stack monitoring data, an estimated 200 Ibs of xylene are released as air emissions during the reporting
year.  Toluene is also present in the air emissions, but not monitored. The stack operates at approximately 125°C.
Based on literature data, the vapor pressures at 125°C for toluene is 1.44 atmospheres and for xylene is 0.93
atmospheres. Using a ratio of the vapor pressures, the amount of toluene released as air emissions from the stack can
be calculated:

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

                 X Ibs/yr toluene   =       (200 Ibs/yr xylene) (1.44 atm toluene)
                                                            (0.93 atm xylene)

Completing the calculation, the facility determines that 310 Ibs of toluene were released as stack air emissions during
the reporting year.

Example 2:
A can making/coating process uses 10,000 gallons per year of a paint that is 3% xylene by volume.  All of the xylene
in the paint is assumed to evaporate during the coating operation. The coating process is equipped with a fume
collection hood that captures 80% of the paint vapors.  The remaining 20% of the paint vapors are assumed to be
released as fugitive air emissions.  The collection hood routes the paint vapors to  an incinerator that is vented to the
atmosphere and has a destruction efficiency of 99% for xylene. The specific gravity of xylene is 0.86 and the density
of water is 8.34 Ib/gal. Fugitive air emissions and stack air emissions may be estimated as follows:

                 1.       The total amount of xylene released to air (assumed to be the total amount of xylene in
                         paint)

                         =        (10,000 gal/yr paint) (3% xylene) (0.86 xylene specific gravity) (density of
                                  water, 8.34 Ibs/gal)

                         =        2,152 Ib/yr xylene evaporated from paint operations

                 2.       The amount of xylene released as fugitive air emissions

                                  (2,152 Ibs/yr) (20%)
                                  430 Ibs/yr

                 3.       The amount of xylene released as point air emissions

                                  (2,152 Ibs/yr) (80% capture efficiency) (100% - 99% incinerated)
                                  17  Ibs/yr
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4.1.4.5        Estimating Release 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
element of the Form R. The recommended approach is that you estimate amounts from all
sources at your facility to each type as identified by the elements of Form R. Table 4-3 presents a
work sheet that may be helpful in compiling this information.  Keep in mind if the total annual
reportable quantity, corresponding to the total of the quantities in Part II, Sections 8.1 through
8.7, on the 1997 version of the Form R, is less than 500 pounds, you may use Form A rather than
Form R.

              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 destruction and removal
efficiency for the chemical  in the treated waste stream, and the concentration of the chemical  in
the influent to treatment. You should report treatment methods that do not actually destroy or
remove the chemical by entering "0" for removal efficiency.  Similarly, on-site energy recovery
methods and on-site recycling methods must be reported in Section 7B and 7C, respectively.
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  Table 4-3  Release and Other Waste Management Quantity Estimation Worksheet
Facility Name:
Toxic Chemical or Chemical Category:
CAS Number:
Reporting Year:
Date Worksheet Prepared: 	
Prepared by:
ON SITE
Release or Other Waste Management Activity Type
FUGITIVE AIR (Sections 5.1 and 8.1 of Form R)
Equipment Leaks
Process Areas
Evaporative Losses (spills, surface impoundments)
Total =
STACK AIR (Sections 5.2 and 8.1 of Form R)
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
Amount (Ibs)











RECEIVING STREAM/WATER BODY DISCHARGE (Sections 5.3 and 8.1 ofFormR)
Storm water Discharge
On-Site Treatment Plant Discharge
Total =
ON-SITE UNDERGROUND INJECTION (Sections 5.4 and 8.1 of Form R)
ON-SITE LAND (Sections 5.5 and 8.1 of Form R)
Landfill
Land Treatment/Application Farming
Surface Impoundment
Other
Total =










ON-SITE ENERGY RECOVERY (Section 8.2 of Form R)
ON-SITE RECYCLING (Section 8.4 of Form R)
ON-SITE TREATMENT (Section 8.6 of Form R)
Basis of Estimate

























OFF SITE
Release or Other Waste Management
Activity Type
Amount (Ibs)
Basis of Estimate
DISCHARGE TO PUBLICLY OWNED TREATMENT WORKS (Section 6.1 of Form R)
OFF-SITE ENERGY RECOVERY (Section 6.2,
energy recovery only, and also 8.3 of Form R)
OFF-SITE RECYCLING (Section 6.2 recycling only
and also 8.5 of Form R)
OFF-SITE TREATMENT (Section 6.1 + 6.2 treated
only and also 8.7 (except metals) of Form R)
QUANTITY RELEASED and/or OTHER WASTE
MANAGEMENT ACTIVITY TYPE- OFF-SITE
(Section 6.2 disposal & Section 6.1 (metals only) and
Section 8.1








Off-Site Location
(name)





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4.2           Process Descriptions (Chemical Use Categories)

              This section describes the 12 common chemical use categories found in the food
processing industry.  Each subsection lists the commonly used EPCRA Section 313 chemicals,
gives an overview of the process involved, identifies the appropriate chemical activities and
reporting thresholds, describes methods for estimating quantities of chemicals released and/or
otherwise waste managed, and discusses common reporting errors.

4.2.1         Water Treatment

              Commonly Used EPCRA Section 313 Chemicals - Chlorine, chlorine dioxide

              Process Description - Chlorine is used to treat process water at food processing
facilities. It is received as a compressed gas and added to process water as a disinfectant.  The
treated water uses include:

              •       Component of a food product;
              •       Wash or convey food products;
              •       Control odor in fish meal processing; and
              •       Cleaning purposes.

At a few plants, chlorine dioxide is manufactured by reacting liquid sodium chlorite, chlorine gas,
and water for use in similar processes. During water treatment, the facility may coincidentally
manufacture listed chemicals, such as chloroform,  as byproducts.

              Reporting Threshold - Depending upon the application, these chemicals may be
manufactured, processed, or otherwise used,  and therefore  subject to different reporting
thresholds.  The most common situation is when purchased chlorine is used to treat water for
washing or conveying fruits or vegetables or for cleaning equipment. In this case, the chlorine is
otherwise used as a chemical processing aid, and subject to the 10,000-pound reporting threshold.
Production of chlorine dioxide on site is considered manufacturing (produced for on-site
use/processing), and should be applied to the 25,000-pound manufacturing threshold. If the
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chlorine dioxide is subsequently used as a disinfectant, the quantity used should also be applied to
the 10,000-pound otherwise used threshold.

              Estimating Release and Other Waste Management Quantities-  The only
release that would be expected in this application is small fugitive air releases of chlorine and
chlorine dioxide. These releases occur from sources such as leaks in valves and fittings and losses
during cylinder changeovers.  For the quantities of chlorine typically used for water treatment
purposes, 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
chlorine are handled, these fugitive releases can be estimated using the SOCMI factors presented
in Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form.

              No releases are typically expected of either of these chemicals to water. Chlorine
reacts very quickly with water to form HOC1, Cl", and FT.  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 occur under normal
circumstances.  Releases of chlorine dioxide to water should be considered but are unlikely based
on its strong oxidizing potential and the constant supply of organics in the waste  stream.
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                                 Example - Chlorine Calculations
Example Release Estimate:

Once C12 is introduced into water or wastewater, it is transformed to HOC1 or other compounds.
The equilibrium constant, Keq, for the reaction is 4.5 x 10"4 at 25° C; therefore:

               Keq  =  4.5 x  10-  = PI [Cl 1 [HOC1]
                                              [C1J
The brackets in Equation 1 represent the concentration of the chemical species in terms of gram moles/L.  At a pH
above 4, the reaction is essentially complete and little C12 remains. In addition, HOC1 may further dissociate into
OC1" and react with ammonia in water to form chloroamines. C12 also will react directly with other compounds in
water.

Releases of chlorine as C12 to water or POTW will therefore be very small. By applying the C1/HOC1 equilibrium
relationship, C12 releases to water can be calculated.  The following example presents C12 releases for a hypothetical
chlorination process in which 100,000 pounds of C12 gas is used during the year, the applied dose is 10 mg/L (this is
an extremely high value), the pH of the discharge is 8, and the facility chlorinates incoming well water and discharges
the water to a stream.

                                  „   _             [Molecular weight of C12 is 71 gms/mole]
  Applied dose   =	
                    71,000 mg C12/1 mol C12
                 = 1.41 x 1Q-4 mol Cl/L = [C12] applied

The goal of this calculation is to find the equilibrium concentration of C12 after its reaction with water (i.e., the [C12]
equilibrium).  From the stoichiometry of the C12/H2O reaction:

                 [C1-] = [HOC1] at equilibrium

Also from stoichiometry:

                 [C1-] = [C12] applied - [C12] equilibnum = 1.41 x lO'4 - [C12] equilibrium

The pH of the water is maintained at a level of 8; therefore:

                 [H+] = 1 x lO'8

Substituting into Equation 1:

                                    (1 x  i(r8) (1.41  x  icr4  - [C1J equilibrium)2
           Keq   =  4.5  x  10 4  =  	  equilibrium
                                                        [C1J
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                             Example - Chlorine Calculations (cont.)

Solving for [C12] equilibrium yields:

                 C12 equilibrium = 4.42 x 10'13 mol C12/L

Translating this into a mass-per-volume basis:

                 C12 equilibrium   = (4.42 x lO'13 mol CL/L) (71 g Cl2/mol) (1000 mg/L)
                                 = 3.14x  10-8mgCl2/L
The applied C12 dose is 10 mg/L, and the remaining C12 after equilibrium is 3.14 x 10"8 mg/L.  The fraction of the
applied C12 dose remaining is therefore:
                 T^   .•     r. f^i       • •         3.14 X 10               1/\-
                 Fraction of CL remaining  =   	   =  3.14 x 10
                               2                     10
                 C12 releases to water = (100,000 Ib) (3.14 x lO'9) = 0.0003 Ib

Similar calculations can be performed for other pH levels at an applied C12 dose of 10 mg/L:
NAVY2\
0910-
Ol.docp
H
8
6
4


C12 usage,
Ib
100,000
100,000
100,000



[H+]
1 x ID'8
1 x ID'6
1 x ID'4

C12 equilibrium
concentration,
mg/L
3.14x ID'8
3.14x 10'6
3.14x 10'4

Fraction of
applied C12 dose
remaining
3.14x ID'9
3.14x ID'7
3.14x ID'5



C12 release, Ib
0.0003
0.03
3
                                 COMMON ERROR - Reporting

The most common reporting error for chlorine or chlorine dioxide treated water is reporting discharges or transfers
when the chemicals have been treated on site.  As indicated above, if the discharge is maintained at a pH above 4,
none of these chemicals are expected to be released to water streams. Although some facilities may monitor the
residual chlorine concentration in their water, this parameter does not represent the C12 concentration.  Residual
chlorine is the sum of the C12, HOC1, and OC1" concentrations. Because the C12 concentration will be negligible under
neutral pH conditions, direct discharges to water or transfers to a POTW may be reported as zero. Note that if your
facility performs no other release and/or other waste management practices involving chlorine, you may be able to file
a Form A rather than a Form R.
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4.2.2          Refrigerant Uses

              Commonly Used EPCRA Section 313 Chemicals - Ammonia, ethylene glycol,
Freon 113, dichlorodifluoromethane (CFC-12), dichlorotetrafluoroethane (CFC-114),
chlorodifluoromethane (HCFC-22).

              Process Description -  Ammonia and (to a much lesser extent) ethylene glycol are
used as heat exchange media in refrigeration processes. These chemicals are continuously reused
in closed-loop units. The ammonia is handled as a gas, while the ethylene glycol is handled as a
liquid.  Both chemicals must be added to refrigeration systems to replace amounts lost through
leaks or when purging a section of the system for maintenance.

              Reporting Threshold - Refrigerants are otherwise used (as a manufacturing aid)
and are therefore subject to the 10,000-pound reporting threshold.

              Estimating Release and Other Waste Management Quantities - Ammonia is a
volatile chemical and will be released to air through system filling operations, relief vents, and
leaks from valves and fittings.  All the anhydrous ammonia lost through these means should be
reported as fugitive air releases. If the system is vented to the air during system maintenance, this
amount should also be reported as a fugitive air release. The lines may be bled directly into water
during system maintenance. In this situation, the anhydrous ammonia transferred to water should
be estimated and reported as transfers to a POTW or directly discharged to water. Note that
beginning with reporting year 1994, U.S. EPA revised the ammonia listing as follows: "ammonia
(includes anhydrous ammonia and aqueous ammonia from water dissociable salts and other
sources; 10% of total aqueous ammonia is reportable under this listing)." U.S. EPA has published
guidance for reporting ammonia and ammonium salts (Appendix C). This guidance  states the
total ammonia that should be considered for reporting can be estimated by summing  all anhydrous
ammonia and 10% of the aqueous ammonia.
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              Ethylene glycol is used in heat exchange applications and released as a result of
other leaks in the system piping or drainage of the system for maintenance purposes.  Releases
and waste management types will be limited to wastewater and non-aqueous liquid waste streams.

              Releases and other waste management activities in refrigeration applications are
best estimated by mass balance. Total release and other waste management amounts are
equivalent to the amounts of the chemicals that have been added to the system to replace losses.
Ammonia is usually released to air, whereas ethylene glycol will usually be transferred to water .
When ammonia is bled to water, an aqueous solution is formed that contains both ammonia and
the ammonium ion. Ammonia estimates obtained from calculations using mass balance equations
are sufficient for reporting requirements if monitoring data are not available. The amount of
ammonia released to air can then be estimated as the difference between total usage and the
amount bled to water.

              If a facility "manufactures," "processes," or "otherwise uses" aqueous ammonia,
the quantity applied toward threshold determinations for the ammonia listing is 10% of the total
quantity of the aqueous ammonia "manufactured," "processed," or "otherwise  used." The
quantity reported when calculating the amount of ammonia that is released, transferred, or
otherwise managed as  waste is 10% of the total quantity of aqueous ammonia released, managed
as waste, or transferred.  See Appendix C for more detailed information.
                      COMMON ERROR - Threshold Determination
 The most common error in refrigerant uses is basing the threshold determination on the total amount of the chemicals
 in the system.  The throughput to be used for a threshold determination is only the amount of new chemicals added to
 the system during the year (i.e., to charge a new system or to replace amounts lost through leaks and maintenance
 activities on an existing system). Thus, though a refrigeration system may contain more than 10,000 pounds of
 ammonia, an EPCRA Section 313 report is not required unless more than 10,000 pounds of new ammonia are added
 to the system during the year. The quantities of the chemicals added during the year can best be determined from
 purchase and inventory records.
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4.2.3         Food Ingredients

              Commonly Used EPCRA Section 313 Chemicals - Phosphoric acid, peracetic
acid, various listed food dyes (e.g., C.I. Food Red 5, C.I. Food Red 15), and various listed
metal/metal compounds (e.g., zinc, zinc compounds, copper, copper compounds, manganese,
manganese compounds, selenium).

              Process Description - Various EPCRA Section 313  chemicals are present in food
ingredients and become part of the final food product.  Several reportable metal and metal
compounds are used as formulation components in prepared feeds, such as zinc compounds,
which are used as an additive in  dog food. Phosphoric acid may be used as a food ingredient in
the preparation of baking ingredients and soft drinks.  Several food dyes are also on the list of
EPCRA Section 313 chemicals.  Food ingredients are handled as solids or liquids and may
undergo various types of physical processing such as blending.

              Reporting Threshold - Food ingredients are processed (as a formulation
component) and are therefore subject to the 25,000-pound reporting threshold, regardless of
whether they are regulated by the FDA.

              Estimating Release and Other Waste Management Quantities - Most
chemicals used as food ingredients are not volatile, and since they become part of the  final
product, only minor release and  otherwise managed quantities would be expected from their
processing.  If the total quantity  released and otherwise managed does not exceed 500 pounds,
you may be eligible to submit the abbreviated Form A.  Engineering judgment can generally be
used to  estimate releases to air or water from handling or mixing operations. The largest source
of release may be equipment cleanup (e.g., tank cleaning, clean-in-place systems). Factors for
estimating such releases can be found in Estimating Releases and Waste Treatment Efficiencies
for the Toxic Chemical Release Inventory Form.  For storage tank losses (including loading and
unloading) of chemicals handled as liquids, estimates of air releases can be made using methods
described  in Compilation of Air Pollutant Emission Factors, AP-42.  Storage tank losses are
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considered point air releases for EPCRA Section 313 reporting. Portions of spills of liquids could
be reported as fugitive air releases, discharges to wastewater, or off-site transfers depending upon
the volatility of the chemical and the ultimate disposal of the material.

               Any phosphoric acid in facility water (e.g., from washdowns or spills) is likely
neutralized before discharge or transfer.  If the pH is maintained above 6, the acid is considered
completely neutralized and you may report zero releases or transfers.  Estimates of releases of
phosphoric acid to water that do occur can be based upon the pH of the wastewater effluent.
Operating records showing the periods during which the pH falls below 6 can be a good basis for
estimating these discharges. Releases can be calculated using the effluent flow rate during the
excursion period, the duration of the excursion, and the average pH during the excursion period.
More information on estimating acid releases can be found in Estimating Releases for Mineral
Acid Discharges Using pH Measurements.
                              COMMON ERRORS - Reporting

 One potential reporting error in food ingredient applications is incorrectly submitting a Form R for saccharin. A
 Form R or Form A is only required for saccharin if the facility manufactures the chemical on site. Processing of
 saccharin as a food ingredient is not subject to EPCRA Section 313 reporting.
 A second potential error is failure to estimate releases and/or other waste management activities of food ingredient
 chemicals that occur during storage, transfer, and mixing operations.  Total usage of the chemicals can be determined
 from purchasing records. Engineering judgment can be used to estimate the minor releases and/or subsequent waste
 management activities that may occur during these operations.
4.2.4          Reactants

               Commonly Used EPCRA Section 313 Chemicals - Ammonia, chlorine, ethylene
oxide, phosphoric acid, propylene oxide.

               Process Description - Various chemicals may be processed as reactants in the
food industry.  These chemicals are raw materials or starting materials for food products.  For
example, ethylene oxide is used as a reactant in the processing of starch to improve the viscosity
of the product. Chlorine, chlorine dioxide, and benzoyl peroxide are used as treatments for flour;
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phosphoric acid is processed in the manufacture of certain food products such as pet foods.
Ammonia is used as a starter component in the batch process manufacture of cheese. Propylene
oxide is reacted with cornstarch to produce hydroxyalkyl starches. These chemicals may be
handled as gases under pressure, liquids, or aqueous solutions.

              Reporting Threshold - Depending upon the nature of the process, these
chemicals are either processed (as a reactant) and therefore subject to the 25,000-pound reporting
threshold, or otherwise used (as a chemical processing aid) and subject to the 10,000-pound
reporting threshold.  The key difference is whether the chemical intentionally leaves the facility
with the product.  In the examples given above, ethylene oxide, phosphoric acid, and propylene
oxide are processed. Chlorine, chlorine dioxide, benzoyl peroxide, and ammonia are otherwise
used.

              Estimating Release and Other Waste Management Quantities -  Most of the
throughput of these chemicals are expected to be consumed during the reaction.  Minor fugitive
air releases of volatile  chemicals such as ethylene oxide, ammonia, and chlorine will occur from
leaks in valves and fittings and losses during cylinder changeovers. If significant quantities of
these chemicals are handled, these fugitive releases can be estimated using the SOCMI  factors
presented in Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical
Release Inventory Form.  If only small quantities are handled, engineering judgment should be
used to estimate fugitive releases (e.g., based on the volume of the connecting hose and the
number of changeovers).

              Estimates of air releases from storage tank losses should be made as discussed in
Section 4.2.3 (including loading and unloading of chemicals handled as liquids).

              Spills are the most likely source of liquid solution releases or other waste
management activities of phosphoric acid or aqueous ammonia. Phosphoric acid is generally
neutralized to a pH of 6.0 or higher before discharge; therefore, you may be able to report zero
                                           4-35

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releases as discussed in Section 4.2.3.  Guidance on estimating ammonia releases is discussed in
Section 4.2.2.
                             COMMON ERROR - Reporting
 The most common reporting error in this application is failure to account for minor fugitive air releases during
 storage and transfer of volatile chemicals such as ethylene oxide, chlorine, or ammonia before their use as reactants.
4.2.5         Catalysts

              Commonly Used EPCRA Section 313 Chemicals - Nickel/nickel compounds

              Process Description -  Certain EPCRA Section 313  metals may be used as
catalysts to help promote a desired reaction in food processing operations. For example, a nickel
catalyst may be used to aid in the hydrogenation of vegetable oil.  Such chemicals are not
consumed in the reaction and do not become part of the product.  The catalyst may eventually
become spent or contaminated and require disposal or regeneration.

              Reporting Threshold - Catalysts are otherwise used (as a chemical processing
aid) and are subject to the 10,000-pound reporting threshold.

              Estimating Release and Other Waste Management Quantities - Catalysts are
typically not volatile and do not become part of the final product. Therefore, the total amount of
chemical added to the system during the year is ultimately released or otherwise managed via
wastewater or solid waste with a small fraction of the catalyst being lost through handling and
processing. Typically, the bulk of the spent catalyst is shipped off site for regeneration. Releases
or other waste management activity via wastewater would likely only occur from plant
washdowns and should be minor.
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                              COMMON ERRORS - Reporting

 The most common reporting error in catalyst usage is basing the threshold determination on the total amount of the
 chemical in the processing system. Similar to refrigerant chemicals, the throughput to be used for a threshold
 determination is only the amount of new chemical added to the system during the year. Therefore, the processing
 system may contain more than 10,000 pounds of catalyst, but an EPCRA Section 313 report is not required unless
 more than 10,000 pounds of new catalyst is added to the system during the year. The quantities of catalyst added
 during the year can best be determined from purchase and inventory records.
 Another possible error would be submitting a Form R or Form A for aluminum oxide, which is used as a catalyst in
 manufacture of edible fats and oils. Beginning with reporting year 1989, aluminum oxide is reportable only when
 handled in fibrous forms.  Thus, its use as a catalyst in food processing is not subject to a threshold determination.
4.2.6         Extraction/Carrier Solvents

              Commonly Used EPCRA Section 313 Chemicals - n-butyl alcohol,
dichloromethane, phosphoric acid, n-hexane, cyclohexane, tert-butyl alcohol.

              Process Description - Certain EPCRA Section 313 chemicals may be used as
extraction or carrier solvents in the food processing industry. For example, n-butyl alcohol may
be used as a carrier solvent for spices. Dichloromethane may be used as an extraction solvent for
hops and flavorings and to remove caffeine from coffee. Phosphoric acid may be used to remove
impurities from vegetable oil. n-Hexane is commonly used to extract the oil from soybeans.
Extraction and carrier solvents are normally  handled as liquids and do not become part of the final
food product.

              Reporting Threshold - Extraction and carrier solvents are otherwise used  (as a
chemical processing aid) and are subject to the 10,000-pound reporting threshold.

              Estimating Release and Other Waste Management Quantities - Releases and
other waste management activities of these chemicals may be through any media depending on the
physical state of the chemical and the process in which it is used.  Release and waste management
amounts are often best estimated by a mass balance, where it is generally reasonable to assume
that the total amount released or managed will equal the usage of the chemical.  It is often
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possible to use a mass balance in conjunction with monitoring data to estimate the release or other
waste managed amount to one medium. This can be accomplished by subtracting the difference
between total usage and the amount known to be released and/or otherwise waste managed to
other media.

              If volatile  solvents such as dichloromethane are used, the quantity released to the
air is equal to total solvent usage for these purposes minus any amounts that are captured or
destroyed by control devices (such as carbon absorbers or thermal oxidizers). A mass balance
may be the best method for estimating these releases.  If no controls exist, all the solvent should
be reported as fugitive or point air releases. If destructive controls are used (e.g., thermal
oxidizers), the amount of solvent destroyed can be determined using engineering assumptions of
the solvent quantity reaching the control device and its destruction efficiency. If nondestructive
controls are used (e.g., absorbers), the amount of the captured solvent in wastes sent off site for
recycling, treatment, or disposal can be determined through analysis of these wastes. The quantity
released to air is the difference between total usage  and the amount captured and/or destroyed.

              Note that the treatment efficiency reported in Section 7A of Form R refers to the
waste stream concentrations sent to the treatment system and the corresponding effluent from the
system, while the quantity reported in Section 8.6 refers to the quantity actually destroyed.  If a
system transfers  100% of the chemical from an air stream to a water stream without any
destruction, the efficiency of the system in removing the chemical from the air stream should be
reported as 100% in Section 7A; however, "zero" should be  reported in Section 8.6 because the
chemical has not been treated for destruction. Water releases, or subsequent waste management
from control devices can be estimated from monitoring data.

              In aqueous extraction processes, the EPCRA  Section 313 chemical may be
transferred to water. If this medium is the only  one to which it is transferred, a mass balance may
be the best method for estimating the quantity discharged or  otherwise managed.  Waste solvents
are often shipped off site  for disposal, combustion for energy recovery, treatment, or recycling. If
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releases and/or waste management activities involve several media, wastewater monitoring data or
permit requirements along with waste manifests from off-site transfers can be used to estimate the
release and other waste management quantities.
                              COMMON ERRORS - Reporting

 A common reporting error for extraction or carrier solvents is failure to account for all the chemical usage through
 release and/or other waste management. Typically, none of the solvent should be assumed to remain with the food
 product.  All usage should be accounted for through air releases, amounts captured or destroyed in control devices,
 and amounts sent off site.  The total usage is best determined from purchasing records for the solvent.
 Another common reporting error is overestimation of the amount of solvent in waste sent off site.  This quantity
 should be based on analysis of the waste. Most likely, the waste is not 100% solvent, and the total amount of waste
 shipped off site must be adjusted for the solvent concentration.  Many facilities that receive waste solvents will
 provide information on the quantity of solvents present. This information is a key component of a mass balance for
 estimating solvent release and/or other waste management quantities.
4.2.7          Cleaning/Disinfectant Uses

               Commonly Used EPCRA Section 313 Chemicals -  Chlorine, chlorine dioxide,
formaldehyde, nitric acid, phosphoric acid, 1,1,1-trichloroethane.

               Process Description -  Nitric acid and phosphoric acid in their liquid form may be
used to clean process equipment in the food industry.  Chlorine can also be used for cleaning
purposes by reacting it with sodium hydroxide to form a sodium hypochlorite solution. Chlorine
dioxide is used as a germicidal disinfectant or sanitizer. Formaldehyde is used as a sterilant to
limit microbial action in beet sugar processing equipment.

               Reporting Threshold - The acids and formaldehyde are otherwise used in this
application (ancillary or other use) and are therefore subject to the 10,000-pound reporting
threshold.  Chlorine used to produce sodium hypochlorite is processed (as a reactant), and has a
25,000-pound reporting threshold.

               Estimating Release and Other Waste Management Quantities - Nitric acid and
phosphoric acid in cleaning applications are usually collected and released or otherwise waste
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managed via water.  If the pH is maintained above 6, the acids are considered completely
neutralized, and you may report zero releases or transfers as discussed in Section 4.2.3.

               Chlorine used to produce sodium hypochlorite is consumed during the reaction
with sodium hydroxide.  Therefore, the only quantities released or otherwise managed would
normally be small fugitive air releases from such sources as leaks in valves and fittings and losses
during cylinder changeovers.  Chlorine release and other waste managed quantities should be
estimated as discussed in Section 4.2.1.

               Estimates of air releases from storage tank losses (including loading and unloading
operations) should be made using methods described mAP-42 as discussed in Section 4.2.3.
             COMMON ERRORS - Reporting for Mineral Acids and Chlorine
 The most common reporting error for cleaning uses of acids is overestimation of releases or other waste-management
 activity quantities via water. If the pH of the wastewater discharge is maintained between 6 and 9, which is required
 by many permits, the acid is neutralized and zero releases to water or transfers off site may be reported.
 Another common error is the overestimation of discharges or transfers to water for chlorine and chlorine dioxide.
 (See Section 4.2.1).
 Another type of reporting error in this application involves confusing cleaning chemicals with chlorine.  Chemicals
 called "chlorine bleach" are often used for cleaning purposes.  These cleaners normally contain chemicals such as
 sodium hypochlorite or calcium hypochlorite, and very little free chlorine (C12).  They are not subject to EPCRA
 Section 313 reporting requirements.
4.2.8          Wastewater Treatment

               Commonly Used EPCRA Section 313 Chemicals - Ammonia, chlorine,
hydrochloric acid (acid aerosols), sulfuric acid (acid aerosols), nitric acid, and phosphoric acid.

               Process Description - Various EPCRA Section 313 chemicals are used in
wastewater treatment processes at some food processing plants. Mineral acids and bases are
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often added for pH control and ammonia may be added to provide a nitrogen source for biological
treatment systems.

               Sulfuric acid is the most frequently used acid.  However, as previously discussed in
Section 3.1, U.S. EPA has promulgated final rules delisting non-aerosol forms of both sulfuric and
hydrochloric acid. Therefore, threshold determinations  and release estimates for these chemicals
now only apply to the aerosol forms.  U.S. EPA considers the term aerosol to cover any airborne
acid (including mists, vapors, gas, or fog) without regard to particle size.  If liquid solutions of
these acids are used, the mass of the acid should not be considered for threshold or release or
other waste management calculations. However, if vapors or other aerosols are generated from
the process, the mass of the  acid aerosol that is produced must be applied toward the
manufacturing threshold.  If the aerosol is then processed or otherwise used, its mass should be
applied to those thresholds as applicable.  Releases should be reported as fugitive air releases
(assuming a threshold has been met).
                               Example - Sulfuric Acid Aerosol
 When a scrubber is used to remove sulfuric acid aerosol prior to or in a stack, the aerosol is usually converted to a
 non-aerosol form. The non-aerosol form of sulfuric acid is not reportable under EPCRA Section 313 because the
 qualifier to the sulfuric acid listing includes only the acid aerosol form.  While the sulfuric acid as a discrete chemical
 has not actually been destroyed by the scrubber, the form of the acid reportable under EPCRA Section 313 has been
 destroyed. Therefore, since the sulfuric acid removed by the scrubber is converted to a non-reportable form, the
 quantity removed by the scrubber should be reported as having been treated for destruction. However, all the sulfuric
 acid aerosol that is produced, prior to or after the scrubber, counts toward the "manufacturing" threshold, and any
 sulfuric acid aerosol that is not removed by the scrubber and continues out of the  stack must be reported as a release
 to air.
               The principal base used is sodium hydroxide. However, U.S. EPA delisted this
chemical.  Therefore, it does not need to be considered for EPCRA Section 313 reporting.

               Ammonia can be generated in biological treatment systems when proteins break
down. Ammonia may also be added to the system as a metabolic nitrogen source for the
microbes.  However, as previously discussed, beginning with reporting year 1994, U.S. EPA
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revised the ammonia listing as follows: "ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable salts and other sources; 10% of total aqueous ammonia is
reportable under this listing)." Appendix C contains the U.S. EPA published guidance for
reporting ammonia and ammonium salts.

              Reporting Threshold - Acids used for pH adjustment are considered to be
otherwise used as a processing aid and are subject to the 10,000-pound otherwise use threshold.
In addition to the otherwise use threshold, sulfuric or hydrochloric acid aerosols that are produced
are also subject to the 25,000-pound manufacturing threshold.

              Ammonia is considered otherwise used (ancillary or other use) when used for
wastewater treatment and is therefore subject to the 10,000-pound reporting threshold. If
additional ammonia is produced in the treatment system, this quantity is considered to have been
coincidentally manufactured as a byproduct. This activity also should be considered and the
quantity produced should be applied to the 25,000-pound manufacturing threshold.

              Estimating Release and Other Waste Management Quantities - Most of the
ammonia usage is released or otherwise managed  as waste via water except for small quantities of
ammonia that may be released to air from storage and transfer operations before its introduction
into the wastewater treatment system. Estimating quantities of ammonia that are released and
otherwise waste managed is discussed in Section 4.2.2.

              Estimates of air releases from storage tank losses (including loading and unloading
operations) should be made using methods described mAP-42 as discussed in Section 4.2.3.
Spills of such liquids could be reported as fugitive air releases, discharges to wastewater, or off-
site transfers depending upon the volatility of the chemical and the disposal of the clean up
material.
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                             COMMON ERROR - Reporting

 A common error in wastewater treatment is the failure to report the ammonia that may be coincidentally
 manufactured as a byproduct during the treatment process. Other reportable chemicals also may be coincidentally
 manufactured during such treatments depending upon the chemicals present. Section 4.2.11 discusses calculations
 for such chemicals.
4.2.9         Fumigants

              Commonly Used EPCRA Section 313 Chemicals - Bromomethane (methyl
bromide), ethylene oxide, propylene oxide, bromine.

              Process Description - Various EPCRA Section 313 chemicals are used as
fumigants, either alone or in a mixture with carrier gases, during certain types of food processing
operations. For example, ethylene oxide can be used as a bacteriocide during processing of
spices. Bromomethane (methyl bromide) can be used as an insecticide in grain storage facilities.
In such applications, these chemicals are handled and used as gases.  The fumigant is usually
released to air when fumigation is complete. If the process is conducted in a pressurized
container, the fumigant may be vented to a treatment device such as a scrubber.

              Reporting Threshold - Fumigants are considered otherwise used (as ancillary
use) and are therefore subject to the 10,000-pound reporting threshold.

              Estimating Release and Other Waste Management Quantities - If no control
devices exist, you should assume the total  quantity of these volatile chemicals is released to air.
The air releases should be partitioned between fugitive air releases from leaks in valves and
fittings and losses during cylinder changeovers, and point source air releases from fumigation
operations when the building air is routed through a control device. A mass balance is the  best
approach for estimating releases or other waste management quantities, with an assumption of
minor fugitive air releases. The point source air release total must be adjusted based on the
destruction and removal efficiencies of the control devices, with the amount captured and
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separated to another medium reported as a discharge to water or a transfer to an off-site facility as
appropriate.
                              COMMON ERROR - Reporting
 The threshold determination should be based upon the quantity of the EPCRA Section 313 chemical, not the carrier
 gas. The EPCRA Section 313 chemical may sometimes represent only a small percent of the total gas volume.
4.2.10        Pesticides/Herbicides

              Commonly Used EPCRA Section 313 Chemicals - Bromine, napthalene, and
various listed pesticides and herbicides (e.g., aldrin, captan, 2,4-D, hydrazine, lindane, maneb,
parathion, zineb, atrazine, malathion, diazinon).

              Process Description - Pesticides and herbicides may be handled as solids or as
solids mixed with a liquid to form a sprayable solution. They are typically sprayed mechanically
over the area being treated.  Agricultural activities are normally not subject to EPCRA
Section 313 reporting because they do not fall within the appropriate SIC Codes.  However, some
food processing facilities have multiple establishments with different SIC  Codes (including
agricultural activities where pesticides may be used). For example, a food processing
establishment in a facility may process crops grown at the facility in a separate establishment.  If
the total value of the products at establishments in SIC Codes covered under EPCRA Section 313
exceeds 50% of the value of the entire facility's products or services, or if any single covered
establishment produces or ships products whose value exceeds those of any other establishment
within the facility, the entire facility is subject to EPCRA Section 313 reporting.  Such a multi-
establishment facility must report releases and/or other waste management activities for all listed
chemicals, even from establishments that are not in covered SIC Codes (see Section 2.2 for
further discussion).

              In other words, some food processing facilities may be required to report for
pesticides and herbicides because of the use of these chemicals in related  agricultural  activities at

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the same site. For example, an establishment that processes sugarcane grown at a farm at the

same facility may have to submit an EPCRA Section 313 report for 2,4-D.


               Reporting Threshold - Pesticides and herbicides are otherwise used (ancillary or

other use), and are therefore subject to the 10,000-pound reporting threshold.


               Estimating Release and Other Waste Management Quantities -  Pesticides

and herbicides sprayed onto the area being treated should be considered released on site to land.

Minor amounts of these chemicals could be released to air and/or water from aerial spraying.
                              COMMON ERRORS - Reporting

 The most common reporting error in use of pesticides and herbicides is failure to submit a Form R or Form A for
 these chemicals because they are used only for agricultural purposes at a covered facility. As explained above, a
 Form R or Form A may be required depending on the primary SIC Code of a multi-establishment facility.

 The threshold determination for pesticides and herbicides should be based upon the quantity of the EPCRA Section
 313 chemical used, not the entire quantity of the pesticide formulation. Such formulations often contain other
 chemicals that are not reportable, and the EPCRA Section 313 chemical may represent only a small percent of the
 total quantity of material used.

 Some facilities also may fail to report any release or other waste management activity of these chemicals because they
 are broken down by soil microorganisms, and do not accumulate in the soil from normal agricultural use. The total
 amount of the EPCRA Section 313 chemicals used should be reported without consideration of its disposition after it
 is applied to the soil.
4.2.11         Byproducts or Impurities


               Commonly Produced EPCRA Section 313 Chemicals -  Ammonia, chloroform,

methanol, hydrogen fluoride, sulfuric acid (acid aerosol), hydrochloric acid (acid aerosol),

formaldehyde, metal compounds, nitrate compounds.


               Process Description - Various EPCRA Section 313 chemicals may be

coincidentally manufactured as byproducts at food processing plants during processing
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operations, waste treatment and combustion processes. For example, ammonia can be produced
through breakdown of proteins in a wastewater treatment system. Chloroform can be produced
in a water treatment system employing chlorine, and sulfuric acid can be produced when coal is
used as a fuel for combustion. Effective January 1, 1998 (for the Form R reports due July 1,
1999), U.S. EPA issued a revised interpretation of "otherwise used" to include treatment, by a
covered facility, of wastes received from off site for destruction, disposal, and/or stabilization.
The amount of an EPCRA Section 313 chemical received from off site for waste management
must be included in the "otherwise used" threshold determination. Similarly, if the treatment of a
waste received from off site creates an EPCRA Section 313 chemical, even if the original waste
did not contain an EPCRA Section 313 chemical, the created amount must be included in the
"otherwise used" threshold determination.

              Reporting Threshold - Chemicals produced under these circumstances are
normally considered manufactured as byproducts and are subject to the 25,000-pound reporting
threshold (note that the de minimis exemption does not apply to coincidentally manufactured
byproducts). Occasionally, the produced chemical may be subsequently otherwise used (e.g.,
ammonium sulfate generates an aqueous solution of ammonia, the ammonia is then otherwise
used for water treatment).  In these cases, this quantity is also subject to the otherwise use
threshold of 10,000 pounds. For the  situation where a waste is received from off site for
destruction, disposal, and/or stabilization, the amount of EPCRA Section 313 chemical in the
waste, or the amount of EPCRA Section 313 chemical created in the treatment of the waste, must
be included in the "otherwise used" threshold determination.  If the 10,000-pound threshold is
reached for the facility, all releases and other waste management activities for the chemical must
be reported.
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                        Example - Treatment of Wastes from Off-Site
 A covered facility receives a waste containing 12,000 pounds of Chemical A, an EPCRA Section 313 chemical, from
 off site. The facility treats the waste, destroying Chemical A and in the treatment process manufactures 10,500
 pounds of Chemical B, another EPCRA Section 313 chemical. Chemical B is disposed on site.
 Since the waste was received from off site for the purpose of waste management, the amount of Chemical A must be
 included in the "otherwise used" threshold determination for Chemical A.  The "otherwise use" threshold is 10,000
 pounds and since the amount of Chemical A exceeds this threshold, all releases and other waste management
 activities for Chemical A must be reported.
 Chemical B was "manufactured" in the treatment of a waste received from off site. However, the facility disposed of
 Chemical B on site and waste received from off site for treatment for destruction, disposal, or stabilization is
 considered to be "otherwise used" and the amount of Chemical B must be considered in the "otherwise used"
 threshold determination.  Thus, the reporting threshold for Chemical B has also been exceeded and all releases and
 other waste management activities for Chemical B must be reported.
               Estimating Release and Other Waste Management Quantities -  The release
or other waste management of a coincidentally manufactured chemical depends upon the physical
state of the chemical and the process in which it is produced. The most likely receiving medium
for chemicals coincidentally manufactured during food processing is water.  The specific amounts
released or otherwise managed as waste are often best estimated using monitoring data for the
waste stream. Ammonia presents a special case because anhydrous ammonia (including ammonia
generated from water dissociable ammonium salts) and nitrate compounds (water dissociable,
reportable when in solution) are EPCRA Section 313 chemicals/compounds.  Refer to Appendix
C, Guidance for Reporting Aqueous Ammonia, for details describing threshold and  release
estimates for these chemicals.

               In addition, many food processing facilities use coal and/or fuel oil in boilers or
furnaces for process operations. The combustion of these fuels results in the coincidental
manufacture of several EPCRA Section 313 chemicals and chemical compounds including: metal
compounds, formaldehyde, hydrogen fluoride, and aerosol forms of sulfuric acid and hydrochloric
acid.  If any of these chemicals are manufactured, processed, or otherwise used in other activities,
these fuel-combustion-generated quantities should be included in threshold determinations and
release and other waste management estimates. U.S. EPA's Guidance for Electricity Generating
Facilities describes estimation techniques for combustion processes in detail.

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                              COMMON ERROR - Reporting

 The most common reporting error is failure to take the manufacture of these chemicals into consideration when
 performing threshold determinations or release and other waste management estimates. If the only source of the
 chemical at a facility is through coincidental manufacture, it is likely that the 25,000-pound manufacturing threshold
 may not be exceeded. On the other hand, if the chemical is already reportable at your facility for other reasons, the
 release and other waste management amounts from its formation must be reported (again, note that the de minimis
 exemption does not apply to coincidentally manufactured byproducts).
4.2.12        Can Making/Coating

              Commonly Used EPCRA Section 313 Chemicals - Metal can components such
as manganese, nickel, and chromium; various listed ink and coating solvents (e.g., n-butyl alcohol,
glycol ethers, methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), toluene,
1,1,1-trichloroethane, xylene); and various listed metal compounds used as pigments (e.g., copper
compounds, barium compounds, chromium compounds, zinc compounds, lead compounds).

              Process Description -  Some food processing plants fabricate cans using various
stamping and coating operations.  Strip metal is formed into can bodies and lids using stamping
machines.  Reportable chemicals may also be used during the fabrication of cans in welding,
cementing, or soldering processes.

              The largest reportable use of EPCRA Section 313 chemicals in can making is
typically that of solvents and pigments  in inks and coatings.  Coatings may be applied to both the
interior and exterior of the can, generally using roll  coating, printing, or spraying processes.  In
larger operations, the coatings may be formulated on site.  Various solvents may be used in
printing and coating uses, both as pigment carriers and to clean up equipment and spills.
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              Reporting Threshold - EPCRA Section 313 chemicals in strip metals, solders,
and welding rods are processed and are subject to the 25,000-pound reporting threshold. It is
important that the de minimis and article exemptions be considered for the strip metal. In general,
can making cannot be exempted from threshold determination under the article exemption.  To
decide if the exemption applies, careful consideration must be given to whether the shape of the
metal is changed and whether releases and other waste managed quantities of the listed chemical
exceed 0.5 pounds in a reporting year as a result of operations such as welding.  The article
exemption is explained more fully in EPCRA Section 313 Release Reporting Guidance for Metal
Fabrication and Electroplating (1998).

              Listed chemicals in ink and coating pigments that are intended to remain with the
product are processed and are subject to the 25,000-pound reporting threshold.  Formulation of
the inks or coatings for use on site also constitutes processing of the solvents (as a formulation
component).

              Solvents used in inks and coatings that are intended to  serve as carriers and
evaporate during the process are not intended to remain with the product.  Therefore, they  are
considered to be otherwise used (as a  chemical processing aid). Solvents used for equipment
cleanup are also considered otherwise used (ancillary use) and are subject to the 10,000-pound
reporting threshold.

              Estimating Release and Other Waste Management  Quantities - Releases or
other waste managed quantities from strip metal stamping operations are typically minor.
Scrap from the process is usually shipped off site for metal recycling but could be sent for direct
reuse, which is not reportable. Releases from large soldering or welding operations should be
considered, but are typically small because they are often subject to air permitting requirements.
Releases to air in such instances may therefore best be determined by the permit conditions or
monitoring of the process.  EPCRA Section 313 Release Reporting Guidance for Metal
Fabrication and Electroplating (1998) also contains information on estimating releases and other
waste managed quantities from these types of operations.
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              Most ink and coating solvents are volatile chemicals and it can be assumed the
entire quantity used will evaporate during handling, blending, or drying of the ink or coating.  The
quantity released as a fugitive air emission is therefore equal to total solvent usage for these
purposes minus any amount captured by control devices such as carbon absorbers or thermal
oxidizers (e.g., incinerators). The air release from an air pollution control device (APCD) is
considered a point source release. If the APCD simply transfers the EPCRA Section 313
chemical from the air stream to another medium, the quantity released or otherwise managed
should be partitioned as appropriate.

              If destructive controls are used (e.g., thermal oxidizers), you should estimate the
amount of solvent destroyed using engineering assumptions based on the solvent quantity entering
the control device and its destruction efficiency. If nondestructive controls are used (e.g.,
absorbers ), the amount of the captured solvent in wastes sent off site for recycling, treatment, or
disposal can be estimated through analysis of these wastes.  Note that the treatment efficiency
reported in Section 7A of Form R refers to the waste stream sent to the treatment system and the
corresponding effluent from the system, while the quantity reported in Section 8.6 refers to the
quantity actually destroyed. If a system transfers  100% of the chemical from an air stream to a
water stream without any destruction, the efficiency of the system in removing the chemical from
the air stream should be reported as  100% in Section 7A; however, "zero" should be reported in
Section 8.6 because the chemical has not been treated for destruction. Water releases, or
subsequent waste management from control devices can be  estimated from monitoring data. Air
releases are the difference between total usage and the amount captured in this manner.

              The wastes shipped off site may also contain pigments. The quantity of the
EPCRA Section 313 chemicals involved can be determined through analysis of the wastes or
knowledge of the coating operation transfer efficiency. The total quantity of EPCRA Section 313
coating pigment used multiplied by the factor (1 - transfer efficiency) will yield the total  quantity
of chemical released or subsequently waste managed. Engineering assumptions can then be used
to determine the media of these releases or waste management activities.
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              A portion of the solvents used to clean ink rollers or spills also will evaporate and
should be reported as a fugitive air release (unless captured and sent through an air pollution
control device, in which case a stack/point source release will result). The remaining portion is
typically collected, placed in drums, and shipped off site for disposal, treatment, or reuse.  The
quantity of the EPCRA Section 313 chemicals can be determined through analysis of these
wastes.  The amount of cleanup solvent released to air can be estimated by mass balance, based
on that total solvent used minus the waste solvent from this application sent for recycle or
disposal.

              Additional information on estimating release and/or other waste management
quantities for printing and coating solvents can be found in the U.S. EPA publications, EPCRA
Section 313 Release Reporting Guidance for Printing Operations (1998) and EPCRA Section
313 Release Reporting Guidance for Roller, Knife, and Gravure Coating Operations (1998).
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                                 COMMON ERRORS - Reporting

One possible error in can making/coating operations is failure to report the metal content of the cans under the
assumption that the metal is always subject to the article exemption. As previously stated, this consideration should
be made on a case-by-case basis.

A common reporting error for solvents used in ink and coating applications is failure to account for all solvent usage
through some release or other waste management activity.  Typically, none of the solvent remains with the printed or
coated product. All usage should be accounted for through air releases, amounts captured or destroyed in control
devices, releases to water, waste amounts managed on site, and amounts sent off site.  Total usage is best determined
from purchasing records for the coating or ink and the percentage of the solvent in these materials (as reported in the
MSDS).

Overestimation of the amount of solvent in waste sent off site also can occur. This quantity should be based on
analysis of the waste. Most likely, the waste is not  100% solvent, and the total amount of waste shipped off site must
be adjusted for the solvent concentration. Many facilities that receive waste  solvents will provide information on the
concentrations of chemicals present in the waste sent to them. This information is a key component if a mass balance
is used for estimating the quantity of solvent released and otherwise waste managed.

Another potential error in this category is incorrectly classifying the chemical activity of the coating pigments. While
solvents are typically intended to serve as carriers and do not remain with the product (meaning they are otherwise
used); metals and other chemicals in pigments are often part of the formulation that intentionally stays with the
product.  These chemicals are processed and are subject to the higher 25,000-pound-per-year reporting threshold.

A final reporting error in these applications is incorrectly submitting a Form R or Form A for isopropyl alcohol,
which is often  used as an ink solvent.  A Form R or Form A is only required  for isopropyl alcohol if the facility
manufactures the chemical on site using the strong acid process. Use of isopropyl alcohol as an ink or coating solvent
is therefore not subject to EPCRA Section 313 reporting.
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       Appendix A




TRI GUIDANCE RESOURCES

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                                     Appendix A

                           TRI GUIDANCE RESOURCES


A.1    EPCRA Section 313 RELATED REFERENCES

40 CFR 372. Toxic Chemical Release Reporting: Community Right-to-Know: Final Rule
See 53 FR 4500, February 16,  1988.

Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting
Year
U.S. EPA publishes this document each year to provide current guidance for preparing the Form
R and Form A reports.  This document contains the most up-to-date list of chemicals for which
reports are required. It includes a blank Form R and Form A and provides step-by-step
instructions for completing each report. It also has a list of U.S. EPA regional and state contacts
for EPCRA Section 313 reporting. The current version of this document should always be
consulted in preparing the EPCRA Section 313 report.

Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the Emergency Planning
and Community Right-to-Know Act (EPA 745-R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the
reporting requirements of EPCRA Section 313. The glossary was developed to aid in
determining whether a facility manufactures, processes, or uses a chemical subject to EPCRA
Section 313 reporting.

Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-
Know Act ffiPCRA^ and Section  112frt of the  Clean Air Act (as amended^ (EPA 740-R-95-001)
List of chemicals covered by EPCRA Sections 302 and 313, CERCLA Hazardous Substances,
and CAA 112(r).  The list contains the chemical name, CAS Registry Number, and reporting
requirement(s) to which the chemical is subject.

The Emergency Planning and Community Right-to-Know Act: EPCRA Section 313 Release
Reporting Requirements. August 1995 (EPA 745/K-95-052)
This brochure alerts businesses to their reporting obligations under EPCRA Section 313 and
assists in determining whether their facility is required to report. The brochure contains U.S. EPA
Regional contacts, the list of EPCRA Section 313 toxic chemicals and a description of the
Standard Industrial Classification (SIC) codes subject to EPCRA Section 313.

EPCRA Section 313 Questions and Answers: Revised 1997 Version. November 1997 (EPA 745-
B-97-008)

Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements: Questions and Answers (EPA 745-R-95-011)
This document  assists federal facilities in complying with Executive  Order 12856. This
information has been compiled by U.S. EPA from questions received from federal facilities. This

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document is intended for the exclusive use of federal facilities in complying with Sections 302,
303, 304, 311, 312, and 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA) of 1986 and the Pollution Prevention Act of 1990, as directed by the Executive Order.

Supplier Notification Requirements (EPA 560/4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification
requirements under EPCRA Section 313. The pamphlet explains the supplier notification
requirements, gives examples of situations which require notification, describes the trade secret
provision, and contains a sample notification.

1994 and 1995 Toxic Release Inventory Data Quality Report (EPA 745-R-98-002)
The U.S. EPA conducted TRI data quality site surveys for the reporting years 1987, 1988, 1994,
and 1995. The goals of these surveys were to identify areas in the TRI data collection process
that could be improved, to provide a quantitative assessment of the accuracy of the data collected,
and to disseminate further guidance on the completion of the TRI forms.  This document
summarizes the findings of these surveys. U.S. EPA is in the process of conducting another
survey for reporting year 1996 and may conduct additional surveys in the future.

Toxics Release Inventory Public Data Release
Each year, U.S. EPA releases this publication which summarizes TRI data submitted for the most
recent reporting year: where, how much, and which types of chemicals are being released into the
environment.  It provides comparisons to TRI submissions for earlier years. Extensive tables
itemize releases and transfers by media, chemicals, location, and industry.  Similar reports for each
prior year are available for sale from the Superintendent of Documents, U.S.  Government Printing
Office, Washington DC 20420-9325 (202-512-1800).

Toxics Release Inventory Public Data  Release State Fact Sheets
Each year, U.S. EPA releases the fact sheets in this document that summarize the basic TRI data
for each state. This document is designed as a companion volume to EPA's Toxic Release
Inventory Public Data Release, a more detailed examination of TRI data for the current and
previous years.

Trade Secrets Rule and Form
See 53 FR 28772, July 29, 1988.  This rule implements the trade secrets provision of the EPCRA
(Section 322) and includes a copy of the trade  secret substantiation form.

A.2    INFORMATION SOURCES

Most of the materials included as reference in this manual are available from the following
sources:
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National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OH 45242-2419
(800) 490-9198
Fax: (513)489-8695
Internet: http://www.epa.gov/ncepihom/indxe.html

Emergency Planning and Community Right-to-Know (EPCRA) Information Hotline
U.S. Environmental Protection Agency
(800) 424-9346 or (703) 412-9810 (for the Washington, D.C. metropolitan area)
TDD: (800) 553-7672

Internet Sites

•      WATER8/CHEMDAT8: http://www.epa.gov/ttn/chief/software.htmffiwater8
       WATERS is an analytical model for estimating compound-specific air emissions from
wastewtaer collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3 spreadsheet for
estimating VOC emissions from TSDF processes.

•      Clearinghouse for Inventories and Emission Factors (CHIEF):
       http://www. epa.gov/ttn/chief/
       This site provides access to the latest information and tools for estimating emissions of air
       pollutants and performing emission inventories.

•      Code of Federal Regulations, 40 CFR:  http://www.epa.gov/epacfr40
       This site was created by U.S. EPA to expand access to Title 40 - Environmental
       Protections of the Code of Federal Regulations.

•      Compilation of Air Pollutant Emission Factors (AP-42):
       http://www. epa.gov/ttn/chief/ap42etc. html
       This site provides access to files  containing guidance for estimating emissions from
       specific sources and emission factors.

•      Federal Register Notice: http://www.epa.gov/EPA-TRI
       This site provides access to all Federal Register notices related to the TRI program from
       1994 to current.

•      Material Safety Data Sheets (MSDSs): http://msds.pdc.cornell.edu/issearch/msdssrch.htm
       A key word searchable database of 325,000 MSDSs.

•      TANKS: http://www.epa.gov/ttn/chief/tanks.html
       This site contains information on TANKS, a DOS-based computer software program that
       computes estimates of VOC emissions from fixed and floating-roof storage tanks.
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•      TRI homepage:  http://www.epa.gov/opptintr/tri
       This site contains information on the Toxic Release Inventory and provides links to a
       variety of data and documents related to the TRI program.

•      TOXNET:  http://tamas.nlm.nih.gov/~boyda/htdocs/TOXNET/factsheets/toxnet.html
       TOXNET is a computerized system of files oriented to toxicology and related areas,
       maintained by the National Library of Medicine.

National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Call: (800) 553-6847; (703) 487-4650
Fax:(703) 321-8547
Publication Number PB97-502-587
E-mail: info@ntis.fedworld.gov

RTK-Net is an online network concerned with environmental issues, in particular, matters arising
from the passage of the right-to-know provisions embodied in the EPCRA legislation. RTK-net
was established by  two non-profit organizations (Unison Institute and OMB Watch) to provide
access to TRI, link  TRI with other environmental data, and exchange information among public
interest groups. RTK-Net is a full-service center providing free dial in access privileges to
government and industry,  as well as more  complete database services, training and technical
support, e-mail, and electronic conferences pertaining to issues such as health, activism, and
environmental justice. For more information contact RTK-Net, 1742 Connecticut Ave., NW,
Washington, DC 20009-1146 or phone 202-797-7200. You can register on-line by modem at
202-234-8570, parameters 8,n,l, and log in as "public".

Toxics Release Inventory - CD-ROM
The CD-ROM contains the complete Toxic Release Inventory since 1987, as well as Chemical
Factsheets containing health and environmental effects information for TRI chemicals. User-
friendly software provides the capability to search data by facility, location, chemical,  SIC code,
and many other access points. Other features allow flexibility in printing standard and custom
reports,  data downloading, and calculating releases for search sets (for example, calculate average
air releases for all pulp and paper manufacturers).  To order call or write:

       U.S. Government Printing Office (GPO)
       Superintendent of Documents
       P.O. Box 371964
       Pittsburgh, PA 15250-7954
       Call: (202)  512-1800
       Fax: (202)512-2250
       Stock Number:  055-000-0582-6
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Toxic Release Inventory - On-Line Database
A computerized on-line database of the toxic release inventory data is available through the
National Library of Medicine's (NLM) TOXNET on-line system 24 hours a day. Other NLM files
on TOXNET can provide supporting information in such areas as health hazards and emergency
handling of toxic chemicals. Information on accessing the TOXNET system is available from: TRI
Representative, Specialized Information Services, National Library of Medicine, 8600 Rockville
Pike, Bethesda, MD 20894, (301) 496-6531, average cost of $18.00 per hour.

A.3    INDUSTRY-SPECIFIC TECHNICAL GUIDANCE DOCUMENTS

In 1988 and 1990, U.S. EPA developed a group of individual guidance documents for industries
or activities in industries who primarily manufacture, process, or otherwise use EPCRA
Section 313 chemicals.  See list of industries/activities below. U.S.  EPA is currently revising
some of these documents and preparing additional documents. The newer versions will be
available beginning in the Fall of 1998.

Guidance for Chemical Distribution Facilities (Version 1.0). October 7, 1997

Guidance for Coal Mining Facilities (Version 1.0). September 26, 1997

Guidance for Electricity Generating Facilities (Version 1.0). September 15, 1997

Guidance for Metal Mining Facilities (Version 1.0). October 6, 1997

Guidance for Petroleum Bulk Storage Facilities (Version 1.0). September  15,  1997

Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities (Version 1.0)
October 6, 1997

Electrodeposition of Organic Coatings

Electroplating Operations

Estimating Releases and Waste Treatment Efficiencies

Formulation of Aqueous Solutions

Incidential Manufacture/By-products

Leather Tanning and Finishing Processes

Metal Fabrication Industry

Monofilament Fiber Manufacture
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Paper and Paperboard Production

Presswood & Laminated Wood Products Manufacturing

Printing Operations

Roller. Knife, and Gravure Coating Operations

Rubber Production and Compounding

Semiconductor Manufacture

Smelting Operations

Spray Application of Organic Coatings

Textile Dyeing

Welding Operations

Wood Preserving

U.S. EPA, Office of Compliance, published a series of documents in 1995 called Sector
Notebooks.  These documents provide information of general interest regarding environmental
issues associated with specific industrial sectors. The Document Control Numbers (DCN) range
from EPA/310-R-95-001 through EPA/310-R-95-018.

A.4    CHEMICAL-SPECIFIC GUIDANCE DOCUMENTS

U.S. EPA has also developed a group of guidance documents specific to individual chemicals and
chemical categories.  These are presented below.

Emergency Planning and Community Right-to-Know EPCRA Section 313:  Guidance for
Reporting Aqueous Ammonia. July 1995 (EPA 745-R-95-012)

Emergency Planning and Community Right-to-Know EPCRA Section 313:  List of Toxic
Chemicals within the Chlorophenols Category. November 1995 (EPA 745-B-95-004)

Estimating Releases for Mineral Acid Discharges Using pH Measurements.  U.S. Environmental
Protection Agency. June 1991.

Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size). November 1997 (EPA-745-R-97-007)

Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance
for Reporting. May 1995 (EPA 745-R-95-006)

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Toxic Release Inventory List of Toxic Chemicals within the Nicotine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-004)

Toxic Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category
and Guidance for Reporting. February 1995 (EPA 745-R-95-001)

Toxic Release Inventory List of Toxic of Chemicals within the Polycyclic Aromatic Compounds
Category. February 1995 (EPA 745-R-95-003)

Toxic Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-005)

Toxic Release Inventory List of Toxic of Chemicals within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting. May, 1996 (EPA 745-R-96-004)

Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid
Category. November 1994, EPA 745-B-94-003.

Toxics Release Inventory - Copper Phthalocyanine Compounds Excluded for the Reporting
Requirements Under the Copper Compounds Category on the EPCRA Section 313 List. April
1995, EPA 745-R-95-007.

Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category. November 1994,
EPA 745-B-94-004.

A.5   OTHER USEFUL REFERENCES

Burgess, W.A. Recognition of Health Hazards in Industry. Harvard School of Public Health.
Boston, Massachusetts, John-Wiley & Sons.

CRC Handbook of Chemistry and Physics. Latest Edition, Robert C. Weast, Editor, CRC Press,
Inc., Florida.

Locating and Estimating Air Emissions from Various Sources. Available from:  National
Technical Information Services (NTIS), (703) 487-4650.

The Merck Index. Latest Edition, Merck & Co., Inc., New Jersey.

Perry, R.H. and C.H. Chilton, Chemical Engineer's Handbook. Latest Edition, McGraw-Hill Book
Company, New York.

Sax, N.I. and R. J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van
Nostrand Reinhold Company, New York.
                                         A-7

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           Appendix B




BASIC CALCULATION TECHNIQUES

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                                       Appendix B

                        BASIC CALCULATION TECHNIQUES


This section will provide the basic techniques needed to use specific types of data or engineering
calculations. Examples are provided for:

       (1)     Stack monitoring data;

       (2)     Industrial hygiene data;

       (3)     Raoult's Law;

       (4)     Air emission factors;

       (5)     RCRA hazardous waste analysis data;

       (6)     NPDES monitoring data.

(1)     Stack Monitoring Data

       The following is an example of a release calculation using monitoring data.

       Example: Stack monitoring data are available for a paint booth.  The measured average
       concentration of toluene is 0.1 ppmv (dry gas basis).  The moisture content in the stack is
       typically 10%, and stack conditions are maintained at 80°C and atmospheric pressure.  The
       stack gas velocity is 8 m/s. The diameter of the stack is 0.3 m.  Calculate the point air
       release of toluene.

       Step 1.  Calculate volumetric flow of stack gas stream.
              Volumetric flow = (gas velocity) [(TT) (internal stack diameter)2/4)]
       Volumetric flow = (8 m/s) [(ir)(0.3 m)2/4] = 0.57 m3/s

       Step 2. Correct for moisture content in stack gas stream.

       Stack exhausts may contain large amounts of water vapor. The concentration of the
       chemical in the exhaust is often presented on a dry basis.  For an accurate release rate,
       correct the vent gas flow rate for the moisture content by multiplying by the term
       (1—fraction water vapor).  The dry gas rate can then by multiplied by the chemical
       concentration.
                                           B-l

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(Note: If the toluene concentration is on a wet gas basis, no correction is necessary for
moisture content.)
       Dry volumetric flow = (Volumetric flow) (1-fraction water vapor)


Dry volumetric flow = (0.57m3/s) (1-0.10) = 0.51 m3/s

Step 3. Convert ppmv to mg/m3.

•      ppmv is defined as one part of a chemical in 106 parts of gas (m3/106m3).

•      Use the molar volume of a gas, corrected for stack temperature and pressure
       conditions, calculated by the ideal gas law (PV = nRT). Note that the molar
       volume of an ideal gas at 0°C and 760 mmHg is 22.4L/mole.

•      Molecular weight of toluene (MW) = 92.14 g/mole.

•      R = the Ideal Gas Constant (0.082057 L - atm per mole-Kelvin)

To calculate the molar volume of stack gas, use the ideal gas equation.
                        A-r 1     1        V   RT
                        Molar volume  =  — = 	
For the example, the stack conditions are 80°C (353 K) and atmospheric pressure (1 atm).

            Molar volume =   0.082057  L"atm 1  (353K)/(latm)
                            (          mole-KJ

       = 29.0 L/mole

The conversion of ppmv to mg/m3 can now be calculated.


    —-  =  (concentration of chemical, ppmv)  	  (MW)
    m3J                                  ^ molar volume of gas)
                                  B-2

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       Using the example, the concentration of toluene is calculated as follows:

             0.1  m3"!(  mole  "|( 92.14 g^(     L   \(  1,000
                                                                 = 0.3 mg/r
             106 m3A29.0LM  mole )[  1(T3 m3 "    "
       Step 4. Calculate air releases.

       Air releases are calculated as follows:
        Air Release=(volumetric flow, m3/s)(concentration, mg/m3)(operating time, s/yr)
       The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year.
              Operating time =   8-^^   5^^  52j2±i±i  = 2,080  hr/yr
                               ^   day )\  weekj^    year }
       A-  T>  1       /nci   3/wn-s    /  3sf 3,600 sW 2,080 hrW   Ib
      Air Release = (0.51 m /s)(0.3 mg/m ) —	   —	   	
                    v         / ^      t-7   /\    1_ _   r [       _    [ [  A r A
                                               hr   )(    yr   )( 454  g A 1,000 mgj


                                      = 2.5  Ib/yr of toluene


       It is important to note that this calculation assumes the measured emissions are
representative of actual emissions at all times; however, this is not always the  case. Ideally, a
continuous emissions monitor provides the most representative data.

       Also note that monitoring and stack data may have units which are different than those
used in the example.  Modify conversion factors and constants to reflect your data when
calculating air releases.

(2)    Industrial Hygiene Data

       The following is an example of a release calculation using industrial hygiene data.

       Example: Occupational industrial hygiene data shows that workers are exposed to an
       average of 0.1 ppmv benzene (wet gas basis).  The density of benzene vapor is 0.2 lb/ft3.
       The ventilation system exhausts 20,000 acfm of room air at 70°F.  The plant operates 24
       hours per day, 330 days per year.

       The benzene concentration is on a wet gas basis, therefore a moisture  correction of the
       ventilation flow rate is not necessary. The industrial hygiene data is collected at the same
       ambient conditions as the ventilation system, therefore no adjustment for temperature or

                                          B-3

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       pressure needs to be performed. A conservative estimation of benzene fugitive releases
       could be calculated as follows:
 Air Release   =      (ventilation flow rate, ft3/min)(operating time, min/yr)(concentration of
                      chemical, ppmv)(vapor density of chemical, lb/ft3)
Benzene releases per year would be calculated as follows:


 20,000 ft3)  ( 60 minutes'!  f 24  hr)  f 2^_days\  [ 0.1 ft3 benzene)  ( 0.2 lb'
              (    hour   )  (  day  j  (   year  J  [   io6 ft3 air  j  {  ft3
          minute
                                     =  190 Ib/vr of benzene
(3)    Raoult's Law

       The following is an example of a release calculation using Raoult's Law.  Raoult's Law
states that the partial pressure of a compound in the vapor phase over a solution may be estimated
by multiplying its mole fraction in the liquid solution by the vapor pressure of the pure chemical.
where:

       P°     =      Vapor pressure of pure liquid chemical A;
       XA L   =      Mole fraction of chemical A in solution;
       XA,G   =      Mole fraction of chemical A in the gas phase;
       PA     =      Partial pressure of chemical A in the gas phase; and
       PT     =      Total pressure.

       Example: A wash tank holds a solution containing 10% by weight of
o-xylene (A) and 90% by weight of toluene (B). The tank is vented to the atmosphere; the
process vent flow rate is estimated as 100 acfm (2.83m3/min) based on a minimum fresh air
ventilation rate. The molecular weight of o-xylene is 106.17 g/mole and toluene is 92.14 g/mole.
The vapor pressure of o-xylene is 10 mmHg (0.19 psia). The total pressure of the system is 14.7
psia (atmospheric conditions).  The process tank is in service 250 days/yr. Calculate the air
release of o-xylene.
                                           B-4

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       Step 1:  Calculate the mole fraction of o-xylene in the liquid solution.
                          X
                                           wt fraction A
                                               MWA
                            A'L     wt fraction A    wt fraction B
                                       MW,
                                               MW,
Where:
       MW
       wt fraction
                    Mole fraction of chemical A in liquid solution;
                    Molecular weight of chemical, g/g-mole; and
                    Weight fraction of chemical in material.
                                 X
                                   •A,L

0.1
106.17

0.1 0.9
106.17 92.14
                                        XA,L  = 0.09
       Step 2:  Calculate the mole fraction of o-xylene in the gas phase.
                                       X
                                        A,G
where:
       X
       X
       p°

       PT
•A,G

A,L
Mole fraction of chemical A in gas phase;
Mole fraction of chemical A in liquid solution;
Vapor pressure of pure liquid chemical, A, psia; and
Total pressure of system, psia.
                              XA.G =  [°-09]
                                   0.19  psia
                                   14.7  psia
                                  = 0.001
                                            B-5

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       Step 3: Calculate releases using Raoult's Law.
                        Emissions =  (XG)(AFR)(t)(MWA)
                                                          MV,
where:
       Emissions    =      Air release of pollutant A, g-A/yr;
       XA G         =      Mole fraction of chemical A in gas phase;
       ATRS        =      Air flow rate of room, m3/min;
       t             =      Operating time of wash tank, min/yr;
       MW         =      Molecular weight of chemical, g/g-mole; and
       MV         =      Gas molar volume (22.4L/mole at standard temperature and
                           pressure).

       If conditions vary from standard temperature and pressure the gas molar volume can be
       calculated using the ideal gas law and tank conditions as presented in Example 1.

       The emissions of o-xylene are calculated as shown below.
    c  .  .      ,nnnij 2.83 m3H 250 dayW 24 hrU 60 minW mole W 106.17gW    L
    Emissions = (0.001)  	   	=M 	   	   	   	&" 	
                     I   min  /I   yr   /day I    hr  /  22.4L/   mole
            Emissions =  (4.8 x 106 g/yr)     lb   1  =  10.570  Ib/vr of o-xvlene
                                        I 454 gj

       Air releases for toluene can be calculated in a similar manner.

(4)    Air Emission Factor

       The following is an example of a release calculation using air emission factors.

       Example: An industrial boiler uses 300 gallons per hour of No. 2 fuel oil. The boiler
       operates 2,000 hours per year. Calculate emissions of formaldehyde using the AP-42
       emission factors.


                                     AE = (EF)(AU)
                                          B-6

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where:
       AE    =     Annual emissions of pollutant, Ib/yr
       EF     =     Emission factor of pollutant, lb/103 gallon of fuel.  EF for formaldehyde for
                    an industrial boiler burning No. 2 fuel oil is 0.035 to 0.061 lb/103 gallons.
       AU    =     Quantity of fuel used, gal/yr.

       Using an emission factor of 0.061 pounds of formaldehyde per gallon of fuel, the air
       releases are calculated as follows:
        AT3   ,   0.061 Ib \( 300  gallon V 2,000 hr"|    ...,,/    ff    ,., u j
        AE = | 	   	s.	   _j	   = 36.6 Ib/yr of formaldehyde
                103 gallons/1     hr    ){    yr   /
(5)    RCRA Waste Analysis

       The following is an example of a calculation using RCRA waste analysis data.

       Example: Spent paint wastes were disposed at an off-site waste treatment facility. The
       quantity of paint waste shipped was five 55-gallon drums per year. Analysis of the waste
       showed 5% cadmium by weight. Estimating the density of the paint waste to be 9.5
       Ib/gallon, the amount of cadmium to off-site disposal is calculated as follows:
    Amount of cadmium = (amount of paint waste disposed, gal/yr) (concentration of cadmium, Ib/lb)
                                  (density of paint waste, Ib/gal)
              ( 5  drums V 55  galU 9.5 IbW   51b-Cd   "|    m  ,u/    *•   A  •
               	   	2—   	   	  =  131  Ib/vr of cadmium
              ^   yr   )(  drum ){  gal  )( 100Ib waste)

(6)    NPDES Data

       The following is an example of a calculation using NPDES data.

       NPDES permits require periodic monitoring of the effluent stream. In this example,
quarterly samples were taken to be analyzed for silver content. Each sample was an hourly,
flowrate-based composite taken for one day to be representative of the discharge for that day.
The total effluent volume for that day was also recorded.  The following data were collected on
each sample day.
                                          B-7

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                                   Discharge Flow Rate
            Quarter                    HO6 gal/day^                Total Silver (ua/L)
               1                             0.5                            10
               2                             0.6                            10
               3                             0.4                            6
               4                             0.2                            <3

       To calculate the amount of silver in pounds discharged on each sample day, the
concentration of silver in the discharge is multiplied by the discharge flow rate for that day, as
shown below for the first quarter sample.
                   Amount of silver = (daily flow rate) (silver concentration)
                 10|ig/U  (     Ig   \ (  lib \ ( 3.7851^   0.5 x 106gal
                    L   j  (  106|ig/MJ l454gj (   gal  j (      day
              = 0.04 Ibs/day of silver

       The amount of silver discharged during each of the other three monitoring events was
similarly determined to be:

       0.05 Ibs/day; 0.02 Ibs/day, and 0.005 Ibs/day.

       For the last data point the concentration of silver was reported by the laboratory to be less
than the detection limit of 3 |jg/L.  For this calculation the detection limit was used to calculate the
daily discharge, a conservative assumption.

       The average daily discharge was calculated to be:

                           0.04+0.05+0.02+0.005   AAOIU/J
                          	 = 0.03 Ibs/day
                                     4

       The plant operates 350  days/year (plant shuts down for two weeks in July).

       The estimated annual discharge of silver is calculated as follows:

       Annual discharge = (350 days/year) (0.03  Ibs/day) =  10.5 Ibs of silver/year
                                           B-8

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                 Appendix C




GUIDANCE FOR REPORTING AQUEOUS AMMONIA

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 United States Environmental
 Protect! on_Agency
                            Office of Pollution Prevention
                            and Toxics
                            Washington, DC 20460
July 1995
EPA 745-R-95-012
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
EPCRA Section  313
Guidance for Reporting  Aqueous Ammonia

      EPCRA Section 313  of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using listed
toxic chemicals to report their environmental releases of such chemicals annually. Beginning with
the 1991 reporting year, such facilities also must report pollution prevention and recycling data
for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42 U.S.C. 13106.
When enacted, EPCRA Section 313 established an initial list of toxic chemicals that was
comprised of more than 300  chemicals and 20 chemical categories.  EPCRA Section 313(d)
authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth criteria for
these actions.
                                   CONTENTS

            Introduction	C-2
            Who Must Report	C-2
            Thresholds	C-2
            Chemical Sources of Aqueous Ammonia  	C-3
            De Minimis Concentrations 	C-3

            Guidance for Reporting Aqueous Ammonia	C-4
            Determining Threshold and Release Quantities for Ammonia  	C-4
            Chemical Sources of Aqueous Ammonia  	C-5
            2.2.1  Reporting Aqueous Ammonia Generated from Anhydrous Ammonia
                  in Water	C-5
            2.2.2  Reporting of Ammonia Generated from the Dissociation of
                  Ammonium Salts (Other Than Ammonium Nitrate)	C-6
            2.2.3  Reporting of Aqueous Ammonia Generated from the Dissociation
                  of Ammonium Nitrate	C-7
Section 3.    CAS Number and List of Some Chemical Sources of Aqueous Ammonia  . . . C-10
Section 1.
      1.1
      1.2
      1.3
      1.4

Section 2.
      2.1
      2.2
                                      C-l

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                                 Section 1.  Introduction

       On June 30, 1995 EPA finalized four actions in response to a petition received in 1989 to
delete ammonium sulfate (solution) from the list of toxic chemicals subject to reporting under
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986
(EPCRA), 42 U.S.C. 11001. The four actions taken are summarized as follows: (1) deleted
ammonium sulfate (solution) from the EPCRA Section 313 list of toxic chemicals, (2) required
that threshold and release determinations for aqueous ammonia be based on  10 percent of the
total aqueous ammonia present in aqueous solutions of ammonia, (3) modified the ammonia
listing by adding the following qualifier:  ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous
ammonia is reportable under this listing), and (4) deleted ammonium nitrate (solution) as a
separately listed chemical on the EPCRA Section 313 list of toxic chemicals. All actions are
effective for the 1994 reporting year for reports due July 1, 1995, with the exception of the
deletion of ammonium nitrate (solution) as a separately listed chemical, which is effective for the
1995 reporting year for reports due July 1, 1996. At the time that these actions were finalized,
EPA indicated that the Agency would develop,  as appropriate, interpretations and guidance that
the Agency determines are necessary to facilitate accurate reporting for aqueous ammonia.  This
document constitutes such guidance for reporting under the ammonia listing.

Section 1.1    Who Must Report

       A plant, factory, or other facility is subject to the provisions of EPCRA Section 313, if it
meets all three of the following criteria:

       •       It conducts manufacturing operations (is included in Standard Industrial
              Classification (SIC) codes 20 through 39); and

       •       It has 10 or more full-time employees (or the equivalent 20,000 hours per year);
              and

       •       It manufactures, imports, processes, or  otherwise uses any of the toxic chemicals
              listed on the EPCRA Section 313 list in amounts greater than the "threshold"
              quantities specified below.

Section 1.2    Thresholds

       Thresholds are specified amounts of toxic chemicals used during the calendar year that
trigger reporting requirements.

       If a facility manufactures or imports any of the listed toxic chemicals, the threshold
quantity will be:

       •       25,000 pounds per toxic chemical or category over the calendar year.
                                           C-2

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       If a facility processes any of the listed toxic chemicals, the threshold quantity will be:

       •      25,000 pounds per toxic chemical or category over the calendar year.

       If a facility otherwise uses any of the listed toxic chemicals (without incorporating it into
any product or producing it at the facility), the threshold quantity is:

       •      10,000 pounds per toxic chemical or category over the calendar year.

Section 1.3   Chemical Sources of Aqueous Ammonia

       If a facility manufactures, processes, or otherwise uses anhydrous ammonia or aqueous
ammonia, they must report under the ammonia listing. EPA is providing a table of Chemical
Abstract Service (CAS) numbers and chemical names to aid the regulated community in
determining whether they need to report under the ammonia listing for aqueous ammonia.  This
table includes a list of water dissociable ammonium salts which, when placed in water, are a
source of aqueous ammonia. The table contains only commonly used ammonium salts and
therefore is not exhaustive.  If a facility manufactures, processes, or otherwise uses aqueous
ammonia, regardless of its source, it must report under the ammonia listing, even if the source of
the aqueous ammonia is not listed in the table provided in this document.

Section 1.4   De Minimis Concentrations

       The ammonia listing is subject  to the one percent de minimis concentration.  Thus,
solutions containing aqueous ammonia at a concentration in excess of one percent of the 10
percent reportable under this listing should be factored into threshold and release determinations.
                                           C-3

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                  Section 2. Guidance for Reporting Aqueous Ammonia

       Note: for the purposes of reporting under the ammonia listing for aqueous ammonia,
water dissociable ammonium salts means that the ammonium ion dissociates from its counterion
when in solution.

Section 2.1    Determining Threshold and Release Quantities for Ammonia

       If a facility manufactures, processes, or otherwise uses anhydrous ammonia, the quantity
applied towards threshold determinations for the ammonia listing is the total quantity of the
anhydrous ammonia manufactured, processed, or otherwise used. The quantity reported when
calculating the amount of ammonia that is released, transferred, or otherwise managed is the total
quantity of anhydrous ammonia released or transferred.

       If the facility manufactures, processes, or otherwise uses anhydrous ammonia in quantities
that exceed the appropriate threshold and subsequently dissolves some or all of the anhydrous
ammonia in water, then the following applies:  1) threshold determinations are based on 100
percent of the anhydrous ammonia (simply  10 percent of aqueous ammonia); 2) release, transfer,
and other waste management quantities for the aqueous ammonia are calculated as 10 percent of
total ammonia; 3) release, transfer, and other waste management quantities for the anhydrous
ammonia are calculated as 100 percent of the anhydrous ammonia.

       If a facility manufactures, processes, or otherwise uses aqueous ammonia, the quantity
applied toward threshold determinations for the ammonia listing is 10 percent of the total  quantity
of the aqueous ammonia manufactured, processed, or otherwise used. The quantity reported
when calculating the amount of ammonia that is released, transferred, or otherwise managed is 10
percent of the total quantity of aqueous ammonia released or transferred.

       If a facility dissolves a water dissociable ammonium salt in water that facility has
manufactured  aqueous ammonia and 10 percent of the total aqueous ammonia manufactured
from these salts is to be included in manufacturing threshold determinations under the ammonia
listing.

       If aqueous ammonia from water dissociable ammonium salts is processed or otherwise
used, then 10 percent of the total aqueous ammonia is to be included in all processing and
otherwise use threshold determinations  under the ammonia listing.
 Example 1: In a calendar year, a facility places 25,000 Ibs of anhydrous ammonia in water for
 processing and processes 25,000 Ibs of aqueous ammonia from an ammonium salt. The facility
 must include all of the 25,000 Ibs of anhydrous ammonia in the determination of the processing
 threshold, but only 10 percent (or 2,500 Ibs) of the aqueous ammonia from the ammonium salt
 in the processing threshold determination.	
                                          C-4

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       Total aqueous ammonia is the sum of the two forms of ammonia (un-ionized, NH3, and
ionized, NH4+) present in aqueous solutions.  A precise calculation of the weight of total aqueous
ammonia would require determining the ratio of the two forms of ammonia present using the pH
and temperature of the solution.  The weight of total aqueous ammonia can be more easily
calculated by assuming that aqueous ammonia is comprised entirely of the NH4+ form or the NH3
form. For the purpose of determining threshold and release quantities under EPCRA Section 313,
EPA recommends that total aqueous ammonia be calculated in terms of NH3 equivalents (i.e., for
determining weights, assume total ammonia is comprised entirely of the NH3 form).  This method
is simpler than using pH and temperature data to determine the ratio of the two forms present and
is consistent with the presentation of total ammonia toxicity in a separate EPA document,
Ambient Water Quality Criteria for Ammonia (EPA document #440/5-85-001, January 1985).

Section 2.2   Chemical Sources of Aqueous Ammonia

       Aqueous ammonia may be generated in solution from a variety of sources that include the
release of anhydrous ammonia to water and the dissociation of ammonium salts in water.  Water
dissociable ammonium salts are not reportable in their entirety under the ammonia listing; these
salts are reportable to the extent that they dissociate in water, and only 10 percent of the total
aqueous ammonia that results when these salts dissociate is reportable.  If these salts are not
placed in water, they are not reportable.

       If these salts are purchased neat or as solids by a facility, then placed in water by that
facility, the facility is manufacturing aqueous ammonia.

Section 2.2.1  Reporting Aqueous Ammonia Generated from Anhydrous Ammonia in
              Water

       If the source of aqueous ammonia is anhydrous ammonia in water, total aqueous ammonia
(calculated in terms  of NH3 equivalents) is equal to the quantity of anhydrous ammonia
manufactured,  processed, or otherwise used.  A hypothetical scenario demonstrating the
calculations involved in reporting aqueous ammonia generated from anhydrous ammonia in water
is given in Example  2.
 Example 2:  In a calendar year, a facility uses 30,000 pounds of anhydrous ammonia to
 neutralize acids in a wastewater stream.  The neutralized waste stream (containing aqueous
 ammonia from dissociated ammonium salts) is then transferred to a POTW.  The quantity to be
 applied toward threshold determinations is the total quantity of anhydrous ammonia used in the
 waste stream neutralization, or 30,000 pounds. The quantity of ammonia reported as
 transferred is 10 percent of the total quantity of aqueous ammonia transferred, or 3,000
 pounds.	
                                          C-5

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Section 2.2.2 Reporting Aqueous Ammonia Generated from the Dissociation of
             Ammonium Salts (Other Than Ammonium Nitrate)

       If the source of aqueous ammonia is the dissociation of ammonium salts in water, total
aqueous ammonia (calculated in terms of NH3 equivalents) is calculated from the weight percent
(wt%) of the NH3 equivalents of the ammonium salt.  The NH3 equivalent wt% of an ammonium
salt is calculated using the following equation:

         NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium salt)  x 100

If the source of aqueous ammonia is a monovalent compound (such as ammonium chloride,
NH4C1, ammonium nitrate, NH4NO3, or ammonium bicarbonate (NH4HCO3), the NH3 equivalent
weight is equal to the MW of NH3 (17.03 kg/kmol).  If divalent compounds are involved (such as
ammonium carbonate, (NH4)2CO3), then  the NH3 equivalent weight is equal to the MW of NH3
multiplied by two.  Similarly, if trivalent  compound are involved, then the NH3 equivalent weight
is equal to the MW of NH3 multiplied by three.
 Example 3:
 The NH3 equivalent wt% of ammonium chloride is calculated as follows:

 NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium chloride) x 100
 NH3 equivalent wt% = (17.03)7(53.49) x 100
 NH3 equivalent wt% = 31.84%

 The NH3 equivalent wt% of ammonium carbonate is calculated as follows:

 NH3 equivalent wt% = 2 x (NH3 equivalent weight)/(MW ammonium chloride) x 100
 NH3 equivalent wt% = 2 x (17.03)7(96.09) x  100
 NH3 equivalent wt% = 35.45%	
       To aid the regulated community in reporting under the ammonia listing for aqueous
ammonia, the table of chemical sources of aqueous ammonium provided in Section 3 of this
document includes, in addition to CAS number, chemical name, and molecular weight, the NH3
equivalent wt% of the commonly used, water dissociable ammonium salts listed in this table.
 Example 4: In a calendar year, a facility uses 100,000 pounds of ammonium chloride, NH4C1,
 in aqueous solution which is released to wastewater streams, then transferred to a POTW. The
 NH3 equivalent wt% of ammonium chloride is 31.84% (taken from Table 1 in Section 3 below
 or calculated as in Example 3 above). The total quantity of aqueous ammonia present in
 solution is 31.84% of the 100,000 pounds of ammonia chloride used, or 31,840 pounds.  The
 quantity applied towards threshold determinations for the ammonia listing is 10 percent of the
 total quantity of aqueous ammonia present in solution, or 3,184 pounds. The quantity of
 ammonia reported as released or transferred is 10 percent of the total quantity of aqueous
 ammonia released or transferred, or 3,184 pounds.	

                                          C-6

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 Example 5: In a calendar year, a facility uses 500,000 pounds of ammonium carbonate,
 (NH4)2CO3, and 400,000 pounds of ammonium bicarbonate, NH4HCO3, in aqueous solution
 which is released to wastewater streams, then transferred to a POTW.  The NH3 equivalent
 wt% of ammonium carbonate is 35.45%, and the NH3 equivalent wt% of ammonium
 bicarbonate is 21.54% (taken from Table 1 in Section 3 below or calculated as in Example 3
 above).  The quantity of aqueous ammonia present in solution from ammonium carbonate is
 35.45% of the 500,000 pounds of ammonia carbonate used, or 177,250 pounds. The quantity
 of aqueous ammonia present in solution from ammonium bicarbonate is 21.54% of the 400,000
 pounds of ammonia bicarbonate used or 86,160 pounds. The total quantity of aqueous
 ammonia present in solution is 263,410 pounds. The quantity applied towards threshold
 determinations for the ammonia listing is 10 percent of the total quantity of aqueous ammonia
 present in solution, or 26,341 pounds.  The quantity of ammonia reported as released or
 transferred is 10 percent of the total quantity of aqueous ammonia released or transferred, or
 26,341 pounds.	
Section 2.2.3 Reporting Aqueous Ammonia Generated from the Dissociation of
             Ammonium Nitrate

       Some sources of aqueous ammonia may be reportable under other EPCRA Section 313
category listings. Ammonium nitrate (solution) is relevant to reporting under the ammonia listing
to the extent that 10 percent of the total aqueous ammonia that results when ammonium nitrate
dissociates is reported when determining thresholds and calculating releases.  However, under the
nitrate compound category listing, ammonium nitrate (and other mixed salts containing
ammonium and nitrate) must be reported in its entirety. When reporting ammonium nitrate under
this category listing, the total nitrate compound, including both the nitrate ion portion and the
ammonium counterion, is included when determining threshold quantities.  However, only the
nitrate ion portion is included when determining the amount of ammonium nitrate that is released,
transferred, or otherwise managed in wastes.  The calculations involved in determining threshold
and release quantities for reporting under the nitrate compound category listing are described in a
separate directive, List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting (EPA document #745-R-95-002, February 1995). Note:
reporting ammonium  nitrate under the ammonia listing and nitrate compounds category listing is
effective for the 1995 reporting year for reports due July 1, 1996.
                                          C-7

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Example 6: In a calendar year, a facility uses 1,250,000 pounds of ammonium nitrate,
NH4NO3, in aqueous solution which is released to wastewater streams, then transferred to a
POTW. The NH3 equivalent wt% of ammonium nitrate is 21.28% (taken from Table 1 in
Section 3 below or calculated as in Example 3 above).  The total quantity of aqueous ammonia
present in solution is 21.28% of the 1,250,000 pounds of ammonia chloride used, or 266,000
pounds. The quantity applied towards threshold determinations for the ammonia listing is 10
percent of the total quantity of aqueous ammonia present in solution, or 26,600 pounds.  The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 26,600 pounds. For determining thresholds and
calculating  releases under the nitrate compound category  listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February, 1995).	

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Example 7:  In a calendar year, a facility transfers 100,000 pounds of nitric acid (HNO3) to an
on-site treatment facility.  The nitric acid is neutralized with anhydrous ammonia, and treatment
efficiency is 95 percent (the nitrate compound formed as a result of the treatment is ammonium
nitrate, NH4NO3).  The neutralized waste stream (containing aqueous ammonia from
dissociated ammonium nitrate) is then transferred to a POTW. The quantity of nitric acid
neutralized is 95 percent of 100,000 pounds or 95,000 pounds.  The quantity of nitric acid
neutralized is converted first to kilograms then to kilomoles using the following equations:

       Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
       Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)

Substituting the appropriate values into the above equations yields:

       Kilograms HNO3 neutralized = 95,000 Ibs  x  0.4536  kg/lb = 43,092 kg
       Kilomoles HNO3 neutralized = 43,092 kg H- 63.01 kg/kmol = 683.9 kmol

The quantity of anhydrous ammonia used in kilomoles in the acid neutralization and the
quantity of ammonium nitrate generated in kilomoles from the neutralization are equal to the
quantity of nitric acid neutralized (683.9 kmol). The quantity of anhydrous ammonia used in
kilograms and pounds in the acid neutralization is calculated as follows:

       Kilograms NH3 used = (kmol NH3) x (MW of NH3 in kg/kmol)
       Pounds NH3 used = (kg NH3) x (2.205 Ibs/kg)

Substituting the appropriate values into the above equation yields:

       Kilograms NH3 used = (683.9 kmol) x (17.03 kg/kmol) = 11,647 kmol
       Pounds NH3 used = (11,647 NH3)  x (2,205 Ibs/kg) = 25,682 pounds

The quantity reported applied towards threshold determinations for the ammonia listing is the
total quantity of anhydrous ammonia used in the acid neutralization, or 25,682 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred,  or 2,568 pounds.  For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February 1995).	
                                          C-9

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    Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia
      EPA is providing the following table of CAS numbers and chemical names to aid the
regulated community in determining whether they need to report under the ammonia listing for
aqueous ammonia. If a facility manufactures, processes, or otherwise uses, in aqueous solution, a
chemical which is listed below, they must report 10 percent of the total aqueous ammonia that is
the result of the dissociation of this chemical. However, this list is not exhaustive. If a facility
manufactures, processes, or otherwise uses, in aqueous solution, a water dissociable ammonium
compound, they must report 10 percent of the total aqueous ammonia that is the result of the
dissociation of the compound, even if the compound does not appear in the following table.

                                    Table C-l
               Listing by CAS Number and Molecular Weight of
                 Some Chemical Sources of Aqueous Ammonia
Chemical Name
Ammonium acetate
Ammonium aluminum sulfate
(Ammonium aluminum disulfate)
Ammonium antimony fluoride
(Diammonium pentafluoroantimonate)
Ammonium arsenate
(Ammonium arsenate, hydrogen)
(Ammonium arsenate, dihydrogen)
Ammonium arsenate
(Diammonium arsenate)
(Diammonium arsenate, hydrogen)
(Diammonium arsenate, monohydrogen)
Ammonium arsenite
Ammonium azide
Ammonium benzenesulfonate
Ammonium benzoate
Ammonium bromate
Ammonium bromide
Ammonium cadmium chloride
(Ammonium cadmium trichloride)
Ammonium carbamate
Ammonium carbonate carbamate
Molecular
Weight*
77.08
237.14
252.82
158.97
176.00
124.96
60.06
175.20
139.15
145.94
97.94
236.81
78.07
157.13
NH3
Equivalent
Wt%
22.09
7.181
13.47
10.71
19.35
13.63
28.35
9.720
12.24
11.67
17.39
7.191
21.81
21.68
CAS Number
631-61-8
7784-25-0
32516-50-0
13462-93-6
7784-44-3
13462-94-7
12164-94-2
19402-64-3
1863-63-4
13843-59-9
12124-97-9
18532-52-0
1111-78-0
8000-73-5
                                       C-10

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Table C-l (Continued)
Chemical Name
Ammonium carbonate
(Diammonium carbonate)
Ammonium carbonate, hydrogen
(Ammonium bicarbonate)
Ammonium cerium nitrate
(Ammonium hexanitratocerate)
(Ammonium hexanitratocerate (IV))
(Diammonium cerium hexanitrate)
Ammonium cerous nitrate
(Ammonium cerous nitrate, tetrahydrate)
Ammonium chlorate
Ammonium perchlorate
Ammonium chloride
Ammonium chromate
(Ammonium chromate (VI))
(Diammonium chromate)
Ammonium chromate
(Ammonium dichromate)
(Ammonium dichromate (VI))
(Ammonium bichromate)
(Diammonium dichromate)
Ammonium chromium sulfate
(Ammonium chromic sulfate)
Ammonium citrate
(Ammonium citrate, monohydrogen)
(Ammonium citrate, dibasic)
(Diammonium citrate)
(Diammonium citrate, hydrogen)
Ammonium citrate
(Ammonium citrate, tribasic)
(Triammonium citrate)
Ammonium cobalt sulfate
(Ammonium cobaltous sulfate)
Ammonium cupric chloride
(Ammonium chlorocuprate (II))
(Diammonium copper tetrachloride)
(Diammonium tetrachlorocuprate)
Ammonium cyanate
(Ammonium isocyanate)
Molecular
Weight*
96.09
79.06
548.23
486.22
101.49
117.49
53.49
152.07
252.06
265.17
226.19
243.22
289.14
241.43
60.06
NH3
Equivalent
Wt%
35.45
21.54
6.213
7.005
16.78
14.49
31.84
22.40
13.51
6.422
15.06
21.01
11.78
14.11
28.35
CAS Number
506-87-3
1066-33-7
16774-21-3
13083-04-0
10192-29-7
7790-98-9
12125-02-9
7788-98-9
7789-09-5
13548-43-1
3012-65-5
3458-72-8
13596-46-8
15610-76-1
22981-32-4
        C-ll

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Table C-l (Continued)
Chemical Name
Ammonium cyanide
Ammonium cyanoaurate, monohydrate
(Ammonium tetracyanoaurate, monohydrate)
Ammonium cyanoaurate
(Ammonium dicyanoaurate)
Ammonium ferricyanide
(Ammonium hexacyanoferrate (III))
(Triammonium hexacyanoferrate)
Ammonium ferrocyanide
(Ammonium hexacyanoferrate (II))
(Tetraammonium ferrocyanide)
(Tetraammonium hexacyanoferrate)
Ammonium fluoride
Ammonium fluoride
(Ammonium difluoride)
(Ammonium bifluoride)
(Ammonium fluoride, hydrogen)
(Ammonium difluoride, hydrogen)
(Ammonium bifluoride, hydrogen)
Ammonium fluoroborate
(Ammonium tetrafluoroborate)
Ammonium fluorogermanate (IV)
(Ammonium hexafluorogermanate (IV))
(Diammonium hexafluorogermanate)
Ammonium fluorophosphate
(Ammonium hexafluorophosphate)
Ammonium fluorosulfate
(Ammonium fluorosulfonate)
Ammonium formate
Ammonium gallium sulfate
Ammonium hydroxide
Ammonium iodide
Ammonium iridium chloride
(Ammonium chloroiridate (III))
(Ammonium hexachloroiridate)
(Triammonium hexachloroiridate)
Molecular
Weight*
44.06
319.07
267.04
266.07
284.11
37.04
57.04
104.84
222.66
163.00
117.10
63.06
282.90
35.05
144.94
459.05
NH3
Equivalent
Wt%
38.65
5.337
6.377
19.20
23.98
45.98
29.86
16.24
15.30
10.45
14.54
27.01
6.020
48.59
11.75
11.13
CAS Number
12211-52-8
14323-26-3
31096-40-9
14221-48-8
14481-29-9
12125-01-8
1341-49-7
13826-83-0
16962-47-3
16941-11-0
13446-08-7
540-69-2
15335-98-5
1336-21-6
12027-06-4
15752-05-3
        C-12

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Table C-l (Continued)
Chemical Name
Ammonium iron sulfate
(Ammonium ferric sulfate)
(Ammonium iron disulfate)
Ammonium iron sulfate
(Ammonium ferrous sulfate)
(Diammonium iron disulfate)
(Diammonium ferrous disulfate)
Ammonium lactate
(Ammonium 2-hydroxypropionate)
Ammonium laurate
(Ammonium dodecanoate)
Ammonium magnesium sulfate
Ammonium malate
Ammonium malate, hydrogen
(Ammonium bimalate)
Ammonium molybdate
(Diammonium molybdate)
Ammonium molybdate
(Ammonium heptamolybdate)
(Ammonium molybdate, hydrate)
(Ammonium molybdate, tetrahydrate)
(Ammonium />aramolybdate, tetrahydrate)
Ammonium nickel chloride, hexahydrate
Ammonium nickel sulfate
(Ammonium nickel sulfate, hexahydrate)
(Ammonium nickel disulfate, hexahydrate)
(Diammonium nickel disulfate, hexahydrate)
Ammonium nitrate
Ammonium nitrate sulfate
Ammonium nitrite
Ammonium oleate
Ammonium oxalate
Ammonium palladium chloride
(Ammonium chloropalladate (II))
(Ammonium tetrachloropalladte (II))
(Diammonium tetrachloropalladate)
Ammonium phosphate
(Ammonium orthophosphate)
Molecular
Weight*
269.02
286.05
107.11
217.35
252.50
168.15
151.12
196.01
1,163.8
183.09
286.88
80.04
212.18
64.04
299.50
124.10
284.31
149.09
NH3
Equivalent
Wt%
6.330
11.91
15.90
7.835
13.49
20.26
11.27
17.38
8.780
9.301
11.87
21.28
24.08
26.59
5.686
27.45
11.98
34.27
CAS Number
10138-04-2
10045-89-3
515-98-0
2437-23-2
14727-95-8
6283-27-8
5972-71-4
13106-76-8
12054-85-2
16122-03-5
7785-20-8
6484-52-2
12436-94-1
13446-48-5
544-60-5
1113-38-8
13820-40-1
10124-31-9
        C-13

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Table C-l (Continued)
Chemical Name
Ammonium phosphate
(Ammonium biphosphate)
(Ammonium phosphate, hydrogen)
(Ammonium phosphate, dihydrogen)
(Ammonium orthophosphate, dihydrogen)
(Ammonium phosphate, monobasic)
Ammonium phosphate
(Ammonium phosphate, hydrogen)
(Ammonium orthophosphate, monohydrogen)
(Ammonium phosphate, dibasic)
(Ammonium orthophosphate, dibasic)
(Diammonium phosphate)
(Diammonium orthophosphate)
(Diammonium phosphate, hydrogen)
(Diammonium phosphate, monohydrogen)
(Diammonium orthophosphate, hydrogen)
Ammonium phosphinate
(Ammonium hypophosphite)
Ammonium phosphite
(Ammonium biphosphite)
(Ammonium phosphite, dihydrogen)
Ammonium picramate
Ammonium propionate
Ammonium rhodium chloride
(Ammonium chlororhodate (III))
(Ammonium hexachlororhodate (III))
(Triammonium rhodium hexachloride)
(Triammonium hexachlororhodate)
Ammonium salicylate
(Ammonium 2-hydroxybenzoate)
Ammonium selenide
Ammonium silicon fluoride
(Ammonium fluorosilicate)
(Ammonium hexafluorosilicate)
(Diammonium silicon hexafluoride)
(Diammonium fluorosilicate)
(Diammonium hexafluorosilicate)
Ammonium stearate
(Ammonium octadecanoate)
Ammonium succinate
(Diammonium succinate)
Molecular
Weight*
115.03
132.06
83.03
99.03
216.15
91.11
369.74
155.15
115.04
178.15
301.51
152.15
NH3
Equivalent
Wt%
14.80
25.79
20.51
17.20
7.879
18.69
13.82
10.98
29.61
19.12
5.648
22.39
CAS Number
7722-76-1
7783-28-0
7803-65-8
13446-12-3
1134-85-6
17496-08-1
15336-18-2
528-94-9
66455-76-3
16919-19-0
1002-89-7
2226-88-2
        C-14

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Table C-l (Continued)
Chemical Name
Ammonium sulfamate
(Ammonium amidosulfate)
(Ammonium amidosulfonate)
Ammonium sulfate
(Diammonium sulfate)
Ammonium sulfate
(Ammonium bisulfate)
(Ammonium sulfate, hydrogen)
(Ammonium sulfate, monohydrogen)
Ammonium persutf ate
(Ammonium peroxy sulfate)
(Ammonium peroxy disulfate)
(Diammonium persulfate)
(Diammonium peroxy difulsite)
Ammonium sulfide
(Ammonium bisulfide)
(Ammonium sulfide, hydrogen)
Ammonium sulfide
(Ammonium monosulfide)
(Diammonium sulfide)
Ammonium sulfide
(Diammonium pentasulfide)
Ammonium sulfite, monohydrate
(Diammonium sulfite, monohydrate)
Ammonium sulfite
(Ammonium bisulfite)
(Ammonium sulfite, hydrogen)
Ammonium tetrachloroaurate (III), hydrate
Ammonium thiocarbamate
Ammonium thiocarbonate
(Diammonium trithiocarbonate)
Ammonium thiocyanate
(Ammonium isothiocyanate)
(Ammonium sulfocyanate)
(Ammonium rhodanate)
(Rhodamd)
Ammonium dithionate
Ammonium thiosulfate
(Ammonium hyposulfite)
(Diammonium thiosulfate)
Molecular
Weight*
114.12
132.13
115.10
228.19
51.11
68.14
196.39
116.13
99.10
356.82
94.13
144.27
76.12
196.19
148.20
NH3
Equivalent
Wt%
14.92
25.78
14.80
14.93
33.32
49.99
17.34
29.33
17.18
4.772
18.09
23.61
22.37
17.36
22.98
CAS Number
7773-06-0
7783-20-2
7803-63-6
7727-54-0
12124-99-1
12135-76-1
12135-77-2
7783-11-1
10192-30-0
13874-04-9
16687-42-6
13453-08-2
1762-95-4
60816-52-6
7783-18-8
        C-15

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                                    Table C-l (Continued)
Chemical Name
Ammonium tin bromide
(Ammonium bromostannate (IV))
(Ammonium hexabromostannate (IV))
(Diammonium hexabromostannate)
Ammonium tin chloride
(Ammonium chlorostannate (IV))
(Ammonium hexachlorostannate (IV))
(Diammonium tin hexachloride)
(Diammonium hexachlorostannate)
Ammonium titanium fluoride
(Ammonium fluorotitanate (IV))
(Ammonium hexafluorotitanate (IV))
(Diammonium titanium hexafluoride)
(Diammonium hexafluorotitanate)
Ammonium titanium oxalate, monohydrate
(Diammonium dioxalatooxotitanate, monohydrate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Hexaammonium tungstate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Decaammonium tungstate)
Ammonium valerate
(Ammonium pentoate)
Ammonium zinc chloride
(Ammonium chlorozincate)
(Ammonium tetrachlorozincate)
(Diammonium tetrachlorozincate)
Molecular
Weight*
634.19
367.48
197.95
276.00
1,779.2
3,058.6
119.16
243.27
NH3
Equivalent
Wt%
5.371
9.269
17.21
12.34
5.743
5.568
14.29
14.00
CAS Number
16925-34-1
16960-53-5
16962-40-6
10580-03-7
12028-06-7
11120-25-5
42739-38-8
14639-97-5
*For hydrated compounds, e.g., ammonium sulfite, monohydrate, the molecular weight excludes the weight of the hydrate portion.
                                               C-16

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                        Appendix D

  LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING

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                          United States
                          Environmental Protection
                          Agency
Office of Pollution Prevention and
Toxics
Washington, DC 20460
Revised May 1996
EPA 745-R-96-004
                          TOXICS RELEASE INVENTORY
                          List of Toxic Chemicals Within the Water Dissociable Nitrate
                          Compounds Category and Guidance for Reporting
       EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using listed
toxic chemicals to report their environmental releases of such chemicals annually.  Beginning with
the 1991 reporting year, such facilities also must report pollution prevention and recycling data
for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42 U.S.C. 13106.
When enacted, EPCRA Section 313 established an initial list of toxic chemicals that was
comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section 313(d)
authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth criteria for
these actions.
                                      CONTENTS

Section 1.     Introduction	D-2
       1.1     Who MustReport	D-2
       1.2     Thresholds	D-2
       1.3     Chemicals within  the Water Dissociable Nitrate Compounds Category  	D-3
       1.4     De Minimis Concentrations 	D-3

Section 2.     Guidance for Reporting Chemicals within the Water Dissociable Nitrate
              Compounds Category	D-4
       2.1     Chemicals within  the Water Dissociable Nitrate Compounds Category  	D-4
       2.2     Determining Threshold and Release Quantities for Nitrate Compounds	D-4
       2.3     Reporting Nitrate  Compounds Generated from the Partial or  Complete
              Neutralization of Nitric Acid	D-5
              2.3.1  Estimating Nitric Acid Releases  	D-6
              2.3.2  Estimating Treatment Efficiencies for Nitric Acid
                    Neutralization	D-8
              2.3.3  Estimating Releases of Nitrate Compounds Generated from the
                    Neutralization of Nitric Acid	D-9
       2.4     Generation of Nitrate Compounds from Biological Wastewater Treatment . . D-10

Section 3.     CAS Number List of Some of the Individual Chemicals within the Water
              Dissociable Nitrate Compounds Category	D-l 1
                                          D-l

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                                 Seciton 1. Introduction

       On November 30, 1994 EPA added 286 chemicals and chemical categories, which include
39 chemicals as part of two delineated categories, to the list of toxic chemicals subject to
reporting under EPCRA  Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA), 42 U.S.C. 11001.  These additions are described at 59 FR 61432, and are
effective January 1, 1995 for reports due July 1, 1996.  Six chemical categories (nicotine and
salts, strychnine and salts, polycyclic aromatic compounds, water dissociable nitrate compounds,
diisocyanates, and poly chlorinated alkanes) are included in these additions. At the time of the
addition, EPA indicated that the Agency would develop, as appropriate, interpretations and
guidance that the Agency determines are necessary to facilitate accurate reporting for these
categories.  This document constitutes such guidance for the water dissociable nitrate compounds
category.

Section 1.1   Who Must Report

       A plant, factory, or other facility is subject to the provisions of EPCRA Section 313, if it
meets all three of the  following criteria:

       •     It conducts manufacturing operations (is included in Standard Industrial
             Classification (SIC) codes 20 through 39); and

       •     It has  10 or more full-time employees (or the equivalent 20,000 hours per year);
             and

       •     It manufactures, imports, processes, or otherwise uses any of the toxic chemicals
             listed on the EPCRA Section 313 list in amounts greater than  the "threshold"
             quantities specified below.

Section 1.2   Thresholds

       Thresholds are specified amounts of toxic chemicals used during the calendar year that
trigger reporting requirements.

       If a facility manufactures or imports any of the listed toxic chemicals, the thresholds
quantity will be:

       •     25,000 pounds  per toxic chemical or category over the calendar year.

       If a facility processes any of the listed toxic chemicals, the threshold quantity will be:

       •     25,000 pounds  per toxic chemical or category over the calendar year.
                                          D-2

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              If a facility otherwise uses any of the listed toxic chemicals (without incorporating
it into any product or producing it at the facility), the threshold quantity is:

       •      10,000 pounds per toxic chemical or category over the calendar year.

       EPCRA Section 313 requires threshold determinations for chemical categories to be based
on the total of all chemicals in the category manufactured, processed or otherwise used.  For
example, a facility that manufactures three members of a chemical category would count the total
amount of all three chemicals manufactured towards the manufacturing threshold for that
category. When filing reports for chemical categories, the releases are  determined in the same
manner as the thresholds. One report is filed for the category and all releases are reported on this
form.

Section 1.3    Chemicals Within the Water Dissociable Nitrate Compounds Category

       EPA is providing a list of CAS numbers and chemical names to aid the regulated
community in determining whether they need to report for the water dissociable nitrate
compounds category.  The list includes individual chemicals within the water dissociable nitrate
compounds category.  If a facility is manufacturing, processing, or otherwise using a chemical
which is on this list, they must report this chemical. However, this list  is not exhaustive. If a
facility is manufacturing, processing, or otherwise using a water dissociable nitrate compound,
they must report the chemical, even if it does not appear on the list.

Section 1.4    De Minimis Concentrations

       The water dissociable nitrate compounds category is subject to the one percent de minimis
concentration. Thus, mixtures that  contain members of this category in excess of the de minimis
should be factored into threshold and release  determinations.
                                           D-3

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    Section 2.  Guidance for Reporting Chemicals within the Water Dissociable Nitrate
                                 Compounds Category

       Note: for the purposes of reporting under the nitrate compounds category, water
dissociable means that the nitrate ion dissociates from its counterion when in solution.

Section 2.1   Chemicals within the Water Dissociable Nitrate Compounds Category

       Chemicals within the nitrate compounds category are only reportable when in aqueous
solution. All water dissociable nitrate compounds are included in the nitrate compounds category,
including ammonium nitrate. Specifically listed EPCRA Section 313 chemicals are not included
in threshold determinations for chemical categories such as the water dissociable nitrate
compounds category. Specifically listed toxic chemicals are  subject to their own individual
threshold determinations.  As of December 1,  1994, ammonium nitrate (solution) is not an
individually listed chemical on the EPCRA Section 313 list. However, ammonium nitrate is still
subject to reporting under the nitrate compounds category. In addition, the aqueous ammonia
from the dissociation of ammonium nitrate when in aqueous  solution is subject to  reporting under
the ammonia listing.

Section 2.2   Determining Threshold and Release Quantities for Nitrate Compounds

       The total nitrate compound, including both the nitrate ion portion and the counterion, is
included in the nitrate compounds category. When determining threshold amounts, the total
weight of the nitrate compound is to be included in all calculations. However, only the nitrate ion
portion is to be included when determining the amount of the chemicals within the nitrate
compounds category that is released, transferred, or otherwise managed in wastes.
 Example 1: In a calendar year, a facility processes 100,000 pounds of ammonium nitrate
 (NH4NO3), in aqueous solution, which is released to wastewater streams then transferred to a
 POTW. The quantity applied towards threshold calculations for the nitrate compounds
 category is the total quantity of the nitrate compound or 100,000 pounds.  Since this quantity
 exceeds the 25,000 pound processing threshold, the facility is required to report for the nitrate
 compounds category. Under the nitrate compounds category, only the weight of the nitrate ion
 portion of ammonium nitrate is included in release transfer calculations. The molecular weight
 of the ammonium nitrate is 80.04 and the weight of the nitrate ion portion is 62.01 or 77.47
 percent of the molecular weight of ammonium nitrate.  Therefore, the amount of nitrate ion
 reported as transferred to the POTW is 77.47 percent of 100,000 pounds or 77,470 pounds
 (reported as 77,000 pounds). The aqueous ammonia from ammonium nitrate is reportable
 under the EPCRA Section 313 listing for ammonia.  For determining thresholds and calculating
 releases under the ammonia listing, see the separate directive, Guidance for Reporting Aqueous
 Ammonia (EPA document #745-R-95-0003, July 1995).	
                                          D-4

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 Example 2:  In a calendar year, a facility manufactures as by-products 20,000 pounds of sodium
 nitrate (NaNO3) and 10,000 pounds of calcium nitrate (Ca(NO3)2), both in aqueous solutions,
 and releases these solutions to wastewater streams.  The total quantity of nitrate compounds
 manufactured by the facility is the sum of the two chemicals, or 30,000 pounds, which exceeds
 the manufacturing threshold quantity of 25,000 pounds.  The facility therefore is required to
 report for the nitrate compounds category.  By weight, the nitrate ion portion is 72.96 percent
 of sodium nitrate and is 75.57 percent of calcium nitrate.  Of the 20,000 pounds of the sodium
 nitrate in solution, 72.96 percent or 14,592 pounds is nitrate ion, and similarly, of the 10,000
 pounds of the calcium nitrate in solution, 75.57 percent or 7,557 pounds is nitrate ion.  The
 total nitrate ion in aqueous solution released by the facility is the sum of the nitrate ion in the
 two solutions or 22,149 pounds (reported as 22,000 pounds).	
Section 2.3   Reporting Nitrate Compounds Generated from the Partial or Complete
              Neutralization of Nitric Acid

       Nitric acid is an individually listed chemical on the original EPCRA Section 313 list and is
reported as a separate chemical if the manufacture, process, or otherwise use thresholds are
exceeded. The partial or complete neutralization of nitric acid results in the formation of nitrate
compounds which are reported as chemicals within the nitrate compounds category if their
manufacture, process, or otherwise use thresholds are exceeded.

       Mineral acids such as nitric acid may be present in aqueous waste streams that are sent to
on-site neutralization or are discharged to a publicly owned treatment works (POTW) or other
off-site treatment facility. As  stated in the Toxic Chemical Release Inventory Reporting Form R
and Instructions document (revised 1993 version, EPA 745-K-94-001), on-site acid neutralization
and its efficiency must be reported in Part II, section 7 A of Form R (waste treatment methods and
efficiency section). For purposes of reporting on Form R, EPA considers a waste mineral acid at
a pH 6 or higher to be 100 percent neutralized (water discharges to receiving streams or POTWs
are reported as zero). The nitrate compounds produced from the complete neutralization (pH 6.0
or above) of nitric acid  are reportable under the nitrate compounds category and should be
included in all threshold and release calculations.  Two Form R reports would be required if the
manufacture, process or otherwise use thresholds are exceeded for nitric acid and for the nitrate
compounds category.

       If the nitric acid treatment efficiency is not equal to 100 percent (pH is less than 6), the
amount of the acid remaining in the waste stream which is released to the environment on-site or
off-site must be reported in Part II of Form R. The nitrate compounds produced from the partial
neutralization of nitric acid are reportable under the nitrate compounds category and should be
included in all threshold and release calculations.  Two reports would again be required if the
manufacture, process or otherwise use thresholds are exceeded for nitric acid and for the nitrate
compounds category.
                                           D-5

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Section 2.3.1  Estimating Nitric Acid Releases

       The pH of the waste stream can be used to calculate the amount of nitric acid in the
stream and the efficiency of neutralization. The pH is a measure of the acidity or alkalinity of a
waste stream and can be obtained readily using a pH meter or pH sensitive paper. The pH scale
itself varies from 0 to 14.

       The total nitric acid concentration (ionized and un-ionized) in pounds per gallon can be
calculated by using the pH value of the solution, the molecular weight and ionization constant of
the acid, and appropriate conversion factors. The total acid concentration for nitric acid for
different pH values is listed in Table 1.  The calculation of mineral acid concentrations and the
derivation of Table 1 are discussed in a separate directive, Estimating Releases for Mineral Acid
Discharges Using pH Measurements, and an addendum to this directive.

       The procedure outlined in this guidance document for calculating the quantity of nitrate
compounds formed from the complete or partial neutralization of nitric acid can be used if nitric
acid is the only mineral acid in a solution. In addition, the calculation of nitric acid releases using
only pH measurements is a rough estimate.  The subsequent calculation of nitrate compound
releases is therefore also  only a rough estimate.  The estimates can be made for a waste stream
with a steady pH below 6 or for one whose pH temporarily drops to below pH 6. Facilities
should use their best engineering judgement and knowledge of the solution to evaluate how
reasonable the estimates are.
 Example 3:  In a calendar year, a facility transfers 1.0 million gallons of a solution containing
 nitric acid (HNO3), at pH 4, to a POTW.  Using Table 1 (next page), a pH of 4 corresponds to
 a concentration of 0.0000520 Ibs HNO3/gallon of solution. The weight of HNO3 transferred
 can be estimated using the equation:

              Transfer of HNO3 = (Concentration of HNO3) x (effluent flow rate)

 Substituting the example values into the above equation yields:

    Transfer of HNO3 = 0.0000520 Ibs/gal HNO3 x  1,000,000 gal solution/year = 52 Ibs/year
                                           D-6

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Example 4: A facility had an episodic release of nitric acid (HNO3) in which the waste stream
was temporarily below pH 6.  During the episode, the wastewater (pH 2.0) was discharged to a
river for 20 minutes at a rate of 100 gallons per minute.  Using Table 1, a pH of 2.0 for HNO3
represents a concentration of 0.0052000 Ibs HNO3/gallon of solution.  The amount of the
HNO3 released can be estimated using the following equation:

             Release of HNO3  = (concentration  of HNO3) * (effluent flow rate)

Substituting the example values  in the above equation:

               Release of HNO3 = 0.0052000 Ibs/gal x 100 gal/min x 20 min
                                      = 10 Ibs
                                    Table D-l
                      Nitric Acid Concentration Versus pH
pH
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
Nitric Acid Concentration
(Ibs/gallon)
0.5200000
0.3300000
0.2100000
0.1300000
0.0830000
0.0520000
0.0330000
0.0210000
0.0130000
0.0083000
0.0052000
0.0033000
0.0021000
0.0013000
0.0008300

pH
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
4.8
5.0
5.2
5.4
5.6
5.8
6.0
Nitric Acid Concentration
(Ibs/gallon)
0.0005200
0.0003300
0.0002100
0.0001300
0.0000830
0.0000520
0.0000330
0.0000210
0.0000130
0.0000083
0.0000052
0.0000033
0.0000021
0.0000013
0.0000008
0.0000005
                                        D-7

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Section 2.3.2  Estimating Treatment Efficiencies for Nitric Acid Neutralization

       Nitric acid solutions that are neutralized to a pH of 6 or above have a treatment efficiency
of 100 percent. If nitric acid is neutralized to a pH less than 6, then the reportable treatment
efficiency is somewhere between 0 and 100 percent.  It is possible to estimate the neutralization
treatment efficiency using nitric acid concentration values directly from Table 1 in the equation
given below. The concentrations correspond to the pH values before and after treatment.
                                                  (I-E)
                              Treatment efficiency =	x 100
where:
I      =      Acid concentration before treatment; and
E      =      Acid concentration after treatment.
 Example 5:  A nitric acid (HNO3) waste stream of pH 2.4 is neutralized to pH 4.6. Using
 Table 1, the initial nitric acid concentration is 0.0021000 mol/liter and the final concentration is
 0.0000130 mol/liter. Substituting these values into the equation for treatment efficiency:

                                          (0.0021000-0.0000130)
                      Treatment Efficienc = -         - x 100
                                      =99.4 percent
       For strong acids only (including nitric acid), the net difference in pH before and after
treatment can be used to estimate the treatment efficiency since pH is directly proportional to the
acid concentration. For example, a pH change of one unit results in a treatment efficiency of 90
percent, whether the pH change is from pH 1 to pH 2 or from pH 4 to pH 5.  Table 2 summarizes
treatment efficiencies for various pH changes (the pH change is the difference between the initial
pH and the pH after neutralization). In the table, some pH changes result in the same treatment
efficiency values due to rounding to one decimal place.
                                           D-8

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                                       Table D-2
           Nitric Acid Treatment Efficiencies for Various pH Changes
pH Unit Change
1.0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
Treatment Efficiency
(%)
90.0
92.1
93.7
95.0
96.0
96.8
97.5
98.0
98.4
98.7

pH Unit Change
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
3.0
Treatment Efficiency
(%)
99.0
99.2
99.4
99.5
99.6
99.7
99.8
99.8
99.8
99.9
99.9
 Example 6:  If a nitric acid (HNO3) waste stream of pH 2 is treated to pH 4, the pH change is 2
I units. Using Table 2 above, the treatment efficiency is given as 99.0 percent.                  ||

Section 2.3.3  Estimating Releases of Nitrate Compounds Generated from the
              Neutralization of Nitric Acid

       The nitrate compounds produced from the complete neutralization (pH 6.0 or above) or
partial neutralization (pH less than 6) or nitric acid are reportable under the nitrate compounds
category if the appropriate threshold is met and should be included in all threshold and release
calculations.  In order to determine the quantity of a nitrate compound generated and released, the
quantity of nitric acid released must be known (or calculated from the equations used in Examples
3 and 4 above) as well as the nitric acid treatment efficiency (calculated from the equations used
in Examples 5 and 6 above).

       The neutralization of nitric  acid will most likely result in the generation of monovalent
nitrate compounds (such as sodium nitrate and potassium nitrate). The quantity of these
compounds formed in kilomoles will be equal to the quantity of the nitric acid neutralized in
kilomoles. If divalent nitrate compounds are formed (such as calcium nitrate), the quantity of
these compounds formed in kilomoles will be equal to one-half the quantity of the nitric acid
neutralized in kilomoles. Similarly, if trivalent nitrate compounds are formed (such as iron (III)
nitrate), the quantity formed of these compounds  in kilomoles will be equal to one-third the
quantity of the nitric acid neutralized in kilomoles. Note: to calculate the releases of nitrate
compounds generated from the neutralization of nitric acid, the molecular weight of the nitrate
                                          D-9

-------
compound formed must be used. Molecular weights of some of the individual chemicals within
the water dissociable nitrate compounds category are given in Table 3.
 Example 7:  In a calendar year, a facility transfers 50,000 pounds of nitric acid (HNO3) to an
 on-site treatment facility.  The nitric acid treatment efficiency is 95 percent, and the nitrate
 compound formed as a result of the treatment is sodium nitrate (NaNO3). The quantity of nitric
 acid transferred that is neutralized (generating sodium nitrate) is 95 percent of 50,000 pounds
 or 47,500 pounds. The molecular weight of nitric acid is 63.01 kg/kmol, and the molecular
 weight of sodium nitrate is 84.99 kg/kmol.  The quantity of nitric acid neutralized is converted
 first to kilograms then to kilomoles using the following equations:

        Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x  (0.4536 kg/lb)
        Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)

 Substituting the example values into the above equation yields:

        Kilograms HNO3 neutralized = 47,500 Ibs x 0.4536 kg/lb = 21.546 kg

        Kilomoles HNO3 neutralized = 21,546 kg H- 63.01 kg/kmol = 341.9 kmol

 The quantity of sodium nitrate generated in kilomoles is equal to the quantity of nitric acid
 neutralized (341.9 kmol). The quantity of sodium nitrate generated in kilomoles is converted
 first to kilograms then to pounds using the following equations:

        Kilograms NaNO3 generated = (kmol NaNO3) x (MW of NaNO3 in kg/kmol)
        Pounds NaNO3 generated = (kg NaNO3) x (2.205 Ibs/kg)

 Substituting the values into the above  equation yields:

        Kilograms NaNO3 generated = 341.9 kmol x 84.99 kg/kmol = 29,058  kg
        Pounds NaNO3 generated = 29,058 kg x 2.205 Ibs/kg = 64,073 pounds (reported as
        64,000 pounds)

 The 64,000 pounds of sodium nitrate generated  is the quantity used to determine whether
 thresholds have been met or exceeded. The quantity of nitrate ion released is calculated as in
 Example 1 above.	
Section 2.4    Generation of Nitrate Compounds from Biological Wastewater Treatment

       If a facility treats wastewater on-site biologically, using the activated sludge process, for
example, the facility may be generating nitrate compounds as by-products of this biological
process. The nitrate ion generated from this process will be associated with various counterions
(e.g., sodium ion, potassium ion).  In the absence of information on the identity of the counterion,
a facility should assume for the purposes of EPCRA Section 313 threshold determinations that the
counterion is sodium ion.
                                          D-10

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    Section 3. CAS Number List of Some of the Individual Chemicals within the Water
                       Dissociable Nitrate Compounds Category
      EPA is providing the following table of CAS numbers and chemical names to aid the
regulated community in determining whether they need to report for the water dissociable nitrate
compounds category. If a facility is manufacturing, processing, or otherwise using a chemical
which is listed below, they must report this chemical.  However, this list is not exhaustive.  If a
facility is manufacturing, processing, or otherwise using a water dissociable nitrate compound,
they must report this chemical, even if it does not appear on the following list.

                                    Table D-3
   Listing by CAS Number and Molecular Weight of Some of the Individual
     Chemicals within the Water Dissociable Nitrate Compounds Category
Chemical Name
Aluminum nitrate, nonahydrate
Ammonium nitrate
Cerium (III) ammonium nitrate, tetrahydrate
Cerium (IV) ammonium nitrate
Barium nitrate
Beryllium nitrate, trihydrate
Cadmium nitrate
Cadmium nitrate, tetrahydrate
Calcium nitrate
Calcium nitrate, tetrahydrate
Cerium (III) nitrate, hexahydrate
Cesium nitrate
Chromium (III) nitrate, nonahydrate
Cobalt (II) nitrate, hexahydrate
Copper (II) nitrate, trihydrate
Copper (II) nitrate, hexahydrate
Dysprosium (III) nitrate, pentahydrate
Erbium (III) nitrate, pentahydrate
Gadolinium (III) nitrate, hexahydrate
Gallium nitrate, hydrate
Iron (III) nitrate, hexahydrate
Iron (III) nitrate, nonahydrate
Molecular Weight*
213.00
80.04
486.22
548.23
261.34
133.02
236.42
236.42
164.09
164.09
326.13
194.91
238.01
182.94
187.56
187.56
348.51
353.27
343.26
255.73
241.86
241.86
CAS Number
7784-27-2
6484-52-2
13083-04-0
10139-51-2
10022-31-8
7787-55-5
10325-94-7
10022-68-1
10124-37-5
13477-34-4
10294-41-4
7789-18-6
7789-02-8
10026-22-9
10031-43-3
13478-38-1
10031-49-9
10031-51-3
19598-90-4
69365-72-6
13476-08-9
7782-61-8
                                       D-ll

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                                      Table D-3 (Continued)
Chemical Name
Lanthanum (III) nitrate, hexahydrate
Lead (II) nitrate
Lithium nitrate
Lithium nitrate, trihydrate
Magnesium nitrate, dihydrate
Magnesium nitrate, hexahydrate
Manganese (II) nitrate, tetrahydrate
Neodymium (III) nitrate, hexahydrate
Nickel (II) nitrate, hexahydrate
Potassium nitrate
Rhodium (III) nitrate, dihydrate
Rubidium nitrate
Samarium (III) nitrate, hexahydrate
Scandium (III) nitrate
Scandium (III) nitrate, tetrahydrate
Silver nitrate
Sodium nitrate
Strontium nitrate
Strontium nitrate, tetrahydrate
Terbium (III) nitrate, hexahydrate
Thorium (IV) nitrate
Thorium (IV) nitrate, tetrahydrate
Yttrium (III) nitrate, hexahydrate
Yttrium (III) nitrate, tetrahydrate
Zinc nitrate, trihydrate
Zinc nitrate, hexahydrate
Zirconium (IV) nitrate, pentahydrate
Molecular Weight*
324.92
331.21
68.95
68.95
148.31
148.31
178.95
330.25
182.70
101.10
288.92
147.47
336.37
230.97
230.97
169.87
84.99
211.63
211.63
344.94
480.06
480.06
274.92
274.92
189.39
189.39
339.24
CAS Number
10277-43-7
10099-74-8
7790-69-4
13453-76-4
15750-45-5
13446-18-9
20694-39-7
16454-60-7
13478-00-7
7757-79-1
13465-43-5
13126-12-0
13759-83-6
13465-60-6
16999-44-3
7761-88-8
7631-99-4
10042-76-9
13470-05-8
13451-19-9
13823-29-5
13470-07-0
13494-98-9
13773-69-8
131446-84-9
10196-18-6
13986-27-1
*For hydrated compounds, e.g., aluminum nitrate, nonahydrate, the molecular weight excludes the weight of the hydrate portion. For
example, the same molecular weight is provided for aluminum nitrate, nonahydrate and aluminum nitrate.
                                                  D-12

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                                         INDEX
The pages listed in bold text in the index correspond to the primary uses or definitions of the
associated term. Additionally, this index includes a list of primary purposes for examples and
common errors that are presented throughout the document.
Acid aerosol (see Chemical-specific)
Agricultural activities	4-44
Air emissions
       Fugitive  . .  4-5, 4-7, 4-20, 4-24, 4-28, 4-31, 4-34 to 4-36, 4-38, 4-40 to 4-43, 4-50, 4-51
       Stack or Point source	4-5, 4-24, 4-34, 4-38, 4-43, 4-50, 4-51
Ammonia (see Chemical-specific)
Article exemption (see Exemption)
Auxiliary facility (see Facility)
Basic calculations (see Appendix B)
Byproduct (see Manufacture, Process descriptions)
Can making/can coating	 2-11, 4-1, 4-24, 4-47-48, 4-50
Catalysts (see Process descriptions)
Chemical-specific
       Acid aerosol (sulfuric acid & hydrochloric acid)	 3-6, 3-12, 4-40 to 4-42, 4-45
       Ammonia	2-12, 3-5, 3-8 to 3-10, 3-17, 3-19, 4-20, 4-31, 4-32, 4-34 to 4-36,
                   4-40 to 4-43, 4-45 to 4-47, A-12, B-16, C-l-3, C-5, C-7-15, C-17, D-7, D-8
              Guidance for reporting aqueous ammonia	  Appendix C
       Chlorine	2-11, 3-8, 3-10, 3-17, 4-19, 4-27-30, 4-34-36, 4-39, 4-40, 4-46
       Food dyes  	2-11, 3-9, 4-33
       Herbicides  	2-11, 4-44, 4-45
       Metals/Metal compounds	 3-5, 3-10, 3-14 to 3-15, 4-8, 4-10, 4-15, 4-19,
                                                        4-33, 4-36, 4-45, 4-47 to 4-49, 4-52
       Methanol	  3-17, 4-45
       Nitrate compounds	2-12,  3-5, 4-45, 4-47, C-14,  C-30
              Guidance for reporting nitrate compounds 	  Appendix D
       Pesticides	  2-11, 3-17, 4-44, 4-45
       Zinc	2-13, 3-5,  3-9, 4-33, 4-48, C-29, D-24
Chlorine (see Chemical-specific, Common errors)
Cleaning/disinfectant uses (see Process descriptions)
Coincidental manufacturing (see Manufacturing)
Combustion	3-14, 3-17, 3-18, 4-10, 4-12 to 4-14, 4-22, 4-38, 4-46 to 4-48
       For energy recovery off-site	4-13
       For energy recovery on-site	4-12 to 4-13
       For treatment off-site	4-38
       For treatment on-site	4-10
Common errors
       Ammonia	4-43
       Chlorine	  4-30, 4-40

                                         Index - i

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                                  INDEX (Continued)

       Double counting	4-16
       EPCRA Section 313 chemicals?	3-21
       Exempt activities	3-12
       Farm Workers and Part Time/Seasonal Workers  	2-10
       Mass balances for otherwise used chemicals	4-21
       Mineral acids	4-40
       Multi-establishment facilities  	2-8
       Other reporting  	4-1, 4-34, 4-36 to 4-37, 4-39, 4-44, 4-48, 4-52
       Pesticides	4-45
       Threshold determination	  3-6, 4-32
       Treatment efficiencies  	  4-19, D-15 to D-17
       What if Your Facility Has No Releases	3-21
Container residue (see Examples)
De minimis (see Examples, Exemption)
Documentation (see Recordkeeping)
Emission factor (see Reportable quantity estimates)
Energy recovery (see Combustion for energy recovery)
Engineering calculation	4-18, 4-22, 4-24
EPCRA Hotline	1-2 to 1-5, 2-10, 2-14
Establishment  	2-1, 2-2, 2-7 to 2-8, 2-16, 4-44, 4-45
Examples
       Calculating employees 	2-10
       Chemicals in process water  	3-18
       Chlorine calculations 	4-29
       Container residue	4-10
       De minimis  	3-13 to 3-14
       Emission factors	4-22
       Engineering calculations	4-24
       Form A threshold	2-16
       Mass balance	4-20
       Monitoring data	4-19
       Motor vehicle exemption	3-17
       Multiple establishments 	2-2
       On-site waste treatment	4-11
       Personal use exemption 	3-17
       Primary SIC code	2-8
       Process equipment chemical use	3-18
       Relabeling  	2-14
       Sulfuric acid aerosol	4-41
       Threshold determination	3-7
       Threshold worksheet	3-21
       Treatment of wastes from off-site	4-47
Exemption	3-11
       Activity-related  	3-16

                                         Index - ii

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                                    INDEX (Continued)

       Article	3-15, 4-49, 4-52
       De minimis  	3-12, 4-46, 4-48, 4-49, C-2, C-5, D-2, D-5
       Facility-related	3-16
       Grounds maintenance	3-17
       Janitorial 	3-17
       Laboratory	2-8, 3-16, B-15
       Motor vehicles	3-17
       Personal use	3-17
       Structural components	3-17
Extraction/carrier solvents (see Process descriptions)
Facility
       Auxiliary facility	  2-7, 2-9
       Covered facility 	  2-4, 2-8, 2-18, 4-45 to 4-47
       Multi-establishment facilities  	2-8
       Pilot plant  	  2-8, 3-16
Flow diagrams  (see Process flow diagrams)
Food dyes (see Chemical-specific)
Food ingredients (see Process descriptions)
Form A	1-4, 2-2, 2-15, 4-25, 4-30
Form R	  2-14, 4-5
       Section 5.1 (fugitive emissions)  	4-5
       Section 5.2 (stack  emissions)	4-5
       Section 5.3 (receiving streams)	4-5
       Section 5.4 (underground injection)	4-7
       Section 5.5 (on-site land)	4-7
       Section 6.1 (POTW)  	4-8
       Section 6.2 (other  off-site transfers)	4-8
       Section 7A (on-site treatment)	4-10
       Section 7B (on-site energy recovery)	4-12
       Section 7C (on-site recycling)  	4-12
       Section 8.1 (quantity released)	4-12
       Section 8.2 (quantity used for energy recovery, on-site)	4-13
       Section 8.3 (quantity used for energy recovery, off-site)	4-13
       Section 8.4 (quantity recycled on-site)	4-14
       Section 8.5 (quantity recycled off-site)	4-14
       Section 8.6 (quantity treated on-site) 	4-14
       Section 8.7 (quantity treated off-site)	4-15
       Section 8.8 (remedial actions, catastrophic events, one-time events)	4-15
Fumigants (see Process descriptions)
Guidance for reporting aqueous ammonia (see Chemical-specific)
Herbicides (see Chemical-specific)
Impurities (see Process descriptions)
                                          Index - iii

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                                  INDEX (Continued)

Impurity  	2-12, 3-8, 3-12
Manufacture/Manufacturing	2-10, 2-12, 3-5 to 3-8, 3-15, 4-23, 4-27, 4-31,
                                                                         4-41, 4-42, 4-48
       Byproduct	2-11, 2-12, 3-8, 3-14, 4-45
       Coincidental manufacture	 3-12, 3-14, 3-17, 4-27, 4-42, 4-43, 4-47, 4-48
       Import	2-12
Mass balance (see Examples, Reportable quantity estimates)
Metals/Metal compound (see Chemical-specific)
Methanol (see Chemical-specific)
Mixture	  2-12 to 2-14, 3-1 to 3-4, 3-10, 3-12, 3-21
Monitoring data/records (see Examples, Reportable quantity estimates)
MSDS	  3-3, 3-10
Nitrate compounds (see Chemical-specific)
North American Industry Classification System	2-4
Otherwise use 	2-10, 2-12 to 2-14, 3-5 to 3-8, 3-10, 3-17 to 3-19, 4-21, 4-27, 4-31, 4-33,
                                    4-35 to 4-37, 4-39, 4-42, 4-45 to 4-47, 4-49, A-9, C-8-10
Owner/operator	1-3
Penalties  	1-4
Pesticides (see Chemical-specific, Common errors)
Pilot plant (see Facility)
POTW	4-8, 4-10, 4-11,4-12, 4-15, 4-16, 4-19, 4-29 to 4-31, C-10,
                                                                 C-12-15,D-8, D-9, D-12
Process descriptions (Chemical Use Categories)  	4-27
       Byproducts or impurities  	4-45
       Can making/coating	4-48
       Catalysts  	4-36
       Cleaning/disinfectant uses	4-39
       Extraction/carrier solvents	4-37
       Food ingredients  	4-33
       Fumigants  	4-43
       Reactants	4-34
       Refrigerant uses	4-31
       Wastewater treatment  	4-40
       Water treatment	4-27
Process equipment	  3-10, 3-17, 3-18, 4-39
Process flow diagrams	4-3
       EPCRA Section 313 Reporting Decision Diagram  	2-3
       Release and Other Waste Management Calculation Approach  	4-2
Process/Processing  	2-10 to 2-14, 3-7, 3-9, 3-13, 4-27, 4-33 to 4-37
Reactants (see Process descriptions)
Recordkeeping  	2-17
Recycling	3-20
       Off-site  	 4-8, 4-12, 4-14, 4-38, 4-49, 4-50
       On-site	3-20, 4-12, 4-14

                                         Index - iv

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                                   INDEX (Continued)

Refrigerant uses (see Process descriptions)
Releases  	  4-1, 4-21
       Accidental (not production related)  	4-15
       Estimates (steps to calculate)	  4-1, 4-16
       Sources  	4-3
       Types	4-5
Remediation 	  3-19,4-16
Repackaging 	  2-13, 3-9
Reportable quantity/reportable amount  	1-4, 2-16, 2-19
Reporting criteria	2-1
Reuse 	3-5, 3-19, 4-7, 4-31, 4-49
Standard Industrial Classification	2-1, 2-4, 2-8
Supplier notification  	3-4
Technically qualified individual  	3-16
Thresholds	2-2, 2-4, 3-1
       Manufacturing	3-7
       Otherwise use  	3-7
       Processing	3-7
       Threshold determination	  3-7, 3-10, 3-20, 3-22
Total annual reportable amount (see Reportable quantity)
Trade name product	2-13, 3-1, 3-10 to 3-12
Trade secret	   1-4, 2-17
Transfers	4-7, 4-8, 4-13 to 4-15, D-12, D-19
Treatment
       Off-site  	4-8, 4-15, 4-47
       On-site	  4-7, 4-10, 4-14, 4-25
TRI database	1-3
Waste management (see Transfers)
Waste treatment (see Treatment)
Wastewater discharge  	4-5, 4-16, 4-40
Wastewater treatment  	  4-8, 4-40
Water treatment (see Process descriptions)
Zinc (see Chemical-specific)
                                          Index - v

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