vvEPA
United States
Environmental Protection
Aaencv
Office of Information
Analvs is and Access
March 2000
EPA
220/
2000.1
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS:
Spring 2000
ONE DAY WORKSHOP
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TRAINING DISCLAIMER
This document was developed for the sole purpose of helping potential reporters
understand and comply with the reporting requirements of section 313 of the Emergency
Planning and Community Right-To-Know Act (EPCRA). Nothing in this document is intended
to independently alter, supplement, or revoke the statutory and/or regulator) requirements
imposed by EPCRA section 313 and the applicable regulations at 40 CFR 372. et seq. Although
these training materials provide an overview of the section 313 reporting requirements, facilities
should consult the statute and regulations when developing threshold determinations and
calculating releases and other waste management amounts. Facilities should he aware thai EPA
also provides guidance documents containing both sector specific guidance and guidance on
specific elements of the EPCRA section 313 program. Covered facilities are encouraged 10
consult these guidance documents for additional assistance. Facilities may also receive
assistance by contacting the EPCRA Hotline at (800) 424-9346. This document was prepared
specifically for Reporting Year 1999. for reports due on July 1. 2000. Facilities should he aware
thai EPA may promulgate regulatory changes to the EPCRA section 313 program that may alter
reporting requirements for future reporting years.
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TOXICS RELEASE INVENTORY
PROGRAM
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WHO MUST REPORT?
Facilities (Private- and Public-sector)
in covered primary SIC code(s); and
With 10 or more full time employees (equivalent of 20,000
hours per year); and
That exceed manufacture, or process, or otherwise use
thresholds for each Section 313 chemical
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TRI REPORTING PROCESS
*MPOU: Manufacture (including import), process, or otherwise use
COVERED SIC CODES
Industrial Sector Primary SIC code
Manufacturing
Metal mining
Coal mining
Electrical utilities
Treatment,
Storage, and
Disposal facilities
Solvent recovery
services
Chemical
distributors
20-39
10 (except 1011, 1081, and 1094)
12 (except 1241)
4911, 4931, and 4939, limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce
4953, limited to RCRA Subtitle C permitted or interim
status facilities
7389, limited to facilities primarily engaged in solvent ;
recovery services on a contract or fee basis i
5169
Petroleum bulk
terminals
|5171
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FEDERAL FACILITIES
Federal facilities (covered by Executive Order 12856)
Owned or operated by Executive Branch agencies
» No restrictions based on SIC code
» Includes laboratories, prisons, parks, hospitals
With 10 or more full-time employees (equivalent of 20,000
hours per year)
That exceed manufacture, or process, or otherwise use
thresholds
Agency responsible for reporting on activities at Federal
facilities that are conducted by, for, or in support of the
agency
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DEFINITION OF "FACILITY"
"Facility - all buildings, equipment, structures, and other
stationary items which are located on a single site or
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)."
(EPCRA §329(4))
Establishment - an unique and separate economic unit of a
"facility"
Auxiliary facility - primarily supports another establishment's
activities
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MULTI-ESTABLISHMENT FACILITY
Three separate establishments located on contiguous/adjacent
property owned by same person(s), is one facility under EPCRA
Generic Products Food
Processing
(SIC 2033)
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Generic Products Farm
(SIC 0161)
Gen. Prod. Warehouse
(SIC 4222)
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AUXILIARY FACILiTY
Non-contiguous and non-adjacent to a covered establishment
Primary function is to support a covered establishment's
activities (e.g., warehouses, laboratories)
Assumes SIC code of covered establishment for reporting
purposes
Employee and chemical activity threshold determinations are
separate!
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AUXILIARY FACILITY
ACME Mfg. Facilities
(Warehouse is auxiliary facility of ACME Mfg.)
EMPLOYEE THRESHOLD
10 full-time employee (20,000 hours) threshold
Worked at or directly for facility
Includes operational staff, administrative staff, contractors,
dedicated sales staff, company drivers, off-site direct
corporate support
Does NOT include contract drivers or janitorial contractors
Determinations based on available time management
systems/data
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THRESHOLDS TRIGGERING SECTION 313
REPORTING
A facility meeting all criteria must file a TRI report for a Section
313 chemical if the facility:
Manufactured (including imported) more than 25,000
pounds per year, or
Processed more than 25,000 pounds per year, or
Otherwise used more than 10,000 pounds per year
Activity thresholds are mutually exclusive
Threshold calculations are based on cumulative quantities per
Section 313 chemical over the reporting year
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CATEGORIES OF MANUFACTURING
ACTIVITIES
Manufacturing - generating a Section 313 chemical
Intentionally producing chemicals for:
» Sale
» Distribution
» On-site use or processing (e.g., intermediates)
Coincidentally producing chemicals as impurities or
byproducts:
» At any point at the facility, including waste treatment and
fuel combustion
Importing
» "Cause" to be imported
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CATEGORIES OF PROCESSING ACTIVITIES
Processing - preparation of a Section 313 chemical for further
distribution in commerce
Using as a reactant to manufacture another substance or
product
Adding as a formulation component
Incorporating as an article component
Repackaging for distribution
» Including quantities sent off-site for recycling
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OTHERWISE USE
Otherwise using - includes most activities that are not
manufacturing or processing
Examples
Chemical processing aid (e.g., solvents)
Manufacturing aid (e.g., lubricants, refrigerants)
Ancillary activities (e.g., chemicals used to remediate
wastes)
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OTHERWISE USE (CONTINUED)
Otherwise use of a Section 313 chemical also includes
disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction if:
Section 313 chemical was received from off-site for the
purposes of further waste management, or
Section 313 chemical was manufactured as a result of waste
management activities on materials received from off-site
for the purpose of further waste management
Waste management activities include recycling, combustion for
energy recovery, treatment for destruction, waste stabilization
and release (including disposal)
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CALCULATING ACTIVITY THRESHOLDS
Calculate total amount of Section 313 chemical to a threshold
activity
Example:
» A plant uses MEK to manufacture liquid industrial
adhesive for distribution in commerce. The plant adds
27,000 Ibs. of MEK to the liquid adhesive-making
operation during the reporting year, but 3,000 Ibs. are
volatilized during the operation
» 27,000 Ibs. of MEK is processed, reporting required
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CALCULATING ACTIVITY THRESHOLDS
Activities that do NOT constitute an activity threshold
Storage
Remediation of on-site contamination
Re-labeling without repackaging
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SECTION 313 CHEMICAL LIST
SECTION 313 CHEMICALS AND CHEMICAL
CATEGORIES
Dynamic, evolving list
Additions
Deletions
- Modifications
Petition process to add or delete chemicals or forms of
chemicals
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CHEMICAL LIST CHANGES
Proposed for deletion
Phosphoric acid
Chromite ore mined in the Transvaal Region of South Africa
and the unreacted ore component of the chromite ore
processing residue (COPR)
Deletion proposals denied
MEK
MIBK
Acetonitrile
EPCRA SECTION 313 CHEMICAL
QUALIFIERS
Qualifiers - Listed chemicals with parenthetic qualifiers subject
to TRI reporting only if manufactured, processed, or otherwise
used in specified form. Below are some examples:
CHEMICAL
Aluminum
Zinc
Aluminum oxide
Asbestos
Hydrochloric acid
Sulfuric acid
CAS#
7429-90-5
7440-66-6
1344-28-1
1332-21-4
7647-01-0
7664-93-9
QUALIFIER
Fume or dust
Fume or dust
Fibrous forms
Friable forms
Acid aerosols
Acid aerosols
Not reportable unless present in the specified form
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METAL COMPOUND CATEGORIES
Consider the entire weight of the compounds in the category
when determining thresholds
Include only the weight of the parent metal of the category (e.g.,
copper for copper compounds) when calculating releases and
other waste management quantities
DETERMINING THRESHOLDS FOR METAL
COMPOUNDS
Multiple Compounds Within A Mixture Example
A facility processes 200,000 pounds of a mixture containing
10% zinc chromate and 15% chromium dioxide by weight
Quantity toward chromium compounds threshold
(10% + 15%) x (200,000) = 50,000 pounds
- Quantity toward zinc compounds threshold
(10%) x (200,000) = 20,000 pounds
25,000-pound processing threshold applies; chromium
compounds are reportable and zinc compounds are not
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NITRATE COMPOUNDS
Water dissociable nitrate compounds category
For threshold determinations, use the weight of the nitrate
compound, but use only the weight of the nitrate ion portion
when calculating releases and other waste management
quantities
Nitrate compounds are produced when nitric acid is
neutralized
includes compounds like sodium nitrate, silver nitrate, and
ammonium nitrate
NON-METAL COMPOUND CATEGORIES
Consider the entire weight of the compounds in these
categories when determining thresholds
Include the entire weight of the compounds in the category
when calculating releases and other waste management
quantities for all compounds in these categories
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XYLENE AND XYLENE ISOMERS
If data do not specify o-, m-, or p- isomers of xylene, calculate
thresholds, release and other waste management quantities
based on "xylene (mixed isomers)"
If data specifies o-xylene, m-xylene, or p-xylene individually,
calculate thresholds, release and other waste management
quantities based on the individual isomers
If thresholds are exceeded for more than one isomer,
releases and other waste management quantities can be
consolidated in one report as "xylene (mixed isomers)"
Same logic applies to cresol, toluene diisocyanates
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ACID AEROSOLS THRESHOLD
DETERMINATIONS
Sulfuric Acid Aerosols Formation in Stacks from Combustion
Processes
Sutfuric acid aerosols are formed in flue gas during the
combustion of fuel oil, coal, and other sulfur-containing
fuels
Water and sulfur trioxide, products of fuel combustion, react
quickly to form sulfuric acid
See Guidance for Reporting Sulfuric Acid (March 1998) for
specific calculations
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ACID AEROSOLS THRESHOLD
DETERMINATIONS
Acid Reuse Systems (Sutfuric and hydrochloric acid only)
To calculate the amounts manufactured and otherwise used
the facility may apply the total volume of acid in the system
acid only once toward the threshold and the amount of
virgin added to the system during the RY.
Total System Volume + Total Virgin Acid Added
= Amount Acid Aerosols Manufactured/Otherwise Used
See Guidance for Reporting Sulfuric Acid (March 1998) for
specific calculations
ACID AEROSOLS THRESHOLD
DETERMINATIONS
Acid Aerosols Generated in Storage Tanks
The amount of acid aerosol manufactured is determined by
the average amount that exists in the atmosphere above the
acid solution during the year.
Acid Aerosols Removed by Scrubbers
* Non-aerosol forms of sulfuric/hydrochloric acid are not
reportable under EPCRA Section 313; therefore, acid
aerosols removed by scrubbers are converted to a non-
reportable form, the quantity removed by the scrubber
should be reported as having been treated for destruction
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CHEMICALS MODIFIED
Ammonia
Requires threshold determination and release and other
waste management quantity calculations for aqueous
ammonia from any source (i.e., anhydrous ammonia in
water or water dissociable ammonium salts) be based on 10
percent of the total ammonia present in aqueous solutions
Anhydrous ammonia - include 100% for thresholds and
releases
» Including air releases from aqueous ammonia
Effective RY 1994
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CHEMICALS MODIFIED
Glycol ethers category
Removed surfactant glycol ethers from category (59 FR
34386, 7/5/94)
Common glycol ethers still in category include: .
» 2-Butoxyethanol (CAS #111-76-2)
» Diethylene glycol monoethyl ether acetate
(CAS #112-15-2)
» Diethylene glycol monobutyl ether (CAS # 112-34-5)
Effective RY 1993
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ADMINISTRATIVE STAYS
No reporting required for the following chemicals until further
notice
2,2-Dibromo-3-nitrilopropionamide (DBNPA)
(CAS #10222-01-2)
» Effective RY 1995
Hydrogen sulfide (CAS # 7783-06-4)
» Effective RY 1994
MethyI mercaptan (CAS #74-93-1)
» Effective RY 1994
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SECTION 313 REPORTING
EXEMPTIONS
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SECTION 313 EXEMPTIONS
Originally designed for manufacturing facilities to:
Reduce burden of reporting associated with small or
ancillary chemical uses
If an exemption applies, then the amount of an EPCRA
Section 313 chemical subject to the exemption does not
have to be included in:
» Threshold determinations
» Release and other waste management reporting
» Supplier notification
Recognize that exemptions only apply to certain limited
circumstances
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SECTION 313 EXEMPTIONS
Types of exemptions
De minimis
Articles
Laboratory activities
Motor vehicle maintenance
Routine janitorial or facility grounds maintenance
Structural components
Personal use
Intake water and air
Mining (extraction activities and overburden)
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DE MINIMIS EXEMPTION
The quantity of a Section 313 chemical in a mixture or other
trade name product is eligible for the exemption if the chemical
is:
An OSHA-defined carcinogen present at a concentration of
less than 0.1% by weight
or
Any other Section 313 chemicals present at a concentration
of less than 1% by weight
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption can apply to:
Chemicals in mixtures or other trade name products
processed or otherwise used
Chemicals coincidentally manufactured as impurities that
remain in products
Chemicals imported in mixtures or other trade name
products
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption does not apply to:
Manufacturing chemicals (in most cases)
Manufacturing chemicals as by-products
Coincidentally manufacturing chemicals
» As by-products of waste treatment or fuel combustion
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DE MINIMIS EXEMPTION
How It Works
De minimi's exemption does not apply to:
Wastes and waste streams, from non-exempt sources, that
are processed or otherwise used
» Wastes received from off-site for purposes of on-site
incineration
Releases and other waste management activities from
mixtures or other trade name products that are not
associated with a processing or otherwise use activity
» Material storage not associated with processing or
otherwise use activities
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DE MINIMIS EXEMPTION
How It Works
De minimis concentration for toluene is 1.0% (not an OSHA
carcinogen)
Cleaning
Mixture
0.5% Toluene
(exempt)
Raw Material
Mixture
90% Toluene
(not exempt)
Toluene in cleaning mixture is below de minimis concentration
and is eligible for the exemption
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DE MINIMIS EXEMPTION
How It Works
Processing a Section 313 chemical in a mixture to below the de minimis
concentration does not exempt the chemical from threshold determinations and
release and other waste management calculations
Raw Material
Primer Mixture
(90% Toluene)
Toluene > 1%
De minimis exemption does not apply
Threshold determination required
Release and other waste management
calculations required
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Paint Products
<<1%Toluene)
Toluene <1%
De minimis exemption does not apply
I Threshold determination required
Release and other waste management
I calculations still required 9
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DE MINIMIS EXEMPTION
How It Works
Processing a Section 313 chemical in a mixture to above the de
minimis concentration triggers threshold determinations and release
and other waste management calculation requirements
Petroleum
products
containing
concentrated
toluene
Crude oil
containing trace
amounts of
toluene
Toluene < 1%
De minimis exemption can apply
Do not include in threshold
Do not include in release and other waste
management calculations
| Toluene >1%
De minimis exemption does not apply
Threshold determination required
Release and other waste management
calculations required 1 0
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ARTICLES EXEMPTION
"Article" is defined as an item that is already manufactured
and:
Is formed into a specific shape or design during
manufacture; and
Has end-use functions dependent in whole or in part on its
shape or design during end-use; and
Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility
EPCRA Section 313 chemicals otherwise used to manufacture
an article are not exempt
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ARTICLES EXEMPTION
How It Works
Releases from an article may negate the exemption. To
maintain the article status, total releases from all like items
must be:
In a recognizable form
Recycled or
0.5 pounds or less (may be rounded down to zero)
If more than 0.5 pounds of a Section 313 chemical are released
from all like items in a non-recognizable form and is not
recycled, none of the items meet the articles exemption.
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ARTICLES EXEMPTION
How It Works
Example:
Wire is cut to specified lengths. Wastes include off-spec cuts
and dust.
Dust and off-spec cuts not recognizable as articles, released
from like items in quantities greater than 0.5 pounds, and
not recycled, negate the article status
- Generation of off-spec cuts that are recognizable as articles
will not, by itself, negate the article status
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LABORATORY ACTIVITIES EXEMPTION
Section 313 chemicals manufactured, processed, or otherwise
used in certain laboratory activities, performed under the
supervision of a technically qualified individual, may be eligible
for the exemption
Activity must occur in a laboratory to be exempt
Laboratories, themselves, are not exempt
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LABORATORY ACTIVITIES EXEMPTION
Definition of technically qualified individual (40 CFR 720.3(ee))
Capable of understanding the health and environmental
risks associated with the chemical substance which is used
under his or her supervision because of education, training,
or experience, or a combination of these factors;
Responsible for enforcing appropriate methods of
conducting scientific experimentation, analysis, or chemical
research to minimize such risks; and
Responsible for the safety assessments and clearances
related to the procurement, storage, use, and disposal of the
chemical substance as may be appropriate or required
within the scope of conducting a research and development
activity.
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LABORATORY ACTIVITIES EXEMPTION
How It Works
Section 313 chemicals manufactured, processed, or otherwise
used in these laboratory activities are eligible for the exemption
Sampling and analysis
Quality assurance
Quality control
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LABORATORY ACTIVITIES EXEMPTION
How It Works
Section 313 chemicals manufactured, processed, or otherwise
used in these laboratory.activities are NOT exempt
Any activities conducted outside laboratories
Specialty chemical production
Pilot-scale plant operations
Support services
Photo processing
Equipment maintenance / cleaning
MOTOR VEHICLE MAINTENANCE
EXEMPTION
Section 313 chemicals otherwise used to maintain motor
vehicles operated by the facility are eligible for the exemption
Examples of motor vehicles eligible for the exemption include
cars, trucks, and forklifts
Examples of exempt motor vehicle maintenance:
Body repairs
Parts washing and plating
Fueling and adding other fluids (e.g., ethyiene glycol)
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ROUTINE JANITORIAL OR FACILITY
GROUNDS MAINTENANCE EXEMPTION
Section 313 chemicals contained in products otherwise used
for non-process related routine janitorial or facility grounds
maintenance are eligible for the exemption
Phenol in bathroom disinfectants
Pesticides in lawn care products
Section 313 chemicals otherwise used in the following process-
related activities are not exempt
Facility equipment maintenance
Cleaning or maintenance activities that are integral to the
production process of the facility
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STRUCTURAL COMPONENT EXEMPTION
The otherwise use of Section 313 chemicals, that are part of
structural components of a facility, are eligible for the
exemption provided the structure is not process related
Copper in pipe used in construction of employees'
bathroom facilities
Metals, pigments, and solvents in paint applied to facility
structure
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OTHER SECTION 313 EXEMPTIONS
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lu
Section 313 chemicals contained in non-process related items
for employee personal use
HCFC 22 in air conditioners used solely for employee
comfort
Chlorine used to treat on-site potable water
Phenol in a facility medical dispensary
Section 313 chemicals found in intake water (e.g., process
water and non-contact cooling water) and air (e.g., used as
compressed air)
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SIC CODE-SPECIFIC EXEMPTIONS
SIC Code 12: Coal mining extraction activities are exempt from
threshold determinations and release reporting (40 CFR
372.38(g))
Coal extraction: the physical removal or exposure of ore,
coal, minerals, waste rock, or overburden prior to
beneficiation, and encompasses all extraction-related
activities prior to beneficiation. (40 CFR 372.3)
SIC Code 10: Chemicals in overburden are specifically exempt
from TRI reporting (See 40 CFR 372.38(h))
Overburden: unconsoiidated material that overlies a
deposit of useful materials or ores (40 CFR 372.3) -,,
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EXERCISE #1: THRESHOLD QUIZ
Purpose: Familiarize participants with the criteria for TRI reporting, including thresholds for
manufacturing, processing or otherwise using listed chemicals, which determine
whether or not a facility must submit a Form R for a listed chemical.
Take-Away: Knowledge and understanding of TRI reporting thresholds.
Instructions: Read each question carefully. Using your knowledge of TRI reporting thresholds,
choose the best of the four answers.
1. A facility begins the reporting year with an inventory of 24,600 pounds of copper
sheets for its decorative mail box manufacturing operation, all of which is used in the
reporting year. All sheets are cut and grinded into different diameters during the
processing operation which generated less than 10 pounds of fugitive emissions of copper
during the reporting year. In addition, the facility processes 500 pounds of copper ingots
into wire which is sold to an electronics firm. However, the 500 pounds of copper ingots
were obtained by on-site reuse of the scrap copper generated from the mail box
manufacturing operation. Is this facility's processing of copper subject to EPCRA
Section 313 reporting and why?
a. No, because, the facility is reprocessing 500 pounds of copper, only a total of 24.600
pounds of copper would be applied to the 25,000 pound threshold determination for
processing.
b. No, because the scrap was reused, the article exemption from threshold determinations
is maintained for all uses of copper.
c. Yes, because 24,600 pounds of copper sheets and 500 pounds of copper ingots were
both processed, therefore the facility exceeded the 25,000 pound processing threshold.
d. No. because the 24,600 pounds of copper sheets were present in the facility prior to the
reporting year, it is not calculated for threshold determinations. Only amounts newly
added to the facility are calculated for threshold determinations.
2. A facility processes 100,000 pounds of a mixture containing 25% zinc chromate, and 25%
chromium dioxide by weight. For purposes of Section 313 reporting, how much zinc and
chromium were processed?
a. 25,000 pounds zinc compounds, and 25,000 pounds of chromium compounds
b. 25,000 pounds zinc, and 25,000 pounds chromium
c. 25,000 pounds zinc, and 50.000 pounds chromium
d. 25.000 pounds zinc compounds, and 50,000 pounds chromium compounds
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A facility' buys a solution containing 29 percent 1,1,1-trichloroethane and processes it as a
constituent of a cleaning solution that they sell in retail stores. The 1,1,1-
trichloroethane is present in final product at 0.5 percent. The product is packaged into
one-gallon containers. What amounts of the 1,1,1-trichloroethane in mixtures must
the facility consider for threshold determinations?
a. Any amount used within the facility during the reporting year, except the amount
distributed through retail outlets to consumers, must be considered processed.
b. Because the mixture was otherwise used, it is not eligible for the de minimis
exemption. The quantity used must be applied to the otherwise use threshold.
c. Because the mixture was received and processed in concentrations above the de minimis
for 1,1,1-trichloroethane, all quantities must be applied to the processing threshold.
d. Only amounts distributed into commerce need to be considered towards the processing
threshold, and because these quantities are present below the de minimis concentration.
they are exempt.
Which of the following qualifies as a section 313 reporting exemption?
a. Like "articles" that release over 10 pounds of a section 313 chemical, not recovered,
under regular normal processing or use.
b. Painting process equipment at the facility.
c. Chemical use in non-process related routine janitorial or facility grounds maintenance.
d. Laboratory support activities.
During the reporting year, your facility receives 20,000 pounds of chlorine in solution.
10,000 pounds of the chlorine is transferred to a tank to make a bleaching mixture, where
its concentration drops below the de minimis level, which is then sold and distributed in
commerce. 5,000 pounds of the original mixture is used to treat the drinking water
consumed by employees. The remaining 5,000 pounds of the original mixture is used
throughout the plant to clean process equipment. Wastewater from the cleaning and
bleach production operations is released with chlorine levels well below the de minimis
level. Which of the following is true?
a. All uses of the chlorine are subject to section 313 reporting because the concentration of
the received mixture is well above the de minimis level and the threshold limit for
otherwise use has been met.
b. Only the use of chlorine for drinking water is exempt from section 313 reporting.
c. Only the drinking water and cleaning operations will be exempt from section 313
reporting due to the personal use and routine maintenance exemptions, respectively.
d. The drinking water and cleaning uses are covered under the personal use and routine
maintenance exemptions, respectively. The bleach production operation and the
waste water generated in conjunction with this operation are not exempt from section
313 reporting; however, the wastewater from the cleaning operations are exempt.
-------
DETE
RMININC; THRESHOLD;
TRI REPORTING PROCESS
identify Section 313
chemicals
manufactured.
processed. OF
otherwise used at
the site
Determine the
quantity of
Section 3] .3
chemicals
and how they are
manufactured,
processed, or
otherwise used on-
Complete
Form
-------
DETERMINING THRESHOLDS
identify what Section 313 chemicals are handled on-site
Identify concentrations of Section 313 chemicals
Collect data and calculate quantities towards each threshold
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DETERMINING THRESHOLDS
Identify Chemicals and
Concentrations:
MSDS
Specifications
Waste Profiles
Process Knowledge
Other References {AP-42,
Merck Index)
Supplier Notification
Collect Data to Calculate
Thresholds:
Inventory Records
Throughput/Production Data
Purchase Records
EPCRA or Other Env. Reports
Ask the User
Call the Vendor
-------
DETERMINING CONCENTRATIONS OF
SECTION 313 CHEMICALS
Chemical component - include in threshold "each listed Section
313 chemical known to be present" at a concentration greater
than the de minimis limits (EPCRA §313 (g){1)(C))
"Known" - knowledge based on MSDS, analytical data,
process knowledge, labeling, literature, other vendor-
supplied information, or existing analysis
- If concentration is unknown, threshold determination for the
Section 313 chemical is not required (40 CFR 372.30(b)(3))
SUPPLIER NOTIFICATION FOR
MIXTURES AND OTHER TRADE NAME
PRODUCTS
Supplier Notification - requires suppliers to facilities described
in 40 CFR 372.22 to:
Identify Section 313 chemical(s) by name and CAS number
Identify Section 313 chemical(s) as being subject to EPCRA
Section 313 requirements
Provide concentration (or range) of Section 313 chemicals
in mixtures and other trade name products (not wastes)
Provide notification at least annually in writing or attached
to the MSDS
Update notification when changes occur
Only facilities in primary SIC codes 20-39 must initiate the
notification
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-------
DETERMINING CONCENTRATIONS IN
MIXTURES OR OTHER TRADE NAME
PRODUCTS
Include a Section 313 chemical in the threshold determinations
if you know:
Exact concentration - use concentration provided
Upper bound - use upper limit
Range - use the midpoint of the range
Lower bound - subtract out other known constituents,
create a range, and use the midpoint of range
Note: Thresholds are based on weight in pounds.
DETERMINING CONCENTRATIONS
IN WASTES
De minimis exemption does not apply to wastes that are
processed or otherwise used
if concentration is exact, upper bound, range, or lower bound,
use the guidance for mixtures and other trade name products
If concentration is below detection limit, use engineering
judgment:
If the Section 313 chemical is expected to be present,
assume 1/2 of full detection limit
If the Section 313 chemical is not expected to be present,
assume 0
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-------
MEETING MULTIPLE THRESHOLDS
There are many situations where one Section 313 chemical
must be counted towards multiple activity thresholds
Section 313 chemicals manufactured or imported on-site,
then used or incorporated into a product (processed)
Section 313 chemicals formed during destruction of wastes
received from off-site and subsequently destroyed on-site
(manufactured and otherwise used)
Section 313 chemicals that are otherwise used on-site,
recycled, then processed
Section 313 chemicals should not be counted twice towards the
same activity threshold
9
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WATCH FOR DOUBLE COUNTING!!!
For threshold determinations, Section 313 chemicals reused or
recycled at a facility: count original amount used only once
Note: Section 313 chemicals sent off-site for recycling and
returned to the facility are considered new materials and
counted for threshold determinations
For materials in use from previous years: count only the
quantity added during current reporting year
10
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-------
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
Multi-establishment facility
» Apply threshold determination on aggregate amount of
chemicals used at facility
» Able to file separate Form R reports for each
establishment if they are distinct economic entities
(must be designated as part of a facility on Form R)
» Report all releases and other waste management
activities of reportable Section 313 chemicals
» Avoid double-counting of chemicals involved in intra-
facility transfers
II
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CALCULATING THRESHOLDS
Consider all activities
Chemicals used in neutralization, refrigerants, cleaners,
paints, lubricants (for non-vehicles), fuel (for non-vehicles),
refractory bricks
Consider all sources
Purchasing/Inventory Control
Contractors
Bulk deliveries
Capital purchases
"Credit card" or "emergency" purchases
-------
ORCHESTRATING DATA COLLECTION
Methods for orchestrating data collection
Coordinate with purchasing/vendors
Develop inventory controls
Require requisition or "sign out" procedure for Section 313
chemicals
Take year-end inventories
Identify ALL chemical purchasing and usage
Threshold determination worksheets
13
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OPTIONAL SECTION 313 THRESHOLD DETERMINATION WORKSHEET
Facility Name: OM.%J f?HE.MIf"AL Dale Worksheet Prraared:
Tonic Chemical or Chemical
Reporting Year:
Category: Tftl'ul!;nt Prepawrf Rvr .I.S.P.
Step 1. Identify amounts of the toxic chemical manufactured, processed, or otherwise used.
>l hlure Name Paris Washer Fluid
4
5
6
7
SulHmal:
"ir,:r fzz. '"'"^"l
Purcnasitig 50 10.000
Vendor 5 10.000
Purchasing 40 10.000
An...... ,.( ,h,. L,.,^ T,», Ch«ml[.l K, A«»,t> » Ib,,:
M»nuU«tuml
(A) lh».
Pnitcthnl
(B> Ihv
Ottwm iw U«d
S.QflO
1.500
4,000
(0 1M» IhL
Step 2. Identify exempt forms of the toxic chemical that have been included in Step 1.
Mkluri: Name ** Lteieii Ahtnc
1. Yellow Safety Paint
2.
3.
4.
<.
A.
7.
*..,,*
£££: *££%%££;
Struct. Cor p. 100
Step 3. Calculate the amount subject to threshold:
Compare to thresholds for section 313 repurtine.
If any threshold is met. reporting is required for all activities. Do
E^r, A«,,,n, .,1 ,., T,,,,. 1 kl-mlt,, ,n. Ah.,.. ,m I..,:
>l»nufm,|Urcd
IA,t Jhs.
(A - A, p )t>\.
fnu-k'^Ktl
IB.) Ihv
(B-B.I Ibs.
35.MH) Ibv 25.000 IPS.
ot submit this worksheet with Form R. Rei
OtbrntMv lj«cil
1.500
1C, 1 '.*« Ihv
1C -C.I ».000 Ib.
L 0.000 Ibi.
aitt for your rvcords. « .
-------
MANAGEMENT PRACTICES
Begin early
Implement a program to gather "real-time" data on usage
Searches for historical information can be difficult
Use a team approach
* Include all relevant personnel (e.g., engineering,
environmental, operations)
Spread the burden
RECORDKEEPING
Detailed records
Improve reporting accuracy and data quality
Reduce replication of effort from year to year
Well-labeled calculations and assumptions
Serve as standard operating procedures (SOPs) for future
years
Ensure consistency from year to year, especially if
personnel responsible for reporting change
Ail records used to complete Form R must be kept for three
years (40 CFR 372.10}
EPA will review records during a data quality audit 16
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-------
TRI RELEASE AND OTHER WASTE
MANAGEMENT REPORTING
REPORTING METHOD
Identify potential release and other waste management sources
Identify available data and tools
Collect data
Estimate quantity of chemical being released and otherwise
managed as waste
Document your work
-------
I !
TOOLS AND DATA SOURCES FOR
CALCULATING REPORTING ESTIMATES
Process flow diagrams
Waste management manifests, invoices, and waste profiles
Environmental monitoring data
Permit applications
RCRA (BRS), NPDES, CAA, CERCLA and other env. reports
Engineering calculations and other notes
EPA guidance
I
CALCULATING REPORTING ESTIMATES
Consider all sources (routine and non-routine)
Reasonable estimates are required by law
Facility determines best approach
Data and approach must be documented
-------
TECHNIQUES FOR ESTIMATING
CHEMICAL QUANTITIES
Use of monitoring data
Mass balance calculation
Use of emission factors
Engineering calculations
ANALYSIS OF MONITORING DATA
Product of measured concentrations, volumetric flow rates, and
density equals pounds of chemical released per year
Most commonly used for wastewater (Discharge monitoring
reports (DMRs))
Use Basis of Estimate code "M" if calculations based primarily
on monitoring data
-------
MASS BALANCE CALCULATION
Mass Balance is based on the law of conservation of mass
Input + Generation = Output + Amount Reacted + Accumulation
Most useful in simple situations
Use Basis of Estimate code "C"
Example: Estimating fugitive air emissions from storage
containers and process equipment
USE OF PUBLISHED EMISSION FACTORS
Values used to describe the quantity of chemical released as a
function of:
Specific chemical used
Specific process used
Specific equipment used
Available in Compilation of Air Pollutant Emission Factors (AP-
42)
m Use Basis of Estimate code "E"
-------
ENGINEERING CALCULATIONS
Calculations based on best engineering judgment/assumptions
Calculations based on process knowledge
Use of non-chemical-specific emission factors
Use of non-published emission factors
Use Basis of Estimate code "O"
SIGNIFICANT FIGURES
Significant figures should reflect the precision of the estimate
- EPA recommends using two significant figures when
reporting releases and other waste management estimates
If estimate is more precise, additional significant figures
should be used
for estimates under 1,000 pounds, a range code can be
used:
» A= 1-10 Ibs.; B = 11-499 Ibs.; C = 500-999 Ibs.
10
-------
"NA" VS. "0"
Use "NA" (not applicable) when no possibility of Section 313
chemical being released to or otherwise managed as waste in
that media
Example: Facility has no on-site landfill
Use "0" when no release to or other waste management in the
specific media occurs, but is possible
Example: Discharge to water is zero; however, release
possible if control equipment fails
Must indicate a Basis of Estimate code (i.e., M, C, E, O) for
all numerical estimates, including "0"
II
FUGITIVE EMISSIONS
Part II, Section 5.1: Fugitive or non-point air emissions
Approach: ID potential sources -> ID data/tools -> estimate
Data Sources/Tools
Engineering calculations
Emission factors
Monitoring data
Mass balance
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-------
STACK EMISSIONS
Part II, Section 5.2: Stack or point-source air emissions
Approach: ID potential sources -> ID data/tools -> estimate
Data Sources/Tools
» Air permit applications
» CAA Title V air inventories
» Process and production data
» Engineering calculations
» Mass balance
» Emission factors
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WASTEWATER DISCHARGES
Part II, Section 5.3: Release to stream or water body and Part II,
Section 6.1: Discharges to POTW
Approach: ID potential sources --> ID data/tools -> estimate
Potential release sources
Wastewater treatment facility discharge
Storm Drains
Data/Tools
Monitoring, if available
DMRs or other required monitoring data
NPDES permits/permit applications
Process knowledge and/or mass balance
-------
CALCULATING WASTEWATER
DISCHARGES
Calculate the yearly pounds of methanol discharged using the
following data concerning wastewater discharges of methanol:
Date Cone. (mg/L) Flow (MGD) Amt.(lbs./day)
3/1 1.0 1.0 8.33
9/8
0.2
0.2 .33
Average = 4.33
(4.33 Ibs./day) x (365 days/yr.) = 1581 Ibs./yr.
MGD = million gallons per day
1 mg/L = 8.33 lbs./million gal
RELEASED TO LAND ON-SITE
Approach: ID potential sources -> ID data/toots ->estimate
Potential sources of release to land
Landfills
- Surface Impoundments
Spills
Leaks
Data/tools:
Operating records/analytical data
Spill reports
Process knowledge
16
-------
WASTE RELEASED TO LAND ON-SITE-
MIGRATION
Migration of a Section 313 chemical contained in waste
released (including disposal) may occur
* Migration of reportable chemical within one environmental
medium (e.g., leachate from landfill)
» Only required to report initial release of chemical to the
environment
Migration of chemical from one environmental medium to
another (e.g., volatilization from a landfill) within the
reporting year
» Release estimates should be calculated based on
ultimate disposition during reporting year
17
I
ON-SITE WASTE MANAGEMENT
Examples
Air pollution control devices (Section 7A)
Wastewater treatment processes (Section 7A)
Energy recovery devices (Section 7B)
Recycling devices (Section 7C)
Consistency between Sections 7 and 8
-------
OFF-SITE WASTE MANAGEMENT
Approach: ID potential sources -> ID data/tools --> estimate
Potential sources of off-site waste management
Identify final disposition of Section 313 chemical
» Disposal
» Waste treatment
» Energy recovery
» Recycling
Data/tools
Waste manifests and vendor receipts
RCRA reports
Waste characterization - analyses, profiles
19
MAXIMUM QUANTITY ON-SITE
Part It, Section 4.1: Maximum amount on-site at any time during
the calendar year
Based on amount in storage, process, and wastes
Not the same as Tier II maximum amount on site
» Tier II is usually by mixtures, Form R is chemical-specific
» Tier II excludes hazardous wastes, Form R does not
Data sources
Tier II records/calculations
Waste inventory data
20
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BEST PRACTICE: RECORDKEEPING
importance of good recordkeeping
Detailed records improve reporting accuracy and data
quality
Well-labeled calculations and engineering assumptions
serve as standard operating procedures for future years
» Reduce replication
» Ensure consistency
Requirements
All records used to complete Form R reports must be kept
for three years (40 CFR 372.10)
EPA will review records during a data quality audit
21
-------
FORM R / FORM A OVERVIEW
AUTOMATED TRI REPORTING
SYSTEM (ATRS)
Voluntary option to submit form electronically
Forms submitted on diskette and loaded directly into EPA's TRI
Database
Windows 3.1, 95, 98, NT versions available
ATRS has built-in data validation program and pick lists
A signed ATRS - generated cover letter is the sole paper
requirement
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-------
OVERVIEW OF FORM R
Two principal types of information
Facility-specific
Chemical-specific
One form must be submitted to EPA and to the SERC/TERC for
each Section 313 chemical or chemical category exceeding
applicable thresholds
PART I: FACILITY INFORMATION
Identifies the facility
Name and address
TRI facility identification number
Provides key data for linking information to other databases
SIC code(s)
Identification numbers (RCRA, NPDES, Dun & Bradstreet,
Underground Injection Control)
Identifies key personnel
Technical contact
Public contact
-------
PART II: CHEMICAL-SPECIFIC
INFORMATION
Identifies the Section 313 chemical and its uses at the facility
Chemical identity
Activities and uses of the Section 313 chemical
Maximum amount on-site at one time
Identifies quantities released and managed as wastes
Total release of the Section 313 chemical to each medium
Transfers of waste to off-site locations (excluding transfers
for sale)
On-site waste treatment methods and efficiency(ies)
Identifies other waste management and source reduction
activities ,
PART II. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Total aggregate releases of Section 313 chemical to the
environment from the facility during calendar year
Report total releases of Section 313 chemical to each
environmental medium
In column A, Total Releases, report total quantity
A range code can be used for quantities less than 1,000
pounds)
» A = 1 -10 pounds
» B = 11 -499 pounds
» C = 500 - 999 pounds
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-------
PART II. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Basis of estimate codes
i
Monitoring data (M)
Mass balance (C)
Emission factor (E)
Other approaches and engineering estimates (O)
Use the code for the method used to estimate the largest
portion of the release
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PART II. SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
OFF-SITE LOCATIONS
Includes both off-site location information and quantities of
Section 313 chemicals transferred to off-site locations
Report quantities of a Section 313 chemical sent off-site to any
POTW or other location for recycling, energy recovery, waste
treatment, or disposal
Report only total quantity of a Section 313 chemical transferred
off-site, not entire waste
In Sections 6.1.A.1 and 6.2.A, Total Transfers, report total
quantity
A range code can be used for quantities less than 1,000
pounds
» A = 1 -10 pounds
» B = 11 -499 pounds
» C = 500 - 999 pounds 8
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PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
General waste stream type containing the Section 313
chemical, treatment method(s), influent concentration range,
estimate of treatment efficiency, and indication if information is
based on operating data
Report each waste treatment method that the Section 313
chemical undergoes
Include even if method has no effect on Section 313
chemical
Only data element in Form R focusing on the entire waste
stream rather than the Section 313 chemical in the waste
stream
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PART II. SECTION 7B: ON-SITE ENERGY
RECOVERY PROCESSES
Enter on-site energy recovery methods for Section 313
chemical
Section 313 chemical must be combustible and have a significant
heating value (e.g., 5,000 BTU/lb.)
Combustion unit is integrated into an energy recovery system
(e.g., industrial furnace, industrial kiln, or boiler)
Enter codes in descending order by quantities combusted
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) - Check here if no on-site energy recovery is applied to any wasti
stream containing the toxic chemical or chemical category.
-------
PART II. SECTION 7C: ON-SITE
RECYCLING PROCESSES
Enter methods used for on-site recycling of Section 313
chemical
Codes for recycling methods used are found in EPA
instructions document
Do not include energy recovery processes
Enter codes in descending order by quantities recycled
SECTION 7C. ON-SITE RECYCLING PROCESSES
Not Applicable (MA) - Check here if no on-site recycling is applied lo any waste
stream containing the toxic chemical or chemical category.
Recycling Method! Met l^lurMer cod«(i|]
11
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PHOTOCOPYING PAGES OF FORM R
Form R pages may be photocopied if additional space is necessary to
complete these sections (photocopying is not necessary with ATRS)
Section 6.1: Transfers to POTWs
Section 6.2: Transfers to Other Off-Site Locations
Section 7A: Waste Treatment Methods and Efficiency
When photocopying pages, you must complete the box on each page
to indicate the number of copies you are attaching
For the page being photocopied, enter in the left box the total number
of pages submitted including the original
original + number photocopied = total pages submitted
In the second box, indicate the position of the individual page
Example
If additional pages of Part ][. Sections 6.2/1,\ are attached, indicate the total number of pages in this
box f~~l and indicate w hich Part II, Sections 6.2/7 A page this is, here. D (example: 1.2.3. etc.)
12
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-------
-------
(IMPORTANT: Type or print: read instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 01/01/2001
Page 1 of 5
EPA
FORM R
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
United States Section 313 of the Emergency Planning and Community Right-to-Know. Act of 1986.
tnvironmentai protection a,so known gs Tjt|e m of the Superfund Amendments and Reauthorization Act
Agency
WHERETO SEND COMPLETED FORMS: 1. EPCRA Reporting Center 2. APPROPRIATE STATE OFFICE j Enter "X''here if Inis
P.O Box 3348 (See instructions in Appendix F) j is a revision
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
For EPA use onlv
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
No (Do not answer 2.2:
Yes (Answer question 2.2;
Attach substantiation forms)
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that t have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
information is true and complete and that the amounts and values in this report are accurate based on reasonable estimates
using data available to the preparers of this report.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name
Facility or Establishment Name or Mailing Atloressti* ciiftere;ii from street address)
Street |
Mailing Address
City/Coun!y/State/Zip Code
City/County/State/Zip Code
4.2
This report contains information for:
^Important : check a or b: check c if applicable)
An entire
facility
Part of a
facility c-
A Federal
facility
4.3
Technical Contact Name
TeieBnone Number (include area code)
4.4
Public Contact Name
Numr>er (include area code) I
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
4.6
Latitude
Decrees
Minutes
Seconds
Longitude
Degrees
Seconds
4.7
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
b.
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
i 5.2
Parent Company's Dun & Bradstreet Number
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
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Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical. Cateaorv or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a cnenmctii cnieriory.i
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
1.3
Generic Cnemical Name (Important: Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must oe structurally cesr.riain'p t
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
a. Produce b. I Import
n
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
3.2 Process the toxic chemical:
As a reactant
As a formulation component
As an article component
Repackaging
3.3 Otherwise use the toxic chemical:
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year)
(Enter range code or estimate*)
B. Basts of Estimate
(enter code)
C. % From Storm water
5.1
5.2
5.3
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
NA
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
5.4.1
Underground Injection onsite
to Class I Wells
! 5.4.2
Underground Injection onsite
to Class II-V Wells
NA
NA
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box. | (example: 1,2,3. etc.)
EPA form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
* Range Codes: A= 1 -10 pounds: B= 11-499 pounds: C= 500 - 999 pounds.
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Page 3 of 5
EPA FORM R
PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical. Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (Continued)
NA
A. Total Release (pounds/year) (enter range
code" or estimate)
B. Basis of Estimate
(enter code)
5.5
Disposal to land onsite
5.5.1A
RCRA Subtitle C landfills
5.5.1B
Other landfills
5.5.2
Land treatment/application
farming
5.5.3
Surface Impoundment
5.5.4 Other disposal
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A Total Quantity Transferred to POTWs and Basis of Estimate
6.1.A.1. Total Transfers(pounds/year)
(enter range code* or estimate)
6.1.A.2 Basis of Estimate
(enter code)
6.1.B.
POTW Name
POTW Address
City
State
County
6.1.B.
POTW Name
POTW Address
City
State
County
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box I and indicate the Part II, Section 6.1 page number in this box I (example: 1,2,3, etc.]
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2. Off-Site EPA Identification Number (RCRA ID No.)
Off-Site Location Name
Off-Site Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
Yes
No
EPA Form 9350-1 (Rev.04/97) - Previous editions are obsolete.
* Range Codes: A =1-10 pounds: B = 11 -499 nounds: C = 500 - 999 pounds.
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Page 4 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Mumber
Toxic Chemical. Category or Generic Name
j SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (Continued)
A. Total Transfers (pounds/year)
(enter range code* or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enler code)
1.
1.
1. M
2. M
3.
3. M
4.
4. M
6.2. Off-Site EPA Identification Number (RCRA ID No.)
Off-Site location Name
Off-Sile Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pounds/year)
(enter range code* or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. M
2.
2.
2. M
i 3.
3. M
4.
4- M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
i
Not Applicable (NA) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
a. General
Waste Stream
(enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
c. Range of Influent
Concentration
d. Waste Treatment
Efficiency
Estimate
e. Based on
Operating Data ?
7 A. 1c
7A. 1d
7A.1e
Yes No
7A.2c
7A.2d
7A.2e
Yes No
7A.3c
7A. 3d
7A.3e
Yes No
7A.4C
7A.4d
7A.4e
Yes No
7A.5c
7A. 5d
7A.5e
Yes No
! If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box
i and indicate the Part II, Section 6.2/7A page number in this box : | | (example: 1,2,3, etc)
EPA Form 9350-1 (Rev, 04/97) - Previous editions are obsolete.
* Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
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Page 5 of 5
! EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical. Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Check here if no on-site energy recovery is appl ed to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character cocfe(s)]
12 34
SECTION 7C. ON-SITE RECYCLING PROCESSES
DNot Applicable (NA) - Check here if no on-site recycling is applied la any waste
stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
1. 2. 3. 4.
6. 7. 8. 9.
5.
10.
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
8.1
8.2
8.3
8.4
8.5
8.6
B.7
8.8
8.9
8.10
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Quantity released "
Quantity used for energy recovery
onsite
Quantity used for energy recovery
offsite
Quantity recycled onsite
Quantity recycled offsite
Quantity treated onsite
Quantity treated offsite
Column A Column B
Prior Year Current Reporting Year
(pounds/year) (pounds/yean
Quantity released to the environment as a result of remedial actions.
catastrophic events, or one-time events not associated with production
processes (pounds/year)
Production ratio or activity index
Column C Column D
Following Year Second Following Year
(pounrjsjyean (nounds/yenr)
Did your facility engage in any source reduction activities for this chemical during the reporting year? If not,
enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activit es
(enter code(s}]
Methods to Identify Activity (enter codes)
a. b. c.
a. b. c.
a. b. c.
a. b. c.
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES NO
" Report releases pursuarH lo EPCRA Seclion 329(81 including "any spilling, leaking, pump ng, pouring, emitting, emptying, discnargmg.
in ec mo. escaping, leacning. dumping, or fnsnosing into the environment." Do not include any Quantity treated onsite or offstte
EPA Form 9350-1 (Rev. 04/97} - Previous editions are obsolete.
-------
-------
ALTERNATE THRESHOLD RULE
EPA published Final Rule (40 CFR 372.27; 59 FR 61501,
11/30/94)
Reduced reporting option for low annual reportable
amounts
» No Form R report
» No release, other waste management, or source
reduction reporting
» Submit certification form (Form A) each year
ALTERNATE THRESHOLD RULE
Criteria for using alternate threshold
Do not exceed 1,000,000 pounds manufactured, processed,
or otherwise used, and
Do not exceed 500 pounds of a Section 313 chemical
equivalent to the sum of the quantities released, transferred
off-site in wastes, and combusted for energy recovery,
recycled, or treated on-site.
-------
ALTERNATE THRESHOLD RULE
Recordkeeping
All documentation to support the determination, including:
» Inventory, purchasing, and sales records
» Release calculations
» Waste manifests or receipts
» Other waste management data
OVERVIEW:
FORM R VS. FORM A
Form A
Standard Reporting
Method
Use for all levels of
releases and other waste
management
Report releases, other
waste management, and
source reduction
activities
Recordkeeping
Requirements
Alternate Reporting
Method
Use for low annual
reportable amounts
(<500 Ibs.)
Submit Certification
Form
Recordkeeping
Requirements
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-------
(IMPORTANT: Type or print: read instructions before completing form)
Form Approved OMB Number: 2070-0143
Approval Expires: 01/01/2001 Page _1_of
A United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center 2. APPROPRIATE STATE OFFICE
P.O Box 3348 (See instructions in Appendix F)
Merrifiefd. VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2:
Attach substantiation forms)
No (Do not answer 2.2:
Go to Section 3)
2.2
is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1}
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best at my knowledge and belief, for .each toxic chemical listed in the statement, the annual reportable
amount as defined in 40 CFR 372.27 (a), did not exceed 500 pounds for this reporting year and that the chemical was
manufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Faci I i ly or E slablishmenl Name |
Facility or Establishment Name or Mailing Adoresstif different from street address)
Street
Mailing Address |
City/Couniy/State/Zip Code
City/County/State/Zip Code
4.2
This report contains information for: flmportanl : check c if applicable)
A Federal
facility
4.3
Technical Contact Name
Teleohone Mumper (include area code)
4.4
Intentionally left blank
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Numbers) (9 digits)
4.8
EPA Identification Number
(RCRA f.D. No) (12 characters)
4.9
Facility NPDES Permit
Nurnber(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Numberfs) (12 digits)
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-2
-------
IMPORTANT: Type or print; read instructions before completing form
Page of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION
TRIFID:
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number f Important: En'er only one number exactly as it appears on tne Section 313 list. Enter category coae if reporting a chemicBi category.)
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on tne Section 313 list.!
1.3
Generic Chemical Name (Imooroni: Complete only if Part I. Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on Ine Section 313 list Enter category coae if reporlinrj a cnemical coteuory t
1.2
Toxic Chemical or Chemical Category Name (Important; Enter only one name exactly as it appears on the Section 313 list i
1.3
Generic Chemical Name (Important: Complete only if Part I. Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important: Enter only one number exactly as it appears on me Section 313 list. Enter category coae if reporting s cnemical cmeaory.i
1.2
Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on tne Section 313 list.)
1.3
Generic Chemical Name (Important: Complete only if Part I. Section 2.1 is checked "yes". Generic Name must De struciurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numoers, letters, spaces and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (important: Enter onlv one number exactly as it appears on Ine Section 313 list. Enter category coae if reporting a cnemicol uaieuory.i
1.2
Toxic Chemical or Chemical Category Name (Important: £nter only one name exactly as it appears on me Section 313 lisl.)
1.3
Generic Chemical Name (Important: Complete only if Part I. Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section it you completed Section 1 above.]
2.1
Generic Chemical Name Piovided by Supplier (Important: Maximum of 70 characters, including numbers, letters, spaces and punctuation.)
EPA Form 9350-2
(Make additional copies of this page, if needed)
-------
ATRS SOFTWARE
Advantages of completing Form R or Form A electronically
Reduce error by covered facilities
Reduce data entry error by EPA
Reduced data entry redundancy
Photocopying pages of the Form R would not be required
Menu-driven screens with special "hot" keys displayed
"Pick lists" containing valid reporting codes
"Real-time" error checking and validation
Submission of forms on magnetic media is encouraged but not
17
required
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ATRS SOFTWARE
Technical Support
Phone: 703-816-4434
Fax: 703-816-4466
e-mail: tris.user.support@epcra.org
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II OVERVIEW OF POLLUTION PREVENTION
REPORTING _
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POLLUTION PREVENTION HIERARCHY
Source Reduction
Disposal or Other
Release to
Environment
-------
THINGS TO REMEMBER WHEN
COMPLETING SECTION 8
Key concepts
* Waste streams
Process streams
Reportable recycling
Source reduction activities
Develop consistent definitions for key terms
Across facility
Across agency/company
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
Column A - Prior Reporting Year Estimate
Column B - Current Reporting Year Estimate
Column C - Next Reporting Year Projection
Column D - Following Reporting Year Projection
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Page 5 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical. Category or Generic Name
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
1
.. , ,. .. ..,., Check here if no on-site energy recovery is applied to any waste
Not Applicable (NA) - *"
stream containing the toxic chemical or chemical category.
Energy Recovery Methods (enter 3-character code{s)j
12 34
SECTION 7C. ON-SITE RECYCLING PROCESSES
I
Not Applicable (NA) - Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category.
Recycling Methods [enter 3-character code(s)]
1. 2. 3. 4.
6. 7. 8. 9.
5.
10.
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
8.10
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Quantity released "
Quantity used for energy recovers'
onsite
Quantity used for energy recovery
offsite
Quantity recycled onsiie
Quantity recycled offsite
Quantity treated onsite
Quantity treated offsite
Column A Column B
Prior Year Current Reporting Year
(poundstyear) (Bounds/year)
Quantity released to the environment as a result of remedial actions.
catastrophic events, or one-time events not associated with production
processes (pounds/year)
Production ratio or activity index
Column C Column D
Following Year Second Following Year
(pounds/year) (pounds/year)
Did your facility engage in any source reduction activities for this chemical during the reporting year? If not.
enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activities
{enter code(s)]
Methods to Identify Activity (enter codes)
a. b. c.
a. b. c.
a. b. c.
a. b. c.
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES NO
" Report releases pursuanl lo EDCRA SecJ on 329(8) including "any spilling, leaking, pumping, pouring, emitting, emptying. Discharging.
iniecliru:. t?sc30ino leacninq. dumping, or disposing into the environment" Do not include anv Quantity treaiefl onstte or offsite
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
-------
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
Quantity of a Section 313 chemical reported in Sections 8.1
through 8.7 does not include releases (including on-site
and off-site disposal) and other off-site waste management
activities resulting from remedial actions, catastrophic
events, or one-time events not associated with production
process. These quantities should be reported in Section 8.8
only.
RELEASES
Section 8.1: Quantity released
Quantity of a Section 313 chemical "released"
» Definition of release: "...any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing...into the
environment..." (EPCRA §329(8))
» Includes fugitive and stack air emissions, releases to
land, releases to water, underground injections, and on-
site and off-site disposal
» Includes metals in wastes sent to a POTW (metals
cannot be destroyed)
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RELEASES
Section 8.1: Quantity Released (continued)
§ 8.1 = §5 + §6.2 (disposal only) + §6.1 (for metals and metal
compounds only) - §8.8 (release or off-site disposal only)
Possible data sources
» Data and calculations from Sections 5 and 6 of Form R
ENERGY RECOVERY
Sections 8.2 and 8.3: On-site and off-site energy recovery
Things' to remember about energy recovery
» Combustion unit (e.g., industrial furnace, industrial kiln,
or boiler) must be integrated into an energy recovery
system
» Section 313 chemical must have significant heating
value (e.g., 5,000 BTU/lb.)
» Section 313 chemicals that are, or are contained in,
commercially available fuels should not be reported as
combusted for energy recovery
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-------
ENERGY RECOVERY
Section 8.2: On-site energy recovery
Quantity of Section 313 chemical used for energy recovery
on-site
» Quantity actually combusted in the energy recovery unit
- nor the quantity entering the unit
A code reported in Section 7B indicates that Section 8.2
should be calculated
Possible data sources
» Engineering process specifications
» Mass balance calculations
» Best engineering judgement c
ENERGY RECOVERY
Section 8.3: Off-site energy recovery
Quantity of Section 313 chemical that is transferred off-site
for energy recovery
» Includes total quantity of Section 313 chemical
transferred off-site for energy recovery purposes - not
quantity actually combusted off-site
Possible data sources
» Section 6.2 (codes M56 and M92) of Form R
» Receipts from off-site facilities
» RCRA hazardous waste manifests
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RECYCLING
Section 8.4: On-site recycling
Quantity of Section 313 chemical recycled on-site
» Includes total quantity of Section 313 chemical
recovered from the recycling process and made
available for further use
Possible data sources
» Engineering process specifications
» Mass balance calculations
A code reported in Section 7C indicates that Section 8.4
should be calculated
RECYCLING
Section 8.5: Off-site recycling
Quantity of Section 313 chemical transferred off-site for
recycling
» Includes total quantity of Section 313 chemical
transferred to off-site locations for recycling
Possible data sources
» Section 6.2 of Form R (only for recycling destinations)
» Receipts from off-site recycling facilities
» RCRA hazardous waste manifests
» RCRA Hazardous Waste Report (BRS)
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WASTE TREATMENT
Section 8.6: Quantity treated on-site
Quantity of Section 313 chemical treated on-site
» Includes all quantities of Section 313 chemical destroyed
* Possible data sources
» Calculations used to complete Section 7A of Form R
i:
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WASTE TREATMENT
Section 8.7: Off-site waste treatment
The amount of Section 313 chemical that is transferred off-
site for waste treatment
» includes all quantities of Section 313 chemical
transferred to off-site facilities for waste treatment
Possible data sources
» Sections 6.1.A. 1 and 6.2.A (i.e., off-site transfers for
waste treatment)
Important: Assume all Section 6.1.A.1 quantities are
treated, except metals and metal compounds
-------
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8: Remedial, catastrophic, or one-time releases
Quantity of Section 313 chemical released into the
environment or transferred off-site as a result of:
» Remediation
» Catastrophic events (e.g., earthquake, hurricane, fire,
floods)
» One-time events not associated with production
processes (e.g., pipe rupture due to unexpected weather)
Does not include Section 313 chemicals treated, recovered,
or recycled on-site.
Excludes quantities in Sections 8.1 through 8.7
15
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SOURCE REDUCTION AND OTHER WASTE
MANAGEMENT ACTIVITIES
Important points regarding Sections 8.1 through 8.8
Sum of the quantities in Sections 8.1 through 8.7 equals the
total quantity of the Section 313 chemical "entering any
waste stream (or otherwise released into the environment)
prior to recycling, treatment, or disposal." (PPA section
6607(b)(1))
Quantities reported in Sections 8.1 through 8.7 are exclusive
of each other
Sum of Sections 8.1 through 8.7 is mutually exclusive of the
quantity in Section 8.8
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PRODUCTION RATIO OR ACTIVITY INDEX
Section 8.9: Production ratio or activity index
A ratio of production or activity involving the Section 313
chemical in the reporting year to production or activity in
the previous year
Allows quantities of the Section 313 chemical reported in
Sections 8.1 through 8.7 in the current year to be compared
to quantities reported in the prior year
Production ratio or activity index is determined by dividing
the level of production (or activity) in the current year by the
level of production (or activity) in the prior year
Select methodology least likely to be affected by potential
source reduction activities
SOURCE REDUCTION ACTIVITIES
Section 8.10
Source reduction practices used with respect to the Section
313 chemical at the facility and the methods used to identify
those activities
This section includes only those source reduction activities
implemented during the reporting year
» Only include activities that reduce or eliminate quantities
reported in Sections 8.1 through 8.7
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OPTIONAL INFORMATION
Section 8.11
Facility should indicate whether additional optional
information on source reduction, recycling, or pollution
control activities is included with the report
A one-page summary is encouraged
Facility can provide information on previous years' activities
EPA and others use this information for granting awards
and recognition to companies and employees
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PERSISTENT, BIOACCUMULATIVE,
TOXIC (PBT) CHEMICAL RULE
jpg
The PBT Rule
PBT rule published in the Federal Register on October 29,1999
(64 FR 58666)
Rule applies beginning RY 2000, reports due 7/1/01
Rule adds new chemicals to the TRI list
Rule creates a new class of chemicals (PBT chemicals) with
lower thresholds and special requirements
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PBT CHEMICALS AND THRESHOLDS
100lb/yr-
10lb/yr-
Aldrin
Methoxychtor
Pendimethalin
Chlordane
Heptachlor
Mercury
Toxaphene
Isodrin
PCBs
Polycyclic aromatic comp.
Tetrabromobisphenol A
Trifluralin
Benzo(g,h,i)perylene
Hexachlorobenzene
Mercury compounds
Octachlorostyrene
Pentachlorobenzene
0.1 gr/yr - Dioxin and dioxin-like compounds
PBT CHEMICALS AND EXEMPTIONS
The de minimis exemption has been eliminated for PBT
chemicals except for purposes of supplier notification
Users of mixtures must use best readily available
knowledge to determine PBT chemicals present and
concentrations
No other EPCRA section 313 regulatory exemptions were
modified or restricted by the PBT rule
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PBT THRESHOLDS
The combination of the low thresholds and no de minimis
exemption means that a thorough review of chemical activities
may be needed to achieve compliance with the PBT rule
* Impurities need to be evaluated
Chemicals used in low volumes need to be considered
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PBT CHEMICALS
Eighteen chemicals and chemical categories are regulated by the
PBT rule:
Pesticides - Aldrin, Chlordane, Heptachlor, Isodrin,
Methoxychlor, Pendimethalin, Toxaphene, and Trifluralin
Aromatics - Benzo(g,h,i)perylene, Polycyclic aromatic
compounds (PAC) category, Dioxin and dioxin-like compounds
category, Hexachlorobenzene, Octachlorostyrene,
Pentachlorobenzene, Polychlorinated biphenyl (PCB), and
Tetrabromobisphenol A (TBBPA)
Metals - Mercury and Mercury compounds
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PBT CHEMICALS
The following are NOT on the EPCRA Section 313 PBT list for
RY 2000:
Lead
Lead compounds
Cobalt
Cobalt compounds
Dicofol (pesticide)
Vanadium (except in alloy)
Vanadium compounds
POLYCYCLIC AROMATIC COMPOUNDS
3-Methylchioanthrene and Benzo(j,k)fluorene (fluoranthene) are
being added as members of the PAC category
All members (new and old) of the newly expanded PAC
category are PBT chemicals
Benzo(g,h,l)perylene is an individually listed polycyclic
aromatic hydrocarbon (PAH) that is a PBT chemical
PACs are found in coal, fuel oil and other petroleum products
For more information see "Locating And Estimating Air
Emissions From Sources Of Polycyclic Organic Matter,"
(http://www.epa.gov/ttn/chief/) & "Guidance for Reporting Toxic
Chemicals within the Polycyclic Aromatic Compounds
Category" (http://www.epa.gov/tri/)
6
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Dioxin and dioxin-like compounds category qualifier reads:
"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."
Category includes polychiorinated dioxins and furans with
chlorine in at least the 2,3, 7, and 8 positions
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Dioxin and dioxin-like compounds may be formed as
byproducts when chlorine-containing materials are involved in
combustion or other high-temperature processes
Emission factors are available:
"Locating And Estimating Air Emissions From Sources Of
Dioxins And Furans" (http://www.epa.gov/ttn/chief/)
"The inventory of Sources of Dioxin in the United States"
(http://www.epa.gov/nceawww1/diox.htm)
Dioxin and dioxin-like compounds may aiso be manufactured
during the manufacture of chemicals involving chlorine and
remain with the manufactured chemicals as impurities
TO
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MERCURY
Mercury compounds may be present in mined ores, petroleum
products, and coal
Combustion of fuels represents an otherwise use of
mercury compounds and manufacture of mercury
Mercury in switches and fluorescent lamps may be article
exempt
Mercury also used in a wide variety of processes
For more information see "Locating And Estimating Air
Emissions From Sources Of Mercury and Mercury
Compounds," 12/97 (EPA-454/R-97-012) is available at
http://www.epa.gov/ttn/chief/
VANADIUM
PBT rule modifies the listing for vanadium: Qualifier now reads
"except when contained in an alloy"
"Alloy" does not include slags, crystalline structures, ores
PBT rule adds vanadium compounds to the TRI list
Neither vanadium (except when in an alloy) nor vanadium
compounds are on PBT list for RY 2000
Vanadium oxide is produced during combustion of fuels
Vanadium is used to produce various alloys
Prior to becoming part of the alloy, vanadium is a listed
chemical
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PBT REPORTING
For PBT chemicals, EPA is requiring more precise reporting:
EPA has prohibited use of Form A's
EPA has prohibited use of range codes for reporting
releases and waste management quantities
EPA will be modifying the Form R or developing a new form for
PBT chemicals
DATA PRECISION
Report releases and other waste management quantities >0.1
Ib. at a level of precision supported by the data and estimation
technique used
Can be more precise than whole numbers and two
significant digits
If 157.243 pounds calculated, report 157.2,157,160, or 200
pounds depending on accuracy/quality of data source(s)
Similar recommendation fordioxin and dioxin-like compounds
but limit is lower: 100 micrograms (equals 0.0001 grams)
If 1.57243 grams calculated, report 1.5724,1.572,1.57,1.6, or
2 grams depending on accuracy/quality of data source(s)
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FORM R /FORM A SUBMISSION:
GETTING IT RIGHT!
WHY IT'S IMPORTANT TO GET IT RIGHT
Using TRI Data
EPA is required to make non-trade secret data available to
the public through an on-line database (operated by
National Library of Medicine)
Data are widely available on Internet
Data are available in other forms (reports, CD-ROM)
All states receive data; some will make it available
electronically
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EPCRA SECTION 313 ENFORCEMENT
Current enforcement trends
Shift from simply identifying non-reporting facilities to
facilities submitting poor quality data
Focus on multi-media inspections (i.e., across Agency
programs)
Assign pollution prevention-related supplemental
environmental projects (SEPs)
» In FY98, 36% of EPCRA penalty actions included a SEP.
Most SEPs of any regulatory program.
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EPCRA SECTION 313 ENFORCEMENT
Koch Refining ($585,000)
Data quality violations
Sinclair Oil Corp. ($201,968 + $350,000 SEP)
Non-reporting and data quality errors on emissions
Coca-Cola Bottling Company ($14,838 + $44,000 equipment to
LEPC)
EPCRA Sections 311, 312 and 313 violations
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EPCRA SECTION 326: CIVIL ACTIONS
Any person may bring civil action on their own behalf against a
private-sector facility owner or operator for:
Failure to submit emergency follow-up notices under
Section 304
Failure to submit an MSDS or a list of USDS chemicals
Failure to complete or submit Tier l/ll inventories
Failure to complete or submit Form Rs or Form As
COMMONLY MADE ERRORS
Threshold determination errors
Completion errors
Release estimation errors
Off-site transfers reporting errors
Other waste management and source reduction errors
Federal facility name and/or parent company name errors
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THRESHOLD DETERMINATIONS
Helpful hints for conducting accurate threshold determinations
Apply chemicals to correct threshold activity
Avoid missing a Section 313 chemical by considering: all
avenues a chemical may enter a facility; chemical qualifiers;
chemical synonyms; oron-site manufacturing
Consider quantities of Section 313 chemicals in mixtures or
other trade name products
Recognize the limitations of eligibility for exemptions
Results of incorrect threshold determinations
No form is submitted when one is required
Federal facility does not meet requirements of E012856
7
FORM COMPLETION CHECKLIST
Helpful hints for completing the Form R/Form A
Complete all required sections of a current, valid form
Verify trade secret information (if applicable)
Correctly identify the Section 313 chemical using the correct
CAS number and correct listed TRf name
Use the NA indicator for data elements that are not relevant
Indicate the correct reporting year
Verify latitude/longitude coordinates
Clearly identify revisions or duplicate submissions
Sign hardcopy of forms or certification letters for electronic
submissions o
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RELEASE ESTIMATES
Helpful hints for accurate release estimates
Differentiate fugitive from stack emissions
Zero air emissions for VOCs are unlikely
Always use your best available information
Estimate the quantity of Section 313 chemical, not the
entire waste stream
Check your math
Document your work!
Result of release estimation errors
Suspect release estimates
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SUBMITTING REVISIONS
Revisions can be made electronically or in hardcopy
Hardcopy revisions must be made in blue or black ink on a
copy of the form originally submitted
Magnetic media revisions must be accompanied by a newly
signed cover letter
For revisions made for reporting year 1991 or later, mark an "X"
in the space marked "Enter "X" here if this is a revision" on
pagel
Provide a new original signature and date for each revision
Send to EPA's EPCRA Reporting Center and to the appropriate
state agency
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ADDITIONAL INFORMATION ABOUT TRI
EPA Regional and State TRI Contacts
* Check the Form R and Instructions booklet
RCRA, Superfund & EPCRA Hotline
(800) 424-9346 or (703) 412-9810 (DC Metro area)
Regulatory assistance
Information on availability of EPA publications
Information on EPA's electronic resources
EPA ELECTRONIC MAILING LISTS
(LISTSERVER)
To subscribe to an electronic mailing list (listserver), send e-mail to:
listserver@unixmail.rtpnc.epa.gov.
Subject line: SUBSCRIBE TO LISTSERVERS
Text: SUBSCRIBE
SUBSCRIBE EPA-WASTE JOHN SMITH
Some mailing lists are:
EPA-TRI2: Toxic Release Inventory Federal Registers
HOTLINE_OSWER: RCRA, Superfund & EPCRA Monthly Hotline Report
and Updates
EPA-PRESS: EPA press releases
ERA-MEETING: EPA meeting notification
OPPT-NEWSBREAK: OPPT Library daily news service
12
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DOCUMENT DISTRIBUTION CENTERS
RCRA, Superfund & EPCRA Hotline
(800) 424-9346
(703) 412-9810 (DC Metro area)
Fax (703) 412-3333
http://www.epa.gov/epaoswer/hotline
National Center for Environmental
Publications and Information (NCEPI)
1-800-490-9198
http://www.epa.gov/ncepihom/
index.html
U.S. Government Printing Office (GPO)
(202)512-1800
Fax:(202)512-2250
http://www.gpo.gov
National Technical Information
Service (NTIS)
(800) 553-6847
(703) 605-6000 (DC Metro area)
http://www.ntis.gov
ONLINE ACCESS TO TRI DATA
Right-to-Know Network (RTK NET)
Modem: (202) 234-8570; Information: (202) 234-8494; Internet:
http://www.rtk.net
ENVIRO FACTS Database Internet Site
http://www.epa.gov/enviro/htm l/ef_home.html
Environmental Defense Fund
http://www.scorecard.org
TOXNET (National Library of Medicine)
Modem: (301) 946-1184; Information: (301) 496-6531; Internet:
http://www.nlm.nih.gov
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PUBLIC ACCESS TO TRI
TRI User Support Service: (202) 260-1531
TRI Reports (EPCRA Hotline and EPA TRI Web Site)
TRI Public Data Release Annual Report
TRI Public Data Release State Fact Sheets
TRI CD-ROM (GPO/NTIS)
State Data Diskettes (GPO)
TRI HOMEPAGE
EPA Toxic Release Inventory: Community Right to Know
Homepage (http://www.epa.gov/tri)
General information on the TRI program and program
development
Information on how to use the TRI data
Access to TRI data (e.g., public data release, state fact
sheets, links to TRI databases)
Guidance documents for newly added industries
EPCRA Section 313 Questions and Answers Document
(Revised 1998 version)
Automated TRI Reporting Software (ATRS)
16
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SECTION 313 GENERAL GUIDANCE
Toxic Chemical Release Inventory Reporting Form R and
Instructions
EPCRA Section 313 Questions and Answers (Revised 1998
Version) EPA745-B-98-004
Common Synonyms
Consolidated List of Chemicals Subject to Reporting Under the
Act (Title III List of Lists)
Most recent version on Internet:
http://www.epa.gov/tri/guidance.htm
17
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SECTION 313 TECHNICAL GUIDANCE
Industry-Specific Technical Guidance Documents such as:
* Estimating Chemical Releases From Electroplating
Operations
Guidance for New Industries
Chemical-Specific Guidance Documents such as:
Guidance for Reporting Sulfuric Acid
List of Toxic Chemicals within the Glycol Ethers Category
Estimating Releases and Waste Treatment Efficiencies For the
Toxic Chemical Release Inventory Form
18
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SECTION 313 TECHNICAL GUIDANCE
Technology Transfer Network (TTN)
Help Desk (919) 541-5384
Internet: http://www.epa.gov/ttn/
Compilation of Air Pollutant Emission Factors (AP-42)
Water 9/ChemDat 9 programs
TANKS program
19
POLLUTION PREVENTION INFORMATION
OPPT Pollution Prevention (P2) Internet Site
- http://www.epa.gov/opptintr/p2home/index.html
EnviroSenSe Information Network
BBS modem (703) 908-2092; User support (703) 908-2007
http://es.epa.gov/index.html
Pollution Prevention Information Clearinghouse (PPIC)
(202)260-1023
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