United States
Environmental Protection
Agency
Office of Environmental
Information
Washington, DC 20460
EPA260-B-01-013
August 2001
&EPA Emergency Planning and Community Right-
To-Know Act Section 313 Reporting Guidance
for the Presswood and Laminated Products
Industry
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DISCLAIMER
This guidance is intended to assist industry with EPCRA sections 13 reporting for the presswood
and laminated products industry. In addition to providing an overview of aspects of the statutory
and regulatory requirements of the EPCRA section 313 program, this document also provides
recommendations and emission factors to assist industry with EPCRA reporting. These
recommendations do not supercede any statutory or regulatory requirements, are subject to
change, and are not independently binding on either EPA or covered facilities. Additionally, if a
conflict exists between this guidance and the statutory or regulatory requirements, the conflict
must be resolved in favor of the statute or regulation. Although EPA encourages industry to
consider these recommendations and emission factors, in reviewing this document, industry
should be aware that these recommendations and emission factors were developed to address
common circumstances at typical facilities. The circumstances at a specific facility may
significantly differ from those contemplated in the development of this document. Thus
individual facilities may find that the recommendations and emission factors provided in this
document are inapplicable to their processes or circumstances, and that alternative approaches or
information are more accurate and/or more appropriate for meeting the statutory and regulatory
requirements of EPCRA section 313. Facilities are encouraged to contact the Agency with any
additional or clarifying questions about the recommendations and emission factors in this
document, or if the facility believes that EPA has incorrectly characterized a particular process
or recommendation. Additional guidance documents, including industry- and chemical-specific
guidance documents, are available at the EPA TRI website: http://www.epa.gov/tri/.
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT vi
OVERVIEW vii
CHAPTER 1 - INTRODUCTION 1-1
1.0 PURPOSE 1-1
1.1 Background on EPCRA Section 313 and PPA Section 6607 1-3
CHAPTER 2 - REPORTING REQUIREMENTS 2-1
2.0 PURPOSE 2-1
2.1 Must You Report? 2-2
2.2 SIC Code Determination 2-5
2.3 Number of Employees 2-8
2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section
313 Chemicals or Chemical Categories 2-9
2.5 Activity Categories 2-11
2.6 Persistent, Bioaccumulative, and Toxic (PBT) Chemicals 2-14
2.7 How Do You Report? 2-16
2.8 Form R 2-17
2.9 Form A Certification 2-18
2.10 Trade Secrets 2-19
2.11 Recordkeeping 2-20
CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL CATEGORY
ACTIVITY THRESHOLD DETERMINATIONS 3-1
3.0 PURPOSE 3-1
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported), Processed, or
Otherwise Used 3-1
Qualifiers 3-4
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities
for Each EPCRA Section 313 Chemical and Chemical Category 3-8
3.2.1 Concentration Ranges for Threshold Determination 3-12
3.2.2 Evaluation of Exemptions 3-14
3.2.2.1 DeMmimis Exemption 3-14
3.2.2.2 Articles Exemption 3-17
3.2.2.3 Facility-Related Exemption 3-19
Laboratory Activity Exemption 3-19
3.2.2.4 Activity-Related Exemptions (Otherwise Use
Exemptions) 3-19
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TABLE OF CONTENTS (Continued)
Page
3.2.3 Additional Guidance on Threshold Calculations for Certain
Activities 3-21
3.2.3.1 Reuse Activities 3-22
3.2.3.2 Remediation Activities 3-22
3.2.3.3 Recycling Activities 3-23
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313
Chemical and Chemical Category and Determine Which Ones
Exceed an Activity Threshold 3-23
CHAPTER 4 - ESTIMATING RELEASE AND OTHER WASTE MANAGEMENT
QUANTITIES 4-1
4.0 PURPOSE 4-1
4.1 General Steps for Determining Release and Other Waste
Management Activity Quantities 4-1
4.1.1 Step 1: Prepare a Process Flow Diagram 4-3
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities 4-3
4.1.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-4
4.1.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-18
4.1.4.1 Monitoring Data or Direct Measurement (code M) . . . 4-20
4.1.4.2 Mass Balance (code C) 4-20
4.1.4.3 Emission Factors (code E) 4-22
4.1.4.4 Engineering Calculations (code O) 4-25
4.1.4.5 Estimating Release and Other Waste Management
Quantities 4-27
4.2 Determination of Release and Other Waste Management Activity
Quantities from the Presswood and Laminated Wood Products
Industry 4-32
4.2.1 Process Description 4-34
4.2.2 Drying 4-43
4.2.3 Presses 4-48
4.2.4 Finishing Operations 4-51
4.2.5 Combustion 4-54
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TABLE OF CONTENTS (Continued)
INDEX
Appendix A EPCRA SECTION 313 GUIDANCE RESOURCES
Appendix B BASIC CALCULATION TECHNIQUES
Appendix C PRESS WOOD/LAMINATED WOOD PRODUCTS EMISSION FACTORS
Appendix D UNIT CONVERSION FACTORS
in
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LIST OF TABLES
Page
2-1 SIC Codes Covered by EPCRA Section 313 Reporting 2-5
2-2 SIC Codes for Facilities That May Manufacture Presswood and Laminated
Wood Products 2-6
2-3 EPCRA Section 313 Chemicals and Chemical Categories Commonly
Encountered in Presswood and Laminated Wood Products Manufacturing . . 2-10
2-4 Activity Categories 2-12
2-5 Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals 2-14
3-1 Reporting Thresholds 3-8
3-2 Description of Manufacturing Subcategories 3-10
3-3 Description of Processing Subcategories 3-11
3-4 Description of Otherwise Use Subcategories 3-12
3-5 EPCRA Section 313 Reporting Threshold Worksheet 3-26
3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet 3-27
4-1 Summary of Liquid Residue Quantities From Pilot-Scale Experimental
Study 4-9
4-2 Potential Data Sources for Release and Other Waste Management
Calculations 4-19
4-3 Release and Other Waste Management Quantity Estimation Worksheet .... 4-28
4-4 Concentrations of Section 313 Constituents and Their Compounds Found
in No. 6 Fuel Oil and Tons of Oil Needed to Manufacture 25,000 Ibs 4-56
4-5 Section 313 Metal Emission Factors for Fuel Combustion 4-57
4-6 Emission Factor and Tons of No. 6 Fuel Oil Needed to Manufacture 25,000
Pounds of Formaldehyde 4-58
IV
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LIST OF FIGURES
Page
2-1 EPCRA Section 313 Reporting Decision Diagram 2-4
4-1 Release and Other Waste Management Activity Calculation Approach 4-2
4-2 Possible Release and Other Waste Management Activity Types
for EPCRA Section 313 Chemicals and Chemical Categories 4-5
4-3 Overall Process Flow Diagram - Application of Organic Coatings 4-33
4-4 Process Flow Diagram - Drying 4-44
4-5 Process Flow Diagram - Pressing 4-49
4-6 Process Flow Diagram - Finishing Operations 4-52
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ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of the Hardwood Plywood and Veneer Association (HPVA), the National Council of the Paper
Industry for Air and Stream Improvement, Inc. (NCASI), APA - the Engineered Wood
Association, and the American Hardboard Association (AHA). Without the insight provided by
those in industry with actual experience in fulfilling the reporting requirements of EPCRA
Section 313 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.
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OVERVIEW
This document supersedes the booklets entitled Title III Section 313 Release
Reporting Guidance, Estimating Chemical Releases from Presswood and Laminated Wood
Products Manufacturing (EPA-560/4-88-004i), dated March 1988. It is intended to assist
establishments and facilities manufacturing presswood and laminated wood products in
complying with the Emergency Planning and Community Right-To-Know Act (EPCRA) Section
313 and Pollution Prevention Act (PPA) Section 6607 reporting requirements, including the
preparation of Form R or Form A certification statement. The EPCRA Section 313 program is
commonly referred to as the Toxics Release Inventory (TRI).
The principal differences in this new document include:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
U.S. Environmental Protection Agency's (U.S. EPA's) interpretive
guidance on various issues specific to presswood and laminated wood
products operations; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
documents.
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 and PPA
Section 6607, starting with how to determine if your facility must report and ending with
guidance for estimating release and other waste management activity quantities.
Presswood and laminated wood products include a variety of products used in
many applications. Examples of the types of products that are covered in this document include
particleboard, oriented strandboard, hardboard, medium density fiberboard, plywood, veneer,
and engineered wood products. Other terms for these products include paneling and
reconstituted wood products. Presswood and laminated wood products are used in everything
from kitchen cabinets to building construction.
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While the specific operations and raw materials used in these processes vary,
environmental releases from the manufacture of presswood and laminated wood products
originate in essentially three types of operations:
1. Drying;
2. Gluing/pressing; and
3. Finishing operations.
The majority of EPCRA Section 313 chemical or chemical category releases and
other waste management activities from the manufacture of presswood and laminated wood
products are formaldehyde and methanol air emissions. These originate primarily from wood
dryers and hot presses. Finishing operations may also result in the release or management of
smaller quantities of solvents used in filling, painting, laminating, and edge finishing operations.
It is recognized that not all presswood and laminated wood products
manufacturing establishments will have all unit operations described in this document.
However, each of the unit operations discussed are common operations found in presswood and
laminated wood products manufacturing establishments covered by EPCRA Section 313
reporting requirements. To use this guidance, select the operation, or combination of operations,
that most closely fits the activities at your establishment.
Chapter 1 introduces EPCRA Section 313 and PPA Section 6607 reporting and
provides a brief background on Section 313 of EPCRA and Section 6607 of PPA.
Chapter 2 discusses reporting requirements and begins with how to determine
whether your facility must report. This determination is based on your answers to a series of
four questions:
Is your facility's primary SIC Code on the EPCRA Section 313 list?
Does your facility employ ten or more full-time employees or the
equivalent?
Does your facility manufacture, process, or otherwise use any EPCRA
Section 313 chemicals or chemical categories?
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Does your facility exceed any of the activity thresholds for an EPCRA
Section 313 chemical or chemical category?
If the answer to ANY ONE of the first three questions is "No" you are not
required to submit an EPCRA Section 313 report for any chemicals. If you answer "Yes" to the
first three questions and "No" to the fourth, you are not required to submit an EPCRA Section
313 report for that chemical or chemical category. 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 Form A
certification statement (40 CFR § 372.22) . Chapter 2 provides detailed information on the
requirements for each kind of report. Chapter 2 concludes with a discussion on how to address
trade secrets and the records that should be kept to support your reporting.
Chapter 3 discusses ways to calculate the activity thresholds (manufacture,
process, and otherwise use) for the EPCRA Section 313 chemicals or chemical categories.
Information is provided on how to determine which EPCRA Section 313 chemicals or chemical
categories your facility manufactures, processes, or otherwise uses and how to 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 or chemical categories exceed a reporting threshold.
Chapter 4 discusses ways to estimate the release and other waste management
activity amounts for those EPCRA Section 313 chemicals and chemical categories for which you
must prepare a report. The first part of this chapter provides a step-by-step approach designed to
minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical or
chemical category and any potential sources or types of release and other waste management
activities. This procedure consists of:
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Preparation of a detailed process flow diagram;
Identification of EPCRA Section 313 chemicals and chemical categories
and potential sources of chemical release and other waste management
activities;
Identification of the potential types of release and other waste
management activities from each source; and
Determination of the most appropriate methods for estimating the
quantities of EPCRA Section 313 chemical and chemical category release
and other waste management activities.
The second part of Chapter 4 is organized by the three typical activities in
presswood and laminated wood product manufacturing operations where EPCRA Section 313
chemicals and chemical categories are found: drying, pressing, and finishing. The commonly
used EPCRA Section 313 chemicals and chemical categories, process descriptions, release and
other waste management activity estimates, example calculations, and common problems are
presented.
This document includes examples and common errors applicable to presswood
and laminated wood products manufacturing operations. These examples are based on questions
and information received from representatives of the Hardwood Plywood and Veneer
Association (HPVA), the National Council of the Paper Industry for Air and Stream
Improvement, Inc. (NCASI), APA - the Engineered Wood Association, and the American
Hardboard Association (AHA), questions received by the EPCRA Hotline, and questions
identified during voluntary site surveys of facilities that have filed EPCRA Section 313 reports
in the past. Selected issues and guidance addressing these common problems are presented
throughout this document as applicable.
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CHAPTER 1 - INTRODUCTION
i.o PURPOSE
The purpose of this guidance manual is two-fold. The primary purpose is to assist
facilities manufacturing presswood and laminated wood products in complying with the
reporting requirements of Section 313 of the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA) and of Section 6607 of the Pollution Prevention Act of 1990 (PPA).
This manual explains the EPCRA Section 313 reporting requirements and discusses specific
release and other waste management activities encountered at many facilities that conduct these
types of operations. Since each plant is unique, the recommendations presented may have to be
modified for your particular facility. The secondary purpose is to provide information to other
interested parties (such as management, legal professionals, inspectors, consultants, teachers,
students, and the general public) about the processes and some of the toxic chemicals used in this
industry.
This manual is intended solely for guidance and does not alter any statutory or
regulatory requirements. The document should be used in conjunction with the appropriate
statutes and regulations, but does not supersede them. Accordingly, the reader should consult
other applicable documents (for example, the statute, the Code of Federal Regulations (CFR),
relevant preamble language, and the current Toxic Chemical Release Inventory Reporting Forms
and Instructions (TRI Forms and Instructions^ 2000 version; EPA-745-B-01-001, February
2001)).
This document supersedes the 1988 document entitled Title III Section 313
Release Reporting Guidance, Estimating Chemical Releases from Presswood and Laminated
Wood Products Manufacturing (EPA-560/4-88-004i). This new document includes:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
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•• U.S. Environmental Protection Agency's (U.S. EPA's) guidance on
various issues specific to presswood and laminated wood products; and
•• EPCRA Section 313 issues regarding processes not discussed in the earlier
document.
This document supplements the TRI Forms and Instructions document that is updated and
published annually by 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 EPCRA Section 313 reporting requirements are reflected in the annual TRI Forms and
Instructions and should be reviewed before compiling information for the report.
The objectives of this manual are to:
•• 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.
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 presswood and laminated wood products operations. Used in conjunction with the most
current TRI Forms and Instructions and Estimating Releases and Waste Treatment Efficiencies
for the Toxic Chemical Release Inventory Form (2001 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 edition of EPCRA Section 313,
Questions and Answers (the 1998 edition is EPA 745-B-98-004), which is available on the U.S.
EPA's TRI website (http://www.epa.gov/tri) or by contacting the EPCRA Hotline at 1-800-
424-9346. In the Washington, DC metropolitan area, call 703-412-9810.
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1.1 Background on EPCRA Section 313 and PPA Section 6607
The following overview of EPCRA Section 313 and Section 6607 of the PPA will
provide you with a basic understanding of the objectives and requirements of this program, and
will help you in completing your forms.
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
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 R reports and Form A
certification statements) on over 600 EPCRA Section 313 chemicals and chemical categories (40
CFR § 372.22). Covered facilities report the amounts released or otherwise managed as waste
(40 CFR § 372.85). However, if a facility meets the reporting criteria for listed toxic chemicals,
the facility must report even if there are no releases or other waste management quantities
associated with these chemicals (40 CFR § 372.30(a));(40 CFR § 372.85(b)(15)). Throughout
this document, whenever EPCRA Section 313 chemicals are discussed, the discussion includes
toxic chemical categories, as appropriate. Toxic chemicals or chemical categories may be added
or deleted from the list (EPCRA § 313 (d)(2)). Therefore, before completing your annual report,
be sure to check the most current list included with the TRI Forms and Instructions when
evaluating the toxic chemicals and chemical categories present at your facility. Copies of the
reporting package can be requested from the EPCRA Hotline, 1-800-424-9346 or accessed
through TRI website (http://www.epa.gov/tri/).
All facilities meeting the EPCRA Section 313 reporting criteria must report the
annual release and other waste management activity quantities (routine and accidental) of
EPCRA Section 313 chemicals and chemical categories to all environmental media. A separate
report is required for each EPCRA Section 313 chemical or chemical category that is
manufactured (including imported), processed, or otherwise used above the reporting threshold
(40 CFR § 372.85). The reports must be submitted to U.S. EPA and State or Tribal
governments, on or before July 1, for activities in the previous calendar year (40 CFR §
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372.30(d)). On July 1, the owner/operator of the facility is primarily responsible for the report,
even if the owner/operator did not own the facility during the reporting year (40 CFR § 372.5).
However, property owners with no business interest in the operation of the facility, other than a
lessor interest, are exempt from reporting requirements (40 CFR § 372.38(e)).
EPCRA also mandates U.S. EPA to establish and maintain a publicly available
database system consisting of the information reported under Section 313 and under Section
6607 of the PPA. This database, known as the Toxics Release Inventory (TRI) database, can be
accessed through the following sources:
•• U.S. EPA Internet site, http://www.epa.gov/tri:
•• TRI Explorer, http://www.epa.gov/triexplorer;
Envirofacts Warehouse Internet site, http://www.epa.gov/enviro/; and
•• Right-to-Know network, http://www.rtk.net/trisearch.html.
However, information qualifying as a trade secret, in accordance with the
regulatory requirements, is protected from public release (40 CFR § 350). In addition to being a
resource for the public, TRI data are also used in the research and development of regulations
related to EPCRA Section 313 chemicals and chemical categories.
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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 certification statement). This chapter presents the EPCRA Section 313 reporting
requirements to help you determine if these requirements apply to your facility. It also discusses
the reporting of trade secrets and 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 under common control with such person)" (40 CFR § 372.3). A facility may contain more
than one establishment. An "establishment" is defined as, "an economic unit, generally at a
single physical location, where business is conducted, or where 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 establishments at one facility to report separately. However, the combined
quantities of EPCRA Section 313 chemicals and chemical categories manufactured, processed,
or otherwise used in all establishments making up that facility must be considered for threshold
determinations (40 CFR § 372.25(c); 40 CFR § 372.25(d)). Also, the combined release and
other waste management activity quantities reported singly for each establishment must total
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 the SIC Code and employee
threshold criteria, release and other waste management activities from all establishments at the
facility must be reported (40 CFR § 372.25(c); 40 CFR § 372.25(d)). The preceding discussion
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is particularly applicable to presswood and laminated wood products operations since they may
be one of several industrial establishments using EPCRA Section 313 chemicals and chemical
categories at a large wood processing facility.
Example - Multiple Establishments
Your facility has several different establishments, all with SIC Codes covered under EPCRA Section 313. One
establishment used 7,000 pounds of toluene, an EPCRA Section 313 chemical, during the year to clean
equipment. Another establishment purchased and used 4,000 pounds of toluene during the year as a solvent to
separate a component from a mixture, with recovery of the toluene for reuse. Both activities constitute otherwise
use of the EPCRA Section 313 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 the release and other waste management of toluene
from your facility, or two Form Rs, one from each establishment. Please note that you may be eligible to file
one Form A certification statement for the facility but you cannot file a separate Form A certification
statement 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 primary SIC Code for your facility included in the list covered by
EPCRA Section 313 reporting (see Section 2.2)?
2) Does your facility have 10 or more full-time employees or the equivalent
(see Section 2.3)?
3) Does your facility manufacture (which includes importation), process, or
otherwise use EPCRA Section 313 chemicals or chemical categories (see
Section 2.4)?
4) Does your facility exceed any applicable thresholds of EPCRA Section
313 chemicals or chemical categories (for non-PBT 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;
for PBT chemicals - see Section 2.6 for applicable thresholds)?
If you answered "No" to any of the first three questions, you are not required to
prepare any EPCRA Section 313 reports. If you answered "Yes" to ALL of the first three
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questions, you must complete a threshold calculation for each EPCRA Section 313 chemical at
the facility, and submit an EPCRA Section 313 report for each toxic chemical and chemical
category exceeding the applicable threshold (40 CFR § 372.22).
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Is Your Facility's Primary SIC Code Included
on the EPCRA Section 313 List?
(See Section 2.2)
NO
YES
Does Your Facility Have 10 or More Full-Time
Employees or the Equivalent?
(See Section 2.3)
NO
YES
Does Your Facility Manufacture, Process, or
Otherwise Use any EPCRA Section 313
Chemicals or Chemical Categories?
(See Section 2.4)
NO
STOP
NO EPCRA
SECTION 313 REPORTS
REQUIRED FOR ANY
CHEMICALS OR
CHEMICAL CATEGORIES
YES
Does Your Facility Exceed Any of the
Thresholds for a Chemical or Chemical
Category (after excluding quantities that are
exempt from threshold calculations)
(See Section 2.5)
NO
AN EPCRA SECTION 313 REPORT IS
NOT REQUIRED FOR THIS CHEMICAL
OR CHEMICAL CATEGORY
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
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 Ib/yr
(See Section 2.9)
YES
NO
FORM A OR FORM R
IS REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY (FOR PBT
CHEMICALS, A FORM R IS REQUIRED)
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY (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 (40 CFR § 372.22(b)).
Table 2-1
SIC Codes Covered by EPCRA Section 313 Reporting
SIC Codes
10
12
20 through 3 9
491 1,4931, and 4939
4953
5169
5171
7389
Industry
Metal Mining
Coal Mining
Manufacturing
Electric and Other Services and
Combination Utilities
Refuse Systems
Chemicals and Allied Products
Petroleum Bulk Stations and Terminals
Business Services
Qualifiers
Except SIC Codes 1011, 1081, and 1094
Except SIC Code 1241
None
Limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce
Limited to facilities regulated under
RCRA Subtitle C
None
None
Limited to facilities primarily engaged in
solvent recovery services on a contract
or fee basis
Table 2-2 presents a listing of each SIC Code for facilities typically engaged in
the manufacture of presswood and laminated wood products, 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 or visit U.S.
Census Bureau's web site at http://www.census.gov/epcd/www/sic.html.
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Table 2-2
SIC Codes for Facilities That May Manufacture
Presswood and Laminated Wood Products
SIC Code
2435
2436
2439
2493
2499
SIC Description
Hardwood (Veneer and/or Plywood)
Softwood (Veneer and/or Plywood)
Structural Wood Members, Not Elsewhere Classified
Reconstituted Wood Products (Particleboard, Medium Density Fiberboard,
Oriented Strandboard, etc.), Hardboard, and Fiberboard
Wood Products, Not Elsewhere Classified
Note that auxiliary facilities can assume the SIC Code of another covered
establishment if the primary function is to support the covered establishment's operations (40
CFR § 372.22). For the purpose of EPCRA Section 313, auxiliary facilities are defined as those
that are primarily engaged in performing support services for another covered establishment or
multiple establishments of a covered facility, and are in a different physical location from the
primary facility (53 FR 4503; Standard Industrial Classification Manual, OMB, 1987). 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. If an auxiliary facility's primary function is
to support/service a facility with a covered SIC Code, the auxiliary facility assumes the covered
SIC Code as its primary SIC Code and must consider the other reporting requirements ((40 CFR
§ 372.22; 53 FR 4503) to determine if it must comply with the EPCRA Section 313 reporting
requirements. However, if the SIC Code for the primary facility is not covered by EPCRA
Section 313, then neither the primary nor the auxiliary facility is required to submit a report.
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:
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All the establishments have SIC Codes covered by EPCRA Section 313;
OR
The total value of the products shipped or services provided at
establishments with covered SIC Codes is greater than 50% of the value of
the entire facility's products and services; OR
Any one of the establishments with a covered SIC Code ships and/or
produces products or provides services whose value exceeds the value of
services provided, products produced and/or shipped by every other
establishment within the facility (40 CFR § 372.22).
Example - Primary SIC Code
A facility has two establishments. The first, a retail wood dealer, is in SIC Code 5211. SIC Code 5211 is not a
covered SIC Code. However, the second establishment, a wood products shop, is in SIC Code 2499, which is a
covered SIC Code. The facility also determines the product is worth $500/unit as received from the
establishment in the non-covered SIC Code and the value of the product is $l,500/unit after processing by the
establishment in the covered SIC Code. The value added by the establishment in the covered SIC Code is more
than 50% of the product value; therefore, the primary SIC Code is 2499, a covered SIC Code. Thus, the
establishment is covered by EPCRA Section 313 reporting and the entire facility (i.e., both establishments) is
subject to reporting.
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
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. Likewise,
warehouses that qualify as auxiliary facilities of covered facilities also must report, provided all
applicable reporting requirements are met (53 FR 4503).
While you are currently required to determine your facility's reporting eligibility
based on the SIC code system described above, it is important to be aware that the SIC code
system will be replaced by a new system in the future. On April 9, 1997 (62 FR 17287), the
Office of Management and Budget promulgated the North American Industrial Classification
System (NAICS). NAICS is a new economic classification system that replaces the SIC code
system as a means of classifying economic activities for economic forecasting and statistical
purposes. The transition to the new NAICS may require regulatory actions. As a result, the SIC
code system is still required to be used as the mechanism to determine your facility's reporting
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eligibility. EPA will issue notice in the Federal Register to inform you and other EPCRA
Section 313 facilities of its plans to adopt the NAICS and how facilities should make their
NAICS code determination.
2.3 Number of Employees
If your facility meets SIC Code and activity threshold criteria, you are required to
prepare an EPCRA Section 313 report if your facility has 10 or more full-time employees or the
equivalent (40 CFR § 372.22(a)). A full-time employee equivalent is defined as a work year of
2,000 hours. If your facility's employees hours total 20,000 or more hours in a calendar year,
you meet the 10 or more employee threshold criterion (40 CFR § 372.3).
The following information 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 and minor intermittent service vendors (e.g., trash
handlers)).
In general, if an individual is employed or hired to work at the facility, all the
hours worked by that individual for the facility (including paid leave and overtime) should be
counted in determining if the 20,000-hour criterion has been met.
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Example - Employee Equivalent Calculation
Your facility has six full-time employees working 2,000 hours/year. You also employ two full-time sales people
and a delivery truck driver (employed by the facility) who are assigned to the plant, each working 2,000
hours/year but predominantly on the road or from their homes. The wastewater treatment system (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) are:
(9 employees) x (2,000 hours/year) = 18,000 hours/year
Hours for the wastewater treatment system operator are:
(2 hours/day) x (5 days/week) x (52 weeks/year) = 520 hours/year; and
Hours for the construction crew are:
(4 contractors) x (1,000 hours) = 4,000 hours/year.
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.
2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section 313
Chemicals or Chemical Categories
If you are in a covered SIC Code and have 10 or more full-time employee
equivalents, determine which EPCRA Section 313 chemicals and chemical categories are
manufactured, processed, or otherwise used at your facility. One way to do this is to prepare a
list which includes all toxic chemicals and chemical categories found in mixtures and trade
name products at all establishments at the facility. This list should then be compared to the
CURRENT list of EPCRA Section 313 chemicals and chemical categories 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 and chemical
categories at your facility, evaluate the activities involving each toxic chemical and chemical
category and determine if any activity thresholds have been met.
The original list of chemicals and chemical categories subject to EPCRA Section
313 reporting was a combination of 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
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initiatives, or industry or the public can petition U.S. EPA to modify the list (EPCRA § 3 13 (d) +
(e)). When evaluating a chemical or chemical category for addition or deletion from the list,
U.S. EPA must consider the chemical's potential acute human health effects, chronic human
health effects, or its adverse environmental effects (EPCRA § 313(d)(2)). U.S. EPA reviews
these petitions and initiates a rulemaking to add or delete the toxic chemical or chemical
category from the list, or publishes an explanation why it denied the petition (EPCRA §
Note that toxic chemicals and chemical categories are periodically added,
delisted, or modified. Therefore, it is imperative that you refer to the appropriate reporting
year's list. You can refer to the U.S. EPA's TRI website, http://www.epa.gov/tri, for updated
guidance. Also, note that a list of synonyms for EPCRA Section 313 chemicals and chemical
categories 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, (EPA 745-
R-95-008). Table 2-3 lists the EPCRA Section 313 chemicals and chemical categories most
frequently reported for presswood and laminated wood products manufacturing operations. This
list is not intended to be all inclusive and should only be used as a guide.
Table 2-3
EPCRA Section 313 Chemicals and Chemical Categories Commonly
Encountered in Presswood and Laminated Wood Products Manufacturing
Process
Drying
Pressing
Finishing
Section 313 Chemicals
Methanol, formaldehyde, acetaldehyde,
acrolein, phenol, propionaldehyde
Methanol, formaldehyde, diisocyanates,
phenol, acetaldehyde, propionaldehyde
Xylene, toluene, MEK, glycol ethers
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2.5 Activity Categories
EPCRA Section 313 defines three activity categories for the listed toxic
chemicals and chemical categories: manufacturing (which includes importing), processing, and
otherwise use. For non-PBT chemicals, activity thresholds are 25,000 pounds per year for
manufacturing, 25,000 pounds per year for processing, and 10,000 pounds per year for otherwise
use1 (40 CFR § 372.25). These thresholds apply to each toxic chemical or chemical category
individually. The quantity of toxic chemicals or chemical categories stored on site or purchased
is not relevant for threshold determinations. Rather, the determination is based solely on the
annual quantity actually manufactured (including imported), processed, or otherwise used.
Therefore, EPCRA Section 313 chemicals and chemical categories that are brought on site and
stored, and are neither incorporated into a product for distribution in commerce nor otherwise
used on site during the reporting year, are not considered towards any activity threshold (EPCRA
§ 313(a) & (b); EPCRA Section 313 Questions and Answers, Revised 1998 Version, Q&A 87
(1998), EPA 745-B-98-004, December 1998).
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.
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Table 2-4
Activity Categories
Activity
Category
Definition
Threshold1
(lb/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical or chemical
category. For example, methanol generated from wood dryers would be considered a
manufacturing activity. Manufacture also applies to an EPCRA Section 313 chemical or
chemical category that is produced coincidentally during the manufacture, processing,
otherwise use, or disposal of another chemical or mixture of chemicals as a byproduct,
and an EPCRA Section 313 chemical or chemical category 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 (40 CFR §
372.3). An example of coincidental manufacturing could be the production of ammonia
or nitrate compounds in a wastewater treatment system.
25,000
Process
To prepare an EPCRA Section 313 chemical or chemical category, or a mixture or trade
name product containing an EPCRA Section 313 chemical or chemical category, for
distribution in commerce (40 CFR § 372.3). For example, formaldehyde which remains
with a wood product would be considered processed. 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 an EPCRA Section 313 chemical or chemical category 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 an EPCRA Section 313 chemical or chemical category that does not
fall under the manufacture or process definitions is classified as otherwise use (40 CFR
§ 372.3). An EPCRA Section 313 chemical or chemical category that is otherwise used
does not function by being 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, xylene used as a carrier
solvent for wood stain is classified as otherwise used.
On May 1, 1997 U.S. EPA revised the interpretation of otherwise use. The following
new otherwise use definition became effective with the 1998 reporting year (62 FR
23834, May 1, 1997):
Otherwise use means "any use of a toxic chemical, including 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
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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COMMON ERROR - Formaldehyde in Waste Products
Facilities often overlook air emissions from other waste management activities. For example, formaldehyde that
remains in wood products may be released to the air as fugitive emissions when the wood products are disposed
on-site. Based on the disposal method, engineering calculations can be used to determine the amount of
formaldehyde, if any, released to air.
Assuming the toxic chemical has not been imported, the relabeling or
redistribution of an EPCRA Section 313 chemical or chemical category where no repackaging
occurs does not constitute manufacturing, processing, or otherwise use of that chemical (EPCRA
§ 313(a) & (b); 40 CFR § 372.3). This type of activity should not be included in threshold
determinations.
Example - Relabeling
You buy a mixture in small containers that contains an EPCRA Section 313 chemical or chemical category.
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
or chemical category in the small containers should not be counted toward the processing threshold (because you
did not repackage the chemical) or the otherwise use threshold, nor should it be counted toward the
manufacturing activity threshold unless the small containers were imported. However, you must consider other
EPCRA Section 313 chemicals and chemical categories that you manufactured in the kit toward manufacturing
and processing threshold determinations.
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 use threshold determination for Chemical A. The otherwise use threshold is 10,000
pounds and since the amount of Chemical A exceeds this threshold, all release 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. The quantity of chemical B
should be counted towards the manufacturing threshold. 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 (40 CFR § 372.3). Therefore, the amount of Chemical B must also be considered in the
otherwise use threshold determination. Thus, the reporting threshold for Chemical B has also been exceeded and
all release and other waste management activities for Chemical B must be reported.
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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 release and other waste management activities of that EPCRA Section 313
chemical or chemical category at the facility must be considered for reporting (40 CFR §
372.25(c) & (d)).
2.6
Persistent Bioaccumulative, and Toxic (PBT) Chemicals
U.S. EPA promulgated the final rule for Persistent, Bioaccumulative, and Toxic
(PBT) chemicals in the October 29, 1999 Federal Register (64 FR 58666). This rule applies for
the reporting year beginning January 1, 2000 (for EPCRA Section 313 reports that must be filed
by July 1, 2001).
In this rule, U.S. EPA has added seven chemicals and lowered the reporting
thresholds for 18 chemicals and chemical categories that meet the EPCRA Section 313 criteria
for persistence and bioaccumulation. The PBT chemicals and their thresholds are listed in Table
2-5.
Table 2-5
Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals
Section 313 Chemical Name or Chemical
Category
Aldrin
Benzo(g,h,i)perylene
Chlordane
Dioxin and dioxin-like compounds category
(manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that chemical)
Heptachlor
CASRN
309-00-2
191-24-2
57-74-9
NA
76-44-8
Section 313 Reporting Threshold (in
pounds unless noted other-wise)
100
10
10
0.1 grams
10
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Section 313 Chemical Name or Chemical
Category
Hexachlorobenzene
Isodrin
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polycyclic aromatic compounds category
Poly chlorinated biphenyl (PCBs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
Mercury
Mercury compounds
CASRN
118-74-1
465-73-6
72-43-5
29082-74-4
40487-42-1
608-93-5
NA
1336-36-3
79-94-7
8001-35-2
1582-09-8
7439-97-6
NA
Section 313 Reporting Threshold (in
pounds unless noted other-wise)
10
10
100
10
100
10
100
10
100
10
100
10
10
U.S. EPA also added two toxic chemicals to the poly cyclic aromatic compounds
(PACs) category that is listed above:
Benzo(j,k)fluorene (fluoranthene)
•• 3-methylchloanthrene
(40 CFR § 372.65(c)) These two toxic chemicals are not to be reported individually; rather, they
must be included within the PACs compound category (40 CFR § 372.25(h)).
U.S. EPA finalized two thresholds based on the toxic chemicals' potential to
persist and bioaccumulate in the environment. The two levels include setting Section 313
manufacture, process, and otherwise use thresholds to 100 pounds for PBT chemicals and to 10
pounds for that subset of PBT chemicals that are highly persistent and highly bioaccumulative.
One exception is the dioxin and dioxin-like compounds category. EPA set the threshold for the
dioxin and dioxin-like compound category at 0.1 gram.
The de minimis exemption is inapplicable to the reporting of the PBT chemicals
(40 CFR § 372.38(a)). However, this action does not affect the applicability of the de minimis
exemption to the supplier notification requirements ((40 CFR § 372.45(d)(l)). U.S. EPA also
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excluded all PBT chemicals from eligibility for the alternate threshold of 1 million pounds (see
Section 2.9) (40 CFR § 372.27(e)) and eliminated range reporting of PBT chemicals and
chemical categories for on-site releases and transfers off-site for further waste management (40
CFR § 372.85(b)(15) & (16)).
Note that U.S. EPA is currently developing four guidance documents for PBT
chemicals modified by the PBT rule:
•• Dioxins and dioxin-like compounds (EPA-745-B-00-021);
•• Poly cyclic aromatic compounds (PACs) category (EPA-260-B-01-003);
•• Mercury and mercury compounds (EPA-260-B-01-004); and
Pesticides and Other PBT chemicals (EPA-260-B-01-005).
Please refer to these guidance documents as appropriate if they are applicable to your facility.
2.7 How Do You Report?
You must submit an EPCRA Section 313 report for each EPCRA Section 313
chemical or chemical category that exceeds a threshold for manufacturing, OR processing, OR
otherwise use (providing you meet the employee and SIC Code criteria) (40 CFR § 372.25).
Provided you do not exceed certain alternate activity thresholds and total annual reportable
amounts, you may prepare a Form A certification (See Section 2.9) rather than a Form R for non-
PBT chemicals (40 CFR § 372.27). The TRIForms and Instructions contain detailed directions
for the preparation and submittal of EPCRA Section 313 reports for the reporting year. The TRI
Forms and Instructions are sent to all facilities that submitted EPCRA Section 313 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).
2.8 FormR
Form R is the report in which the information on the release or other waste
management activities for toxic chemicals required by EPCRA Section 313 is reported. If you
are submitting a Form R, it is essential that you use the TRI Forms and Instructions for the
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appropriate reporting year. U.S. EPA encourages the electronic submittal of the Form R, via the
Automated Toxics Release Inventory Reporting Software (ATRS) or TRI Made Easy (TRI-ME)
Software. Use of the ATRS and TRI-ME will save preparation time in data entry and
photocopying and reduce errors via on-line validation routines and use of pick lists. In addition,
the TRI-ME Software will guide you through the process of determining your reporting
requirements and assist you in completing the Form Rs.
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 EPCRA Section 313 chemical or chemical category; it cannot be reused
year to year even if reporting has not changed.
Submission of incomplete EPCRA Section 313 reports 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 the Form R and submitting the EPCRA Section 313 report.
2.9 Form A Certification
U.S. EPA developed the Form A Certification Statement to reduce the annual
reporting burden for facilities with minimal amounts of EPCRA Section 313 chemicals or
chemical categories released and otherwise managed as waste (59 FR 61488, November 1994;
applicable beginning reporting year 1994 and beyond). On Form A certification you certify that
you are not required to report the release and other waste management information required by
EPCRA Section 313 and PPA Section 6607. A facility must meet the following two criteria to
use a Form A certification:
First, the total annual reportable amount of the EPCRA Section 313
chemical or chemical category cannot exceed 500 pounds per year. The
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"reportable amount" is defined as the sum of the on-site amounts released
(including disposal), treated, combusted for energy recovery, and
recycled, 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
2000 version of the Form R (40 CFR § 372.27).
Second, the amount of the EPCRA Section 313 chemical or chemical
category 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
certification cannot be used (40 CFR § 372.27).
Example - Form A Certification Threshold
If the combined annual reportable amounts from all activities do not exceed 500 pounds, a facility that
manufactures 900,000 pounds of an EPCRA Section 313 chemical or chemical category and processes
150,000 pounds of the same chemical or chemical category is eligible to use the Form A certification because the
facility did not exceed the one million pounds for either activity, even though the total usage exceeds one million
pounds.
The Form A Certification Statement must be submitted for each eligible EPCRA
Section 313 chemical or chemical category (40 CFR § 372.27). The information on the Form A
certification will be included in the publicly accessible TRI database; however, these data are
marked to indicate that they represent certification statements rather than Form Rs. Note that
separate establishments at a facility cannot submit separate Form A certification statements for
the same chemical or chemical category; rather, only one Form A certification statement per
EPCRA Section 313 chemical or chemical category can be submitted per facility (40 CFR §
372.27).
While Form A certification requests facility identification and chemical
identification information, no release and other waste management quantity estimations to any
media are required. You simply certify that the total annual reportable amount did not exceed
500 pounds and that amounts manufactured, processed, or otherwise used did not exceed
1,000,000 pounds. Once the facility has completed estimates to justify the submission of a Form
A certification, there is a considerable time savings in using the Form A certification, especially
in subsequent years, providing activities involving the toxic chemical or chemical category did
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not change significantly. U.S. EPA strongly recommends that you document your initial
rationale and refer to it every year, to verify that you have not modified a part of the process that
would invalidate the initial rationale supporting submission of Form A certification.
2.10 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 EPCRA Section 313 report. One set of reports should be "sanitized" (i.e.,
it should provide a generic name for the EPCRA Section 313 chemical or chemical category
identity). This version will be made available to the public. The second version, the
"unsanitized" version, should provide the actual identity of the EPCRA Section 313 chemical or
chemical category and have the trade secret claim clearly marked in Part I, Section 2.1 of the
Form R or Form A certification. The trade secrets provision only applies to the EPCRA Section
313 chemical or chemical category identity. All other parts of the Form R or Form A
certification must be filled out accordingly (40 CFR § 350.3).
Individual states may have additional criteria for confidential business
information and the submittal of both sanitized and unsanitized reports for EPCRA Section 313
chemicals and chemical categories. Facilities may jeopardize the trade secret status of an
EPCRA Section 313 chemical or chemical category 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 TRIForms and Instructions.
2.11 Recordkeeping
Complete and accurate records are absolutely essential to 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
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the reported data in the event of U.S. EPA compliance audits. U.S. EPA requires you to
maintain records substantiating each EPCRA Section 313 report submission for a minimum of
three years (40 CFR § 372.10). Each facility must keep copies of every EPCRA Section 313
report along with all supporting documents, calculations, work sheets, and other forms that you
used to prepare the EPCRA Section 313 report (40 CFR § 372.10). U.S. EPA may request this
supporting documentation during a regulatory audit.
Violation of EPCRA Section 313 reporting provisions may result in federal civil
penalties of up to $27,500 per day for each violation (40 CFR § 372.18; 40 CFR § 19.4). State
enforcement provisions may also be applicable depending on the state's EPCRA Section 313
reporting regulations.
Specifically, U.S. EPA requires the following records be maintained for a period
of three years from the date of the submission of a report (summarized from 40 CFR § 372.10):
1) A copy of each EPCRA Section 313 report that is submitted.
2) All supporting materials and documentation used to make the compliance
determination that the facility or establishment is a covered facility.
3) Documentation supporting the report submitted, which may include some
or all of the following:
Claimed allowable exemptions,
•• Threshold determinations,
Calculations for each quantity reported as being released, either on
or off site, or otherwise managed as waste,
•• Activity determinations, including dates of manufacturing,
processing, or use,
•• The basis of all estimates,
•• Receipts or manifests associated with transfers of each EPCRA
Section 313 chemical or chemical category in waste 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) For facilities submitting a Form A certification, all supporting materials
used to make the compliance determination that the facility or
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establishment is eligible to submit a Form A certification, which may
include:
Data supporting the determination that the alternate threshold
applies,
Calculations of the annual reportable amounts,
Receipts or manifests associated with the transfer of each EPCRA
Section 313 chemical or chemical category in waste 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.
EPCRA Section 313 reporting does not require additional testing or monitoring.
Rather, in order to report, facilities may use readily available data collected pursuant to other
provisions of law, or where such data are not readily available, reasonable estimates of the
amounts involved (EPCRA § 313(g)(2)). Some facilities may have detailed monitoring data and
off-site transfer records that can be used for estimates while others may only have purchase and
inventory records. Examples of records that you could use, if applicable, might include:
Each EPCRA Section 313 report 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);
•• EPCRA Section 313 Reporting Release and Other Waste Management
Quantity Estimation Worksheets (sample worksheets can be found in
Chapter 4 of this document);
Engineering calculations and other notes;
Formulation sheets;
Purchase records from suppliers;
Inventory data;
Material Safety Data Sheets (MSDSs);
•• New Source Performance Standards (NSPS);
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;
•• Clean Air Act Title V permit data;
•• Flow measurement data;
•• Resource Conservation Recovery Act (RCRA) hazardous waste
generator's reports;
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Pretreatment reports filed with local governments;
Invoices from waste management firms;
Manufacturer's estimates of treatment efficiencies;
Comprehensive Environmental Response, Conservation, and Liability Act
of 1980 (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 CHEMICAL OR CHEMICAL
CATEGORY ACTIVITY 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. Threshold
determinations are essentially a three step process:
Step 1) Identify any EPCRA Section 313 chemicals and chemical categories you
manufacture/import, process, or otherwise use.
Step 2) Identify the activity category and any exempt activities for each EPCRA
Section 313 chemical or chemical category.
Step 3) Calculate the quantity of each EPCRA Section 313 chemical or chemical
category and determine which ones exceed an activity threshold.
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported), Processed, or Otherwise
Used
Compile lists of all chemicals, mixtures, and raw materials (e.g., wood) at your
facility. For facilities with many different chemicals, mixtures, and raw materials 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 (this list should include
chemicals present in raw materials). On the second list, under the name of each mixture/trade
name product, write the names of all chemicals in that product. Next, compare the chemicals
and chemical categories on both lists to the current EPCRA Section 313 chemicals and chemical
categories list found in the TRIForms and Instructions (remember that toxic chemicals and
chemical categories may be periodically added and deleted and you should use the current
reporting year's instructions). Highlight the EPCRA Section 313 chemicals and chemical
categories that are on your lists.
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Review the lists to be sure each toxic chemical and chemical category is shown
by its correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical
used as a solvent in finishing operations is toluene. Toluene (Chemical Abstracts Service (CAS)
Registry No. 108-88-3) has several synonyms including: methylbenzene; methylbenzol;
phenylmethane; and toluol. It should be reported on Form R (or Form A certification), Item 1.2,
by its EPCRA Section 313 chemical name, toluene (40 CFR § 372.85(b)(10)). Synonyms can be
found in the U.S. EPA document Common Synonyms for Chemicals Listed Under Section 313 of
the Emergency Planning and Community Right-to-Know Act (EPA 745-R-95-008).
While you must consider every toxic chemical on the EPCRA Section 313
chemical and chemical category list, you should be aware of the toxic chemicals and chemical
categories typically used in presswood and laminated product manufacturing operations (40 CFR
§ 372.25(h)). As a guide, the most frequently reported EPCRA Section 313 chemicals and
chemical categories for reporting year 1995 by presswood and laminated product manufacturing
facilities, 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 toxic
chemical and chemical category list and performing threshold calculations. The spreadsheet
could show the toxic chemical, chemical category or chemical mixture with corresponding
component concentrations; the yearly quantity manufactured, processed, or otherwise used; and
the CAS Registry 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 or chemical category in every mixture, compound, and trade name
product. You may want to use the TRI-ME Software as one easy way to perform your chemical
threshold determinations.
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 system will also reduce the potential of inadvertently overlooking EPCRA
Section 313 chemicals or chemical categories present in mixtures purchased from off-site
sources.
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To develop the toxic chemical and chemical category list and the associated
activity categories you may want to consult the following:
Material Safety Data Sheets (MSDSs);
•• Facility purchasing records;
•• New Source Performance Standards (NSPS);
•• Inventory records;
Air and water discharge permits;
Individual manufacturing/operating functions; and
Receipts or manifests associated with the transfer of each EPCRA Section
313 chemical and chemical category in waste to off-site locations.
The following is suggested useful information needed to prepare your EPCRA
Section 313 reports and should be included for each toxic chemical and chemical category on
your spreadsheet:
•• The mixture name and associated EPCRA Section 313 chemical and
chemical category names;
The associated Chemical Abstract Service (CAS) Registry numbers;
•• The trade name for mixtures and compounds;
•• The throughput quantities; and
•• Whether the toxic chemical or chemical category is manufactured,
processed, or otherwise used at the facility (be sure to include quantities
that are coincidentally manufactured and imported, as appropriate).
MSDSs provide important information for the type and composition of chemicals
and chemical categories in mixtures, and for determining whether you have purchased raw
materials that contain EPCRA Section 313 chemicals and chemical categories. As of 1989,
chemical suppliers to facilities in SIC Major Group Codes 20 through 39 are required to notify
manufacturing customers of any EPCRA Section 313 chemicals and chemical categories present
above the applicable de minimis concentration in mixtures or trade name products distributed to
facilities (40 CFR § 372.45(a)). The notice must be provided to the receiving facility and may
be attached or incorporated into that product's MSDS (40 CFR § 372.45(c)(5)). If no MSDS is
required, the notification must be in a letter that accompanies the first shipment of the product to
your facility each year (40 CFR § 372.45(c)). This letter must contain the chemical name, CAS
Registry number, and the weight or volume percent (or a range) of the EPCRA Section 313
chemical or chemical category in mixtures or trade name products (40 CFR § 372.45(b)).
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Carefully review the entire MSDS. Although new MSDSs must list whether
EPCRA Section 313 chemicals and chemical categories are present (40 CFR § 372.45(b)), 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. The most likely
sections of an MSDS to provide information on EPCRA Section 313 chemicals and chemical
categories are:
Physical properties/chemical composition section;
Regulatory section;
Hazardous components section;
Labeling section; and
Additional information section.
Also, many EPCRA Section 313 chemicals or chemical categories are present as
impurities in 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)(40 CFR § 372.3);
(40 CFR § 372.38(a)).
COMMON ERROR - Mixture Components
Facilities often overlook EPCRA Section 313 chemicals and chemical categories that are present in small
quantities of bulk solutions. For example, a common chemical used in finishing operations is xylene. Xylene is
often purchased in large quantities for use as a solvent, among other things. Most facilities correctly report for
xylene; however, ethyl benzene is typically present at up to 15% in solutions of xylene commercially available.
Many facilities have historically overlooked the presence of ethyl benzene in their xylene mixture.
Qualifiers
Several toxic chemicals on the EPCRA Section 313 chemical and chemical
category list include qualifiers related to use or form. Some toxic chemicals are reportable
ONLY if manufactured by a specified process or classified in a specified activity category (40
CFR § 372.25(f)). 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 (40 CFR § 372.65).
Some other chemicals are only reportable if present in certain forms (40 CFR § 372.25(g)). For
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example, only yellow or white phosphorus is reportable, while black or red phosphorus is not
reportable (40 CFR § 372.65).
The qualifiers and associated toxic chemicals and chemical categories listed in 40
CFR § 372.65 are presented below. Please make special note of the discussion pertaining to
vanadium and vanadium compounds because effective as of December 31, 1999, U.S. EPA
removed the fume or dust qualifier for vanadium and added to the EPCRA Section 313 list all
forms of vanadium, with the exception of vanadium when contained in alloys, and vanadium
compounds.
Aluminum oxide (fibrous) - Aluminum oxide is only subject to threshold
determination and release and other waste management calculations 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 commonly used in high-temperature insulation applications
such as furnace linings, filtration, gaskets, joints, and seals (55 FR 5221
(February 14, 1990)).
Ammonia (includes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources) - On June 26,
1995, U.S. EPA qualified the listing for ammonia (CAS Registry No.
7664-41-7) and deleted ammonium sulfate (solution) (CAS Registry No.
7783-20-2) from the EPCRA Section 313 chemical list. Both the
qualification and the deletion were effective as of reporting year 1994.
The qualifier for ammonia means that anhydrous forms of ammonia are
100% reportable while only 10% of the total aqueous ammonia is
reportable. Any evaporation of ammonia from aqueous ammonia
solutions is considered anhydrous ammonia. This qualifier applies to both
activity threshold determinations and release and other waste management
calculations. Note that while ammonium sulfate is no longer an EPCRA
Section 313 chemical, 10% of the aqueous ammonia formed from the
dissociation of ammonium sulfate (and all other ammonium salts) is
reportable, and must be included in both activity threshold determinations
and release and other waste management calculations. Additionally, any
ammonium nitrate must also be included in the threshold determination
and the nitrate portion included in the release and other waste
management calculations, for the nitrate compounds category. U.S. EPA
has published guidance on reporting for ammonia and ammonium salts in
Emergency Planning and Community Right-to-Know, EPCRA Section
313, Guidance for Reporting Aqueous Ammonia, EPA 745-R-95-012.
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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.
Fume or dust - Two metals (aluminum 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. There is no particle size limitation for particulates. For example,
use of zinc metal as a paint component is not subject to reporting unless
the zinc is in the form of a fume or dust. However, even though elemental
zinc is reportable only in the fume or dust form, all forms of zinc
compounds are reportable. Note that the entire weight of all zinc
compounds should be included in the threshold determination for zinc
compounds, while only the metal portion of metal compounds is reported
in the release and other waste management amounts. Prior to reporting
year 2000, vanadium was also qualified with "fume or dust." As of
reporting year 2000, this qualifier has been removed for vanadium such
that all physical forms are now reportable. Please see the discussion on
vanadium and vanadium compounds below, if applicable.
Hydrochloric acid (acid aerosols) - On July 25, 1996, US EPA
promulgated a final rule delisting non-aerosol forms of hydrochloric acid
(CAS Registry No. 7647-01-0) from the EPCRA Section 313 chemical list
(effective for the 1995 reporting year). Therefore, threshold
determinations and release and other waste management estimates now
apply only to the aerosol forms. Under EPCRA Section 313, the term
aerosol covers any generation of airborne acid (including mists, vapors,
gas, or fog) without any particle size limitation. Therefore, any process
that sprays hydrochloric acid "manufactures" hydrochloric acid aerosol
and you should include this quantity in the manufacturing threshold
determination.
Manufacturing qualifiers - Two toxic chemicals, 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
isopropyl alcohol in cleanup operations should not report for isopropyl
alcohol.
Nitrate Compounds (water dissociable; reportable only in aqueous
solution) - A nitrate compound is covered by this listing only when in
water and if water dissociable. Although the complete weight of the
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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 calculations. One
issue recently raised by industry is how to report nitrate compounds in
wastewater and sludge that is applied to farms as a nitrogen source (either
on site or off site). Although during such use nitrate compounds may be
taken up by plants and cycled back into the ecosystem, U.S. EPA
considers that the nitrate compounds in wastewaters/sludges are managed
as waste. In this scenario, nitrate compounds should be reported as being
disposed to land (either on site or off site as appropriate). U.S. EPA has
published guidance for these chemicals in List of Toxic Chemicals Within
the Water Dissociable Nitrate Compounds Category and Guidance for
Reporting, EPA 745-R-96-004.
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.
Sulfuric acid (acid aerosols) - On June 26, 1995, U.S. EPA promulgated
a final rule delisting non-aerosol forms of sulfuric acid (CAS Registry 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 apply only to the aerosol
forms. Under EPCRA Section 313, the term aerosol covers any
generation of airborne acid (including mists, vapors, gas, or fog) without
any particle size limitation. Therefore, any process that sprays sulfuric
acid "manufactures" sulfuric acid aerosol and you should include this
quantity in the manufacturing threshold determination. U.S. EPA has
published guidance for acid aerosols in Guidance for Reporting Sulfuric
Acid, EPA 745-R-97-007.
Vanadium and vanadium compounds - Note that prior to reporting year
2000 (effective December 31, 1999 for EPCRA Section 313 reports that
must be filed by July 1, 2001), the fume or dust qualifier also applied to
vanadium. Effective December 31, 1999, U.S. EPA removed the "fume or
dust" qualifier for vanadium and added to the EPCRA Section 313 list all
forms of vanadium and vanadium compounds, with the exception of
vanadium when contained in alloys. Therefore, vanadium that is present
in fumes, dusts, or any other physical forms of alloys should not be
considered for EPCRA Section 313 reporting. However, if vanadium is
separated from the alloy, all physical forms of the vanadium are
considered to be manufactured and the quantity manufactured should be
applied to the 25,000-pound manufacturing threshold. If the vanadium is
subsequently processed or otherwise used, the applicable quantity should
also be applied to the processing or otherwise use threshold(s). If a
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threshold is exceeded, all quantities released or otherwise managed as
waste must be reported as appropriate.
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for Each
EPCRA Section 313 Chemical and Chemical Category
The next step is to identify the activity category (or categories) and any exempt
activities for each EPCRA Section 313 chemical and chemical category 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). Each threshold must be
individually calculated (40 CFR § 372.25); they are mutually exclusive and are not additive.
Table 3-1
Reporting Thresholds
Activity Category
Manufacture (including import)
Process
Otherwise use
Threshold1
25,000 pounds per year
25,000 pounds per year
10,000 pounds per year
'These reporting thresholds are for non-PBT chemicals. See Section 2.6 for reporting thresholds applicable
to PBT chemicals.
Example -Threshold Determination
If your facility manufactures 22,000 pounds of an EPCRA Section 313 chemical or chemical category and you
also otherwise use 8,000 pounds of the same chemical or chemical category, you have not exceeded either
threshold and an EPCRA Section 313 report for that chemical or chemical category is not required. However, if
your facility manufactures 28,000 pounds per year of an EPCRA Section 313 chemical or chemical category and
otherwise uses 8,000 pounds of the same chemical or chemical category, you have exceeded the manufacturing
threshold and ALL release and other waste management quantities (except those specifically exempted) of that
chemical or chemical category must be reported on the Form R, including those from the otherwise use activity.
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Example - Xylene Isomers
Presswood and laminated wood products manufacturing operations use the EPCRA Section 313 chemical xylene,
with the xylene (mixed isomers), CAS Registry No. 1330-20-7, being the most frequently reported type. Ortho-,
meta-, and para-xylenes are listed on the EPCRA Section 313 chemicals and chemical categories list in addition
to xylene (mixed isomers). The mixed isomers classification must be used when a mixture contains any
combination of two or more of the isomers. The threshold determination for xylene must be calculated for each
isomeric form individually unless the xylenes are manufactured, processed, or otherwise used as a mixture of
xylene isomers. For example, a covered facility annually uses 8,000 pounds of para-xylene, 6,000 pounds of
ortho-xylene, and 8,000 pounds of mixed isomers as carrier solvents in three separate processing lines. All three
activities of xylene are classified as otherwise use as the carrier is intended to evaporate and not remain with the
product. There are no other uses of any form of xylene in the facility. The otherwise use activity threshold of
10,000 pounds/year has not been reached for any of the xylenes and an EPCRA Section 313 report need not be
prepared for xylene. However, should any two of the streams mix, the facility will exceed the otherwise use
threshold for mixed isomers and an EPCRA Section 313 report must be prepared for the mixed isomer form of
xylene.
COMMON ERROR - Threshold Determination for Recirculation
Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals or
chemical categories in a recirculation system rather than the amount actually used in the reporting year. The
amount of the EPCRA Section 313 chemical or chemical category 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, a solvent containing an EPCRA Section 313
chemical or chemical category is used, recirculated on site, and reused as a solvent. The amount of EPCRA
Section 313 chemical or chemical category recirculated in the on-site recycling process is not considered in the
threshold determination because it is considered a "direct reuse" and is not reportable. Only the amount of new
chemical added to the system should be included in the otherwise used threshold calculation. However, if you
send a solvent containing an EPCRA Section 313 chemical or chemical category off site for distillation and
subsequent recycling, it should be reported as a transfer to an off-site location for recycling (Part II, Sections 6.2
and 8.5 of the 1999 Form R) because the distillation is considered a waste management activity. The amount of
solvent returned to you and subsequently used in the same reporting year must be included in the threshold
determination. If the reporting threshold is exceeded, the total quantity recycled should be reported in Section
8.4, i.e., the amount recycled on site must be reported in Section 8.4 each time it is recycled.
Each of the activity categories is divided into subcategories. As discussed in the
TRIForms 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 selected examples, are presented in Tables 3-2, 3-3, and 3-4.
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Table 3-2
Description of Manufacturing Subcategories
Manufacturing
Activity Subcategory
Description
Examples in Presswood/
Laminated Wood
Products Manufacturing
Operations*
Produced or imported
for on-site
use/processing
A toxic chemical or chemical category that is produced
or imported and then further processed or otherwise
used at the same facility.
Produced or imported
for sale/distribution
A toxic chemical or chemical category that is produced
or imported specifically for sale or distribution outside
the manufacturing facility.
Produced as a
byproduct
A toxic chemical or chemical category 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. EPCRA Section 313 chemicals or chemical
categories produced and released as a result of waste
treatment or disposal are also considered byproducts.
Methanol, formaldehyde,
acetaldehyde
Produced as an
impurity
A toxic chemical or chemical category 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.
Formaldehyde
* 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
Description of Processing Subcategories
Processing Activity
Subcategory
Description
Examples in Presswood/
Laminated Wood Products
Manufacturing Operations*
Reactant
A natural or synthetic toxic chemical or
chemical category used in chemical reactions
for the manufacture of another chemical
substance or product. Examples include
feedstocks, raw materials, intermediates, and
initiators.
Formaldehyde, phenol
Formulation
component
A toxic chemical or chemical category 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.
Inks, paints, synthetic patches
Article component
A toxic chemical or chemical category that
becomes an integral component of an article
distributed for industrial, trade, or consumer
use.
Repackaging only
A toxic chemical or chemical category 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
Description of Otherwise Use Subcategories
Otherwise Use Activity
Subcategory
Description
Examples in Presswood/
Laminated Wood Products
Manufacturing Operations*
Chemical processing aid
A toxic chemical or chemical category 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.
Diisocyanates, xylene, MEK,
toluene, glycol ethers
Manufacturing aid
A toxic chemical or chemical category 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.
Thermal oil
Ancillary or other use
A toxic chemical or chemical category 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.
Glycol ethers
* 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 should use the best, readily available information collected pursuant to other
provisions of law or where such data are not available, reasonable estimates for all calculations
in EPCRA Section 313 reporting. The concentration of an EPCRA Section 313 chemical or
chemical category in a mixture or trade name product may be known as a specific concentration,
as an average, as a range, or as an upper or lower bound concentration. If you know the specific
concentration of an EPCRA Section 313 chemical or chemical category in a mixture or trade
name product, you must use that value (40 CFR 372.30 (b)(i)). If only an average concentration
is provided (e.g., by the supplier), you can use that value in the threshold determinations. If only
the upper bound concentration is known, you must use this value in the threshold calculation (40
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CFR 372.30(b)(3)(ii)). If only the lower bound concentration is provided or the concentration is
given as a range or an upper and lower bound concentrations, EPA has developed the following
guidance on the use of this type of information in threshold determinations.
If the concentration is given as a range or an upper and lower bound, EPA
recommends that you use the mid-point in your calculations. 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%. EPA
recommends you use the mid-point value of 30% methanol in your calculations for threshold
determinations.
If only the lower bound concentration is given and the concentrations of the other
components are given, EPA recommends that you subtract the other components total from
100% to calculate the upper bound concentration. EPA then recommends that you determine the
midpoint for use in your calculations. For example, the MSDS states that a solvent contains at
least 50% methyl ethyl ketone (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 EPA recommends you use in
your threshold calculations.
If only the lower bound concentration is given and the concentration of the other
component(s) is not given, EPA recommends that you assume the upper bound for the EPCRA
section 313 chemical or chemical category is 100% and use the mid-point. Alternatively,
product quality requirements or information available from the most similar process stream may
be used to determine the upper bound of the range.
Special guidance for concentration ranges that straddle the de minimis value is presented in
Section 3.2.2.1.
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3.2.2 Evaluation of Exemptions
When determining thresholds, you can exclude quantities of any EPCRA Section
313 chemicals and chemical categories 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.
COMMON ERROR - Exempt Activities
If an EPCRA Section 313 chemical or chemical category is used in exempt activities, the quantity used in these
activities does not need to be included in your threshold determinations or release and other waste management
calculations, even if the chemical or chemical category is used in a reportable activity elsewhere in the facility
(40 CFR § 372.38).
3.2.2.1 De Minimis Exemption
If the amount of EPCRA Section 313 chemical(s) or chemical categories 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 (40 CFR § 372.38(a)). Note that this
exemption does not apply to manufacturing, except for importation or as an impurity as
discussed below. Also note that the de minimis exemption does not apply to the manufacturing,
processing, or otherwise use of the PBT chemicals (refer to Section 2.6) (40 CFR § 372.38(a)).
The de minimis concentration for EPCRA Section 313 chemicals and chemical categories is 1%,
except for Occupational Safety and Health Administration (OSHA)-defmed carcinogens, which
have a 0.1% de minimis concentration (40 CFR § 372.38(a)). Note that if a mixture contains
more than one member of an EPCRA Section 313 chemical category, the weight percent of all
members must be summed (40 CFR § 372.25(h)). 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 current edition of EPCRA Section 313
Questions and Answers (1998 edition is EPA 745-B-98-004; see Appendix A, Directive #2) that
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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 chemical category with the
associated de minimis value.
Once the de minimis level has been equaled or exceeded, the exemption no longer
applies to that process stream, even if the EPCRA Section 313 chemical or chemical category
later falls below the de minimis concentration. All release and other waste management
activities that occur after the de minimis concentration has been equaled or exceeded are subject
to reporting. The facility does not have to report release and other waste management activities
that took place before the de minimis concentration was equaled or exceeded in the process
stream.
Example - De Minimis
Your facility processes a mixture containing 1.1% nitric acid and 0.6% manganese. The de minimis exemption
would apply to manganese because the concentration is below 1% which is the de minimis level for manganese;
however, it would not apply to nitric acid. All of the nitric acid must be included in threshold determinations,
and release and other waste management calculations.
The de minimis exemption also applies to EPCRA Section 313 chemicals and
chemical categories that are coincidentally manufactured below the de minimis level only if that
chemical is manufactured as an impurity in a mixture (53 FR 4504, February 16, 1988)). In
addition, the exemption applies to EPCRA Section 313 chemicals and chemical categories below
the de minimis concentration in an imported mixture or trade name product.
For some mixtures the concentration of EPCRA Section 313 chemicals and
chemical categories may be available only as a range. U.S. EPA has developed guidance on how
to determine quantities applicable to threshold determinations, and release and other waste
management calculations when this range straddles the de minimis value. In general, only the
quantity of the processed or otherwise used EPCRA Section 313 chemical or chemical category
whose concentration exceeds the de minimis must be considered (40 CFR § 372.38(a)).
Therefore, U.S. EPA allows facilities to estimate the quantity below the de minimis and exclude
it from further consideration. The following examples illustrate this point.
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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 \%de
minimis concentration exemption. The amount of mixture subject to reporting is the quantity containing manganese at or
above the de minimis concentration:
8,000,000 x [(0.0125 - 0.0099) - (0.0125 - 0.0025)]
The average concentration of manganese that is not exempt (at or above the de minimis) is:
(0.0125+ 0.01)-2
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management
estimates is:
(8,000,000) x (0.0125'0.0099)
(0.0125' 0.0025)
(0.0125' 0.01)
(2)
•23,400 pounds
= 23,400 pounds manganese (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 (at or above de minimis) is:
(8,000,000) x (0.012 - 0.009) - (0.012 - 0.002)
The average concentration of manganese that is not exempt (at or above de minimis) is:
(0.012+ 0.01)-(2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management
estimates is:
(8,000,000) x (Q.012-0.009)
(0.012-0.002)
(0.012+0.01)
(2)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold)
The exemption does not apply to EPCRA Section 313 chemicals and chemical
categories coincidentally manufactured as byproducts and separated from the product, nor does it
apply to EPCRA Section 313 chemicals and chemical categories coincidentally manufactured as
a result of waste management activities, from either on site or off site. (Under EPCRA Section
313, U.S. EPA does not consider waste to be a mixture (see 53 FR4501, 4504 (February 16,
1988); 62 FR 23,845-46 (May 1, 1997).) For example, many facilities treat waste solvents by
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incinerating them. If coal is used as the primary fuel source to incinerate these waste solvents,
combustion 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 EPCRA Section 313 chemicals or chemical categories as a byproduct or in a
waste treatment process, the formation of these compounds must be considered for threshold
determinations, and release and other waste management calculations.(40 CFR § 372.3)
3.2.2.2 Articles Exemption
An article is defined (40 CFR § 372.3) 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 or chemical category under
normal conditions of processing or otherwise use of the item at the facility.
If you receive a manufactured article from another facility or you produce the
article in your facility and process or otherwise use it without changing the shape or design, and
your processing or otherwise use does not result in the release of more than 0.5 pound of the
EPCRA Section 313 chemical or chemical category in a reporting year from all like articles, then
the EPCRA Section 313 chemical or chemical category in that article is exempt from threshold
determinations and release and other waste management calculations (The 0.5 pound limit does
not apply to each individual article, but applies to the sum of all releases from processing or use
of all like articles) (40 CFR § 372.38(b)). Section 313 chemicals or chemical categories used to
produce an article, however, do not qualify for the article exemption.
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 original 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 formed into wire or rods. However, cutting a manufactured item into pieces that are
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recognizable as the article would not change the exemption status as long as the diameter and the
thickness of the item remain unchanged (53 FR 4507 (February 16, 1988)). 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 above 0.5 pound per year occur from all like articles.
Any processing or otherwise use of an article that results in a release above 0.5
pound per year for each EPCRA Section 313 chemical or chemical category for all like articles
negates the exemption (40 CFR § 372.3, 372.38(b)). Cutting, grinding, melting, or other
activities performed on a manufactured item could result in a release of an EPCRA Section 313
chemical or chemical category during normal conditions of processing or otherwise use and,
therefore, could negate the article exemption if the total annual releases from all like articles
exceed 0.5 pound in a calendar year. However, if all of the resulting waste is recycled or reused,
either on site or off site, so that the release of the EPCRA Section 313 chemical or chemical
category does not exceed 0.5 pound for the calendar year, then the article's exemption status
may be maintained. If the processing or otherwise use of similar manufactured items results in a
total release of less than or equal to 0.5 pound of any individual EPCRA Section 313 chemical or
chemical category to any environmental media in a calendar year, U.S. EPA will allow this
quantity to be rounded to zero and the manufactured items maintain their article status. The 0.5-
pound limit does not apply to each individual article, but applies to the sum of all releases from
processing or otherwise use of like articles for each EPCRA Section 313 chemical or chemical
category. The current edition of EPCRA Section 313 Questions and Answers (1998 edition is
EPA 745-B-98-004) presents several specific question and answers/discussions pertaining to the
articles exemption.
Example - Articles Exemption
Your facility purchased plastic components that contain an EPCRA Section 313 chemical. The components, in
their purchased form, are used in the manufacture of wood products at the facility. The plastic components are
considered articles for Section 313 reporting purposes. However, if the releases from all like articles is greater
than 0.5 pound per year the components will lose their article status.
3.2.2.3 Facility-Related Exemption - Laboratory Activity Exemption
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EPCRA Section 313 chemicals and chemical categories that are manufactured,
processed, or otherwise used in laboratories under the supervision of a technically qualified
individual are exempted from the threshold determination (and subsequent release and other
waste management calculations) (40 CFR § 372.38(d)). This exemption may be applicable in
circumstances such as laboratory sampling and analysis, research and development, and quality
assurance and quality control activities. It does not include pilot plant scale or specialty
chemical production (40 CFR § 372.38(d)). It also does not include laboratory support activities.
For example, chemicals used to maintain laboratory equipment are not eligible for the laboratory
exemption.
Example - Laboratory Activity Exemption
An adhesives manufacturer has a research laboratory that uses various formulations of resins containing EPCRA
Section 313 chemicals and chemical categories to test adhesive qualities for a particleboard manufacturer. The
testing is under the supervision of a "technically qualified individual" in the laboratory. The EPCRA Section
313 chemicals and chemical categories used in this activity would be exempt from EPCRA Section 313 reporting
and should not be included in any threshold determinations or release and other waste management calculations.
3.2.2.4 Activity-Related Exemptions (Otherwise Use Exemptions)
Some exemptions apply to the otherwise use of an EPCRA Section 313 chemical
and chemical category. The specific quantities of EPCRA Section 313 chemicals and chemical
categories used in these activities do not need to be included in facility threshold determinations
(nor the associated release and other waste management calculations)(40 CFR § 372.38(c)). The
following otherwise use activities are considered exempt:
EPCRA Section 313 chemicals and chemical categories used in routine
janitorial or facility grounds maintenance. Examples are bathroom cleaners,
fertilizers, and garden pesticides similar in type or concentration to consumer
products. Materials used to clean process equipment do not meet this exemption.
Personal use of items. Examples are foods, drugs, cosmetics, and other personal
items including those items within the facility such as in a facility operated
cafeteria, store, or infirmary. Office supplies such as correction fluid are also
exempt.
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Example - Personal Use Exemption
Toluene in nail polish is exempt from threshold determinations and release and other
waste management calculations.
Structural components of the facility Exemptions apply to EPCRA Section
313 chemicals and chemical categories 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 buildings.
Materials used to construct, repair, or maintain process equipment are not exempt.
EPCRA Section 313 chemicals and chemical categories used with facility
motor vehicles. This exemption includes the use of EPCRA Section 313
chemicals and chemical categories 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, cleaning
solutions, and solvents in paint used to touch up the vehicle. Motor vehicles
include cars, trucks, forklifts, locomotives, and aircraft. Note that this exemption
only applies to the OTHERWISE USE of EPCRA Section 313 chemicals and
chemical categories. The coincidental manufacture of EPCRA Section 313
chemicals and chemical categories resulting from combustion of gasoline is not
exempt and should be considered toward 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 calculations.
This exemption does NOT apply to stationary equipment. The use of lubricants
and fuels for stationary process equipment (e.g., pumps and compressors) and
stationary energy sources (e.g., furnaces, boilers, heaters), are NOT exempt.
Example - Process Equipment Chemical Use
Lubricants containing EPCRA Section 313 chemicals and chemical categories 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 that aid facility process operations are not exempt and the amount of the
EPCRA Section 313 chemicals and chemical categories in the lubricant should be
applied to the otherwise use threshold.
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EPCRA Section 313 chemicals and chemical categories in certain air or
water drawn from the environment or municipal sources. Included are
EPCRA Section 313 chemicals and chemical categories present in process water
and non-contact cooling water drawn from the environment or a municipal
source, or toxic chemicals and chemical categories present in air used either as
compressed air or as an oxygen source for combustion.
Example - Toxic Chemicals in Process Water
A facility uses river water for one of its processes. This water contains approximately
100 pounds of an EPCRA Section 313 chemical or chemical category. The facility
ultimately returns the water that contains the entire 100 pounds of the EPCRA Section
313 chemical or chemical category to the river. The EPCRA Section 313 chemical or
chemical category in the water can be considered exempt because the EPCRA Section
313 chemical or chemical category was present as it was drawn from the environment.
The facility does not need to consider the EPCRA Section 313 chemical or chemical
category drawn with river water for threshold determinations or release and other waste
management calculations.
3.2.3 Additional Guidance on Threshold Calculations for Certain Activities
This section covers three specific situations in which the threshold determination
may vary from normal facility operations: reuse, remediation, and recycling activities of
EPCRA Section 313 chemicals and chemical categories.
3.2.3.1 Reuse Activities
Threshold determinations of EPCRA Section 313 chemicals or chemical
categories that are reused at the facility are based only on the amount of the EPCRA Section 313
chemical or chemical category that is added to the system 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 EPCRA Section 313 chemical or chemical category 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 new or fresh anhydrous ammonia during the year, the facility would exceed the
otherwise use threshold, and be required to report (40 CFR § 372.25(e)).
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3.2.3.2 Remediation Activities
EPCRA Section 313 chemicals and chemical categories undergoing remediation
are not being manufactured, processed, or otherwise used. Therefore, they are not included in
the activity threshold determinations.
However, if you are conducting remediation of an EPCRA Section 313 chemical
or chemical category that is also being manufactured, processed, or otherwise used by the facility
above an activity threshold level, you must consider this activity for release and other waste
management calculations. You must report any release or other waste management quantities of
an EPCRA Section 313 chemical or chemical category due to remediation in Part II, Sections 5
through 8, accordingly, of the 1999 Form R. (40 CFR § 372.85(b)(15)+(16)) Those quantities
would also be considered as part of the amount for determining Form A certification eligibility.
EPCRA Section 313 chemicals and chemical categories used for remediation must be considered
toward threshold determinations. (40 CFR § 372.3) If an EPCRA Section 313 chemical or
chemical category exceeds one of the reporting thresholds elsewhere at the facility, all release
and other waste management activity quantities of that chemical or chemical category must be
reported, including release and other waste management activity quantities resulting from
remediation.(40 CFR § 372.85(b)(15)+(16))
Excavation (that is considered part of the remedial action ) of material already
landfilled does not constitute a manufacturing, processing, or otherwise use activity. However,
routine activities (e.g., dredging a lagoon), even if not performed every year, are not considered
to be remedial actions and may be subject to reporting.
3.2.3.3 Recycling Activities
For on-site recycling and reuse systems, where the same EPCRA Section 313
chemical or chemical category is recycled and reused multiple times, only count the quantity
recycled or reused once (at the time it is introduced into the system) for threshold calculations
(40 CFR § 372.25(e)). (Please note that for reporting on-site waste management activities the
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quantity of the EPCRA Section 313 chemical or chemical category should be counted every time
it exits the recycling unit in Section 8 of Form R.) EPCRA Section 313 chemicals and chemical
categories recycled off site and returned to the facility should be treated as newly purchased
materials for purposes of EPCRA Section 313 threshold determinations.
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313 Chemical and Chemical
Category and Determine Which Ones Exceed an Activity Threshold
The final step is to determine the quantity and which EPCRA Section 313
chemicals and chemical categories exceed an activity threshold. At this point you should have:
1. Identified each EPCRA Section 313 chemical and chemical category at your
facility.
2. Determined the activity category for each EPCRA Section 313 chemical and
chemical category (manufactured, processed, or otherwise used).
Now, sum the amount for each EPCRA Section 313 chemical and chemical category by
activity category, subtract all exempt quantities, and compare the totals to the applicable
thresholds. Each EPCRA Section 313 chemical and chemical category exceeding any one of the
activity thresholds requires the submission of an EPCRA Section 313 report. Provided you meet
certain criteria, you may prepare a Form A certification rather than a Form R (see Section 2.9).
COMMON ERROR - Assuming a Threshold is Exceeded
U.S. EPA has published a report, The 1994 and 1995 Toxic Release Inventory Data Quality Report, EPA 745-R-
98-002, with the site survey results of over 100 facilities to evaluate EPCRA Section 313 reporting quality. One
of the findings of this survey was that facilities that simply assumed that chemical activity thresholds were
exceeded were often in error. This resulted in many of these facilities filing EPCRA Section 313 reports when
thresholds were actually not exceeded. Unless the facility has strong grounds to support such an assumption, the
time spent in explicitly calculating the activity threshold is well spent.
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COMMON ERROR - Zero Release and Other Waste Management Quantities
If you meet all reporting criteria and exceed any activity threshold for an EPCRA Section 313 chemical or
chemical category, you must file an EPCRA Section 313 report for that chemical or chemical category, even if
you have zero release and other waste management activity quantities. Exceeding the chemical activity
threshold, not the quantity released or otherwise managed as waste, determines whether you report. Note that if
the release and other waste management activity quantity is 500 pounds or less for each chemical or chemical
category you may be eligible to use the alternate certification statement, Form A, rather than a Form R (see
Section 2-9).
To determine if an EPCRA Section 313 chemical or chemical category exceeds a
reporting threshold, calculate the annual activity amount of that chemical. Start with the amount
of chemical or chemical category at the facility as of January 1, add any amounts brought on site
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 or chemical category. 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 how the work sheet can be used for the following
example:
Example - Threshold Worksheet
Assume your facility purchases, in the applicable reporting year, two mixtures that contain xylene (mixed
isomers). You purchased 25,000 pounds of Mixture A (which is 50% xylene, by weight, according to the
MSDS) and 110,000 pounds of Mixture B (which contains 20% xylene, by weight). 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 an EPCRA Section 313 report that includes releases and other
waste management quantities from all activities (including processing).
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Table 3-5. EPCRA Section 313 Reporting Threshold Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source
Total Weight
(Ib)
Percent
EPCRA
Section 313
Chemical or
Chemical
Category
by Weight
EPCRA
Section 313
Chemical or
Chemical
Category
Weight (Ib)
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
(A) Ib
Processed
(B) Ib
Otherwise Used
(0 Ib
OJ
to
Exempt quantity of chemical or chemical category 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 EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(A,) Ib
Processed
(B,) Ib
Otherwise Used
(C,) Ib
Ib
Ib
Amount subject to threshold: (A-Aj)_
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities1: 25.000 Ib 25.000 Ib
If any one of the thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
Ib
10,000 Ib
'These activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals; for dioxin and dioxin-like
compounds, the activity threshold amount is 0.1 gram.
-------
Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet
Facility Name: Plywood USA.
EPCRA Section 313 Chemical or Chemical Category: Xylene (mixed isomers)
CAS Registry Number: 1330-20-7
Reporting Year: 1999
Date Worksheet Prepared: May 1. 2000
Prepared By: A.B. Galloway
Amounts of chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Information
Source
MSDS
MSDS
Total Weight
Ob)
25,000
110,000
Percent
EPCRA
Section 313
Chemical or
Chemical
Category
by Weight
50%
20%
EPCRA
Section 313
Chemical or
Chemical
Category
Weight (Ib)
12,500
22,000
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
—
—
(A) 0 Ib.
Processed
12,500
11,000
(B) 23,500 Ib.
Otherwise Used
—
11,000
(C) 11,000 Ib.
OJ
to
Exempt quantity of chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)
none
none
Fraction or Percent Exempt
(if Applicable)
Amount of the EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(Aj) 0 Ib.
Processed
(BO 0 Ib.
Otherwise Used
(c^oib.
Amount subject to threshold: (A-Aj) 0 Ib. (B-Bj) 23,500 Ib. (C-Q) 11,000 Ib.
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities1: 25.000 Ib. 25.000 Ib. 10.000 Ib.
If any one of three thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
'These activity thresholds apply to non-PBT chemicals. See Section 2.6 for activity thresholds applicable to PBT chemicals; for dioxin and dioxin-like
compounds, the activity threshold amount is 0.1 gram.
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CHAPTER 4 - ESTIMATING RELEASE AND
OTHER WASTE MANAGEMENT QUANTITIES
4.0 PURPOSE
This chapter is intended to guide the user in developing a systematic approach for
estimating release and other waste management quantities of EPCRA Section 313 chemicals and
chemical categories from presswood and laminated wood products manufacturing operations.
Figure 4-1 diagrams a recommended approach for estimating quantities of reportable EPCRA
Section 313 chemicals or chemical categories.
This chapter also includes common EPCRA Section 313 reporting and
compliance issues as they apply to presswood and laminated wood products manufacturing. The
general discussion (Section 4.1) is followed by a presentation of specific examples and issues
(Section 4.2). The basic calculation techniques and examples provided in Appendix B may be
used to estimate the release and other waste management quantities of toxic chemicals and
chemical categories.
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities
Release and other waste management activity quantities can be determined by
completing the following four steps, described in detail in the following sections.
Step 1) Prepare a process flow diagram.
Step 2) Identify EPCRA Section 313 chemicals and chemical categories and
potential sources of chemical release and other waste management
activities.
Step 3) Identify release and other waste management activity types.
Step 4) Determine the most appropriate method(s) and calculate the estimates for
release and other waste management activity quantities.
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STEP 1:
Prepare Process
Flow Diagram
STEP2: Identify EPCRA
Section 313 Chemicals
or Chemical Categories
STEP2: Identify Sources of Release
and Other Waste
Management Activities
Source 1
Source 2
STEPS: Define the
Operation
Source 3
STEPS: Identify Release and Other
Waste Management Activity
Types
i i i i i
Fugitive
Air
Point Discharge
Air to
Waterbody
Underground
Injection
Land
On Site
POTW
Transfer
Off Site for
Recycling
Transfer
Off Site for
Energy Recovery
Transfer
Off Site for
Treatment
Transfer On-Site
Off Site for Waste
Disposal Treatment
On-Site On-Site
Energy Recycling
Recovery
1
1
STEP4: Review Available
Data & Choose
Estimation Method
STEP4:
Calculate Estimates for
Release and Other Waste
Management Activity
Quantities
Figure 4-1. Release and Other Waste Management Activity Calculation Approach
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For EPCRA Section 313 reporting purposes, "sources" means the streams or units
that generate the release and other waste management activity (such as process vents, container
residue, or spills) and "types" means the environmental media corresponding to elements in
Sections 5 through 8 of the 2000 Form R (for example, releases to fugitive air, releases to stack
air, discharges to receiving streams or POTWs, or releases to land).
4.1.1 Step 1: Prepare a Process Flow Diagram
Preparing a process flow diagram will help you to identify potential sources and
types of EPCRA Section 313 chemicals and chemical categories released and 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 and chemical categories are used and the medium to which they may be released
or otherwise managed as waste.
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories
and Potential Sources of Chemical Release and Other Waste Management
Activities
Once a process flow diagram has been developed, determine the potential sources
and the EPCRA Section 313 chemicals and chemical categories that may be released and
otherwise managed as waste from each unit operation and process. Remember to include upsets
and routine maintenance activities. Potential sources include:
Accidental spills and •• Fittings;
releases; •• Flanges;
Air pollution control devices •• Process discharge stream;
(e.g., baghouses, electrostatic •• Process vents;
precipitators, and scrubbers); •• Pumps;
Clean up and housekeeping •• Recycling and energy
practices; recovery byproducts;
Combustion byproducts; •• Relief valves;
Container residues; •• Stock pile losses;
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Storage tanks; •• Treatment sludge;
Storm water runoff; •• Volatilization from process
Tower stacks; or treatment; and
Transfer operations; •• Waste treatment discharges.
Next, identify the EPCRA Section 313 chemicals and chemical categories that
may be released or otherwise managed as waste from each source. A thorough knowledge of the
facility operations and processes is required for this determination. You should also consider
whether any of the EPCRA Section 313 chemicals or chemical categories are coincidentally
manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals and chemical
categories typically used in the operations common to presswood and laminated wood products
manufacturing. This table can be used as an aid in identifying which chemicals and chemical
categories are found in your process. The list may not include all the EPCRA Section 313
chemicals and chemical categories your facility uses, and it may include many chemicals and
chemical categories that you do not use.
4.1.3 Step 3: Identify Release and Other Waste Management Activity Types
For each identified source of an EPCRA Section 313 chemical or chemical
category, examine all possible release and other waste management activity types. Figure 4-2
schematically represents the possible release and other waste management activity types 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 release and other waste
management activities have been considered.
a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) -
Includes all 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.;
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Point Sources
(Part II, Sections
5.2 and 8.1)
Fugitive Emissions
(Part II, Sections
5.1 and 8.1)
Toxic Chemical In
Operation
Transfer Off Site for Recycling
(Part II, Sections 6.2 and 8.5)
Transfer Off Site for Energy Recovery
(Part II, Sections 6.2 and 8.3)
Transfer Off Site for Treatment
(Part II, Sections 6.2 and 8.7)
Transfer Off Site for Disposal
(Part II, Sections 6.2 and 8.1)
On-Site Treatment
(Part II, Sections 7 A and 8.6)
On-Site Energy Recovery
(Part II, Sections 7B and 8.2)
On-Site Recycling
(Part II, Sections 7C and 8.4)
POTW
Un/dDer9ro,un,d ln.Jection (Part II, Sections
( ^ "-Sections 6.1 and 8.1, or 8.7)
Receiving Streams 5.4 and 8.1)
(Part II, Sections Land on site (landfill,
5.3 and 8.1) land treatment,
surface impoundment)
(Part II, Sections
5.5 and 8.1)
Figure 4-2. Possible Release and Other Waste Management Activity Types1
for EPCRA Section 313 Chemicals and Chemical Categories
Releases from building ventilation systems, such as a roof fan in
an open room (e.g., fan above an uncontrolled press);
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) -
Includes all emissions to the air that occur through stacks, vents, ducts,
pipes, or any confined air stream, including the emissions from storage
tanks and air pollution control equipment. Air emissions from presses
'Sections refer to 1999 Form R. Quantities released to the environment as a result of remedial actions, catastrophic
events, or one-time events should be reported in Part II, Section 8 as Subsection 8.8.
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may be channeled through air pollution control devices. These are
considered stack emissions. 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, certain state air quality reporting
requirements, not associated with EPCRA Section 313 reporting, consider
ventilation systems to be a stack or point source.
c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3
of Form R) - Includes direct wastewater discharges to a receiving stream
or surface water body. Discharges usually occur under a NPDES or
SPDES permit.
d. Underground Injection On-Site to Class I Wells (Part II, Section 5.4.1
of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of
Form R) - Includes releases 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. Disposal to Land On-Site (Part II, Section 5.5 of Form R) - Includes
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 (Part II,
Section 5.5.1 A) or a non-hazardous waste landfill (Part II, Section
5.5. IB). Both types are included if they are located on site. Leaks
from landfills in the years subsequent to the disposal of the
EPCRA Section 313 chemicals or chemical categories in the
landfill 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 an EPCRA Section
313 chemical or chemical category is applied to or incorporated
into soil. Volatilization of an EPCRA Section 313 chemical or
chemical category because of 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
4-6
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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 toxic chemical or chemical
category after application to the land does not change the required
reporting. For example, even if the toxic chemical or chemical
category 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.
Quantities of the toxic chemical released to surface impoundments
that are used merely as part of a wastewater treatment process
generally must not be reported in this section. However, if the
sludge from the surface impoundment contains the EPCRA Section
313 chemical or chemical category, then the EPCRA Section 313
chemicals or chemical categories in the sludge should be reported
in this section unless the sludge is removed and subjected to
another waste management activity.
(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
EPCRA Section 313 chemical or chemical category to land.
f. Discharges to Publicly Owned Treatment Works (POTW) (Part II,
Section 6.1 of Form R) - Includes the amount of EPCRA Section 313
chemical or chemical category 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 (40 CFR § 372.85(b)(16)(i)).
g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form
R) - Includes all off-site transfers containing the EPCRA Section 313
chemical or chemical category for the purposes of disposal, treatment,
energy recovery, or recycling. Off-site transfer for disposal includes
underground injection, landfill/surface impoundment, other land disposal
and transfer to a waste broker for disposal. The amount transferred off
site for disposal must also be reported in Section 8.1 (40 CFR §
372.85(b)(16)(ii)).
Also reported in Section 6.2 would be any residual EPCRA Section 313
chemicals or chemical categories in "empty" containers transferred off
4-7
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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 EPCRA Section 313 chemical or chemical category in this section (40
CFR § 372.85(b)(16)(ii)).
COMMON ERROR - Shipping Container Residue
Do not overlook residual toxic chemicals or chemical categories in containers. U.S.
EPA has published The 1994 and 1995 Toxic Release Inventory Data Quality Report,
EPA 745-R-98-002, presenting the site survey results of over 100 facilities to evaluate
EPCRA Section 313 reporting quality. This survey found the largest source of
overlooked release and other waste management activities was from container residue.
So-called "empty" drums may contain an inch or more of liquid after draining and
similarly "empty" bags may contain residues of dust and powder. Even though each
individual drum or bag may only contain a small amount of an EPCRA Section 313
chemical or chemical category, for facilities that receive hundreds or thousands of
drums or bags each year the annual cumulative amount of an EPCRA Section 313
chemical or chemical category can be substantial. The quantities should typically be
reported in Section 6.2 (see Table 4-1 for estimates of liquid drum residual and the text
of this section for estimates of residual from solids). Please note that unlike RCRA,
EPCRA Section 313 does not define what constitutes an "empty" container.
Actual data and a knowledge of the unloading methods at your facility can
be used to estimate the quantity of residual EPCRA Section 313 chemicals
or chemical categories 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 a study of liquid 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. No testing was conducted for residual
solids in this study. If data or site-specific knowledge is available to
estimate the quantity of solid residual in containers, it should be
considered. If no data are available, U.S. EPA believes an estimate of 1%
residual solid is reasonable.
4-8
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Table 4-1
Summary of Liquid 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 OiF
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
Tor 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
The following example describes how the information in the table can be used to
estimate the quantity of an EPCRA Section 313 chemical or chemical category in
water that was used to clean drums on site.
4-9
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Example - Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10% aqueous solution 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.
From Table 4-1, the average drum residue quantity for this scenario is 2.29%. 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 of the
EPCRA Section 313 chemical transferred to the drum reclaimer should be reported as "zero."
The annual quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the
mean weight percent of residual solution remaining in a pumped steel drum by the total annual weight of solution
in the drums. If the density is not known, it may be appropriate to use the density of water (8.34 pounds per
gallon):
(0.0229) x (55 gal/drum) x (1,000 drums) x (8.34 Ib/gal) = 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 Ib solution) x (0.1) = 1,050 pounds of the EPCRA Section 313 chemical
Therefore, 1,050 pounds of the EPCRA Section 313 chemical are transferred to the POTW, and should be
reported in Part II, Sections 6.1 and 8.7 of the 1999 Form R. Because they cannot be destroyed, metals cannot be
reported as being treated, and metals and metal portions of metal compounds should be reported in Part II,
Section 6.1 and 8.1 of the 1999 Form R.
Example - Container Residue in Tank Trucks
Many wood products facilities purchase resin in tank trucks for processing operations. The tank trucks are
typically returned to the supplier without washing on site, or are sent off site for cleaning at a transportation
equipment cleaning facility. Any EPCRA Section 313 chemicals in the residue in the empty trucks should be
considered as a possible off-site transfer for EPCRA Section 313 reports. If the tank truck is returned to the
supplier and refilled without cleaning, the residue does not need to be reported. However, if the tank truck is
sent off-site for cleaning the quantity must be reported as an off-site transfer for disposal (or recycle, treatment,
or energy recovery if appropriate) (40 CFR § 372.85(b)(16) & (17)).
For example, your site receives one tank truck every two days of a liquid phenol-formaldehyde resin for
processing plywood. After the trucks are emptied, they are sent to an off-site facility for cleaning. You have
determined that the trucks contains 5,000 gallons resin when full, the resin density is 10 Ib/gal, and
approximately 0.2% of the resin remains in the trucks as a residual quantity after they have been emptied.
Further, based on material analysis, the resin contains (by weight) 0.5% formaldehyde, 0.22% methanol, and
0.75% phenol.
[continued on next page]
4-10
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Phenol and methanol are both below their de minimis concentrations (1%). Therefore, they do not need to be
considered in this off-site transfer estimate. However, formaldehyde is not below its de minimis concentration
(0.1%) and this activity must be included in threshold determinations and the off-site transfer estimate as follows:
Threshold Calculation:
Amount of formaldehyde brought on site:
(5,000 gal/truck) x (10 Ib/gal) x (1 truck/2 days) x (365 days/yr) x (0.5%
formaldehyde)
45,625 Ib formaldehyde/yr
Since the reporting threshold for processing has been exceeded, all releases and other waste management
quantities of formaldehyde must be reported.
Off-Site Transfer Calculation:
Amount of formaldehyde sent off-site for disposal as residue in the empty trucks:
[quantity resin received in trucks] x [percent residue remaining after emptying trucks]
x [concentration formaldehyde in residue]
[(5,000 gal/truck) x (10 Ib/gal) x (1 truck/2 days) x (365 days/yr)] x [0.2% residue] x
[0.5% formaldehyde]
91 Ib formaldehyde
This quantity must be reported in Part II, Section 6.2 and included in Part II, Section 8.1 of the Form R.
h. On-Site Waste Treatment (Part II, Section 7A of Form R) - Includes
all on-site waste treatment of EPCRA Section 313 chemicals or chemical
categories. The information reported in Section 7A focuses on the
treatment of the entire waste stream, not the specific EPCRA Section 313
chemical or chemical category. The information includes type of waste
stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment
methods or sequence; influent concentrations of the EPCRA Section 313
chemical or chemical category; treatment efficiency (combined removal
and destruction) of the entire method or sequence; and whether efficiency
data are based on actual operating data. Metals and metal portions of
metal compounds treated in 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 could be completed for on-site treatment of a
wastewater stream containing three EPCRA Section 313 chemicals or
chemical categories.
4-11
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Example - On-Site Waste Treatment
A process at your 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.
The two 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 that removes 99% of chemical A; a
neutralization tank in which 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 would be completed slightly differently when you file the Form R for each of the chemicals or
chemical categories. The table accompanying this example shows how Section 7A would be completed for each
chemical or chemical category. First, on each Form R you identify the type of waste stream in Section 7 A. la as
wastewater (aqueous waste, code W). Next, on each Form R 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 or chemical category
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: P19 (liquid phase separation), Cl 1 (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 or chemical category specific. It applies to the entire waste stream being treated. Section 7A. Ic of
each Form R should show the concentration of the specific chemical or chemical category in the influent to the
first step of the process (oil/water separation). For this example, assume chemicals or chemical categories 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 or chemical category for which you are preparing the Form R. 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 or chemical category, as
appropriate (40 CFR § 372.85(b)(17)).
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 %
[continued o
7A.le
Yes No
X
n next page]
4-12
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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. 1 d refers to the amount of EPCRA Section 313 chemical or chemical category destroyed and/or
removed from the applicable waste stream. The amount actually destroyed would be reported in Section 8.6
(quantity treated on site). For example, when completing the Form R for chemical B you would 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 would be reported in Section 6.2 and
8.1. However, when completing the Form R for chemical C you would 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) - Includes all
on-site energy recovery of reported EPCRA Section 313 chemicals and
chemical categories. U.S. EPA's view is that EPCRA Section 313
chemicals or chemical categories that do not contribute significant heat
energy during combustion processes can not be considered for energy
recovery. Therefore, only EPCRA Section 313 chemicals or chemical
categories 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 or chemical
category is incinerated on site but does not significantly contribute energy
to the process, (e.g., chlorofluorocarbons (CFCs)) it must be considered
on-site waste treatment (see 4.1.3, h. above) (see PPA § 6607; 63 FR
52,184). Metals and metal portions of metal compounds will never be
combusted for energy recovery.
j. On-Site Recycling (Part II, Section 7C of Form R) - Includes all on-site
recycling methods used on EPCRA Section 313 chemicals or chemical
categories.
k. Source Reduction and Recycling Activities (Part II, Section 8 of Form
R)2 - Provide information about source reduction and recycling activities
related to the EPCRA Section 313 chemical or chemical category for
which release and 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
2The Subsection 8.1 through 8.8 designations are for the 1999 Form R. Please refer to the current reporting year
TRI Forms and Instructions for any changes.
4-13
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the quantity reported in Section 8.8 that was released on site or
sent off site for disposal:
§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal) -
§8.8 (on-site 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 or chemical category in wastes combusted for energy
recovery on site. This estimate should be the quantity of the toxic
chemical or chemical category 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 or chemical category combusted for
energy recovery purposes. If monitoring data are not available,
vendor specifications regarding combustion efficiency may be
used as they relate to the EPCRA Section 313 chemical or
chemical category. There should be quantities 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 an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the toxic chemical or chemical category (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 (63 FR 52,184). If an EPCRA Section 313
chemical or chemical category that 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). Metals and metal compounds in a waste
that are combusted on site will never be combusted for energy
recovery and are considered to be disposed. Note that "NA"
should be reported for EPCRA Section 313 chemicals or chemical
categories that do not have a significant heating value. This
includes metals, metal portions of metal compounds, halogens,
hydrochlorofluorocarbons (HCFCs), and CFCs.
(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:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
4-14
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Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the toxic chemical or chemical category (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 an EPCRA Section 313 chemical or chemical
category that 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).
However, this does not apply to metals and metal compounds.
Metals and metal compounds sent off site for combustion in
energy recovery units must be considered as 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
or chemical categories that do not have a significant heating value.
This includes metals, metal portions of metal compounds,
halogens, HCFCs, and CFCs.
(4) Quantity Recycled On-Site (Part II, Section 8.4 of Form R) -
Estimate the quantity of the EPCRA Section 313 chemical or
chemical category recycled in wastes on site. This estimate should
be the quantity of the toxic chemical or chemical category 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, determine if operating data exist that
indicate a recovery efficiency and use that efficiency value
combined with throughput data to calculate an estimate. If
operating data are unavailable, available vendor specifications may
be appropriate.
(5) Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -
The quantity reported in Section 8.5 would 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.
If the facility has knowledge about metals being recovered, this
quantity should be reported in Section 8.5. (PPA § 6607)
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
4-15
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COMMON ERROR - Direct Reuse vs. Recycling
The direct reuse of an EPCRA Section 313 chemical does not need to be
included in the amount reported in Part II, Section 8 of Form R (40 CFR §
372.25(e)). However, recycling of the chemical should be included.
(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 or
chemical category in wastes. The quantities reported in Section
8.6 will be those that have undergone processes that are a subset of
the processes for which codes were reported in Section 7 A, where
treatment includes physical removal from a waste stream. To
estimate the quantity treated, determine if operating data exist that
indicate a treatment efficiency (e.g., destruction or chemical
conversion of the EPCRA Section 313 chemical or chemical
category) and use that efficiency value combined with throughput
data to calculate an estimate. Because metals cannot be destroyed
or chemically converted into something other than the metal or
metal compound, metals cannot be reported as treated in Section
8.6. Note that conversion of a metal from one oxidation state to
another (e.g., Cr(VI) to Cr(III)) is not considered treatment for
Section 8.6. If operating data are unavailable, available vendor
specifications may be appropriate. Section 7A must be completed
if a quantity is entered in Section 8.6 (40 CFR § 372.85(b)(17)).
(7) Quantity Treated Off-Site (Part II, Section 8.7 of Form R) -
The quantity reported in Section 8.7 would 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:
§8.7 = §6.1 (except metals and metal compounds) + §6.2
(treatment) - §8.8 (off-site treatment)
Because metals cannot be destroyed or chemically converted into
something other than the metal or metal compound, metals cannot
be reported as treated in Section 8.7. Quantities of metals reported
in Section 6.1 and 6.2 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
4-16
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Form R) - The purpose of this section is to separate quantities
recycled off site, used for energy recovery off site, treated off site,
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 or chemical category released directly into the
environment or sent off site for recycling, energy recovery,
treatment, or disposal during the reporting year because of 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.
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. This includes small
drippings and spills that often occur during transfer operations and
loading/unloading operations associated with many coating
processes.
On-site releases and off-site transfers for further waste
management from remediation of an EPCRA Section 313 chemical
or chemical category 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 or chemical categories 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 in Sections 8.1 through 8.7 of Form R.
4-17
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COMMON ERROR - Double Counting
Release and other waste management activities should not be "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
release 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, U.S. EPA
recommends 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) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
After you have identified all of the potential sources for release and other waste
management activity types, estimate the quantities of each EPCRA Section 313 chemical and
chemical category released and otherwise managed as waste. U.S. EPA has identified four basic
methods that may be used to develop estimates (each method has been assigned a code that must
be included 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 the U.S. EPA publication,
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
Forms (2000 edition). They are also briefly described below. A more detailed discussion
including examples of selected calculation techniques is presented in Appendix B. EPCRA does
not require you to conduct additional sampling or testing for EPCRA Section 313 reporting.
Rather, facilities may use readily available data collected pursuant to other provisions of law, or
where such data are not readily available, reasonable estimates of the amounts involved (EPCRA
§ 313(g)(2)). 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 the primary method used for each estimation (40 CFR § 372.85(b)(15)(i)).
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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. 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.
Once all potential release and other waste management activity sources, types,
and estimation methods have been determined, an estimate for each EPCRA Section 313
chemical and chemical category can be developed corresponding to the elements on Form R.
Table 4-2
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data
•• Air permits
•• Continuous emission monitoring
•• Effluent limitations
•• Hazardous waste analysis
•• Industrial hygiene monitoring data
•• NPDES permits
•• Outfall monitoring data
• • pH for acids and bases
• • POTW pretreatment standards
•• RCRA permit
• • Stack monitoring data
•• New Source Performance Standards
• • Title V permit data
Emission Factors
Mass Balance
•• Air emissions inventory
•• Hazardous material inventory
•• Hazardous waste manifests
•• MSDSs
• • Pollution prevention reports
•• Spill event records
• • Supply and purchasing records
AP-42 chemical specific emission factors
Facility or trade association derived chemical-
specific emission factors
Engineering Calculations
• • Facility non-chemical specific emission factors.
•• Henry's Law
•• Raoult'sLaw
• • SOCMI* or trade association non-chemical
specific emission factors
•• Solubilities
•• Volatilization rates
* Synthetic Organic Chemicals Manufacturing Industry.
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4.1.4.1 Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for
developing toxic chemical release and 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 representative, you must decide if another
estimation method would give a more accurate result.
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. The treated
wastewater is discharged to an off-site POTW. The amount of copper transferred off site to the POTW (for
Sections 6.1 and 8.1 of the FormR) is estimated as follows:
Amount of copper transferred
• (2 mg/L) x 1 ) x I!? ) x t 1 x (! 50o ooo gal/yr)
( 1,000 mgj ^ 453.59 gj ^ 0.2642 galj
= 25 Ib/yr
COMMON ERROR - Treatment Efficiencies
Vendor data on treatment efficiencies often represent ideal operating conditions. You may 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 certain 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 an EPCRA Section 313
chemical or chemical category entering and leaving an operation. The mass balance is written as
follows:
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Input + Generation = Output + Consumption
where:
Input refers to the materials (toxic chemicals) entering an operation. For
example, chlorine added to process water as a disinfectant would be
considered an input to the water treatment operation or EPCRA Section
313 chemical contained in a resin or added to the wood material.
•• Generation identifies those toxic chemicals created during an operation
(manufactured, including coincidental manufacturing). For example,
when nitrogen sources are used in biological wastewater treatment
systems, nitrate compounds and additional ammonia may be
coincidentally manufactured.
•• Output refers to the materials (toxic chemicals) leaving an operation by
various avenues. Output (avenues) may include on-site release and other
on-site waste management activities; transfers off site for recycling,
energy recovery, treatment, storage, or disposal; or the amount of toxic
chemical that leaves with the final product. For example, free
formaldehyde remaining in a presswood product should be considered an
output, or EPCRA Section 313 chemical emissions from a wood dryer.
•• Consumption refers to the amount of toxic chemical converted to another
substance during the operation (i.e., reacted). For example, in the
phosphating process, accelerators may be added to enhance reaction
speed, eliminate hydrogen production, or sludge formation control.
Several materials can be used for this purpose, including nitrite or nitrate
compounds, which would be consumed in the process. Also, a urea
scavenger is used to react with any excess formaldehyde in a urea-
formaldehyde resin.
The mass balance technique may be applied toward manufactured, processed, or
otherwise used toxic chemicals and chemical categories. It is typically most useful for otherwise
used toxic chemicals or chemical categories that do not become part of the final product, such as
catalysts. 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.
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Example - Mass Balance
A facility otherwise uses a volatile EPCRA Section 313 chemical as a refrigerant and adds 20,000 pounds to the
refrigeration system (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. 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 (Ib/yr) - Amount released to wastewater (Ib/yr)
= 20,000 Ib/yr - 1,200 Ib/yr
= 18,800 Ib/yr
This quantity would be reported in Sections 5.1 and 8.1 of Form R.
COMMON ERROR - Mass Balances for Otherwise Used Toxic Chemicals
Facilities often do not account for the entire quantity of EPCRA Section 313 chemicals or chemical categories
that are otherwise used. Many EPCRA Section 313 chemicals and chemical categories are used as carrier
solvents and are classified as otherwise used. Such chemicals and chemical categories may or may not leave the
facility with the product. For those instances where the EPCRA Section 313 chemical or chemical category does
not leave the facility in the product, all throughput may be lost during processing through on-site releases to air,
water, or land, or it may be shipped off site for further waste management activities. Thus, the entire throughput
is often reportable on Form R as release and 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 to estimate the release and other waste management 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 or chemical category released with an associated activity. These factors are usually
expressed as the weight of chemical or chemical category released divided by a unit weight,
volume, distance, or duration of the activity releasing the toxic 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. If there are more than one EPA
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published emission factors, determine which is the most appropriate for your operation and
document your rationale.
The most widely known and used source for emission factors is U.S. EPA's
publication Compilation of Air Pollutant Emission Factors (AP-42). Volume I of AP-42
contains information on over 200 stationary source categories, including process descriptions
and potential sources of air emissions from these processes. Methodologies for estimating the
quantity of air pollutant emissions from these sources are presented as Emission Factors. For
EPCRA Section 313 purposes only CHEMICAL-SPECIFIC emission factors can be reported as
Code "E" - Emission Factor in Part II, Section 5, Column B, Basis for estimate, of the Form R.
AP-42 contains emission factors for individual chemicals and for the chemical group Volatile
Organic Compounds (VOCs). The VOC emission factors are NOT chemical specific and when
used must be reported in Column B as Code "O" - Engineering Calculations. Each chapter in
Volume I covers a major industry or source category. Of special interest to presswood and
laminated wood products manufacturing operations would be Chapter 10: Wood Products
Industry, in particular Sections 10.5, Plywood Manufacturing; and 10.6, Reconstituted Wood
Products.
AP-42 can be accessed at the following Internet site:
• • http://www.epa.gov/ttn/chief/ap42.html
Note that U.S. EPA is currently developing additional emission factors and
associated guidance for presswood operations. You should periodically review AP-42 for this
updated guidance.
In an effort to provide current emissions data in an easy-to-access format, U.S.
EPA has prepared a CD-ROM entitled Air CHIEF (Air ClearingHouse for Inventories and
Emission Factors). The Air CHIEF CD-ROM is updated annually and is available from the
Government Printing Office and can be ordered from their Web site. In addition to AP-42, the
Air CHIEF CD-ROM contains the Factor Information Retrieval (FIRE) data system, a database
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management system containing U.S. EPA's recommended emission estimation factors for
criteria and hazardous air pollutants. The CD-ROM also contains installable copies of software
programs for air emission estimation models such as "TANKS" for VOC emission from storage
tanks; "WATERS" for air emissions from wastewater systems; and "CHEMDAT8" for VOC
emissions from Treatment, Storage, and Disposal Facility (TSDF) processes. Additional
information on Air CHIEF and the CD-ROM is available at:
•• http://www.epa.gov/ttn/chief/airchief.html
Your facility may have developed non-chemical-specific emission factors for
fugitive or stack emissions from dryers or presses based on stack tests for various air permits.
Be sure to consider these emission factors if appropriate. However, if such factors are used, they
are considered "engineering calculations" for the purposes of EPCRA Section 313 reporting.
Example - Emission Factors
Emission factors have been developed for air releases of fuel constituents and combustion products from boiler
operations. AP-42 lists a following emission factor for formaldehyde when No. 6 fuel oil is consumed by
electricity generating facilities (EGFs):
0.033 Ib formaldehyde generated/103 gal No. 6 fuel oil fired.
Assuming a facility met reporting requirements for formaldehyde, the EOF 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:
(0.033 lb/103 gal) x (1,000,000 gal)
= 33 Ib of formaldehyde generated
If there are no engineering controls or air pollution control devices that would destroy or remove the
formaldehyde, this quantity would be reported in Part II, Sections 5.2 and 8.1 of the 2000 Form R.
NOTE: No. 6 fuel oil contains other EPCRA Section 313 chemicals and chemical categories and EPCRA
Section 313 chemicals and chemical categories may also be coincidentally manufactured during combustion. All
should be considered for EPCRA Section 313 reporting.
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4.1.4.4 Engineering Calculations (code O)
Engineering calculations are assumptions and/or judgments used to estimate
quantities of EPCRA Section 313 chemicals and chemical categories released or otherwise
managed as waste. 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 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.
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, but should be
classified as "Engineering Calculations" for EPCRA Section 313 reporting.
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Examples - 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 and the concentrations of the chemicals in the liquid feedstock are
approximately the same. 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, you determine that an estimated 200 Ib 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 20°C. Based on literature data, the vapor pressure at 20°C for toluene is 22 millimeters
of mercury (mmHg) and for xylene is 6 mmHg. Using a ratio of the vapor pressures, the amount of toluene
released as air emissions from the stack can be calculated:
X Ib/yr toluene = 22 mmHg (vapor pressure of toluene)
200 Ib/yr xylene 6 mmHg (vapor pressure of xylene)
X Ib/yr toluene = (200 Ib/yr xylene) (22 mmHg toluene)
(6 mmHg xylene)
Completing the calculation, you determine that 730 Ibs of toluene were released as stack air emissions during the
reporting year. The quantity of toluene released would be reported in Section 5.2 of the 1999 Form R.
Example 2:
A finishing process uses 10,000 gallons per year of a coating that is 3% xylene by volume. All of the xylene in
the coating is assumed to evaporate during the operation. The process is equipped with a fume collection hood
that captures 80% of the solvent vapors. The remaining 20% of the vapors are assumed to be released as fugitive
air emissions. The collection hood routes the 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 volatilized to air (assumed to be the total amount of xylene
in the coating)
(10,000 gal/yr coating) x (0.03, three percent xylene) x
(0.86 xylene specific gravity) x (8.34 Ib/gal, density of water)
2,152 Ib/yr xylene evaporated from finishing operations
2. The amount of xylene released as fugitive air emissions
(2,152 Ib/yr) x (0.2; twenty percent released as fugitive air emissions)
430 Ib/yr
This would be reported in Part II, Sections 5.1 and 8.1 of the 1999 Form R.
3. The amount of xylene released as stack air emissions
(2,152 Ib/yr) x (0.8, eighty percent capture efficiency) x (1-0.99, percent not
incinerated)
17 Ib/yr
This would be reported in Part II, Sections 5.2 and 8.1 of the 1999 Form R.
4.1.4.5 Estimating Release and Other Waste Management Quantities
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Once all sources, types, and appropriate estimation methodologies have been
identified, you can estimate the release and other waste management activity quantities of
EPCRA Section 313 chemicals or chemical categories 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.
If you prepare a Form R, you must also enter on-site treatment information in
Section 7 A, including the code for each treatment method used, the destruction and removal
efficiency for the EPCRA Section 313 chemical or chemical category in the treated waste
stream, and the concentration of the EPCRA Section 313 chemical or chemical category in the
influent to treatment (40 CFR § 372.85(b)(17)). You should report treatment methods that do
not actually destroy or remove the toxic chemical or chemical category by entering "zero (0)" for
removal efficiency (53 FR 4517). Similarly, on-site energy recovery methods and on-site
recycling methods must be reported in Sections 7B and 7C, respectively.
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Table 4-3
Facility Name:
Release and Other
Waste Management Quantity Estimation Worksheet
Date Worksheet Prepared:
Prepared by:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(2000 version)
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses, Spills, Surface Impoundments
Total =
5. land 8. lor 8.8
5.1 and 8.1 or 8. 8
5. land 8.1 or 8. 8
5. land 8. lor 8.8
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
5.2 and 8. lor 8.8
5.2 and 8. lor 8.8
5.2 and 8.1 or 8. 8
5.2 and 8. lor 8.8
5.2 and 8.1 or 8. 8
RECEIVING STREAM/WATER BODY DISCHARGE
Stormwater Discharge
On-Site Treatment Plant Discharge
Total =
5.3 and 8. lor 8.8
5.3 and 8.1 or 8. 8
5.3 and 8. lor 8.8
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II - V Wells
Total =
5.4 and 8.1 or 8. 8
5.4 and 8. lor 8.8
5.4 and 8.1 or 8. 8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(2000 version)
ON-SITE LAND
RCRA Subtitle C Landfill
Other Landfill
Land Treatment/ Application Farming
Surface Impoundment
Other Disposal
Total =
ON-SITE ENERGY RECOVERY
Industrial Kiln
Industrial Furnace
Industrial Boiler
Other Energy Recovery Methods
Total =
ON-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Acid Regeneration
Other Reuse or Recovery
Total =
ON-SITE TREATMENT
Air Emissions Treatment
Biological Treatment
Chemical Treatment
Incineration/Thermal Treatment
Physical Treatment
Solidification/Stabilization
Total =
5. 5 and 8.1 or 8. 8
5.5 and 8. lor 8.8
5. 5 and 8.1, or 8.8
5. 5 and 8.1 or 8. 8
5.5 and 8. lor 8.8
5. 5 and 8.1 or 8. 8
8.2
8.2
8.2
8.2
8.2
8.4
8.4
8.4
8.4
8.4
8.6
8.6
8.6
8.6
8.6
8.6
8.6
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
Ob)
Basis of
Estimate
Form R Element*
(2000 version)
Off-Site Location
(name)
OFF-SITE DISPOSAL
Solidification/Stabilization (metals and
metal compounds only)
Amount of metal and metal compounds to
POTW
Wastewater Treatment (excluding
POTWs) metals and metal compounds
only
Underground Injection
Landfill/Surface Impoundment
Land Treatment
Other Land Disposal
Other Off-Site Management
Total =
6.2 and 8.1 or 8. 8
6.1 and 8.1 or 8. 8
6.2 and 8. lor 8.8
6.2 and 8.1 or 8. 8
6. 2 and 8. lor 8.8
6.2 and 8. lor 8.8
6. 2 and 8.1 or 8. 8
6. 2 and 8. lor 8. 8
6.2 and 8. lor 8.8
OTHER AMOUNTS SENT OFF SITE
Amounts sent for storage
Amounts sent for unknown waste
management practice
Total =
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
OFF-SITE TREATMENT
Solidification/Stabilization
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Wastewater Treatment (to POTW
excluding metals and metal compounds)
Wastewater Treatment (excluding POTW
and metal and metal compounds)
Sent to Waste Treatment Broker
Total =
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6. 2 and 8.7 or 8. 8
6. land 8.7 or 8.8
6.2 and 8.7 or 8. 8
6. 2 and 8. 7 or 8. 8
6.2 and 8.7 or 8. 8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
Ob)
Basis of
Estimate
Form R Element*
(2000 version)
Off-Site Location
(name)
OFF-SITE ENERGY RECOVERY
Off-Site Energy Recovery
Sent to Energy Recovery Broker
Total =
6.2 and 8.3 or 8.8
6.2 and 8.3 or 8.8
6.2 and 8. 3 or 8. 8
OFF-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Sent to Recycling Waste Broker
Total =
6.2 and 8.5 or 8.8
6. 2 and 8. 5 or 8. 8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6. 2 and 8. 5 or 8. 8
6.2 and 8.5 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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4.2 Determination of Release and Other Waste Management Activity Quantities
from the Presswood and Laminated Wood Products Industry
Presswood and laminated wood products include a variety of products such as
plywood, veneer, waferboard, oriented strandboard, particleboard, medium density fiberboard,
hardboard, and engineered lumber. Essentially, all of these products are manufactured using
wood as a raw product, refining the wood to thin sheets, chips, strands, or fibers, and re-
combining the wood using some type of adhesive or resin, usually under pressure and/or heat.
EPCRA Section 313 chemicals or chemical categories may be found in the adhesives and resins.
They may also be generated as a by-product from refining the wood or from the combustion of
wood in dryers.
While the specific processes involved with the manufacture of each type of
presswood and laminated product are unique, the basic processes are similar. In general, the
manufacture of each type of product consists of a four-step process that involves similar unit
operations and corresponding release and waste management of EPCRA Section 313 chemicals
and chemical categories. For the purposes of this document, these general steps are defined as:
Drying (see Section 4.2.2);
Pressing (see Section 4.2.3);
Finishing (see Section 4.2.4); and
Combustion (see Section 4.2.5).
Figure 4-3 presents an overall process flow diagram for these general steps.
Detailed diagrams for drying, pressing, and finishing can be found in Sections 4.2.1, 4.2.2, and
4.2.3, respectively.
It is recognized that not all presswood and laminated wood products
manufacturing establishments will have all unit operations described in this document. For
example, softwood plywood manufacturers may not have finishing operations. However, each
of the unit operations discussed are common operations found in presswood and laminated wood
products manufacturing establishments covered by EPCRA Section 313 reporting requirements.
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Wood
On Site T
i
Resins/Adhesives
Air Emissions
A l On Site Treatment Air Emissions
t ,. 1
w urying * rressing
"reatment
i
Coati
i
ngs.Fillers.Etc.
Air Emissions
. t
Finishing
^ r
Container Residue
^
r
Final Product
Container Residue
Figure 4-3. Overall Process Flow Diagram - Application of Organic Coatings
-------
You should select the operation, or combination of operations, that most closely fits the activities
at your establishment.
A brief discussion of the individual processes involved with manufacture of
presswood and laminated products listed above is provided in Section 4.2.1. Sections 4.2.2
through 4.2.5 discuss each of the general steps in the manufacture of presswood and laminated
wood products and the corresponding estimation of releases and other waste management
quantities.
4.2.1 Process Description
Plywood/Veneer
Plywood is a building material consisting of veneers (thin wood layers or plies)
bonded with an adhesive. The outer layers (face and back) surround a core that is usually
lumber, veneer, or particleboard. The manufacture of plywood consists of seven main processes:
log debarking and bucking, heating the logs, peeling the logs into veneers, drying the veneers,
gluing the veneers together, pressing the veneers in a hot press, and finishing processes such as
sanding and trimming.
The initial step in plywood manufacturing is feeding logs through debarking
machines. After the bark is removed, the logs are cut to appropriate lengths (bucking). The logs
(now referred to as blocks) are then heated to improve the cutting action of the veneer lathe or
slicer, resulting in better surface finish. Blocks are heated to around 93* C (200* F) using a
variety of methods - hot water baths, steam heat, hot water spray, or a combination of the three.
After heating, the logs are processed to generate veneer. For most applications, a
veneer lathe is used, but some decorative, high quality veneer is generated with a veneer slicer.
The veneer lathe or slicer compress the wood with a nosebar while cutting the blocks into
veneers, typically 1/8 inch thick. These pieces are then clipped to a useable width.
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The veneers are then dried in a veneer dryer until the target moisture content is
reached. Target moisture content, ranging from <1% to 15%, depends on the type of resin used
in subsequent gluing steps. After drying, the veneers are glued together with a thermosetting
resin. The two main types of resins are phenol-formaldehyde, which is used for softwood and
exterior grades of hardwood, and urea-formaldehyde, which is used to glue interior grades of
hardwood. The resins are applied by glue spreaders, curtain coaters, or spray systems.
At the hot press, the laid-up assembly of veneers is consolidated under heat and
pressure. Hot pressing has two main objectives: (1) to press the glue into a thin layer over each
sheet of veneer; and (2) to activate the thermosetting resins. The press time and temperature
vary depending on the wood species used, the resin used, and the press design. Press times range
from 2 to 7 minutes and press temperature ranges for softwood and hardwood plywood are 270* •
330* F and 225* »to 275* F, respectively. Following the hot press, the plywood may undergo
trimming and sanding operations.
Waferboard/Oriented Strandboard
Waferboard (WB) and oriented Strandboard (OSB) belong to the subset of
reconstituted wood panel products called flakeboards. They are structural panels made from
wood wafers specially produced from logs at the plant. The relatively long and narrow flakes
(strands) are blended with resin and formed into a 3- or 5-layered mat. Aligning the strands in
each layer perpendicular to adjacent layers gives OSB flexural properties superior to those of
randomly oriented waferboard.
WB/OSB manufacturing begins with whole logs, which are cut to 100-inch
lengths by a slasher saw. The logs are then debarked and carried to stationary slasher saws,
where they are cut into bolts (33-inches long), in preparation for the waferizer. The waferizer
slices the logs into wafers with approximate dimensions of 1.5 in. x 3 in. x 0.028 in.
Triple-pass rotary drum dryers are typical in WB/OSB plants. The dryers are
normally fired with wood residue from the plant, but occasionally oil or natural gas are also used
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as fuels. The wafers are dried to a low moisture content (generally 4% to 10%, dry basis) to
compensate for moisture gained by adding resins and other additives.
After drying, the wafers are conveyed pneumatically from the dryer, separated
from the gas stream at the primary cyclone, and screened to remove fines and separate the wafers
by surface area and weight. The gas stream continues through an air pollution control device
and is vented to the atmosphere. The screened wafers are stored in dry bins.
The dried wafers are blended with resin, wax, and other additives. The most
commonly used binders are thermosetting urea-formaldehyde (WB production only), phenol-
formaldehyde, and isocyanate resins, all of which require the application of heat for curing.
At the mat forming process the wafers are metered out on a continuously moving
screen system. This process is the only step where there is any significant difference between
WB and OSB production. In WB production, the wafers are allowed to fall randomly to the
moving screen below to form a mat of the required thickness. In OSB production, the wafers are
oriented electrostatically or mechanically in one direction. Subsequent forming heads create
distinct layers in which the wafers are oriented perpendicular to those in the previous layer.
In the mat trimming section, a traveling saw cuts the formed mat into desired
lengths. The trimmed mat proceeds to the accumulating press loader and the hot press. The
press applies heat and pressure to activate the resin and bond the wafers into a solid reconstituted
product. In most hot presses, boilers generate the steam heat by burning plant residuals. Hot oil
and hot water also can be used to heat the press. After cooling, the bonded panel is trimmed to
final dimensions, finished (if necessary), and packaged for shipment.
Particleboard
Particleboard is defined as a panel product manufactured from lignocellulosic
materials, primarily in the form of discrete particles, combined with a synthetic resin or other
suitable binder and bonded together under heat and pressure. The primary difference between
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particleboard and other reconstituted wood products is the material or particles used in its
production. The major types of particles used to manufacture particleboard include wood
shavings, flakes, wafers, chips, sawdust, strands, slivers, and wood wool.
The general steps used to produce particleboard include raw material procurement
or generation, classifying by size, drying, blending with resin and sometimes wax, forming the
resinated material into a mat, hot pressing, and finishing.
The furnish or raw material for particleboard normally consists of wood particles,
primarily wood chips, sawdust, and planer shavings. This material may be shipped to the facility
or generated onsite. In facilities where chips are generated on site, logs are debarked, cut, and
chipped. After receipt or generation, the furnish may be reduced in size by means of
hammermills, flakers, or refiners. The material is then screened using vibrating or gyrator
screens, or the particles are air-classified. The purpose of this step is to remove the fines and to
separate the core material from the surface material. The screened or classified material is stored
until conveyed to dryers. Rotary dryers (single and triple-pass) are the most commonly used
dryer type in the particleboard industry. In addition, some facilities use tube dryers to dry the
furnish. Wood-fired dryers are used at most facilities, however, gas- and oil-fired dryers are also
used.
After drying, the particles pass through a primary cyclone for product recovery
and are stored in holding bins until transferred to the blenders. At the blenders, the core and
surface materials are mixed with resin, wax, and other additives by means of spray nozzles,
tubes, or atomizers. The most commonly used resins are phenol-formaldehyde and urea-
formaldehyde.
The blended material is conveyed to the forming machine, which deposits the
resinated material into a continuous mat. Formers use air to convey the material, which is
dropped or thrown into an air chamber above a moving caul, belt, or screen and floats down into
position. To produce multilayer particleboard, several forming heads can be used in series, or air
currents can produce a gradation of particle sizes from face to core.
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The mat may be prepressed prior to trimming. Following trimming, the press
applies heat and pressure to activate the resin and bond the fibers into a solid panel. Presses
generally are steam-heated using steam generated by a boiler that burns wood residue. However,
hot oil and hot water are also used to heat the press.
Once the particleboard panels are sanded and trimmed to final dimensions, any
other finishing operations (e.g., edge painting, laminate or veneer application) are done, and the
finished product is packaged for shipment.
Medium Density Fiberboard
Medium density fiberboard (MDF) is a dry-formed panel product manufactured
from lignocellulosic fibers with an interfiber bond formed by a synthetic resin or other suitable
organic binder. The general steps used to produce MDF include mechanical pulping of wood
chips to fibers (refining), drying, blending fibers with resin and sometimes wax, forming the
resinated material into a mat, and hot pressing.
The furnish for MDF normally consists of wood chips. Clean chips are softened
by steam and then sent to atmospheric or pressurized disk refiners, also known as attrition mills.
The refiners use single or double revolving disks to mechanically pulp the chips to obtain fibers
in a suitable form for making the board.
From the refiners, the fibers move to the drying and blending area. Heat for the
dryers is usually provided by the direct firing of propane, natural gas, or distillate oil. The
sequence of the drying and blending operations depends on the method by which resins and
other additives are blended with the fibers. Some plants inject resins into a short-retention
blender, while others inject resin formulations into a blowline system. If resin is added in a
separate blender, the fibers are first dried and separated from the gas stream by a primary
cyclone, then conveyed to the blender. The fibers then are blended with resin, wax, and any
other additives and conveyed to a dry fiber storage bin. Urea-formaldehyde (UF) resins are the
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most common resins used. Phenolic resins and melamine resins may also be used, however
MDF plants generally do not use phenolic resins.
Air conveys the resinated fibers from storage to the forming machine, where they
are deposited on a continuously moving screen system. The continuously formed mat must be
prepressed before being loaded into the hot press. After prepressing, some pretrimming is done.
The prepressed and trimmed mats then are transferred to the hot press. The press applies heat
and pressure to activate the resin and bond the fibers into a solid panel. Radio-frequency (RF)
heating and steam heating of the press platens are common in domestic MDF plants. After
pressing, the boards are cooled, sanded, trimmed to final dimensions, finished if required, and
packaged for shipment.
Hardboard/Fiberboard
Hardboard and fiberboard are similar to MDF in some respects. Hardboard is a
higher-density version of MDF, while fiberboard has a lower density than MDF. Hardboard is
used for housing (e.g., exterior siding, garage doors, and interior door facings), furniture, store
fixtures, automotive interiors, and toys. Fiberboard is used for housing, roofing, and office
furnishings. Like MDF, hardboard and fiberboard are manufactured from wood chips which are
softened and refined into wood fibers. However, the processes and resins used to manufacture
hardboard and fiberboard differ from those used to manufacture MDF.
One of three processes may be used to manufacture hardboard: dry process, wet
process, or wet/dry processes. Dry processing involves dry mat forming and pressing, while wet
processing involves wet forming and wet pressing. Wet/dry processing involves wet forming
followed by dry pressing. Fiberboard is manufactured by wet forming, however the fiberboard is
not pressed.
Dry process hardboard manufacturing is similar to MDF manufacturing, except
for the resin used and operations following pressing. The hardboard wood furnish is dried using
tube dryers. Blowline blending is used to blend PF resin with the hardboard fibers. If a blowline
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system is used, the fibers are blended with resin, wax, and other additives in a blowpipe that
discharges the resinated fibers to the dryer. The resinated, dried fibers are formed into a mat and
pressed. Following pressing, the boards are coated with a drying oil and further dried in a
tempering oven. Tempering of the hardboard improves its water resistance. Once tempered, the
boards are re-humidified to improve their dimensional stability. Following humidification, the
boards are finished and packaged for shipment.
Wet hardboard, wet/dry hardboard, and fiberboard mats are formed using a wet
process in which fibers are mixed with water and adhesive and then metered onto a wire screen.
Water is drained away with the aid of suction applied to the underside of the screen. The fiber
mat, along with the supporting wire, is moved to a prepress where excess water is squeezed out.
A PF adhesive is used for wet process hardboard. Linseed oil, asphalt, and/or starch is used as
the binder in wet/dry process hardboard and fiberboard manufacturing.
Once formed, wet process hardboard is pressed and further dried in a bake oven.
The wet process boards are then passed through a humidifier and finished. Wet/dry process
hardboard is dried in a conveyor-type dryer before being hot pressed. Once pressed, the wet/dry
hardboard is tempered and re-humidified. Fiberboard is also dried in a conveyor-type dryer
following forming. The fiberboard is ready for finishing once it is dried.
Engineered Wood Products
Engineered wood products are made from lumber, veneers, strands of wood, or
from other small wood elements that are bound together with structural adhesives to form
lumber-like structural products. They are designed for use as girders, beams, headers, joists,
studs, columns, and other end uses. The engineered wood products discussed in this document
include laminated veneer lumber (LVL), laminated strand lumber (LSL), parallel strand lumber
(PSL), I-joists, and glue-laminated beams (glu-lam).
Laminated Veneer Lumber - Laminated veneer lumber consists of layers of
wood veneers laminated together into a billet with PF resin. Laminated veneer lumber is used
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for headers, beams, rafters, and I-joist flanges. Veneers used in LVL manufacture are either
purchased pre-dried, purchased green and dried on site, or peeled and dried on site. Softwood or
hardwood veneers may be used to manufacture LVL. The veneer dryers used at LVL plants are
the same types of dryers in use at plywood plants. The dried veneers are graded and passed
under a curtain or roll coater where phenol-formaldehyde (PF) resin is applied. Some plants that
manufacture LVL from hardwood species may use urea-formaldehyde (UF) resin rather than PF
resin. Next, the veneers are manually laid up into a long stack that is several inches thick. The
veneer stack is fed to a hot press where the veneers are pressed into a solid billet under heat and
pressure. Batch or continuous presses heated by electricity, microwaves, hot oil, steam, or radio
frequency (RF) waves are used for LVL. Billets exiting the press are several inches thick, and
may be made even thicker in a secondary gluing operation. The billets are sawed into strips
based on customer specifications. Trademarks or grade stamps may be applied in ink to the LVL
before it is shipped from the plant.
Laminated Strand Lumber - Laminated strand lumber is made up of hardwood
strands glued together with the grain of each strand oriented parallel to the length of the finished
product. Whole logs are received at the plant, debarked, cut to length, and conditioned in heated
log vats. The conditioned logs are cut into long strands. The strands are screened and dried in
either a conveyor or rotary drum dryer. The dried strands are re-screened and blended with MDI
resin in a rotating blender. From the blender, the resinated strands are formed into mats. The
mats are pressed in a single-opening, batch, steam-injection press. The press compacts the loose
mat of strands into a billet that is several inches thick. The pressed billets are sanded, cut to
dimensions, and packaged for shipment.
Parallel Strand Lumber - Parallel strand lumber is made of hardwood or
softwood veneer strands glued together with PF resin. Logs are peeled into veneers and dried
onsite in veneer dryers. The dried veneer is clipped into strands. The veneer strands are coated
with PF resin, aligned, and fed into a continuous press. The press uses microwaves to cure the
PF resin. A variety of billet dimensions may be produced in the continuous press. Following
pressing, the billets are sawn according to customer specifications and packaged for shipment.
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I-Joists - Wood I-joists are a family of engineered wood products consisting of a
web made from a structural panel such as plywood or OSB which is glued between two flanges
made from sawn lumber or LVL. They are used in residential and commercial buildings as floor
joists, roof joists, headers, and for other structural applications. The processes for manufacturing
wood I-joists range from continuously operated automated production lines to custom hand lay-
up processes. Regardless of the process, the general steps used to fabricate I-joists include:
flange preparation, web preparation, I-joist assembly, and I-joist curing. Web preparation
involves ripping of the web into sections of desired length and machining (tapering) the edges of
the web. Flange preparation involves ripping of sawn lumber, LVL, or other engineered wood
material to the desired width. If required, the flanges may be finger-jointed end-to-end to form a
continuous flange. During the finger-jointing process, grooves are cut into the end of each
flange, a phenol-resorcinol-formaldehyde (PRF) finger-jointing resin is applied between the
grooves, the flanges are fitted together end-to-end, and the finger-jointing resin is cured in a
radio-frequency (RF) tunnel. Next a groove is routed into one face of the flange along its length.
Resin (PRF or MDI) is applied in the flange groove and to the short edges of the web material.
The webs are fitted together into the resinated grooves between two flanges. The I-joists then
pass through an oven or curing chamber to cure the adhesive. Once cured, the finished I-joists
are inspected and bundled for shipment.
Glu-Laminated Beams - Glu-laminated beams are manufactured by glueing
lumber faces together to form larger structural members for applications such as ridge beams,
garage door headers, floor beams, and arches. The glu-lam manufacturing process consists of
four phases: (1) drying and grading the lumber; (2) finger-jointing the lumber into longer
laminations; (3) face gluing the laminations; and (4) finishing and fabrication. Lumber used to
manufacture glu-lam may be dried on site in a lumber kiln or purchased pre-dried from suppliers.
The dried lumber is graded and sorted. To manufacture glu-lam in long lengths, the lumber must
be finger-jointed at its ends in a process similar to that described above for I-joist flanges. Next,
the lumber is planed and adhesive is spread onto the lumber face. Phenol-resorcinol-
formaldehyde is the most commonly used adhesive for face gluing. Other adhesives used for
face gluing include PF resin or melamine-urea-formaldehyde (MUF) resin. The resinated lumber
is assembled into a specified lay-up pattern and is clamped in a clamping bed where a
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mechanical or hydraulic system brings the lumber into close contact. Curved beams are clamped
in a curved form. The beams are cured at room temperature for several hours before the pressure
is released. After the glu-lam beams are removed from the clamping system, the sides are planed
or sanded to remove beads of adhesive. The top and bottom of the beams may be lightly planed
or sanded depending on appearance requirements. Corners are often rounded as well. The
specified appearance of the member dictates whether additional finishing is required at this point
in the manufacturing process. Knot holes may be filled with putty patches and the beams may be
further sanded. End sealers, surface sealers, finishes, or primer coats may also be applied.
4.2.2 Drying
Drying of the wood prior to subsequent manufacturing steps is needed to obtain a
consistent raw product (for reconstituted wood products), as well as to prevent further warping
or cracking once the wood has been combined into the finished product (for plywood and
veneer). Dryer types include veneer and rotary dryers for particles and flakes (particleboard and
OSB), tube dryers for wood fibers (MDF and dry process hardboard), and other conveyor-type
dryers for wood slurries (wet/dry hardboard and fiberboard) and flakes (OSB). Hardboard plants
also operate bake and/or tempering ovens. Dryers may be direct-fired (the exhaust gases from
the combustion process directly contact the wood) or indirect-fired (through the use of steam).
Wood may be the only fuel, or supplemental fuels, such as fuel oil or natural gas, may be used.
EPCRA Section 313 chemicals and chemical categories are generated from both
the combustion process as well as from the wood itself. Air emissions from dryers include wood
dust and other solid paniculate matter (PM), formaldehyde, methanol, and other combustion
products (such as acetaldehyde). Additional toxic chemicals emitted from dryers may include
acrolein, propionaldehyde, and phenol. Furthermore, small amounts of benzene cumene, M&K,
MIBK, styrene, toluene, and xylenes may also be emitted from some dryers.
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Exhaust gases from wood dryers may be controlled for filterable and condensable
particulate matter (PM) as well as for VOC's. VOC control devices used on dryers are typically
incineration devices, including regenerative thermal oxidizers, regenerative catalytic oxidizers,
thermal oxidizers, and thermal catalytic oxidizers.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram can be prepared to help identify all potential
sources and types of toxic chemical and chemical category release and other waste management
activities. A typical flow diagram is presented in Figure 4-4.
Air Pollution
Control Device
Treated exhaust
(stack air release)
Participate matter and
other treatment residuals
(on- or off-site energy recovery,
recycle, treatment, or disposal)
Exhaust Gases
(On-site treatment)
• Fugitive and stack air releases
Wet Wood •
Drying
"Dry Wood
(to Pressing)
Indirect Heat/Burner Exhaust
Boiler/Burner
->Boiler Exhaust
Fuel
Fuel Storage
Tank
•*• Stack air release
Figure 4-4. Process Flow Diagram - Drying
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The most common potential source of EPCRA Section 313 chemicals and
chemical categories from dryers are exhaust gases from the dryer vents (if uncontrolled) and
control device stacks. EPCRA Section 313 chemicals and chemical categories from dryers
include organic chemicals generated from heating the wood and chemicals, and chemicals
coincidentally manufactured from the combustion of dryer fuel (typically wood, fuel oil, or
natural gas) in direct-fired dryers. If fuel is stored in on-site storage vessels, the daily loading
and breathing losses from pressure release valves will result in stack air releases.
The two most predominant EPCRA Section 313 chemicals and chemical
categories which would be expected from wood dryers are formaldehyde and methanol. These
are generated directly from the heating of the wood. Formaldehyde and other EPCRA Section
313 chemicals (such as acetaldehyde) and chemical categories may also be generated as a
product of incomplete combustion of the fuel (particularly if fuel oil is used). Quantities of these
chemicals emitted from these sources are dependent on many variables, including wood species,
dryer temperature, dryer heating method, fuel used, season of the year, time between logging and
processing, wood storage time, and wood moisture content.
Step 3: Identify Release and Other Waste Management Activity Types
The primary sources of release are the drying units and corresponding boilers.
Release types include fugitive emissions to the air from uncontrolled vents and leaks from the
dryer, and stack emissions directly from the dryer (if uncontrolled) and from the control device
stack.
If the exhaust gases from the dryer are controlled, on-site treatment quantities
would also be estimated. Note that any EPCRA Section 313 chemical or chemical category sent
through an air pollution control device is considered to have been treated for destruction if it is
converted to another chemical or it is HC1 or H2SO4 acid aerosols. The treatment efficiency of
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the unit should be reported in Section 7A and the quantity treated for destruction should be
reported in Section 8.6 (for example, the formaldehyde destruction efficiency of a thermal
oxidizer should be reported in Section 7 A, and the amount (Ib/yr) of formaldehyde destroyed
should be reported in Section 8.6). Also, note that any EPCRA Section 313 chemical or
chemical category sent through an air pollution control device is considered to have been
captured for further waste management activities if it is not converted to another chemical or it is
not HC1 or H2SO4 acid aerosols. The capture efficiency of the unit should be reported in Section
7A and the quantity captured should be reported in Sections 6 and/or 8 depending on the final
disposition of the toxic chemical or chemical category. If fuel oil storage tanks are present at
your facility, the expected release from breathing and loading operations should be considered a
stack release (53 FR 4515).
Typical release and other waste management activities and associated EPCRA
Section 313 chemicals and chemical categories are:
Typical Type of Release/Waste
Management Activity
Fugitive Air
Stack Air
On-Site Treatment
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Methanol, Formaldehyde
Methanol, Formaldehyde, Acetaldehyde
Methanol, Formaldehyde
It should be noted that if fossil fuels are used in dryers or in other applications at a
facility, they may contain EPCRA Section 313 chemicals or chemical categories above the de
minimis level. Please refer to Section 4.2.5 for a discussion of how to determine if these
operations are subject to reporting.
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Stack testing and the use of emission factors are the most viable options for
estimating releases and other waste management activity quantities from dryers. This is because
emissions associated with dryers are usually generated during the drying process (either evolved
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from the raw materials or coincidentally manufactured from combustion of the fuel) and a mass
balance approach is typically not practical. If controlled emission rates are unknown, the
quantity of EPCRA Section 313 chemicals and chemical categories treated on-site may be
calculated using published or vendor provided control efficiency information.
Please refer to Appendix C for a summary of currently available emission factors
for presswood and laminated wood products processes. The following example presents the
steps to estimate stack emissions of formaldehyde from the drying of poplar veneer.
Example - Dryers (Stack Emissions of Formaldehyde)
Your facility manufactures plywood using poplar veneer. In 1999, your facility processed 12,900 square feet per
hour of 3/8 inch veneer through a veneer dryer (indirect heat) and the dryer was in operation 40 hours per week
during 50 weeks. The formaldehyde emissions can be calculated using AP-42 emission factors. The AP-42
emission factor for this operation is 0.0023 pounds formaldehyde per thousand square feet veneer.
Step 1. Calculate the total hours of operation over the course of the year.
Total hours of operation = (50 weeks/year) x (40 hours/week)
= 2,000 hours per year
Step 2. Calculate the total quantity of veneer dried in the dryer.
Quantity of veneer = (12,900 square feet/hr) x (2,000 hours per year)
= 25,800,000 square feet/year
Step 3. Estimate formaldehyde emissions.
Formaldehyde emissions = (25,800,000 square feet/year) x (0.0023 pounds formaldehyde/1,000
square feet)
= 59.34 pounds formaldehyde/year
This quantity would be reported in Part II, Section 5.2 (stack or point air emissions) and included in Section 8.1
(quantity released) of the FormR.
Please note that if the emission factors used to estimate releases are developed from on-site testing data, they
should be coded as "engineering judgement" on the Form R.
As discussed under Step 3, if an air pollution control device is used, you are required to report the quantity of the
EPCRA Section 313 chemical or chemical category that is destroyed and/or removed from the waste stream in
Sections 6, 7, and 8 as appropriate. A detailed example for estimating and reporting quantities sent to on-site
treatment have been presented in Section 4.1.3.h.
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4.2.3 Presses
Presses are used to compress wood products to the desired density, and to provide
sufficient contact time and pressure to allow resins and adhesives to fix. Typical adhesives (or
glues) used in this industry include thermosetting urea-formaldehyde (UF), phenol-formaldehyde
(PF), and isocyanate resins. UF resins are typically used in hardwood plywood, MDF, and
particleboard manufacture. PF resins are typically used in softwood plywood and wet/dry
process hardboard. A combination of PF and isocyanate resins are typically used in oriented
strandboard and waferboard. PF and UF resins are also used in the manufacture of particleboard.
Hardboard and engineered lumber plants primarily use PF, phenol-resorcinol-formaldehyde
(PRF), or MDI resin. Fiberboard and wet/dry hardboard plants use starch, asphalt, or linseed oil
as a binder.
These resins may be combined with a variety of additives prior to application to
the wood. The additives include extenders, fillers, catalysts, and caustic solutions. Most
additives, however, do not contain EPCRA Section 313 chemicals or chemical categories.
Step 1: Prepare Process Flow Diagram
U.S. EPA recommends you prepare a site-specific process flow diagram to help
identify all potential sources and types of chemical and chemical category release and other
waste management activities. A typical flow diagram is presented in Figure 4-5.
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Stack Air
Resins/Adhesives
Dry Wood
Fugitive Air
Pressing
Product
Container
Residue
Figure 4-5. Process Flow Diagram - Pressing
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Potential sources of EPCRA Section 313 chemicals and chemical categories from
press operations include building vents (if uncontrolled), control device stacks, and "empty"
containers of resins, adhesives, and additives that may contain residual EPCRA Section 313
chemicals or chemical categories.
Factors that affect press emissions include resin composition, wood species, press
temperature, and press cycle time. When the press opens, vapors that may include resin
ingredients such as formaldehyde, phenol, methyl diisocyanate (MDI), and other EPCRA
Section 313 chemicals and chemical categories are released to the atmosphere through roof vents
above the press. Board coolers (where the wood product may be sent following the press
operations) may also be a source of releases.
Formaldehyde emitted through press vents during pressing and board cooling
operations is dependent upon the amount of excess (free) formaldehyde in the resin as well as
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press temperature and cycle time. Small quantities of excess formaldehyde are often present in
resin mixtures to ensure adequate resin strength.
Step 3: Identify Release and Other Waste Management Activity Types
Common release and other waste management activity types from press
operations include fugitive emissions from board coolers and stack emissions from control
devices and press vents, on-site treatment from control devices, and off-site transfer of "empty"
containers of resins, adhesives, and additives. Typical release and other waste management
activities and associated EPCRA Section 313 chemicals and chemical categories are:
Typical Type of Release/Waste Management
Activity
Stack Air
Fugitive Air
On-Site Treatment (control devices)
Off-Site Transfer (residual in empty containers)
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Methanol, Formaldehyde, Phenol, Diisocyanates
Methanol, Formaldehyde, Phenol, Diisocyanates
Methanol, Formaldehyde, Phenol, Diisocyanates
Formaldehyde, Phenol, Diisocyanates
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Mass balances, stack tests, control device efficiencies, and emission factors may
be used to estimate release and other waste management activity quantities from press operations
(including board coolers if used). Mass balances may be appropriate for estimating
formaldehyde releases if the amount of formaldehyde in the resin is known, as well as for
estimating releases of solvents used as additives. It should be noted that the mass balance
approach is most suitable if all the different fates of the chemical being estimated are known.
Quantities of EPCRA Section 313 chemicals and chemical categories in "empty"
containers can be estimated using established residue factors based on the method of cleaning or
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draining of the container (see the discussion in Section 4.1.3.g including the common error,
Table 4-1, and the corresponding container residue example).
The following example illustrates the use of AP-42 emission factors to estimate
formaldehyde releases from a batch press and board cooler.
Example - Presses
Your facility manufactured 30,000,000 square feet of 3/4 inch particleboard in 1999. The process used is a batch
hot press followed by a board cooler. The formaldehyde emissions can be calculated from these operations using
AP-42 emission factors. The current AP-42 emission factors for formaldehyde from batch hot presses and board
coolers are 0.26 and 0.027 pounds per thousand square feet (3/4-inch basis), respectively. (Note: these emission
factors assume urea-formaldehyde resins are used.)
Annual emissions from the batch press = (30,000,000 square feet per year) x (0.26 pounds formaldehyde
per 1,000 square feet)
= 7,800 pounds formaldehyde per year
Annual emissions from the board cooler = (30,000,000 square feet per year) x (0.027 pounds per 1,000
square feet)
= 810 pounds formaldehyde per year
Total Annual formaldehyde emissions = 7,800 (Ibs/year) + 810 (Ibs/year)
= 8,610 Ibs/year
This quantity would be reported in Part II, Section 5.2 (stack or point air emissions) and included in Section 8.1
(quantity released) as appropriate. If an air pollution control device is used to reduce emissions, you should
recalculate the quantity released based on the device's efficiency and complete Part II, Sections 7 and 8.6 as
appropriate (see Section 4.1.3.hfor a detailed example of on-site treatment).
4.2.4 Finishing Operations
Finishing operations include any processes performed on the wood products
subsequent to the pressing and cooling operations described above. Finishing operations may
include sanding, cutting, trimming, painting, filling, and coating. Wood residue from these
operations is typically collected for energy recovery via combustion in on-site boilers to heat
dryers or presses.
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Step 1: Prepare Process Flow Diagram
U.S. EPA recommends you prepare a site-specific process flow diagram to help
identify all potential sources and types of toxic chemical and chemical category release and other
waste management activities. Your diagram would include all of the applicable finishing
operations discussed above. A typical flow diagram is presented in Figure 4-6.
Stack Air
Coating, Fillers, sealers
j
Fugitive Air
t
Wood Product
(from pressing)
Finishing
operation
Finished Wood Product
Container Residue
(on-site or off-site energy recovery, recycle, treatment, or disposal)
Figure 4-6. Process Flow Diagram - Finishing Operations
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The most common potential source of EPCRA Section 313 chemicals and
chemical categories from finishing operations are trimming and sawdust residue, evaporation of
solvents used in coatings and other surface protectants, and container residues (from "empty"
containers of finishing additives).
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Step 3: Identify Release and Other Waste Management Activity Types
Release and other waste management activity types from finishing operations
include fugitive and stack emissions from the evaporation of volatile coating solvents and
cleaning compounds, and off-site transfer of drum residues (to energy recovery, recycle,
treatment, or disposal). If wood residue is collected and burned on-site for heat recovery (such
as for heating of direct-fired dryers), then EPCRA Section 313 chemicals and chemical
categories in the residue should be considered for on-site energy recovery. If this residue is
transferred off-site it should be reported as a waste that is managed to energy recovery, recycle,
treatment, or disposal as appropriate (40 CFR § 372.85(b)(16)(ii)(B)). Typical release and other
waste management activities and corresponding EPCRA Section 313 chemicals and chemical
categories are:
Typical Type of Release/Waste Management
Activity
Stack Air
Fugitive Air
On-Site Energy Recovery
Off-Site Transfer (wood residue and residual
chemicals in empty containers)
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Xylene, Toluene, methyl ethyl ketone (MEK), Glycol Ethers
Xylene, Toluene, MEK, Glycol Ethers
Xylene, Toluene, MEK, Glycol Ethers
Xylene, Toluene, MEK, Glycol Ethers
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Emission factors, mass balances, and source testing may be used to estimate
releases and other waste management quantities from finishing operations.
Quantities of EPCRA Section 313 chemicals and chemical categories in "empty"
containers can be estimated using established residue factors based on the method of cleaning or
draining of the container (see the discussion in Section 4.1.3.g including the Common Error,
Table 4-1, and the corresponding container residue example).
4-53
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The following example illustrates the use of emission factors to estimate the
uncontrolled emissions from sanding operations.
Example - Finishing Operations (Fugitive Methanol Emissions from Sanding)
Your facility manufactured 121,000,000 square feet of medium density fiberboard in 1999. As part of the
finishing process, both the top and bottom of each board is sanded to produce a uniform surface. Methanol
emissions from the sanding operations can be calculated using the site-calculated emission factor of 0.003
pounds per thousand square feet of fiberboard (see Table C-13, Appendix C).
Annual Methanol emissions = (121,000,000 square feet/year) x (0.003 pounds methanol per 1,000 square
feet)
= 363 pounds methanol per year
4.2.5 Combustion
If the fuel that is used for your boiler or dryer contains EPCRA Section 313
chemicals or chemical categories, or if these toxic chemicals are coincidentally manufactured
during the combustion of the fuel, you must conduct the appropriate threshold and release
calculations (40 CFR § 372.3). Natural gas is not expected to contain or generate EPCRA
Section 313 chemicals or chemical categories and coal is not typically used. However, if fuel oil
or wood is used you should consider it as a potential source of EPCRA Section 313 chemicals or
chemical categories and calculate the amount of each chemical manufactured and/or released.
U.S. EPA has analyzed various fuels used for boilers in Section 313 Emergency
Planning and Community Right-to-Know-Act Guidance for Electricity Generating Facilities
(EPA 745-B-99-003). A summary of that analysis is presented here. Please refer to the detailed
discussion in the above referenced document for further information.
In general, coal and fuel oils typically contain many organic chemicals along with
metals and metal compounds. Combustion of these fuels results in the coincidental manufacture
of metal compounds. Formaldehyde is also coincidentally manufactured if fuel oil is used.
Wood combustion may also result in the coincidental manufacture of EPCRA Section 313
chemicals and chemical categories (refer to Section 1.6 of AP-42).
4-54
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To estimate the total quantity of all metal compounds that are coincidentally
manufactured, U.S. EPA assumes the metal in the fuel is converted to the metal oxide. A
balanced stoichiometric equation from the metal to the metal oxide is then used to determine the
mass of oxide generated. This quantity can be used for threshold determinations.
Based on the typical concentration of metal found in fuel oil and the
stoichiometric conversion to the appropriate metal oxide, the approximate quantity of fuel oil
required to exceed the manufacturing threshold can be calculated. This information has been
reproduced in Table 4-4.
4-55
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Table 4-4
Concentrations of Section 313 Constituents and Their Compounds Found in
No. 6 Fuel Oil and Tons of Oil Needed to Manufacture 25,000 Ibs.
Fuel Oil Constituents
Manganese/MnO2
Nickel/NiO
Lead/PbO2
Cadmium/CdO
Copper/CuO
Cobalt/CoO
Selenium/SeO2
Beryllium
Antimony
Arsenic/As2O5
Mercury /HgO
Chromium/CrO3
Silver/AgO
Concentration
(micrograms/gram)
50.0
37.5
1.0
0.3
0.3
0.15
0.09
0.08
0.01
0.058
0.005
0.0045
0.0002
Compound
Concentration
(micrograms/gram)
79.1
47.7
1.2
0.3
0.4
0.19
0.13
0.22
0.01
0.088
0.005
0.009
0.0002
Approximate Tons of
Fuel Oil Required to
Manufacture 25,000 Ibs.
of Metal Compound
(assuming 8 Ibs./gallon
as the density for No. 6
Fuel Oil)
158,000
262,000
10,831,000
36,500,000
33,291,000
65,790,000
98,870,000
56,277,000
944,149,000
140,503,000
2,301,136,000
1,444,539,000
53,571,429,000
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix E,
Table E-6.
If a threshold is exceeded you must estimate the quantity of metal that is released
from the boiler (40 CFR § 372.30(a)). Table 4-5 presents emission factors for each metal from
combustion of number 6 fuel oil. Note that while the entire mass of metal compound applies to
threshold calculations, only the mass of the parent metal must be reported for release and other
waste management estimates (40 CFR § 372.25(h)).
4-56
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Table 4-5
Section 313 Metal Emission Factors for Fuel Combustion
No. 6 Fuel Oil Combustion3
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Chromium (VI)
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Average Emission Factor1" (lb/103
Gal)
5.25E-03
1.32E-03
2.57E-03
2.78E-05
3.98E-04
8.45E-04
2.48E-04
6.02E-03
1.76E-03
1.51E-03
3.00E-03
1.13E-04
8.45E-02
6.83E-04
TJata are for residual oil fired boilers, Source Classification Codes (SCCs) 1-01-004-01/04.
bTo convert from lb/103 gal to kg/103 L, multiply by 0.12.
Table 4-6 presents the approximate quantity of fuel oil required to exceed the
manufacturing threshold for formaldehyde and an emission factor is provided for industrial
boilers and furnaces.
4-57
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Table 4-6
Emission Factor and Tons of No. 6 Fuel Oil Needed to Manufacture 25,000
Pounds of Formaldehyde
Section 313 Chemical
Formaldehyde
Emission Factor (Ibs./ton)
0.00075a
Approx. Tons of Fuel Oil Needed
to Manufacture 25,000 Ibs. Of
Formaldehyde
33,333,000
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix E,
Table E-10.
"Emission factor is an average range of data for industrial oil-fired boilers and furnaces. Note that the document
cautions that "Since formaldehyde is a product of incomplete combustion, it is likely that modern units, particularly
for utilities, would have lower emissions than those in these tests which date to the mid-1960s. Additional
emissions testing is clearly needed to establish reliable boiler emission factors for formaldehyde."
4-58
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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.
Activity
Chemical use, subcategories 2-11 to 2-18, 3-8 to 3-12
Exemption (see Exemptions)
Thresholds (see Threshold)
Air emissions
Fugitive 2-13, Chapter 4, B-4
Stack or point source Chapter 4, B-l to B-3
Article exemption (see Exemptions)
Automated toxics release inventory reporting software (ATRS) 2-17, A-1, A-2
Chemical-specific
Acid aerosols 3-6, 3-7, 3-17, 4-46, 4-47, A-5
Ammonia 2-12, 3-5, 3-6, 3-21, 3-22, 4-22, A-5
Metals/metal compounds 3-6, 3-17, 4-7, 4-11 to 4-17, 4-31, 4-55, 4-56
Nitrate compounds 2-12, 3-5, 3-7, 4-22, A-6
Zinc 3-6
Combustion 3-17, 3-20, 3-21, Chapter 4
Common errors
Assuming a threshold is exceeded 3-24
Direct reuse vs recycling 4-17
Double counting 4-19
Exempt activities 3-14
Formaldehyde in Waste Products 2-13
Mass balance 4-23
Mixture components 3-4
Shipping container residue 4-8
Threshold determination for recirculation 3-9
Treatment efficiencies 4-21
Zero release and other waste management quantities 3-24
Container residue 4-3, 4-8 to 4-11, 4-52 to 4-54
Example, container residue 4-8 to 4-11
De minimis (see Exemptions)
Example, de minimis 3-15
Example, de minimis concentration ranges 3-16
Disposal
Land, on-site 4-6 to 4-7
Land, off-site 4-7 to 4-8, 4-11 to 4-12, 4-31
Documentation (see Recordkeeping)
Double counting 4-6, 4-19
Common error, double counting 4-19
Index-i
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INDEX (Continued)
Emission factors Chapter 4, B-6
Example, emission factors 4-25, B-6
Employee equivalent calculation 2-8 to 2-9
Example, calculating employees 2-9
Energy recovery (see Combustion for energy recovery)
Engineering calculation 4-20, 4-24 to 4-27, B-l
Example, engineering calculations 4-27
EPCRA hotline 1-2, 1-3, 1-5, 2-9, 2-16
Establishment 2-1, 2-5 to 2-7
Example, multiple establishments 2-2
Example, primary SIC code 2-7
Examples
Article exemption 3-18
Toxic chemicals in process water 3-21
Container residue 4-11
De minimis 3-15
De minimis concentration ranges 3-16
Dryers 4-48
Emission factors 4-25, B-6
Employee equivalent calculation 2-9
Engineering calculation 4-27
Finishing operations 4-55
Form A certification threshold 2-18
Laboratory exemption 3-19
Mass balance 4-23
Monitoring data 4-21
Motor vehicle exemption 3-20
Multiple establishments 2-2
On-site waste treatment 4-13
Personal use exemption 3-20
Presses 4-52
Primary SIC code 2-7
Process equipment chemical use 3-21
Relabeling 2-13
Stack monitoring B-l
Threshold determination 3-8
Threshold worksheet 3-25
Treatment of wastes from off site 2-13
Xylene isomers 3-9
Exempt activities 2-15, 3-1, 3-8, 3-13 to 3-21, 3-23, 3-25
Common error, exempt activities 3-14
Exemptions 3-12
Activity-related 3-19
Article 3-17
Index-ii
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INDEX (Continued)
De minimis 3-14
Drawn from environment 3-21
Evaluation of 3-12
Facility-related 3-19
Grounds maintenance 3-20
Janitorial 3-20
Laboratory 3-19
Motor vehicle 3-20
Personal use, example 3-20
Structural components 3-20
Facility
Auxiliary facility 2-6
Covered facility 2-1, 2-6, 2-7
Multi-establishment facilities (see Establishments)
Pilot plant 2-7
Facility-related exemption (see Exemption)
Form A certification 1-3 to 1-5, 2-1, 2-2, 2-16 to 2-21, 3-20 to 3-24
Example Form A certification threshold 2-18
Form R 1-3 to 1-5, 2-1, 2-2, 2-6, 2-16 to 2-21, 3-22 to 3-24, Chapter 4
Impurity 2-12, 3-10, 3-14, 3-15
Laboratory exemption (see Exemption)
Manufacture/Manufacturing 1-3, 2-3 to 2-6, 2-8, 2-12, 3-5, 3-9
Byproduct 2-12, 3-10, 3-16, 3-17, 4-3
Coincidental manufacture 2-12, 3-17, 3-20, 3-21, 4-54, 4-55
Manufacturing subcategories 3-10
Mass balance 4-19 to 4-23, 4-48, 4-51, 4-54
Example, mass balance 4-22
Common error, otherwise used toxic chemicals (see otherwise use) 4-22
Metal compound (see Chemical-specific)
Methods (see Reportable amount estimate methods)
Mixture 2-2, 2-9, 2-12, 2-13, 3-1 to 3-4, 3-9 to 3-17, 3-25, to 3-27, 4-50, A-6
Monitoring data 2-21, 4-14, 4-18 to 4-20, 4-22, 4-26, B-l
Example, monitoring data 4-20
Motor vehicle exemption (see Exemption)
MSDS 2-21, 3-3, 3-4, 3-13, 3-16, 3-25, 4-19
Otherwise use Chapter 2, Chapter 3, 4-21, 4-22
Common error, mass balance for otherwise used toxic chemicals 4-21
Otherwise use subcategories 3-12
Owner/operator 1-4
Penalties 1-5
Pilot plant (see Facility)
Point source (see Air emissions)
POTW 4-3 to 4-30
Process/processing 1-3, 1-4, Chapter 2, Chapter 3, 4-7, 4-15
Index-iii
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INDEX (Continued)
Process equipment 3-20, 3-21
Example, process equipment chemical use 3-21
Process water 3-21
Example, toxic chemicals in process water 3-21
Processing subcategories 3-11
Qualifiers 2-5, 3-4 to 3-6
Recycling 2-18, 3-9, 3-21, 3-23, 4-3, 4-7, 4-13 to 4-17, 4-21, 4-27
Off-site 4-7, 4-15
On-site 4-13, 4-15
Relabeling, example 2-13
Release Chapter 4
Accidental 4-3, 4-6
Estimates (steps to calculate) Chapter 4
Sources Chapter 4
Types Chapter 4
Remediation 2-21 to 2-23, 4-17
Repackaging 2-13, 3-11
Reportable amount estimation methods 1-4, 2-16 to 2-21
Emission factors Chapter 4
Engineering calculations Chapter 4
Mass balance Chapter 4
Monitoring data/records Chapter 4
Reporting criteria 1-3, 3-24
Reuse 2-3, 3-9, 3-18 to 3-23, 4-7, 4-16, 4-29
Standard Industrial Classification (SIC) 1-3, 2-2 to 2-7
Primary SIC code 2-7
Supplier notification 2-16
Technically qualified individual 3-19
Threshold worksheet 2-21, 3-25 to 3-27
Thresholds 3-7
Common error, threshold determination 3-8
Example, threshold determination 3-7
Threshold determination Chapter 3, 3-20
Threshold worksheet 3-25
Total annual reportable amount (see Reportable amount)
Trade secret 1-4, 2-1, 2-19
Transfers Chapter 4
Treatment efficiency 4-10, 4-11, 4-19
Treatment for destruction
On-site 2-12, 2-13
Off-site 2-12, 2-13
TRI database 2-18
Waste management Chapter 4
Waste treatment (see Treatment for destruction)
Index-iv
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INDEX (Continued)
Common error, treatment efficiencies 4-19
Example, on-site waste treatment 4-11
Example, treatment of wastes from off site 2-13
Wastewater discharge 4-6, 4-38, 4-42, 4-45, 4-47, 4-56, B-7
Wastewater treatment 4-7, 4-11, 4-19 to 4-20, 4-43, 4-51, 4-57, 4-59
Index-v
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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 FR4500, February 16, 1988.
Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting
Year - See also Automated Toxics Release Inventory Reporting Software (ATRS) under Section
A.2, Internet Sites.
U.S. EPA publishes this document each year to provide current guidance for preparing the Form
R reports and Form A certification statements. 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 certification
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 (EPCRA^) and Section 112(f) 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: 1998 Version. (EPA 745-B-98-004).
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
document is intended for the exclusive use of federal facilities in complying with Sections 302,
A-l
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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.
Toxic Chemical Release Inventory - Data Quality Checks to Prevent Common Reporting Errors
on Form R/Form A Certification (EPA 745-R-98-012)
This is a compilation of Notices of Data Change, Significant Error, Noncompliance, or Technical
Error. It provides a listing of common errors found on the Form R reports submitted to U.S.
EPA. It also provides a discussion of the types of errors which result in each of the above
Notices as well as a list of Notice of Technical Error codes and descriptions.
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:
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/index. 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
TRI homepage: http://www.epa.gov/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.
Automated Toxics Release Inventory Reporting Software (ATRS):
http://www.epa.gov/atrs
This site provides access to the automated EPCRA Section 313 reporting forms
for electronic submittal of required data to U.S. EPA.
A-2
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Air CHIEF CD-ROM
http://www.epa.gov/ttn/chief/airchief.html
This site provides information on the Air CHIEF CD-ROM, contents, ordering
information, system requirements, and sources for additional information.
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/ap42e tc. 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.
WATER8/CHEMDAT8: http://www. epa.gov/ttn/chief/software.html#water8
WATERS is an analytical model for estimating compound-specific air emissions
from wastewater collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3
spreadsheet for estimating VOC emissions from TSDF processes.
A-3
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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 2001.
Chemical Distribution Facilities. January 1999 (EPA 745-B-99-005)
Coal Mining Facilities. January 1999 (EPA 745-B-99-002)
Coincidental Manufacture/Bv-Products (EPA 260-B-01-012)
Electricity Generating Facilities. January 1999 (EPA 745-B-99-003)
Estimating Releases and Waste Treatment Efficiencies (EPA260-F-01-004)
Federal Facilities. May 2000 (EPA-745-R-00-003)
Food Processors. September 1998 (EPA 745-R-98-011)
Formulation of Aqueous Solutions. March 1988 (EPA 560-4-88-004F)
Foundry Operations (EPA 260-B-01-009)
Leather Tanning and Finishing Industry. April 2000 (EPA 745-B-00-012)
Metal Mining Facilities. January 1999 (EPA 745-B-99-001)
Metal Working and Electroplating Operations. (EPA260-B-01-010)
Monofilament Fiber Manufacture (EPA 260-B-01-014)
Pulp. Paper, and Paperboard Production (EPA 260-B-01-015)
Petroleum Terminals and Bulk Storage Facilities. January 1999 (EPA 745-B-99-006)
Presswood & Laminated Wood Products Manufacturing (EPA 260-B-01-013)
Printing. Publishing and Packaging Industry. April 2000 (EPA 745-B-00-005)
RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities. January 1999 (EPA 745-B-99-
004)
Rubber and Plastics Manufacturing. April 2000 (EPA 745-B-00-017)
A-4
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Semiconductor Manufacture. July 1999 (EPA 745-R-99-007)
Smelting Operations (EPA 260-B-01-011)
Spray Application and Electrodeposition of Organic Coatings. December 1998 (EPA 745-B-99-
014)
Textile Processing Industry. April 200 (EPA 745-B-00-008)
Welding Operations (EPA 260-B-01-007)
Wood Preserving Operations (EPA 260-B-01-008)
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. December 2000 (EPA 745-R-00-005)
Emergency Planning and Community Right-to-Know EPCRA Section 313: List of Toxic
Chemicals within the Chlorophenols Category. June 1999 (EPA 745-B-99-013)
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting Toxic Chemicals within Dioxin and Dioxin-like Compounds Category. December
2000 (EPA 745-B-00-021)
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! March 1998 (EPA-745-R-97-007)
Guidance for Reporting Hydrochloric Acid (acid aerosols including mists, vapors, gas, fog, and
other airborne forms of any particle size). December 1999 (EPA-745-B-99-014)
Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and
Guidance for Reporting. December 2000 (EPA 745-R-00-004)
Toxic Release Inventory: List of Toxic Chemicals within the Nicotine and Salts Category. June
1999(EPA745-R-99-010)
A-5
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Toxic Release Inventory: List of Toxic Chemicals within the Poly chlorinated Alkanes Category
and Guidance for Reporting. June 1999 (EPA 745-B-99-023)
Toxic Release Inventory: List of Toxic Chemicals within the Strychnine and Salts Category.
June 1999 (EPA 745-R-99-011)
Toxic Release Inventory List of Toxic of Chemicals within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting. December 2000 (EPA 745-R-00-006)
Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid.
Salts and Esters Category and List of Mixtures that Contain the Individually Listed Chemicals
Maneb. Metiram. Nabam and Zineb. December 2000 (EPA 745-B-00-018)
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
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting: Mercury and Mercury Compounds Category. June 2001 (EPA 745-B-01-OOX)
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting: Pesticides and Other Persistent Bioaccumulative Toxic (PBT) Chemicals. June 2001
(EPA745-B-01-OOX)
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting: Polycyclic Aromatic Compounds Category. June 2001 (EPA 745-B-01-OOX)
Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category. June 1999 (EPA
745-B-99-011)
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.
Kirk Othmer - Encyclopedia of Chemical Technology. Latest Edition, John Wiley & Sons, New
York.
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.
A-6
-------
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
-------
Appendix B
BASIC CALCULATION TECHNIQUES
-------
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) x [(11) x (internal stack diameter)2/4)]
Volumetric flow = (8.0 m/s) x [(71) x (0.3 m)2/4] = 0.6 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.
(Note: If the toluene concentration is on a wet gas basis, no correction is
necessary for moisture content.)
B-l
-------
Dry volumetric flow = (Volumetric flow) x (1-fraction water vapor)
Dry volumetric flow = (0.6 m3/s) x (1-0.10) = 0.5 m3/s
Step 3. Convert ppmv to mg/m3.
•• ppmv is defined as one part of a chemical in 106 parts of gas (1.0 m3/106
m3).
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 237 K and 1 atm is 22.4 L/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.
V RT
Molar volume • •— • •
For the example, the stack conditions are 80° C (353 K) and atmospheric pressure
(1 atm).
Molar volume = I 0.082057 L atm I x (353 K)/(latm)
I mole-Kj
= 29.0 L/mole
The conversion of ppmv to mg/m3 can now be calculated.
—- = (concentration of chemical, ppmv) x x (MW)
m3 J V molar volume of gasj
B-2
-------
Using the example, the concentration of toluene is calculated as follows:
0.1 m3
106 m3
x jnolej ,92^ t L \ x 1.000 ^, = 0.3 mg/m
U9-OLJ ( mole ) 10'3 m3 ( 1 g '
3
Step 4. Calculate air releases.
Air releases are calculated as follows:
Air Release=(volumetric flow, m3/s) x (concentration, mg/m3) x (operating time, s/yr)
The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year.
*9L
Operating time = 8 -- x 5 - x 52 = 2,080 hr/yr
day) ( week) ( yr )
Air Release = (0.5 m3/s) x (0.3 mg/m3) x | _l x 2>080 _»»
'
hr j V yr J ^ 454 gj I, 1,000 mg
• *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 that 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 pressure needs to be performed. A conservative
estimation of benzene fugitive releases could be calculated as follows:
Air Release =
(ventilation flow rate, ft3/min) x (operating time, min/yr) x
(concentration of chemical, ppmv) x (vapor density of chemical, Ib/ft3)
Benzene releases per year would be calculated as follows:
20,000 ft-
mrn
60 min
- X
hr J
24 hr1
-
day ,
330 day
0.1 ft3 benzene
106 ft3 air J
0.2 Ib
ft3
•190 Ib/yr 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.
PA ~
where:
P
X
X
A,L
•A,G
PT
Vapor pressure of pure liquid chemical A;
Mole fraction of chemical A in solution;
Mole fraction of chemical A in the gas phase;
Partial pressure of chemical A in the gas phase; and
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 mm of Hg (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.
Step 1: Calculate the mole fraction of o-xylene in the liquid solution.
B-4
-------
X
A,L
wt fraction A
MWA
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/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 P»
where:
XA,L
p..
PT
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.
•[0.09]
0.19 psia
14.7 psia
•0.001
Step 3: Calculate releases using Raoult's Law.
B-5
-------
Emissions •'(XAG) x (APR) x (t) x (MWA) x I J_ J
where:
Emissions = Air release of pollutant A, g-A/yr;
XA G = Mole fraction of chemical A in gas phase;
APR = 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 (22.4 L/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.
Emissions = (0.001) x
( 2.83m3>| ( 250 day] ( 24 tir^l ( 60 min^ ( mole } ( 106.17 g] ( L \
^ min j (, yr ) ( day ) ( hr ) (22AL) ( mole ) ( 10'?m3J
= 4.8 x 106g/yr
The emission of o-xylene is calculated as shown below.
Emissions • »(4.8 x 106 g/yr) x b • • 10,570 Ib/yr of o» xylene
I 454 g)
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) x (AU) x (QT)
B-6
-------
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.
OT = Operating time, hr/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 1M f 300 gal 1 ( 2,000 hr I ., , ,, , ,. ,. , , , ,
AE • • x §_ x -i . .36.6 Ib/yr of formaldehyde
( 103 gal J I 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) x (concentration of cadmium, Ib/lb)
(density of paint waste, Ib/gal)
5 drums 1 f 55 gal) f 9.5 Ib | f 51b Cd ) 101 ,,, ,, , .
lvl ° i y i ivi ' ''131 Ib/yr of cadmium
X
^ yr ) \ drum ) ( gal ) ( lOOlb 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, flow rate-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
-------
Yearly Quarter Discharge Flow Rate
Sample Number (106 gal/daV) Total Silver
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) x (silver concentration)
TJ. + ~ ^ ( 10 tig ^
First Quarter: — ^
IK \ f Hb 1 ( 3.785 L\ ( 0.5 x 106gaf
°— - - - °—
106|igJ 1454§J V gal H daY
= 0.04 Ib/day of silver
The amount of silver discharged during each of the other three monitoring events
was similarly determined to be:
0.05 Ib/day; 0.02 Ib/day, and 0.005 Ib/day.
For the last data point the concentration of silver was reported by the laboratory to
be less than the detection limit of 3 |ig/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:
Ib/day "0.03 Ib/day
0.04»€.Q5'€.02' €.005\
)
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 day/yr) (0.03 Ib/day) = 10.5 Ib of silver/yr
-------
Appendix C
PRESSWOOD/LAMINATED WOOD PRODUCTS EMISSION FACTORS
-------
Table C-l
Emission Factors for Plywood Veneer Dryers3
Source
Poplar (SCC 3-07-007-69)
Emission Control
None
Formaldehyde
0.0023
Emission Factor
Rating
E
"Reference = AP-42.
Factors represent uncontrolled emissions unless noted. SCC = Source Classification Code. All emission factors in
units of pounds per thousand square feet of 3/8-inch thick veneer (Ib/MSF 3/8). One Ib/MSF 3/8 = 0.5 kg/m3.
Table C-2
Emission Factors for Plywood Presses - Formaldehyde"
Source
Plywood press
UF resin
(SCC 3-07-007-81)
UF resin, wet scrubber
(SCC 3-07-007-81)
Formaldehyde
0.0042
0.0025
Emission Factor
Rating
E
E
"Reference = AP-42.
SCC = Source Classification Code. Emission factors units are pounds per thousand square feet
of 3/8-inch thick panel (Ib/MSF 3/8). One Ib/MSF 3/8 = 0.5 kg/m3. UF = urea-formaldehyde.
C-l
-------
Table C-3
Emission Factors for OSB Dryers3
Source
Emission
Control
Device15
CASRNC
Pollutant
Emission
Factor
Emission
Factor
Rating
Rotary dryer, direct wood-fired
Unspecified pines
(SCC 3-07-010-01)
Aspen
(SCC 3-07-010-08)
Hardwoods
(SCC 3-07-010-10)
None
RTO
None
None
RTO
50-00-0
50-00-0
50-00-0
50-00-0
71-43-2
50-32-8
108-95-2
50-00-0
Formaldehyde
Formaldehyde
Formaldehyde
Formaldehyde
Benzene
Benzo-a-pyrene
Phenol
Formaldehyde
0.067
0.034
0.11
0.084
0.0016
0.0000030
0.0050
0.017
D
E
E
D
E
E
E
E
Rotary dryer, direct natural gas-fired
Hardwoods
(SCC 3-07-010-20)
None
50-00-0
Formaldehyde
0.036
E
"Reference = AP-42.
Emission factor units are pounds of pollutant per oven-dried ton of wood material out of dryer (Ib/ODT). One
Ib/ODT = 0.5 kg/Mg (oven-dried). Factors represent uncontrolled emissions unless otherwise noted. SCC = Source
Classification Code.
C-2
-------
Table C-4
Emission Factors for OSB Presses3
Source"
Hot press, PF resin
(SCC 3-07-010-53)
Hot press, MDI resin
(SCC 3-07-010-55)
Hot press, PF/MDI resins
(SCC 3-07-010-57)
Emission
Control
Device0
None
None
None
RTO
CASRN"
50-00-0
91-20-3
108-95-2
50-00-0
101-68-8
50-00-0
101-68-8
108-95-2
50-00-0
101-68-8
108-95-2
Pollutant
Formaldehyde
Naphthalene
Phenol
Formaldehyde
MDI
Formaldehyde
MDI
Phenol
Formaldehyde
MDI
Phenol
Emission
Factor
0.043
0.0030
0.053
0.064
0.0017
0.063
0.0021
0.019
0.0043
0.000078
0.0026
Emission
Factor
Rating
E
E
E
E
E
D
D
D
E
E
E
"Reference = AP-42.
Emission factors units are pounds of pollutant per thousand square feet of 3/8-inch thick panel (Ib/MSF 3/8). One
Ib/MSF 3/8 = 0.5 kg/m3. Factors represent uncontrolled emissions unless otherwise noted. SCC = Source
Classification Code.
bPF = phenol formaldehyde; MDI - methylene diphenyl diisocyanate; PF/MDI - PF resin in surface layers, MDI
resin in core layers.
GEmission control device: RTO = regenerative thermal oxidizer.
dCASRN = Chemistry Abstracts Service Registry Number.
C-2
-------
Table C-5
Emission Factors for Particleboard Dryers3
Source
Rotary dryer, direct wood-fired
Southern yellow pine
(SCC 3-07-006-06)
Rotary dryer, direct wood-fired,
unspecified pines0, 730« F inlet air
(SCC 3-07-006-02)
CASRN"
50-00-0
77-55-6
95-63-6
5779-94-2
108-10-1
101-77-9
80-56-8
10482-56-1
75-07-0
67-64-1
98-86-2
107-02-8
107-13-1
127-91-3
100-52-7
71-43-2
92-52-4
117-81-7
74-83-9
75-15-0
56-23-5
74-87-3
98-82-8
84-74-2
100-41-4
50-00-0
66-25-1
123-31-9
590-86-3
108-38-3,
106-42-3
78-93-3
75-09-2
110-54-3
98-95-3
95-47-6
99-87-6
100-42-5
Pollutant
Formaldehyde
1,1,1 -Trichloroethane
1,2,4-Trimethyl benzene
2, 5 -Dimethyl benzaldehyde
4-Methyl-2-pentanone
4,4-Methylene dianiline
Alpha pinene
Alpha terpeneol
Acetaldehyde
Acetone
Acetophenone
Acrolein
Acrylonitrile
Beta pinene
Benzaldehyde
Benzene
Biphenyl
Bis-(2-ethylhexyl phthalate)
Bromomethane
Butylbenzyl phthalate
Butyladehyde
Carbon disulfide
Carbon tetrachloride
Chloromethane
Cumene
Di-n-butyl phthalate
Dimethyl sulfide
Ethyl benzene
Formaldehyde
Hexaldehyde
Hydroquinone
Isovaleraldehyde
m,p-Xylene
m-Tolualdehyde
Methyl ethyl ketone
Methylene chloride
n-Hexane
Nitrobenzen
o-Xylene
p-Cymene
Styrene
Trans 1,4-dichlorobutene
Emission
Factor
0.021
1.2E-05
9.0E-05
3.3E-05
8.1E-05
3.3E-05
0.46
0.066
0.010
0.0079
6.4E-05
0.0033
8.9E-05
0.16
0.0026
0.00022
3.9E-05
0.00032
2.8E-05
1.4E-05
0.0031
1.8E-05
1.2E-05
0.00011
6.9E-05
2.3E-05
1.4E-05
3.8E-06
0.030
0.016
6.0E-05
0.00052
0.00011
0.00035
0.0013
0.00066
2.6E.05
1.7E-05
1.4E-05
0.0062
0.00012
2.4E-05
Emission
Factor Rating
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
C-4
-------
Table C-5 (Continued)
Source
Rotary dryer, direct wood-fired,
unspecified pines0, 730« F inlet air
(SCC 3-07-006-02) (cont.)
Rotary dryer, direct wood-fired,
unspecified pines0, 900 • F inlet air
(SCC 3-07-006-04)
CASRN"
108-88-3
110-64-3
108-05-4
5779.94-2
80-56-8
10482-56-1
75-07-0
67-64-1
107-02-8
127-91-3
100-52-7
67-66-3
123-73-9
98-82-8
50-00-0
66-25-1
590-86-3
108-38-3,
106-42-3
78-93-3
75-09-2
529-20-4
95-47-6
99-87-6
104-87-0
123-38-6
100-42-5
108-88-3
110-64-3
Pollutant
Toluene
Valeraldehyde
Vinyl acetate
2,5 Dimethyl benzaldehyde
Alpha pinene
Alpha terpeneol
Acetaldehyde
Acetone
Acrolein
Beta pinene
Benzaldehyde
Butyl aldehyde
Chloroform
Crotonaldehyde
Cumene
Formaldehyde
Hexaldehyde
Isovaleraldehyde
m-, p-Xylene
Methyl ethyl ketone
Methylene chloride
n-Butyraldehyde
o-Tolualdehyde
o-Xylene
p-Cymene
p-Tolualdehyde
Propionaldehyde
Styrene
Toluene
Valderaldehyde
Emission
Factor
0.0017
0.0045
2.9E-05
0.0053
1.9
0.17
0.072
0.16
0.023
0.82
0.12
0.029
0.00010
0.010
0.0020
0.17
0.022
0.018
0.0076
0.0092
0.0022
0.030
0.011
0.00045
0.011
0.026
0.011
0.00036
0.021
0.014
Emission
Factor Rating
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
"Reference = AP-42.
Factors represent uncontrolled emissions. Emission factor units are pounds of pollutant per oven-dried ton of wood material
out of dryer (Ib/ODT). One Ib/ODT = 0.5 kg/Mg (oven-dried). SCC = Source Classification Code.
bCASRN = Chemistry Abstracts Service Registry Number.
°Unspecified pines = mixed pine species or the specific pine species processed were not reported.
C-5
-------
Table C-6
Emission Factors for Particleboard Presses and Board Coolers3
Source
Batch hot press, UF resin
(SCC 3-07-006-51)
Veneer hot press, UF resin
(SCC 3-07-020-21)
Board Cooler, UF resin
(SCC 3-07-006-61)
CASRN"
5779-94-2
75-07-0
67-64-1
107-02-8
100-52-7
123-73-9
50-00-0
66-25-1
590-86-3
78-93-3
80-56-8
127-91-3
123-38-6
108-88-3
110-64-3
71-55-6
75-07-0
50-00-0
66-25-1
78-93-3
50-00-0
75-07-0
67-64-1
107-02-8
100-52-7
123-73-9
66-25-1
590-86-3
78-93-3
110-62-3
Pollutant
2,5 Dimethyl benzaldehyde
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Butylaldehyde
Crotonaldehyde
Formaldehyde
Hexaldehyde
Isovaleraldehyde
Methyl ethyl ketone
a-Pinene
b-Pinene
Propionaldehyde
Toluene
Valderaldehyde
1,1,1 -Trichloroethane
Acetaldehyde
Butylaldehyde
Formaldehyde
Hexaldehyde
Methyl ethyl ketone
Formaldehyde
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Butylaldehyde
Crotonaldehyde
Hexaldehyde
Isolvaleraldehyde
Methyl ethyl ketone
Valeraldehyde
Emission
Factor
0.00032
0.014
0.013
0.0019
0.0018
0.0018
0.00050
0.26
0.045
0.0011
0.0014
0.00054
0.00011
7.2E-05
0.00047
0.0039
0.00022
9.9E-05
0.00014
0.0062
0.11
0.00028
0.027
0.0013
0.0020
0.00036
0.00042
0.00060
0.00029
0.0011
0.00040
0.00011
0.0015
Emission
Factor Rating
E
E
E
E
E
E
E
D
E
E
E
E
E
E
E
E
E
E
E
E
E
E
D
E
E
E
E
E
E
E
E
"Reference = AP-42.
Emission factors units are pounds of pollutant per thousand square feet of 3/4-inch thick panel (Ib/MSF 3/4. One
Ib/MSF 3/4= 0.26 kg/m3. Factors represent uncontrolled emissions. SCC = Source Classification Code. All data for
mills using urea-formaldehyde resins.
bCASRN = Chemistry Abstracts Service Registry Number.
C-6
-------
Table C-7
Emission Factors for Laminated Veneer Lumber (LVL) Press Emissions3
Pollutant
Acetaldehyde
Formaldehyde
Methanol
Propionaldehyde
Emission Factor Ib/MCF
5.1E-2
5.0E-2
3.1E+0
2.2E-2
"Reference - NCASI Technical Bulletin No. 769.
MCF = 1,000 cubic feet.
Table C-8
Emission Factors for Wood I-Joist Line Emissions3
Pollutant
Formaldehyde
Methanol
I-Beam Line Ib/MLF
1.8E-4
1.7E-2
"Reference - NCASI Technical Bulletin No. 769.
MLF = 1,000 cubic feet.
Table C-9
Emission Factors for MDF Dryers3
Source
Tube dryer, direct wood-fired
Hardwoods
(SCC 3-07-009-25)
Tube dryer, indirect heat
Hardwoods
(SCC 3-07-009-35)
CASRN"
50-00-0
50-00-0
75-07-0
Pollutant
Formaldehyde
Formaldehyde
Acetaldehyde
Emission
Factor
0.86
0.20
0.013
Emission
Factor
Rating
E
E
E
C-7
-------
Source
Mixed species0
(SCC 3-07-009-39)
CASRN"
50-00-0
5779-94-2
75-07-0
67-64-1
98-86-2
107-02-8
80-56-8
10482-56-1
100-52-7
117-81-7
127-91-3
74-87-3
123-73-9
84-74-2
66-25-1
540-84-1
590-86-3
78-93-3
75-09-2
91-20-3
110-54-3
529-20-4
108-95-2
123-38-6
99-87-6
104-87-0
75-69-4
110-62-3
Pollutant
Formaldehyde
2,5-Dimethyl benzaldehyde
Acetaldehyde
Acetone
Acetophenone
Acrolein
Alpha pinene
Alpha terpeneol
Benzaldehyde
Bis-(2-ethylhexyl phthalate)
Butylbenzyl phthalate
Butylaldehyde
Beta pinene
Chloromethane
Crotonaldehyde
Di-n-butyl phthalate
Hexaldehyde
Isooctane
Isovaleraldehyde
Methyl ethyl ketone
Methyl ene chloride
Napthalene
n-Hexane
o-Tolualdehyde
Phenol
Propionaldehyde
p-Cymene
p-Tolualdehyde
Trichlorofluoromethane
Valeraldehyde
Emission
Factor
1.4
3.8x ID'4
0.013
0.0025
2.4 x ID'4
0.0022
0.0062
0.0022
0.0026
2.7 x ID'4
2.4 x ID'4
0.0028
0.0064
0.0015
0.0019
1.8 x ID'4
0.0026
6.2 x ID'4
0.0019
0.0063
0.0029
6.6 x ID'4
0.0014
7.4 x ID'4
2.0 x ID'4
0.0011
1.9x ID'4
0.0036
0.0014
0.0021
Emission
Factor
Rating
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
E
"Reference = AP-42.
Factors represent uncontrolled emissions. SCC = Source Classification Code. All emission factors in units of pounds
per oven-dried ton of wood material out of dryer (Ib/ODT). One Ib/ODT = 0.5 kg/Mg (oven-dried).
bCASRN = Chemistry Abstracts Service Registry Number.
"Mixed species = 50 percent hardwood and 50 percent softwood.
-------
Table C-10
Emission Factors for MDF Tube Dryer Emissions3
Pollutant
Methanol
Emission Factor for Non-
Blowline Blend Dryers Ib/ODT
9.8E-1
Emission Factor for
Blowline Blend Dryers
Ib/ODT
9.3E-1
"Reference = NCASI Technical Bulletin No. 770.
ODT = Oven Dried Tons.
Table C-ll
Emission Factors for MDF Presses and Board Coolers3
Source
Batch hot press, UF resin
(SCC 3-07-009-60)
Continuous hot press, UF resin
(SCC 3-07-009-50)
Uncontrolled
RTO-controlled
CASRN"
5779.94.2
75-07-0
67-64-1
107-02-8
100-52-7
123-73-9
50-00-0
66-25-1
590-86-3
78-93-3
529-20-4
123-38-6
104-87-0
110-62-3
50-00-0
50-00-0
Pollutant
2,5-Dimethyl benzaldehyde
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Butylaldehyde
Crotonaldehyde
Formaldehyde
Hexaldehyde
Isovaleraldehyde
Methyl ethyl ketone
o-Tolualdehyde
Propionaldehyde
p-Tolualdehyde
Valeraldehyde
Formaldehyde
Formaldehyde
Emission
Factor
0.0025
0.0051
0.0031
0.0012
0.00055
0.0024
0.0011
0.30
0.0029
0.0014
0.00059
0.00070
0.00054
0.0010
0.0024
1.1
0.0091
Emission
Factor
Rating
E
E
E
E
E
E
E
D
E
E
E
E
E
E
E
E
E
C-9
-------
Table C-ll (Continued)
Source
MDF board cooler, UF resin
(SCC 3-07-009-71)
MDF board cooler, UF resin
(cont.)
CASRN"
5779-94-2
75-07-0
67-64-1
107-02-8
100-52-7
123-73-9
50-00-0
66-25-1
590-86-3
78-93-3
529-20-4
104-87-0
110-62-3
Pollutant
2,5-Dimethyl benzaldehyde
Acetaldehyde
Acetone
Acrolein
Benzaldehyde
Butylaldehyde
Crotonaldehyde
Formaldehyde
Hexaldehyde
Isovaleraldehyde
Methyl ethyl ketone
o-Tolualdehyde
p-Tolualdehyde
Valeraldehyde
Emission
Factor
0.00019
0.0010
0.0021
0.00022
9.9 xlO'5
0.0014
0.00026
0.11
0.00065
0.00025
0.00011
6.5 x ID'5
0.00017
0.00048
Emission
Factor
Rating
E
E
E
E
E
E
E
E
E
E
E
E
E
E
"Reference = AP-42.
Emission factors units are pounds of pollutant per thousand square feet of 3/4-inch thick panel (Ib/MSF 3/4. One
Ib/MSF 3/4= 0.26kg/m3. Factors represent uncontrolled emissions unless otherwise noted. SCC = Source Classification
Code. All data for mills using urea-formaldehyde resins.
bCASRN = Chemistry Abstracts Service Registry Number.
Table C-12
Emission Factors for MDF Press Emissions"
Pollutant
Methanol
Methyl isobutyl ketone
Phenol
Emission Factor Ib/MSF 3/4"
3.7E-1
3.0E-3
7.7E-3
"Reference = NCASI Technical Bulletin No. 770.
MSF = 1,000 square feet.
C-10
-------
Table C-13
Emission Factors for MDF Sanders3
Pollutant
Formaldehyde
Methanol
Phenol
Styrene
Emission Factor Ib/MSF
2.5E-3
2.7E-3
3.2E-3
2.4E-4
"Reference = NCASI Technical Bulletin No. 770.
MSF = 1,000 square feet.
Table C-14
Emission Factors for OSB Press Emissions"
Pollutant
Acetaldehyde
Methanol
Hardwood Press Ib/MSF
3/8"
6.5E-3
2.7E-1
Softwood Press Ib/MSF
3/8"
9.9E-3
3.5E-1
"Reference = NCASI Technical Bulletin No. 772.
MSF = 1,000 square feet.
C-ll
-------
Table C-15
Emission Factors for OSB Dryer Emissions (Southern Pine)3
Analyte
Acetaldehyde
Acrolein
Benzene
Formaldehyde
Methanol
Methyl ethyl ketone (MEK)
Phenol
Propionaldehyde
Toluene
Emission Factor Ib/ODT
1.1E-1
6.0E-2
6.6E-3
2.3E-1
l.OE-1
1.3E-3
1.5E-2
6.9E-3
1.5E-2
"Reference = NCASI Technical Bulletin No. 772.
ODT = oven dried tons.
Table C-16
Emission Factors for Particleboard Mill (Board Coolers)3
Analyte
Formaldehyde
Methanol
Methyl isobutyl ketone
Emission Factor Ib/MSF 3/4"
1.4E-2
8.5E-2
9.2E-4
"Reference = NCASI Technical Bulletin No. 771.
MSF = 1,000 square feet.
C-12
-------
Table C-17
Emission Factors for Uncontrolled Particleboard Batch Press3
Analyte
Benzene
Methanol
Methyl isobutyl ketone
Phenol
Emission Factor Ib/MSF 3/4"
1.5E-3
5.7E-1
5.5E-3
6.3E-3
"Reference = NCASI Technical Bulletin No. 771.
MSF = 1,000 square feet.
Table C-18
Emission Factors for Particleboard Rotary Dryer3
Analyte
Acetaldehyde
Acrolein
Benzene
Formaldehyde
Methanol
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone
Phenol
Propionaldehyde
Toluene
m,p-xylene
Southern Pine
Emission
Factors for
"Dry" Furnish
Ib/ODT
6.3E-3
1.9E-3
l.OE-2
9.6E-3
1.4E-3
2.3E-3
Mixed Western
Softwood
Emission Factors
Ib/ODT
2.8E-2
6.6E-3
2.8E-3
1.2E-1
4.3E-2
l.OE-2
1.8E-3
6.0E-3
7.7E-4
Mixed Northern
Hardwood and
Northern Pine
Emission Factors
Ib/ODT
1.1E-1
2.3E-2
7.5E-3
1.9E-1
7.3E-2
1.6E-2
4.0E-3
1.4E-2
l.OE-2
"Reference = NCASI Technical Bulletin No. 771.
ODT = oven dried tons.
C-13
-------
Table C-19
Emission Factors for Particleboard Refiner/Hammermill and Flaker3
Analyte
Methanol
Phenol
Emission Factor Ib/ODT
6.9E-3
1.1E-3
"Reference = NCASI Technical Bulletin No. 771.
ODT = oven dried tons.
C-14
-------
Appendix D
UNIT CONVERSION FACTORS
(From U.S. Coast Guard Commandant Instruction M. 16465.12A)
-------
CONVERSION FACTORS
To Convert
To
Multiply By
Length
inches
inches
feet
feet
feet
feet
yards
yards
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
meters
meters
meters
nautical miles
millimeters
feet
inches
meters
yards
miles (U.S. statute)
feet
miles (U.S. statute)
feet
yards
meters
nautical miles
feet
yards
miles (U.S. statute)
miles (U.S. statute)
25.4
0.0833
12
0.3048
0.3333
0.0001894
3
0.0005682
5280
1760
1609
0.868
3.271
1.094
0.0006214
1.152
Area
square inches
square inches
square feet
square feet
square meters
square miles
square yards
square centimeters
square feet
square inches
square meters
square feet
square yards
square feet
6.452
0.006944
144
0.09290
10.76
3,097,600
9
Volume
cubic inches
cubic inches
cubic feet
cubic feet
cubic feet
cubic meters
liters
quarts (U.S. liquid)
U.S. gallons
U.S. gallons
U.S. gallons
barrels (petroleum)
Imperial gallons
milliliters
cubic centimeters
cubic feet
cubic inches
cubic meters
U.S. gallons
cubic feet
quarts (U.S. liquid)
liters
barrels (petroleum)
cubic feet
Imperial gallons
U.S. gallons
U.S. gallons
cubic centimeters
16.39
0.0005787
1728
0.02832
7.481
35.31
1.057
0.9463
0.02381
0.1337
0.8327
42
1.201
1
D-l
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Time
seconds
seconds
seconds
minutes
minutes
minutes
hours
hours
hours
minutes
hours
days
seconds
hours
days
seconds
minutes
days
0.01667
0.0002778
0.00001157
60
0.01667
0.0006944
3600
60
0.04167
Mass or Weight
pounds
pounds
pounds
pounds
tons (short)
tons (metric)
tons (long)
kilograms
tonnes (metric tons)
kilograms
short tons
long tons
metric tons
pounds
pounds
pounds
pounds
kilograms
0.4536
0.0005
0.000464
0.0004536
2000
2205
2240
2.205
1000
Energy
calories
calories
Btu (British thermal units)
Btu
joules
joules
Btu
joules
calories
joules
calories
Btu
0.003968
4.187
252.0
1055
0.2388
0.0009479
Velocity
feet per second
feet per second
feet per second
meters per second
meters per second
miles per hour
miles per hour
knots
knots
knots
pounds per cubic foot
grams per cubic centimeter
grams er cubic centimeter
kilograms per cubic meter
meters per second
miles per hour
knots
feet per second
miles per hour
meters per second
feet per second
meters per second
miles per hour
feet per second
grams per cubic centimeter
pounds per cubic foot
kilograms per cubic meter
grams per cubic centimeter
0.3048
0.6818
0.5921
3.281
2.237
0.4470
1.467
0.5148
1.151
1.689
0.01602
62.42
1000
0.001
D-2
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Pressure
ponds per square inch (absolute) (psia)
psia
psia
psia
pounds per square inch (gauge) (psig)
millimeters of mercury (torr)
millimeters of mercury (torr)
inches of water
kilograms per square centimeter
inches of water
kilograms per square centimeter
atmospheres
kilograms per square centimeter
atmospheres
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2)
atmospheres
inches of water
millimeters of mercury (torr)
psia
psia
kN/m2
psia
millimeters of mercury (torr)
kN/m2
atmospheres
kN/m2
psia
psia
kN/m2
psia
atmospheres
atmospheres
kilograms per square centimeter
6.895
0.0680
27.67
51.72
add 14.70
0.01934
0.1333
0.03614
735.6
0.2491
0.9678
101.3
14.22
14.70
100
0.1450
0.9869
0.009869
1.020
Viscosity
centipoises
pounds per foot per second
centipoises
centipoises
poises
grams per centimeter per second
Newton seconds per square meter
pounds per foot per second 0.0006720
centipoises 1488
poises 0.01
Newton seconds per square meter 0.001
grams per centimeter per second 1
poises 1
centipoises 1000
Thermal Conductivity
Btu per hour per foot per • F
Btu per hour per foot per • F
watts per meter-kelvin
kilocalories per hour per meter per • C
kilocalories per hour per meter per • C
watts per meter-kelvin 1.731
kilocalories per hour per meter per • C 1.488
Btu per hour per foot per • F 0.5778
watts per meter-kelvin 1.163
Btu per hour per foot per • F 0.6720
Heat Capacity
Btu per pound per • F
Btu per pound per • F
joules per kilogram-kelvin
calories per gram per • C
calories per gram per • C
joules per kilogram-kelvin
Btu per pound per • F
Btu per pound per • F
1
4187
0.0002388
1
D-3
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Concentration (in water solution)
parts per million (ppm)
milligrams per liter
milligrams per cubic meter
grams per cubic centimeter
grams per cubic centimeter
pounds per cubic foot
milligrams per liter
ppm
grams per cubic centimeter
milligrams per cubic meter
pounds per cubic foot
grams per cubic centimeter
1
1
IxlO'9
IxlO9
62.42
0.01602
Temperature
degrees Kelvin (• K)
degrees Rankine (• R)
degrees centigrade (• C)
degrees Fahrenheit (• F)
degrees centigrade (• C)
degrees Fahrenheit (• F)
degrees Rankine (• R)
degrees Kelvin (• K)
degrees Fahrenheit (• F)
degrees centigrade (• C)
degrees Kelvin (• K)
degrees Kelvin (• K)
1.8
0.5556
first multiply by 1.8, then add 32
first subtract 32, then multiply by
0.5556
add 273.2
add 459.7
Flow
cubic feet per second
U.S. gallons per minute
U.S. gallons per minute
cubic feet per second
448.9
0.002228
Universal Gas Constant (R)
8.314 joules per gram mole-kelvin
1.987 calories per gram mole-kelvin
1.987 Btu per pound mole per • F
10.73 psia-cubic feet per pound mole per • F
82.057 atm-cubic centimeters per gram mole-kelvin
62.361 millimeters mercury liter per gram mole-kelvin
D-4
------- |