United States Office of Environmental EPA 260-B-01-005
Environmental Protection Information August 2001
Agency Washington, DC 20460 FINAL
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW ACT -
SECTION 313:
Guidance for Reporting Toxic Chemicals:
Pesticides and Other Persistent
Bioaccumulative Toxic (PBT) Chemicals
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986
(EPCRA) requires certain facilities manufacturing, processing, or otherwise using listed toxic
chemicals to report the annual quantity of such chemicals entering each environmental medium.
Such facilities must also report pollution prevention and recycling data for such chemicals,
pursuant to section 6607 of the Pollution Prevention Act, 42 U.S.C. 13106. When enacted,
EPCRA Section 313 established an initial list of toxic chemicals that was comprised of more
than 300 chemicals and 20 chemical categories. EPCRA Section 313(d) authorizes EPA to add
chemicals to or delete chemicals from the list, and sets forth criteria for these actions. EPCRA
Section 313 currently requires reporting on over 600 chemicals and chemical categories.
CONTENTS
SECTION 1.0 INTRODUCTION 1
Section 1.1 Background 1
Section 1.2 Who Must Report? 3
Section 1.3 What are the Reporting Thresholds for PBT Chemicals? 5
Section 1.4 What Other Changes to the EPCRA Section 313 Reporting
Requirements Apply to PBT Chemicals? 7
1.4.1 De Minimis Exemption 7
1.4.2 Alternate Reporting Threshold (1 Million Lbs); Form A 7
1.4.3 Range Reporting 8
1.4.4 Data Precision 8
SECTION 2.0 SOURCES AND USES OF PESTICIDES AND OTHER SELECT PBT CHEMICALS 9
SECTION 3.0 GUIDANCE ON ESTIMATING ENVIRONMENTAL RELEASES OF PBT CHEMICALS ... 16
Section 3.1 General Guidance 16
3.1.1 Threshold Determination 16
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CONTENTS (Continued)
3.1.2 Exemptions 19
Section 3.2 Methods for Calculating Annual Releases and Other Waste
Management Quantities of PBT Chemicals 21
SECTION 4.0 REFERENCES 28
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LIST OF TABLES
1-1 Select Chemical Additions/Revisions Based on the PBT Chemical Rule 1
3-1 Quantity of Benzo(g,h,i)perylene Required to Meet the Reporting Threshold in
Common Fuels 19
3-2 Potential Data Sources for Release and Other Waste Management
Calculations 25
3-3 Published Emission Factors for Select PBT Chemicals 26
in
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DISCLAIMER
This guidance document is intended to assist industry with EPCRA Section 313 reporting for
pesticides and other PBT chemicals. 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 supersede 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 guidance on this site 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. To that end, industry should use facility specific
information and process knowledge, where available, to meet the 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 specific and chemical specific guidance
documents, are also available at the EPA TRI website: .
IV
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SECTION 1.0 INTRODUCTION
Section 1.1 Background
On October 29, 1999, EPA promulgated the Final Rule on Persistent,
Bioaccumulative, and Toxic (PBT) chemicals ( 64 FR 58666). This rule added several
chemicals to Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) list of toxic chemicals and established lower reporting thresholds for these and
other PBT chemicals that were already reportable under Section 313. The specific
additions/revisions to the Toxics Release Inventory (TRI) reporting requirements for the
chemicals covered in this document are summarized below in Table 1-1.
Table 1-1
Select Chemical Additions/Revisions Based on the PBT Chemical Rule
Chemical Name or Chemical Category
Aldrin
Benzo(g,h,i,)perylene1>2
Chlordane
Heptachlor
Hexachlorobenzene
Isodrin
Methoxychlor
Octachlorostyrene1
Pendimethalin
Pentachlorobenzene1
Polychlorinated biphenyl (PCBs)
Tetrabromobisphenol A1
Toxaphene
Trifluralin
CASRN
309-00-2
191-24-2
57-74-9
76-44-8
118-74-1
465-73-6
72-43-5
29082-74-4
40487-42-1
608-93-5
1336-36-3
79-94-7
8001-35-2
1582-09-8
Section 313 Reporting
Threshold (pounds)
100
10
10
10
10
10
100
10
100
10
10
100
10
100
'These chemicals and chemical categories were added to the EPCRA Section 313 chemical list as a result of the
PBT rule, published on October 29, 1999.
2Benzo(g,h,i)perylene is a PAC; however it is listed separately on the EPCRA Section 313 chemical list and is not
part of the PAC chemical category.
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The chemicals presented in Table 1-1 are referred to as "PBT Chemicals"
throughout this document. The purpose of this guidance document is to assist facilities in
complying with the reporting requirements of EPCRA Section 313 for these PBT chemicals.
Table 1-1 lists the reporting thresholds for the PBT chemicals discussed in this guidance
document. Facilities that meet the EPCRA Section 313 employee threshold and SIC code
requirements, and that exceed the reporting threshold for these PBT chemicals are subject to the
new EPCRA Section 313 annual reporting requirements beginning with reporting year 2000,
with the first reports due by July 1, 2001.
This document explains the EPCRA Section 313 reporting requirements, and
provides guidance on how to estimate annual releases and other waste management quantities of
PBT chemicals from certain industries and industrial activities. Because each facility is unique,
the recommendations presented may have to be adjusted to the specific nature of operations at
your facility or industrial activity.
A primary goal of EPCRA is to increase the public's knowledge of, and access to,
information on the presence and release and other waste management activities of EPCRA
Section 313 toxic chemicals in their communities. Under EPCRA Section 313, certain facilities
exceeding reporting thresholds are required to submit annual toxic chemical release forms.
These forms must be submitted to EPA and State or Tribal governments, on or before July 1, for
activities in the previous calendar year. The owner/operator of the facility on July 1 of the
reporting deadline is primarily responsible for the report, even if the owner/operator did not own
the facility during the reporting year. EPCRA mandates that EPA establish and maintain a
publicly available database consisting of the information reported under Section 313. This
database, known as the Toxics Release Inventory (TRI), can be accessed through the following
sources:
EPA's Internet site, www.epa.gov/tri;
TRI Explorer Internet site, www.epa.gov/triexplorer;
Envirofacts Warehouse Internet site,
www.epa.gov/enviro/html/tris/tris_overview.html; and
EPA's annual TRI data release materials (summary information).
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The objectives of this guidance document are to:
•• Provide explanation and assistance on EPCRA Section 313 reporting
requirements for select PBT chemicals;
Promote consistency in the method of estimating annual releases and other
waste management quantities of select PBT chemicals for certain
industries and industrial classes; and
•• Reduce the level of effort expended by those facilities that prepare an
EPCRA Section 313 report for these PBT chemicals.
Section 1.2 Who Must Report?
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, which is
controlled by, or which is under common control with such person)." (EPCRA Section 328(4)).
A facility may contain more than one "establishment" (40 CFR 372.3). An "establishment" is
defined as, "an economic unit, generally at a single physical location, where business is
conducted or where services or industrial operations are performed" (40 CFR 372.3).
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. Also, the combined release and other waste management activities reported
singly for each establishment must total those for the facility as a whole (40 CFR 372.30(c)).
Note that if a facility is comprised of more than one establishment, once an
activity threshold is met by the facility, provided that 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 372.30(c)).
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A facility is subject to the provisions of EPCRA Section 313, if it meets all three
of the following criteria:
•• It is included in Standard Industrial Classification (SIC) codes 20 through
39; SIC code 10 (except SIC codes 1011, 1081, and 1094); SIC code 12
(except SIC code 1241); SIC code 4911 (limited to facilities that combust
coal and/or oil for the purpose of generating power for distribution in
commerce), SIC code 4931 (limited to facilities that combust coal and/or
oil for the purpose of generating power for distribution in commerce), or
SIC code 4939 (limited to facilities that combust coal and/or oil for the
purpose of generating power for distribution in commerce); SIC code
4953 (limited to facilities regulated under the Resource Conservation and
Recovery Act, subtitle C, 42 U.S.C. section 6921 etseq.); SIC code 5169;
SIC code 5171; or SIC code 7389 (limited to facilities primarily engaged
in solvent recovery services on a contract or fee basis); and
•• It has 10 or more full-time employees (or the equivalent of 20,000 hours
per year); and
•• It manufactures (includes imports), processes, or otherwise uses any of the
toxic chemicals listed on the EPCRA Section 313 list in amounts greater
than the threshold quantities established in 40 CFR 372.25, 372.28. See
Section 1.3.
These three criteria alone, not a facility's release and other waste management
quantities, determine whether a facility must prepare an EPCRA Section 313 report. A facility
that meets these three criteria is still required to prepare an EPCRA Section 313 report even if
that facility has no releases and other waste management quantities of EPCRA Section 313
chemicals or chemical categories.
In addition, pursuant to Executive Order 13148 entitled "Greening the
Government Through Leadership in Environmental Management," federal facilities are required
to comply with the reporting requirements of EPCRA Section 313. This requirement is
mandated regardless of the federal facility's SIC code.
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Section 1.3 What are the Reporting Thresholds for PBT Chemicals?
Thresholds are specified amounts of listed toxic chemicals manufactured,
processed, or otherwise used during the calendar year that trigger reporting requirements.
EPCRA Section 313 establishes default reporting thresholds, but authorizes EPA to establish
lower thresholds for particular chemicals, classes of chemicals, or categories of facilities, if a
different threshold is warranted. EPA has used this authority to establish lower thresholds for
PBT chemicals (see 40 CFR 370.28; 64 FR 58666). Therefore, provided the facility meets the
SIC code and employee threshold criteria, reporting is required for the PBT chemicals aldrin,
methoxychlor, pendimethalin, tetrabromobisphenol A, and trifluralin:
•• If a facility manufactures more than 100 pounds of that PBT chemical
during the calender year.
•• If a facility processes more than 100 pounds of that PBT chemical during
the calender year.
•• If a facility otherwise uses more than 100 pounds of that PBT chemical
during the calender year.
In addition, provided that the facility meets the SIC code and employee threshold criteria,
reporting is required for the PBT chemicals benzo(g,h,i)perylene, chlordane, heptachlor,
hexachlorobenzene, isodrin, octachlorostyrene, pentachlorobenzene, polychlorinated biphenyl
(PCBs), and toxaphene:
•• If a facility manufactures more than 10 pounds of that PBT chemical
during the calendar year.
•• If a facility processes more than 10 pounds of that PBT chemical during
the calendar year.
•• If a facility otherwise uses more than 10 pounds of that PBT chemical
during the calendar year.
The terms manufacture, process, and otherwise use are defined at 40 CFR 372.3
as:
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Manufacture means to produce, prepare, import, or compound a toxic chemical.
Manufacture also applies to a toxic chemical that is produced coincidentally
during the manufacture, processing, otherwise use, or disposal of another
chemical or mixture of chemicals, including a toxic chemical that is separated
from that other chemical or mixture of chemicals as a byproduct, and a toxic
chemical that remains in that other chemical or mixture of chemicals as an
impurity.
Process means the preparation of a toxic chemical, after its manufacture, for
distribution in commerce: (1) In the same form or physical state as, or in a
different form or physical state from, that in which it was received by the person
so preparing such substance, or (2) As part of an article containing the toxic
chemical. Process also applies to the processing of a toxic chemical contained in
a mixture or trade name product.
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 offsite 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. Relabeling or redistributing of the toxic chemical
in which no repackaging of the toxic chemical occurs does not constitute
otherwise use or processing of the toxic chemical.
The quantities of PBT chemicals included in threshold determinations are not
limited to the amounts released to the environment. All PBT chemicals manufactured,
processed, or otherwise used are to be counted toward threshold determinations, including any
amount of PBT chemicals that may be generated in closed systems. Quantities required to meet
the threshold for some fuels and other raw materials may be found in Table 3-1. For more
information on threshold determinations for PBT chemicals, see Section 3.1.1.
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Section 1.4 What Other Changes to the EPCRA Section 313 Reporting Requirements
Apply to PBT Chemicals?
EPA has also made modifications and/or clarifications to certain reporting
exemptions and requirements for the PBT chemicals that are subject to the lower reporting
thresholds. Each of the changes as they apply to PBT chemicals is discussed in the following
subsections.
1.4.1 De Minimis Exemption
The de minimis exemption allows facilities to disregard certain minimal
concentrations of toxic chemicals in mixtures or other trade name products they process or
otherwise use when making threshold determinations and release and other waste management
calculations.
EPA eliminated the de minimis exemption for EPCRA Section 313 PBT
chemicals. This means that facilities are required to include all amounts of PBT chemicals in
threshold determinations and all amounts of PBT chemicals in release and other waste
management calculations regardless of the concentration of PBT chemicals in mixtures or trade
name products (40 CFR 372.38(a)). However, the elimination of the de minimis exemption for
PBT chemicals does not affect the applicability of the de minimis exemption to the supplier
notification requirements.
1.4.2 Alternate Reporting Threshold (One Million Pounds) and Form A
The "Alternate Threshold for Facilities with Low Annual Reportable Amounts,"
provides facilities otherwise meeting EPCRA Section 313 reporting thresholds the option of
certifying on a Form A (a two-page certification statement) that they do not exceed 500 pounds
for the total annual reportable amount for that chemical, and that their amounts manufactured,
processed, or otherwise used for that chemical do not exceed one million pounds.
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EPA has excluded PBT chemicals from eligibility for the "Alternate Threshold
for Facilities with Low Annual Reportable Amounts" (40 CFR 372.27(e)). Therefore, the
alternate threshold of one million pounds and the Form A certification statement are not options
for PBT chemicals.
1.4.3 Range Reporting
For facilities with total annual releases or off-site transfers of an EPCRA Section
313 chemical of less than 1,000 pounds, EPA generally allows the amounts to be reported on the
Form R either as an estimate or by using ranges.
For PBT chemicals, EPA has eliminated the range reporting option for releases
and other waste management activities. This means that for those sections of the Form R for
which range reporting is an option, the option cannot be used when reporting on PBT chemicals
(40 CFR 372.85 (b)(15)(i)). Thus, facilities are required to report an actual number rather than a
selected range. However, the elimination of range reporting for PBT chemicals for releases and
transfers does not affect the applicability of range reporting of the maximum amount on site as
required by EPCRA Section 313(g).
1.4.4 Data Precision
Facilities should report for PBT chemicals at a level of precision supported by the
data and the estimation techniques on which the estimate is based. However, the smallest
quantity that need be reported on the Form R for PBT chemicals is 0.1 pounds.
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SECTION 2.0 SOURCES AND USES OF PESTICIDES AND
OTHER SELECT PBT CHEMICALS
The following paragraphs describe pesticides and other select chemicals regulated
by the PBT rule. Please be aware that while some historical frequency data are provided below,
the lower reporting thresholds now in effect are expected to increase the number of reports
submitted for each chemical.
Aldrin
Aldrin is a soil insecticide that was used on crops from the 1950s until the early
1970s, at which time all uses except termite control were canceled. Aldrin is now listed by EPA
as a canceled pesticide, and it is no longer manufactured or used in any circumstance in the
United States. The collection and eventual destruction of aldrin at Resource Conservation
Recovery Act (RCRA) Subtitle C transfer and disposal facilities falls under the TRI reporting
requirements. This chemical may still be otherwise used and should continue to be reported to
the EPA for TRI purposes. One Form R was received for aldrin in 1999.
Benzo(g,h,i)perylene
Benzo(g,h,i)perylene is a polycyclic aromatic compound (PAC). It may be found
in oil, coal, wood, and natural gas. Formation of benzo(g,h,i)perylene and other PACs occurs as
a by-product of incomplete combustion. Fossil fuel combustion for heat and power generation is
the primary source of PACs; however, other industrial processes also contribute. For example,
benzo(g,h,i)perylene may be manufactured during synthetic fuel production, coal processing, and
petroleum refining. For more information on sources of PACs and benzo(g,h,i)perylene, refer to
U.S. EPA's Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic Compounds
Category. Benzo(g,h,i)perylene was added to the EPCRA Section 313 list of toxic chemicals in
1999.
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Chlordane
Chlordane is a broad-spectrum insecticide that was used on agricultural crops, in
homes and gardens, for turf and ornamentals, and for termite and ant control. It has been banned
from domestic use since 1988, but was manufactured for export up until 1997 by one
corporation. Chlordane collected and disposed of at RCRA Subtitle C transfer and disposal
facilities should continue to be reported to EPA for TRI purposes. In 1999, four Form R reports
were submitted for chlordane.
Heptachlor
Heptachlor was first registered in the United States in 1952 for use as a broad-
spectrum insecticide, but was also used for home and garden insect control, for termite control,
and as a seed treatment. It is presently used in the United States only to control fire ants in
buried transformer and telephone/cable boxes. The production of heptachlor in the United States
ended in 1997, but heptachlor collected and disposed of at RCRA Subtitle C transfer and
disposal facilities should continue to be reported to EPA for TRI purposes. In 1999, four Form R
reports were submitted for heptachlor.
Hexachlorobenzene
Hexachlorobenzene was produced up until 1985 as a pesticide/fungicide used to
treat wheat seeds, onions, and sorghum. It is no longer used as an active ingredient; however, it
is contained as an impurity or formed as a by-product during the manufacturing of several
common pesticides currently in use including atrazine, lindane, maleic anyhydride, and
propazine.
Hexachlorobenzene may also be produced as a by-product in the manufacture of
chlorinated organics (such as carbon tetrachloride, perchloroethylene, trichloroethylene, ethylene
dichloride, and 1,1,1-trichloroethane), in certain metal smelting and refining operations, during
the combustion of chlorinated organic chemicals, and in coal-fired utility boilers. It is usually
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found in the still bottoms generated during chlorinated organic chemical purification and may be
emitted from distillation columns. Hexachlorobenzene may also be indirectly produced during
chlorine manufacturing, tire manufacturing, and some metal manufacturing operations (metallic
magnesium and aluminum foundries/smelters) (1,3,4). In 1999, 20 Form Rs were submitted for
hexachl orob enzene.
Isodrin
Isodrin is an insecticide that is no longer manufactured or used commercially in
the United States. Small releases or other waste management activities of isodrin may be
reported in TRI as remaining stockpiles are collected for destruction. In addition to any residual
release or other waste management activities from the manufacture and use of isodrin, it may
also be indirectly created/released from coal mining, foundries, waste incineration, and
nonferrous metals manufacturing. Although it was reportable, no Form Rs were submitted for
isodrin in 1999.
Methoxychlor
Methoxychlor is currently used as an insecticide to control flies, mosquitoes,
cockroaches, chiggers, and a variety of other insects. Methoxychlor and other related
methoxychlor products are used on fruits, vegetables, and other plants (10). Reporting is
expected during manufacturing, formulation, packaging, and disposal of methoxychlor. In 1999,
three Form Rs were submitted for methoxychlor.
Octachlorostyrene
Octachlorostyrene is not manufactured as a commercial product, and no
commercial uses of Octachlorostyrene are known. It is a possible by-product of chlorine
production, metal product/finishing operations, pesticide manufacturing, and high-temperature
incineration of chlorinated hydrocarbons (especially plastic wastes). It has been identified as a
by-product from the manufacture of carbon tetrachloride and perchloroethylene.
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Added to the EPCRA Section 313 list of toxic chemicals in 1999,
octachlorostyrene has not been reportable to EPA for TRI purposes in the past. Due to its
structural similarity to hexachlorobenzene it may be manufactured as a by-product in many of
the same processes as hexachlorobenzene.
Pendimethalin
Pendimethalin is currently used as an insecticide and herbicide on a variety of
agricultural crops. It is currently registered as the active ingredient in 58 pesticide products
intended for agricultural, domestic, and commercial uses. Reporting of pendimethalin is
expected to occur from manufacturing, formulation, packaging, and activities associated with its
use. In 1999, ten Form Rs were submitted for pendimethalin.
Pentachlorobenzene
Pentachlorobenzene is used exclusively as an intermediate in the production of
the fungicide pentachloronitrobenzene (quintozene). It is found in the quintozene process waste
stream as an unreacted intermediate and in the final product as an impurity. Pentachlorobenzene
may be produced whenever organic compounds are burned in the presence of a chlorine source,
as well as in small quantities in waste incineration, cement kilns, and secondary copper
production processes.
Information on releases of pentachlorobenzene is limited. However, it is
structurally similar to hexachlorobenzene and may be a by-product in chemical reactions that are
known to produce hexachlorobenzene as a by-product.
Pentachlorobenzene was not reportable to EPA for TRI purposes in 1999.
However, eight Form Rs were submitted for quintozene. Since pentachlorobenzene is found in
the quintozene process waste stream it is expected that pentachlorobenzene will also be reported
at the same facilities.
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Polychlorinated Biphenyls (PCBs)
PCBs (Chemical Abstract Service Registry Number 1336-36-3) are a group of
over 200 synthetic halogenated aromatic hydrocarbons that were commercially used and sold as
a mixture of isomers. Since the 1930s, PCBs have been used as dielectric agents (high- and low-
voltage power capacitors and small industrial capacitors in equipment such as air conditioners,
pumps, and fans), heat transfer agents, lubricants, flame retardants, plasticizers, and
waterproofing materials. Depending on conditions, PCBs may be inadvertently created in some
chlorinated organic chemical processes.
While many boilers and other combustion facilities burn virgin oil, some do not.
That is, some facilities use fuel which has been gathered from other locations by oil recyclers;
this fuel is commonly called "used oil". In some instances, used oil may contain PCBs. If your
facility combusts used oil and you do not have better data, assume that the upper bound
concentration of PCBs is 2 ppm. If, for example, a boiler is a TSCA-qualified combustion
facility, then the concentration of PCBs may be greater than 2 ppm.
Domestic production of PCBs was banned in 1976. In 1979, the PCB Ban Rule
was issued requiring all non-totally enclosed PCB activity to be authorized by EPA. Examples
of authorized activities include servicing PCB transformers and PCB-contaminated transformers,
servicing railroad transformers and mine equipment, and use in heat transfer and hydraulic
systems.
In general, PCBs may be released from the authorized handling of PCBs in the
activities described above, the waste management activities associated with PCB-contaminated
wastes, and from combustion processes. Specific activities that might lead to releases of PCBs
include used oil handling at bulk stations and bulk terminals, residual oil combustion, waste
incineration (tires, medical/biological/hazardous/municipal waste, and sewage sludge), and any
waste management activities in which PCB-contaminated soil, transformers, capacitors, or other
materials are handled. In 1999, 16 Form Rs were submitted for PCBs.
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Tetrabromobisphenol A
Tetrabromobisphenol A (TBBPA) is the largest globally produced brominated
flame retardant. It is often used in plastics and engineering resins for printed circuit boards and
computer equipment. TBBPA may be used as a reactive or additive flame retardant in
acrylonitrile-butadiene-stryrene (ABS) resins, epoxy and polycarbonate resins, high-impact
polystyrene, unsaturated polyester resins, and thermoplastic polymers. When TBBPA is used as
a reactive flame retardant, it is chemically transformed into another substance. In this instance,
TBBPA is not present in the finished substance, except as trace amounts of unreacted starting
material.
TBBPA is currently only produced at two facilities in the United States. TBBPA
releases and other waste management activities associated with these facilities should be
reported to TRI. Other reporting is expected from facilities using TBBPA in the manufacture of
consumable goods such as televisions, VCRs, computer wire and cable, printed circuit boards,
and computer housings. Many products containing TBBPA may be subject to the EPCRA
Section 313 article exemption.
Reporting year 2000 will be the first year TBBPA is reported under EPCRA
Section 313. However, in 1999, 124 Form Rs were submitted for decabromodiphenyl oxide
(DBDPO), a similar brominated flame retardant used in various resins.
Toxaphene
Toxaphene is a poly chlorinated camphene that was first commercialized in 1948
and became one of the most widely used chlorinated pesticides in the history of U.S. agriculture.
It was used on a variety of crops as well as on livestock and poultry. All domestic uses of
toxaphene were banned in 1990, but it is still used as an insecticide on bananas and pineapples in
Puerto Rico and the Virgin Islands. Efforts made in several states to collect out of date and
banned pesticides have resulted in the collection of tens of thousands of pounds of toxaphene,
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which were presumably sent to RCRA Subtitle C transfer and disposal facilities. Four Form Rs
were received for toxaphene in 1999.
Trifluralin
Trifluralin is a herbicide that is currently used primarily on cotton and soybean
crops. In 1995, trifluralin use was estimated to be 25.6 million pounds. As this herbicide
continues to be manufactured, releases and waste management activities associated with its
manufacture and distribution should continue to be reported in TRI. In 1999, 11 Form Rs were
submitted for trifluralin.
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SECTION 3.0 GUIDANCE ON ESTIMATING ENVIRONMENTAL
RELEASES OF PBT CHEMICALS
Section 3.1 General Guidance
EPA is providing the following guidance for use by facilities in estimating and
reporting annual releases and other waste management quantities for PBT chemicals. It is not
designed to provide exhaustive guidance for all situations involving PBT chemicals. Guidance
documents for reporting the following PBT chemicals are also available: polycyclic aromatic
carbons, mercury and mercury compounds, and dioxin and dioxin-like compounds. Please
consult industry specific guidance documents applicable to your facility for more detailed
guidance. Additional information and guidance is also available from the EPA's EPCRA
Hotline, 1-800-424-9346, and the Toxics Release Inventory (TRI) website at
http://www.epa.gov/tri. EPA also publishes an annual guidance document for EPCRA Section
313 reporting entitled Toxic Chemical Release Inventory Reporting Forms and Instructions.
You should consult the most current version before preparing any report for your facility.
This document includes concentration and emission factor data which may be
used as default values in calculating activity thresholds, releases and other waste management
quantities. EPA recommends that facilities complete these calculations using best readily
available information applicable to their operations, even when it differs from the data provided
herein. EPA also recommends that facilities maintain documentation of the basis for making
these estimates. Facilities are not required to perform additional testing for EPCRA Section 313
reporting.
3.1.1 Threshold Determination
As mentioned previously, EPA lowered the reporting threshold for PBT
chemicals for each of the reporting activities (manufacturing, processing, and otherwise use).
Each activity threshold is determined independently. When determining if a threshold is
exceeded for PBT chemicals, you should calculate the amount of each PBT chemical
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manufactured, the amount of each PBT chemical processed, and the amount of each PBT
chemical otherwise used. Quantities required to meet the threshold for some fuels and other raw
materials may be found in Table 3-1. The following example illustrates how to determine if a
threshold has been exceeded for a PBT chemical.
Example - Threshold Determination Using Published Data
This sample calculation illustrates the use of published chemical-specific concentration data to determine
threshold quantities.
Your facility has a primary SIC Code covered by EPCRA Section 313 reporting requirements and has over 200
full-time employees. Your facility requires large quantities of steam in the manufacturing process generated by
oil-fired boilers. The No. 6 fuel oil you purchase to use in the boilers contains trace amounts of
benzo(g,h,i)perylene. The combustion of the fuel oil constitutes otherwise use of benzo(g,h,i)perylene. You
need to determine if your facility otherwise uses benzo(g,h,i)perylene in an amount exceeding the annual
reporting threshold of 10 pounds.
To determine if your facility exceeds the otherwise use threshold for benzo(g,h,i)perylene, you must determine
the amount of benzo(g,h,i)perylene present in the No. 6 fuel oil you purchased. Using the concentration in Table
3-1, benzo(g,h,i)perylene is present in residual fuel at a concentration of 26.5 ppm. The density of No. 6 fuel oil
is 8 Ib/gal, and your facility used 144,000 gallons of No. 6 fuel oil during the reporting year. The quantity used
to determine if you are required to report may be calculated as follows:
(144,000 gal/yr oil consumed) * (26.5 Ib benzo(g,h,i)perylene/lE+6 Ib residual oil) * (8 Ib/gal
oil density)
= 30.5 Ib/yr benzo(g,h,i)perylene used
Your facility exceeded the otherwise used threshold of 10 Ib/year and is required to report.
The concentration of an EPCRA Section 313 PBT chemical may be known as a
specific concentration, as an average, as a range, or as an upper or lower boundary. If you know
the specific concentration of the EPCRA Section 313 chemical in the stream, you must use that
value (40 CFR 372.30 (b)(i). If only an average concentration is provided (e.g., by the supplier),
use that value in the threshold calculation. If only the upper bound concentration is known, you
must use that value in the threshold calculation (40 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
boundary, 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 boundary,
EPA recommends that you use the mid-point in your calculations.
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•• If only the lower bound concentration of the EPCRA Section 313
chemical is given and the concentrations of the other components are
given, EPA recommends that you subtract the other component total from
100% to calculate the upper bound of the PBT chemical concentration.
EPA then recommends that you should then determine the mid-point for
use in your calculations.
•• If only the lower bound concentration of the EPCRA Section 313
chemical is given and the concentration of the other components is not
given, EPA recommends that you assume the upper bound for the PBT
chemical 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.
Chemical production facilities may manufacture PBT chemicals for other industry
use. Production records are a great source for determining the amount manufactured. You must
also include the importing of PBT chemicals in your manufacturing threshold determination.
(EPCRA Section 313 (b)(l)(c)(i)). You should easily obtain these amounts from purchasing
records.
Table 3-1 provides concentrations of benzo(g,h,i)perylene in fuels. EPA
recognizes that the scientific literature shows that there is significant variability in the
concentrations of benzo(g,h,i)perylene in fuels. As always, facilities should use the best
available information that is applicable to their operations. In the absence of better data, EPA
recommends using the default values listed in Table 3-1 for these commonly used fuels.
Diesel fuel is also a likely source of benzo(g,h,i)perylene; EPA does not have a
default value for sites to use at this time.
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Table 3-1
Quantity of Benzo(g,h,i)perylene Required to Meet the Reporting Threshold
in Common Fuels
Fuel Type
No. 2 Fuel Oil
No. 6 Fuel Oil (Bunker C)
Gasoline
Paving Asphalt
Crude Oil
Benzo(g,h,i)perylene
Concentration (ppm)
0.05
26.5
2.55
1.2
(a)
Reference
11
12
13
6
Quantity Needed to
Meet Threshold
(gallons)"
2.82 xlO7
4.78 xlO4
7.00 xlO5
7.69 xlO5
(a) Benzo(g,h,i)perylene concentration in crude oil depends on the crude oil type. Additional benzo(g,h,i)perylene
may be formed during petroleum refining operations.
(b) Assumes the following densities: No. 2 Fuel Oil = 7.1 Ib/gallon; No. 6 Fuel Oil = 7.9 Ib/gallon; gasoline = 5.6
Ib/gallon; and paving asphalt = 10.84 Ib/gallon.
If you perform threshold calculations for benzo(g,h,i)perylene, you should also
perform threshold calculations for the polycyclic aromatic compound (PAC) category.
Benzo(g,h,i)perylene (a PAC) is reported separately from the PAC chemical category. The
reporting threshold for benzo(g,h,i)perylene is 10 Ib/yr and the reporting threshold for the PAC
category is 100 Ib/yr. If you exceed a reporting threshold for both benzo(g,h,i)perylene and the
PAC category, separate Form Rs must be submitted. For more information on the PAC chemical
category, refer to the EPCRA Section 313 Guidance for Reporting Toxic Chemicals: Polycyclic
Aromatic Compounds Category.
3.1.2
Exemptions
EPA has established four classes of exemptions: de minimis, article,
facility/laboratory related, and activity related. Chemicals or chemical categories that qualify for
these exemptions may be excluded from threshold determinations and release or other waste
management estimations.
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The PBT final rule states that the de minimis exemption does not apply to PBT
chemicals or chemical categories (40 CFR 372.38(a)).
For purposes of the article exemption (40 CFR 372.38(b)), an article is defined as
a manufactured item that:
Is formed to a specific shape or design during manufacture;
•• Has end-use functions dependent in whole or in part upon its shape or
design; and
Does not release an EPCRA Section 313 chemical or chemical category
under normal conditions of processing or otherwise use of the item at the
facility (40 CFR 372.3).
If you receive a manufactured article from another facility (e.g., a transformer
containing PCBs), the PBT chemical in that article may be exempt from threshold
determinations and release and other waste management calculations if you meet the following:
•• You 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 PBT chemical or any other TRI chemical in a
reporting year from all like articles.
COMMON ERROR - PCBs in Articles
EPA has stated that transformers are articles (and thus exempt from threshold determinations), but that the
release or removal of fluid from the transformer negates the article status. The article status of only those
transformers that have fluids removed (e.g., servicing or retro filling), or have fluids escape are affected.
However, the PCBs are still not considered towards the reporting threshold if no new PCB-containing fluid is
added, since the threshold determination is based on fluid added, not lost.
EPA has stated that disposal or removal of articles does not constitute a release. Therefore, disposal on site, or
off-site transfer of the whole transformer with fluid content undisturbed, does not negate the article status. The
transformer is not included in threshold determinations and does not have to be reported as a release or an off-
site transfer of PCBs for purposes of Section 313 reporting.
When calculating the threshold for otherwise use, a facility must consider only the amount of PCBs added to
transformers during the reporting year (e.g, "topping off a transformer), not the amount of working fluid
contained in the transformer. (Ref: USEPA, 1998 EPCRA Section 313 Q&A, Directive #6)
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Any PBT chemicals manufactured, processed, or otherwise used in laboratories
under the supervision of a technically qualified individual may be exempt from threshold
determinations and release and other waste management calculations (40 CFR 372.38(d)).
The activity-related exemptions are available for PBT chemicals (see 40 CFR
372.38.)
Section 3.2 Methods for Calculating Annual Releases and Other Waste Management
Quantities of PBT Chemicals
You must estimate release and other waste management quantities if the reporting
threshold for one of the manufacturing, processing, or otherwise use activities is exceeded. EPA
recommends that you calculate PBT releases and other waste management activities by
following these steps:
1. Identify the processes/operations in which PBT chemicals may be
manufactured, processed, or otherwise used.
2. Determine potential sources of releases and other waste management
activities (e.g., process wastewater discharge, emissions from operations).
3. Identify the types of releases and other waste management activities.
These types correspond to the Form R (e.g., stack emissions, sent off site
for recycling).
4. Determine the most appropriate estimation method(s) and calculate the
estimates for release and other waste management quantities.
During threshold determinations, you should have identified the processes and
operations in which PBT chemicals are found. Potential release and other waste management
sources of PBT chemicals include the following:
Accidental spills and releases;
Air pollution control devices (e.g., baghouses, electrostatic precipitators,
and scrubbers);
Clean up and housekeeping practices;
Combustion by-products;
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•• Container residues;
•• Process discharge stream;
•• Recycling and energy recovery by-products;
Storage tanks;
Tower stacks;
Transfer operations;
Treatment sludge;
•• Volatilization from processes; and
•• Waste treatment discharges.
After determining the release and other waste management activity sources of
PBT chemicals, you are ready to determine the types of releases and other waste management
activities. These final destinations of PBT chemicals (not including incorporation into a final
product) correspond to elements of the Form R. The potential types of releases and other waste
management activities include:
Fugitive or nonpoint air emissions (Part II, Section 5.1 of Form R): PBT
chemical emissions are considered to be fugitive if not released through
stacks, vents, ducts, pipes, or any other confined air stream. You must
include (1) fugitive equipment leaks from valves, pump seals, flanges,
compressors, sampling connections, open-ended lines, etc.; (2)
evaporative losses from surface impoundments and spills; (3) releases
from building ventilation systems; and (4) any other fugitive or non-point
air emissions.
Stack or point air emissions (Part II, Section 5.2 of Form R): PBT
chemical emissions are considered to be stack if released through stacks,
confined vents, ducts, pipes, or other confined air streams. You must
include storage tank emissions. Air releases from air pollution control
equipment would generally fall in this category. Using the control
efficiency of an air pollution control device, you can determine how much
of the PBT chemical is released through the air device.
Discharges to receiving streams or water bodies (Part II, Section 5.3 of
Form R): PBT chemicals may be released in wastewater directly from the
process or from a treatment system. Monitoring is often performed at
either type of outfall. This information can be used to determine the
concentrations of PBT chemicals leaving the facility.
Underground injection on site (Part II, Section 5.4 of Form R): This waste
management type is not common for PBT chemicals.
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•• Disposal to land on site (Part II, Section 5.5 of Form R): This type of
release may occur if materials containing PBT chemicals are spilled
during processing or transfer operations.
Discharges to Publicly Owned Treatment Works (POTW) (Part II, Section
6.1 of Form R): As with the receiving stream discharge, monitoring may
be available to determine the PBT chemical concentration in a waste
stream from a process or from a treatment operation.
•• Transfers to other off-site locations (Part II, Section 6.2 of Form R): This
type includes transferring PBT chemicals off site for recovery. Other
sources include used baghouse wastes sent to landfills, or other PBT
chemical wastes sent off site for disposal, treatment, or recycling.
On-site waste treatment (Part II, Section 7A of Form R): You should
report the amount of PBT chemicals treated by your facility. Following
treatment, PBT chemicals may be present in sludge or the water (at a
reduced concentration).
•• On-site energy recovery (Part II, Section 7B of Form R): EPA believes
that chemicals that do not contribute significant heat energy during the
combustion process should not be considered for energy recovery.
•• On-site recycling (Part II, Section 7C of Form R). If you perform
recycling, you should report the amount recycled in Section 7C of the
Form R.
After you have identified all of the potential sources for release and other waste
management activities, you must estimate the quantities of PBT chemicals released and
otherwise managed as waste from these sources.
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).
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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 (8).
Many data sources exist for these (and other) methods of developing estimates.
Table 3-2 presents potential data sources and the estimation methodology in which each
estimation source is most likely to prove useful. 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.
Air emission monitoring for PBT chemicals may be required under industry
National Emission Standards for Hazardous Air Pollutants (NESHAPs), referred to as Maximum
Achievable Control Technology (MACT) Standards. The HAP list includes PCBs, chlordane,
heptachlor, hexachlorobenzene, methoxychlor, toxaphene, and trifluralin. Standards have been
finalized for some industry source categories and additional categories are upcoming.
Emission factors that may apply to the PBT chemicals addressed in this document
are presented in Table 3-3. Note that emission factor units vary from one factor to another.
24
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Table 3-2
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
•• NPDES1 permits
•• Outfall monitoring data
•• POTW pretreatment standards
•• RCRA2 permit
•• Stack monitoring data
•• New Source Performance Standards
• • Title V Permit Data
•• MACT7 Standards
Emission Factors
•• AP-423 chemical specific emission factors
• • Facility or trade association derived chemical-
specific emission factors
Mass Balance
•• Air emissions inventory
•• Hazardous material inventory
•• Hazardous waste manifests
•• MSDSs4
• • Pollution prevention reports
•• Spill event records
•• Supply and purchasing records
Engineering Calculations
•• NIT5 database
• • Facility non chemical-specific emission factors.
•• Henry's Law
•• Raoult'sLaw
• • SOCMI5 or trade association non-chemical
specific emission factors
•• Solubilities
•• Volatilization rates
'National Pollutant Discharge Elimination System.
2Resource Conservation Recovery Act.
Compilation of Emission Factors, U.S. EPA.
"Material Safety Data Sheets.
5Synthetic Organic Chemicals Manufacturing Industry.
""National Toxic Inventory.
^Maximum Achievable Control Technology.
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Table 3-3
Published Emission Factors for Select PBT Chemicals
PBT Chemical
PCBs
Hexachlorobenzene
Benzo(g,h,i)perylene
Source Category
Hazardous waste incineration
Residual oil combustion
Secondary aluminum casting (using
hexachloroethane for hydrogen degassing),
controlled
Secondary copper smelting/refining (charge
with scrap copper and brass: cupolas),
controlled
Incineration (industrial/hazardous waste),
miscellaneous controls
Primary iron (windbox, discharge end, sinter
breaker), controlled
Cement manufacturing (kilns including
preheater/precalciner kiln, including fuel
supplement wastes), controlled
Cement manufacturing (kilns including
preheater/precalciner kilns, excluding fuel
supplement wastes), controlled
Coal combustion (utility), controlled
Coal combustion (industrial), uncontrolled
or low efficiency paniculate controls
Wood/bark waste combustion, controlled
Carbon tetrachloride production
Perchloroethylene production
1,1,1-trichloroethane production
Ethylene dichloride production
Trichloroethylene production
Controlled coal combustion
Wood waste combustion (with PM controls,
50% moisture basis; 4500 Btu/lb higher
heating value)
No. 6 Fuel oil combustion
Emission
Factor
2.0 x IQ-3
1 x 10'6
1.00 xlO'2
7.80 x 10-5
S.SOxlO'5
3.00 xlO'6
9.2 x 10'7
3.40 xlO'7
1.2xlO-6
1.6 x 10-7
1.20 xlO'7
4.05 x 10'5
4.31 x 10'5
1.08 x IQ-6
8.50 x 10'7
6.86 x IQ-7
2.7x 10-8
1.4 lx 10'6
2.26x 10'6
Emission Factor Units
Ib/ton PCB burned
Ib/lb PCB burned
Ib/ton Al produced 2
Ib/ton scrap feed 2
Ib/ton waste feed 2
Ib/ton sinter produced 2
Ib/ton clinker produced 2
Ib/ton clinker produced 2
Ib/ton coal burned 2
Ib/ton coal burned 2
Ib/ton wood waste burned 2
Ib HCB/lb production
Ib HCB/lb production
Ib HCB/lb production
Ib HCB/lb production
Ib HCB/lb production
Ib/ton coal combusted
Ib/ton wood waste burned
lb/1000 gal oil combusted
Reference1
2
2
5
5
5
5
5
5
5
5
5
7
7
7
7
7
9
9
9
PM - Paniculate Matter
HCB - hexachlorobenzene
'Corresponds to references listed in Section 3.0.
2 Converted from metric units
The use of one of these factors is illustrated in the following example.
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Example - Release and Other Waste Management Estimation
This sample calculation illustrates how you might estimate release and other waste management quantities for
Form R reporting.
The threshold determination in Section 3.1.1 showed that you otherwise used a total of 30.5 pounds of
benzo(g,h,i)perylene during the combustion of 144,000 gallons of residual fuel oil. Using an emission factor of
2.26 x 10"6 Ib benzo(g,h,i)perylene/1000 gal residual oil combusted, air emissions may be calculated as follows:
Quantity released = (2.26 x 10'6 Ib benzo(g,h,i)perylene /1000 gal oil) x (144,000 gal oil)
3.25 x lQ-4lb/yr
Since this is less than 0.1 pounds, you need only report zero pounds in Part II, Sections 5.2 and 8.1 of the 2000
FormR.
In cases where testing is available, releases may be quantified as shown in the
following example.
Example - Release and Other Waste Management Estimation (Waste Treatment)
Your facility is a RCRA Subtitle C transfer and disposal facility that collects and treats a variety of hazardous
wastes, including hexachlorobenzene. In 1999, your facility accepted 10,000 pounds of hexachlorobenzene in
various industrial wastes. You have tested your thermal incinerators and have found you can achieve 99.999%
removal and destruction efficiency for all organics.
The quantity treated on site may be calculated as follows:
Quantity treated on site = 10,000 (Ib hexachlorobenzene incinerated/year x (0.99999)
9,999.9 (Ib/year)
You should report this amount as being treated on site in Part II, Section 7A.
The amount released through the incinerator stack is the difference between the amount incinerated and the
amount treated, or 0.1 (Ib/year). You should report this amount in Part II, Sections 5.2 and 8.1 of the 2000
FormR.
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SECTION 4.0 REFERENCES
1. U. S. EPA. Economic Analysis of the Final Rule to Modify Reporting of Persistent
Bioaccumulative Toxic Chemicals Under EPCRA Section 313. Office of
Pollution Prevention and Toxics. October 1999.
2. U.S. EPA. 1990 Emissions Inventory of Section 112 (c) (6) Pollutants.
Emissions, Monitoring, and Analysis Division and Air Quality Strategies and
Standards Division. Research Triangle Park, North Carolina. June 1997.
3. Kroschwitz, I. (Ed.) Kirk-Othmer 's Encyclopedia of Industrial Chemicals. 4th ed.
John Wiley and Sons. New York. 1994.
4. Westberg, H. et.al. Emissions of Some Organo-chlorine Compounds in
Experimental Aluminum Degassing with Hexachloroethane. Applied
Occupational and Environmental Hygiene 12 (3). March 1997. pages 178-183.
5. Environment Canada. Supplementary Guide for Reporting to the National
Pollutant Release Inventory (NPRI) -Alternate Thresholds - 2000, Emission
Factors Database, National Pollutant Release Inventory. January 2001.
http://www.ee.gc.ca/pdb/npri/npri_gdocs_e.cfm#gdocs
6. Malaiyandi, M., A. Benedik, A. P. Holko, and J. J. Bancsi. Measurement of
potentially hazardous polynuclear aromatic hydrocarbons from occupational
exposure during roofing and paving operations, pages 471-489. In: M. Cooke,
A. J. Dennis, and G. L. Fisher (Eds). Polynuclear Aromatic Hydrocarbons:
Physical and Biological Chemistry. Sixth International Symposium. Batelle
Press. Columbus, OH. 1982. (Cited in American Petroleum Institute (API).
Transport and Fate of non-BTEXPetroleum Chemicals in Soil and Groundwater.
API Publication No. 4593. September 1994. page A-24).
7. U.S. EPA. Estimation of National Hexachlorobenzene Emissions for 1990.
Office of Air Quality Planning and Standards. Research Triangle Park, NC.
October 1993. pages 1-20 to 1-24.
8. U.S. EPA. Estimating Releases and Waste Treatment Efficiencies for the Toxic
Chemical Release Inventory Forms. 1999.
9. U.S. EPA. Compilation of Air Pollutant Emission Factors., AP-42.
10. State of California Environmental Protection Agency. Summary of Pesticide Use
Report Data. Department of Pesticide Regulation. Sacramento, CA. 1998.
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11. Boehm, P.D., J. Brown, and A. G. Requejo. The fate and partitioning of
hydrocarbon additives to drilling muds as determined in laboratory studies.
pages 545-576. In: F.R. Engelhardt, J. P. Ray, A. H. Gillam (Eds), Drilling
Wastes. Elsievier Applied Science Publishers. 1989. (Cited in American
Petroleum Institute (API). Transport and Fate of non-BTEXPetroleum
Chemicals in Soil and Groundwater. API Publication No. 4593. September
1994. pageA-23).
12. Wang, Zhendi, et.al. Using systematic and comparative analytical data to
identify the source of an unknown oil on contaminated birds. Journal of
Chromatography A. 775. 1997. page 260.
13. Guerin, M. R. Energy sources ofpolycyclic aromatic hydrocarbons. Oak Ridge
National Laboratory, Oak Ridge, TN. Conf. 770130-2. 78 pp. 1997. (Cited in
American Petroleum Institute (API). Transport and Fate of non-BTEX Petroleum
Chemicals in Soil and Groundwater. API Publication No. 4593. September
1994. page A-12).
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