?/EPA
United States
Environmental Protection
Agency
Office of Information
Analysis and Access
March 2000
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS:
Spring 2000
Two DAY WORKSHOP
2202002
-------
-------
Q®-
I
-------
TOXICS RELEASE INVENTORY
PROGRAM
WHO MUST REPORT?
Facilities (Private- and Public-sector)
- In covered primary SIC code(s); and
• With 10 of 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
WHAT TO REPORT?
File a TRI report for each Section 313 chemical exceeding
threshold
Submit to U.S. EPA. designated state officials or designated
tribal office
-------
Wiii!imiiia«^^
TRI REPORTING PROCESS
i
-o
COVERED SIC CODES
1 Manufacturing
Metal mining
Coal mining
Electrical utilities
Treatment,
Storage, and
Disposal facilities
Solvent recovery
services
Chemical
distributors
Petroleum bulk
terminals
20-39
10 (except 1011. 1081, and 1094)
12 (except 1241)
491 1 . 4931 , and 4939. limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce
49S3, 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
S169
5171
FEDERAL FACILITIES
Federal facilities (covered by Executive Order 12356)
'• 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
-------
SIC CODES
• EPCRA Section 313 subjects facilities to reporting based on
classification of primary activities in the Standard Industrial
Classification (SIC) system (40 CFR 372.22)
• On April 9,1997 (82 FR 17288), the North American Industry
Classification (NAIC) System was implemented
• SIC codes are to be used until EPA transitions to new NAIC
system in future reporting years
• A crosswalk exists between the SIC and new NAIC codes (see
62 FR 172188)
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
MULTI-ESTABLISHMENT FACILITY
Three separate establishments located on contiguous/adjacent
property owned by same per*on(s), is one facility undar EPCRA
Gene
ric Product* food
Procauing
(SIC 2033)
min
Generic Products Farm
(SIC 0161)
Gm.Prod.Wanhout*
(SIC 4222)
-------
BHTHaiii^^
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
• Federal facilities and federal contractor* (GOCOs)
Contractor 1
DOE
..---"
J Contractor
Ex. 1: Two ••parot* reporting fadlilw
(HUD and DOT including Coaa Guoid)
Ex. 2: On* reporting facilih/
|DOE)
101
AUXILIARY FACILITY
Non-contiguous and non-adjacunt to a covered establishment
Primary function la to support a covered establishment's
activities (e.g., warehouses, laboratories)
Assumes SIC cod* of covered establishment for reporting
purposes
Employee and chemical activity threshold determinations
separate!
AUXILIARY FACILITY
ACME Mfg. F«ciliti«
(Warehouse Is auxiliary facility of ACME Mfg.)
-------
^^
EMPLOYEE THRESHOLD
I • 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
13
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 u*ed 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
CATEGORIES OF MANUFACTURING
ACTIVITIES
Manufacturing - generating a Section 313 chemical
* Intentions!ly prooucino ctmnicfllA
. Sate
On-*ite use or processing (e.g.. intermediates)
Coincidental^ producing chemicals as impurities or
Including waste treatment and
Importing
, "Cause" to be Imported
-------
MANUFACTURING WITHIN A
CHEMICAL CATEGORY
• Chemical conversion within a motal or organic compound
category must be counted toward* the manufacturing
threshold
• For Example:
• A copper mine converts copper sulflde to copper sulfate in
Its beneftciatlon operations
> Copper sulfate, a member of the copper compounds
category, is "manufactured"
16
CATEGORIES OF PROCESSING ACTIVITIES
I • 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
17
REPACKAGING AS A
PROCESSING ACTIVITY
• Repackaging a Section 313 chemical for distribution Into
commerce is considered processing
• Repackaging Includes transfer:
» From container to tanker truck and visa versa
> Between similar size containers
» Via pipeline to/from a tank
• Repackaging does not Include:
» Sampling without repackaging
i Re-labeling
| • Repackaging without distribution Into commerce Is not
considered processing
IS
-------
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)
19
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)
20
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
21
-------
CALCULATING ACTIVITY THRESHOLDS
Activities that do NOT constitute an activity threshold
• Storage
• Remediation of on-site contamination
• Re-labeling without repackaging
SECTION 313 CHEMICALS AND CHEMICAL
CATEGORIES
Original list developed from Maryland -High Production
Volume" and New Jersey "Right to Know" chemical lists
Current list contains over 600 individual chemicals and
chemical categories (See Table II of the TRI Reporting Forms
and Instructions document)
Petition process to add or delete chemicals or forms of
chemicals
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:
QUALIFIER
Fum* or dust
Fibrous forms
Friable forms
Manufactured by strong acid process |
Yellow or whits
Manufacture only
Acid urosols
Acid asrosols
CHEMICAL
Aluminum
Aluminum oxide
Asbestos
Isopropyl alcohol
Phosphorus
Saccharin
Hydrochloric acid
Sulfuric Mid
CASO
7429-90-5
1944.21-1
1332-21-4
67-63-0
772J-14-0
tl-07-2
7(47-01-0
76M-93-9
-------
i';' tasff«*!&• '^
EPCRA SECTION 313 CHEMICALS
Calculate threshold determinations and release* and other
wast* management estimates by multiplying the percentage of
a Section 113 chemical by the total amount of the mixture.
other trade name product, or waste
• Example: 80,000 pounds of a solvent containing benzene
was used on-sita at the facility to clean machinery. The
solvent contains 10% benzene.
» 80,000 pounds X 10% = 8,000 pounds otherwise used
25
COMPOUND CATEGORIES
Count together all compounds that fall within a category, even
if different compounds within a category are used in separate
operations
• For example, if a facility processes 20,000 Ibs. of methylene
bis(phenylisocyanato) (MDI) in one operation and 10,000 Ibs.
of 1,4-Cyclohexane diisocyanate in another operation
during the reporting year
» 30,000 Ibs, of diisocyanates have been processed.
Reporting for dllsocyanata* category is required!
Consider the entire weight of lha compounds in the category
when determining thresholds
Calculations for release and other waste management
estimate are different for metal and nitrate compounds
26
•»!!.—l.jagl,....«-.»......l» ,;;,llln,...ll.ll.,... .1 „„„„„„„ ,,l,,i.,,,l l»,,,,,i, , .;„.... inaBHT II
-------
-------
SECTION 313 REPORTING
EXEMPTIONS
••iSm^^^
SECTION 313 EXEMPTIONS
Originally designed for manufacturing facilities to:
• Reduce burden of reporting associated with small or
ancillary chemical uses
• If an exemption applies, than the amount of an EPCRA
Section 313 chemical subject to the exemption does not
hav* to be included in:
• Threshold determinations
» Release and other waste management reporting
» Supplier notification
Recognize that exemptions only apply to certain limited
circumstances
SECTION 313 EXEMPTIONS
Types of exemptions
• De minlmis
• 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)
-------
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
Any other Section 313 chemicals present at a concentration
of less than 1% by weight
IBBtffl H
DE MINIMIS EXEMPTION
How It Works
D« mm/mis 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
•J..il"'1!,'
DE MINIMIS EXEMPTION
How It Works
Oe mlnlmls 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
a^am-^im^M^VKSmmmi-^m^^M&^^^^mwm^-^^^^sm^^^^- i*.^.*;*;*!**!:"^!
-------
v a !•; >3 fail.
DE MINIMIS EXEMPTION
How It Works
• De minima 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 trad* name products that are not
associated with a processing or otherwise use activity
> Material storage not associated with processing or
otherwise use activities
BsmhiMmriHiffliiitmiiurfl B!aE.i.B.Hin^r.*.i«a™i.ai.iiqi!ai^^^^ ;Tiiiiii*iil -E...I. .
DE MINIMIS EXEMPTION
How It Works
• Da minimls 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 minimls concentration
and is eligible for the exemption
8
DE MINIMIS EXEMPTION
How It Works
Procftuing « Section 31J chemfe*! fn * mixture to bejtfw th« rmlnBtlon* and
Tolu«w>1«
• Mmft>MJ««i>|>tl<»
• DtAtftAnU tumpflon doM not apply
• RrtMMMdoUtirwMfiiniftMgwItMt
oleuKIoninqlilrad
i:
-------
DE MINIMIS EXEMPTION
How It Works
i Ctuotay
I eont»tnhH| it;
I wnaurntel
a Section 313 chemical in e mixture to above the eto
minimi* concentration triggers thraahoU determinations and release
and other waste management calculation requirements
PWTDhum
ptedwctc
contMnbtg
ffl^
to
ARTICLES EXEMPTION
"Article" ts 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
ARTICLES EXEMPTION
How It Works
Releases from an article may negate the exemption. To
maintain (he article status, total releases from all like Hems
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 article exemption.
-------
. >'•"'!%'£ a!:'!
vfi ftr. ~ WSf
f!:! if. '• •• *M . SB
ARTICLES EXEMPTION
How It Works
Example:
Wire is cut to specified length*. Wastes include off-spec cute
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
13
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
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.
-------
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
16
LABORATORY ACTIVITIES EXEMPTION
How It Works
| Section 313 chemicals manufactured, processed, or otherwise
| used in these laboratory activities are NOT exempt
I • Any activities conducted outside laboratories
I Specialty chemical production
i Pilot-scale plant operations
I Support services
• Photo processing
• Equipment maintenance / cleaning
17
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 forkllfts
Examples of exempt motor vehicle maintenance:
* Body repairs
• Parts washing and plating
• Fueling and adding other fluids (e.g., ethylene glycol)
-------
il'S "UK "t 1 ff
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
19
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
OTHER SECTION 313 EXEMPTIONS
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)
-------
UI !i. i'!S!'!i»:»i k ErPMT!.,' i. H a5.pi1 fl'it'. i- •'''',
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
Denunciation, 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: unconsolldated material that overlies a
deposit of useful materials or ores (40 CFR 372.3) -,„
-------
IMININQ THRESHOLD!
TRI REPORTING PROCESS
DETERMINING THRESHOLDS
Identify what Section 313 chemicals are handled on-site
Identify concentrations of Section 313 chemical*
Collect data and calculate quantities towards each threshold
-------
DETERMINING THRESHOLDS
Identify Chemlcel» and
Concentration*:
Collect Data to Calculate
hold>
MSDS
Specifications
Wist* Profiles
Process Knowledge
Inventory Records
Tnroughput/Pnxluctlon Data
Purchase Records
EPCRA or Olh*r Env. Report*
Ask the User
CHI trie Vendor
Other Reference* (AP-42,
Merck Index)
Supplier Notification
DETERMINING CONCENTRATIONS OF
SECTION 313 CHEMICALS
Chemical component • include in threehotd "each listed Section
313 chemical known to be present" at a concentration greater
than the dem/rt/m/s 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 chemlcal(s) by name and CAS number
• Identify Section 313 ehemical(a) 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 _
-------
DETERMINING CONCENTRATIONS IN
MIXTURES OR OTHER TRADE NAME
PRODUCTS
• Include * 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 baaed on weight in pounds.
im^^^^^
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
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-slte,
then used or incorporated into a product (processed)
• Section 313 chemicals formed during destruction of wastes
received from off-site and subsequently destroyed on-sit«
(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
-------
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 aent 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
MULTI-ESTABLISHMENT FACILITY
• Determining how facilities report
• M ulti -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 aj] releases and other waste management
activities of reportable Section 313 chemicals
» Avoid double-counting of chemicals involved in Intra-
facility transfers
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
121
-------
ORCHESTRATING DATA COLLECTION
> ckntnl *r
is
1- J.tABfB'Ml*'
n.1. JdMHif>nmirtfiiTinipfl>>Mi
(•rfi.i i*rt*ln.U» fnr wlim JU itfiTtrnf
yO.mk.rfJkita.i, rvpMii.pi. ™x,,irw)fiK»«»flirtJ«t DrjiHl«tkiiillkl.«wVbqt«f4*r«-MlL RMite ferjioir ntforti | ^
MANAGEMENT PRACTICES
ir
^;
?!
id
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
15 i
-------
RECORDKEEPING
Detailed records
* Improve reporting accuracy and data quatity
• Reduce replication of effort from year to year
Well-labeled calculations and assumptions
• Serve as standard operating procedures (SOPsJ for future
years
• Ensure consistency from year to year, especially If
personnel responsible for reporting change
All records used to complete Form R must be kept for three
years (40 CFR 372.10)
E • EPA will review records during a data quality audit 161
-------
EXERCISE #1
IDENTIFYING EPCRA SECTION 313 CHEMICALS
Purpose:
Familiarize participants with the chemical lists in Table 2 of the TRI
Forms and Instructions Document.
Ability to identify correctly Section 313 chemicals from MSDSs.
Take-Aways: Understanding of nuances of chemical compositions.
Materials: TRI Forms and Instructions Document
Material Safety Data Sheets (MSDSs)
Instructions: Attached is a package of chemicals, chemical compounds, and chemical
mixtures present at your facility. Determine if any of these chemicals or
parts of these chemicals is on the EPCRA Section 313 list. If you
determine that a chemical or component of a product or mixture is on the
list present at or above the appropriate de minimis level, prepare a list of
the appropriate section 313 chemicals and CAS numbers.
-------
(0
u
UJ
u
O
U
Ul
CO
u
EL
UJ
O
UJ
Q
-------
I.
MEAOOWBRaaK COMPANY
3PELTEB. WEST VIRGINIA 26498
RAW MATERIAL SUPPLIER DATA SHEET
TRADE NAME CRUDE ZINC OXIDE
CHEMICAL XAME
MANUFACTURER
SPECIFICATIONS
Za
Fe
Al
Pb
Cl
Cd
Cu
ZINC GXZOE
GRADE A
II.
III.
IV.
v.
VI.
VII.
VII.
50-591
1-31
.3-3.31
0.1-0.5 Avg.
0.0-0.31
Lams Than .01
0.04-O.AO
EPA/CAS 1J14-IJ-2
MEADOWBROOK COMPANY
017 OF T. L. DIAMOND & CO., INC.
CRAPE B
601-681
1-31
.3-3.31
0.2 0.1-0.5 Avg.0.21
0.0-0.31
.01
0.04-0.40
NOW TOXIC SOLID MATERIAL WITH A PARTICLE SIZE RANGE
UP TO X/4 INCH.
SPECIFIC GRAVITY 5.5.
APPARENT DENSITY 130-160 LSS/CU FOOT
NON SOU1ABT f 121 WATER KOR VDLAZILE
LIGHT GRAY, ODORLESS COARSE PONDER
HO FIRE OR EXPLOSION HAZARD.
OR CARBON VHEN HEATED.
CAN REACT WITH MAGNESIUM
HO PARTICULAR HEALTH HAZARD, TLV (S) FOR PRINCIPLE
INGREDIENT
PEL 2 Mg/M' FOX ZINC OXIDE FUME
REACTIVE AT AMBIENT EXCEPT WITH MINERAL ACIDS
SPILL OR UE/tfc PROCEDURES
Claaa up 4 return co labeled containers
PERSONAL PROTECTION
Niosh respirator suggested for comfort when material
is dry ft dusty
HANDLERS SHOULD WEAR GLOVES AND SAFETY COCCLZS.
;iH 13 '95 IX,:
-------
3M General Offices
3M Center
St. Paul. Minnesota 55144.1000
812/733-1 MO
I
12743
7
MATERIAL SAFETY
DATA SHEET
DIVISION: INDUSTRIAL MINERAL DIVISION
TRADE NAME:
3M BRAND ROOFING GRANULES CVAUSAU, WI3
3ft I.D. NUMBER: 91-0111-1216-0 98-0111-1217-8 98-0111-1218-4 98-0111-1219-4
98-0111-1220-2 98-0111-1221-0 98-0111-1222-8 91-0111-1223-*
98-0111-1252-5 98-0111-1233-3 98-0111-1278-0 98-0111-1288-9
98-0111-1290-5 98-0111-1292-1 98-0111-1293-9 98-0111-1294-7
98-0111-1318-4 98-0111-1319-2 98-0111-1320-0 98-0111-1321-8
98-0111-1322-6 98-0111-1323-4 98-0111-1324-2 98-0111-1325-9
98-0111-15*8-1 98-0111-1444-8 96-0111-1445-5 98-0111-1444-3
98-0111-1447-1 98-0111-1448-9 98-0111-1449-7 98-0111-1450-5
98-0111-1451-3 98-0111-1452-1 98-0111-1453-9 98-0111-1454-7
98-0111-1457-0 98-0111-1484-4 98-0111-1488-5
ISSUED t SEPTEMBER 13. 1994
SUPERSEDES: NOVEMBER 23. 1993
DOCUMENT* 10-0170-0
PLAGIOCLASE FELDSPAR
QUARTZ
POTASSIUM FELDSPAR
SODIUM SILICATE
KAOLIN
CARBON BLACK
CHROMIUM OXIDE (TRIVALENT CHROMIUM)
HYDRO TREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES
RUTILE TITANIUM DIOXIDE
IRON OXIDE CFE203)
ZINC FERRITE
.. Nona. 30.0
.. 14808-60-7* 25
. . Nono y 20
.. 1344-09-8 V, <
.. 1332-58-7^ <
. . 1333-86-4 *j <
. . 1308-38-9 v <
. . 64742-52-5' <
. . 1317-80-2 - <
. . 1309-37-1 «' <
. . 12063-19-5 <
35
31
25
5.1
5.<
0.
0.
0.
0.
0.
0.
.0
)
I
NOTE: THE AMOUNT OP DUST GENERATED WHILE HANDLING THESE ROOFING GRANULES IS
EXPECTED TO VARY DEPENDING ON THE USER'S OPERATION. THf LEVEL OP
RESPIRABLE CRYSTALLINE SILICA IS EXPECTED TO BE LESS THAN IS* OP THE
RESP1RABLE DUST.
THIS PRODUCT CONTAINS Till FOLLOWING TOXIC CHEMICAL
[CAU SUBJECT TO THI REPORT!
REQUIREMENTS OF SECTION 313 OF TZTZJC XZZ OF THE EHEROENCT PLANNING ANOCOMMUNm RIGHT-
ACT OF 198* AMD *9 CFR PART 372*
CHROMIUM OXIDE (TRIVALENT CHROMIUM)
ZINC FERRITE
BQXLXXO POXHTi
7AFOR PRESSURE*
7APOR DENSITY I
EVAPORATION RATEs ,
SOLUBILITY IBJ HATER i
SF. GRAVITY:
PERCENT VOLATILE* ,
VOLATILE ORBANICSt ,
, . . . N/A
. . . . N/A
. . . . N/A
. . . . N/A
. . . . N/A
.... 2.6-2.7
. . . . M/A
. . . . N/A
Abbreviation* i H/D - Not 0«t«r«ined N/A - Not Apolicablo
-------
JM General Offices
3M Center
St. Paui. Minnesota £5!"-'COO
812/733-1 HO
07-08
12744
MATERIAL SAFETY
DATA SHEET,
MSOSj 3» BRAND ROOFING GRANULES CWAVSAV, HZ)
SEPTEMBER 13, 19W
PAGE. 2 of S
70C LESS H20 ft EXEHFT SOLVENT N/A
-Hi SL BASIC
VISCOSITY: [j/J
An>EARAN3tANB'6oORt"*Gr«nui««. Various colors, slightly oiiy
FLASH POXKT: N/A
FLArniABLZ LXHXTS - LtL: ..... N/A
FLAHHASLS LIMITS • VfL» M/A
AUTOISNIT10M TZMPERATORTi ... N/A
EXTXN6UZSHINO KEOIAs
Nen-eoabuatifale. Chaaae material suitable for aurreundino fir*.
SPECIAL FIU 7IQHTINB PROCEDURES»
Not aopiicable .. ,. ' ' • ' '
OHUSVAL nKt AND OCPL03IQN HAZARDS i
Ne unusual fire or exalesien hazards are anticipated.
CTTVTTY UAfT
»ATIItIALS TO AVOID,
Occur
HAZARDOUS OtCOHPOSITXON PRODUCTS*
Hone known.
5. EHTIROmiEHTAI. INfOHIIATinM
or fro. othor section.. C«il«t »ill.d ».t.ri.l.
Us* «««t SMooaina- compound or water to avoid dusting.
RXCORHCNOO DISPOSAL* . ..j,« • "
OisBose) of wests eroduet in a sanitary landfill.
Sine, reoulatiwis vary, consult aooiicable regulations or .authorities
boforo) dissosal.
EHTIROlOItllTAL OATAt
Hot determined.
No«. < Not U.S.
r
: No REACTI7ITY, Ho
Yes CHROMIC: Yea
—^ M/A - Mat Aaelicabla
-------
I
3M Central Offices
jM Center
SI Paul. Minnvsota 55144.1 COC
612/733-1 ?10
07-08
CT 2TO r
nm 3
MATERIAL SAFETY
DATA SHEET
3H BRAND ROOFING GRANULES CWAUSAB, MI 3
SEPTEMBER 13, Iff*
PAGE. 3 of =
EXE CONTACTS ' -
Immediately flush ayes with large amounts of wstsr. Set immediate
medical attention.
SKIN CONTACT*
Na naect for first aid is anticipated in the event of skin contact.
INHALATION!
If signs/symptoms occur, raseve person to fresh air. If
signs/symptoms continue, call a physician.
IT SWALLOWED i
Drink two 9!
of water. Call a physician.
£« PROTECTION! . ^ ,
Avoid «y« contact. Tha following should ba worn alona or an
combination, as aporooriato, to pravant «ya contact: Uaar safaty
glassos with sida shialds.
5KZ M a
Avoid prolongad or rooaatad skin contact..
7SITZLATXON PROTECTION t
If oBnauavt vanxilation is not available, us* appropriate r«sp»ratary
prataetLon. '
RESPIRATORY PROTECTIONt . 0___.. ^
Avoid braathino of dust. Salact en» of tha following KXOSH approvad
rasviratora basad on airborna concentration a* contaminants and in
aeeordanca. with OSHA rigulatienst half -mask dusrt rasairater.
or ACCIDENTAL XROTSTIONI
Wash hand* aftar handling and before aeting.
R1LUAHDU1U STORAOlt
Nat aavlicable.
FIRE AND EXPLOSION ATOZBANCEs
Nat applicable.
EXPOSURE LXIIXTS
QUARTZ
0.1
as quartz
ACSIH
dust
Abbreviations i N/0 - Not Oatermined N/A - Nat Applicabla
-------
3M General Offices
2M Center
SL Paul. Minnesota SS!**-tOOO
512/733-mo
07-08
127*6
MATERIAL SAFETY
DATA SHEET
«SOS: 3H BRAND ROOFING 6UANVX.E5 (UAUSAV, WZJ
SEFTEH8CR 13,
PABEi
ef 5
(earn; anneal
EXPOSURE LznzTS
TNOftEBZENTS
POTASSIUM FELDSPAR .
SODIUM SILICATE
KAOLIN
KAOLIN
CARBON BLACX
CARBON BLACK
CHROMIUM OXIDE CTRIVALEHT CHROMIUM) . .
CHROMIUM OXIDE CTRIVALENT CHROMIUM) - -
VflUIE UNIT
am ousr-tz rase.
NONE NONE
NONE NONE
2 mg/aJ
resoirable dust.
10 mg/aJ
3.5 ng/«3
3.5 mg/a3
0.5 mg/vi
as Cr
0.5 «g/a£
as Cr
TYPB AUTH SXXH*
TWAlSHA
dust
NONE NONE
NONE NONE
TWA ACSIH
TWA OSHA
TWA ACSIH
TWA OSHA-
TWA ACSIH
TWA OSHA
HYOROTREATE9 HEAVY NAPHTKENIC
PETROLEUM DISTILLATES
HYDROTREATEO HEAVY NAfHTHENIC
PETROLEUM DISTILLATES
RUTILE TITANIUM DIOXIDE
RUTILE TITANIUM DIOXIDE
IRON OXIDE (FEZOS)
TWA CKRG
10 mg/mS
IB ng/ai
Iff m«/Hi
5 mg/mS
as Fa
10 m«/«ii
»m -fvma
5
ZINC FERRITE NONE* NONE-
IRON OXIDE CFEZOS)
IRON OXIDE (FEZOS)
STEL
TWA
TWA
TWA
TWA
TWA
NONE
CMR9
ACSIH
OSHA
ACSIH
OSHA
ACSIH
NONE
* SXZN NOTATZONi Listed «IOS*«RCM indicated with "Y* under SKIN refer to
the ootenta.i contribution to the overeii .KDOSUT* by the "»*•«•«";."«*»,
including mucous »e«brene and eye, either by exrbome jr. mere oarticuiar
by direc? contact with the- substance. Vehicles can alter skin »oserpt*on.
SOURCE 07 EXVOSURC LIMIT DATA i
• ACSIH t Aewrican Conference of Qevern __ . -.-
- OSHA• Occupational Safety and Health Administration
• CJOtS t Chasu.es 1 Manufacture Recommended Guidelines
• NONE) None) Estsslished
ntsl Industrial Hygianiats
CTE CONTACT: ^ . ^
Hay cause eye irritation if dust gets into eyes.
SEXN CONTACT: ... , ., _^__*
Ne adverse health effects are exeected fro" skin contact.
INMAXiATZONt
Single owerexoesure. above reee«nended guidelines, nay causes
Abbreviations i N/D - Net Determined N/A - Met Applicable
^ c
-------
I
3M General Offices
3M Center
St. Piul. Minnesota 35T44.JOOO
612/733-1110
37-08
CT
MATERIAL SAFETY
DATA SHEET
PAfil -
KSOS: 3» BRAND ROCfINQ GRANULES CUAUSAD, WI)
SEPTEMBER 13t 19f4
PAGE; 5 of 5
Irritation (upper respiratory)» signa/syoptowa can include
sereneaa of the* nesa and throat* coughing and sneezing.
Prolonged or repeeted ovarexposure, abova raeomandad guidalinaa.
may eauaai
Silicaais: signs/sywotoma can inciuda ahar-tnaaa ef braath and
paraiatenT eouoning.
Pnaumaeaniaais (ganaraiJ: siena/aywot
eaugnina and shertnaas of braath.
can ineluda paraiatant
17 S*AU.OtftDi
Inoaation is not a likaly routa of axaaaura ta thia oreduet.
CANCER:
QUARTZ SILICA (14808-60-7) ia a oatantial eanear hazard causing lung
tuaors by tha inhalation and intratraehaal reutaa of axoosura in
laboratory aniaal studiastNTP antieiaatad ttummn eareinogan, I ARC
probable human careinogan 2A, Calif. Proposition 65).
HEADING 9KTZON CHANOD SXKCE NOVEMBER 23. 199S ISSUE
IHOREDIENTS SECTZON CHANOEO SZRCE NOVEHBER ZS. 1993 ISSUE
EHTIROH. DATA SECTION CHANGED SZRCE NOVEMBER 23. 1995 ISSUE
PMCCAUT. INTO. SECTION CHANGED SINCE NOVEMBER 23. 199S ISSUE
HEALTH HAZ8. DATA SECTZON CHANGED SINCE NOVEMBER 23. 199S ISSUE
Abbreviations i H/D - Not Datarvdnad M/A - Nat Apviieabla
"Ka in*orwat»en on xnia OataTahaaT roaraaanxa our eurranx data ana boat
ooinion mm to tha erooar uaa in hanaiing of this notarial unaar no™**...
conditiona. Any uaa of tha material which is not in eanforaanea with this
Data Sheat ar which involves using tha material in eoacunatxan w*tn eny
r«»oon»ibility of the user.
-------
iMATERlAL SAFETY DATA SHEET
Sealed Air Corporation
• 3 On $«*«•>»•• f«ai
v* 36110 'IU1171MMO
I-A
Page i of 6
Issued 4/97
EMERGENCY TELEPHONE NO:
(203) 791-3500 M-F 8:30-5:00 ET
CHEMTREC 1-800-424-9300 (for Chemical Emergency"
spill, leak, fire exposure or accident. 24 hours >
SECTION 1 - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Product Name:
Chemical Name:
Trade Name:
Chemical Family:
Chemical Formula:
INSTAPAK • COMPONENT "A"
Polymethyiene Polyphenyiisocyanate
Polymeric MDI
Aromatic Isocyanates
N.A.
SECTION 2 - COMPOSITION / INFORMATION ON
K92iartous Ingredients;
Polymeric Diphenyimethane
Diisocyanate < "polymeric" MDI)
Contains:
4,4'-Diphenylmethane diisocyanate
(4,4'-MDI; CAS 101-68-8; s 45% )
Other MDI isomers and oligomers
CAS No.
9016-87-9
INGREDIENTS
Wt.% QSHA.PFL
100 N.E.
0.02 ppm
(Ceiling)
N.E.
*
ACGTH-TT V
N.E.
0.005 ppm
(TWA)
N.E.
SECTION 3 - HAZARDOUS IDENTIFICATION
EMERGENCY OVERVIEW
Hazards: Irritating to eyes, respiratory system and skin. Inhalation at levels above the
occupational exposure limit could cause respiratory sensitization. The onset of the respiratory symptoms
may be delayed for several hours after exposure. A hyper-reactive response to even minimal
concentrations of MDI may develop in sensitized persons. Sensitized persons should not be exposed to
any mixture containing unreacted MDI.
Reacts slowly with water to produce carbon dioxide which may rupture closed
containers. This reaction accelerates at higher temperatures.
Appearance: Dark brawn liquid.
Qdor Slightly aromatic (musty).
Note: Read the entire MSDS for a more thorouah evaluation of the hazards.
•*t.• notUT*aLisntB' MA •«OT***I
-------
•00
999
Sealed Air Corporation
Page 2 of 6
issued 4/97
•••«• :*.-»*» cr
I SECTION 4 - FIRST AID MEASURES
Remove from further exposure and obtain medical anention. Treatment is symptomatic for
primary irritation or difficulty in breathing. If breathing is labored, oxygen should be administered b-.
qualified personnel. Apply artificial respiration if breathing has ceased or shows signs of failing.
Asthmatic -I ike symptoms, if manifested, may develop immediately, or be delayed for up to several hours.
Skin Comaer Wash affected area thoroughly with soap and water. Launder contaminated clothing
thoroughly before reuse. If irritation, redness, or a burning sensation develops and persists, obtain medical
advice.
Eve Contact- Flush with copious amounts of water for at least 1 S minutes, holding lids open with fingers.
If irritation persists, repeat flushing. Refer individual to a physician for immediate follow-up.
^- Do NOT induce vomiting. Provided the patient is conscious, wash out mouth with water then
give I or 2 glasses of water to drink. Refer person to medical personnel for immediate attention.
tp physician*! Symptomatic and supportive therapy as needed. Following severe exposure medicai
follow-up should be monitored for 48 hours. Pulmonary disorders may be aggravated by overexposure.
SECTION 5 • FIRE-FIGHTING MEASURES
Flash Pntnr 390" F (199" C) [Perisky- Martens Closed Cupj
Flammable Ljtujfra f loweri; Not available
Ffammaple Limits Cupperl: Not available
Extinguishing Media: Carbon dioxide (COT) . dry chemical, or chemical foam. If water is used, large
quantities are required. Contain run-off water with temporary barriers.
Fire ana E.rBtn«Jton
- Containers may burst under intense heat. Avoid water contamination in
closed containers: carbon dioxide is evolved which can cause pressure buiid-up. Caution: Reaction
between water and hot isocyanate can be vigorous.
Special Fire Fighting Procedure^ Firefighters must wear self-contained breathing apparatus to protect
against toxic and irritating vapors; full protective clothing should also be worn.
NFPA Hazard Coder
Health: I
Flammabilicy: I
Reactivity: I
Special Hazard: None
SECTION 6 - ACCIDENTAL RELEASE MEASURES
Evacuate area surrounding the spill and prevent further leakage, spillage or entry into drains. Eye and skin
protection should be worn during spill cleanup and ventilation maintained. If the potential for airborne
concentrations of MDI above the PEL exists, then respiratory protection should be worn.
•» * • wOf m*MJ9M«0 «<*.«"OT4»*IIC*«II *(
.1.« ieeur.1. to in* omt «taw«a«« O» S«MM tut CWBartliOrt. I'M ««• on "••»
-------
000
Sealed Air Corporal ion
UA
Page 3 of 6
issued 4/97
•1 OM
. Craw*. CT 36*10. IK31 W JSOO
SECTION «- ACCIDENTAL RELEASE MEASURES (continued)
Contain and cover spill with loose absorbent (earth, sand, sawdust or other absorbent materiaj). or
absorbent pillows, pads or socks. Collect absorbed material in open containers or plastic bags, and treat
with deactivating solution (90% water. 8'/« concentrated ammonia. 2% detergent). Allow 10 stand
uncovered for 48-72 hours to permit carbon dioxide to escape and solidification to occur. Wash spill area
with deactivating solution and let stand for IS minutes or longer. Dispose of spilled material properly.
SECTION 7 - HANDLING AND STORAGE
Min. 50° F ( 1 0° O Max. 10(P F (38* C)
ifer 6 months
Speetat genytivityr Reacts with moisture to produce carbon dioxide gas.
Precautions to be Taken m Handj«ngjpd Storage^ Do not store drums uncovered outdoors. Do not reseal
containers unless it is certain that no moisture contamination has occurred. Do not breathe vapors or allow
skin contact.
SECTION 8 - EXPOSURE CONTROLS/PERSONAL PROTECTION j
Limits;
HMTS Hazard Code:
OSHA-PEL: 4,4'-Diphenyimethane diisocyanate;
ACGIH-TLV: 4,4>-Dipnenyimethane diisocyanate;
Ceiling - 0.02 ppm
TWA- 0.005 ppm
Health
Ftammabiiity
Reactivity
PPE
3
1
I
8
(Personal Protective Equipment)
Protection? Due to the low vapor pressure of this material, the PEL is not likely to be
exceeded under normal conditions. If the material is heated or spilled in a confined area, respiratory
protection should be worn. Because of their short life and lack of breakthrough indicators, cartridge type
respirators equipped for organic vapors are generally not recommended for use with isocyanates. They
can be used for short term emergency situations at concentrations below the PEL where the presence of
adequate breathing oxygen can be assured. Where concentrations exceed the PEL. air supplied respirators
must be ttsfd
Eye Pmreenon? Goggles or safety glasses with side shields.
Protective Clathiay Chemical resistant butyl rubber, nitrite rubber, neoprene, or other suitable protective
gloves.
Ventilation; Use local exhaust ventilation if necessary to maintain levels below the PEL. For guidance on
engineering controls refer to the ACGIH publication •'Industrial Ventilation1*.
Other: Eyewash station, safety shower and deactivating solution should be available. Refer to the
"Recommendations for the Safe Use and Handling of tnstapak* Foam-in-Pface Chemicals" bulletin before
handling instapak* chemicals. _
X ». • «OT AMUCMLt » I • «CTWf :MS«I8H'
-------
eao
Seated Air Corooranon
I-A
Page 4 of6
Issued 4/97
-. s« S«*«i>«t tfm <3v*w* c* rstta. sat
j SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES
Form: Liquid
Color- Dark brawn
QdQg Slightly aromatic (musty)
Vapor Pqp*iry/Air • t Y 8.5
Molecular Weight; AppTOX. 350
Melting Point- N. E.
Bailing Paint: 406" F (20S» Q fc
Vapor ?m«fire; < 10"* mm Hg @ 25" C (for Polymeric MDtt
Specific Gravity? 1.24 (§ 25* C
Bulk Demity IOJ IbS/gai
% Volatile hv Volume; Nil
Soltihilitv in Water Not soluble. Reacts slowly with water
to liberate CO] 2"i.
I SECTION 10 - STABILITY AND REACTIVITY
Stabiiitv Stable under normal conditions. Avoid temperatures above 110* F (43" C) or below 40* F (4° C).
Polymerization: May occur at elevated temperatures in the presence of moisture, alkalies, tertiary amines and
metal compounds.
Conditions to Avoid; Contact with moisture and other materials which contain active hydrogen.
Incompatible Material Water, amines, strong bases and alcohols. The faction with water is slow at
temperatures less than 1 20°F (49*C) but is accelerated at higher temperatures.
Decomposition Products Highly unlikely under normal industrial use. Exposure to fire or extreme
heat may generate oxides of carbon, oxides of nitrogen, and traces of hydrogen cyanide.
SECTION 11 - TOXICOLOGICAL INFORMATION
PolvmeHe MDI:
LD^, Oral:
LD^, Dermal:
LC<9, Inhalation:
>l5.SOOmg/kg(rat)
>SOOO mg/kg (rabbit)
370 - 490 mg/nW4 hours (rat) for an aerosol of polymeric MDI
Primary Routed of gxpn«ifg; Skin contact from liquid. Inhalation. However, due to the low vapor pressure,
overexposure is not expected under normal conditions unless material is heated or used in a poorly ventilated
inhalation: This product is a respiratory irritant and potential respiratory sensmzer. inhalation of vapor or
aerosol at levels above me occupational exposure limit can cause respiratory sensirization. Symptoms may
include irritation to the eyes, nose, throat, and lungs, possibly combined with dryness of the throat, tightness of
chest and difficulty in breathing. The onset of respiratory symptoms may be delayed for several hours after
exposure. A hyper-reactive response to even minimal concentrations of MDI may develop in viumml person:
Sensitized persons should be removed from any further exposure. Persons with asthma-type conditions or otne
chronic respiratory diseases should be excluded from working wim MDI. In a single evaluation of 5 men
occupationally exposed to MDI and hydrocarbon solvent vapors under conditions where adequate ventilation or
other safety precautions were oai used, neuropsychologic findings were attributed to MDI.
Conner. Mav came irritation or rash. Can cause skin discolonrion. Repeated and/or prolonged contact
may result in skin sensitizarion. There is limited evidence from laboratory tern that skin contact may play a r
in respiratory sensitization. This data reinforces the need to prevent direct skin contact and the importance 01
protective gloves.
x L • MOT OTA
-------
I
Seated Air Corporation
I-A
Page 5 of6
Issued 4/97
CT :u>a ;
.SECTION 11 - TOXICOLOGICAL INFORMATION (continued)
Eve <*ontacT- Liquid can cause eye irritation, tearing, reddening and swelling. Permanent corneai injury is
unlikely. Exposure co MDI vapors in excess of 0.02 ppm may cause irritation.
fflggsiinn: Ingestion is unlikely. Based on the acute oral LD,,, this product is considered practically non-toxic by
tngestion. tngestion can cause irritation and corrosive action in the mouth, stomach and digestive tract
ChrtmiC Effem: A study was conducted where groups of rats were exposed for 6 hours/day, 5 days/week for a
lifetime to atmospheres of respirable polymeric MDI aerosol either at concentrations of 0.0.2,1, or 6 mg/nV
(which corresponds to MDI levels equal to the OSHA-PEL. 5 times the OSHA-FEL and 30 times the OSHA-
PEL). No adverse effects were observed at 0.2 mg/m4 concentrations. At the I m§/mj concentration, minimal
nasal and lung irritant effects were seen. Only at the top concentration (6 mym1) was there an increased
incidence of benign tumor of the tung(adenoma) and one malignant tumor (adenocarcinoma). Overall, the
tumor incidence, both benign and malignant, and the number ofanimais with tumors were not different. The
increased incidence of lung tumors is associated with prolonged respiratory irritation and the concurrent
accumulation of yellow material in the lung. In the absence of prolonged exposure to high concentrations
leading to chronic irritation and lung damage, it is highly unlikely that tumor formation will occur.
Larctnaynteifv- The ingredients of this product <>0.1%) are not classified as carcinogenic by ACGIH or iARC.
not regulated as carcinogens by OS HA and not listed as carcinogens by NTP.
Mutagemcitv There is no substantial evidence of rnutagentc potential.
Regredugttve Effects: No adverse reproductive effects are anticipated.
TeraiQgenietTv and Fetotoxicity; No birth defects were seen in two independent animal (rat) studies.
Fetotoxiciry was observed at doses that were extremely toxic (including lethal) to the mother. The dose that
produced this effect (1.2 ppm) is 60 times higher than the OSHA-PEL. Fetotoxiciry was not observed at doses
that were not maternally toxic. The doses used in these studies were maximal, respirabie concentrations well in
excess of the defined occupational exposure limits.
SECTION 12 - ECOLOGICAL INFORMATION
Environmental Fate and Distnbutioq: It is unlikely that significant environmental exposure in the air or water
will arise, based on consideration of the production and use of the substance.
and Degradation; Immiscible with water, but will react with water to produce carbon dioxide, and
men and non-biodegradable solids.
Auatic Taxieitvr
EC»(24hour>:
ECW;
>IOOO my I (Zebra fish) At the highest level of 1000 mg/i, there were no deaths.
>IOOO my I (Daphnea magna)
>100mgrl(E.Coli)
I SECTION 13 - DISPOSAL CONSIDERATIONS
incinerate or dispose of in accordance with existing federal, state and local environmental control regulations.
This material is not a hazardous waste under RCRA 40 CFR 261 when disposed of in its purchased form. Small
quantities should be treated with deactivation solution outlined in Section 6. Refer to the "Recommendations for
the Safe Use and Handling of Instapak* Foam- m- Place Chemicals" bulletin for additional information
concerning disposal of wastes and empty containers. Chemical waste, regardless of quantity, should never be
pourea into drains, sewers or waterways.
If .MOTHTAVUIMQ M» .«OT»W,lCA*»Jl • I . «CTIVI l»«MCi
-".I ifltormtnon n iu»nniuw ».inoui -«w*iix (lamMO or .
-
-------
Sealed Mr Corporation
I-A
Page 6 of 6
Issued 4/97
T 1:00
SECTION 14 - TRANSPORT INFORMATION
DOT: Containers less than 5.000 pounds are not regulated.
IMP: Not regulated.
: Not regulated.
Quantity rROV 5.000 Ibs. for Methyiene diphenyl diisocyanaie (MDI\ CAS #101-68-8 (a 45% of
product).
SECTION 15 - REGULATORY INFORMATION
This product is considered hazardous under the Federal OSHA Hazard Communication Standard
:9CFR 19 10.1ZOO.
TSrA Status: All ingredients are listed or are not required to be listed.
SARA '0? gxtfgmetv Hazardous Substances: None
"!•"»?? Mayard Categories: Immediate (acute) Health Hazard
Delayed (chronic) Health Hazard
Reactive Hazard
in Mired (ngrediemsr This product contains the following chemicals subject to the reporting
requirements: 1 00% Otisocyanate compounds (Category Code N 1 20).
l^CRA Status: Discarded product is not a hazardous waste under RCRA, 40 CFR 261, when disposed of in its
purchased form.
j SECTION 16 - OTHER INFORMATION __
The following states have regulations that apply to the use of this product.
MA Massachusetts Hazardous Substance List NJ New Jersey Hazardous Substance List
PA Pennsylvania Hazardous Substance List
The appropriate state agency should be contacted for further details on regulatory requirements for the substances
shown below.
Methyiene bisphenyi isocyanate(MDI)
(Benzene. l.r-methylenefais(4-] isocyanato-)
CAS No.
101-68-8
Wt %
45
Sectioms) Revised: Format change
Printed on recycled paper (50* secondary material.
minimum 10% post consumer) using vegetable based inks
M-3 Rev. 4/97
-------
Material Safety Data Sheet
3m
Section TI
TRADE NAMt
Product Identification"-
DOT SHIPPING NAMC
Litntiii MBS (Contain* HBrnhnHi
708-438-1800
Lli£lli£2Jf
Section 2
Hazardous: Ingredients"
X NA 171?
ao-»i-e
108-91-fi
%
c is TUA: » PP»
< 30 T1»: 10 pp»
< 40 TUA: 10
Physical Data
jm.
Clear,
8*llw
Section 4
Rre 3: Explosion Hazard Data
HASH POINT |& METHOD USIS)
13SF TW
RAMMAIUUMtn M Affl WCTVOUIMC
I0WBI UTKR
TO 10
TEMKIUniBE
DO
EXTINGUISH INO MEDIA:
FT1AM
^
SPt OAinitE FIGHTlNerHOCEOUttS;
Firefighter* should uear full protective gear Including self
UNUSUAl H« AND fXPIOSION HAZAttT
Reactivitv Data
SlUtUTY(NO«MAl CONDITIONS)
O4
IONS TO AVOID
g.*.— fcir-* T"" •""••
ATCDIAIC
1O AVOID)
Strong *oid*» oiidizittg ignis
HALUtOOUS DECOMPOSTK3N PRODUCTS
Qud»« of Mrbott 2
HA2AROOUS POlfMEUZATiON
CONDITIONS TO AVOID
GRACE Dearborn
, OhMM W. R. GWCB i Co. - Co*.. 2M GMM Sn*. Id. Zurich. L 60047 {708» 438-1800
-------
I
Section 6
HealttrHazmxtinfonnatiarr
TOXIOTY INFORMATION;
Exposure level not established
for product. See Beetle* 3 fw oeaeonent
INHALATION: Inhalation of mist My irritate respiratory passages.
IMGESTION: Haroful if swallowed.
SXIN CONTACT: Prolonged or frecuent skin eortact will cause- irritation
and Mtf oause cheucal burns. Possible sfcia seesitlxer.
CYC PffUTflfT- tK^T «»!»•• «*T»4»^*^«p
EMERGENCT AND FIRST AID PHOC6OURB
INHALATION: ftwiove affeeta^ person to frwh air aid treat sgoptaM.
IN6ESTION: If eonseieus. give water to dilute ami contact physician
SKIN CONTACT, (lash uith soap ft water. Reeove contaminated clothing
~ -before reuse.
CTE CONTACT: Flush wit* water for 15 eiautes atd SMk eedical attention.
Section 7
Special Protection Infarrnatian
Vf NtlURON BEQUIUMENIS
RorecnoM
Long sl«*v« uork shirt «od pants. dMftiMlfiwUetiv* aprn
Spill or Leak Procedure
Sections
SICKIDIAKf IFMAimALtt
Extinguish all flam in tlw vjoiaittf. UMT pretootiv* eiothina i*aludi«f
eheaical i»esi*ta*t ewrshoe*. Dik» spill a»d sMk us o» an iaort abaorttnt
Flush aroa of spill utth «Mt«r.
WASTIOISPOillMfTHOO
Oispost of in '38-1800
-------
CAWOK INDUSTRIES, INC.
P.O. BOX 26447
Tespe, AZ 85225
Phone: 800-255-3423
602-258-2402
Date: flay I, 1910
MATERIAL SAFETY DATA SHEET
SECTION I - PRODUCT IDENTIFICATION
»»»»«»«*
Procuc: Nane: Al-5(R) DE-ICING FU)K>
General/Generic ID: Glycol-Alcohol Solution
SECTION II - HAZARDOUS INGREDIENTS ««»«««••
Tttll JTtlt
INGREDIENT
tthylene Glycoi*
ISOCTOpyl AlCOTiOl
CAS NO
107-21-1
67-63-0
CAS NAME
1,2-Elhanediol
2-Prcpanol
Wol
ee
W4*
PEL
£0ppa
400 ppa
TIV (UKITS)
50 ppa
ceiling vapor
400 pps
'Surest to reporting reqairenents of Section 313 of SARA Title II!
PROPERTY
Initial Boiling Point
Specific Gravity (H2C«1)
vapor Density
Percent Volstiles
8y Volune
Appearance and Odor
Vapor Pressure
Solubility in Water 5 by «t.
Evaporation Rate
SECTION III - PHYSICAL DATA.****'*»»»*»«"»»»"»«*«""»""«***««"»»"
REFINSCNT
ProAJCt
Heavier Than Air
Ingredients with initial
Soiling points below 425 deg F
Product
•Butyl Acetate
KASUREKNT
256 deg F (124 (ieg C) 1760 cs Kg
1.095 « 68 deg F (20 deg C)
2.5 (Air»l)
100*
Colorless liquid, faint alcohol odor
9.4 n Kg I 68 deg F (20 deg C)
loot
>i.OO
(R) Registered Tradeaark of Canyon Industries, Inc.
Page 1 of 3
-------
SXX*¥¥¥XX*XXTXftXXXXXX¥XXXTXX*XX¥*tTff¥X¥¥ SECTION IV - FIR£ AND EXPLOSION DATA «*»¥»T««¥M¥¥»¥T¥¥¥t¥rtx*¥¥r¥¥¥¥¥t¥¥X«¥
Flash Point: 138 deg f (Pensky-nartens, ASTM 93)
Flaaaable Liaits
in Air, I by Voluae: Coaponent (lowest) Lower: 2.0 Upper: 12.7
Extinguishing Media: tfater, Fog or Carton Dioxide or Dry Chenical
Special Fire Fighting
Procedures: Do not spray fires directly. A solid stress of water cirectes into net, cumin; liquid can
cause frothing. Use self-contained breathing apparatus and protective clothing
Unusual Fire and
Explosion Hazards: None
NFPA Ha:ard Rat ing: Health:! Fire: 2 Reactivity: 0
*XXXXX»¥¥¥¥X>XIXXXSXZXZX¥XIX¥irtS*»X¥¥¥¥X*¥*srr,T]QN \f —HgJIJH KAZARD DATA ¥XXXXX»X¥t»X¥»»¥¥¥¥¥¥X¥¥¥**X¥¥¥t¥«W¥¥¥t»XTX
Permissible Exposure Level (PEL): 50 ppa
Threshold Liait Value (TLV): 50 ppa
EFFECTS OF OVEREXPOSURE FOR PRODUCT:
Eyes: Can cause irritation, redness, tearing.
Skin: Can cause irritation. Prolonged or repeated contact can cause irritation, defatting,
deraatitis.
Breathing: Excessive inhalation of vapors can cause nasal and respiratory irritation.
Swallowing: Hay cause abdoainal dlscoafort and pain, dizziness, aalalse, luaSar pain, oiiguria, ureaia,
and central nervous systea depression. Severe kidney dauge accoapanies gross cverexposure.
Chronic effects
of Ovtrexposure: Inhalation of aists aay produce signs of central nervous systea effects, particularly
dizziness and nystagaus.
Other Health
Hazards: None currently known.
EMERGENCY AND FIRST AID PROCEDURES:
If swallowed: If conscious, give two glasses of water, induce vcaitingby sticking finger down throat. Call a
physician mediately. Never give anything by aouth to an unconscious person.
If on skin: Reaove contaainated clothing and thoroughly wash exposed area with soap and water. Launder
contaainated clothing before reuse.
If in eyes: Flush with large aaounts of water, lifting upper and lower lids occasionally. Get aedical attention.
If inhaled: If affected, resove individual to fresh air. If breathing is difficult, adainister oxygen.' If
breathing has stopped, give artificial respiration. Keep person wara, quiet, and get aedicai
attention.
*XZ¥¥¥X¥¥¥¥¥¥¥¥¥¥XX¥X¥*X¥¥¥¥XmtX¥¥¥¥T¥T¥¥¥¥X SECTION VI * REACTIVITY DATA *»**»**¥¥¥X¥¥¥¥¥X¥t¥¥¥¥¥¥»»»*¥¥¥¥¥»¥IX***X¥¥¥
HAZARDOUS POLYMERIZATION:
STABILITY:
INCCnPftTIBlLlTY:
HAZARDOUS COK8UST1W OR
DECOMPOSITION PRODUCTS:
Will not occur Conditions to Avoid: None
Stable Conditions to Avoid: Heat, sparks, and open flsaes
Strong oxidizing agents (e.g. nitric and sulfuric acids, peraanganates, etc.)
Burning aay produce toxic aaterlals: Carton dioxide and/or carbon aonoxide, etc.
Page 2 of 3
-------
«ECTIQN yjj „ SPILL OR LEAK PROCEDURES
STEPS TO 8E TAKEN IF CATER IftL
IS RELEASED Oft SPILLED: -Vcar suitable protective equipreRt.
•Small spills snould be flushed with large quantities of water.
-Larger spills should be collected for disposal.
Incinerate in a furnace where percittes under appropriate Feceral, State, :r.d local
regulations. See Section IX.
WASTE DISPOSAL METHOD:
SECTION VIII - SPECIAL PROTECTION 1NFORKATION
RESPIRATORY PROTECTION: Self-contained breathing apparatus in high concentrations.
IXXXXZXXZ¥¥X¥¥XISXZXXXSXTXXXXXXIXXXX
VENTILATION:
PROTECTIVE CLOVES:
EYE PROTECTION:
OTHER PROTECTIVE
Provide sufficient mechanical (general) and/or local exhaust ventilation to maintain exposure
below TLV (s).
wear resistant gloves such as: Rubber, Plastic, Neoprene, 8una-N.
Chemical splash goggles in compliance with OSKA regulations are advisee:.
Eye batn and safety snowr.
I¥f¥¥¥¥¥X¥?¥T¥X¥tZX¥1*I¥¥¥I¥IfITTIXXXXITXXTX SECTION IX • SPECIAL PRECAUTIONS "»»»W*>***¥T¥**¥*¥lr****l¥T**T**1¥1*¥I¥1¥
PRECAUTIONS TO 8E TAKEN IN HAilDLlNC AND STORAGE:
Keep away fron heat, sparks and open flasses.
nay be fatal if swallowed.
Do not breathe aist. Avoid prolonged or repeated breathing of vapor.
Avoid contact with eyes.
Vash thoroughly after handling.
Keep container closed. Do not store in open or unlabeled containers.
FOR INDUSTRIAL USE CM.Y
OTHER PRECAUTIONS: Uhere heavy concentrations of a fine list are present, a respirator should be used to
prevent inhaling aist particies. Containers of this aaterial nay be hazardous when
eaptied. Since eoptied containers retain product residues (vapor, liquid, and/or solid),
ail ha:ard precautions given in this data sheet oust be observed.
?I»*»tT»t»»ltXttX«tt*»t»*tIt»»I»»ft¥T»I»*f¥»
The information contained herein is believed to be accurate but is not warranted to be whether originating with
Canyon Industries, Inc. or not. The Information is presented solely for consideration, investigation, and
verification. Recipients are advised to confirm in advance of need that the information is current, applicable,
and suitable to their circumstances.
Page 3 of 3
-------
-------
EXERCISE #2: DETERMINING THRESHOLDS
MANUFACTURING CASE STUDY
Using the information in the exercise, complete the following tasks to determine which
chemicals will require you to prepare a Form R report.
1. Identify each listed chemical or chemical category manufactured, processed, and/or
otherwise used at the facility that you should evaluate for threshold determinations.
2. Use the attached threshold determination worksheets to determine which toxic chemicals
meet or exceed an applicable threshold for manufacture, process, or otherwise use.
3. Prepare Part II, Sections 1, 2 and 3 of Form R for each toxic chemical that exceeds an
applicable threshold.
Make any necessary assumptions and be prepared to identify the assumptions you have made and
the approach you used in completing this exercise.
Facility Description and Chemical Usage
Darcy Corp. operates adjacent plants at a site in central Ohio: Plant 1 manufactures industrial
refrigeration units and Plant 2 manufactures molded plastic components for a variety of
consumer product applications. Plant 1 employs a staff of 1,600 employees. Plant 2 employs a
staff of 800 full-time employees. The two plants operate independently.
Plant 1 uses Hi-Copper Brass Tubing (90.0 percent copper, 9.2 percent zinc) in the manufacture
of the air conditioners' components. The tubing is cut, bent into the appropriate shapes, and
welded into the air conditioning units. The purchasing department indicates that Plant 1 received
100,000 pounds of Hi-Copper Brass Tubing in the reporting year.
One of the refrigerants used by Plant 1 in its products is HCFC-22 (>98.0 percent pure). The
A100 series of refrigeration units use HCFC-22. In the reporting year, the facility produced 240
of these units, each of which contains 100 pounds of HCFC-22. Information provided by the
HCFC-22 supplier indicates that they delivered 20,000 pounds to the site's HCFC-22 storage
tank in the reporting year. Inventory records for the HCFC-22 storage tank indicated that the
tank contained 15,000 pounds at the beginning of the reporting year and 9,000 pounds at the end
of the reporting year.
Plant 1 paints certain refrigeration unit components using a paint that contains 10 weight percent
methyl-ethyl-ketone (MEK), a solvent. Paint booth logs indicate Plant 1 used 110,000 pounds of
this paint in these painting operations.
Plant 2 uses a resin in an injection molding process to make various plastic components.
Inventory records indicate that the facility used 300,000 pounds of the resin in the reporting year.
The resin contains 4 weight percent of barium hydroxide and 1.5 percent elemental zinc.
-------
Information obtained from the vendor indicates that during the curing of the resin, 1 pound of
ammonia is generated for each 100 pounds of resin used.
Inventory records indicate that 10,000 pounds of an adhesive that contains 12 weight percent
MEK was used as a solvent in the adhesive application operations in the reporting year.
In the reporting year, a contractor painted the exterior and interior of all buildings on site. The
contractor reported that their paint usage in the reporting year was 20,000 pounds, containing 5
weight percent MEK.
In the reporting year, remediation of soil contaminated with 1,1,1-trichloroethane (TCA) and 2-
butanone was conducted with a soil vapor extraction (SVE) system. After being processed
through an activated carbon adsorption unit that is 99 percent efficient in capturing the organic
emissions, the exhaust from the SVE system is emitted to the air through a stack. The SVE
system is estimated to extract from the ground and send to the activated carbon adsorption unit
20 pounds of TCA and 10 pounds of 2-butanone every month. The carbon is replaced every 10
months and the spent carbon is sent to ACME for incineration.
-------
1
J
fr
£
11
I
H g :g ;3
*3'1*
§
1
I
-------
I U !
1
8 8
r)
"S1
'iV
I— JS
11
PB
ci
en
I
•9
I i
-------
u
1
a
5
1
|||
HI
It
Si
!*
II
o 1
s
•3
I
"S
4
II
ia^8
.??£
2
"S
a
I
.
If
3
'Z
y, 81
A
S
1 ? ^
O v
^M 41
PC 2
ill
i ! 1
** b «B
c a *
I g. g.
§ i
u a
-------
If
^
I,
u
gig
a.!
h
I
•8
1*
WJ :
3
i:
•s
£
*
f
I
§
i*.-
s*
t'S
c
,
' Z
u
pa
A
«4
! f
§ .3
3 £
2
r
a
-------
Sir
u
I
s
n.
g
B!
1
1
5
i
Z
-------
^2'
Am
;••••*•
. •:-&*.
" *^ ^-
cs
tal:
II
I
3'1
I
•
S
A
nt subject to
Compare to thresh
If any threshold is
-------
Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category 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 chemical category.)
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 Chemical Name (Important: Complete
only if Part 1, 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 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
Produce
b.
Import
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
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. Basis of Estimate
(enter code)
C. % From Stormwater
Fugitive or non-point
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
Underground Injection onsite
Underground Injection onsite
to Class II-V Wells
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.
-------
Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category 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 chemical category.)
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 Chemical Name (Important: Complete only if Part 1, 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 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
Produce b.
Import
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
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
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
5.3.1
A. Total Release (pounds/year)
(Enter range code or estimate*)
B. Basis of Estimate
(enter code)
C. % From Stormwater
5.3.2
5.3.3
5.4.1
Underground Injection onslte
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; 8= 11- 499 pounds; C= 500 - 999 pounds.
-------
Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category 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 (he Section 313 list. Enter category code if reporting a chemical category.)
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 Chemical Name (Important: Complete only if Part 1, 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 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
{Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a. | Produce b. | Import
If produce or import:
Foron-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
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. Basis of Estimate
(enter code)
C. % From Stormwater
Fugitive or non-point
air emissions
Stack or point
air emissions
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
Underground Injection onsite
Underground Injection onsite
to Class II-V Wells
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.
-------
Page 2 of S
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category 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 exactiy as il appears on the Section 313 list. Enter category code if reporting a chemical category.)
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 Chemical Name (Important: Complete only if Part 1. 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, tetters, 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:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a.
Produce
b.
Import
If produce or import:
For on-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
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
Fugitive or non-pomt
air emissions
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
A. Total Release (pounds/year)
(Enter range code or estimate*)
B. Basis of Estimate
(enter code)
C. % From Stormwater
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
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.
-------
TRI RELEASE AND OTHER WASTE
MANAGEMENT REPORTING
THE EPCRA SECTION 313 REPORTING
PROCESS
SECTION 313 REPORTING
Importance of a structurad process for release and other waste
management reporting
• Ensures accurate data
• Reduces burden in completing Form R report
* Systematic approach reduces redundancy over time
> Team approach distributes responsibility
• Ensures compliance with TRI reporting requirements
-------
^
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
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
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
-------
i <¥,
TECHNIQUES FOR ESTIMATING
CHEMICAL QUANTITIES
r
a
Use at 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 (DMR»»
• Use Basis of Estimate code "M" if calculations based primarily
on monitoring data
ill
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
-------
* i ISS. •/:?;, :^ ..?"v!^ Taj.'! S'%: •< V;: "fff^ hm j.
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-
41)
m Use Basis of Estimate code "E"
10
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 IDS.; B = 11-499 IDS.; C = 500-999 Ibs.
12
-------
"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, 0} for
all numerical estimates, including "0"
13
FUGITIVE EMISSIONS
Part It, 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
14
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
15
-------
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 ,
to
CALCULATING WASTEWATER
DISCHARGES
• Calculate the yearly pounds of methane! discharged using the
following data concerning wastewater discharges of methanol
Date Cone. (mflfL) Flow (MGD) Aml.(lb5./day)
3/1 1.0 1.0 8.33
9(8 0.2 0.2 .33
Average^ 4.33
(4.33 Ibs./day) x (36$ days/yr.) = 1581 Ibsjyr.
MGD = million gallons per day
1 mgfl. a 8.33 Ibs./million gal
17
RELEASED TO LAND ON-SITE
Part II, Section S.4
» 5.4.1 Underground Injection on-site to Class I Wells
» 5.4.2 Underground Injection on-site to Class II-V Wells
Part II, Section 5.5: Releases to land
. 5.5.1A RCRA Subtitle C Landfills
. 5.5.1 B Other Landfills
• 5.5.2 Land treatment/application farming
. S.S.3 Surface impoundment
» 5.5.4 Other disposal
18
-------
RELEASED TO LAND ON-SITE
Approach: ID potential sources ~> ID data/tools ->estimate
Potential sources of release to (and
• Landfills
• Surface Impoundments
• Spills
• Leaks
Data/tools:
• Operating records/analytical data
• Spill reports
• Process knowledge
? 't fc;1 •• '^:- r
WASTE RELEASED TO LAND ON-SITE-
STORAGE
Storage of wastes on the land
• Regular shipment schedule
. Must transfer the waste off-site before that reporting year's
Form R report is submitted or July 1, whichever comes first
• Report material transferred off-site during the year in Part II.
Section G of Form R
• No regular shipment schedule
> Report material added to pile that remains on-site during the
year as the quantity released to land, Part II, Section 5.5.4 of
Form R
20
^
ON-SITE WASTE MANAGEMENT
Examples of on-site waste management (Section 7)
• Air Pollution control devices (Section 7A)
• Wastewater treatment processes (Section 7A)
• Energy recovery devices (Section 7B)
• Recycling devices (Section 7C)
21
-------
wiW '• ft -',» rtrt lute r ° "111 .'":« i'fi r fo • • jJJJfr-iri.1'? i-l; '-• % ]
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
22
MAXIMUM QUANTITY ON-SITE
Part II, 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
. 21
BEST PRACTICE: RECORDKEEPING
Importance of good recordkeeplng
• Detailed records improve reporting accuracy and data
quality
• Welt-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 year* (40 CFR 372.10)
• EPA will review records during a data quality audit
24
-------
^^
REFERENCE SOURCES
Estimating Releases and Waste Treatment Efficiencies
EPA Industry Guidance
AP-42: Compilation of Air Pollutant Emission Factors
Technology Transfer Network (http://www.epa.govfttn)
. AP-42
• Water 8/ChemDat 8 programs
• TANKS program
Perry's Chemical Engineer's Handbook: CKC Handbook of
Chemistty ami Physics; Lange's Handbook of Chemistry
25
-------
-------
OVERVIEW OF FORM R
i
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
-------
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
• SlCcode(s)
Identification numbers (RCRA, NPDES, Dun & Bradstreet,
Underground Injection Control)
Identifies key personnel
• Technical contact
• Public contact
-------
PART I. SECTIONS 1 AND 2
• Reporting year is the calendar year to which the reported information applies;
not the year in which the form is submitted
• Trade secret submissions require substantiation
• Two forms are required for trade secret submissions:
• One complete
• One "sanitized" version
• Separate process for national security claims
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR 19
SECTION 2. TRADE SECRET INFORMATION
2.1
. -4-__t J
••CTM?
nYas(AnHwquMtlcn2.2; I I No Donol«n«w«r
*n»di«jb«artiMionfonr») ' — ' t3 igolo Mellon 3
2.2
ll till* copy D Mlbta- D urwrtllMa
(AntWM arty If "YES" In 2.1)
PART I. SECTION 3
An original signature is required
Name must be legible (printed or typed)
Title of the official who signs is also required
SECTION 3. CERTIFICATION (Important: Read and sign after com pitting all form sections.)
I hereby certify that I have reviewed the attached documents and that, to Die best of my knowledge and belief, the
submitted Information Is true and complete and that the amounts end values In this report are accurate based on
reasonable estimates using data available to the preparers of mis report.
Hunt «nd
-------
PART L SECTION 4.1
All parts of the facility name and address are essential
Mailing address required if different from street address
TRI facility identification number (if a form was filed in a
previous reporting year) or "New Facility" (if reporting for the
first time)
SECTION 4. FACILITY IDENTIFICATION
4.1
:.nh(unrR«
MttthmogJ jftlftB J
SUULl
:ittfCountW$lM«Ze Coda 1
TRI FMCity ID Numb»r
fpnhty nrp^fn[i|JEfii««iBi««™»nrlulJi*nfl Adifcucc fit MRMWil ftnm «fm«f nrtiV.mil 1
M«lmn Ajjfl-0s J J
CttvtCourt^tiffts ^f. |
PART I. SECTION 4.1
Federal facilities
• Enter name of Federal department or agency standard
acronym followed by the site name
SECTION 4
.4, |
jauaautt>
fflMtJ
DMCourtvtfS1*aZK
FACILITY IDENTIFICATION
U.S. DOE Kama* City Plant
: •*! i
**
C?4l J
TRI Fftjiitv IONumb»r |
»M|j^^nMNm.V««M«rau..minmM«»miJ
jMadinn /y^g££ |
QtWCourtii'SlWa/Zri Coda 1
8
-------
PART I. SECTION 4.2 THROUGH 4.4
Specify whether the form covers all or part of the facility
• Federal facilities check only "c"
• List name and phone number
• Technical contact - should be able to explain data to EPA
• Public contact - should be able to represent the facility's
data to the public
SECTION 4. FACILITY IDENTIFICATION (Continued)
4.2
4.3
4.4
This report contains information for: i— i An entr. .— • Put rfi . r~l * P»*W
QgBSdoKeh«*igl>:clw<*cllq>f>iiaMi) LJ <•<*& >-> bdlly C'LJ tacitly
Technical Contact Name
Public Contact Name
rdophcna Nimbw (Indud. ma |
sooti
r«te|*oni Number (InelMiiina oxi*} 1
iiiifflMiiffl^
PART I. SECTION 4.5 THROUGH 4.6
Enter covered 4-diqrt SIC code(s)
• Enter primary SIC code in first box (a.)
• Enter other covered SIC codes in decreasing order of
significance
Supply latitude and longitude coordinates
4.9
4.6
SIC Code(s) (4-dlglts)
Latitude
Mirny
a.
DVM<
MndM
b.
S.OT1A
C.
Longitude
d.
0
-------
PART I. SECTION 4.7 THROUGH 4.10
Enter the specified identification numbers or "NA" if not
applicable
• Enter Dun and Bradstreet number(s)
• EPA ID numbers (assigned to RCRA-covered facilities)
• NPDES permit number(s)
• Underground Injection Well Code (UIC) I.D. number(s)
4.7
Dim & Bradstreet
Numbers) (9 digits)
i.
to-
4.
a
EPA Identification
Numbers) (RCRA
I.D. No.) ('2
characters)
a.
b.
4.
9
Facility NPDES
Permit Numbers)
(9 characters
a.
b.
4.10
Underground
Injection Well Code
(UIC) 1.0. Numberfs)
(12 digits)
a.
b.
11
PART I. SECTION 5
Private-sector and GOCO facilities
• Enter complete name and Dun & Bradstreet number of parent
company
Federal facilities
• Enter the complete name of department or agency for parent
company (e.g., U.S. Department of Interior)
• Check "NA" for Dun & Bradstreet number of parent company
5.2 Pirtnt Company's Dun A Bratereet Number [J NA (B digits)
-------
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
13
PART II. SECTIONS 1 AND 2: TOXIC
CHEMICAL OR MIXTURE IDENTITY
SECTION 1. TOXIC CHEMICAL IDENTITY
(Impomnt: DONOTcemplrtotNi
Mellon a you complc* .d Stolon 2 Mow.)
1.1
CM Hart*IUPOBTANT: Ert) ippan on Be S Ktai J« lit)
1.3
• Complete either Section 1.1 & 1.2 or Section 1.3 or Section 2
• Enter CAS number or category code and name of Section 313
chemical or chemical category (except on "sanitized" form)
• Enter generic name only if claiming Section 313 chem ical name as a
trade secret (Section 1.3)
SECTION 2. MIXTURE COMPONENT IDENTITY
2.1
(ImpafUnlr DONOTcwnpl««thi«
Men on II you comptate Socllon 1 drew.)
nrf7»clM^
• If supplier claims trade secret, report generic name by supplier
14
iiijmmmmiitiiti»i»imiiimitim»imm»ii»inmiiii!iiiiiiiiiii mmim minini itiitimiiimimiimiimmitimitiitiitiftiimi
-------
PART II. SECTION 3: ACTIVITIES AND USES
OF THE CHEMICAL AT THE FACILITY
• Specify use(s) of the Section 313 chemical: manufacture,
process, or otherwise use
• Report only activities taking place at reporting facility
• Check aji applicable boxes
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: check all thai apply)
3.1 MamiaohnlnetadcchBnileal:
aQ Produce b.D Import
If produce or import
cQ For on-aite use/processing
dO ForsaleWistiibulion
«Q Ai "byproduct
f.Q As in impurity
3.2) Proem thtunccteittcai:
aO Aiaraactant
bO As a formulation component
cQ As an snide component
dO Repackaging
3.3 1 WhemluineVntindccneMeal:
aj I At i chemical processing aid
bl""l As a manufacturing aid
cj 1 Ancillary orotherusv
15
PART II. SECTION 4: MAXIMUM AMOUNT
OF THE TOXIC CHEMICAL ON-SITE AT
ANY TIME DURING YEAR
Insert appropriate code from instructions indicating the
maximum quantity on-site
Use maximum total amount present at one time during
reporting year, even if Section 313 chemical is present at more
than one location at the facility
Include amounts in storage, processes, and wastes (but not
those amounts which have been previously land disposed)
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE
AT ANY TIME DURING THE CALENDAR YEAR
4.1
[ | (Entertwo-digitcodBlr
-------
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
17
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
-------
PART II. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Section 5.1 Fugitive or Non-Point Air Emissions
• Enter total fugitive releases of Section 313 chemical in column A,
including leaks, evaporative losses, building ventilation, or other
non-point air emissions
Section 5.2 Stack or Point Air Emissions
• Enter total releases to air from point sources, including stacks,
vents, pipes, ducts, storage tanks, or other confined air streams
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
S.1
5.2
Fugitive or non-point air
emissions
Stack or point air
emissions
DNA
DNA
A. ToURllUM[p-~u
tMlfannaft**
IMnrihnloMtalk)
!. BMhrf
Elttauto
[•nNreo4ti
C.*Fro»
Itomilu
;, -
PART II. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
• Section 5.3 Releases to Streams or Water Bodies
• Enter names of streams or water bodies to which your facility directly
discharges the Section 313 chemical
• Enter total amount of releases to each receiving stream or water body in
column A; include amounts from stormwater runoff, if available
• Indicate in column C the percentage of the total quantity (by weight) of the
Section 313 chemical contributed by stormwater
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
5.3
DlKti irgts to rtcaMng ThniniB or
wmter bodies {viler one mint per bo*
Strum or VW«r todr Nan*
5,3.1
5.3.2
5.3.3
', \
k ToMRdau|ri>unds««i|
-------
PART II. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Section 5.4.1 Underground Injection to Class I wells
• Enter total amount of Section 313 chemical injected into Class I
wells at facility in column A and basis of estimate code in column
B
Section 5.4.2 Underground Injection to Class II - V wells
• Enter total amount of Section 313 chemical injected into Class II - V
wells at facility in column A and basis of estimate code in column
B
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
S4.1
S.4.1
Underground bi)Ktl«u an-
>K>lDCI«nlVUII<
Undvgroml Hj«clion« on-
•»• loamU-VW.il>
DNA
DNA
X. loU RtfaM fcxntt
v««!linli»r«nir»>o
Mftjaaqprnlim*)
B. Bali*
Elfetlte
(•rtvaxn}
C. KFnB
•» ^ ^ ^
\
21
PART H. SECTION 5: QUANTITY OF THE TOXIC
CHEMICAL ENTERING EACH ENV. MEDIUM
• Section 6.5 Releases to Land On-Site
• Other disposal (6.5.4) includes spills or leaks of the Section 313 chemical to I
land
• Quantities of Section 313 chemicals released to air or water after initial
release to land (e.g., volatilization from surface impoundments) are not
included here
SECTION 9. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
S.S
5.5.1A
S.S.1B
9.0.2
5.S.3
5.3.4
Dl*po«al to hnd on-dto
RCRASuMKtoC landfill*
Other landfill.
Lind tmtimntfapplicitlon
farming
Surfio impoundmtni
Offer diiposil
NA
«. TiMIMinitBirAT
VtaJfiflifrTOCntormm
nHnxtmtvlOmMt
B. BiJtolErttol*.
(Mwcad*)
..f'H'r1:- . ..:.::;:::':?:V :'.v ^i-'1:'1? :..:!..J.2-::V::' .".-:•- 7?:?'.-:.~ji"t W^
n
D
a
a
a
22
-------
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 23
PART II. SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
OFF-SITE LOCATIONS
Section 6.1 Discharges to Publicly Owned Treatment Works
• Enter total quantity of the Section 313 chemical transferred
to all POTWs and basis of estimate
SECTION S. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1. A Tata) Quantity Transferred to POTWs and Basis of Estimate
6.1X1 TotriTimtmtpoundtfyori
(enter rang, code or utlmtte)
G.1A.Z BuilofEfllmtt
(inter cod*)
-------
PART IL SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS
TO OFF-SITE LOCATIONS
i Section 6.1.B POTW Name and Location
• Include name and address of each POTW
• Photocopy page 3 if reporting discharges to more than 2
POTWs (ATRS accommodates this without photocopying)
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
in. _ ' rc™""1"
POTW Address
City j State)
tva 1 POTWNime
POTW Address
| County) |ZH
City |sfat(j
[ Count)] Zlf
>
25
i«ffiiBHBinmiiiramfimfflfflffln^^
PART II. SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
OFF-SITE LOCATIONS
• Section 6.2 Transfers to Other Off-Site Locations
• Include name, address, and EPA identification (RCRA ID) number
• Enter quantities, basis of estimate, and codes for multiple activities (waste
treatment, disposal, recycling, and energy recovery) in Rows 1 through 4
• Photocopy page 4 if reporting more than 2 off-site transfer locations (ATRS
accommodates this without photocopying)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6.2. OFF-SITE EPA DEHTFICATIONNUIlBERIRCIUD NO.) I
OO-sta Loalion Mime |
OfhteAiMKSl |
•rj
SUkj | Cart? | | Zip j
K lOMBon MMttf eprtml < reporting ftdllly or fmt cUJyunyT QY» DNo
A. Total Tmn»fira(paund*ygar)
(•rttir rang! cod* Or Mllmito)
1.
i
).
4.
(antvcodi)
1.
1
3.
4.
C. TVp. of WMH TrgotrnwH [Nipooi'
RKycllna/E>»ray RMOV«V(«
-------
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
27
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
-------
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
Section 7A.a General Waste Stream
• Enter a waste stream code for each waste treatment method
sequence
» There are four waste stream types: Gaseous, Wastewater, Liquid
Waste, Solid Waste
Section 7A.b Waste Treatment Method(s) Sequence
• Enter code(s) from EPA instructions document for on-site waste treatment
method(s) used
• Enter code(s) regardless of whether waste treatment actually affected the
Section 313 chemical
• Report waste treatment method(s) used on aggregate waste stream as single
stream
• If applicable, enter codes in sequence in which they occur
29
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.c Range of Influent Concentration
• Use range of concentration of the Section 313 chemical in waste
stream as it typically enters treatment equipment
• Enter code(s) for concentration ranges (parts per million) from
EPA instructions document
• Section 7A.d Waste Treatment Efficiency Estimates
• Waste treatment efficiency expressed as percent removal of
Section 313 chemical from waste stream through biological
degradation, chemical conversion, or physical removal
» Use overall efficiency of waste treatment sequence, not a specific
waste treatment method
Use percent removal of Section 313 chemical only, not other
constituents of the waste stream
30
-------
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.e Based on Operating Data?
• Check "yes" if efficiency estimate is based on monitoring from
typical operating conditions
• Check "no" if efficiency estimate is based on published data for
similar processes or equipment supplier's literature, or if the
influent or effluent waste comparison or the flow rate was
otherwise estimated
31
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• i
!
Procedures for using two lines of data to enter 9 or more
sequential waste treatment methods
SECTION 7 A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
n Not Applicable (NA) - Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
» (Mini b W.«Tr»t«
WiMSmtm (««»>*.id«B>»»9 •
IMffcrte)
7A.U
W
7A.2*
7A.3a
A
ll PIT I 4! P61 I sl P«2 I
» | P21 | 7 | P21 [ »[ PH [
•I 1 \ 1 .'| 1
7A.1DI i 1 i 1
-_J 1 A01 21 HA
c. Rmytet
Irttart
CatMfm
7A.1C
NA
7A.2C
t
7A.3c
1
4. wul.
Traonilt
E Bnrioi
OpMXg
DM?
7A.1l
Y«* Ne
n D
7A.Z<
. VM No
ST O
7A.3*
In Hi
EI n
32
-------
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 wast
stream containing the toxic chemical or chemical category.
Eiwgr RMomy Mtt»* [«*' 1-chmctir adiM)
33
PART II. SECTION 1C: 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
D Not Applicable (NA) - Check here if no on-slte recycling is applied to any waste
stream containing the toxic chemical or chemical category.
34
-------
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
Exftmpl*:
If additional pages of Part II, Sections 6.2/7 A are attached, indicate the total number of pages in this
box d and indicate which Part II, Section} 6.2/7A page this is, here. D (example: 1.2.3. etc.)
35
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
required
36
-------
ATRS SOFTWARE
Technical Support
• Phone: 703-816-4434
• Fax: 703-816-4466
• e-mail: tris.user.support@epcra.org
-------
(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
United States
Environmental Protection
Agency
FORM R
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986,
also known as Title III of the Superfund Amendments and Reauthorization Act
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifield, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
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?
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 I 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 Addressfif different from street address)
Street
Mailing Address |
City/County/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
b.
Part of a
facility
A Federal
facility
4.3
Technical Contact Name
Telephone Number (include area code) [
Telephone Number (include area code) [
4.4
Public Contact Name
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 I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(DIG) I.D. Number(s) (12 digits)
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
D
5.2
Parent Company's Dun & Bradstreet Number
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
-------
Page 2 ol
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category 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 exectly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
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 Chemical Name (Important: Complete
only if Part 1, 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 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a. I Produce b. Import
If produce or import:
For ort-site use/processing
For sale/distribution
As a byproduct
As an impurity
As a reactant
As a formulation component
As an article component
Repackaging
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. Basis of Estimate
(enter code)
C. % From Stormwater
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 It-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. f I (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.
-------
Page 3 of 5
EPA FORM R
PART il. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRl Facility !D Number
Toxic Chemical, Category or Generic Name
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (Continued)
5.5
5.5.1A
5.5.1B
Disposal to land onsite
RCRA Subtitle C landfills
Other landfills
NA
A. Total Release (pounds/year) (enter range
code* or estimate)
B. Basis of Estimate
(enter code)
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
Zip
6.1.B.
POTW Name
POTW Address
City
State
County
Zip
If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
in this box | [ and indicate the Part II, Section 6.1 page number in this box | [ (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
Slate
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 pounds; C = 500 - 999 pounds.
-------
Page 4 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
Toxic Chemical, Category or Generic Name
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 (enter code)
1.
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4.
4. M
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
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.
1.
1. M
2.
2.
2. M
3.
3.
3. M
4.
4. M
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
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
Based on
Operating Data ?
7A.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
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.
-------
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
D
Not Applicable (NA)-
Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)J
2
SECTION 7C, ON-SITE RECYCLING PROCESSES
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)]
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
Column A
Prior Year
(pounds/year)
Column B
Current Reporting Year
(pounds/year)
Column C
Following Year
(pounds/year)
Column 0
Second Following Year
(pounds/year)
8.1
Quantity released **
8.2
Quantity used for energy recovery
onsite
8.3
Quantity used for energy recovery
offsite
8.4
Quantity recycled onsite
8.5
Quantity recycled offsite
8.6
Quantity treated onsite
8.7
Quantity treated offsite
8.8
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
8.9
Production ratio or activity index
8.10
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)
8.10.1
a.
b.
8.10.2
b.
8.10.3
8.10.4
a.
8.11
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES
NO
* Report releases pursuant to EPCRA Section 329(8) including "any spilling, leaking, pumping, pouring, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or disposing into the environment." Do not include any quantity treated onsite or offsite.
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
-------
POLLUTIONfRREyENTFON
REPORTING®*
POLLUTION PREVENTION HIERARCHY
THINGS TO REMEMBER WHEN
COMPLETING SECTION 8
Key concepts
• Waste streams
• Process streams
* Reputable recycling
• Source reduction activities
Develop consistent definitions for key terms
• Across facility
• Across agency/company
-------
Page 5 of S
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
Not Applicable (NA)-
Check here if no on-ste energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
2
SECTION 7C. ON-SITE RECYCLING PROCESSES
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)j
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
Column A
Prior Year
(pounds/year)
Column B
Current Reporting Year
(pounds/year)
Column C
Following Year
(pounds/year)
Column D
Second Following Year
(pounds/year)
8.1
Quantity released **
8.2
Quantity used for energy recovery
onsite
8.3
Quantity used for energy recovery
oftsite
8.4
Quantity recycled onsite
8,5
Quantity recycled offsite
8.6
Quantity treated onsite
8.7
Quantity treated offsite
8.8
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
8.9
Production ratio or activity index
8.10
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)
8.10.1
8.10.2
8.10.3
a.
8.10.4
a.
8.11
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES
NO
" Report releases pursuant lo EPCRA Section 329(8} including 'any spilling, leaking, pumping, pouring, emitting, emptying, discharging,
injecting, escaping, teaching, dumping, or disposing into the environment." Do not include any quantity treated onsite
-------
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
• Column A - Prior Reporting Year Estimate
• Column B - Currant Reporting Y««r Estimate
• Column C - Next Roporting Year Projection
• Column D • Following Reporting Year Projection
RELEASES AND OTHER WASTE
MANAGEMENT
Sections 8.1 through 8.7 at Form K
Quantity of a Section 313 chemical reported In Sections 8.1
not Include release* (including on-slte
and off-site disposal) and other off-site waste management
activities resulting from remedial actions, catastrophic
•vents, or one-time events not associated with production
mines should be reported in Section 8.8
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 dlsposing...into the
environment..." (EPCRA $329(8))
» Includes fugitive and stack air emissions, releases to
land, releases to water, underground injections, and on-
slte and off-site disposal
» Includes metals in wastes sent to a POTW (metals
cannot be destroyed)
-------
I
Section 8.1: Quantity Released (continued)
§ 8.1 = $5 » §6.2 (disposal only) * §6.1 (for metals and metal
compounds only) -§88 (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-slt« 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
ENERGY RECOVERY
Section 8.2: On-slte energy recovery
Quantity of Section 313 chemical used for energy recovery
on-slte
* Quantity actually combusted In the energy recovery unit
- not the quantity entering the unit
A code reported in Section 7B indicates that Section 8.Z
should be calculated
Possible data sources
» Engineering process specifications
> Mass balance calculations
» Best engineering judgement
-------
Hiitji mat m
ENERGY RECOVERY
• Section 8.3: Off-site energy recovery
• Quantity of Section 313 chemical that is transferred off-si la
for energy recovery
> Includes total quantity of Section 313 chemical
transferred off-site for energy recovery purposes - oof
quantity actually combusted off-site
• Possible data sources
» Section 8.2 (codes M56 and M92) of Form R
» Receipts from off-site facilities
» RCRA hazardous waste manifests
"'•'•" "'-"""""I" 'l™t."m«!..
RECYCLING
• Section 8.4: On-slte recycling
• Quantity of Section 313 chemical recycled on-slte
» 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 3.4
should be calculated
CALCULATING QUANTITY RECYCLED
IN SECTION 8.4
-------
I
RECYCLING
Section 8.5: Off-site recycling
• Quantity of Section 313 chemical (ranJferred off-site for
recycling
» Includes total quantity of Section 313 chemical
transferred to off-site location* for recycling
• Po»lbla 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)
WASTE TREATMENT
Section 8.6: Quantity treated on-slte
• Quantity of Section 313 chemical treated on-stte
» Includes all quantities of Section 313 chemical destroyed
• Possible data sources
» Calculations used to complete Section 7A of Form R
WASTE TREATMENT
Section 6.7: 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-lite 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)
Doe* not include Section 313 chemicals treated, recovered,
or recycled on-slte.
Excludes quantities in Sections 8.1 through 8.7
CALCULATING QUANTITY REPORTED
IN SECTION 8,8
Catastrophic,
Release
On-site \ (3)
Remedial
Cleanup
Off*stte Transfers
(1) *(2) * (4) - Total Section ».« Quantity
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8 (continued)
• Possible data sources
» Quantities reported in Part II, Sections 5 and 6
» Accident investigation reports
» Inventory reconciliation
> Mass balance calculations
» Monitoring reports (e.g., pH, discharge monitoring
reports, continuous emissions monitoring)
» CERCLA reports filed with the National Response Center
» Release notification reports required under EPCRA
section
-------
_ o
II
(N
-------
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(bN1))
• 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
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
PRODUCTION RATIO
Use production ratio if Section 313 chemical usage is directly
proportional to a production level
• Equation
Quantity of Product: Current Reporting Year
1.14
Quantity of Product: Prior Reporting Year
Example:
Oven manufacturing
40,000 ovens assembled (Current RY)
35,000 ovens assembled (Prior RY)
-------
ACTIVITY INDEX
Use activity Index if Section 313 chemical usage is related to an
activity at the facility and not to a production level
equation
Level of Activity : Current Reporting Year
Level of Activity: prior Reporting Year
Example:
Tank Washouts
60 Washouts (Current RY)
50 Washouts (Prior RY)
PRODUCTION RATIO OR ACTIVITY INDEX
Possible data sources
• Production reports
• Maintenance records for otherwise used chemicals
• Waste minimization section of the RCRA Hazardous Waste
Report
• Statefcorporate pollution prevention reports
SOURCE REDUCTION ACTIVITIES
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
-------
SOURCE REDUCTION ACTIVITIES
Section 8.10 (continued}
• Possible data sources
> Standard operating procedure*
> Process changes or equipment changes (e.g.,
replacements, adjustments)
» Raw material changes
» Work orders for process changes
» Product redesign specifications
» Audit reports and follow-up actions
> Waste minimization section of the RCRA Hazardous
Waste Report
> State/corporate pollution prevention reports
OPTIONAL INFORMATION
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
-------
-------
TRI UPDATE
TRI UPDATE
TRI expansion
• Industry Expansion
• PBT Reporting
Reporting form changes
Interpretive guidance
Form R submissions/revisions
INDUSTRY EXPANSION
| • TRI now covers seven new Industries (Metal Mines, Coal Mines,
Electricity Generating Facilities. Petroleum Bulk Terminals,
Chemical Distributors, Solvent Recyclers, & Hazardous Waste
Treatment and Disposal Facilities)
• First Form R report* were due by 7/1/99
• EPA has prepared guidance documents for specific
industries
• New Supplier Notification Requirements for facilities in SIC
codes 20-39
• EPA revised definition of "otherwise use" to include
treatment and disposal of wastes received from off-site
-------
iaH i •'! g,.i,!HBU MS I; i n WH M'B,'!ffl.|.W Sii'iiH WiWUPt
INDUSTRY EXPANSION
EPA considering petition to add SIC Code 45, Transportation
By Air (February 10,1998; S3 FR 6691)
• EPA also considering elimination or modification of the
motor vehicle exemption and otherwise use exemptions
PERSISTENT, BIOACCUMULATIVE, TOXIC
CHEMICALS
PBT final rule was published in the Federal Register on October
29,1999 (64 FR 58666).
• Effective for RY 2000. reports due by 7/1/01
* Does not impact reporting for RY 1999
Proposal to add Lead and Lead Compounds to the PBT list
published in Federal Register on August 1, 1999 (64 FR 42222);
EPA reviewing comments
PPA REPORTING
PPA (Section 8) reporting
• EPA may Issue proposed rule within the year
EPA considering petition to modify its guidance on "Energy
Recovery" to include the combustion of high-energy
chemicals for the purpose of destroying low-energy
chemicals in hazardous waste incinerators. (64 FR 15324;
March 31.1999)
-------
REPORTING FORM CHANGES
For RY 1999, the first SIC code reported should b« primary SIC
coda
Other recent modifications
• Underground injection: releases to Clan I wells reported
separately from releases to class It-V wells
On-iite landfills: releases to RCRA subtitle C landfills
reported separately from release* to other types at landfills
Report multiple chemicals on a single Form A certification
statement
FORM R SUBMISSIONS/REVISIONS
Voluntary revisions m
st be submitted by July 31 of the same
the reporting deadline for the revised data to be
included in the next TRI dan release
Form R submitted to replace previously filed Form A
Considered to be a late submission of a Form R and a
equest for a withdrawal of the previously filed Form A
• Do not check the revision boxl
No DOS version of ATRS for RY 1999
CHEMICAL MIGRATION GUIDANCE
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 and reported for
all media in Part II, Sections S, 6, and 8 of Form R
-------
THRESHOLD GUIDANCE
For threshold determinations, tho definitions of "manufacture.
"process," and "otherwise use" currently do nol include
Section 313 chemicals:
• Remediated
• Demolished
• Treated in wastes generated on site
• Stored
• Recycled on-slte for use on-sfte
These activities, !n and of themselves, do not constitute
threshold activities
OTHERWISE USE EXEMPTION GUIDANCE
Otherwise use exemptions do not apply to coincidental
manufacturing activities
• Ammonia colncldentally manufactured, as a result of the
degradation of the sewage, is not exempt under the
personal use exemption
• Acid aerosols and metal compounds manufactured as by-
products of fuel combustion
Section 319 chemicals in gasoline used to refuel motor vehicles
from off-site are considered processed and do not qualify for
the motor vehicle maintenance exemption
Laboratory activities exemptions only applies to certain
activities that take place In a laboratory.
-------
SECTION 313 CHEMICAL LIST
SECTION 313 CHEMICAL LIST
• Current list contain* over 600 Individual chemicals and
chemical categories (40 CFR 372.65)
• Top 20 chemicals for 1997 based on total waste
Methanol
Copper
Creosote
Phosphoric acid
Copper crnpds.
Nitric acid
Xylene (mix.)
Ethylene
Propylene
Zinc cmpds.
Ethylene glycol
Vinyl chloride
Chlorine
Sulfuric acid (aerosol)
Toluene
Ammonia
Lead cmpds.
n-Hexane
Nitrate cmpds.
HCI (aerosol)
SECTION 313 CHEMICALS AND CHEMICAL
CATEGORIES
Dynamic, evolving list
• Additions
• Deletions
• Modification*
Petition process to add or delete chemicals or forms of
chemicals
-------
CHEMICALS ADDED BY THE PBT RULE
Additions to TRI list effective 1(1/00 for reports due 7/1/01
• Benzo(g,h,i)perylene
* Benzo(J,k)fluorene (fluoranthene) & 3-methylcholanthrene
added as part of polycyclic aromatic compounds (PACs)
category
• Octochlorostyrene
• Pentachtorobenzena
• Tetrabromobisphonol A (TBBPA)
• Dloxin and dloxln-like compounds category
• Vanadium compounds
Modifications to TRI list effective 1/1(00 for reports due 7/1/01
• Vanadium (fume or dust) is now vanadium (except when in
an alloy)
CHEMICAL LIST CHANGES
• Proposed for deletion
* Phosphoric acid
• Chremite or* mined in the Transvaal Region of South Afric
and the unreacted ore component of the chromite ore
processing residue (COPR)
• Deletion proposals denied
• MEK
EPCRA SECTION 313 CHEMICAL
QUALIFIERS
Usted chemicals with parenthetic quallfl
to TRI reporting only If manufactured, process!
used In specified form. Below are some examples
Not raportaeli unli«» pnwent in tnt tpeelflea form
-------
METAL COMPOUND CATEGORIES
I • Consider the entire weight of the compounds In the category
when determining thresholds
| • Include only the weight of the parent motal 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
NITRATE COMPOUNDS
Water dissociable nitrate compounda category
• For threshold determinations, use the weight of the nitrate
compound, but use only the weight of Che 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
-------
DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
| • 20,000 pounds of nitric acid (HNO,) an nautrallzed with sodium
hydroxide (NaOH) in an on-slte wastewater treatment system.
Perform a threshold d«tarmlnation tar nitrate compounds
(water dissociable; In aqueous solution):
Assume
• Neutralization 100% complete and generates sodium nitrate
(NaNO,}, which I* released to a waWrbody
• Molecular weight (MW) of HNO, - 6J
• MWofNaNO, = 85
• 1 mol» of HNO, generate* 1 mole of NaNO,
10
DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
Example [continued)
Quantity of NaNO, manufactured • quantity of HNO,
neutralized x (MW of NaNOJMW of HNO,)
Quantity of NaNO, manufactured = 20,000 pounds x (85/63)
Quantity of NaNO, manufactured o 26,914 pounds
The 25,000 pound manufacturing threshold is exceededl
CALCULATING RELEASES FOR
NITRATE COMPOUNDS
Example (continued)
Ralaasss are reported on nitrate Ion (NO,') basis. Calculate the |
quantity of nitrate ion (MW of NO,- = 82) released (o a
watertaody:
Pounds of NO,-« pounds of NaNO, x (MW of NO,7MW of
NaNO,)
Pounds of NO,-« 26,884 pounds x (62/85)
Pounds of NO,- » 19,882 pound* (rounded to 20,000 pounds)
12
-------
NON-METAL COMPOUND CATEGORIES
Consider the entire weight of Hie 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 compound* in these categories
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 isonwrs)"
If data specifies o-xylene, m-xylena, 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 isonwr,
releases and other waste management quantities can be
consolidated in one report as "xylene (mixed isomers}"
I • Same logic applies to cresol, toluene diisocyanates
14
CHEMICALS MODIFIED
• Ammonia
Requires threshold determination and release and other
waste management quantity calculations for aqueous
ammonia from any source (i.a,, 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 RY1994
15
-------
CHEMICALS MODIFIED
Glycol ether* category
• Removed surfactant glycol ether* from category (59 FR
34386,7/5/94)
• Common glycol ethers (till In category Include:
, 2-Butoxyethanol (CAS * 111-76-2)
• Dlethylene glycol rnooewthyl ether acetate
(CAS #112-18-2)
. Dlethylene glycol monobutyl ether (CAS * 112-34-5)
• Effective RY1993
16
ADMINISTRATIVE STAYS
| • No reporting required for the following chemlcale until further
notice
• 2,2-Dlbromo-3-nltrtlopropionemide (DBNPA)
(CAS # 10222-01-2)
. Effective RY 1995
- Hydrogen sulflde (CAS * 77834)8-4)
» Effective RY 1994
• Methyl mercaptun (CAS #74-93-1)
. Effective RY 1994
17
-------
EXERCISE 4:
CALCULATING RELEASES OF AMMONIA AND NITRATE COMPOUNDS
During the calendar year, a facility uses 200,000 pounds of nitric acid solution containing 50
percent (by weight) nitric acid (HNO3) in an etching operation. All of the nitric acid is
eventually transferred to an on-site treatment facility as part of an aqueous waste stream. The
nitric acid is neutralized with pure (gaseous) anhydrous ammonia (NH3). The facility uses an
excess of ammonia to assure complete neutralization to pH 8. During the calendar year, the
facility used 30,000 pounds of ammonia. As a result of the treatment process, a nitrate
compound, ammonium nitrate (NH4NO3), is formed. The ammonium nitrate and any
remaining ammonia are then released to a waterbody.
Using the additional information below, complete questions a through d.
Assumptions
For simplicity, assume air emissions are zero.
Chemical Name Molecular Weights
Ammonium nitrate (NH4N03)
Ammonia (NH3)
Nitric acid (HNO3)
Nitrate ion (NO3~)
Chemistry Fundamentals
= 80.04 Ib/lbmol
= 17.03 Ib/lbmol
= 63.01 Ib/lbmol
= 62.01 Ib/lbmol
Nitric acid (HNO3) and anhydrous ammonia (NH3) are monovalent and react in a 1:1 ratio.
One mole of NH3 is used to neutralize each mole of HNO3 treated. When neutralized with
anhydrous ammonia, nitric acid (HNO3) produces ammonium nitrate (NH4NO3) in a 1:1 ratio.
These substances are monovalent, so for each mole of HNO3 neutralized, one mole of
NH4NO3 is produced. As indicated in the following formula:
HNO3 + NH3 * NH4NO3
Therefore, 63.01 pounds of nitric acid reacts with 17.03 pounds of ammonia to produce 80.04
pounds of ammonium nitrate (which contains 62.01 pounds of nitrate ion).
a) Based on the above scenario and information available, determine which toxic
chemicals would be subject to EPCRA section 313 threshold and release
determinations.
-------
b) Calculate the quantity of nitric acid applied towards threshold determinations and
release calculations.
-------
c) Calculate the quantity of ammonia applied towards threshold determinations and
release calculations.
d) Calculate the quantity of ammonium nitrate applied towards threshold
determinations and release calculations.
-------
-------
METAL AND METAL COMPOUND
REPORTING
EPCRA SECTION 313 METALS
| • Metals an EPCRA section 313 chemicals
• Examples:
» Elemental metals: chromium, nickel, manganese, cobalt,
silver, arsenic, copper
> Metal compound categories: zinc compounds, selenium
compounds, nickel compounds, chromium compounds
» Individually listed metal compounds: sodium
fluoroacetate, calcium cyanairide, lithium carbonate,
molybdenum trioxlde, titanium Mraehlorfde
Alloys are mixtures of elemental metals
• Stainless steels, nickel superalloys, brasses, aluminum
alloys, and carbon steels
EPCRA SECTION 313 METALS WITH
QUALIFIERS
Metais and metal compounds can have qualifiers:
• Zinc (fume or dust)
• Aluminum (fume or dust)
• Vanadium (fume or du»t)
» Beginning RY 2000, listing will change to vanadium
(except when in an alloy)
Aluminum oxide (fibrous forms)
-------
EPCRA SECTION 313 METAL COMPOUND
CATEGORIES
I Consider the entire weight of th* compound* in the category
when determining thresholds
I Include only the weight of the parent metal of the category (e.g.,
copper for copper compounds) when calculating releases, off-
site transfers, and waste management activities
•Hag wmnmmm mwau >
iiii&H
EPCRA SECTION 313 METALS
AND COMPOUNDCATEGORIES
Elemental metals and metal compound categories are
separately listed chemicals under EPCRA Section 313
• Separate threshold determinations
• Report for each listing (e.g., nickel or nickel compound
category) only If the threshold for each listing is exceeded
• If threshold exceeded for both the elemental metal & metal
compound category (e.g., nickel and nickel compounds),
you have options to report separately or file one combined
report
• CATEGORIES OF MANUFACTURING
ACTIVITIES
Manufacturing - generating a Section 313 chemical
• Combustion..When coal or oil are combusted, metal oxides ,
are manufactured
• Electroplating. In a nickel plating operation, elemental nickel
• and nickel compounds are manufactured
• Fume or Dust. Machining an aluminum part manufactures
aluminum (fume or dust)
• Importing. Importing copper ore = manufacturing copper
• BaneflclaUon of ore. Complex process where metal
compounds are converted to other metal compounds and
elemental metals
-------
CATEGORIES OF PROCESSING ACTIVITIES
Proceeding - incorporating a swoon 313 chemical Into a
product for further distribution in commerce
Metal* and metal compounds extracted from mines
distributed Into commerce
Metals are Incorporated Into a wide variety of products
including motor vehicles, consumer product*, Industrial
equipment, and various other products
Metals sent off-site for recycling or reuse
I
I
Otherwise using - Includes most activities that are not
manufacturing or processing
• Fabricating and/or using tooling
• Installation of process-related equipment and piping
. For example, constructing storage tanks
• Use of ash and waste rock for land contouring, structural
backfill, or soil building
THRESHOLD DETERMINATIONS: DATA
SOURCES
Mines
• Use ore analyses and geochemlcal knowledge
• Examine If Impurities are ever concentrated above dt
minimi* concentration
j • Industrial processing of alloys
• Use alloy specification* in addition to MSDSs to Improve
precision
* Be comprehensive: Some carbon steels and aluminum
alloys may contain manganese above dt minimi*
-------
ARTICLES EXEMPTION TEST
I • The three criteria for articles exemption status are:
• 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 use conditions at a facility
• Articles exemption is often inappropriately usedl
• A useful rule of thumb is that when metal Is melted,
machined, or ground, articles exemption usually NOT
applicable.
STRUCTURAL COMPONENT
EXEMPTION TEST
Structural components need to pass a test to be exempt. Test
has 2 criteria:
• Is part of the facility structure; and
• Is NOT process related.
Non-process-related structural Items eligible for the exemption:
• Potable water pipes and other non-process-related pipes
and structures
Procasssd-related items/uses NOT eligible for the exemption:
• Refractory brick, process-related pipes, anodes used In
electroplating, grinding wheels, & metal working tools
FORM R: AIR EMISSIONS
Fugitive emissions (Section 5.1) - - '
• Ambient air monitoring can Indicate emissions occurring.
Particular* emission data combined with speclatlon can be
used to estimate emissions
Stack emissions (Section 5.2)
• Many techniques available: adjusting permit estimates to
actual production, use of sampling data, back-calculation
from control device efficiencies and quantity of dust
collected, and engineering estimates
-------
FORM R: WASTEWATER DISCHARGES
• Wastewater discharges (Section 5.3 and/or Section 8.1)
• Calculate based on wastawater flows and measured
concentrations
• For metal* not measured, consider engineering estimate
(e.g., use ratio of metals In process and measured metal
quantity)
me; *t... vr iram la?.
FORM R: OFF-SITE WASTE TRANSFERS
• It's critical to be comprehensive!
• Potential off-site waste transfers of reportablo metals
• Hazardous waste
* Non-hazardous waste (e.g., waste oil and coolant)
• Trash
• Scrap metal (reuse versus recycle)
• Exercise caution when using TCLP data
FORM R: OFF-SITE WASTE TRANSFERS
Report final disposition of metal sent off-site for fur*
Off-site waste management codas for metals are disposal and
M41 SoUdificatlon/StabHIzabon-Metals and Matal
M82 Wastewater Treatment (Excluding POTW)-Matals
and Metal Compounds only
-------
TREATMENT OF METALS
Generally, metals cannot be treated or combusted for energy
recovery tor sections 6 and 8 of Part II of the Form R
• Metal* are elements and cannot be destroyed
• Exceptions Include conversions to non-listed chemicals,
Including:
» Aluminum (fume or dust) converted to a solution
» Barium chloride (Included in barium compounds
category) converted to barium sulfate (not included)
» Molybdenum trioxlde converted to molybdenum
carbonate
RECYCLE OR REUSE?
Metal sent off-site for direct reuse
• Is processing
* No contaminants removed
• De mlnlmis exemption applies
• Not reported on Form R
RECYCLE OR REUSE?
Materials sent off-site for recycling:
* Contaminants removed or usable materials extracted
• Is processing
• Da minimls exemption DOES NOT apply
• Report on Form R in Sections 6.2 end 8.5
-------
FORM R: SECTION 7, ON-SITE WASTE
TREATMENT
Part II, Section 7A: On-slte waste treatment methods and
efficiency
• Treatment INCLUDES removal from waste stream
• Report any waste treatment step through which a reportable
chemical passes
Air pollution control equipment and wastewater treatment
typically reported
FORM R: SECTION 8
Consistency with data reported on other parts of Form R is
critical
• Quantity Released: §8.1 = §5 + §8.2 (disposal codes only) »
§6.1 (metals and metal compounds only) - §8.8 (release or
off-site disposal only)
• Off-Site Recycling: §8.5 = §6.2 (recycling codes only) • §8 8
(off-site recycling)
• On-Sile & Off-Site Energy Recovery: §8.2 =• NA & §8.3 = MA
• On-Site 4 Off-Site Waste Treatment: §8.6 = NA 4 §8.7 • NA
» Remember exceptions when treatment of metals can
occur)
-------
-------
ACID AEROSOL AND FUEL
COMBUSTION REPORTING
ACID AEROSOLS
Aerosol forms include any airborne hydrochloric acid
(including mists, vapors, gases or fogs) droplets without regard
to particle size
Sulfuric acid listing modified, effective RY 1994
Hydrochloric acid listing modified, effective RY 1995
ACID AEROSOLS THRESHOLD
DETERMINATIONS
Manufacture - Acid aerosols manufactured from non-aerosol
acid solutions and as by-products of combustion
Processing - Acid aerosol or a reaction product is incorporated
Into a product for distribution into commerce
Otherwise Us* - Acid aerosol used, e.g., spray application for
etching, cleaning, neutralizing, without Incorporation into a
proouct
-------
ACID AEROSOLS THRESHOLD
DETERMINATIONS
Acid Rente Systems (Sulfuric and hydrochloric acid only)
• Acid aerosol manufactured and otherwise used.
• .Simplified method of estimating quantity for threshold
determination:
TotM System Volum* » Total Virgin Acid Added
• Amount Acid A«ro«ol» MimituturM/ottiMwi» UH<|
See EPA's Guidance lor Reporting Suffurle Acid (March
1998) tor specific calculations
4
vu 'ik.j.yisae <&,
ACID AEROSOLS TREATMENT FOR
DESTRUCTION
• Acid Aerosols Removed by Scrubbers
• Non-aerosol forms of sulfuricftiydrochloric acid are not
reportable under EPCRA Section 313
• Acid aerosols removed by scrubbers are converted to a
non-reportable form
• Report the quantity removed by the scrubber as treatment
for destruction
COMBUSTION
EPCRA Section 31J chemicals may be coincidental^
manufactured during combustion of:
• OH .
• Coal
• .Natural gas
• Wast*
• Other materials
-------
COMBUSTION - MANUFACTURING
Examples of manufactured chemicals:
» Hydrochloric acid aerosol, sulfuric acid aerosol
» Hydrogen fluoride
» Metal compounds and metals (e.g., mercury)
» Organics
» Dioxin
De minimi* does not apply
Most other exemptions do not apply
jiifj. . a- '."..'.Sir', •, ","! ..... •ai.'WMi.!' •• "-.a "" ••''!.!," .•
COMBUSTION - OTHERWISE USE
Combustion of fuel is also otherwise USB
De mtnimis and other exemptions would apply
Example: 1,2,4-lrimethylbenzene and n-hexane in No. 2 fuel oil
illiiiliiB!!
COMBUSTION & METAL COMPOUNDS
• Metal compounds and elemental metals in fuel are converted to
metal oxide
• If no other data available, assume compound is lowest weight
oxide that could be manufactured from metal
• Example
» Nickel in fuel -» Assume NiO not Ni,0, is manufactured
-------
COMBUSTION & METAL COMPOUNDS
• Amount of metal compound manufactured Is determined by
the total weight of the compound, not the parent metal
• Be comprehensive: include all metal compounds and all
combustion units and any other activities that may
manufacture metal compounds
• Elemental metal may be manufactured (e.g., mercury)
• Releases and other waste management estimates are based
on the weight of the parent metal
10
iu^i^ r a tw
METAL COMPOUNDS
Example calculation:
- During the year, a facility bums 7O,000 tons of coal with a
manganese (Mn) concentration of 141 micrograms/gram.
Lowest weight Mn compound manufactured •
Molecular weight Mn = 55
Molecular weight MnO = 71
Do they exceed the manufacturing threshold?
MnO
METAL COMPOUNDS
Amount MnO manufactured
= amount coal x concentration Mn x MW^MW
= 70,000 tons x 2,000 Itas/ton x 141 ug/g x 71/55
- 25,483 pounds
Threshold exceeded
-------
METAL COMPOUNDS IN COAL
• Sources of data for calculating amounts manufactured
• Fuel analysis, fuel specifications, or other supplier
information
• U.S. Geological Survey's (USCS) coal quality data base
(http://energy.er.usgs.gov/products/databases/CoalOual')
• Electrical Power Research Institute's (EPRI) PISCES data
base on coal constituents
• Tables In EPA's EPCRA Section 313 Industry Guidance:
Electricity Generating Facilities
13
METAL COMPOUNDS IN OIL
Sources of data for calculating amounts manufactured
• Producer's fuel analysis, fuel specifications, or other
producer information
• Tables in EPA's EPCRA Section 313 Industry Guidance
Electricity Generating Facilities
14
ACIDS FORMED DURING COMBUSTION
Hydrochloric acid aerosols and hydrogen fluoride form during
th* combustion of fuels/wastes containing chlorine & fluorine
• See EPA's EPCRA Section 313 Industry Guidance:
electricity Generating Facilities for emission factors
Sulfurlc acid aerosols form in stacks from combustion
processes of fuel oil, coal, and other sulfur-containing fuels
* Water and sulfur trioxide, products of fuel combustion, react
quickly to form sulfurie acid in the presence of moisture
• See EPA's Guidance for Reporting SuHuric Acid (M arch
1998) for specific calculations
-------
-'•!! • ia a
ORGANICS
Organic* may ba released during combustion, e.g., PACs,
formaldehyde
Manufacture of formaldehyde and releases of other organlcs:
see emission factors in EPA's EPCRA Section 313 Industry
Guidance: Electricity Generating Facilities
for more information on PACs: sea EPA'a Guidance for
Reporting Toxic Chemicals In the Polycyclic Aromatic
Compounds Category
16
an ii.aii.i
ii W :.'»• •' • .'•.," h
|j';;,!lniy-t"'|;j,i;tii..i,lii';'''|';i
RELEASES FROM COMBUSTION
• Sources of data:
• Monitoring data
• Facility-specific emission factors
• Emission factors in EPA's EPCRA Guidance for Electricity
Generating Facilities guidance document
17
COMBUSTION ASH
Combustion ash may contain manufactured metals and metal
compounds.
Ash released on-site (e.g., land disposal, fugitive air emissions)
• De mlnlmls exemption does not apply to manufacture of
metals and metal compounds as by-products
• Ash used on-slte to construct roads or berms should be
reported as release to land: other disposal (Section 5.S.4 of
Form R)
18
-------
COMBUSTION ASH
Ash sent off-site to be managed as a waste should be reported
In Section 6.2. Example: ash sent off-site for direct application
to land as roadflll
Ash sent off-site for direct reuse is not reported on the Form R.
Example: ash used to manufacture concrete blocks
Ash considered distributed Into commerce and, therefore,
processed
D» mlolmlt exemption can apply
-------
-------
MAINTENANCE CHEMICALS
AND OTHERWISE USE
MAINTENANCE CHEMICALS AND
OTHERWISE USE
Otherwise uses of Section 313 chemicals include:
• Maintaining process-related equipment and structures
• Cleaning process-related equipment and structures
• Other activities including waste treatment, process-
related building cooling/heating, and process-related
fuel use (not used in motor vehicle activities)
MAINTENANCE CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise used for
maintenance of process equipment and structures:
Xylene in paint
Zinc compounds in lubricating oils
Metal alloys in parts tooltng and equipment repair
Metal compounds in welding rods used to repair
equipment and structures
Metal compounds in refractory bricks used to line
furnaces
-------
! fd 8,'H *B -iiv&N"! an !'fil.iiWB!liBSieiHMT.'l,il.l;;
CLEANING CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise used for
cleaning process equipment and structures:
• 1,2,4-trimethyIbenzene in dies*! fuel used to clean bulk
storage tanks
• Phenol in paint strippers
• Xylene in degreasers
* Dlehlorofluoromethane In contact cleaners
ADDITIONAL CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise used at
facilities:
• HCFC-22 used to refrigerate product before sale
• Ammonia used to treat process water
* Ethylbenzene in fuel used to power process equipment
* Ethytene glyco) sprayed on coal piles to prevent
freezing
• Pesticides used in cooling towers to prevent algae
OTHERWISE USE
CHEMICAL EXEMPTIONS
For Section 313 chemicals otherwise used for mainten
or cleaning of non process-related equipment and
structure*, the following may apply:
• Routine janitorial or facility grounds maintenance
exemption
• Example: Xylene in cletners used to clean Hie employee
cafeteria
Structural component exemption
> Example: Toluene In paint used to paint the employe*
recreation center
-------
a at la wigo.-1 ii ••,• \s s n i
OTHERWISE USE
CHEMICAL EXEMPTIONS
Motor vehicle exemption if the chemical is used to
maintain motor vehicles operated by the facility
» Example: Xylerte in engine deoreasers used to maintain the
facility motor vehicles
Personal use exemption if the chemical is contained In
non-process related Items solely for employee personal
» Example: Chlorine to treat on-sita drinking water
.. 83" .'.r>f™ n? .• I:: -
OTHERWISE USE
CHEMICAL EXEMPTIONS
For Section 313 chemicals contained in like items (e.g.,
tooling) otherwise used for maintenance of equipment and
structures:
• Article exemption provided that the item:
» Is formed into a specific shape or design during
manufacture; and
• Has end-use functions dependent in whole or in part on iti
shape or design during end-use; and
» Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility [> 0.5
tbs.)
ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
Otherwise use chemicals are easily overlooked and not
accounted for In threshold determinations
Identify otherwise use activities even If a manufacturing
and/or processing threshold has been exceeded for a
section 313 chemical
Develop tools to identify and account for the otherwise use
of these chemicals in mixtures or trade name products
-------
'a'8'i; t i
ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
• Identify Die otherwise use activities at your facility and the
mixtures and trade name products used in those activities
• Identify the avenues through which these mixtures and
trade name products enter your facility
• Purchasing/Inventory . .
• Contractors
* "Credit card" or "emergency" purchases
• Sulk shipments
10
ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
Develop methods for orchestrating data collection of
mixtures and trade name products being otherwise used
• Coordinate with purchasing/vendors
• Develop inventory controls
• Require maintenance logs for process equipment
• Require requisition or "sign out" procedure for Section
313 chemicals from tool cribs and supply rooms
• Take year-end inventories
ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
Implement a program to gather real-time" data on
usage (I.e., every week, month, quarter)
• Suppliers may be slow to provide data
Use a team approach "
• Include all relevant personnel (e.g., engineering,
. environmental, operations, supply room, purchasing)
-------
ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
• Detailed records
• Improve reporting accuracy and data quality
• Reduce replication of effort from year to year
• Well-labeled calculation! and assumptions
• Serve a» standard operating procedures (SOPs) for
future years
• Ensure consistency from year to year, especially If
personnel responsible for reporting change
• All 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
13
-------
-------
FORM R /FORM A SUBMISSION:
GETTING IT RIGHT!
,;
ALTERNATE THRESHOLD RULE
• EPA published Final Rule (40 CFR 372.27; 59 FR 61501,
11/30/94)
• Reduced reporting option for low annual importable
amount*
> 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 pound* manufactured, processed,
or otherwise used, and
• Do not exceed $00 pounds of a Section 313 chemical
equivalent to the sum of the quantities released, transferred
off-site In wastes, combusted for energy recovery on- or off-
site, recycled, or treated on-sfte.
-------
(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number: 2070-0143
Approval Expires: 01/01/2001 Pa9e _Lof.
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifleld, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
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 of 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
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Street
Mailing Address
City/County/State/Zip Code
City/County/State/Zip Code
4.2
This report contains information for: (Important: check c if applicable)
A Federal
facility
4.3
Technical Contact Name
Telephone Number (include area code) [
4.4
Intentionally left blank
4.5
SIC Code (s) (4 digits)
Primary
b.
d.
4.6
Latitude
Minutes
Seconds
Longitude
Degrees
Minutes
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
n
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 (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
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 Chemical Name (Important: Complete only if Part J, 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 the Section 313 list. Enter category code if reporting a chemical category.)
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 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 the Section 313 list. Enter category code if reporting a chemical category.)
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 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 the Section 313 list. Enter category code if reporting a chemical category.)
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 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.)
EPA Form 9350-2
(Make additional copies of this page, if needed)
-------
ALTERNATE THRESHOLD RULE
Recordkeeplng
> All documentation to support the determination, Including
> Inventory, purchasing, and sales records
» Release calculations
» Wast* manifesto or receipts
» Other wests management data
OVERVIEW:
FORM R VS. FORM A
Standard Reporting
Method
Alternate Reporting
Method
Use for all levels of
releases and other waste
management
Use for tow annual
reportable amounts
(<500!bs.)
Report releases, other
waste management, and
source reduction
activities
Submit Certification
Form
Recordkeeplng
Requirements
Recordkeeplng
Requirements
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
-------
SECONDARYIMPACTS
Some Mat* and federal regulation* link fees, pollution
prevention planning requirement!, and storm water permitting
requirement! to the requirement to file i Federal Form R.
Facilities that become subject to TRI reporting as a result of the
PBT nil* may become lubjecl to additional requirement*.
EPCRA SECTION 313 ENFORCEMENT
!• Current enforcement trend*
• Shift from simply Identifying non-reporting facilities to
facilities submitting poor quality data
• Focus on multi-media Inspections (Le., across Agency
programs)
• Assign pollution prevention-related supplemental
environmental projects (SEPs)
• In FYM. 3«K of EPCRA penalty actions Included a SEP.
Most SEP* of any regulatory program.
EPCRA SECTION 313 ENFORCEMENT
Current enforcement trend*
• CKtien Initiated Enforcement
> EPCRA Section 313 and stormwatsr requirement*
generated thi largest number of calls to EPA hotlines —
over 22,000 for those two programs, end close to 40,000
for the FYM total.
121
-------
EPCRA SECTION 313 ENFORCEMENT
Koch Refining (UB5.000)
• Data quality violations
Sinclair Oil Corp, (1201,968 » 1350,000 SEP)
- Non-reporting and data quality error* on emissions
Coca-Cola Bottling Company (114,111»144,000 equipment to
LEPC}
• EPCRA Sections 311,312 and 111 violations
131
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 aubm It emergency follow-up notices under
Section 304
• Failure to submit an MSDS or a list of MSDS chemicals
• Failure to complete or submit Tier Ml Inventories
- Failure to complete or submit Form Rs or Form As
EPCRA SECTION 326: CIVIL ACTIONS
State and local government! may bring a civil action against a
pilvsta-seclar facility owner or operator for:
- Failure to notify the SERC regarding coverage under the
emergency planning and notification requlremente
• Failure to make relevant emergency planning Information
available as requested by the LEPC • - . - .
• Failure to submit MSDS or list of hazardous chemicals
• Failure to prepare or submit Tier mi Inventories
Any SERC or LEPC may bring a civil action against a facility for
failure to submit Tier II Information upon request
151
-------
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
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-slte 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 EO1Z85C
FORM COMPLETION CHECKLIST
Helpful hints for completing the Form R/Foim A
• Complete all required sections of a current, valid form
• Verify trade secret Information (H applicable)
• Correctly identify the Section 313 chemical using the correct |
CAS number and correct listed TRI name
• Use the MA 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
-------
FORM COMPLETION CHECKLIST (CONT'D)
• Result of completion errors
• Delay in processing of form
• Form prevented from being entered into the database
• To avoid completion errors, use EPA's ATRS software
* ATRS will prompt the user to complete required sections
ATRS will require the use of NA as a terminating indicator or
to denote data elements that are not relevant
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
OFF-SITE TRANSFER
REPORTING
Helpful hints for accurate off-site transfer reporting
• Do not report Intra-f acillty transfers as off-site transfers
Report the quantity of Section 313 chemical transferred, not
the entire transfer quantity
Identify waste treatment, disposal, recycling, and energy
recovery activities correctly
Results of off-site transfer errors
• Incorrect estimates (e.g., over-estimates)
Mlsclasslflcaflon of facility's handling of Section 313
chemicals In wastes
-------
r B. Mat e rt.a; i! M^a-
WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTION 8.1
Helpful hints for reporting quantity released, Section 8.1
• Include off-site disposal quantities (reported In Section 6.2),
on-site releases (reported in Sections 5.1 through 5.5), and
releases to POTWs for metals and metal compounds only
(reported in Section 6.1}
• Do not include non-production-related, one-time events
(e.g., catastrophic or remedial releases/transfers)
» These should be reported in Section 8.8
"iMHKPTI
WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTIONS 8.2-8.7
For on-site energy recovery (Section 8.2), on-site recycling
(Section 8.4), and on-site treatment (Section 8.6):
• Report the quantity of Section 313 chemical actually
recovered, recycled, or treated, not the total amount
entering the recovery, recycling, or treatment unit
For off-site energy recovery (Section 8.3), off-site recycling
(Section 8.5), and off-site treatment (Section 8.7):
• Conversely, report the total quantity sent off-site for
recovery, recycling, or treatment
» Vou are not required to know the efficiency of the off-site
unit'
WASTE MANAGEMENT AND SOURCE
REDUCTION
Helpful bints for Sections 8.2-8.7
• Energy recovery, Sections 8.2 and 8.3
> Report only for substances with significant heat value
(do not report halons, metals, or metal compounds)
» Do not include incineration activities
• Metals and metal compounds cannot be destroyed;
therefore, do not report quantities in Sections 8.8, or 8.7
241
-------
tKOn .fi'UBM 1 S M MBTBBtfMaMBi:
WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTION 8.8
Helpful hints for reporting catastrophic and remedial releases
and transfers, Section 8.8
• Section 8.8 is exclusive of Sections 8.1 through 8.7 (do not
Include Section 8.8 quantities in Sections 8.1 through 8.7)
• Section 8.8 quantities should be included in Sections 5-7 (as
appropriate)
25
FEDERAL FACILITY
IDENTIFICATION
Helpful hints for federal facilities
• Correctly identify department or agency
• Check box c. in Part I, Section 4.2 (or enter "F" on the ATRS
software)
• Correctly identify GOCO
• Use SIC codes in Part I, Section 4.5 that best describes the
facility's activities
• Results of Incorrect federal facility identification
• Double-counting
• Form entered into TRI database improperly
26
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
27|
-------
TRI KNOWLEDGE 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-A ways: 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.
A facility processes 21,000 pounds of formaldehyde each calendar year. It also imports and then
otherwise uses 9,000 pounds of formaldehyde annually. In addition, each year the facility
receives 15,000 pounds of solution that contains 34 percent formaldehyde by weight and
repackages it for distribution and sale. The firm is in SIC code 2834, ships over 600 pounds of
formaldehyde in wastes off-site for disposal, and has 20 full-time employees. Assuming these
values remain the same over the next five years, under section 313 this firm:
a. Must report for each calendar year.
b. Does not have to report for each calendar year, because the thresholds are not met.
c. Will not be required to report for each calendar year because it does not manufacture the
chemical.
d. Is not required to report because it employs less than 25 full-time employees.
Fifteen thousand (15,000) pounds of a listed chemical is purchased in the current reporting year
and is used in a re-circulating cooling jacket. This quantity remains in use indefinitely and no
additional quantity is added in subsequent years. Are you required to report for this chemical and
if so, for what year?
a. Do not consider this type of material at all because it is a purchased compound.
b. The use of the compound must be considered towards the otherwise use threshold for the
current reporting year only.
c. The use of the compound must be considered for the current reporting year and every
reporting year thereafter, until the mixture is replaced.
d. Consider only a part of the total amount the current reporting year, and a part every
reporting year thereafter, for the life of the mixture.
-------
3. A facility produces nitrate compounds as a result of its waste treatment operations, and transfers
the nitrate compounds to an off-site location, where all of the section 313 chemical is extracted
and recycled. Which of the following is true?
a. The facility can exclude amounts of the nitrate compound from threshold determinations
and release estimation because the source qualifies for the de minimisexemption.
b. Coincidental production of the nitrate compounds is not covered under section 313,
therefore the facility need not consider this source of chemical production towards
thresholds and estimation of off-site transfers.
c. The facility need not consider this source for thresholds and estimation of off-site
transfer because all of the listed chemical is eventually recycled.
d. The facility must include all amounts of the nitrate compounds coincidentally produced
in threshold determinations and release and other waste management calculations if it
exceeds a threshold.
4. Ten times per year, a facility receives chlorine in 1 ton cylinders. Half of the chlorine mixture 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. One fourth of the original mixture
is used to treat the drinking water consumed by employees. The remaining one fourth 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
wastewaters generated in conjunction with this operation are not exempt from section 313
reporting; however, the wastewaters from the cleaning operations are exempt.
-------
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
If a chemical on Section 313 list has a "qualifier," it means that it is subject to TRI reporting
when manufactured, processed, or otherwise used
a. in the thresholds specified (i.e., its reporting threshold is higher or lower than that for
other chemicals)
b. in the specified form or activity
c. within the specified SIC code industries
d. except when used at federal facilities
For aqueous ammonia, what percentage of the total ammonia present is applied to threshold
determinations?
a.
b.
c.
d.
100%
10%
1%
20%
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.
-------
9. Which of the following qualifies as a section 313 reporting exemption?
a. Like "articles" that release over 10 pounds of a section 313 chem icaK 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
10. In order to file a Form A Report, you must manufacture or process or otherwise use no more than
one million pounds of the toxic chemical and you must have
a. Less than 1,000 pounds of total releases and other waste management estimates of the toxic
chemical
b. No more than 500 pounds of total releases and other waste management estimates of the toxic
chemical
c. No more than 100 pounds of total releases and other waste management estimates of the toxic
chemical
d. No more than 50 pounds of total releases and other waste management estimates of the toxic
chemical
-------
PERSISTENT, BIOACCUMULATWE,
TOXIC (PBT) CHEMICAL RULE
The PBT Rule
PBT rate publMitd in Hi* Ftdtnl Rtoteter on October 29,1999
I64FR 58666)
Rule applies btglnnlng RY 2000. reports due 7/1/01
Ruto adds mwchcmkals toffra TRIIM
Rule create* a new class of chemicals (PBT chemicals) with
lower thresholds and special requirement*
PBT CHEMICALS AND THRESHOLDS
• lOOIWyr- AWfln
KMhoxychlor
Pendinwtnalin
• 10lhryr- Chlordane
Heptachtof
Mercury
Toxaphene
feodrln
PCBs
• 0.1gr/yr- Dtoxln and dkutin-lllu e
Polyeycltc aromatic eomp.
Trffluralln
Benzo(g,h,l)p»rytene
Hexachlorabenzene
Mkicuiy cofnpounciB
Pvntachlorobenzene
om pounds
-------
Illlilllilllllliillililliililililllllllilllllilii
PBT CHEMICALS AND EXEMPTIONS
The oc mlnlmls exemption has been eliminated for PBT
chemicals except for purposes of supplier notification
• Users of mixtures must use best readily available
knowledge ID determine PBT chemicals present and
concentrations
No other EPCRA section 311 regulatory exemptions were
modified or restricted by the PBT rule
PBT THRESHOLDS
The combination of the taw threshold* and no de mirfmif
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 tow volumes need to be considered
PBT CHEMICALS
Eighteen chemicals and chemical categories are regulated by the
PBT rule:
!• Pesticides - AMrln. Chlordane. Heetaehtor. Isodrln.
Methoxychlor, Pendlmeflialin, Toxaphene, and Trhluralln
AromaHcs • Benzo(g,h,l)perylene, Porycyclic aromatic
compounds (PAC) category, Dloxin and dioxln-fike compounds
category, Hexachlorobenzene, Octachlorostyrene,
Pentachtorobenzene. Porychtorinated blphenyl (PCS), and
Tetrabr omobiiphenol A (TBBPA)
la Metals-Mercury and Mercury compounds
-------
PBT CHEMICALS
The fallowing are NOT on the EPCRA Section 313 PBT list for
RY 2000:
Lead compounds
Cobalt
Cobalt compounds
Dicofol (pesticide)
Vanadium (except In alloy)
Vanadium compounds
POLYCYCLIC AROMATIC COMPOUNDS
3-MethylchloanthreM and BenzoU.klffliorani |fNioranthene,are
being added as numbers of the PAC category
All members (new and old) of the newly expanded PAC
category are PBT chemicals
BenzofohJlperylene Is an individually listed pel/cyclic
aromatic hydrocarbon (PAH) that Is a PBT chemical
• Other Individually listed PAHs are not In the category and
are not PBT chemicals
DIOXIN AND DIOXIN-LUCE COMPOUNDS
Dtoxln and dtoxhriike compounds category quainter reads:
and the processing or otherwise use of dloxin
and dtoxhi-iike compounds If the dtoxfn and dtoxln-like
compounds are present
contaminants in a chemical and if
they were created during the manufacturing of that chemical.
Category Includes polychtorinated dloxlns and furans with
chlorine In at least the 2,3,7, and 8 positions
-------
1
VANADIUM
I • PUT nil* modifies th* listing for vanadium:
• Vanadium, wlUi the qualifier "Aim* or dust," has b*tn on
. th* list of section 313 chemicals since 1987
• Qualifier now reads "except when contained In an alloy"
» "Alloy" does not Include slags, crystalline structures,
ores
» EPA is reviewing what actions to lake regarding alloys
PBT rule adds vanadium compounds to Oie TRI list
Neither vanadium (except when In an alloy) nor vanadium
compounds are on PBT list for RY 2004
PBT REPORTING
For PBT chemicals, iPA 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 oner wast* management quantities XJ.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 digital
• If 157.243 pounds calculated, report 1S7.2,1S7,160, or 200
pounds depending on accuracyrquallty of data source(s)
Similar recommendation for dioxln and dloxbi-Hk* compounds
but limit Is lower: 100 mlcrograms (equals 0.0001 grams)
• If 1.5724) grams calculated, report 1.57J4,1.572,1.57,1.6, or
2 grams depending on accuracy/quality of data sourcefs)
-------
X. S KfflM !• I1 *n**.W K *« TH1
EPA's PBT INITIATIVE
Initiative orchestrates activities across numerous EPA
programs; example activities under EPA's multimedia PBT
strategy:
• Integrated Urban Air Toxics Strategy and the Toxic
Substances Control Act (TSCA) PBT policy statement
» EPA Action Plan for Mercury
• International programs, e.g., Great Lakes Virtual Elimination
Strategy
• PBT Listserver: Email pbt-s trateqyjSunlxmail.rtpnc.epa.gov
Place subscribe into subject line and body
PBT Initiative's home page: http:ffwww.epa.gov/pbt/
-------
Newly Expanded Polycyclic Aromatic Compounds (PACs) Category
Name
Benz(a)anthracene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(j,k)fluorene*
Benzo(r,s,t)pentaphene
Benzo(a)phenanthrene
Benzo(a)pyrene
Dibenz(a,h)acridine
DJbenz(a,j)acridine
Dibenzo(a,h)anthracene
7H-Dibenzo(c,g)carbazole
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7,1 2-Dimethylbenz(a)anthracene
lndeno[1 ,2,3-cd]pyrene
3-Methylcholanthrene*
5-Methylchrysene
1-Nitropyrene
CAS#
00056-55-3
00205-99-2
00205-82-3
00207-08-9
00206-44-0
00189-55-9
00218-01-9
00050-32-8
00226-36-8
00224-42-0
00053-70-3
00194-59-2
05385-75-1
00192-65-4
00189-64-0
00191-30-0
£0057-97-6
00193-39-5
00056-49-5
03697-24-3
05522-43-0
New
Source: Persistent Bioaccumulative Toxic Chemicals; Final Rule (64 FR 58666; October 29, 1999)
The New Dioxin and Dioxin-Like Compounds Category
Name
2,3,7,8-Tetrachlorodibenzo-dtoxin
1,2,3,7,8-Pentachlorodibenzo-dioxin
1,2,3,4,7,8-Hexachlorodibenzo-dioxin
1,2,3,6,7,8-Hexachlorodibenzo-dioxin
1,2,3,7,8,9-Hexachlorodibenzo-dioxin
1,2,3,4,6,7,8'Heptachlorodibenzo-dioxin
1,2,3,4,6,7,8,9-Octachlorodibenzo-dioxin
2,3,7, 8-Tetrachlorodibenzofuran
1,2,3,7,8-Pentachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,7,8,9-Hexachlorodibenzofuran
2,3,4,6,7,8-Hexachlorodibenzofuran
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-Heptachlorodibenzofuran
1,2,3,4,6,7,8,9-Octachlorodibenzofuran
CAS#
01746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
03268-87-9
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
Source: Persistent Bioaccumulative Toxic Chemicals; Final Rule (64 FR 58666; October 29, 1999)
-------
PBT REPORTING
COMBUSTION
Combustion activities are expected to be the primary source of
PBT reports
Mercury, PACs, and benzo(g,n,i)perylene are contained in
residual fuel oil (#6). distillate fuel oil («), and coal
Dioxln and dioxin-like compounds and vanadium
compounds may also be manufactured during combustion
of these fuels
DIOX1N 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," May 1997 (EPA-454/R-97-003) is
available at http:(/www.*pa.govfttn;ehtefJap42etc.rrtml#L6
• "The Inventory of Sources of Dioxln In the United States,"
April 1998, (EPA/SOO/P-9W002Aa) is available at
http:flwww.epa.gov/neeawww1/diox.htni
-------
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Dloxin and dioxhi-tike compounds may also be manufactured
during tit* manufacture of chemicals Involving chlorine and
remain wtth the manufactured chemicals as Impurities
• Examples: Chloranll, Pentachtorophenol (PCP). Ethylene
dichlorlde (EDO), Vinyl chloride (VCk Polyvinytehlorlde
(PVC), 2,4-0,2,4-D Ester Herbicides
Dloxin and dloxuHIke compounds may be manufactured during
some metallurgical processes and at some pulp and paper mils
• For more Information: "The Inventory of Sources of Dloxin
In the United States"
MERCURY
Mercury may be present in mined ores
Mercury Is present In petroleum products and coal
• Combustion of fuels ht expected to be the main source of
mercury reports
Me re ury 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 Mr
Emissions From Sources Of Mercury and Mercury
Compounds," 12/97 (EPA-454/R-97412) Is available at
POLYCYCLIC AROMATIC COMPOUNDS
| • PACs are found in coal, fuel oil and other petroleum products
• Refiners, coal mines, and petroleum bulk terminals process
PACs
• Electricity generating facilities and many manufacturing
facilities otherwise use PACs In fuel combustion.
Ben2o(glh,l)peiylene is a separately listed PAH that can be
found where PACc an found.
For more Information see "Locating And Estimating Air
Emissions From Sources Of Porycycllc Organic Matter," 7198
(EPA-454IR-98-014) Is available at
httpJ/www.epa.oov»tbVchlef(ap42etc.htmWLE
-------
•"'' 'ii;
POLYCHLORINATED BIPHENYLS (PCBs)
• PCBs present in some dielectric fluid in electrical equipment
• Off-site shipment of PCBs for treatment or disposal does
not constitute a manufacturing, processing, or otherwise
use activity
• Could be processed if oil containing PCBs sent off site for
recycling
• Could be otherwise used if recycled/reconditioned oil with
PCBs put into service
• PCB transformers are considered exempt as articles if no PCBs
released during normal use
• PCBs could be present In fuel oils
TETRABROMOBISPHENOL A
• TBBPA - flame retardant used in plastics and engineering
resins for printed circuit boards and computer equipment
• TBBPA is used In polymers, such as
• Acrylonitrile Butadiene Styrene (ABS),
* Epoxy and polycarbonate resins,
• High-impact polystyrene,
• Phenolic resins,
• Adhesives,
• Unsaturated polyester resins, and
• Thermoplastic polyesters.
• Users of plastics with additive TBBPA may be Impacted as well
• TBBPA is used as a reactive or additive flame retardant
m m« i. ' -"-» •'•» mi T
iBk.. - ..... KWW Kin r EMBBJ
HEXACHLOROBENZENE
Hexachlorobenzene (HCB) is produced as a byproduct or
impurity in chemical manufacturing processes involving
chlorine
• HCB may be an impurity in many chemicals including.Freon
113, Penlachlorophenol, Polyvinyl chloride,
Tetrachloroethylene, Trichloroethylene, and 1,1,1-
Trichloroethana
HCB can also be manufactured during the combustion of
chlorinated organic compounds and coal
HCB can be manufactured when hexachloroethane is used to
remove hydrogen gas from molten aluminum
-------
OCTACHLOROSTYRENE
No commercial uses ofoctachlorostynne (OCS) are known , a
por/ehlorinated styrene
OCS Is a possible byproduct of chlorim production,
chlorlnaflon reactions, and metal product/finishing operations
OCS may also be formed by the high-temperature Incineration
of chlorinated hydrocarbons
OCS Is expected to be found where HCB is present
PENTACHLOROBENZENE
Pentachlorebenzene Is used as an Intermediate In the
production of the fungicide pentachloronitrobenzene
(quintozene)
Pentachlorabenzene may be produced In small quantities In
combustion processes such as medical waste Incinerators,
cement kilns, municipal waste and sewage sludge incinerators
and secondary copper production
Pentachlorabenzene Is expected to be found where HCB and
OCS are present
PESTICIDES
| • PBT listed pesticides Include:
• Aldrin, CMordane, Heptachlor, Isodrln, Methoxychlor,
Pendlmethalln, Toxapnene, and Trffluralln
All of these pesticides currently are TRI chemicals
Potential reporting facilities include manufacturers and
processors of the pesticides as well as TSDFs that manage
pesticide-containing wastes.
EPA does not expect any additional reports on these pesticide
from users of pesticides
-------
VANADIUM
Vanadium (except In an alloy) and vanadium compounds art
addid by the PBT rule but am NOT on TRIPBTlist
Vanadium is present coal, oil, and natural gas
• Vanadium oxide is produced during combustion of fuels
• Mnes, refiners, and «tectrtctty generating facilities expected
to be Impacted
| • Vanadium Is used to produce various allays
• Prior to becoming part of the alloy, vanadium Is a listed
chemical
• Once part of the alley, vanadium Is not a listed chemical
-------
-------
PBT Quiz
Multiple Choice: For each item below, circle the answer or answers that is the BEST response
for the question. All activities described below took place in RY 2000.
1. Which of the following chemicals is NOT a PBT chemical.
a. Mercury
b. Chloroform
c. PCBs
d. Mercury Compounds
e. Toxaphene
2. My facility manufactured .009 Ibs of dioxin and dioxin like compounds in our combustion
units, and also incorporated 11.4 pounds of mercury into thermometers for our company's
facility in Canada during the reporting year. Have I exceeded any thresholds?
a. No. The facility doesn't exceed the threshold for dioxin and dioxin like compounds and
the thermometers qualify for the articles exemption. Therefore, no thresholds have been
exceeded.
b. The facility must report for mercury, but does not exceed the threshold for dioxin
compounds.
c. The facility must report for dioxin and dioxin like compounds, but since the mercury is
going to another country, it doesn't have to report for mercury.
d. The facility must report for both dioxin and dioxin like compounds and mercury.
3. At Fred's golf club manufacturing facility, 5 pounds of polycyclic aromatic compounds
(PACs) are manufactured in the combustion unit, 55 pounds of PACs are processed in the
club handles, and 45 pounds of PACs are otherwise used by contractors that are constructing
a new manufacturing plant. Does Fred need to report for PACs?
a. No, none of the thresholds have been exceeded during the reporting year.
b. Yes, since 5 + 45 + 55 equals 105, Fred must report for PACs by July 1, 2001.
c. Yes, the processing and otherwise use activities both exceed a threshold.
d. Yes, Fred has to report, but he doesn't have to consider the contractors because they
aren't employed directly by Fred's company.
-------
4. Which of the following statements is TRUE for PBT chemicals?
a. Facilities can use the de minimis exemption for all PBT chemicals except for dioxin and
dioxin-Jike compounds
b. Facilities can report using the Form A for PBT chemicals
c. Fluorescent light tubes used and disposed uncrushed containing mercury are subject to
the articles exemption
d. Only count dioxin and dioxin-like compounds if they are manufactured at your facility
5. During the reporting year, PCB-containing oil in transformers at the site have been replaced
with non-PCB-containing oil. As a result of this project, 22 pounds of PCBs were shipped
off site to be combusted in an incinerator. What should be done?
a. Prepare a Form R report for PCBs.
b. Document that a threshold has not been exceeded.
c. Prepare a Form R or a Form A report for PCBs.
d. Call the National Response Center within 15 minutes.
6. Due to combustion of fossil fuels, 0.08 grams of dioxins are manufactured and released to air
through stacks. The facility also otherwise uses pentachlorophenol (which contains 0.03
grams of dioxins as an impurity) in an operation. The dioxins from this operation are also
released to the air through a stack. What should be done?
a. Prepare a Form R report for dioxin and dioxin like compounds and report 0.1 grams for
stack emissions.
b. Document that a threshold has not been exceeded because activity thresholds are
aggregated separately
c. Prepare a Form R report for dioxin and dioxin like compounds and report 0.11 grams for
stack emissions.
d. Prepare a Form R report for dioxin and dioxin like compounds and report 0 pounds for
stack emissions.
-------
INFORMATION RESOURCES
g Wcjjjj Jin »®fi>Mu mil I'iij a jt _' r [ a t, g1«
ADDITIONAL INFORMATION ABOUT TRI
EPA Regional and State TR! 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:
NstsenrerQunixmall.rtpnc.epa.80v.
Subject line: SUBSCRIBE TO USTSERVERS
Text: SUBSCRIBE Oast name>
SUBSCRIBE EPA-WASTE JOHN SMITH
Some mailing lists are:
• EPA-TRI2: Tonic R«l»»»« Inventory Federal Regiit»r»
• HOTLINE OSWER: RCRA. Suptrtund t EPCRAMonthlv Hotline Rtport
andUpdaMi
• EPA^RESS: EPA prais ratoam
• EPA-MEETING: EPA muting notification
• OPPT-NEWSBREAK: OPPT Library daily i)«w> Mrvio
-------
DOCUMENT DISTRIBUTION CENTERS
RCRA, 3up«f Mitt 4 EPCRA Hotllnt
(100) 424-U4*
(703) 412-M1* |DC M*tf» iru)
F« {703) 412-3113
h«p:#www.tpi.Dtjv;tpaotw«r/tiotllne
National C«raerfoc Environmental
Publications and Information (NCEPI)
1-WnM90.lt II
http:ffwww.epa.gov/nCQpirtom/
indu.ntml
U.S. Qovnninant Mining Offio (QPO)
(202)111-1100
F«»: (202) 512-2250
Hationil TeehniMl Infomution
S>rvic> (NT1S)
(«00) 553-SM7
1701) SOS-600C1 (DC MMro am)
ONLINE ACCESS TO TRI DATA
Right-to-Know Network (RTK NET)
• Modem: [202) 234-8570; Information: (202) 234-8494; Internet:
http:0www.rtk.net
ENVIROFACTS Database Internet Site
http:Wwww.epa. gov/«nvrro;html/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.rrlm.rilh.gov
• nominal access chafge
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 (nttp:0www.epa.govftri)
• 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 Ansimrs Document
(Revised 19*8 version)
• Automated TRI Reporting Software (ATRS)
SECTION 313 GENERAL GUIDANCE
Toxic Chemical Re/ease Inventory Reporting Form R ana
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 Ust of Lists)
• Most recent version on Internet:
http://www.epa.gov/tri/
SECTION 313 TECHNICAL GUIDANCE
Industry-Specific Technical Guidance Documents such as:
• estimating Chemical Releases From Electroplating
Operations
• Guidance tor New industries
(http://www.epa.gov/tri/9uidance.htm>
Chemical-Specific Guidance Documents such as:
• Guidance for Reporting Sulfurlc Add
• List of Toxic Chemicals within the Glycol Ethers Category
• http://www.epa.gov/tri/guidance.htm
Estimating Releases and Waste Treatment Efficiencies For the
Toxic Chemlcaf He/ease Inventory Form g I
-------
SECTION 313 TECHNICAL GUIDANCE
Technology Transfer Network (TTN)
• Help De»k (919) 541-5384
• Internet: http7fwww.epa.gov/ttn/
• Compilation olAIr Pollutant Emission Factor* (AP-42)
• Water 9/ChamDat 9 programs
• TANKS program
POLLUTION PREVENTION INFORMATION
• OPPT Pollution Prevention (P2) Internet Site
• http://www.epa.gov/opptintr'p2home/index.html
• EnvirotenSe 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
-------
-------
-------
------- |