r/EPA
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
April 15, 1998
EPA 745-B-98-003
                 EMERGENCY PLANNING AND COMMUNITY
                      RIGHT-TO-KNOW ACT SECTION 313
                GUIDANCE FOR METAL MINING FACILITIES
                                    (Version 1.1)
EPA
745-
B-
98-003
c.2
            U.S EPA Headquarters Library-
                 Mai! code 3404T
            1200 Pennsylvania Avenue NIW
              Washington. DC 20460
                  202-566-0556
                            Internet Address (JRLl • http://www.epa.gov

            Recycled/Recyclable • Pnnted with Vegetable Oil Based Inks on Recycled Paper (20% Postconsumer)

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                   United States              Office of Pollution           April 15,1998
                   Environmental Protection      Prevention and Toxics         EPA 745-B-98-003
                   Agency                  Washington, DC 20460
                  EMERGENCY PLANNING AND COMMUNITY
                       RIGHT-TO-KNOW ACT SECTION 313
                  GUIDANCE FOR METAL MINING FACILITIES
                                    (Version 1.1)
\>
                                    CONTENTS


     Section 1.   Introduction	1-1


     Section 2.   Section 313 Reporting Requirements	 2-1


     Section 3.   Making Threshold Determinations	 3-1


     Section 4.   Overall Section 313 Release Estimation	 4-1


     Section 5.   Calculating Release Estimations At Metal Mining Facilities.   5-1
                               U.S EPA Headquarters Library
                                    Mail code 3404T
                               1200 Pennsylvania Avenue NW
                                 Washington, DC 20460
                                    202-566-0556

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 SECTION 313 EMERGENCY PLANNING AND
    COMMUNITY RIGHT-TO-KNOW ACT


GUIDANCE FOR METAL MINING FACILITIES
                Version 1.1

               April 15, 1998

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                          TABLE OF CONTENTS

SECTION 1
      INTRODUCTION	*	 1-1

SECTION 2
      SECTION 313 REPORTING REQUIREMENTS	2-1
      WHO MUST REPORT? 	2-1
           Reduced Reporting	2-2
           What is a facility?	2-2
           How to Determine Your SIC Code	,	2-3
           How to Determine Your Number of Employees	2-4
      CHEMICAL ACTIVITY THRESHOLDS	2-4
           Manufacture	2-5
           Process	2-5
           Otherwise use	2-7
      EXEMPTIONS	,	2-11
      SUPPLIER NOTIFICATION REQUIREMENTS  . .  	2-15
      LISTED SECTION 313 CHEMICALS	 2-16
      WHAT MUST BE REPORTED''  	2-18
      DOCUMENTING REPORTING EFFORTS	2-19

SECTION 3
      MAKING THE THRESHOLD DETERMINATION	3-1
      CONDUCTING THE THRESHOLD DETERMINATION	3-3

SECTION 4
      OVERVIEW OF SECTION 313 RELEASE ESTIMATION	4-1
      GENERAL CONCEPTS	4-1
           Release Estimation	4-1
           Reasonable Estimates: Significant Figures and Use of Range Codes	4-6
           "NA" versus "0"	4-7
      REPORTING RELEASES IN FORM R, PART II	4-7
           Fugitive or Non-Point Emissions  	4-8
           Stack or Point-Source Air Emissions  	4-10
           Wastewater Discharges	4-10
           Underground Injection On-Site	4-12
           Release to Land On-Site	4-13
           Transfers in Wastes to Other Off-site Locations 	4-14
           On-site Waste Treatment Methods and Efficiency	4-14
           On-site Energy Recovery Processes 	4-15
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             On-site Energy Recycling Processes	4-15
             Source Reduction and Recycling Activities	4-16
             Quantity Released	%	4-16
             Quantity Used for Energy Recovery On-site	4-16
             Quantity Used for Energy Recovery Off-site	4-17
             Quantity Recycled On-site 	4-17
             Quantity Recycled Off-site	:. . . . 4-17
             Quantity Treated On-site 	4-17
             Quantity Treated Off-site 	4-18
             Quantity Released to the Environment as a Result of Remedial Actions,
                   Catastrophic Events, or One-time Events Not Associated with Production
                   Processes  	4-18

SECTION 5
      CALCULATING RELEASE ESTIMATIONS AT METAL MINING FACILITIES   5-1
      BENEFICIATION	5-1
      COMMINUTION 	5-3
             Crushing	5-3
             Sorting and Sizing	5-3
             Grinding	5-4
             Washing	5-6
      CONCENTRATION/CONDITIONING  	5-6
             Physical 	5-6
                   Gravity Concentration	,	5-6
                   Magnetic Separation	5-7
                   Electrostatic Separation	5-7
                   Filtration	5-7
                   Flotation	5-8
             Chemical Processes  	 5-10
                   Leaching	5-10
                          Heap Leaching 	5-11
                          Tank and Vat Leaching	5-12
                          Dump Leaching	5-14
                          In Situ Leaching  	 5-14
                          Bioleaching	5-15
                   Solvent Extraction 	5-15
                   Electrowinning	5-16
                   Zinc Precipitation 	5-18
                   Amalgamation	 5-18
                   Activated Carbon Adsorption	5-18
                   Ion Exchange  	5-20
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            Heat Processes	5-20
                   Calcining	5-20
                   Roasting	5-20
                   Sintering	5-21
                   Autoclaving 	5-21
                   Palletizing and Briquetting  	5-21

APPENDIX A
      ALPHABETICAL LISTING OF SECTION 313 CHEMICALS  	A-l

APPENDIX B
      LIST OF ACTIVITIES THAT FALL UNDER EACH SIC CODE
      IN MAJOR GROUP 10	B-l

                                LIST OF TABLES

Table 1-1. Summary of Reporting Requirements Under EPCRA  	 1-4
Table 3-1.  Examples of Manufactured, Processed, and Otherwise Used Chemicals
      at Metal Mines  	3.-1
Table 4-1.  SOCMI Average Emission Factors	4-9
Table 5-1.  Beneficiation Processes 	5-2
Table 5-2.  Emission Factors for Metal Mining Operations	5-5
Table 5-3.  Common Copper Beneficiation Flotation Agents
      Containing Section 313 Chemicals	5-9
Table 5-4.  Common Lead/Zinc Benefication Flotation Agents
      Containing Section 313 Chemicals	5-9


                                LIST OF FIGURES

Figure 4-1. Schematic of Typical Copper Mining Extraction and Beneficiation
      Wastestreams  	4-3
Figure 5-1. Flotation Process 	5-8
Figure 5-2. Heap Leaching	5-11
Figure 5-3. Heap Leaching with Zinc Precipitation 	5-12
Figure 5-4. Vat Leaching 	  5-13
Figure 5-5. Activated Carbon Adsorption	5-18
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TRI FORM R GUIDANCE DOCUMENT	METAL MINING FACILITIES

                                      SECTION 1
                                  INTRODUCTION
                                                         »
This guidance document has been prepared to assist metal mining facilities in complying with
the reporting requirements of Section 313 of the Emergency Planning and Community Right-to-
Know Act (EPCRA, Public Law 99-499, Title III of the Superfund Amendments and
Reauthorization Act of 1986, hereafter EPCRA Section 313) and Section 6607 of the Pollution
Prevention Act (PPA). This guidance document is intended for use along with the Toxic
Chemical Release Inventory Reporting Form R and Instructions document published annually by
the U.S. Environmental Protection Agency (EPA). For further assistance and to obtain copies of
the latest version of this instruction document, contact the EPCRA Hotline at 1-800-535-0202.
The other EPCRA reporting programs are summarized at the end of this section.

One of the primary goals of the EPCRA program is to increase the public's knowledge of, and
access to, information on both the presence of Section 313 chemicals in their communities and
on releases and other waste management activities of Section 313 chemicals into the
environment.  Since 1987, certain facilities in the manufacturing sector have been reporting
information on releases and other waste management activities of Section 313 chemicals to EPA
and states throughout the United States.  As a result of an EPA rulemaking (62 FR 23834, May 1,
1997), certain additional industry groups, including metal mining facilities (Standard Industrial
Classification (SIC) Major Group 10, except 1011, 1081, and  1094) are now required to evaluate
their chemical use and management activities to determine potential reporting responsibilities
under EPCRA Section 313.

Section 313 establishes annual reporting requirements for Section 313 chemicals provided that
certain activity thresholds are met.  Section 313 includes a list of over 650 chemicals and
chemical categories. These chemicals and chemical categories were either originally selected by
Congress or were added by EPA through rulemaking.

The Section 313 reporting requirements apply to owners or operators of facilities which meet all
of the following three criteria:

      •      The facility must be  in SIC code 10 (except  1011, 1081, and 1094), or  12 (except
              1241), or 20-39 (manufacturing facilities), or 4911  (limited to facilities that
             combust coal and/or oil for the purpose of generating power for distribution in
             commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose
             of generating power for distribution in commerce) and 4939 (limited to facilities
             that combust coal and/or oil for the purpose of generating power for distribution
             in commerce), or 4953 (limited to facilities regulated under RCRA subtitle C), or
             5169, or 5171, or 7389 (limited to facilities primarily engaged in solvent recovery
             services on a contract or fee basis); and,

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       •      The facility must have 10 or more full-time employees (or the total hours worked
              by all employees is greater than 20,000 hours), and

       •      The facility manufactures (defined to include importing), processes, or otherwise
              uses any Section 313  chemical in quantities greater than the established threshold
              in the course of a calendar year.

For each Section 313 chemical or chemical category, covered facilities must report the total
annual releases, both routine and accidental, to all environmental media; and other on-site waste
management activities, including quantities recycled, combusted for energy recovery and treated
for destruction, and off-site transfers for disposal, waste treatment, energy recovery and
recycling. This information is submitted on the Toxic Chemical Release Inventory (TRI)
Reporting Form, which is called the "Form R." (As discussed in the following chapter, facilities
meeting certain conditions are eligible to report using an abbreviated Form A.)

The annual Form R or Form A reports are submitted to EPA headquarters and to a state
designated agency, usually a State Emergency Response Commission (SERC), or in some cases a
Tribal Emergency Response Commission (TERC), annually on or before July 1 st for activities
occurring during the previous calendar year (e.g., July 1,  1999, for activities during the period
from January 1 to December 31, 1998).

EPCRA mandated that EPA establish and maintain a national TRI database to assist in research
and the development of regulations, guidelines, and standards related to Section 313 chemicals
and to  make the TRI data available to the general public and any interested parties.  The TRI
database is computer-accessible to anyone with a modem via the National Library of Medicine's
TOXNET on-line system.  The TRI data are also available through many other sources, including
EPA's Internet Web site; public libraries on microfiche; the Government Printing Office on CD-
ROM,  and the National Technical Information Service on magnetic tape and individual  state
diskettes.

Facility owners or operators who violate the Section 313 reporting provisions may be assessed
civil penalties of up to $25,000 per day for each violation. In addition, state enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.

This document is organized into several sections to provide quick reference.  Section 2  presents
an overview of the Section 313 reporting requirements. Section 3 provides a detailed discussion
of how to make threshold determinations regarding the manufacture, processing, and otherwise
use of Section 313 chemicals.  Section 4 covers general concepts relating to reporting and release
estimating, and provides potential data sources for determining releases at metal mining facilities
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and other amounts managed. Section 5 presents a detailed discussion of EPCRA Section 313
release and other waste management scenarios in the metal mining industry and covers
developing estimates of releases and other waste management activities for several types of
operations commonly encountered by the metal mining industry. Finally, Appendix A provides
an alphabetical listing of the Section 313 chemicals and chemical categories subject to EPCRA
Section 313, the de minimis concentrations for each Section 313 chemical, and the RCRA status
of the chemical.  Appendix B provides a table listing the efficiencies of RCRA treatment
technologies. Appendix C provides a bibliography of relevant EPA documents used to help
metal mining facilities in complying with EPCRA Section 313.
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             Table 1-1. Summary of Reporting Requirements Under EPCRA
  EPCRA
  Section
                          Reporting Requirements
  Sections
  302 - 303
  Presence of
  Extremely
  Hazardous
  Substances
  (40 CFR
  §355.30)
If a facility has  one or more "extremely hazardous substances" present on site in
quantities greater than Threshold Planning Quantities (TPQs) established by EPA, it
must notify its State Emergency Response Commission (SERC) and Local Emergency
Planning Committee (LEPC) that it is subject to the emergency planning requirements
of these sections.  A facility representative must be designated to participate in the local
emergency planning process. The facility also must provide any information deemed
necessary for development or implementation of a local emergency plan.
  Section 304
  Emergency
  Notificatio
  n (40 CFR
  §355.40)
A facility must notify the LEPC and SERC immediately of the release of any "extremely
hazardous substance" (listed in 40 CFR Part 355, Appendices A and B) or any hazardous
substance under CERCLA (listed in 40 CFR 302.4), in amounts at or above the specified
Reportable Quantities that EPA establishes for each substance. The facility must follow
up this initial notification with a written statement providing details of the incident.
  Section 311
  Material
  Safety Data
  Sheet
  (MSDS)
  Reporting*
  (40 CFR
  §370.21)
A facility must submit to the LEPC, SERC, and local fire department a list of Material
Safety Data Sheets (MSDSs), or copies of MSDSs, for any "hazardous chemicals" (as
defined  under the  Occupational Safety and Health Administration (OSHA)  Hazard
Communication  Standard) that are present on site  in quantities greater than 10,000
pounds.  A facility also must report any "extremely  hazardous substances" (EHS) (as
defined under Section 302) that are present on site in quantities at or above the  TPQ or
500 pounds,  whichever is less.  Submissions are required within 90 days of the date
when new chemicals are first present at or above specified  thresholds or  if new
information on previously reported chemicals becomes available.  Some states have
established lower activity thresholds.
  Section 312
  Hazardous
  Chemical
  Inventory*
  (40 CFR
  §370.25)
A facility must submit to the LEPC, SERC, and local fire department certain information
for any "hazardous chemical" or EHS reportable under Section 311. This information
is most  commonly submitted on a Tier I or Tier II Form and includes a description of
any type of hazard the material may pose, the quantities stored, general storage locations,
and type of storage. The reports for each calendar year are due on or before March 1 of
the following year. Most states require or request that facilities submit the more detailed
Tier  II reporting form or a state-issued version of that form. In  addition, some states
have established lower activity thresholds and require more detailed or  additional
information.                          ;
        Facilities that are not subject to OSHA are not covered by EPCRA Sections 311 or 312.
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  EPCRA
  Section
                           Reporting Requirements
  Section
  313: Toxic
  Chemical
  Release
  Inventory
  Reporting
  (Form R)
  (40 CFR
  §372)
A facility in certain SIC codes meeting threshold/equirements is required to report
annually amounts of listed Section 313 chemicals released or otherwise managed to
EPA and designated state agencies. Section 313 includes a list of over 650 chemicals
and chemical categories. Release reporting information is submitted on the Toxic
Chemical Release Inventory (TRI) Reporting Form, Form R.

The Section 313 reporting requirements apply to owners or operators of facilities
which meet all of the following three criteria:

•     Facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except
       1241), or 20-39 (manufacturing facilities), or 4911 (limited to facilities that
       combust coal and/or oil for the purpose of generating power for distribution in
       commerce), 4931 (limited to facilities that combust coal and/or oil for the
       purpose of generating power for distribution in commerce) and 4939 (limited
       to facilities that combust coal and/or oil for the purpose of generating power
       for distribution in commerce), or 4953 (limited to facilities regulated under
       RCRA subtitle C), or  5169, or 5171, or 7389 (limited to facilities primarily
       engaged in solvent recovery services on a contract or fee basis); and,

"     Facility must have 10  or more full-time employees (or the total hours worked
       by all employees is greater than 20,000 hours), and

•     Facility must manufacture (including importation), process, or otherwise use a
       listed Section 313 chemical in excess of specific threshold quantities.

The threshold quantities for reporting under Section 313 are based on the amount of
the Section 313 chemical manufactured, processed, or otherwise used during the
calendar year.  Specifically, the thresholds are greater than 25,000 pounds if
manufactured, or 25,000 pounds if processed, or 10,000 pounds if otherwise used.

EPCRA mandated that EPA establish and maintain a national TRI database to assist
in research and the development of regulations, guidelines, and standards related to
Section 313 chemicals and to  make the TRI data available to the general public and
any interested parties.  The TRI database is computer-accessible to anyone with a
modem via  the Internet or the National Library of Medicine's TOXNET on-iine
system.
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                                      SECTION 2
                    SECTION 313 REPORTING REQUIREMENTS
WHO MUST REPORT?

A facility is subject to the provisions of the Section 313 reporting requirements if it meets all
three of the following criteria:

       •      The facility must be in SIC code 10 (except 1011,1081, and 1094), or 12 (except
              1241), or 20-39 (manufacturing facilities), or 4911 (limited to facilities that
             combust coal and/or oil for the purpose of generating power for distribution in
             commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose
             of generating power for distribution in commerce) and 4939 (limited to facilities
             that combust coal and/or oil for the purpose of generating power for distribution
             in commerce), or 4953 (limited to facilities regulated under RCRA subtitle C), or
             5169, or 5171,  or 7389 (limited to facilities primarily engaged in solvent recovery
             services on a contract or fee basis) hereafter "covered SIC codes"; and.

    •         Facility must have 10 or more full-time employees (or the total hours worked by
             all employees is greater than 20,000 hours), and

    •         The facility manufactures (defined to include importation), or processes, or
             otherwise uses  any Section 313 chemical in quantities greater than the established
             threshold in the course of a calendar year.

Instructions regarding how to  determine the facility SIC code, employee threshold, or activity
follows; for additional detail please consult the Toxic Chemical Release Inventory Reporting
Form R and Instructions, a document published annually by EPA.

In addition, pursuant to Executive Order (EO) 12856 signed by the President on August 3, 1993,
Federal facilities are required to determine the applicability of the EPCRA Section 313 reporting
requirements  regardless of the facility's SIC codes.  Federal facilities that have 10 or more full
time employees or the equivalent and manufacture, process, or otherwise use listed  Section 313
chemicals at or above established thresholds are subject to EPCRA Section 313 reporting.
Federal facilities were required to begin reporting no later than reporting year 1994; their first
Form R or Form A reports were due by July  1, 1995.

The amount of the chemical released to the environment does not affect  the need to report. Even
if there are no releases of a listed Section  313 chemical, a facility must report if it meets the
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requirements regarding SIC code, number of employees, and activity threshold.  A threshold
determination must be made individually for each Section 313 chemical.
                                                          %
Thresholds are based on operation year, this includes partial year reporting and reporting by a
facility that is going through closure.  The facilities should consider the portion of the year for
which they operated to determine the actual employee hours worked as well as threshold
determination and release reporting.

Reduced Reporting

On November 30, 1994, EPA published a final rule (59 FRJ 61488) that provides an alternative
reporting option to qualifying facilities.  Eligible facilities wishing to take advantage of this
alternative reporting option may report on a simplified two page form referred to as Form A and
do not have to use Form R The rule entitled "TRI Alternate Threshold for Facilities with Low
Annual Reportable Amounts," provides facilities that otherwise meet EPCRA Section 313
activity thresholds the option of reporting on Form A, provided that they do not exceed 500
pounds for the total annual reportable amount (defined belpw) for that chemical, and that the
amounts manufactured, processed or otherwise used do not exceed 1 million pounds.  As with
determining an activity threshold to determine if the chemical activity has been exceeded,
facilities must evaluate each activity threshold separately, for example, a facility that
manufactures 900,000 pounds per year of a Section 313 chemical and processes 150,000 pounds
per year of a Section 313 chemical would still be eligible to use the Form A.

For the purpose of reporting on Form A,, the annual reportable amount is equal to the combined
total quantities released (including disposed) at the facility, treated  at the facility (as represented
by amounts destroyed or converted by treatment processes), recycled at the facility, combusted
for the purpose of energy recovery at the facility, and amounts transferred from the facility to off-
site locations for the purpose of recycling, energy recovery, treatment, and/or disposal. These
quantities do not include amounts of the chemical accidentally released.  These volumes
correspond to the sum of amounts reported on Form R, as Part II column B of section 8, data
elements 8.1 (quantity released),  8.2 (quantity used for energy recovery on-site), 8.3 (quantity
used for energy recovery off-site), 8.4 (quantity recycled on-site), 8.5 (quantity recycled off-site),
8.6 (quantity treated on-site),  and 8.7 (quantity treated off-site). See Section 4 of this document
for more guidance on completing Part II, Section 8 of Form R.

What is a facility?

Under EPCRA, a "facility" is defined as 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). An "establishment" is generally a single physical location, where
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business is conducted or where services or industrial operations are performed. A facility may
contain more than one establishment.  For example, a mine, mill, and smelter would be one
facility if all three units were owned and operated by the same company and are located on
contiguous or adjacent properties.  A single facility therefore can be a multi-establishment
complex. Such a facility may submit reports that cover all its establishments, or the individual
establishments may report separately.  However, for the purposes of determining thresholds, all
chemical activities for the entire facility must be considered.

How to Determine Your SIC Code"

Standard Industrial Classification (SIC) codes  10 (except 1011, 1081, and 1094), 12 (except
1241), 20-39 (manufacturing facilities), 4911, 4931 and 4939 (limited to facilities that combust
coal and/or oil for the purpose of generating power for distribution in commerce), 4953 (limited
to facilities regulated under RCRA subtitle C), 5169, 5171, and 7389 (limited to facilities
primarily engaged in solvent recovery services on a contract or fee basis) are covered under
section 313 of EPCRA. In addition, a facility not classified within these SIC codes may assume
the SIC code of the facility that it supports, based on its auxiliary association.  (For more details,
see current year's EPCRA Section 313 Forms and Instructions document.) The first two digits of
a 4-digit SIC code define a major business sector, while the last two digits denote a facility's
specialty within the major sector. A facility should determine its own SIC code(s), based on its
activities on-site and the "Standard Industrial Classification Manual 1987." In some cases, a
state agency or other organization may have assigned SIC codes on a different basis than the one
used in the SIC Manual.  For the purposes of TRI reporting, state assigned codes should not be
used if they differ from ones assigned using the SIC Manual.

Your facility may include multiple establishments that have different SIC codes. In order to
determine which SIC code best represents the facility, the facility should calculate the value of
the products or services produced or provided at/by or shipped from each establishment within
the facility and then use the following rule to determine if your facility comes within the covered
SIC codes, and the SIC code criterion is met.

    •   If the total value of the products or services shipped, produced or provided at
        establishments in "covered"  SIC codes is greater than 50 percent of the value of the entire
        facility's products and  services, the entire facility comes within the covered SIC codes,
        and the SIC code criterion is met.
        Please note: The North American Industrial Classification System that appeared in the Federal Register
on April 9, 1997 will replace the 1987 Standard Industrial Classification System (SIC). Regulatory entities,
including EPA, will take steps to adopt the new classification system over the next few years. In the meantime,
facilities should consider their activities in relation to the 1987 SIC code svstem.
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    •   If any one establishment in the specified set of SIC codes produces, provides or ships
       products or service whose value exceeds the value of products and services produced or
       shipped by all other establishments within the facility, the facility comes within the
       covered SIC codes, and the SIC code criterion is met.

The value of production or service attributable to a particular establishment may be isolated by
subtracting the product or service value obtained from other establishments within the same
facility from the total product or service value of the facility. This procedure eliminates the
potential for "double counting" production or service in situations where establishments are
engaged in sequential production activities at a single facility.

How to Determine Your Number of Employees

A "full time employee," for the purpose of Section 313 repprting, is defined as 2,000 work hours
per year. The number of full time employees is dependent only upon the total number of hours
worked by all employees during the calendar year for that facility and not the number of persons
working. To determine the number of full time employees working for your facility, add up the
hours worked by all employees during the calendar year including contract employees and sales
and support staff, and divide the  total by 2,000 hours. In other words, if the total number of
hours worked by all employees is 20,000 hours or more, your facility meets the ten employee
threshold.

Facilities may have contract workers present at times to conduct maintenance and service
operations, including equipment, motor vehicle, and building maintenance, construction, and
operating processes and waste management activities (e.g., remediation). The hours of all these
contract workers count toward the employee threshold for importing under Section 313.  In
addition, the hours worked by professionals (e.g., those on salary, that do not clock in or out)
also count towards the facility's's employee  threshold. Employees that perform activities which
routinely occur off-site such as truck drivers, but who are based at the facility are also counted
towards the employee threshold. Routine activities performed at  the facility by outside personnel
such as contract drivers that are not based at the facility are not counted towards the employee
threshold.

CHEMICAL ACTIVITY THRESHOLDS

Section 313 requires a facility that meets the SIC code and employee criteria to submit Form R
reports for any listed Section 3 1 3 chemical or chemical category that it manufactures in annual
quantities greater than 25,000 pounds, processes in annual quantities greater than 25,000 pounds,
or otherwise uses in annual quantities greater than 10,000 pounds (40 CFR §372.3).  These
thresholds (manufacture, process, or otherwise use) will be referenced throughout this document
as "activity thresholds." Chemicals must be evaluated in association with one or more of these
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three categories when determining whether an activity threshold has been exceeded. These
categories are:
                                                          t
    •     Manufacture - "Manufacture" means to produce, prepare, compound, or import a listed
         Section 313 chemical. Import is defined as causing the Section 313 chemical to be
         imported into the customs territory of the United States. If you order a listed Section
         313 chemical (or a mixture containing the chemical) from a foreign supplier, then you
         have imported the chemical when that shipment arrives at your facility directly from a
         source outside of the United States. By ordering the chemical, you have "caused it to
         be imported," even though you may have used an import brokerage firm as an agent to
         obtain the Section 313 chemical.  If the importation was directed by the parent
         company, then the facility receiving the chemical is not considered to have imported the
         chemical.

    The term manufacture also includes coincidental production of a listed chemical (e.g., as a
    byproduct or impurity) as a result of the manufacture, processing, otherwise use, or waste
    management of other chemical substances. The fact that the coincidental manufacturing of
    these byproducts is not the primary purpose of the facility is irrelevant. Listed EPCRA
    Section 313 chemicals coincidentally manufactured by a facility must be factored into
    threshold determinations and release calculations.

    •     Manufactured Activities and Definitions

    •   Produced or imported for on-site use/processing
            A chemical that is produced or  imported and then further processed or
            otherwise used at the same facility.
       •     Produced or imported for sale/distribution
            A chemical that is produced or  imported specifically for sale or
            distribution outside the facility.
       •    Produced as a by-product
            A chemical that is produced coincidentally during the production,
            processing, otherwise use, or disposal of another chemical substance or
            mixture and, following its production, is separated from that other
            chemical substance or mixture.  Section 313 chemicals produced and
            released as a result of waste treatment for disposal are also considered
            byproducts.
       •    Produced as an impurity
            A chemical that is produced coincidentally as a result of the
            manufacture, processing, or otherwise use of another chemical but is
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            not separated and remains primarily in the mixture or product with that
            other chemical.
                                                         »
    •   Process - "Process" means the preparation of a listed toxic chemical in the same, as well
       as different form, state or quantity, after its manufacture, for distribution in commerce.
       Processing is usually the intentional incorporation of a Section 313 chemical into a
       product.  Processing includes preparation of the Section 313 chemical in the same
       physical state or chemical form as that received by your facility, or preparation that
       produces a change in physical state or chemical form. The term also applies to the
       processing of a mixture or other trade name product that contains a listed Section 313
       chemical as one component.  Processing activities include  use of Section 313 chemicals
       as reactants, in formulations, and as article components, and repackaging. Processing
       may also include the recycling of a Section 313 chemical for distribution in commerce.
       For example, if a facility receives a waste containing a Section 313 chemical from off-
       site, recovers that chemical, and repackages the chemical for distribution in commerce,
       the facility would count the amount of the Section 313 chemical recovered toward its
       processing threshold.


    The extraction and subsequent distribution in commerce of ore containing EPCRA Section
    313 chemicals constitutes "processing" of those listed chemicals. For the purposes of the
    processing definition, EPA defines extraction to mean the physical removal or exposure of
    ore, coal, minerals, waste rock, or overburden prior to beneficiation, and encompasses all
    extraction-related activities prior to beneficiation.  Extraction does not include beneficiation
    (including coal preparation) mineral processing, in situ leaching or any further activities.
    (See 40 CFR §372.3.) Removal of waste rock to gairi access to an ore body does not
    constitute processing provided that the material is not subsequently distributed in
    commerce. If waste rock is simply disposed of, amounts  of listed toxic chemicals
    contained in the waste rock are  not considered toward threshold determinations.
    However, disposal and other releases of listed toxic chemicals contained in waste rock
    may be reportable if thresholds  are exceeded for the chemical elsewhere at the facility.

    Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
    313 chemical occurs does not constitute processing of the Section 313 chemical.

    •   Processed Activities and Definitions
            As a reactant
            A natural or synthetic chemical used in chemical reactions for the
            manufacture of another chemical substance or product. This includes,
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            but is not limited to, feedstocks, raw materials, intermediates, and
            initiators.
       •    As a formulation component                     ,
            A chemical added to a product (or product mixture) prior to further
            distribution of the product that acts as a performance enhancer during
            use of the product. Examples of Section 313 chemicals used in this
            capacity include, but are not limited to, additives, dyes, reaction
            diluents, initiators, solvents, inhibitors, emulsifiers, surfactants,
            lubricants, flame retardants, and Theological modifiers.
       •    As an article component
            A chemical that becomes an integral component of an article
            distributed for industrial, trade, or consumer use.
       •    Repackaging
            Processing or preparation of a Section 313 chemical (or product
            mixture) for distribution in commerce in a different form, state, or
            quantity. This includes, but is not limited to, the transfer of material
            from a bulk container, such as a tank truck, to smaller containers such
            as cans or bottles.

    •   Otherwise use - Any use involving a listed Section 313 chemical at a facility that does
       not fall under the definitions of'manufacture" or "process" is an otherwise use of that
       chemical.  A chemical that is otherwise used by a facility is  not incorporated into a
       product distributed in commerce and includes use of the Section 313 chemical as a
       chemical processing aid or as a manufacturing aid or for ancillary uses such as treating
       wastes.  Otherwise use of a Section 313 chemical does not include disposal, stabilization
       (without subsequent distribution in commerce),  or treatment for destruction unless:

       (1)  The Section 313 chemical that was disposed,  stabilized, or treated for destruction
            was received from off-site for the purposes of further waste management, or

       (2)  The Section 313 chemical that was disposed,  stabilized, or treated for destruction
            was manufactured as a result of waste management activities on materials received
            from off-site for the purpose of further waste management.

    Relabeling or redistributing of the Section 313 chemical where no repackaging of the Section
    313 chemical occurs does not constitute the otherwise use of the Section 313 chemical.
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    The difference between "processing" and "otherwise use" is important because these
    activities are subject to different activity thresholds.  jSecause beneficiation of ore is
    preparation of its constituents, any beneficiation of ore containing Section 313 chemicals
    (e.g., copper  in copper ore) is considered processing if there is subsequent distribution in
    commerce. Processing implies incorporation; for the purposes of EPCRA Section 313, a
    constituent Section 313 chemical is "processed" if ore is beneficiated for distribution in
    commerce (e.g, sale of a metal concentrate). This is true whether the Section 313 chemical
    is the target metal or a non-target metal. For example, when copper ore containing traces
    of lead is beneficiated for distribution in commerce, both lead and copper are processed.
    In contrast, "otherwise use" implies non-incorporatiop; the chemical is not intended to
    become part of a product.  For example, the use of sodium cyanide to extract gold from
    gold ore represents an "otherwise use" of an EPCRA Section 313 chemical.

    •   Otherwise Used Activities and Definitions

       •    As a chemical processing aid
            A chemical that is added to a reaction mixture to aid in the
            manufacture or synthesis of another chemical jsubstance but is not
            intended to remain in or become part of the product or product
            mixture.  Examples of such Section 313 chemicals include, but are not
            limited to, process solvents, catalysts, inhibitors, initiators, reaction
            terminators, and solution buffers.
       •    As a manufacturing aid
            A chemical that aids the manufacturing process that does not become
            part of the resulting product and is not added to the reaction mixture
            during the manufacture or synthesis of another chemical substance.
            Examples include, but are not limited to, process lubricants,
            metalworking fluids, coolants, refrigerants, arid hydraulic fluids.
       «    Ancillary or other use
            A chemical that is used at a facility for purposes other than aiding
            chemical processing or manufacturing as described above. Examples
            of such Section 313 chemicals include, but are not limited to, cleaners,
            degreasers, lubricants, fuels, and chemicals used for treating wastes.
                                                     i
For purposes of the otherwise use definition, EPA interprets waste management activities to
include recycling, combustion for energy recovery, treatment for destruction, waste stabilization,
and release, including disposal.  Waste management does not include the storage, container
transfer, or tank transfer of a Section 313 chemical if no recycling, combustion for energy,
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treatment for destruction, waste stabilization, or release of the chemical occurs at the facility.
(See 62 FR 23850)
                                                         »
For purposes of the otherwise use definition, EPA interprets waste management activities to
include recycling, combustion for energy recovery, treatment for destruction, waste stabilization,
and release, including disposal. Waste management does not include the storage, container
transfer, or tank transfer of a Section 313 chemical if no recycling, combustion for energy,
treatment for destruction, waste stabilization, or release of the chemical occurs at the facility.
(See 62 FR 23 850)


Recycling for the purposes of EPCRA Section 313 is interpreted to include: (1) the recovery
for reuse of a Section 313 chemical from a gaseous, aerosol, aqueous, liquid,  or solid stream;
or (2) the reuse or the recovery  for use of a Section 313 chemical that is a RCRA hazardous
waste as defined in 40 CFR Part 261.  Recovery is the act of extracting or removing the toxic
chemical from a waste stream and includes: (1) the reclamation of the toxic chemical from a
stream that entered a waste treatment or pollution control device or process where destruction
of the stream or destruction or removal of certain constituents of the stream occurs (including
air pollution control devices or processes, wastewater treatment or control devices or
processes, Federal or state permitted treatment or control devices or processes, and other types
of treatment or control  devices or processes); and (2) the reclamation for reuse of an
"otherwise used" toxic chemical that is spent or contaminated and that must be recovered for
further use in either the original or any other operations. (See EPA document, Interpretations
of Waste Management Activities: Recycling, Combustion for Energy Recovery, Waste
Stabilization and Release.)
Combustion for energy recovery is interpreted by EPA to include the combustion of a Section
313 chemical that is (1) (a) a RCRA hazardous waste or waste fuel, (b) a constituent of a
RCRA hazardous waste or waste fuel, or (c) a spent or contaminated "otherwise used"
material; and that (2) has a heating value greater than or equal to 5,000 British thermal units
(BTU) per pound in an energy or materials recovery device.  Energy or materials recovery
devices are boilers and industrial furnaces as defined in 40 CFR §372.3  (See 62 FR 23891).  In
determining whether an EPCRA Section 313 listed toxic chemical is combusted for energy
recovery, the facility should consider the BTU value of the toxic chemical and not of the
chemical stream.  If the heating value of the Section 313 chemical is below 5,000 BTU, the
chemical is being treated  for destruction. A facility that blends and subsequently distributes in
commerce a waste-derived fuel "processes" EPCRA Section 313 listed toxic chemicals that are
constituents of that waste-derived fuel.  In contrast, if subsequent to blending the waste-derived
fuel, that same facility combusts on-site  the waste-derived fuel in an energy recovery unit, the
facility "otherwise uses"  EPCRA Section 313 listed  toxic  chemicals that are constituents of
that waste-derived fuel.  An  EPCRA Section 313 listed toxic chemical that has a heat value of
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less than 5,000 BTUs and that is a constituent of a waste-derived fuel is "otherwise used" if
that fuel is combusted in an on-site energy recovery unit (62 FR 23851).
                                                         \
EPA defines Treatment for destruction to mean the destruction of a Section 313 chemical in
waste such that the substance is no longer the toxic chemical subject to reporting under
EPCRA Section 313.  Treatment for destruction does not include the destruction of a Section
313 chemical in waste where the Section 313 chemical has a heat value greater than 5,000
British Thermal Units (BTU) and is combusted in any device that is an industrial boiler or
furnace. (See 40 CFR §372.3.)  "Treatment for destruction" includes acid or alkaline
neutralization if the toxic chemical is the entity that reacts with the acid or base.  "Treatment
for destruction" does not include: (1) neutralization of a waste stream containing toxic
chemicals if the toxic chemicals themselves do not react with the acid or base (See 40 CFR
§372.3), (2) preparation of a toxic chemical for disposal, (3) removal of toxic chemicals from
waste streams, and (4) activities intended to render a waste stream more suitable for further use
or processing, such as distillation or sedimentation. For example, neutralization of pure nitric
acid is considered treatment  for destruction. In contrast, neutralization of nitric acid
containing three percent lead is not considered treatment for destruction of the lead component,
because the lead has not reacted with the neutralizing agent (See 62 FR 23852).

EPA defines Waste stabilization to mean any physical or chemical process used to either
reduce the mobility of hazardous constituents in a hazardous waste or eliminate free liquid as
determined by a RCRA approved test method  (e.g., Test Method 9095).  A waste stabilization
process includes mixing the  hazardous waste with binders or other materials and curing the
resulting hazardous waste and binder mixture.  Other synonymous terms used to refer  to this
process are "stabilization," "waste fixation," or "waste solidification."  (See 40 CFR  §372.3.)

Release is defined by  EPCRA Section 329(8) to mean any spilling, leaking, pumping,  pouring,
emitting, emptying, discharging, injecting, escaping, leaching, dumping,  or disposing  into the
environment (including the abandonment or discarding of barrels, containers, and other closed
receptacles) of any toxic chemical. (See 40 CFR §372.3.)

Disposal is defined by EPA  to mean any underground injection, placement in landfills/surface
impoundments, land treatment, or other intentional land disposal.  (See 40 11CFR §372.3.)
Beneficiation means the preparation of ores to regulate the size (including crushing and
grinding) of the product, to remove unwanted constituents, or to improve the quality, purity,
or grade of a desired product.  (See 40 CFR §372.3.) This definition is broad and includes, all
activities mining facilities considered to be beneficiation under the Resource Conservation and
Recovery Act (RCRA) definition of beneficiation found at 40 CFR §261.4(b)(7), which states:
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       ",..beneficiation of ores and minerals is restricted to the following activities:
       Crushing; grinding; washing; dissolution; crystallization; filtration; sorting;
       sizing; drying; sintering; pelletizing; briquetting; calcining to remove water
       and/or carbon dioxide; roasting, autoclaving, and/or chlorination in
       preparation for leaching (except where the roasting (and/or autoclaving and/or
       chlorination)bleaching sequence produces a final or intermediate product that
       does not undergo further beneficiation or processing); gravity concentration;
       magnetic separation; electrostatic separation; flotation; ion exchange; solvent
       extraction; electrowinning; precipitation; amalgamation; and heap, dump, vat,
       tank, and in situ leaching."

Additional activities that occur to prepare ores through regulating the size of the product,
removing unwanted constituents,  or improving the quality, purity, or grade of a desired
product are considered beneficiation for the purposes of EPCRA Section 313 reporting.

EPA believes that "overburden" and "waste rock" constitute two separate and discernable
types of materials that may be managed as waste (62 FR 23859).

Overburden is the consolidated material that overlies a deposit of useful materials or ores. It
does not include any portion of ore or waste rock. Listed toxic chemicals contained in
overburden are specifically exempt from section 313 reporting for metal mining facilities.  (See
40 CFR §372.38(h).)

Waste rock as described in the preamble, "generally considered that portion of the ore body that
is barren or submarginal rock or ore which has been mined but is not of sufficient value to
warrant treatment and is therefore removed ahead of the milling processes. Waste rock is part of
the ore body and  may, depending  on economic  conditions, become a valuable source of a
metal..." (62 FR 23859)

Based on EPA's evaluation of the  metal mining  industry, the Agency believes that metal mining
activities routinely involve or result in the manufacturing, processing, or otherwise use of
EPCRA Section 313 chemicals (62 FR 23834, May 1, 1997). The term manufacture includes the
coincidental manufacture of a chemical, such as a byproduct or impurity, from the
manufacturing, processing, otherwise use or waste management of another chemical substance or
mixture.  Thresholds must be calculated separately for manufacture, process, or otherwise use of
the same chemical. If any single threshold is exceeded for a listed  Section 313 chemical, the
facility must submit a Form R covering all nonexempt activities. Metal mining facilities will be
required to factor into their threshold determinations and reporting calculations the quantities of
EPCRA Section 313 chemicals used in support activities such as froth flotation, non-motor
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vehicle equipment maintenance, and dewatering. Chemicals involved in these support activities
are classified under the otherwise use category.
                                                          t
EXEMPTIONS

Section 313 provides for exemptions from reporting for specific "processing" or "otherwise use"
activities.  The instructions provided in Toxic Chemical Release Inventory Reporting Form R and
Instructions should be reviewed carefully before proceeding. The following discussion
summarizes the exemption instructions. A facility does not have to consider amounts of listed
Section 313 chemicals involved in any of these processing or otherwise use activities when
determining if activity thresholds have been exceeded or when estimating environmental
releases.  Limited exemptions apply to manufacturing activities.  For example, manufacturing a
Section 313 chemical for research and development purposes and manufacturing as an impurity
below a specified level in a product distributed beyond the facility both can be exempt.  The
EPA's Toxic Chemical Release Inventory Questions and Answers, Revised 1990 Version [EPA
560/4/91-003 (will be revised in near future)]  and the Toxic Release Inventory Reporting Form
R and Instructions also contain information about these exemptions. (See Appendix B for
ordering information.)


    •   The de minimis exemption allows facilities to disregard certain minimal concentrations
       of chemicals in mixtures or trade name products they "process" or "otherwise use" in
       making threshold determinations and release and other waste management
       determinations.  Any Section 313 chemical in ore or waste rock that is  at a level below
       de minimis concentration and remains below the de minimis concentration throughout
       the extraction process does  not have to be factored into threshold or release
       determinations for amounts processed by the facility.  The de minimis exemption does
       not apply to the "manufacture" of a Section 313 chemical except if that Section 313
       chemical is "manufactured" as an impurity and remains in the product distributed in
       commerce below the appropriate de minimis level.  The de minimis exemption does not
       apply to a byproduct "manufactured" coincidentally as a result of "manufacturing,"
       "processing,"  "otherwise use," or any waste management activities.

    This de minimis exemption applies solely to "mixtures" and trade name products. EPA's
    long-standing interpretation has been that "mixture" does not include waste.  Therefore, the
    de minimis exemption cannot be applied to Section 313 chemicals in a waste even if the
    waste is being "processed" or "otherwise used."

    When determining whether the de minimis exemption applies to a Section 313 chemical, the
    owner or operator should only consider the concentration of the Section 313 chemical in
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   mixtures and trade name products in process streams in which the Section 313 chemical is
   undergoing a reportable activity.  If the Section 313 chemical in a process stream is
   "manufactured" as an impurity, "processed," or "otherwise used" and is below the
   appropriate de minimis concentration level, then the quantity of the Section 313 chemical in
   that process stream does not have to be applied to threshold determinations nor included in
   release or other waste management determinations.  If a Section 313 chemical in a process
   stream meets the de minimis exemption, all releases and other waste management activities
   associated with the Section 313 chemical in that stream are exempt from EPCRA section 313
   reporting.  It is possible to meet an activity (e.g., processing) threshold for a Section 313
   chemical on a facility-wide basis,  but not be required to calculate releases or other waste
   management quantities associated with a particular process because that process involves
   only mixtures or trade name products containing the Section 313 chemical below the de
   minimis level.

   Once a Section 313 chemical concentration is above the appropriate de minimis
   concentration, threshold determinations and release and other waste management
   determinations must be made, even if the chemical later falls below de minimis level in the
   same process stream.  Thus, all releases and other quantities managed as waste which occur
   after the de minimis level has been exceeded are then subject to reporting.  If a Section 313
   chemical in a mixture or trade name product above de minimis is brought on-site, the de
   minimis exemption never applies.

   The de minimis concentration level is consistent with the OSHA Hazard Communication
   Standard requirements for development of Materiai Safety Data  Sheets (MSDSs).  The de
   minimis level is 1.0 percent except if the Section 313 chemical is an OSHA-defined
   carcinogen. The de minimis level for OSHA-defined carcinogens is 0.1 percent. For
   mixtures or other trade name products that contain one or more  members of a listed Section
   313 Section 313 chemical category, the de minimis level applies  to the aggregate
   concentration of all such members and not to each individually. The list of Section 313
   chemicals in the publication Toxic Chemical Release Inventory Reporting Form R and
   Instructions for the current reporting year contains the de minimis values for each of the
   Section 313 chemicals and chemical categories.

   •   Materials that are processed or used as articles - Quantities of a listed Section 313
       chemical contained in an article do not have to be factored into threshold or release
       determinations when that article is processed or otherwise used at  your facility.  An
       article is defined as a manufactured item that is  formed to a specific shape or design
       during manufacture, that has  end-use functions  dependent in  whole or in part upon its
       shape or design during end-use, and that does not release a Section 313 chemical under
       the normal conditions of the processing or use of that item at the facility.
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   If the processing or otherwise use of like articles results in a total release of less than 0.5
   pounds of a Section 313 chemical in a calendar year to all environmental media, EPA will
   allow this release quantity to be rounded to zero, and the manufactured items remain exempt
   as articles. EPA requires facilities to round off and report all estimates to the nearest whole
   number. The 0.5-pound limit does not apply to each individual article, but applies to the sum
   of all releases from processing or otherwise use of like Articles.

   The article exemption applies to the normal processing or otherwise use of an article. It does
   not apply to the manufacture of an article. Thus, Section 313 chemicals processed into
   articles manufactured at a facility must be factored into threshold and release determinations.

   A closed item containing Section 313 chemicals (e.g., a transformer containing PCBs) that
   does not release the Section 313 chemicals during normal use is considered an article if a
   facility uses the item as intended and the Section 313  chemicals are not released. If a facility
   services the closed item (e.g., a transformer) by replacing the Section 313 chemicals, the
   Section 313 chemicals added during the reporting year must counted in threshold
   determinations.

   *   Materials that are structural components of the facility - Chemicals present in
       materials used to construct, repair, or maintain a plant building are exempt from the
       activity thresholds. For example, solvents and pigments present in paint used to coat the
       structural components of a building would be exempt from threshold determination and
       release reporting.

   *   Materials used for janitorial or facility grounds maintenance - Chemicals present in
       materials used for routine or facility grounds maintenance are exempt from the activity
       thresholds.  Examples include bathroom cleaners, fertilizers, and garden pesticides in the
       same form and concentration commonly distributed to consumers. Chemicals used for
       equipment maintenance, such as the use  of oil or cleaning solvents, are not exempt.

   •   Materials used with facility motor vehicles - Chemicals present in materials used for
       operating and maintaining motor vehicles operated by the facility are exempt from the
       activity thresholds. Examples include gasoline, radiator coolant, and  windshield wiper
       fluid used in equipment  such as  cars, trucks, forklifts, and tow motors.

   •   Personal items - Chemicals present in materials such as foods, drugs, cosmetics, or other
       personal items are exempt from the activity thresholds. Examples include materials used
       in the facility cafeteria and infirmary. Chemicals used for heating and air conditioning
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       solely to provide comfort to personnel are also exempt from reporting. If a building's
       temperature is regulated to facilitate a process or treatment operation, the Section 313
       chemicals used to heat or cool the building are not exempt. Units that supply both
       personal comfort and operational needs may be apportioned, if it is possible to separate
       them.

    *   Laboratory materials - Chemicals used in certain laboratory activities that are
       conducted under the supervision of a technically qualified individual (as defined under 40
       CFR §720.3(ee)) are exempt from the activity thresholds.  The laboratory activities
       exemption applies only to sampling and analysis, research and development, and quality
       assurance and quality control activities. The exemption does not apply to the use or
       production of listed Section 313 chemicals in pilot-plant operations and laboratories for
       distribution in commerce (e.g., specialty chemicals) and laboratory support services.

»   Materials as they are drawn from the environment or municipal sources - Chemicals
    contained in intake water (used for processing or non-contact cooling) or in intake air (used
    either as compressed air or for combustion) are exempt from the activity thresholds.

    •   Property owners - Property owners that merely own real estate on which a facility
       covered by Section 313 is located and have no business interest  in the operation of that
       facility (e.g., a company owns an industrial park) are exempt for Section 313 reporting.
       The operator of that facility, however, is subject to reporting requirements,

SUPPLIER NOTIFICATION REQUIREMENTS

Because manufacturers reporting under Section 313 must know the Section 313 chemical
composition of the products they use to be able to accurately calculate releases, EPA requires
some suppliers of mixtures or trade name products containing one or more of the listed Section
313 chemicals to notify their customers of the identity of the chemical in the mixture or the trade
name product. This requirement has been in effect since January 1, 1989.

A facility must comply with the Section 313 supplier notification requirements if it owns or
operates a facility which meets all of the following criteria.

    •   The facility is in SIC codes 20-39,

    •   The facility manufactures, imports,  or processes a Section 313 chemical, and
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       •  The facility sells or otherwise distributes in commerce a mixture or trade name
          product containing the Section 313 chemical to either;

            A facility described in 40 CFR §372.22 (covered facility group), or
            A facility that then sells the same mixture or trade name product to a facility
            described in 40 CFR §372.22 (covered facility group).

The supplier notification requirements do not apply to TRI chemicals that are themselves
wastestreams or are constituents of wastestreams.

LISTED SECTION 313 CHEMICALS

Appendix A to this document contains an alphabetical listing of the chemicals subject to Section
313 reporting at the time of publication of this document, including their de minimis
concentrations. EPA publications Common Synonyms for Section 313 Chemicals (EPA 745-R-
95-008) and Consolidated List of Chemicals Subject to Reporting Under the Act (Title III List of
Lists) (EPA-550-B-96-015) may also be useful references when reviewing the chemicals at your
facility for Section 313 coverage.

The list of Section 313 chemicals is amended frequently.  Users of this guidance document or
other documents listing Section 313 chemicals are cautione
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        should determine if, for example, it generated more than 25,000 pounds of "aluminum
        (fume or dust)." Similarly, there may be certain technologies in which one of these
        metals is processed in the form of a fume or dust to make other Section 313 chemicals or
        other products for distribution in commerce. In reporting releases, the facility would
        report only releases of the fume or dusts.

   EPA considers dusts to consist of solid particles generated by any mechanical processing of
   materials including crushing, grinding, rapid impact, handling, detonation, and decrepitation
   of organic and inorganic materials such as rock, ore, and metal.  Dusts do not tend to
   flocculate, except under electrostatic forces.  A fiime is an airborne dispersion consisting of
   small solid particles created by condensation from a gaseous state, in distinction to a gas or
   vapor. Fumes arise from the heating of solids such as aluminum. The condensation is often
   accompanied by a chemical reaction such as oxidation.  Fumes flocculate and sometimes
   coalesce.  Other metals, (e.g.,  such as lead or copper) are not  limited by this qualifier and are
   subject to reporting in all forms (fume, dust, and wet).

   •    Manufacturing qualifiers -Two of the entries in the Section 313 chemical list contain a
        qualifier relating to manufacture. For isopropyl alcohol, the qualifier is "manufacturing -
        strong acid process". For saccharin the qualifier simply is "manufacturing." For
        isopropyl alcohol, the qualifier means that  only facilities manufacturing isopropyl
        alcohol by the strong acid process are required to report. In the case of saccharin, only
        manufacturers of the Section 313 chemical are subject to the reporting requirements. A
        facility that processes or otherwise uses either Section 313 chemical would not be
        required to report for those chemicals. In both cases, the  facility is not required to
        provide supplier notification because only  the manufacturer, not the user, of the Section
        313 chemical must report.

   •    Ammonia (includes anhydrous ammonia and aqueous ammonia from water
        dissociable ammonium salts and other sources; 10 percent of total aqueous
        ammonia is reportable under this listing) - The qualifier for ammonia means that
        anhydrous forms of ammonia are 100 percent reportable  and aqueous forms are limited
        to 10 percent of total aqueous ammonia. Therefore, when determining thresholds,
        releases, and other waste management quantities all anhydrous ammonia is included but
        only 10 percent of total aqueous ammonia is included. Any evaporation of ammonia
        from aqueous ammonia solutions is considered anhydrous ammonia and should be
        included in the appropriate threshold and release determinations.

   •    Phosphorus (yellow or white) - The listing for phosphorus is qualified by the term
        "yellow or white" This means that only manufacturing, processing, or otherwise use of
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                METAL MINING FACILITIES
        phosphorus in the yellow or white chemical forms require reporting. Conversely,
        manufacturing, processing,  or otherwise use of "black" or "red" phosphorus does not
        trigger reporting.

    •    Asbestos (friable) - The listing for asbestos is qualified by the term "friable," referring
        to the physical characteristic of being able to be crumbled, pulverized, or reducible to a
        powder with hand pressure. Only manufacturing, processing, or otherwise use of
        asbestos in the friable form triggers reporting.

    •    Aluminum oxide (fibrous forms) - The listing for aluminum oxide is qualified by the
        term "fibrous forms." Fibrous refers to a man-made form of aluminum oxide that is
        processed to produce strands or filaments which can be cut to various lengths depending
        on the application. Only manufacturing, processing, or otherwise use of aluminum oxide
        in the fibrous form triggers reporting

    •    Hydrochloric acid and sulfuric acid (acid aerosbls including mists, vapors, gas, fog,
        and other airborne forms  of any particle size) - The qualifier for hydrochloric acid
        and  sulfuric acid means that only aerosol forms of this chemical are reportable.  Aqueous
        solutions are not covered by this listing, but airborne forms generated from aqueous
        solutions are covered.

    *    Nitrate compounds (water dissociable; reportable only when in an aqueous
        solution) - The qualifier for the nitrate compounds category limits the reporting to
        nitrate compounds that dissociate in water, and thereby generate nitrate ions. For the
        purposes of threshold determinations, the entire weight of the nitrate compound must be
        included in all calculations.  For  the purposes of reporting releases and other waste
        management quantities, only the weight of the nitrite ion should be included in the
        calculations of these quantities.

WHAT MUST BE REPORTED?


If your facility is included  in the specified set of SIC codes, has ten or more full-time employees
or the equivalent,  and manufactures, processes, or otherwise uses one of the listed Section 313
chemicals in  amounts greater than the appropriate thresholds, you must report the following
information on Form R:


    •    Name  and location of your facility;
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                 METAL MINING FACILITIES
   •    Identity of the listed Section 313 chemical (unless you claim its identity to be a trade
        secret);
                                                          %
   •    Whether you manufacture, process, or otherwise use the chemical any other way;

   •    Maximum quantity of the chemical on-site at any time during the year;

   •   Quantities of the chemical released  during the year to environmental media, including
       both accidental spills and routine emissions;

   •   Quantities of the chemical subject to on site waste management actions, including
       recycling, energy recovery, or waste treatment,

   •    Off-site locations to which you shipped wastes containing the chemical and the
        quantities of the chemical sent to those locations;

   •    Information on source reduction activities; and

   •    Treatment methods used for wastes containing the chemical and estimates of their
        efficiency for the reportable Section 313 chemical.

A release is defined under EPCRA Section 329(8) as any spilling, leaking, pumping, pouring,
emitting, emptying, discharging,  injecting, escaping, leaching, dumping, or disposing into the
environment of any listed Section 313 chemical.  The definition of release includes the
abandonment or discarding of barrels, containers, and other closed receptacles. Separate release
estimates must be provided for releases to air, water, and land (e.g., deep well injection, surface
impoundment, permitted landfill).

DOCUMENTING REPORTING EFFORTS

Sound recordkeeping practices are essential for accurate and efficient TRI reporting   EPA
requires that facilities keep a copy of each Form R or Form A report filed for at least three years
from the date of submission (40 CFR §372.10). These reports will also be of use to facilities in
subsequent years when completing future Form R or Form A reports. EPA also requires that
facilities maintain those documents, calculations, worksheets, and other forms upon which they
relied to file Form R or Form A reports. EPA may request this supporting documentation from
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                METAL MINING FACILITIES
the facility, for example, to conduct data quality reviews of present or past Form R or Form A
submissions.
Supporting documentation, organized by year, that a facility should maintain may include, if
applicable:
       Previous years' Forms Rs and Form As;
       Section 313 Reporting Threshold Worksheets (a sample worksheet is given in the Toxic
       Chemical Release Inventory Reporting Form R an,d Instructions document;
       Engineering calculations and other notes;
       Purchase records from suppliers;
       Inventory data;
       EPA (NPDES) permits and monitoring reports;
       EPCRA Section 312, Tier II Reports;
       Monitoring records;
       Flowmeter data,
       RCRA Hazardous Waste Generator's Report;
       Pretreatment reports filed by the facility with the local government;
       Invoices from waste management companies;
       Manufacturer's estimates of treatment efficiencies;
       RCRA Manifests; and
       Process diagrams.                            i
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                              SECTION 3
                 MAKING THE THRESHOLD DETERMINATION
                                                    \
A separate Toxic Chemical Release Inventory Reporting Form must be submitted for each listed
chemical that is "manufactured," "processed," or "otherwise used" above an activity threshold at
your facility, assuming the SIC code and employee criteria are met.  Current EPCRA Section 313
guidance for metal mining facilities is shown in Table 3-1:
    Table 3-1. Examples of Manufactured, Processed, and Otherwise Used Chemicals
                                at Metal Mines *
; " ' \ " " : - "'V ' -" - , >; - \ f - Manufactured Chemicals - ^ ' '-' t "t-<^"..
Byproducts or coincidentally manufactured Section 313 chemicals are not subject to the de
minimis exemption and all quantities of such chemicals should be included in your threshold
determination for manufacturing of the new Section 313 chemical. This includes Section 313
chemicals manufactured in tailings impoundments.
If an elemental metal is converted to a metal compound, or if one metal compound is
converted to another metal compound, then a metal compound has been manufactured, even
if it is within the same Section 313 metal compound category. The quantity of the Section 313
metal compound manufactured must be counted towards the 25,000 pound threshold.
•••.' Activity. :-':- • : '
Produced or imported for on-site
use/processing
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
•'...•: Examples .... -
Conversion of copper sulfide to copper sulfate in the
leaching process.
Conversion of copper sulfate to copper (cathodes) in
electrowinning.
Sulfuric acid aerosols formed by spraying sulfuric acid
solutions in the leaching process.
Conversion of trace amounts of compounds of lead,
copper, nickel, or mercury to elemental forms in gold dore
shipped offsite as product.
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^pf^m&^^^ - -i
The recovery of a Section 313 chemical from a mixture for further distribution is processing
of that chemical. Metal recovery from metal bearing ores that result in a product that is sold
should be considered in your threshold determination for processing activities. Similarly,
Section 313 metals in tailings distributed in commerce foil reclamation must be counted
towards the processing threshold.
jii:W^SM^^^§i§ilii
As a reactant
As a formulation component
As an article component
Repackaging only
:plp!^
Zinc dust that is used to precipitate gold from pregnant
gold-cyanide solutions. Flotation reagents such as
benzene, arsenic compounds, chromium compounds, and
copper compounds, used in mineral beneficiation that
remain in the product.
May not occur in metal mining.
Copper cathodes produced from electrowinning
May not occur at a mining facility
%:-v Vv ^"/ « -'- -f • Q&vmfal3srt£kei$c*te > - - ,,
The use of a Section 313 chemical in a mixture that is not incorporated into products
distributed by the facility is otherwise use of that chemical. Cyanide compounds used in
leaching processes to concentrate Section 3 1 3 metals (or metal compounds) from ore materials
extracted from the ground are "otherwise used" because the cyanide compounds are not
distributed in commerce. These compounds should be considered in your threshold
determination as otherwise use activities.
>'•-- -•.'<':--•" "^CtiYifjy:- '-'-';>; y • '- •'.:•:
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
•:•/: , i j.v. ' 4:-^6^:>; :. I Examples
Lead-based steel wool used as a cathode in the
electrowinning process. Chemicals used in solvent
extraction/electrowinning. Cyanide leaching for
beneficiation of gold ores.
Nitric acid used to regenerate carbon adsorption beds used
in cyanide leaching process. Sulfuric acid used to
regenerate carbon filters, only to the extent that sulfuric
acid fumes are released.
Naphthalene in diesel fuel used in stationary equipment.
Chlorine used to treat cyanide in waste water.
*More complete discussions of the industry-specific examples can be found in Section 5 of this guidance manual.
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   •   For threshold determinations, the concentration of metal compounds is determined by
       the total weight percent of the compound, not the parent metal.
                                                          \
   •   If more than one Section 313 metal compound within a Section 313 metal compound
       category is present in the ore, the concentration is determined by the total weight percent
       of all compounds within a specific listed Section 313 category.  That concentration
       would be used to determine the applicability of the de minimis exemption and to
       calculate threshold determinations, if appropriate. Facilities should factor in variability
       of the metal compounds within the ore.  Variability in an ore body is expected.  In
       calculating the activity threshold, the facility should develop an average based on known
       information.  If sampling normally conducted by the facility produces results of varying
       concentrations, these should be averaged for an overall average concentration.  If the
       facility has more than one extraction point, and sampling yields consistent results per
       point of extraction but different results as compared to other points of extraction (e.g.,
       one area above de minimis and one below), then  the facility may develop an activity
       threshold estimate separately for each area sampled for purposes of determining
       reporting thresholds.

   •   The Section 313 chemicals present in "overburden," the unconsolidated or consolidated
       material that overlies a deposit of useful materials or ores, is exempt from threshold
       determinations and release calculations if processed or otherwise used by metal mining
       facilities within SIC code 10.

   •   Waste rock is not considered overburden because it is considered a portion of the ore
       body and may, depending on economic conditions, become a valuable source of a metal
       or metal compound.  Waste  rock that is separated from the ore body and deposited on-
       site or transferred off-site for purposes of disposal or other waste management activities
       has not undergone an EPCRA  Section 313 reportable activity, and therefore, amounts of
       Section 313 chemicals contained in the waste rock do not have to be considered towards
       activity thresholds.

CONDUCTING THE THRESHOLD DETERMINATION
An activity threshold determination must
be made individually for each Section 313
chemical by each activity in which the
chemical is manufactured, processed, or
otherwise used at your facility.  The
               STEP ONE
Identify Section 313  chemicals  that are
manufactured, processed or otherwise used.
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                                                           METAL MINING FACILITIES
threshold determination is one criterion used to ascertain whether a Form R or Form A is
required to be submitted.
The primary function of most mining facilities is the extraction and beneficiation of metal ore to
produce a metal concentrate. The purpose of beneficiation is to concentrate the valuable metal in
the ore by separating the valuable portion from the non-valuable portion. The beneficiation
method or methods used vary with mining operations and depend on ore characteristics and
economic considerations and include flotation, leaching, solvent extraction, electrowinning and
other methods. To perform a comprehensive and accurate threshold determination, the facility
must determine (1) what Section 313 chemicals (such as metals and metal compounds) are
present in the mined ore and at what concentrations, (2) what Section 313  chemicals (such as
metals and metal compounds) that are present in the mined! ore below de minimis concentrations
                                               are concentrated above de minimis at some
                                               point in the beneficiation process, and (3)
                                               what chemicals (flotation agents, leaching
                                               agents, cyanides, equipment maintenance
                                               chemicals, waste treatment chemicals, etc.)
                                               are otherwise used during the beneficiation
                                               activities.

                                               Some processing activities will involve the
                                               conversion or reaction of chemicals to
                                               produce a new chemical, such as occurs with
                                               chemical oxidation or chemical precipitation.
                                               Mining facilities should closely examine their
                                               processes to determine whether a Section 313
                                               chemical are  manufactured. (See box.)

                                               Carefully examine the Section 313 list of
                                               chemicals in Appendix A and check the list of
                                               Section 313 chemicals in the publication
                                               Toxic Chemical Release Inventory Reporting
                                               Form R and Instructions for the current
                                               reporting year to determine whether the list of
                                               chemicals has been updated.

                                               Any chemical purchased by facilities for use
                                               as processing or manufacturing aids or for
                                               treating waste are  considered "otherwise
                                               used". In addition, EPCRA Section 313
          Sulfuric Acid Aerosols

Sulfuric acid is only a Section 313 chemical
when it exists  as an acid aerosol  including
mists, vapors, fog, and other airborne species
of any particle size.  Producing a sulfuric acid
aerosol from liquid sulfuric acid  is considered
"manufacturing"    under   TRI   In  some
leaching  operations,  dilute  sulfuric  acid  is
sprayed or dripped onto the ore. This spraying
or dripping may result in the manufacture of
sulfuric acid  in the  aerosol  form.  Facilities
should apply the total volume of acid in the
spraying system during the reporting year to
the threshold, rather than count  all quantities
of acid aerosol generated in the system. Since
the acid aerosols are  "manufactured" and then
"otherwise used" in these acid reuse systems,
the 10,000 pound "otherwise use"  threshold
would be the threshold that would first trigger
reporting from such systems. For example, if
a facility starts the year with  2,000 pounds of
sulfuric acid in the system, and adds 500
pounds during  the reporting  year,  2,500
pounds of sulfuric acid aerosol would  be
applied to the manufacturing and otherwise
use threshold.
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chemicals in materials purchased to be used as fuel or for maintaining equipment operations,
other than for maintaining motor vehicles, should be included in the threshold determination for
"otherwise use" activities.  Any EPCRA Section 313 chemicals in materials purchased to be used
in the waste management processes should also be included in the threshold determination for
"otherwise use" activities.
                                                         STEP TWO
                                          Identify "processing" and "otherwise use"
                                          activities that are subject to exemptions.
                                          Exclude chemicals  associated with  these
                                          activities     from     your    threshold
                                          determination.
When performing your threshold
determinations, it is important to
remember that exemptions apply to
certain facility-related activities. These
exemptions were discussed in Section 2 of
this guidance document and may apply
only to certain "manufacturing,"
"processing," or "otherwise use"
activities.  For the purposes of an activity
threshold analysis, the following areas should be examined closely to determine whether the TRI
chemicals subject to certain activities should be included in the activity threshold and reporting
calculations:


   •    Overburden: The Section 313 chemicals present in "overburden," the unconsolidated or
        consolidated material that overlies a deposit of useful materials or ores, are exempt from
        threshold determinations and release calculations if processed or otherwise used by
        metal mining facilities within SIC code 10.

   •    Laboratories: Sampling and analysis, research and development (R&D), and QA/QC
        activities undertaken in laboratories are exempt if conducted under the supervision of a
        technically qualified individual.  Pilot plants and support services, such as photo
        processing, waste water treatment, and instrument sterilization are not exempt. Wastes
        generated during sampling and analysis, R&D, and QA/QC activities in an on-site
        laboratory are exempt.

   •    Motor vehicles: Use of products containing Section 313 chemicals used for maintaining
        motor vehicles operated by the facility are exempt, as well as the fuels used in those
        vehicles.

   •    Routine janitorial or facility grounds maintenance: The routine maintenance
        exemption is intended to cover janitorial or other custodial or plant grounds maintenance
        activities using such substances as bathroom cleaners, or fertilizers and pesticides used
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
       to maintain lawns, in the same form and concentration commonly distributed to
       consumers. Equipment maintenance such as the use of oil or grease is not exempt.
                                                        \
       Materials as they are drawn from the environment or municipal sources- Chemicals
       contained in intake water (used for processing or non-contact cooling) or in intake air
       (used either as compressed air or for combustion) are exempt from the activity
       thresholds.  However, EPCRA Section 313 chemicals manufactured from use of the air
       or water are not exempt and must be considered for the threshold determination.
In making threshold determinations, it is
important that you keep in mind that a de
tninimis exemption applies only to Section
313 chemicals in mixtures or trade name
products manufactured as impurities or
processed or otherwise used in mixtures
or trade name products. This exemption
does not apply to chemicals that are
manufactured as byproducts nor does it
apply to chemicals in wastes that are
processed or otherwise used.

Metal mining facilities should bear in
mind that metal beneficiation processes
concentrate metals and/or metal
compounds.  In instances where the ore as
mined did not contain Section 313
chemicals above the de minimis
concentration, concentrating the metal and/or the metal compounds could result in the metal
and/or the metal compound being present above the de minimis concentration. From the point at
which the metal and/or the metal compound meets or surpasses the de minimis concentration, the
metal should be included in your threshold determination and release estimates.  For example,
metals may become concentrated in a tailings pond.

Section 313 chemicals present at less than 1 percent (< 10,000 ppm) for chemicals that do not
meet the OSHA carcinogen standard or less than 0.1 percent (< 1,000 ppm) for chemicals that do
meet the OSHA carcinogen standard do not have to be considered when making your threshold
determinations for processing or otherwise use. Appendix A to this document contains the list of
Section 313 chemicals subject to reporting, along with the de minimis concentration associated
with the chemical. The list of Section  313 chemicals in the publication Toxic Chemical Release
             STEP THREE
Determine whether  TRI chemicals  are
present in mixtures or trade name products
that are processed or otherwise used below
the de minimis concentration threshold and
eliminate from further consideration in your
processing and otherwise  use threshold
determination  those  chemicals below de
minimis, unless those chemicals are later
concentrated.   Also  determine  whether
chemicals are present  as impurities  below
the de minimis concentration threshold in
manufactured products and eliminate from
further     consideration     in     your
manufacturing  threshold  determination
those chemicals below de minimis.
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Inventory Reporting Form R and Instructions for the current reporting year should also be
checked to determine whether the list of chemicals has been updated (e.g., changes in listed
chemicals and chemical categories, and de minimis levels).
Threshold determinations are made based
on the best available information in your
possession. Inventory data, consumption
information, and supplier notifications
can be used in determining the amount of
chemicals used for the purpose of making
a threshold determination.  In general, the
type of data to be used in calculating
threshold determinations is shown below:
              STEP FOUR
Gather data  needed  for  calculations  of
threshold determination, including:

•      Inventory Data
•      Consumption Information
•      Supplier Notification
•      Ore Sampling and Analysis Data
       MSDS
•      Analysis of Waste Products
•      Permits
-   Analysis prior to extraction,
-   Analysis during/after beneficiation,
-   Analysis during/after leaching,
-   Volume determination, or
    Estimations.

Where data are lacking and the metal mining facility has reason to suspect that a TRI chemical is
present, reasonable estimates should be made.  For example, a typical concentration may be
established based on best engineering judgement.  Where the metal mining facility does not have
a reason to suspect that such a Section 313 chemical is present in a mixture, that mixture need
not be included in the threshold determination.
                                                    *,
Further, tailings impoundments found at mining operations perform a number of functions,
including the following:


    •    Removal of suspended solids by sedimentation
        Precipitation of heavy metals as hydroxides
        Permanent containment of settled tailings
        Stabilization of some oxidizable constituents (e.g., thiosalts, cyanides, flotation reagents)
        Storage and stabilization of process recycle water
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                METAL MINING FACILITIES
  Sources of Information for Metal Compound
           Threshold Determinations

  Metal mining facilities should use the best
  available information for determining thresholds
  of metal compounds in ore. In the absence of
  recent data (such as current ore analysis),
  historical data such as those collected before or
  during the mine's first operations may provide
  reasonable estimates. Metal mining facilities
  that only know total elemental metal
  concentrations in ore, (i.e., do not know the
  specific compounds present in the ore), can use
  additional information to make a reasonable
  threshold determination. For example, if the
  facility has information indicating that the metal
  will naturally exist  as a particular type of
  compound (e.g., copper sulfides) the facility can
  assume the metal exists as the lowest weight
  suffide compound  (e.g., CuS).  If the facility
  has no information on the type of compound
  that is present (e.g., does not know if a non-
  target metal exists  as a sulfide, oxide, carbonate,
  etc.), they may assume that the metal exists as
  the lowest weight oxide.
        Some or all of these functions can result
        in the manufacture of Section 313
        chpmical^ that are subject to reporting,
        such as the manufacture of a metal
        hydroxide that is a Section 313 chemical.
        Other chemicals may be added to the
        tailings impoundment to promote
        precipitation, stabilization, or oxidation.
        If these are Section 313 chemicals, they
        are "otherwise used" and should be
        considered in making threshold
        determinations,  as discussed in this
        section, as well  as release estimates, as
        discussed in Section 5.

        Threshold determinations are made based
        on the best available information in your
        possession.  In general, the following
        methods should be employed to
        determine the appropriate concentrations
        to use in threshold determinations:

           •    If the exact concentration is
          ;     known  (e.g., 33.0% toluene), use
               it.
       If only the upper bound is known
       (e.g., <5% toluene), use it (e.g., 5%
       toluene).


       If the concentration is know (e.g., 10-
       30% toluene), then use the midpoint
       (e.g., 20% toluene).


       If only the lower bound is known,
       assume the upper bound is 100%.
       Factor out other known constituents
                 STEP FIVE
   Calculate  the quantity of each chemical
   manufactured,  processed  and  otherwise
   used, in pounds, to determine whether the
   activity threshold has been exceeded.  The
   Form  R  must  be completed  for  each
   chemical! otherwise used in excess of 10,000
   pounds and for each chemical processed in
   excess of 25,000 pounds, for each chemical
   manufactured in excess of 25,000 pounds.
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                 METAL MINING FACILITIES
        (e.g., 10% water and >60%toluene), create a range (e.g., 60-90% toluene) and then use
        the midpoint (e.g., 75% toluene).
                                                                \
In cases where certain materials that have broad ranges or high upper bounds for multiple
constituents (e.g., %x+%y+%z=l 10% of mixture), the total components of a mixture should not
exceed 100%. In these instances, the best available information should be used to estimate the
approximate concentration of the chemicals in the material.  However, if a facility is aware that a
chemical is probably present in a mixture but has no information on its concentration in the
mixture, then they are not required to consider that chemical in its threshold determinations.
                              THRESHOLD DETERMINATIONS FOR
                                  ELEMENTS AND COMPOUNDS

   Many metals are Section 313 chemicals, and a mine that processes quantities of Section 313 metals in excess
   of the 25,000-pound per year threshold must complete a Form R for the metal and estimate releases if the
   concentrations of these metal ever meet or exceed the de minimis concentration during the beneficiation
   process. (See Appendix A for list of chemicals and de minimis concentrations) The metal in the ore can
   exist in its elemental form but more commonly exists in the compound state. Antimony compounds,
   arsenic compounds, banum compounds*, cadmium compounds, chromium compounds, cobalt compounds,
   copper compounds*, lead compounds, manganese compounds, mercury compounds, nickel compounds,
   selenium compounds, silver compounds, thallium compounds, and zinc compounds are separate Section 313
   chemical categories distinct from the elemental form.

   Therefore, two separate and exclusive threshold determinations must be made — one for the elemental
   metal and one for total metal compounds Threshold determinations for the metal compound categories
   require the calculation to be made on the cumulative weight of all metal compounds in that category that are in
   a mined ore  If the mined ore contains metal compounds at or above the de minimis concentration by weight
   on a compound basis or if the mined ore is beneficiated and the metal compounds are concentrated such that
  • the total concentration of metal compounds is at or above the de minimis concentration, then releases of the
   parent metal only need to be estimated and reported from the point in the process in which the metal
   compounds first meet or exceed the de minimi.1! level.  For mined ores containing more than one memijer of a
   listed Section 313 metal compound category, the de minimis level applies to the aggregate concentration of all
   members \\ithin the listed category, and not  to each individually.

   Ore also may contain other metals or metal compound categories than the valued minerals. If the
   concentration of these other metals or metal compounds exceed the de minimis concentration, then releases of
   these metals also need to be reported.

   Compounds that contain metals from one or more different metal compound categories are counted
   towards the threshold for each category.  For example, the entire weight of Cu,AsS4 (enargite) would be
   considered towards thresholds for both copper compounds and arsenic compounds.

   *See Appendix A for exceptions to the copper compounds and barium compounds categories.
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                                     SECTION 4
               OVERVIEW OF SECTION 313 RELEASE ESTIMATION
                                                         .•
This section presents general guidelines for preparing Section 313 release estimates. It begins
with a discussion of general ideas on estimating chemical releases.  A summary of errors that
commonly occur in Section 313 reporting follows.

GENERAL CONCEPTS

Release Estimation

A Form R or Form A must be completed for each Section 313 chemical that meets the applicable
activity thresholds. Each form requests facility specific information and identifies the chemical
for which thresholds were exceeded. Form A (the abbreviated report) includes a statement that
the facility did not exceed specified amounts while, the main components of Form R are
environmental release estimates to all media for the reportable chemical during the preceding
calendar year. This includes all wastes containing the reportable Section 313 chemical that are
sent off-site from the facility for further waste management.  Specifically, facility release
estimates must be made for the following release sources:

   •    Releases to air from fugitive or non-point sources (Section 5.1)

   •    Releases to air from stack or point sources (Section 5.2)

   •    Releases to water directly discharged to a receiving stream (Section 5.3)

   •    Releases in wastes that are injected underground (Section 5.4)

   »    Releases to land on-site (Section 5.5)

   •    Releases to water discharged to a publicly owned treatment works (POTW) (Section 6.1)

   •    Wastes transferred off-site for recycling, energy recovery, waste treatment, or disposal
        (Section 6.2)
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                  METAL MINING FACILITIES
 Waste Rock

 As discussed in Section 3 of this document, waste rock
 that is separated from the ore body and deposited on-site
 or transferred off-site for purposes of disposal or other
 waste management activities has not undergone an
 EPCRA Section 313 reportable activity, and therefore,
 amounts of Section 313 chemicals contained in the
 waste rock do not have to be considered towards activity
 thresholds.

 However, because the waste rock has not undergone a
 reportable activity does not infer that waste management
 activities associated with the waste rock are exempt. In
 the above description (where the waste rock is simply
 disposed of), amounts  of the EPCRA Section 313
 chemicals in the waste rock  must be considered for
 release and other waste management reporting (e.g.  ,
 disposed to  land  on-site),  provided that  an activity
 threshold has been exceeded elsewhere at the facility.

 Additionally, because the waste rock has not undergone
 a "threshold activity", (i.e., "manufacture, process, or
 otherwise use") amounts of EPCRA Section  313
 chemicals further managed as waste are not eligible for
 the de minimix exemption.

 Amounts of EPCRA Section  313 chemicals in waste
 rock must  be considered  toward  the "processing"
 threshold if the waste rock is  distributed in commerce
 for beneficial reuse (e.g., as roadfill), or if the waste
 rock undergoes beneficiation  (actually   no  longer
 considered waste rock) and is distributed in commerce.
    Development of accurate and comprehensive
    release estimates requires consideration of all
    possible release pathways. The threshold
    determination provides valuable information
    when beginning the release estimation
    process for a Section 313 chemical: each
    material containing a Section 313 chemical is
    identified. For each of these materials, the
    facility should identify all potential release
    sources.  A useful way to do this is to draw a
    process flow diagram that traces the
    material's path through the plant. The
    process flow diagram should identify each
    major piece of equipment (including
    pollution control devices) through which the
    material passes, from its initial entry into the
    facility to its final disposition.  The diagram
    should also identify all potential release
    sources' and pollution control equipment for
    the chemical.
       Underground Mines

       Waste  rock  that remains underground  is
       reported as a release to land (Part II, Section
       5.5.4 of Form R - Other Disposal).  Fugitive
       emissions underground that are not released to
       the  afr but  settle underground   are also
       reported as a release to land (Section 5.5.4 of
As a guide to better understanding releases, Figure 4-1 presents the steps typically used in the
copper mining industry, beginning with extraction. Releases associated with extraction are
reportable, with the exception of releases from overburden, which are exempt under 40 CFR
§372.38(h).  Overburden is the unconsolidated or consolidated material that overlies a deposit of
useful materials or ores.  Figure 4-1 presents the extraction phase at the top, in the white box.
Potential release pathways include disposal of leach ore in leach dumps, disposal of waste rock in
waste dumps, and releases to surface water.
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                                                  METAL MINING FACILITIES
Figure 4-1. Schematic of Typical Copper Mining Extraction and Beneficiation Wastestreams
                                                          Min> Water DfaJnag*
                                                               (PPT) Pradpatator
                                                                (IX)
                                                                (A)  Pra0nantSolutlc
                                                                (B)  Bamn Solution
                                                                (C)  Mate Up Water
                                                                (D)
                                                                    Tlilckanar
                                                                {E)
                                       Waste Typa»
                               • A. Waste Dumpa
                               ' 8. Laaeh Dump
                               . C. NPDESSi*1aea Water DtedMign
                                O. Surfae* Water Run-off
                                E. Laaeh Circuit Sludgaa from SX/EW
                                  fadMy
                                F. Floatation CifcuHCtoanout*
                                G. Sdid Tailing*
                               . RNPOESTailinptDiicharga
                                 (limited in arid »nv
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TRI FORM R GUIDANCE DOCUMENT
                METAL MINING FACILITIES
In the copper beneficiation process, crushing and grinding, flotation1, and leaching are used.
Figure 4-1 also presents the potential solid waste and water releases from these processes as well
as the points where on-site recycling or reclamation can occur.  In addition to land and water
releases and recycling activities shown, mines will have fugitive air emissions of fume and dust
(all particle sizes are included). These air emissions will be higher in dry operations than in wet
operations, and should also be considered in Section 313 reporting. Mines can utilize process
flow diagrams, such as the one presented in Figure 4-1, to identify potential points of release of
Section 313 chemicals. (The boxes which differentiate extraction and beneficiation in Figure 4-1
are for illustrative purposes only.  Any official determination of the RCRA status of a mining
activity should be obtained from the appropriate State or EPA Region.)
                                                      i

After you have identified all the potential release sources for a chemical, you can estimate
releases for each source.  Often, the starting point for a release estimate is chemical throughput
data, which are typically available from threshold determination calculations.

Given the chemical throughput quantities for a process, you must apply other data and
assumptions to complete the estimates. This information includes process-specific data (e.g.,
scrubber efficiency) and any data developed for other environmentally oriented purposes (e.g., air
and wastewater monitoring data, air and water permits and permit applications, RCRA manifest
data, monitoring data).

Section 313  does not require any new monitoring to be performed.  Facilities should use existing
data to calculate release estimates.  The accuracy of a release estimate is proportional to the
quantity and quality of the data used in its preparation. Situations may arise where estimates
based on one set of data contradict estimates based on another. In such cases, the facility should
document the  rationale for using one data set (or method) versus another.  If a facility is aware
that a chemical is probably present but has no method to estimate releases or quantities on site,
then they are not required to report on that chemical.

Release estimates can be developed by combining all available data with assumptions concerning
the fate of each chemical in the process. There are  four geperal methods for developing a release
estimate. These methods may be used together or in sequence in developing release estimates.

       •      Direct measurement (basis of estimate code = M, entered in Part II Sections 5
              and 6) - These are  estimates based on actual monitoring of the concentration of a
       1 Flotation is the process where particles of one or more minerals are preferentially wetted by various agents
causing the hydrophobic minerals to adhere to the surfaces of air bubbles. As the air bubbles rise to the surface, the
desired minerals are transported to the surface and are removed by skimming.  See Chapter 5 for more details.
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              chemical.  The chemical's concentration in the waste stream multiplied by the
              flow rate or volume of the waste stream and its density yields the mass of the
              chemical released.  Direct measurement is typically used to estimate releases via
              wastewater, solid waste, and hazardous waste, in part, to ensure compliance with
              applicable environmental regulations.  Although this estimation method should
              yield the most accurate results, only rarely are sufficient data available for direct
              measurement data to be applied without also resorting to other techniques (e.g.,
              engineering calculations, mass balance). The frequency of the direct
              measurements should be taken into account when determining if monitoring data
              alone are sufficient for making a reasonable estimate.  For example, if a facility
              has only gathered monitoring data once throughout the year, other methods may
              provide a more accurate estimate.

       Note that if a measurement indicates that a Section 313  chemical is below detection, this
       is not equivalent to stating that the chemical is not present. If the Section 313 chemical is
       known to be present, a concentration  equivalent to half the detection limit should be used
       in subsequent calculations  of release estimate quantities (i.e., if the limit of detection is 10
       mg/1, release calculations should be performed during a concentration of 5 mg/1). If the
       Section 313 chemical is not known to be present in the waste, then zero can be assumed.

       •      Mass balance (basis of estimate code = C entered in Part II, Sections 5 and 6) -
              These are estimates based on a knowledge of the quantity of a chemical entering
              and leaving a process. An imaginary boundary is first drawn around the process,
              and all streams entering or leaving the boundary are identified. Assuming the
              amount of the chemical in the process input streams is known, a facility could
              calculate the quantity in waste streams by difference.  A facility would need to
              account for any accumulation or depletion of the chemical within the mass
              balance boundary.  The equation for mass balance is:

               Input - Generation = Output + Amount Reacted -r Accumulation

       Using a mass balance to  estimate a relatively small release of a chemical with a large
       throughput can lead to inaccurate, or even negative release estimates.  Even a small
       percentage error in a large throughput could amount to a greater quantity than the release
       recalculated.  When several large values each with their respective errors are used to
       calculate a small release, propagation  of errors occurs which could yield a highly
       inaccurate value. Other techniques should be considered in these  situations.
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       Mass balance estimates usually require engineering calculations or assumptions to be
       made (e.g., all usage results in air or water releases). These assumptions should be
       explicitly stated in the documentation and should be checked for reasonableness.

       •      Emission factors (basis of estimate code - E entered in Part II, Sections 5 and 6)
              - Release information derived from facilities or processes similar to yours can be
              used to estimate releases. Emission factors come in two forms.  The first
              expresses releases as a ratio of the amount of chemical released to facility
              throughput or production (e.g., 0.5 pound of Chemical X released per every pound
              of Material Y used)  The second provides a typical concentration of a chemical in
              a waste stream (e.g., 0.1 mg/L of Chemical Z in wastewater from scrubbers).
              These factors, combined with process throughput or waste stream flow data, can
              be used as a  basis for the release estimate.  Many emission factors are available in
              Compilation of Air Pollutant Emission Fadtors (AP-42).  AP-42 can be accessed
              via the Internet at http://www.epa.gov/ttn/qhief/ap42etc.html. The basis of
              estimate code "E" can only be used for published Section 313 chemical-specific
              emission factors.

       The reliability of emission factors depends on the quality and quantity of data used in
       their derivation, plus the similarity of the process to which  they are applied and the
       quality of raw materials for the process.

       *      Engineering calculations and assumptions (basis of estimate code = O entered
              in Part II, Sections 5 and 6) - Estimates thai do not fall into any of the above
              categories are considered engineering calculations.  Typically, these estimates are
              based on standard engineering principles using properties of the chemicals
              involved, process data, or process knowledge. Example chemical properties
              include vapor pressure, solubility in water, and density. Example process
              parameters include temperature, pressure, and material flow rate. Other examples
              of engineering calculations would be the use of general equipment emissions
              factors or non-published, facility-developed emissions factors.

Reasonable Estimates: Significant Figures and Use of flange Codes

EPA recommends that two significant figures be used when reporting release and off-site transfer
quantities in Part II,  Sections 5 and 6 of Form R. Use of two significant figures may prevent
errors from being reported on Form R, because a small calculating error may not impact the final
reported quantity if the quantity is rounded to two significant figures. If you have reason to
believe that your best estimate of a release quantity is particularly imprecise, you could use one
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significant figure or one of the range codes in reporting releases in Part II, Sections 5 and 6 of the
Form R, if applicable:
                                                          .«
       Range Code A = 1 to 10 pounds
       Range Code B = 11 to 499 pounds
       Range Code C = 500 to 999 pounds

"NA" versus "0"

If you have no releases of a Section 313 chemical to a particular medium, report either "NA,"
not applicable, or "0," as appropriate.  Report "NA" only when there is no possibility a
release could have occurred to a specific medium or off-site location.  If a release to a specific
medium or off-site location could have occurred, but either did not occur or the annual aggre-
gate release was less than 0.5 pounds, report zero.  However,  if you report zero releases, a
basis of estimate must be provided.  If use of the Section 313 chemical began in the reporting
year, enter "NA" as the production ratio or activity index (Part II, Section 8.9 of the Form R).
For example, if nitric acid is involved in the facility's processing activities but the facility
neutralizes the wastes to a pH of 6 or above, then the facility reports a "0" release for the
Section 313 chemical.  If the facility has no underground injection well, "NA" would be
written in Part I, Section 4.10 and checked in Part II, Section 5.4.1  and 5.4.2 of Form R.
Also, if the facility did not use the Section 313 chemical in the previous year, the facility
would have no basis to develop a production ratio or activity index, "NA" would be checked
in Part II, Section 8.9 of Form R.
REPORTING RELEASES IN FORM R, PART II


The following sections discuss the types of release reporting required on the Form R.  Releases
must be partitioned into land and air releases and should not be inadvertently "double counted."
For example, a single wastewater discharge should not be listed as both a release to water (on-
site) and a discharge to a POTW (off-site), nor should a release to land be listed as a release to
both land (on-site) and a transfer to an off-site landfill.  Also, subsequent releases from land
(such  as a leak from an impoundment) to groundwater is included as a land release in the year the
leakage occurred. No reporting is required past the year in which it occurred,even if it leaches
out to ground water in the next year.
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It is important to note that historical releases are not included in release reporting.  For example,
contamination around an underground storage tank (UST) is discovered, but there is no active
leak from the tank.  If you know that the contamination occWed^during the reporting year (RY),
then report the leak as a release to land.  However, if the leak did not occur during the RY, it
should not be included in release reporting.


Metal mining facilities that close during the reporting year count all quantities of Section 313
chemicals manufactured, processed, or otherwise used during the entire reporting year. Similarly,
all quantities of Section 313 chemicals released or managed as waste during the reporting year
are reported in the appropriate section of the Form R.  Section 313 chemicals in waste rock,
tailings, or other wastes left on land are reported as releases! to land (Part II, Section 5.5.4 of
FormR).                                               ;

Finally, the amount of leaks or spills onto pads or containment  areas should not automatically be
reported as released to land. The amount should be considered as treated or disposed depending
on type of disposal activity.  After releases to air, amounts cleaned up and disposed of off-site,
amounts recycled, and amounts released to water are considered, then the amount remaining on
the pad is considered to be released to land  Amounts spilled into containment that are directly
reused within the same reporting year without requiring treatment prior to reuse are not subject to
release reporting.

Fugitive or Non-Point  Emissions (Part II, Section 5.1 of Form R)
Fugitive emissions can occur from almost any part of a facility's operation. Potential sources
include the following:
              Normal leakage of valves,
              pump seals, flanges,
              connectors, and other
              devices
              Sampling, Packaging,
              Loading, and unloading of
              chemicals
              Cleaning and maintenance
              activities such as blowing
              out pipes
              Containers of raw
              materials, intermediates, or
              wastes
TSCREEN and SHEAR

To  estimate  emissions  from tailings piles, the
TSCREEN  model can be  used to correctly analyze
toxic emissions and their subsequent dispersion from
one of many different  types of possible releases,
including tailiqgs piles.   The computer program
TSCREEN,  A Model for Screening Toxic Air Pollutant
Concentrations, should be used in conjunction with the
"Workbook  of Screening Techniques  for Assessing
Impacts of  Toxic Air Pollutants (Revised)"  (EPA.
1992a). With the use of these tools one can determine
the type of release and the steps to be followed to
simulate the release.   TSCREEN can be downloaded
at http://\vww.epa.gov/scram001.
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            Storage piles and spills
            Evaporation from cooling towers, ponds, surface
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       •       impoundments, and on-site wastewater mapagement systems (including on-site
             sewers)
       •      Drum residues

Where actual monitoring or measurement data are not available, data sources and calculation
methods that could be employed in estimating fugitive emissions include the following:
       •      Industrial Hygiene monitoring data
       •      AP-42 Emissions Factors (listed in Table 5-2)
       •      SOCMI emission factors (listed in Table 4-1)
       •      Facility-specific emission factors, models
       •      Mass balance (for volatile solvents)
       •      EPA models such as WATERS for wastewater management systems
       •      Data from a leak detection and repair (LDAR) program
       •      Engineering calculations
             CHEMDAT8, TANKS, TSCREEN and SHEAR, etc

Additional models are provided on page 4-9 and in Appendix C.

                Table 4-1. SOCMI AVERAGE EMISSION FACTORS*
Equipment type
Valves
Pump sealsb
Compressor seals
Pressure relief valves
Connectors
Open-ended lines
Sampling connections
Service'
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
All
All
All
Emission factors* (ibs/hr/source)
0.0131
0.60887
0.00051
0.0438
0.0190
0.502
0.229
0.00403
0.0037
0.033
•Protocol for Equipment Leak Emission Estimates (EPA. EPA-453'R-95-017)
a These factors are for total organic compound emissions
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                   METAL MINING FACILITIES
b The light liquid pump seal factor can be used to estimate
the leak rate from agitator seals
c "Gas" is material in a gaseous state at operating conditions,
"Light liquid" is material in a liquid state in which the sum of
the concentration of individual constituents with a vapor
pressure over 0.3 kilopascals (kPa) at 20 C is greater than or
equal to 20 weight percent, and "Heavy liquid" is material
that is not defined as a gas or light liquid.
Stack or Point-Source Air Emissions (Part
II, Section 5.2 of Form R)
Point-source air emissions can occur from
numerous pieces of process equipment
throughout a facility. Potential sources include
the following:

        •      Air pollution control devices
               such as scrubbers, condensers,
               baghouses, etc.
        •      Storage tanks, process tanks,
               and waste tanks
        •      Process vessels such as
               reactors  and distillation columns
    TANKS

    The TANKS program is designed to estimate emissions
    of organic chemicals from  several types of storage
    tanks.  The calculations are performed according to
    EPA's AP-42, Chapter 12.  After the user provides
    specific information concerning a storage tank and its
    liquid contents, the system  produces a report which
    estimates  the chemical emissions  for the tank on an
    annual or partial  year  basis.   The user can  also
    determine individual component losses by using one of
    the specification options available in the program.

    The TANKS program relies on a chemical database of
    over 100 organic liquids and a meteorological database
    which includes over  250 cities in the United States:
    users may add new  chemicals and  cities  to these
    databases by providing specific information through
    system utilities. On-line  help provides documentation
    and user assistance for each screen  of the program.  The
    TANKS program and manual can be downloaded from
    the Internet at http://ww\v.eDa.gov/ttn/chief/tanks.html.
Where actual monitoring or measurement data are not available, data sources and calculation
methods that could be employed in estimating stack or point source emissions include the
following:
               Air emission inventories
               Air permit applications
               Process and production data
               Emission factors from EPA
               and commercial models
               Engineering calculations
Wastewater Discharges (Part II, Section 5.3
and 6.1 of Form R)
Discharges to a stream or water body are
reported in Part 11, Section 5.3 of Form R,
    WATERS

    A computer program, WATERS,  is  available for
    estimating the fate of organic compounds in various
    wastewater treatment  units,  including   collection
    systems, aerated basins, and other units  WATERS is
    written to run under DOS without the need to purchase
    other  programs.  WATERS  contains useful features
    such as the ability to link treatment units to form  a
    treatment system,  the ability for recycle among units,
    and the  ability to generate  and  save site-specific
    compound properties. The WATERS program and users
    manual can be downloaded from the world wide web at
    httn ://www.epa. eov/ttn/
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while transfers to Publicly Owned
Treatment Works (POTWs) are reported in
Part II, Section 6,1  of Form R. Because the
release estimation approach is similar for
both types of wastewater discharges, they
are discussed here together
  CHEMDAT8

  Analytical models*have been developed to estimate
  emissions of organic compounds via vahous pathways
  from wastewater and waste management units. Some
  of  these models  have been  assembled  into a
  spreadsheet called CHEMDAT8 for use on a PC.  A
  user's guide for CHEMDAT8 is also available. Area
  emission sources for which models are included in the
  spreadsheet are as follows: nonaerated impoundments,
  which include surface impoundments  and open top
  WWT tanks;  aerated impoundments, which include
  aerated  surface  impoundments  and  aerated WWT
  tanks; disposal impoundments, which include  non-
  aerated  disposal impoundments;  land treatment;  and
  landfills. These models can  be used to estimate the
  magnitude  of  site  air emissions   for regulatory
  purposes. The CHEMDAT8  program and manual can
  be  downloaded  from  the  world  wide  web  at
  hftp: //www .jepa gov/ttn/chief/
  software.htmllwaterS
A facility that discharges or has the potential
to discharge water containing regulated
wastes must operate under the terms of
Federal, State, and/or local permits, such as
a NPDES permit, or a POTW agreement.
The permit(s) or agreement usually require
measurements of the water volume and
monitoring and analyses of some
generalized wastewater parameters including
concentrations of various constituents. In
some cases, the constituent analyses
required for permit compliance includes
Section 313 chemicals. In these instances, releases can be calculated by multiplying the volume
of wastewater released by the concentration of the chemical released. Releases discharged to a
POTW should be reported  as off-site transfers on Part II, Section 6.1 of Form R.

Based on the concentration and wastewater flow data available, an estimate of discharges to
water can be  calculated.  Facilities should calculate the daily average discharges of a reportable
Section 313 chemical in pounds and must use those estimates to determine the annual discharge
in pounds per year. Using the daily concentration data avaijable for the reportable chemical
combined with the wastewater flow data for each of the sampling dates, calculate an estimate of
pounds per day for each sampling date.  After the calculations are made for each monitoring
point (e.g., daily, monthly), the pounds discharged are averaged to determine an average daily
discharge amount which would be multiplied by the number of days discharges were possible
(e.g., 365 days a year).
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                                       Example Calculation of Yearly Wastewater
                                       Discharge

                                       A facility has monitoring data on discharges to water of xylene,
                                       a listed Section 313 chemical, and a Form R report is required.
                                       In  this example, monitoring data on this chemical are only
                                       available for two days in the year. The daily quantities of pounds
                                       of xylene released for those two dates would then be divided by
                                       the number of sample dates to determine the daily average for the
                                       whole reporting year, which would be used to estimate the annual
                                       discharge of xylene in wastewater:
If no monitoring data exist, NPDES
permit applications or POTW
agreements may provide information
useful to estimating releases.
Otherwise, process knowledge (or in
some cases, mass balance) needs to
be utilized to develop an estimate.

Section 313 reporting rules consider
a waste stream containing a
reportable acid (e.g., nitric acid) with
a pH at 6 or above to be completely
neutralized. Thus, if listed acids have
been neutralized to pH at 6 or above
before discharge to water or POTW,
zero releases should be reported. Any
excursions below a pH of 6
potentially constitute release of a
reportable acid.  For more
information on calculating such
discharges of mineral acids, see
EPA's Estimating Releases of Mineral Acid Discharges Using pH Measurements (EPA 745/F-
97-003, June 1991). Note that  sulfuric and hydrochloric acids are only reportable in aerosol
forms.
Date
3/1/96
9/8/96
Concentratio
n (mg/1)
1.0
0.2
Flow
(MGD)
1.0
0.2
Daily
Discharge
8.33 Ibs.
0.332 Ibs.
                                       Annual Calculation:
                                        8.33 Ibs. + 0.332 lbs./2 days x 365 days/year'
1580.82 Ibs/vr
Releases should not be inadvertently "double counted."  A single wastewater discharge should
not be listed as both a release to water (on-site) and a discharge to POTW (off-site). Similarly, a
release to land should not be listed as both a release to land (on-site) and a transfer to an off-site
landfill.

Underground Injection On-Site (Part II, Section 5.4 of Form R)

A facility that has an underground injection well for waste disposal is regulated by Safe Drinking
Water Act (SDWA) permits. The permit(s) usually require measurements of the waste volume
and analyses of some generalized  waste parameters including concentrations of various
constituents.  When the constituents for which the permit requires analyses include reportable
Section 313 chemicals, releases via underground injection can be calculated by multiplying the
volume of waste injected  by the concentration of the chemical in the waste. Facilities must
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report amounts of Section 313 chemicals
injected into Class I wells (Part II, Section
5.4.1 of Form R) and amounts injected
into Class II-V (Part II, Section 5.4.2 of
Form R)

Release to Land On-Site (Part II,
Section 5.5 of Form  R)

In most circumstances involving the
disposal of many Section 313 chemicals,
land disposal is regulated by RCRA and
state regulations. In part II, Section 5.5,
TRJ is concerned with the  total amount of
the specified reportable Section 313
chemical released to land, regardless of the
potential for the chemical to leach from
the disposed waste.

On-site disposal  includes disposal in an
on-site RCRA Subtitle C landfill (Part II,
Section 5.5.1 A of Form R), disposal in
other on-site landfills (Pan II, Section
5.5. IB of Form R), disposal in a land
treatment/application farming unit (Part II,
Section 5.5.2 of Form R),  and disposal in a
surface impoundment (Part II, Section
5.5.3 of Form R). Data concerning these
types of "intentional" on-site disposal are
usually readily available because facilities
are required to monitor the quantity of
waste and will have a waste profile that
describes typical concentration ranges for
waste constituents. In some cases,
concentrations of constituents in the waste
have been measured.  If on-site waste
treatment occurs prior to on-site land
disposal, the treatment efficiency and a mass balance can be conducted to determine the quantity
of a chemical that is land disposed.  For example, a facility can determine the amount of the
chemical present in the untreated waste, determine the efficiency of treatment in removing or
     Estimating Releases for Accidental Losses
                  *.
 Leaks, spills, and drips from the loading and transfer of
 chemicals received at the facility should be considered
 and reported in your release estimates. Data concerning
 specific incidents  (such  as  notification reports  or
 incident logs)  should be used to  estimate releases.
 Equations found in Section 6 of EPA's Estimating
 Releases and  Waste Treatment Efficiencies for the
 Toxic Chemical Release Inventory Form (EPA 560/4-
 88-002, December  1987),  provides guidance on
 calculating  releases  from chemical spills  or  leaks,
 including  liquid  discharges,  fraction of  discharge
 flashed, vapqrization, two-phase discharges, and gas
 discharges.

 EXAMPLE:  A facility uses more than  10,000 pounds
 of ethylene glycol during the year to prevent freezing of
 coal piles. While unloading on a windless overcast day,
 a malfunctioik  occurs and onsite personnel visually
 estimate that SO gallons of ethylene glycol are spilled.
 Most of the spill  remains on the  pad, however, an
 estimated ten percent flows off the pad and onto the
 soil. Absorbent material used to remove the ethylene
 glycol from the concrete pad is transferred offsite for
 disposal. How would these releases be reported on the
 Form R? The density of ethylene glycol is 9.3 pounds
 per gallon, and the vapor pressure is 0.06 mm Hg at 68°
 F.

 Quantity spilled = 50galx 9.3 Ibs.'gal = 465 Ibs.
 Amount spilled onto pad = 465 x 90% = 418.5 Ibs.
 Amount spilled onto soil = 465 x 10% = 46.6 Ibs.

 Air emissions of ethylene glycol are expected to be
 negligible  due to  the  low  vapor  pressure and
 environmental  conditions, provided  response and
 cleanup are immediate.  Therefore, the total amount
 spilled onto Ihe  concrete pad (418.5  pounds)  is
 transferred offsite and should be reported in Sections
 6.2,  and the total  amount spilled onto the soil (46.6
 pounds) should be reported in  Section 5.5.4, othur
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                 METAL MINING FACILITIES
destroying the chemical in the waste, account for other releases (i.e., fugitive emissions, leaks,
spills, accidental releases, losses to air pollution control devices, etc.), and determine that the
remainder is the quantity of the chemical land disposed.

Releases to land on-site/other disposal (Part II, Section 5.5.4 of Form R) include the amount of
chemical released to land on site not covered by any of the above categories and include spills,
leaks, or "unintentional" disposal, such as metal dust that is deposited onto soil. Incident logs or
spill reports can provide useful information.

Transfers in Wastes to Other Off-site Locations (Part n, Section 6.2 of Form R)

Similar to on-site disposal, data concerning off-site waste transfers are usually readily available
because facilities are required to monitor the quantity of waste and either measure concentrations
of chemicals or develop a waste profile that describes typical concentration ranges. Under
Section 313, off-site transfer estimates are based on the final, known disposition of the reportable
Section 313 chemical in the waste sent off-site for further waste management.  For example, a
reportable Section 313 metal is contained in a waste solvent sent off-site for energy recovery
purposes.  Even though the waste stream as a whole has a sufficient heat value to warrant energy
recovery, metals do not have a significant heat value and, therefore, cannot be combusted  for
energy recovery. Unless the facility had additional information on the fate of the reportable
Section 313 metal in this waste,  the facility must assume the metal is being disposed and should
report the quantity sent off-site accordingly in Part II, Sections 6.2 and 8.1 of Form R.

Even wastes that were minimally processed, such as wastes that were  repackaged, such as small
containers removed from a lab pack that were not otherwise opened or managed, may need to be
reported if the article exemption (as discussed in Section 2) is not applicable.

On-site Waste Treatment Methods and Efficiency (Part II, Section 7A of Form R)

In Section 7A, the following information must be reported:
              General waste stream types containing the Section 313 chemical being reported;
              Waste treatment methods or sequence used on all waste streams containing the
              Section 313 chemical;
              Range of concentration of the Section 313 chemical in the influent at the first step
              in a waste treatment system;
              Efficiency of the waste treatment method or sequence in destroying or removing
              the Section 313 chemical; and
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                METAL MINING FACILITIES
       •      Indication of whether the efficiency estimate was based on actual operating data.

Report any waste treatment step through which the reportable Section 313 chemical passes
regardless of treatment efficiency. Report all non-identical parallel steps and all sequential steps.

Waste treatment for the purpose of Section 7A is defined &s removal of the Section 313 chemical
from the waste through destruction, biological degradation, chemical conversion, or physical
removal. Note that this definition of waste treatment is broader than the definition used in Part II,
Section 8 of Form R (discussed later). Section 7 A treatment efficiency is calculated as follows:
      percent efficiency = (input - output} x 100%
                              input

If your facility has a measurement of the pollutant concentration of input and output at the
treatment unit, these data should be used to calculate the treatment efficiency. If these
measurements are not available, data from literature or the equipment manufacturer can be used
for estimation purposes. Equipment manufacturer data on treatment efficiencies often represent
idea! operating conditions with an ideal waste matrix Thus, you may want to adjust such data to
account for downtime, process upsets, and other less than optimum conditions during the year
that would result in lower efficiencies.

Estimates of treatment efficiencies by process for EPCRA Section 313 chemicals are available
from the ATTIC database via modem from ATTIC by calling data number (703) 908-2138.

On-site Energy Recovery Processes (Part D, Section  7B of Form R)

In Section 7B, methods used to combust the Section 313 chemical in wastes for energy recovery
are reported. Two conditions need to be met to report the combustion of a Section 313 chemical
as energy recovery: (1) the chemical must  have a heat of combustion high enough to support
combustion (e.g., 5,000 BTU per pound or greater), and (2) must be combusted in a unit
equipped with an energy recovery device, such as a waste heat boiler.

On-site Energy Recycling Processes (Part II, Section 7C of Form R)

In Section 7C, methods used to recycle the Section 313  chemical in wastes are reported.
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  TRI FORM R GUIDANCE DOCUMENT	METAL MINING FACILITIES

  Source Reduction and Recycling Activities (Part n, Section 8 of Form R)

  The following discussion for Sections 8.1 through 8.7 applies to the current reporting year (i.e.,
  column B of Section 8 of the Form R).

  Quantity Released (Part D, Section 8.1 of Form R)

  The quantity reported in Section 8.1 is the quantity reported in all of Section 5, plus any quantity
  of a listed toxic metal or metal compound which was contained in waste transferred off-site to a
  POTW reported in Section 6.1, plus the quantity reported as sent off-site for disposal in Section
  6.2 minus the quantity reported in Section 8.8 that was released or transferred off site for
  disposal:

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

  Section 6.2 disposal codes are Ml0, M71, M72, M73, M79, M90, M94, and M99. In addition,
  EPCRA Section 313 listed metals and metal compounds in waste streams sent off-site to POTWs
  should be reported in Section 8.1, unless the facility has knowledge that the metal is being
  recovered.

  Quantity Used for Energy Recovery On-site (Part II, Section 8.2 of Form R)

  Estimate a quantity of the Section 313 chemical in wastes combusted for energy recovery on-site.
  This estimate should be the quantity of the chemical combusted in the process for which codes
  were reported in Section 7B. Test data from trial burns or other monitoring data may be used to
  estimate the quantity of the Section 313 chemical combusted for energy recovery purposes.  If
  monitoring data are not available, vendor specifications regarding combustion efficiency may be
  used as they relate to the reportable Section 313 chemical. A quantity must be reported in
  Section 8.2 when a method of on-site energy recovery is reported in Section 7B and vice versa.
  Two conditions need to be met to report the combustion of a Section 313 chemical as energy
  recovery:  the chemical (1) must have a heat of combustion high enough to support combustion
  (e.g., 5,000 BTU per pound or greater), and (2) must be combusted in a unit equipped with an
  energy recovery device, such as a waste heat boiler. Note that "NA" should be reported for
  Section 313 chemicals which are Halons (e.g., CFCs) and metals that do not have a heat of
  combustion sufficient to sustain combustion.
\
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                 METAL MINING FACILITIES
Quantity Used for Energy Recovery Off-site (Part D, Section 8.3 of Form R)

The quantity reported in Section 8.3 is the quantity reported in Section 6.2 for which energy
recovery codes are reported. Section 6.2 energy recovery codes are M56 and M92.  If a quantity
is reported in Section 8.8, subtract any associated off-site transfers for energy recovery:

       §8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
                                                      i
Quantity Recycled On-site (Part n, Section 8.4 of Form R)
Estimate a quantity of the Section 313 chemical recycled in wastes on-site. This estimate should
be the quantity of the chemical recycled in the process for which codes were reported in Section
7C. A quantity should be reported in Section 8.4 when a method of on-site recycling is reported
in Section 7C and vice versa.  To estimate this quantity, you! should determine if operating data
exist which indicate a recovery efficiency and use that efficiency value combined with
throughput data to calculate an estimate.  If operating data are unavailable, use available vendor
specifications.

Quantity Recycled Off-site (Part II, Section 8.5 of Form R)
The quantity reported in Section 8.5 must be the same as the. quantity reported in Section 6.2 for
which recycling codes are reported. Section 6.2 recycling codes are M20, M24, M28, and M93.
If a quantity is reported in Section 8.8, subtract any associated off-site transfers for recycling:

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

Quantity Treated On-site (Part II, Section 8.6 of Form R)
Waste treatment in Section 8 is limited to the destruction or c,hemical conversion of the Section
313 chemical.  The quantities reported in Section 8.6 will be those treated in a subset of the
processes for which codes were reported in Section 7 A, where treatment includes physical
removal from a waste stream. To estimate this quantity, you should determine if operating data
exist which indicate a treatment (e.g., destruction or chemical conversion of Section 313
chemical) efficiency and use that efficiency value combined with throughput data to calculate an
estimate. If operating data are unavailable, use available vendor specifications. Section 7A must
be completed if a quantity is entered in Section 8.6.
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          Quantity Treated Off-site (Part n, Section 8.7 of Form R)

          The quantity reported in Section 8.7 must be the sum of the quantities reported in Section 6.2, for
          which treatment codes are reported, and the quantities reported in Section 6.1, which were sent to
          a POTW. Section 6.2 waste treatment codes are M40, M50, M54, M61, M69, and M95. If a
          quantity is reported in Section 8.8, subtract any associated off-site transfers for treatment:

                  §8.7 = §6.1 + §6.2 (treatment) - §8.8 (off-site treatment).

          Because metals cannot be destroyed or chemically converted, metals cannot be reported as
          treated  in Section 8. Quantities of metals reported in Section 6.1 and 6.2 as being treated should
          be reported in Section 8.1 (Quantity released), unless the facility has knowledge that the metal is
          being recovered.

          Quantity Reieased to the Environment as a Result of Remedial Actions, Catastrophic
          Events, or One-time Events Not Associated with Production Processes (Part II, Section 8.8
          of Form R)

          The quantity reported in Section 8.8 is the quantity of the Section 313 chemical released directly
          into the environment  or sent off-site for recycling,  waste treatment, energy recovery, or disposal
          during the reporting year due to any of the following events:

                  (1) Remedial actions
                  (2) Catastrophic events such as earthquakes, fires, or floods
                  (3) One-time events not associated with normal or routine production processes

          The quantity reported in Section 8.8 should not be included with quantities reported in Part II
          Sections 8,1 through  8.7 of Form R, but should be included in Part II, Sections 5 and 6 of Form
          R as appropriate.

          Spills that occur as a  routine part of production operations and could  be reduced or eliminated by
          improved handling, loading, or unloading procedures are  included in the quantities reported in
          Section 8.1 through 8.7 as appropriate. Releases and off-site transfers from remediation of a
          Section 313  chemical or an unpreventable accident unrelated to production (such as a hurricane)
          that cause a  reportable Section 313  chemical to be released are reportable in Section 8.8.
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                METAL MINING FACILITIES
On-site treatment, energy recovery, or recycling of Section > 313 chemicals in wastes generated as
a result of remedial actions, catastrophic events, or one-tim|e events associated with production
processes are not reported in Part II, Section 8.8 nor Sections 8.1 through 8.7 of Form R.
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                METAL MINING FACILITIES
                                     SECTION 5
    CALCULATING RELEASE ESTIMATIONS AT METAL MINING FACILITIES
Mineral extraction is the process of accessing and removing ore from the ground.  Depending on
the nature and location of the ore deposit, one of three general methods of extraction may be
employed. In surface mining, near-surface ore deposits are accessed by removing overlying rock
and soil to expose the ore. In deeper deposits, the ore may be accessed by constructing horizontal
tunnels and vertical shafts through which ore may be transported to the surface, in a method
called underground mining. Finally,  some deposits may be soluble or easily melted, or may
occur as solution in their native form. These deposits may be extracted by using wells to pump a
solution into the ore deposit and then to remove the solution to the surface in a process called
solution mining.  Releases associated with extraction are reportable, with the exception of
releases from overburden, which are exempt under 40 CFR §372.38(h).  Overburden is the
unconsolidated or consolidated material that overlies a deposit of useful  materials or ores.
Once extracted from the mine, ore must pass through a variety of steps before the valued
minerals are separated from the host rock material. Collectively called beneficiation, these steps
typically include crushing and grinding to reduce the size of the ore;  physical, chemical, or
electrochemical methods to separate metals from host rock; and chemical or electrochemical
steps to concentrate the metals. Following beneficiation, ores will be further processed by pyro-
metallurgical process, such as smelting or refining.
BENEFICIATION

The remainder of this section focusses on calculating releases from beneficiation activities at
metal mining operation in SIC Codes 1021, 1031, 1041, 1044, 1061, and 1099. The type and
concentration of the target mineral and the nature of the host rock help to determine the
beneficiation methods required to separate and concentrate the metals. As discussed earlier,
beneficiation is defined at 40 CFR §372.3, for the purposes of the TRI program, to mean
the preparation of ores to regulate the size (including crushing and grinding) of the
product, to remove unwanted constituents, or to improve the quality, purity, or grade of a
desired product.

To help mining facilities better understand the EPCRA Section 313 reporting requirements, this
section presents a brief discussion of each of the activities specified in the definition of
beneficiation found in RCRA, along with a discussion of release pathways and release estimation
techniques. Beneficiation is defined for the RCRA program (at 40 CFR §261.4(b)(7)) to include
the following activities:
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                METAL MINING FACILITIES
       Crushing; grinding; washing; dissolution; crystallization; filtration; sorting;
       sizing; drying; sintering; pelletizing; briquetting; calcining to remove water
       and/or carbon dioxide; roasting, autoclaving, and/or chlorination in preparation
      for leaching (except where the roasting (and/or autoclaving and/or chlorina-
       tion)/leaching sequence produces a final or intermediate product that does not
       undergo further beneficiation or processing); gravity concentration; magnetic
       separation; electrostatic separation; flotation; ion exchange; solvent extraction;
       electro/winning; precipitation; amalgamation; and heap, dump, vat, tank, and in
       situ leaching.
The RCRA definition of beneficiation is used here as a guide only.  Other activities
performed at mining facilities may be considered beneftciation for the purposes of TRI
reporting, and facilities must examine all on-site activities to determine whether the activity
is exempt from reporting. The steps shown in Table 5-1 are broken into discussions of
comminution  and concentration/conditioning. Specific examples from mining operations are
presented to aid the reader and assist in clarifying the concepts. Release estimations will be
unique for each facility depending upon the extraction activities and beneficiation techniques
used.

                            Table 5-1.  Beneficiation Processes
Comminution
Crushing
Grinding
Sorting
Sizing




Concentration/Conditioning Processes
Physical
Gravity Concentration
Magnetic Separation
Electrostatic
Separation
Filtration



Chemical
Leaching
Flotation^
Solvent Extraction
Electrowinning
Precipitation
Amalgamation
Carbon Adsorption
Ion Exchange
Heat
Roasting
Sintering
Autoclaving
Pelletizing
Briquetting
Calcining


The beneficiation process begins with the comminution of ore (e.g., crushing, grinding, sorting
and sizing of extracted ore in preparation for further activities to recover valued minerals).
Following comminution, the ore may be subjected to one or more processes to concentrate or
condition the material to concentrate the target metal or metal compounds.  The following
sections describe these major processes used.  Facilities utilizing unique or innovative processes
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                METAL MINING FACILITIES
involving Section 313 chemicals subject to reporting, which are not described in this manual,
should consider all potential pathways for release of the chemicals.
COMMINUTION

As part of the preparatory process, ores need to be transported from the excavation site to the
comminution site.  Based on the type of terrain, transportation can be by rubber-tired vehicle,
rail, train, or by conveyer. Paniculate emissions can be generated from specific transportation
activities, particularly during loading and unloading.  For metals and metal compounds present in
ores at or above the de minimis levels, these particulate emissions should be reported as fugitive
emissions (Part II,  Section 5.1 of Form R) provided an activity threshold is met or exceeded.
While the motor vehicle exemption applies to activities involving maintaining motor vehicles
operated by the facility, this exemption does not extend to releases from ores being transported in
the vehicles within the facility's boundaries.

Crushing
Crushing reduces the rock size from over 1 meter in diameter to approximately 10-25 mm in
diameter using compression and impact methods. Most crushing operations are dry or use water
sprays to reduce dust emissions. Some mines use water-flush crushers. In most mines, extracted
ores are transported to separate crushing operations, while some mines conduct the crushing
operations directly in the mines, whether underground or in an open pit.
Sorting and Sizing


The size of the crushed ore is regulated by size separators.  Grizzlies are typically used only for
very coarse material, while vibrating and shaker screens are more commonly used overall.  To
facilitate further processing, the crushed ore is mixed with water to form a slurry. Sorting and
sizing can result in the release of particulate matter.  For metals and metal compounds present in
ores at or above the de minimis levels, these particulate emissions should be reported as fugitive
emissions (Part II, Section 5.1 of Form R) provided an activity threshold is met or exceeded.
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                    METAL MINING FACILITIES
Grinding

Grinding is the further size reduction of
crushed materials to allow the required
liberation of the ore metal.  While the
specific method of liberation is
determined by the mineralogy of the ore
deposit and the prevailing economic
conditions, grinding is done through
abrasion and impact in tumbling mills
using steel rods or balls, ceramic pebbles,
or large pieces of the ore itself.  The
tumbling mills are lined with abrasion-
resistant materials to minimize wear of
the mill shell.  Liners and other media
(e.g., steel rods or balls, ceramic pebbles)
are replaced periodically and are mostly
composed of cast or rolled steel and
rubber.  Grinding is a continuous
process, which is either wet or dry. Wet
grinding is most common and is usually
the choice if subsequent processing is
wet.

In most cases, no chemicals that would
trigger TRI reporting are added to this
process.  Since crushing, grinding, and
milling generally does not result in
concentration of any of the Section 313
metal constituents, these processes
should  have no impact on the threshold
determination.  However, these
operations can  result in air emissions
(dusts in particular) that may be
reportable if the initial concentrations of
the Section 313 metal constituents meet
or exceed the specified de minimis levels, provided an activity threshold is met or exceeded.
Air  Emissions  from  Preparation,  Storage,  and
Transport
                  %
Crushing, grinding, and milling operations will result in
the release of ftime or dust. In general, a dry process will
create a dust  (includes all particle sizes) and a wet
process createjs a fume.  Wet processes (i.e., those that
use wet ores or  add water) are less likely to generate
appreciable dust emissions.  Other mining operations,
such as drying of concentrates, storage, and transfer and
loading of mined materials or final product also will
result in generation of fume or dust.
            i
Water sprays, with or without additives, are common for
transport, transfer points, and crushing. Other emissions
from mills may be are controlled through wet scrubbers
or baghouses. Scrubbers and baghouses will appreciably
reduce the fume  and dust emissions to a constant outlet
concentration.! Many mines will have measured data
and/or  estimates  concerning  paniculate  emissions
through the air permitting process.  Table 5-2 presents
paniculate emission factors  for  metal  beneficiation
activities.  (Although much  less commonly used, dry
grinding processes that involve air conveying and air
classification usually use dry  cyclones  for  efficient
product recover)'.  The emissions factors presented in
Table 5-2 are for  emissions  after product  recovery
cyclones.)  Mining  operations can use either measured
data  or the  emission factors in Table 5-2 to  estimate
releases of mefals and metal compounds through  fume
and dust. This can be accomplished by combining either
actual emissions data or emission factors shown in Table
5-2 with knowledge of the concentration of the metal in
the ore to estimate the quantity of parent metal released.

Using this information and the calculations presented
below, facilities  can calculate  reasonable estimates  of
their fugitive and stack air emissions (Part II,  Sections
5.1 and 5.2) as well as estimate the efficiency of any air
control equipment to treat Section 313 chemicals (Part IL
Section 7A of Form R).
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                    Table 5-2.  Emission Factors for Metal Mining Operations
Source
Low-moisture ore"
Primary crushing (SCC 3-03-024-0 1 )"
Secondary crushing (SCC 303-024-02)"
Tertiary crushing (SCC 3-03-024-03)"
Wet grinding
Dry grinding with air conveying and/or air classification (SCC 3-03-024-09)'
Dry grinding without air conveying and/or air classification (SCC 3-03-024-1 0)'
Drying— all minerals except titanium/zirconium sands (SCC 3-03-024-1 ] )f
Drying-titanium/zirconium with cyclones (SCC 3-03-024-1 l)f
Material handling and transfer-all minerals except bauxite (SCC 3-03-024-04 )•
Material handling and transfer-bauxite/alumina (SCC 3-03-024-04)^
High-moisture ore'
Primary crushing (SCC 3-03-024-05)"
Secondary crushing (SCC 3-03-024-06 )d
Tertiary crushing (SCC 3-03-024-07)''
Wet grinding
Dry grinding with air conveying and or air classification (SCC 3-03-024-09)*
Dry grinding without air conveying and/or air classification (SCC 3-03-024-1 0)*
Drying-all minerals except titanium/zirconium sands (SCC 3-03-024-1 1 /
Drying-titanium.'zirconium with cyclones (SCC 3-03-024-1 1 /
Material handling and transfer-all minerals except bauxite (SCC 3-03-024-08)*
Material handling and transfer-bauxite/alumina (SCC 3-03-024-08)*h
Filter able" c
PM1

0.5
1.2
2.7
Neg
28.8
2.4
19.7
0.5
0.12
1.1

0.02
0.05
0.06
Neg
28.8
2.4
19.7
0.5
0.01
ND
RATING

C
D
E

C
D
C
C
C
C

C
D
E

C
D
C
C
C

PM-10

0.05
ND
0.16
Neg
26
0.31
12
ND
0.06
ND

0.01
0.02
0.02
Neg
26
0.31
12
ND
0
ND
RATIN
G

C

E

C
D
C
C
C


C
D
E

C
D
C

C

Source: AP-42. References:  Metallic Mineral Processing Plants-Background Information for Proposed Standards iDrafti.
EPA Contract No. 68-02-3063. TRW, Research Triangle Park, NC, 1981; Telephone communication between E.G. Monnig.
TRW. Environmental Division, and R. Beale. Associated Minerals, Inc., May 17,1982; Written communication from W.R.
Chalker. DuPont. Inc. to S.T. Cufte, U.S. Environmental Protection Agency. Research Triangle Park, NC, December 21.1981;
Written communication from P.M. Fournet, Kaiser Aluminum and Chemical Corporation, to S.T. Cufife. U.S. Environmental
Protection Agency. Research Triangle Park., NC. March 5. 1982.  Factors represent uncontrolled emissions unless otherwise
noted, controlled emission factors are discussed in Section 11.24.3. AH emission factors are in Ib/ton of material processed
unless noted.
1  PM emissions do not equate to quantity' of listed chemical. Such determinations require knowledge of the percent
  concentration of the target chemical in the ore.  SCC = Source Classification Code. Neg = negligible. ND = no data.
b  Filterable PM is that PM collected on or prior to the filter of an EPA Method 5 (or equivalent) sampling train.
'  Defined in Section 11.24.2.
d  Based on weight of material entering primary crusher.
'  Based on weight of material entering grinder; emission factors are the same for both low-moisture and high-moisture ore
  because material is usually dried before entering grinder.
f  Based on weight of material exiting dryer; emission factors are the same for both high-moisture and low-moisture ores, SOK
  emissions are fuel dependent (see Chapter 1), NOX emissions depend on burner design and combustion temperature (see
  Chapter 1),
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 1 Based on weight of material transferred; applies to each loading or unloading operation and conveyor belt transfer point.
 h Bauxite with moisture content as high as 15 to 18% can exhibit the emission characteristics of low- moisture ore; use
  low-moisture ore emission factor for bauxite unless material exhibits obvious sticky, nondusting characteristics.
 "Emission Factor Quality Ratings for Table 5-2 are as follows:           .       -.
 A Excellent. Factor is developed from A- and B-rated source test data taken from many randomly chosen facilities in the
 industry population. The source category population is sufficiently specific to minimize variability.
 B Above average. Factor is developed from A- or B-rated test data from a "reasonable number" of facilities. Although no
 specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with an A rating, the
 source category population is sufficiently specific to minimize variability.
 C Average. Factor is developed from A-, B-, and/or C-rated test data from a reasonable number of facilities. Although no
 specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with the A rating, the •
 source category population is sufficiently specific to minimize variability.
 D Below average. Factor is developed from A-, B-  and/or C-rated test data from a small number of facilities, and there may be
 reason to suspect that these facilities do not represent a random sample of the industry. There also may be evidence of variability
 within the source population.
 E Poor. Factor is developed from C- and D-rated test data, and there may be reason to suspect that the facilities tested do not
 represent a random sample of the industry. There also may be evidence of variability within the source category population.


 Washing


 Washing typically can occur as part of a specific process, such as vat leaching or recovery of
 copper through cementation. Washing and wash water residuals are discussed as part of the
 processes where it may be used. Other washing activities can include washing of muds from ore
 prior to crushing and grinding.  If Section 313 metals or metal compounds are present above the
 de minimis threshold in the ore, washing may result in the release of waters containing the metal
 which should  be reported as releases to water (Part II,  Section 5.3 of Form R).


 CONCENTRATION/CONDITIONING


 Following comminution, the reduced size ore is further processed to concentrate or condition
 the target metals in the ore.  Three primary techniques are used:   (1) physical; (2) chemical;
 and/or (3) heat.  Processes can be used alone  or together in series.  Each of these is described
 below.


 Physical


 Gravity Concentration

  i

The most common method of gravity concentration uses a slurry of ore and water that passes
over a series of riffles to catch the heavier gold and silver particles, but gold pans, sluices,
shaking tables, or jigs also can be used.  For example, in instances where gold or silver occurs
as larger particles in the ore, its  high density relative to other minerals makes gravity a


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practical means of concentration. No Section 313 chemicals are likely to be involved in this
operation as it is strictly a physical beneficiation method. However, if the de minimis
concentration for silver compounds is met or exceeded, any silver contained in discharged
tailings from the gravity process would have to be reported, provided an activity threshold is
met or exceeded.

Magnetic Separation

Magnetic separation employs the magnetic susceptibility of metals to affect separation.  Most
typically, magnetic separation is used to remove highly magnetic minerals, such as iron, but it
may also be used for removal of chromium and other metals or minerals. In magnetic
separation, the ground ores pass over or under a magnetic field, causing the non-magnetic
materials to be removed first, followed at a second point by the magnetic materials.
Operations may be conducted on dry ore or wet slurries.  Magnetic separation is a physical
separation technique. No Section 313 chemicals are likely to be added to this operation.
However, if the de minims concentration for a metal or metal compound is met or exceeded,
any metal or metal  compound contained in discharged tailings from the magnetic separation
process would have to be reported, provided an activity threshold is met or exceeded.

Electrostatic Separation

Electrostatic separation utilizes the differences in electrical conductivity, triboelectic effect, or
polarity between various minerals to affect separation of target metals from other materials.  This
process is used in only limited situations.  In this process, finely ground ore typically is passed
through an ion bombardment field in a rotating grounded drum. Low conductivity materials  stick
to the drum and high conductivity materials are thrown from the drum.  No Section 313
chemicals are likely to be added to this operation as it is strictly a physical beneficiation method.
However, if the de minimis concentration for a metal or metal compound is met  or exceeded, any
metal or metal  compound contained in discharged tailings from the process would have to be
reported, provided an activity threshold is met or exceeded.

Filtration

Water-borne ore fines will be allowed to settle, promoting separation of water and sludge. This
step, typically referred to as thickening, is then followed by filtration. Filtration can be used to
dewater both slurries and tailings. Various types of filters can be used, including drum, plate and
frame,  or belt filter. Filter aids may be used to improve filtration.  Dewatering will result in the
generation of water, which can either be recycled on-site or discharged.  If an activity threshold
is met or exceeded, wastewater discharges would be reported either as discharges to  stream or
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water bodies (Form R, Part II, Section 5.3) or discharges to public owned treatment works (Form
R, Part II, Section 6.1) Non-product filter cake, filtrate, arid spent filter cloths may be generated
and require further management.  These releases may be reportable if, for example, they are
managed in a landfill (Form R, Part II, Section 5.5.1).

Flotation

Flotation is the process where particles of one or more minerals are preferentially wetted by
various agents causing the hydrophobic minerals to adhere to the surfaces of air bubbles. As the
air bubbles rise to the surface, the desired minerals are transported to the surface and are
removed by skimming.  Figure 5-1 provides an overview of the flotation process.  This step
could also generate paniculate and other chemical air emissions.  Froth flotation, is the principal
separation technique for copper, lead, molybdenum, zinc, phosphate, and other metals. Flotation
typically will be conducted using air, water, the prepared ore, flotation agents specially selected
to recover the  desired metal,  and regulating agents (e.g., pH regulators, activators, depressants,
dispersants, or flocculants).

The product of flotation is a metal concentrate that is filtered to remove excess water and
flotation agents prior to transfer or sale to a smelting/refining operation. Beneficiation of
lead/zinc ores is primarily done through the use of flotation of sulfide ores. The flotation  process
is comparable to flotation processes found at other types of metal mines, including copper.

Most flotation or regulating agents (e.g., pine oil, lime) do not contain Section 313 chemicals
above de minimis concentrations, however some flotation agents could.  Examples from  the
copper industry are shown in Table 5-3 and examples from the lead/zinc industry are shown -in
Table 5-4. These lists are not exhaustive and a facility needs to  review its own processes to
identify all reagents used. MSDSs provided by the supplier should identify Section 313
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chemicals present in
the flotation agents
and the concentration
of the chemical. If a activity
threshold is exceeded
for any Section 313
chemical in a
flotation agent (e.g.,
10,000 pounds or
more of the Section
313 chemical are
otherwise used), a
Form R is required
for that chemical and
releases must be
estimated. Residual
flotation agents
would generally be
disposed of in the
tailings
impoundment.
              vvvv
Figure 5-1. Flotation Process
             Table 5-3. Common Copper Beneficiation Flotation Agents
                        Containing Section 313 Chemicals
Flotation Agent
Copper sulfate
Cresylic acid
Nokes reagent
Kerosene
Polyacrylamide
Sodium cyanide
Sodium ferrocyanide
Zinc sulfate
Section 313 Chemical
Copper compounds
Cresols
Arsenic compounds
Cyclohexane, naphthalene, benzene, xylene, and ethyl
benzene (all typically below de minimis)
Acrylamide (monomer)
Cyanide compounds
Cyanide compounds
7inc cnmnounds
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              Table 5-4.  Common Lead/Zinc Benefication Flotation Agents
                           Containing Section 313 Chemicals
Flotation Agent
Copper Sulfate
Cresylic Acid
Sodium Ferrocyanide
Sodium dichromate
Zinc Sulfate
Section 313 Chemical
Copper Compound
Cresols
Cyanide Comp<
>unds
Chromium compounds
Zinc Compounds
After the target minerals are separated, tailings (wastewater in a slurry) may be sent to a
thickener.  The thickener process may also use chemicals to accelerate settling and
agglomeration.  Some of these chemicals are disposed of either along with the tails or
separately. Water from the thickeners is often recycled to the  mill.
The tailings are generally sent to a tailings impoundment, If the surface impoundment is
intended for storage or holding without discharge, the surface impoundment is the final
disposal method, and quantities of Section 313 chemicals in the tailings would be reported in
Part II, Section 5.5.3 of Form R.  Quantities of the Section 313 chemical released to surface
impoundments that are used merely as part of a wastewateit treatment process generally are not
reported as disposal in a surface impoundment.  However, in this case, any seepage of the
Section 313 chemical from the impoundment that occurred during the reporting year would be
reported as a release to land on-site/other disposal (Part II, Section 5.5.4 of Form R). Also, if the
impoundment accumulates sludges containing the Section 313 chemical, you must include an
estimate for Section 5.5.3 unless the sludges are removed and otherwise disposed (in which case
they should be reported under the appropriate section of the Form R for the year in which they
were disposed, provided an activity threshold has been exceeded). In either case, Section 313
chemicals contained in discharges from surface impoundments to surface water would be
reported as a discharge to a receiving stream or water body (Part II, Section 5.3 of Form R).
Even those facilities subject to "zero discharge" requirements of 40 CFR Part 440, Subpart J
may have authorized discharges  due to the stormwater exemption, and these would be
reportable as well.
Facilities must report on the final disposition of chemicals released during the reporting year.  If,
for example, a facility released 1,000 pounds of a Section 313 chemical to land in 1998, of which
500 pounds migrated into the air or was discharged to water during 1998, the facility would
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report 500 pounds released to land and 500 pounds released to air or water for 1998. The facility
does not, however, report amounts that are emitted or migrate from one media to another in
subsequent years. For example, if a facility disposes 1,000 pounds of a Section 313 chemical to
land in 1998, and 500 pounds of this is discharged to water in 1999, the facility reports 1,000
pounds released to land in  1998, and does not report the 500 pounds discharged to water in 1999
on the Form R.

Information on the facility's water balance and composition of its tailings water, solids, and
discharge can be used to calculate estimates of surface impoundment releases and waste
management activities.

Chemical Processes

Leaching


Leaching is a chemical technology that allows for recovery of metals from the ore. This section
discusses five leaching processing used in the metal mining industry. Heap or tank/vat leaching is
the predominant method of beneficiating  gold and silver where dilute solutions of sodium or
potassium cyanide are used as leaching agents to extract these precious metals from ore.  In
copper mining, dilute sulfuric acid is used as the leaching agent in dump leaching processes.
Also copper is leached in situ by the introduction of lixiviants2 directly into the ore deposit via
injection wells, and metal-laden solution is recovered via production wells. Finally, bioleaching
uses microbes or bacteria to leach metals from low-grade sulfide ores.

Heap Leaching


In heap leaching, the leaching solution is  applied directly to crushed or run-of-mine ore on open
heaps as shown in Figure 5-2.  Such ore may be crushed, if necessary, but is not ground.  A heap
is built on an impervious pad, usually with a synthetic liner, to control and collect the leach
solution.  A typical heap leach cycle may last three months. Although the cyanide may be
applied at concentrations below 0.1  percent, solid  cyanide salts usually are purchased in bulk,
and mixed with water to meet the desired concentration. In this case, there would be no de
minimis exemption for cyanide compounds.
       2Lixiviants aid in the separation of soluble and insoluble constituents by percolation

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Following the heap leaching, the ore is rinsed with mine water or mill wastewater, with or
without chlorine or other chemicals, to remove most of the remaining cyanide solutions and gold-
and silver-cyanide complex. Following heap rinsing, the spent ore becomes waste.  The spent ore
is either left as is or, in the case of "on-ofT heap leach padb, is disposed in dumps similar to
those used for waste rock. The spent ore will contain small quantities of waste water from
rinsing the ore, residual cyanide, and metal compounds including metal-cyanide complexes For
non-exempt Section 313 chemicals (i.e., at or above de miqimis levels) for which an activity
threshold has been exceeded, quantities remaining in the heap would be reported as released to
land on site (Part II, Section 5.5 of Form R) when the heap is closed. Sometimes heap leaching
is performed in combination with zinc precipitation (discussed later) as shown in Figure 5-3.
                                                    i
Tank and Vat Leaching

The crushed  and ground ore slurry can be further processed by tank or vat leaching.  For the
purposes of this document, no difference exists in the processes used in a tank- or vat-based
operation. Tank or vat leaching is typically a batch process, although continuous leaching
processes can be used  For copper, vat leaching produces a pregnant leach solution (PLS) of
sufficient copper concentration for electrowinning (30 to 50 kg/m3 of copper). If the iron content
of the solution is high,  the PLS may be sent for solvent extraction prior to electrowinning. Gold
mining also uses vat leaching to recover gold.
                            Figure 5-2.  Heap Leaching
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Agitated vat leaching refers to the relatively rapid leaching of fine particles of ore or roaster
calcines with a strong sulfuric acid solution in agitated tanks.  The tanks are stirred or agitated
by mechanical devices or piped steam discharge.  Compressed air is used in a similar method
of agitation in a pressurized tank operation.  A pressurized operation is used in several
different types of autoclaves.

Some facilities at one time used chlorine to pre-treat the ore. This practice may no longer be in
use.  If it is practiced, this activity would be considered otherwise use and reporting would be
required if 10,000 pounds or more are used in the reporting year. This process would be
expected to result in fugitive air emissions of chlorine (Part II, Section 5.1 of Form R).

As is shown in Figure 5-4, in the gold mining industry, fine ore is mixed with lime and cyanide
solution before it is sent
to leach tanks. As metals
are removed from ore in
vat leach circuits
(recycle loops), a slurry

          Fugitive
          Emissions



                         Figure 5-4. Vat Leaching

Figure 5-3. Heap Leaching with Zinc Precipitation
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 of spent ore tailings is removed. Tailings slurry, typically discharged to unlined or lined earthen
 dam impoundments, may contain residual cyanide, metal-cyanide complexes, and dissolved
 metals.  The residual metals content of the tailings as welt as residual cyanide levels must be
 reported if threshold levels have previously been met or exceeded*.  Reporting amounts placed in
 surface impoundments is discussed previously in this section, under the heading "Flotation".
 The quantity and composition of the tailings is monitored to ensure the efficiency of the leaching
 process.  These data can be used to estimate the quantity of reportable Section 313  chemicals
 discharged to land on site.  The metal-cyanide solution is sent to recovery, typically by activated
 carbon, as described in the following section on recovery techniques.

 After the tailings have settled, water can be recovered for reuse or treatment followed by
 discharge. Prior to wastewater discharge, cyanide may require destructive treatment. This
 treatment would be reportable as on-site treatment (Part II,, Section 8.6 of Form R). This
 treatment can use a number of chemicals including, chlorine and ozone, which are Section 313
 chemicals If chemicals are otherwise used above the 10,000-pound activity threshold, then a
 Form R would be required for that chemical. In some cases, operators may employ cyanide
 destruction technologies for detoxification of tailings slurry prior to discharge to disposal
 impoundments, thus, reported releases may be minimal or zero.  Monitoring data to support
 permit compliance should be available to determine if any releases to water (Part II, Section 5.3
 of Form R) or discharges to surface impoundment (Part II,  Section 5.5.3 of Form R) occurred and
 to estimate the quantity of cyanide compounds treated  (Part II, Section 8.6 of Form R).

 Dump Leaching

 In the dump leaching process, the crushed ore is treated by  a leaching agent, typically dilute
 sulfuric acid.  The sulfuric acid is dripped, sprinkled, or sprayed onto the dump of ore. This
 spraying could result in the manufacture of sulfuric acid in the aerosol form. Note that the de
minitnis exemption does not apply to the manufacture of Sebtion 313 chemicals. If greater than
 25,000 pounds of sulfuric acid in the aerosol form are manufactured, then the manufacturing
threshold has been exceed and a Form R report is required.  Releases of sulfuric acid in the
 aerosol form must be estimated and reported as well.

This leaching process results in the production of pregnant Ifeach solution (PLS), a dilute solution
of copper sulfate, which  may also contain other metals. While the goal is to collect all PLS for
copper recovery, some of the PLS may escape the collection system (e.g., through seepage)
Provided an activity threshold is met or exceeded, the copper (or other Section 313  chemicals) in
the lost PLS would be reported as released to land on-site: other disposal (Part II, Section 5.5.4 of
Form R). The facility water balance and the PLS characterization should provide this
information.  Releases to  water could also occur during large storm events. Some of the PLS may
also be lost to a nearby water body through drainage or storm water. Monitoring required by

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                 METAL MINING FACILITIES
NPDES permits may provide useful data to estimate these releases. The copper in this PLS
would be reported as discharged to a receiving stream or water body (Part II, Section 5.3 of Form
R). Once the leaching process is completed, the dump would cease to be a process unit and the
remaining copper (and/or other Section 313 chemicals) in the dump would be reported as being
released to land on site (Part II, Section 5.5 of Form R).

Barren solution (raffinate) is an acidic aqueous solution that has been stripped of copper but still
has some carryover of the organic extraction/diluent used in the solvent extraction operation.
The raffinate generated at hydrometallurgical plants is typically stored in ponds and recycled to
the dump leaching operation.

In Situ Leaching

Less commonly used, in situ leaching involves the removal of target metals directly from deep-
lying deposits of undisturbed ore or from porous or permeable deposits in disturbed ore through
in-ground leaching.  Section 313 chemicals added to deposits for the purposes ofin-situ leaching
should be reported as a releases to land on-site/other disposal (Part II, Section 5.5.4 of Form R)
provided an activity threshold is met or exceeded. Facilities are responsible only for reporting  of
the final disposition of chemicals released during the reporting year. If, for example, 1,000
pounds of a Section 313 chemicals were used during the year for in-situ leaching in 1998, this
amount need not be reported again in 1999.

Bioleaching

Microbial (or bacterial) leaching is appropriate for low-grade sulfide ores at dump, heap leach,
underground, and possibly in situ leaching operations. The organisms use  atmospheric carbon
dioxide (CO2) for cell growth and oxidize ferrous iron and  sulfides to obtain energy for growth.
Sulfuric acid is a product of the organism's metabolism. For example, for chalcopyrite (a copper
sulfide), the bacteria first oxidizes the ferrous iron to ferric iron. Ferric iron then chemically
oxidizes the sulfide. This bacteria can also assist in the oxidation of sulfur  to sulfuric acid.
Sufficient dissolved oxygen must be available during these oxidation reactions. The other main
growth requirements are ammonia, nitrogen, phosphate, and a suitable temperature
(approximately 30°C) and acidity (approximate pH of 2.0). Some metals,  such as mercury,
silver, and (possibly) molybdenum, can retard or stop leaching by inhibiting or killing the
bacteria. The chemical and biochemical reactions involved in microbial  leaching of copper
ore/minerals are complex and  facilities using this technology are best equipped to determine the
chemical conversions taking place.
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The de minimis exemption does not apply to the manufacture of Section 313 chemicals. If greater
than 25,000 pounds of sulfuric acid in the aerosol form are) manufactured, then the manufacturing
threshold has been exceeded and a Form R report is required. Releases of sulfuric acid in the
aerosol form must be estimated.

Solvent Extraction

Solvent extraction typically is used to extract and concentrate valued minerals from the pregnant
leach solutions.  In the copper industry, the pregnant leaching solution from dump leaching is
pumped to a solvent extraction plant, where it is mixed with an organic solvent in a mixer. The
organic solvent consists of a chelating agent such as alkylated 8-hydroxyquinoline (not a Section
313 chemical) in an organic diluent such as kerosene (containing many petroleum hydrocarbons,
including Section 313 chemicals such as benzene, xylenes, ethylbenzene).  In the mixer, the PLS
is contacted with the organic solvent, forming a copper-organic complex.  The PLS after it has
been stripped of the copper is referred to as barren leachate solution or raffinate and is
recirculated back to the leaching units. Sludge can accumulate in the solvent
extraction/electrowinning system and is land disposed periodically. Copper (or other Section 313
chemicals)  in the sludge would be reported as being released to land on site (Part II, Section 5.5
of Form R) provided an activity threshold is met or exceeded.

In the second stage, the loaded organic  solution is stripped of the copper with concentrated
sulfuric acid solution to produce a solution of copper sulfate for electrowinning. Then the
mixture is allowed to separate in settling tanks, where the barren organic solution can  be recycled
to the solvent extraction stage. The copper-enriched, strong electrolyte flows from the stripping
stages to the strong-electrolyte tanks, where it is pumped tp the electrolyte filters for removal of
the entrained organics or solids. The clarified, strong electrolyte flows to electrolyte circulation
tanks, where it becomes electrolyte for the electrowinning tankhouse. Because the acid
electrolyte  is heated, sulfuric acid in the aerosol form may be manufactured in this process as
well.  The de minimis exemption does not apply to the manufacture of Section 313 chemicals. If
greater than 25,000 pounds of sulfuric acid in the aerosol form are manufactured, then the
manufacturing threshold has been exceeded and a Form R report is required.  Releases of sulfuric
acid in the aerosol form must be estimated.              !
                                                     i

The solvent extraction process generates a "sludge,"  or, as it is known in the copper industry,
"crud" or "gunk."  This sludge consists of a solids and a stabilized emulsion of organic and
aqueous solutions from solvent extraction. It is generated at the organic/aqueous interface in the
settlers and is periodically removed from the system, and centrifuged or otherwise treated to
remove the organics, which are returned to the solvent extraction circuit for reuse. The
composition of the sludge may be monitored or a typical concentration may be available from a
waste profile.  This composition information along with the quantity of the sludge disposed on
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                METAL MINING FACILITIES
site can be used to estimate the quantity of the reportable Section 313 chemicals (e.g., metals and
cyanide compounds) present in the sludge. These estimates would be reported as disposal to land
on site (Part II, Section 5.5 of Form R) provided an activity threshold is met or exceeded.

Electrowinning

Electrowinning is used to remove metals from electrolyte solutions.  Electric current is passed
through a tank and the target metal adheres to the anode or the cathode, enabling recovery.
In the copper industry, electrowinning uses anodes made of lead (a Section 313 chemical) or
stainless steel (which typically contains chromium and nickel, both Section 313 chemicals, above
fife minimis concentrations). Use of these anodes constitutes otherwise use. If more than 0.5
pounds of a Section 313 chemical from the anodes is released, and not recycled, over the course
of the reporting year, the article exemption could not apply to the anodes and the quantity of
Section 313 chemicals in the anodes added to the process during the reporting year would need to
be counted towards the threshold determination.

In the copper industry, the electrochemical reaction at the lead-based anodes produces oxygen
gas and sulfuric acid by electrolysis. Copper often is plated on thin-copper starting sheets. The
cathode copper is then shipped to a mill for fabrication. The spent acid is generally recycled and
pumped back to the leaching operation.  A small amount of wastewater may be discharged as a
bleed stream to surface water (or the bleed stream may be reused elsewhere in the facility).  If the
bleed stream is discharged, the  copper (and possibly other reportable Section 313 chemicals) in
the bleed stream would be reported as released to water (Part II, Section 5.3 of Form R) provided
an activity threshold is met or exceeded.

Electrowinning also is used in the gold/silver industry.  In this case,  the process starts with the
placement of concentrated solution in tanks that commonly contain  steel wool to act as a cathode.
A current is passed through the solution causing the gold/silver to exchange with iron.
Gold/silver on the cathode and  any sludge in the tank is fluxed with  various fluxing agents and
subsequently melted for casting as bullion. If the quantity of a Section 313 chemical used in this
process meets or exceeds the 10,000-pound otherwise use threshold, a Form R report for that
chemical would be required.

Sludge can accumulate in electrowinning tanks. Any sludge generated from this process that
contains reportable Section 313 chemicals for which an activity threshold is met or exceeded
must be included in the Form R. The sludge is typically shipped  off site for recovery of other
metals from the sludge.  Metals in this sludge may be reportable as off-site waste transfers for
recycling (Part II, Sections 6.2  and 8.5 of Form R) if thresholds for  these metals have been
exceeded.
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 Spent electrolyte is generated during electrowinning activities.  Historically, electrolyte is sent
 through a stripping step and is subsequently discharged to a tailings pond. Any reportable
 Section 313 chemicals in the spent electrolyte disposed of in the tailings pond would need to be
 reported as a release to land on site (Part II, Section 5.5 of Form R) provided an activity threshold
 is met or exceeded.

 Over time, electrolyte in the electrowinning cells becomes laden with soluble impurities and
 copper. When this occurs, the solution is removed and replaced with pure electrolyte (to
 maintain the efficiency of the solution and prevent coprecipitation of the impurities at the
 cathode). Purification of the spent electrolyte is done by electrowinning in liberator cells.
 Liberator cells are similar to normal electrolytic cells, but they have lead anodes in place of
 copper anodes. The electrolyte is cascaded through the liberator cells, and an electric current is
 applied.  For example, during copper electrowinning, copper in the solution is deposited on
 copper starting sheets. As the copper in the solution is depleted, the quality of the copper deposit
 is degraded.  Liberator cathodes containing impurities (such as antimony) are returned to  the
 smelter to be melted and cast into anodes.  Purified  electrolyte  is recycled to the electrolytic cells
 Any bleed electrolyte usually is neutralized with mill tailings and disposed of in a tailings pond
 (U.S. EPA 1994).  Any reportable Section 313  chemicals in the bleed electrolyte disposed of in
 the tailings pond would need to be reported as a release to land on site (Part II, Section 5 5 of
 Form R) provided an activity threshold is met or exceeded.

 Zinc Precipitation

 Zinc precipitation is well suited to gold ores containing large amounts of silver. The pregnant
 solution is filtered, and dissolved oxygen is removed. Metallic  zinc dust is added to exchange
 with the gold of the gold-cyanide complex. In some cases, cyanide and lead nitrate or lead
 acetate is added to increase the reaction rate. Gold  precipitates and  is filtered from the solution
 for smelting into dore (unrefined gold). Zinc dust, zinc compounds,  lead compounds, and nitrate
 compounds are listed Section 313 chemicals and if the use pf any of these chemicals exceeds the
 10,000 pound otherwise use threshold, then a Form R is required.

 Amalgamation

 Amalgamation is the technique of wetting metallic gold with mercury to form an alloy.  While
 this process is not used in large-scale operations in the U.S., use of 10,000 pounds or more of
 mercury and/or mercury compounds in a calendar year would require Form R reporting.

Activated Carbon Adsorption

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 Activated carbon adsorption is used to remove the desired metals from pregnant solutions, most
 commonly in gold recovery. The metal is adsorbed onto the carbon and, after the carbon is
 loaded with metals, the metal is desorbed  In gold beneficiation, the gold is removed with a
 solution of cyanide and sodium hydroxide to form a concentrated pregnant solution.  Figure 5-5
 presents an overview of the activated carbon adsorption process. Activated carbon can be
 regenerated, and this activity can occur either on-site or off-site using a variety of different
 means.  If the carbon is sent off-site for regeneration and contains any amount of cyanide (or
 other reportable Section 313 chemical), this would be reported as an off-site transfer in Part II,
 Section 6 of Form R and the appropriate part of Part II, Section 8 of Form R provided an activity
 threshold is met or exceeded. For on-site regeneration, the common method employed is an acid
 rinse using a hydrochloric and/or nitric acid solution. Nitric acid is a Section 313 chemical and
 the quantity of nitric acid used would be applied to the otherwise use threshold.  This process is
 not likely to generate hydrochloric acid in the aerosol form, but if it did, the quantity  of
 hydrochloric acid aerosol would be applied to the "manufacture" and  "otherwise use" thresholds.
 The resulting spent acid wash solutions are neutralized with high-pH tailings slurry, dilute
 sodium hydroxide solution, or water. If the hydrochloric or nitric acids are used at or above the
 10,000-pound otherwise use threshold, a Form R report is required and the quantity neutralized is
 reportable as on-site treatment (Part II, Section 8.6 of Form R). Following  neutralization, the
 wash water, which may contain silver or other Section 313 chemicals, is disposed of in the
 tailings impoundment. This disposal of silver or other reportable Section 313 chemical would be
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                                     METAL MINING FACILITIES
         *Sodium C
               \
           Slud
yanideEuaitive
    4 Ermssio
                       f
Figure 5-5. Activated Carbon Adsorption
reported as a release to land on-site/surface impoundment (Part II, Section 5.5.3) provided an
activity threshold is met or exceeded.                   I
                                                    i
If-the mine is using nitric acid to regenerate their carbon beds, a spent acid wash solution
containing nitric acid will be generated. Quantities of acid neutralized to a pH of 6 or above are
reported as zero, however, the facility could have pH exceedences, which must be reported if the
otherwise use threshold is exceeded.

After the carbon is regenerated, it is returned to the recovery system. The use and regeneration
process gradually decreases the performance of the carbon^  Approximately 10 percent of the
carbon is lost during each process necessitating the addition of fresh carbon.  The spent carbon
may contain cyanide, precious metals, or other Section 313 chemicals.  Generally, spent carbon is
sold as a product to facilities that then recover the precious metals. When sold as a product,
spent carbon shipped off site is not reportable as a release. If the spent  carbon is transferred
offsite for disposal, however, the  quantities of any Section 313 chemicals would be reported in
Part II, Section 6.2, of the Form R provided an activity threshold is met or exceeded.
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Ion Exchange

Metals and metal compounds can be recovered from water-ore slurries using either anionic or
cationic resins in a packed column to effect recovery. Loaded resins are separated from the
remaining water-residue slurry, and the target metals are recovered from the resins. Wastewater
discharges would be reported either as discharges to stream or water bodies (Form R, Part II,
Section 5.3) or discharges to public owned treatment works (Form R, Part II, Section 6.1)
provided an activity threshold is met or exceeded. Non-recoverable resins may be generated and
require further management. These releases may be reportable if, for example, they are managed
in a landfill (For R, Part II, Section 5.5.1) provided an activity threshold is met or exceeded.
Heat Processes

Calcining

Calcining is a heat process used to remove excess water and carbon dioxide from ore slurries.  It
can also be used to oxidize aluminum hydroxide (AJ(OH)3) precipitate to alumina or to dry
sulfide ore slurries prior to roasting. (Kirk Othmer, 4th Ed., Vol.  16, 1995.) Ore is calcined in a
rotary kiln. Potential releases from calcining include calcines offgases, which contain airborne
paniculate emissions (Form R, Part II, Section 5.2); and calcines residues, which are usually
collected and recycled back into the calcinator (Form R, Part II, Section 1C).

Roasting

Roasting can be used as a preparative step to reduce metal sulfides to metal oxides or sulfates,
thus improving the opportunity for recovery of the target metal. Roasting involves heating
sulfide ores in air to convert them to oxide ores.  In effect, roasting oxidizes the sulfur in the ore
generating sulfur dioxide that can be captured and converted into sulfuric acid. Roasting
temperatures are dependent on the mineralogy of the ore, but range as high as several hundred
degrees Celsius.  Sulfur dioxide (SO2) and sulfur trioxide (S03) can be formed from this reaction.
Complete roasting may remove all sulfides, while incomplete roasting will  result in the
conversion of excess sulfur.  Finally, water-soluble sulfates can be produced through a sulfated
roast.  Sulfuric acid can be recovered from the produced sulfur dioxide and sulfur trioxide. This
recovery could result in the manufacture of sulfuric acid in the aerosol form.  If the facility uses
this recovered sulfuric acid on-site, it must apply the amount used to the otherwise use threshold.
As discussed earlier, the de minimis exemption does not apply to the manufacture of Section 313
chemicals. If greater than 25,000 pounds of sulfuric acid in the aerosol form are manufactured,
April 15, 1998
5-21

-------
TRI FORM R GUIDANCE DOCUMENT
                 METAL MINING FACILITIES
then the manufacturing threshold has been exceeded and a Form R report is required.  Releases
of sulfuric acid in the aerosol form must be estimated.
                                                          *
Sintering

Concentrates of certain metals (e.g., lead, zinc) may also be sintered after metal recovery
operations and before smelting and refining.  Sintering involves the partial fusion of ore concen-
trates into an agglomerated material suitable for processing operations.  The sinter material is
typically a crushed and graded structure of porous cellular solids.

Autoclaving

Autoclaving (pressure oxidation) is a relatively new technique that operates at lower
temperatures than roasting. Autoclaving uses pressurized steam to start the reaction and oxygen
to oxidize sulfur-bearing minerals.  Heat released from the oxidation of sulfur sustains the
reaction.

Pelletizing and Briquetting

Similar to sintering, pelletizing is the agglomeration of ores after comminution through balling in
a disk, drum, or cone and heating to a temperature of approximately 1300°C and briquetting is
agglomeration through formation in to briquettes. During the heating, excess water is vaporized
Pelletizing is found almost exclusively in the recovery of iron for blast furnaces and steelmaking
furnaces. Facilities that conduct iron mining (SIC Code 10) 1) are not subject to the reporting
requirements of EPCRA Section 313.
April 15, 1998
5-22

-------
TR1 FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
                           APPENDIX A
          ALPHABETICAL LISTING OF SECTION 313 CHEMICALS
April 15, 1998
A-l

-------
TRJ FORM R GUIDANCE DOCUMENT
METAL MINING FACILITIES
CAS No.


4080-31-3
354-11-0
630-20-6
71-55-6
354-14-3
79-34-5
79-00-5
13474-88-9
812-04-4
111512-56-2
1717-00-6
57-14-7
5124-30-1
96-18-4
120-82-1
95-63-6
106-88-7
96-12-8
106-93-4
422-44-6
354-23-4
431-86-7
1649-08-7
95-50-1
107-06-2
540-59-0
78-87-5
122-66-7
95-54-5
615-28-1
38661-72-2
106-99-0
' 507-55-1
136013-79-1
541-73-1
542-75-6
123-61-5
108-45-2
10347-54-3
2556-36-7
764-41-0
106-46-7
123-91-1
104-49-4
624-18-0
3173-72-6
82-28-0
35691-65-7
354-25-6
75-68-3
5522-43-0
16938-22-0
April 15, 1998


CHEMICAL NAME ,


I -(3-ChloroaJlyl)-3,5,7-triaza-l -azoniaadamanlanc chloride
,1,1 ,2-Tetrachloro-2-fluoroethane (HCFC-1 2 1 a)
,1,1,2-tetrachloroethane :
,1,1-Trichloroethane (Methyl chloroform)
,l,2,2-Tetrachloro-l-fluoroethane(HCFC-121)
,1,2,2-Tetrachloroethane
,1,2-Trichloroethane
1 ,1-Dichloro-l ,2,2,3,3-pentafluoropropane (HCFC-225cc)
1 ,1 -Dichloro-1 ,2,2-trifluoroethane (HCFC-1 23b)
l,l-Dichlorc-l,2,3,3,3-pentafluoropropanc(HCFC-225eb)
1,1 -Dichloro-1 -lluoroethane (HCFC-1 4 1 b)
1,1 -Dimethyl hydrazine
1 , 1 -Methylene bis(4-isocyanatocyclohexanc)
1 ,2,3-Trichloropropane
1 ,2,4-Trichlorobenzene
1 ,2,4-Trimethylbenzene
1 ,2-Butylene oxide
1 J2-Dibromo-3-chloropropane (DBCP)
1,2-Dibromoethane (Ethylene dibromide)
1 2-Dichloro-l ,1 ,2,3,3-pentafluoropropane (HCFC-225bb)
1 ,2-Dichloro- 1 .1 2-trifluoroethane (HCFC- 1 23»)
1.2-Dichloro-l .1 ,3.3.3-pentafluoropropane (HCFC-225da)
1 JJ-Dichloro- 1 .1 -difluoroethane (HCFC-1 32b)
1 .2-Dichlorobenzene
1 ,2-Dichloroethane (Ethylene dichlonde)
1 ,2-Dichloroethylene
1 ,2-Dichloropropane
1 .2-Diphenylhydrazine (Hydrazobenzene)
1 .2-Phenylenediamine
1 ,2-Phenylencdiamine dihydrochloride ••
] ,3-Bis(methylisocyanate)cyclohexane |
1 .3-Butadiene
1 .3-Dichloro-l ,1 ,2.2,3-pentafluoropropane (HCFC-225cb)
-3-Dichloro-l . 1 .2.3.3-pentafluoropropane (HCFC-225ca)
.3 -Dichlorobcnzene
.3 -Dieh loropropy lene
.3-Phenylene diisocyanate
.3 -Phenylenediam ine
l,4-Bis(mcthylisocyanate)cycIohexane
1 ,4-Cyclohexane diisocyanate
1 ,4-Dichloro-2-butene
1 ,4-Dichlorobenzene s'
1 .4-Dioxane
1 .4-Phenylene diisocyanate
1 .4-Phenylenediamine dihydrochloride
1 .5-Naphthalene diisocyanale
1 -Amino-2-methylanthraquinonc
1 -Bromo- 1 -(bromomethyl> 1 .3-propanedicarbonitrile
1-Chloro-l ,lJ>J2-tetrafluoroethane (HCFC-124a)
1-Chloro-l .1 -difluoroethane (HCFC-142b)
1-Nitropyrene
2 2 .4-T rimethy 1 hexamethylene d i isocyanate
A-2
j
i
DC Appx RCRA
Minimis Vffl UTS
Cone
% .0
.0
.0 XX
.0 XX
.0
1.0 X X
1.0 X X
1.0
1.0
1.0
1.0
0.1 X
1.0
0.1 X X
1.0 X X
1.0
1.0
0.1 X X
0.1 X X
1.0
1.0
1.0
1.0
1.0 X X
0.1 X X
1.0
1.0 X X
0.1 X X
1.0 X
1.0
1.0
0.1
1.0
1.0
1.0 X X
O.I X

1.0
1.0
1.0
1.0 X
0.1 X X
0.1 X X

1.0
1.0
0.1
l.Q
1.0
1.0
1.0
1.0



RCRA
Code



U208
U226

U209
U227




U098





U066
U067




U070
U077

U083
U109






U071
U084




U074
U072
U108













-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
128903-21-9
306-83-2
2655-15^1
422^48-0
78-88-6
15646-96-5
95-95-*
88-06-2
94-75-7
53404-37-8
1928-43-4
1929-73-3
94-80-4
2971-38-2
94-11-1
1320-18-9
2702-72-9
94-82-6
615-05-*
39156^1-7
95-80-7
120-83-2
75790-87-3
105-67-9
51-28-5
121-14-2
541-53-7
120-36-5
576-26- i
606-20-2
87-62-7
53-96-3
117-79-3
52-51-7
2837-89-0
75-88-7
" 532-27^
11 0-80-5
149-30-*
109-86-4
75-86-5
109-06-8
88-75-5
79-46-9
90^13-7
422-56-0
91-94-1
612-83-9
64969-34-2
! 19-90-4
91-93-0
20325-40-0

111984-09-9

91-97-4
2,2-Dichloro-l ,1,1 ,3,3-pentafluoropropane (HCFC-225aa)
2,2-Dichloro-l,l,l-trifluoroethane(HCFC-123)
2,3,5-Triraethylphenyl methylcarbamate
2.3-Dichloro- i ,1 ,1 ,2,3-pentafluoropropane (HCFC-225ba)
2 ,3-Dichloropropene
2,4,4-Trimethylhexamethylenediisocyanate
2 .4 ,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-D [Acetic acid, (2,4-dichloro-phenoxy)-]
2,4-D 2-ethyl-4-methylpentyl ester
2,4-D 2-ethylhexyl ester
2,4-D butoxyethyl ester
2,4-D butyl ester
2,4-D chlorocrotyl ester
2,4-D isopropyl ester
2,4-D propylene glycol butyl ether ester
2,4-D sodium salt
2,4-DB
2 .4 -Diatn inoan isole
2.4-Diammoanisole sulfate
2.4-Diaminotoluene
2 ,4-Dichloropheno!
2.4'-Diisocyanatodiphenyl sulfide
2.4-Dimethylphenol
2,4-Dinitrophcnol
2.4-Dinitrotoluene
2.4-Dithiobiuret
2.4-DP
2.6-Dimethylphenol
2.6-Dinitrotoluene
2.6-Xylidine
2-Acetylaminotluorene
2-Aminoanthraquinone
2-Bromo-2-nitropropane-l .3-diol (Bronopol)
2-Chloro-l,l,l .2-tetraJluoroethane (HCFC-124)
2-Chloro-l.l,1-trifluoroethane(HCFC-133a)
2-Chloroacetophenone
2-Ethoxyethanol
2-Mercaptobenzothiazole (MET)
2-Methoxyethanol
2-Methyllactonitrile
2-Methylpyridine
2-Nitrophenol
2-Nitropropane
2-Phenylphenol
3,3-Dichloro- 1 . 1 :1 2 J-pentalluoropropane (HCFC-225ca)
3.3'-Dichlorobenzidine
3.3'-Dichlorobenzidinedihydrochloride
3.3'-Dichlorobenzidine sulfate
3 .3'-Dimethoxybenzidine
3 .3'-Dimethoxybenzidine-4 .4'-diisocyanate
3,3'-Dimethoxybenzidine dihydrochloride (o-Dianisidine
dihydroehloride)
3.3'-Dimethoxybenzidine hydrochloride (o-Dianisidine
hydrochloride)
3.3'-Dimethyl-4.4'-diphenylenediisocyanate
1.0
1.0
1.0
1.0
Yo
1.0
1.0 X X
0.1 X X
1.0 X X
0.
0.
0.
0.
0.
0.
0.
0.
1.0
0.
0.
o. x
.0 XX
.0
.0 XX
.0 xx
.0 XX
1.0 X
O.I
1.0
i.o x x
0.1
0.1 X X
0.1
1.0
0.1
1.0
1.0
1.0 X
1.0
1.0
1.0 X
1.0 X
1.0 X
0.1 X
1.0
1.0
0.1 X
0.1
0.1
0.1 X

0.1

0.1










U240












U081

U101
P048
U105
P049


U106

U005





U359


P069
U191

UI7]


U073


U091






April 15, 1998
A-3

-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
119-93-7
612-82-8

41766-75-0

460-35-5
563-47-3
542-76-7
55406-53-6
101-80-4
4128-73-8
80-05-7
101-14-4
101-61-1
101-77-9
139-65-1
534-52-1
60-09-3
92-67-1
60-11-7
75790-84-0
92-93-3
100-02-7
3697-24-3
99-59-2
99-55-8
57-97-6
194-59-2
71751-41-2
30560-19-1

75-07-0
60-35-5
75-05-8
98-86-2
62476-59-9

107-02-8
79-06-1
79-10-7
107-13-1
15972-60-8
116-06-3
309-00-2


107-18-6
107-05-1
107-11-9
319-84-6
134-32-7
7429-90-5
1344-28-1
20859-73-8
834-12-8

3,3'-D]methylbenzidine (o-Tolidine)
3,3'-Dimethylbcnzidine dihydrochlonde {o-Tolidine
dihydrochioride)
3,3'-Dimethylbenzidine dihydrofluoride (o-Tolidine
dihydrofluoridc)
3-Chloro-l,l,l-trifluoropropane (HCFC-253fb)
3-Chloro-2-mcthyl-l-propene
3-Chloropropionitrilc
3-Iodo-2-propynyl butylcarbamate
4,4'-Diaminodiphenyl ether
4.4'-Diisocyanatodiphenyl ether ,
4,4'-Isopropylidenediphenol
4,4'-Methylenebis(2-chloroaniline)(MBOCA)
4t4'-Methylenebis(N,N-dirnethyl)benzenainine
4,4'-Methylenedianiline
4,4'-Thiodianiline
4.6-Dinitro-o-cresol
4-Aminoazobenzene
4-Aminobiphenyl
4-Dimethylaminoazobenzene
4-Methyldiphcnylmcthane-3,4-diisocyanate
4-Nitrobiphenyl
4-Nitrophenol
5-Methylchrysene
5-Nitro-o-anisidine
5-Nitro-o-toluidine
7,1 2-Dimethylbenz(a)anthracene
7H-Dibenzo(c,g)carbazole
Abamectin [Avermectin Bl]
Acephate (Acetylphosphoramidothioic acid O,S-dimethyl
ester)
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone :
Acifluorfen. sodium salt [5-(2-Chloro-4-
(trifluoromethyl)phenoxy>2-nitrobenzoic acid, sodium salt]
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Alachlor
Aldicarb
Aldrin [1.4:5.8-Dimethanonaphthalene, 1,2,3,4.10.10-
hexachloro- 1 .4.4a,5.8,8a-hexahydro-
(1 .alpha.,4.alpha..4a.beta.,5.alpha..8.alpha..8a.beta.)-]
Allyl alcohol
Ally) chloride
Allylamine
alpha-Hexachlorocyclohexane
alpha-Naphthylamine
Aluminum (fume or dust)
Aluminum oxide (fibrous form)
Aluminum phosphide
Ametryn (N-Ethyl-N'-(l-methylethyl)-6-(methylthio)-l ,3,5,-
triazine-2.4-diamine)
0.1
0.1

0.1
\
1.0
0.1
1.0
1.0
0.1
1.0
1.0
0.
0.
0.
0.
1.0
0.
0
0.
1.0
0.1
1.0

1.0
1.0


1.0
1.0

0.1
0.1
1.0
1.0
1.0

1.0
0.1
1.0
0.1
1.0
1.0
1.0


1.0
1.0
1.0
1.0
0.1
1.0
1.0
1.0
1.0

X






X
X



X



X

X
X


X


X







X
X


X
X

X

X
X


X
X


X


X










X



X



X

X
X


X


X







X



X
X

X






X

X






U095






P027




U158



P047


U093


U170


U181
U094




U001

U003
U004


P003
U007
U008
U009

P070
P004


POOS



U167


P006


April 15, 1998
A-4

-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
33089-61-1
61-82-5
7664-41-7
101-05-3

62-53-3
120-12-7
7440-36-0
7440-38-2
1 332-2 1-4
1912-24-9

7440-39-3
22781-23-3

1861-40-1

17804-35-2
56-55-3
98-87-3
55-21-0
71-43-2
92-87-5
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
189-55-9
98-07-7
98-88^1
94-36-0
100-44-7
7440-41-7
91-59-8
57-57-8
" 82657-04-3
92-52-4
108-60-1
111-91-1
11M4-4
103-23-1
542-88-1
56-35-9
10294-34-5
7637-07-2
314-40-9

53404-19-6

7726-95-6
353-59-3
75-25-2
74-83-9
75-63-8
1689-84-5
Amitraz
Amitrole
Ammonia
Anilazine [4,6-Dichloro-N-(2-chloropheny])- 1 ,3,5-triazin-2-
amine]
Aniline
Anthracene
Antimony
Arsenic
Asbestos (friable)
Atrazine (6-Chloro-N-ethyl-K-( 1 -methylelhyl)-! ,3,5-
triazine-2,4-diamine)
Barium
Bendiocarb [2,2-Dimethyl-l ,3-benzodioxol-4-oI
methylcarbamate]
Benfluralin(N-Butyl-N-ethyl-2,6-dinitro-4-
(trifluoromethyl) benzenamine)
Benomyl
Benz(a)anthracene
Benzal chloride
Benzamide
Benzene
Benzidine
Benzo(a)phenanthrene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j )lluoranthene
Benzo(k)fluoranthene
Benzo(rst)pentaphene
Benzoic trichloride (Benzotrichloride)
Benzoyl chloride
Benzoyl peroxide
Benzyl chloride
Beryllium
beta-Naphthylamine
bcta-Propiolactone
Bifenthrin
Bjphenyl
Bis(2-chloro-l-methylethyl)ether
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-ethylhexyl) adipate
Bis(chioromethyl) ether
Bis(tributyltin) oxide
Boron trichloride
Boron tri fluoride
Bromacil (5-Bromo-6-methyl-3-( 1 -methylpropyl)-2.4-
( 1 H,3H)-pyrimidinedione)
Bromacil. lithium salt (2.4-(lH.3H>Pynmidinedione. 5-
bromo-6-methyl-3 (1-methylpropyl). lithium salt)
Bromine
Bromochlorodifluoromethane (Halon 1211)
Bromoform (Tribromomethane)
Bromomethane (Methvl bromide)
Bromotrilluoromethane (Halon 1301)
Bromoxyni!(3.5-Dibromo-4-hydroxybenzonitrile)
1.0
0.1
1.0
*LO

1.0
1.0
1.0
0.1
0.1
0.1

1.0
1.0

1.0

1.0

1.0
1.0
0.1
0.1







1.0
1.0
1.0
0.1
0.1
0.1
1.0
1.0
1.0
1.0
1.0

0.1
1.0
1.0
1.0
1.0

1.0

.0
.0
.0
.0
.0
.0

X



X

X
X



X
X



X

X

X
X






X


X
X
X



X
X
X

X









X
X







X
X
X
X



X
X



X

X

X











X
X




X
X











X
X



U011



U012












UOI8
U017

U019
U02I

U022



U064
U023


P028
P015
U168



U027
U024
U025

P016









U225
U029


April 15, 1998
A-5

-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
1689-99-2

357-57-3
141-32-2
123-72-8
4680-78-8
6459-94-5
569-64-2
989-38-8
1937-37-7
28407-37-6
2602^6-2
16071-86-6
2832^»0-8
81-88-9
3761-53-3
3118-97-6
842-07-9
97-56-3
492-80-8
128-66-5
7440-43-9
156-62-7
133-06-2

63-25-2
1563-66-2
75-15-0
56-23-5
463-58-1
5234-68-4

120-80-9
2439-01-2

133-90^1
" 57-74-9

115-28-6
90982-32-4

7782-50-5
10049-04-4
79-11-8
108-90-7
510-15-6

75^5-6
75-00-3
67-66-3
74-87-3
107-30-2
76-06-2
126-99-8
63938-10-3
Bromoxynil octanoatc (Octanoic acid, 2,6-dibromo-4- '
cyanophcnyl ester)
Brucine
Butyl acrylate
Butyraldehyde
C.I. Acid Green 3
C.I. Acid Red 114
C. I. Basic Green 4
C.I. Basic Red 1
C.l. Direct Black 38
C.I. Direct Blue 21 8 .
C.l. Direct Blue 6
C.I. Direct Brown 95
C.I. Disperse Yellow 3
C.I. Food Red 15
C.I. Food Red 5
C.I. Solvent Orange 7
C.l. Solvent Yellow 14
C.I. Solvent Yellow 3
C.I. Solvent Yellow 34 (Auramine)
C.I. Vat Yellow 4 .
Cadmium
Calcium cyanamide
Captan [!H-Isoindole-l,3(2H)-di°ne, 3a,4.7.7a-tetrahydfo-
2-[(trichioromcthyl)thio}-]
Carbaryl [1-Naphthalenol. mcthylcarbamate]
Carbofuran
Carbon disulfide
Carbon tetrachloride
Carbonyl sulfide
Carboxin (5,6-Dihydro-2-methyl-N-phenyl-l ,4-oxathiin-3-
carboxamide) '
Catcchol
Chinomethionat (6-Methyl-l .3-dithiolo[4.5-b]quinoxalin-2-
one)
Chloramben [Benzoic acid. 3-amino-2,5-dichloro-]
Chlordane [4.7-Methanoindan, l,2,3.4.5,6.7.8,8-octachl6ro-
2.3,3a.4,7.7a-hexahydro-]
Chlorendic acid
Chlorimuron ethyl (Ethyl-2-[[[(4-chloro-6-
methoxyprimidin-2-yl)-carbonyI]-aminojsulfonyl]benzoate)
Chlorine
Chlorine dioxide
Chloroacetic acid
Chlorobenzcnc
Chlorobenzilate [Benzeneacetic acid,4-chloro-.alpha.-{4-
chlorophenyl)-.alpha.-hydroxy-, ethyl ester]
Chlorodifluoromethane (HCFC-22) :
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloromethyl methyl ether
Chloropicrin
Chloroprene
Chlorotetrafluoroethane
1.0

.0 X
.0
' .0
.0
0.1
.0
.0
0.1
0.1
0.1
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1 X
1.0
0.1 X X
1.0
1.0

1.0 X X
1.0 X X
1.0 X X
0.1 X X
1.0
1.0

1.0
1.0

1.0
0.1 X X

0.1
1.0

1.0
1.0
1.0
1.0 X X
1.0 X X

1.0
1.0 X
0.1 X X
1.0 X X
0.1 X
1.0
1.0 X X
1.0


P018
















U014







P022
U211







U036







U037




U044
U04S
U046

U210

April 15, 1998
A-6

-------
TRJ FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
1897-45-6

75-72-9
5598-13-0

64902-72-3

7440-47-3
7440-48-4
7440-50-8
8001-58-9
1319-77-3
4170-30-3
98-82-8
80-15-9
135-20-6

21725-46-2
1134-23-2
1 10-82-7
108-93-0
68359-37-5


68085-85-8


28057-48-9

533-74-4

53404-60-7

1163-19-5
13684-56-5
117-81-7
- 2303-16-4

25376-45-8
333-41-5
334-88-3
226-36-8
224-42-0
5385-75-1
192-65^1
53-70-3
189-64-0
191-30-0
132-64-9
124-73-2
84-74-2
1918-00-9
99-30-9
90454-18-5
25321-22-6
75-27^1
Chlorothalonil [1 ,3-Benzenedicarbonitrilc, 2,4,5,6-
tetrachloro-]
Chlorotrifluoromethane (CFC-1 3)
Chlorpyrifos methyl (O,O-Dimethyl-O-(3,5,6-trichloro-2-
pyndyOphosphorothioatc)
Chlorsulfuron (2-Chloro-N-[[(4-methoxy-6-methyH ,3,5-
tnazin-2-y))amino]carbonyl]benzenesu)fonamide)
Chromium
Cobalt
Copper
Creosote
Cresol (mixed isomers)
Crotonaidehyde
Cumene
Cumcne hydroperoxide
Cupferron [Benzeneamine, N-hydroxy-N-nitroso,
ammonium salt]
Cyanazine
Cycloate
Cyclohexane
Cyclohexanol
Cyfluthrin(3-(2.2-Dichloroethenyl)-2,2-
dimelhylcyciopropanecarboxylic acid, cyano(4-fluoro-3-
phenoxyphenyl)methyl ester)
Cyhalothrin (3-(2-Chioro-3,3,3-trifluoro-l -propenyl)-2.2-
Dimethylcyclopropanecarboxylic acid cyano(3-
phenoxyphenyl) methyl ester)
d-trans-Allethrin [d-trans-Chrysanthemic acid of d-
allelhrone]
Dazomet {Tetrahydro-3.5-dimethyl-2H-l .3.5-thiadiazine-2-
thione)
Dazomet. sodium salt (Tetrahydro-3,5-dimethyl-2H- 1,3.5-
thiadiazine-2-thione, ion(l-). sodium)
Decabromodiphenyl oxide
Desmedipham
Di(2-ethylhexyl) phthalate (DEHP)
Diallate [Carbamothioic acid, bis(l-methylethyl)-S-{2.3-
dichloro-2-propenyl)ester]
Diaminotoluene (mixed isomers)
Diazmon
Diazomethane
Dibenz(a.h)acridine
Dibenz(aJ)acridine
Dibenzo(a.e)fluoranthene
Dibenzo(a.e)pyrene
Dibenzo(a,h)anth racene
Di benzo(a.h )pyrcne
Di benzo(a,l )pyrene
Dibenzofuran
Dibromotetrafluoroethane (Halon 2402)
Dibutyl phthalate
Dicamba (3,6-Dichloro-2-methyoxybenzoic acid)
Dichloran(2,6-Dichloro-4-nitroaniline)
Dichloro-1,1 ,2-trifluoroethane
Dichlorobenzene (mixed isomers)
Dichlorobromomethane
1.0

1.0
1.0
;
1.0

0.1 X X
0.1
1.0
0.1
1.0 X
1.0 X
1.0
1.0
0.1

1.0
1.0 X X
1.0
1.0
1.0


1.0


1.0

1.0 X

1.0

1.0
1.0
0.1 X X
1.0 X

0.1 X
1.0
1.0


1.0




1.0
1.0
1.0 X X
1.0
1.0
1.0
0.1 X
1.0 X










U051
U052
U053
U055
U096




U056















U028
U062

U221






U063




U069





April 15, 1998
A-7

-------
TRJ FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITES
75-71.8
75-43^»
75-09-2
127564-92-5
97-23-4
76-14-2
34077-87-7
62-73-7

51338-27-3

115-32-2

77-73-6
1464-53-5
1 1 1-42-2
38727-55-8
84-66-2
64-67-5
134190-37-7
35367-38-5
101-90-6
94-58-6
55290-64-7

60-51-5
2524-03-0
131-11-3
77-78-1
124-40-3
2300-66-5
79-44-7
88-85-7
25321-14-6
39300^15-3
957-51-7
'" 1 22-39-4 *
2164-07-0

136-45-8
138-93-2
330-54-1
2439-10-3
106-89-8
13194-48-4

140-88-5
54 1-4 1-3
759-94-4 ,
100^ M
74-85-1
107-21-1
75-21-8
96-45-7.
151-56^
75-34-3
Dichlorodifluoromcthane (CFC-12)
Dichlorofluoromcthane (HCFC-21)
Dichloromethane (Methylene chloride)
Dichloropentafluoropropanc
Dichlorophene (2,2'-Methylenebis(4-chlorophenol)
Dichlorotetrafluoroethane (CFC-1 14)
Dichlorotriiluoroethane
Dichlorvos [Phosphoric acid, 2-dichloroethenyl dimethyl
ester]
Diclofop methyl (2-[4-(2,4-Dichlorophenoxy)
phcnoxy]propanoic acid, methyl ester)
Dicofol [Benzenemethanol, 4-chloro-.alpha.-4-
chlorophcnyl)-.alpha.-(tnchloromethyl)-]
Dicyclopentadicne
• Dicpoxybutane
Diethanolamine
Diethatyl ethyl
Diethyl phthalate
Diethyl sulfate
Diethyldiisocyanalobenzene
Diflubenzuron
Diglycidyl resorcinol ether
Dihydrosafrole
Dimethipin (2.3,-Dihydro-5,6-ditnethyl-l,4-dithiin 1,1,4,4-
tetraoxide)
Dimethoatc
Dimethyl chlorothiophosphate
Dimethyl phthalate
Dimethyl sullate
Dimethylamine
Dimethylamine dicamba
Dimethylcarbamyl chloride
Dinitrobutyl phenol (Dinoscb)
Dinitrotoluene (mixed isomers)
Dinocap
Diphenamid
Diphenylamine
Dipotassium endothall (7-Oxabicyclo(2.2.1)heptanc-2,3-
dicarboxylic acid, dipotassium salt)
Dipropyl isocinchomeronate
Disodium cyanodithioimidocarbonate
Diuron
Dodine (Dodecylguanidine monoacetate)
Epichlorohydrin
Ethoprop (Phosphorodithioic acid O-ethyl S.S-dipropyl
ester)
Ethyl acrylate
Ethyl chloroformate
Ethyl dipropylthiocarbamatc (EPIC)
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Ethylene thiourea
Ethyleneimine (Aziridine)
Ethylidene dichloride
1.0 X X
1.0
0.1 X X
,1.0
1.0
1.0
1.0
0.1

1.0

1.0

1.0
0.1 X
1.0
1.0
0.1
0.1

1.0
0.1
0.1 X
1.0

1.0 X
1.0
1.0 X X
0.1 X
1.0
1.0
0.1 X
.0
.0
.0
.0
.0 x
.0

1.0
1.0
1.0
1.0
0.1 X
1.0

0.1
1.0
1.0 X X
1.0 X
1.0
1.0
0.1 X X
0.1 X
0.1 X
1.0 X X
U075

U080











U085


U088




U090


P044

U102
U103
U092

U097
P020










U04]


U113





U115
U116
P054
U076
April 15, 1998
A-8

-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
52-85-7
60168-88-9

13356-08-6

66441-23-4

72490-01-8

39515-41-8

55-38-9

51630-58-1

14484-64-1
69806-50^1

2164-17-2

7782^1-4
51-21-8
69409-94-5

133-07-3
72178-02-0

50-00-0
64-18-6
76-13-1
76-W-8

87-68-3
118-74-1
77-47-4
67-72-1
' 1335-87-1
70-30-4
680-31-9
51235-04-2
67485-29-4



302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
35554-44-0

193-39-5
13463-40-6
78-84-2
465-73-6
Famphur
Fenarimol(.alpha.-(2-Chlorophenyl)-.aipha.-4-
chlorophenyl)-5-pyrirnidinemethanol)
Fenbutatin oxide (Hexakis(2-methyl-2-
phenylpropyl)distannoxane)
Fenoxaprop ethyl (2-(4-{(6-Chloro-2-
benzoxazoly]en)oxy)phenoxy)propanoic acid, ethyl ester)
Fenoxycarb (2-(4-Phcnoxy-phenoxy)-ethyl]carbamic acid
ethyl ester)
Fenpropathnn (2,2,3,3-Tetramethylcyclopropane carboxylic
acid cyano(3-phenoxyphenyl)mcthyl ester)
Fenthion (O,O-Dimethyl <>[3-methyl-4-(methylthio)
phenyl] ester, phosphorothioic acid)
Fenvalerate (4-Chloro-alpha-(l -methylethyl)benzeneacetic
acid cyano(3-phenoxyphenyl)methyl ester)
Ferbam(Tris(dimethylcarbamodithioato-S.S')iron)
Fluazifop butyl (2-l4-[[5-(Trifluoromethyl)-2-
pyridinyljoxy]-phenoxyjpropanoic acid, butyl ester)
Fiuometuron [Urea, N,N-dimethyI-N'-[3-
(trifluoromethyl)phenyl]-]
Fluorine
Fluorouracil (5-Fluorouracil)
F!uvalinate(N-(2-Chloro-4-(trifluorornethyl)phenylj-DL-
valine(+)-cyano(3-phenoxyphenyl)methyl ester)
Foipet
Fomesafen (5-(2-Chloro-4-(trifluorornethyl)phenoxy)-N
methylsulfonyl)-2-nitrobenzamide)
Formaldehyde
Formic acid
Freon 113 [Ethane. 1,1,2-trichloro-l J.2,-trifluoro-]
Heptachlor [1 .4,5.6.7.8.8-Heptachloro-3a.4,7.7a-tetrahvdro-
4.7-methano-l H-indene]
Hexachioro-1 ,3-butadiene
Hexach lorobenzene
Hexachlorocycjopenladiene
Hexachloroethane
Hexachloronaphthalene
Hexachlorophene
Hexamethylphosphoramide
Hexazinone
Hydramethylnon (Tetrahydro-5,5-dimcthyl-2( 1 H)-
pyrimidinone[3-[4-(trifluoromethyl)phenyl]-]-[2-[4-
(trifluoromethyl)phenyi]ethenyl]-2-
propenylidene ] hydrazone)
Hydrazine
Hydrazine sulfate
Hydrochloric acid
H\ drogen cyanide
Hydrogen fluoride
Hydroquinone
Imazalil(l-[2-(2,4-Dichlorophenyl>2-(2-
propenyloxy)ethyl]- 1 H-imidazole)
Indenofl .2,3-cd]pyrene
Iron pentacarbonyl
Isobutyraldehyde
Isodrin
1.0
1.0

i1'0

1.0

1.0

1.0

1.0

1.0

1.0
1.0

1.0

1.0
1.0
1.0

1.0
1.0

0.1
1.0
1.0


1.0
0.1
1.0
1.0
1.0
1.0
0.1
1.0
1.0



0.1
0.1
1.0
1.0
1.0
1.0
1.0


1.0
1.0
1.0
X X P097














X




X P056






X U122
X U123
X
X X P059

X X U128
X X U127
X X U130
X X U131

X U132






X U133


X P063
X U134



U137


X X P060
April 15, 1998
A-9

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
25311-71-1
4098-71-9
67-63-0
120-58-1
77501-63-1

7439-92-1
58-89-9

330-55-2
554-13-2
108-39-4
99-65-0
108-38-3
121-75-5
108-31-6
109-77-3
12427-38-2

7439-96-5
93-65-2
7439-97-6
150-50-5
126-98-7
137-42-8
67-56-1
20354-26-1

2032-65-7
94-74-6

3653-48-3

72-43-5

'' 96-33-3
79-22-1
78-93-3
60-34-4
74-88-4
108-10-1
624-83-9
556-61-6
80-62-6
298-00-0
1634-04-4
74-95-3
101-68-8
101-68-8
9006-42-2
21087-64-5
7786-34-7
90-94-8
2212-67-1

lsofenphos(2-[[EthoxylI(l-methylethyl)amino]
phosphinothioyljoxy] bcnzoic acid 1-methylethyl ester)
Isophorone diisocyanate
Isopropyl alcohol (mfg-strong acid process)
Isosafrole
l^ctofen(5-(2-Chloro-4-(trifluoromethyl)phenow>2-nitro-
2-ethoxy-l-methyl-2-oxoethyl ester)
Lead
Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-
,(l.alpha.^.alpha.rB.beta.,4.alpha.,5.alpha.,6.beta.>]
Linuron
Lithium carbonate
m-Cresol
m-Dinitrobenzcne
m-Xylene
Malathion
Malcic anhydride
Malononitnle
Maneb [Carbamodithioic acid, I _2-ethanediylbis-.
manganese complex]
Manganese
Mecoprop
Mercury
Merphos
Methacrylonitnle
Metham sodium (Sodium methyldithiocarbamate)
Methano!
Methazole (2-{3,4-Dichlorophenyl)-4-methyl-l ,2,4-
oxadiazolidine-33-dione)
Mcthiocarb
Methoxone ((4-Chloro-2-methvlphenoxy) acetic acid)
(MCPA)
Methoxone sodium salt ((4-Chloro-2-methylphenoxy) ,
acetate sodium salt)
Methoxychlor [Benzene. l,l'-(2,2,2-trichlorocthylidene)bis
[4-methoxy-]
Methyl acrvlate
Methyl chlorocarbonate
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide
Methyl isobutyl ketone
Methyl isocyanate
Methyl isothiocyanate (Isothiocyanatomethane)
Methyl methacrylate
Methyl parathion
Methyl tert-butyl ether
Methylcne bromide
Mcthylenebis(phenylisocyanate)(MBI)
Methy lenebis(phenyl isocyanate) (MDI )
Metiram
Metribuzin
Mevinphos
Michler's ketone
Molinate (IH-Azepine-l carbothioic acid, hexahvdro-S-
ethyl ester)
1.0
1.0
«LO
'l.O
1.0

0.1
0.1

1.0
1.0
.0
.0
.0
.0
.0
.0
1.0

1.0
0.1
1.0
1.0
1.0
1.0
1.0
1.0

1.0
0.1

0.1

1.0

.0
.0
.0
.0
.0
.0
.0
.0
1.0
1.0
1.0
1.0


1.0
1.0
1.0
0.1
1.0



X


X
X







X
X




X

X
X



X




X


X
X
X
X

X

X
X

X






X



X


X
X



X*

X*







X

X

X


X




X



X

X
X


X
X

X






X



U141



U129



U052

U239

U147
U149




U151



U154







U247


U156
UI59
P068
U138
U161
P064

U162
P071

U068








April 15, 1998
A-10

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
1313-27-5
76-15-3
150-68-5
505-60-2
88671-89-0

121-69-7
68-12-2
71-36-3
1 10-54-3
872-50-4
924-42-5
759-73-9
684-93-5
924-16-3
621-64-7
55-18-5
62-75-9
86-30-6
4549-40-0
59-89-2
16543-55-8
100-75-4
142-59-6
300-76-5
91-20-3
7440-02-0
1929-82-4
7697-37-2
139-13-9
98-95-3
1836-75-5
51-75-2

55-63-0
27314-13-2

90-04-0
13-4-29-2
95-48-7
528-29-0
95-53^1
636-21-5
95-47-6
2234-13-1
19044-88-3

20816-12-0
301-12-2

19666-30-9

42874-03-3
10028-15-6
104-94-9
95-69-2
Molybdenum trioxide
Monochloropentafluoroethane (CFC-1 15)
Monuron
Mustard gas [Ethane, 1,1 -thiobis[2-chloro-]
Myclobutanil (.alpha.-Butyl-.alpha.-(4-chlorophenyl)-l H-
1 ,2,4-triazole-l -propanenitrile)
N.N-Dimethylanilme
N,N-Dimethylformamide
n-Butyl alcohol
n-Hexane
N-Methyl-2-pyrroIidone
N-Methylolacrylamide
N-Nitroso-N-ethylurca
N-Nitroso-N-methylurea
N-Nitrosodi-n-butylam i ne
N-Nitrosodi-n-propylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylvinylamine
N-NitrosomorphoIine
N-Nitrosonomicotine
N-Nitrosopipendinc
Nabam
Naled
Naphthalene
Nickel
Nitrapyrin(2-Chloro-6-(trichlorornethyl)pyridine)
Nitric acid
Nitrilotriacetic acid
Nitrobenzene
Nitrofen [Benzene. 2.4-dichloro-l-(4-nitrophenoxv)-]
Nitrogen mustard [2-Chloro-N-(2-chloroethyl)-N-
methvlcthanamine]
Nitroglycerin
Norflurazon(4-Chloro-5-{methylamino)-2-[3-
(trifluoromethyl)phenyl]-3(2H}-pyridazinone)
o-Anisidine
o-Anisidine hydrochloride
o-Cresol
o-Dinitrobenzene
o-Toluidine
o-Toluidine hydrochloride
o-Xylenc
Octachloronaphthalene
Oryzalin (4-(Dipropylamino)-3.5-
dinitrobenzenesulfonamide)
Osmium tetroxide
Oxydemeton methyl (S-(2-(Ethylsultinyl)ethyl) O.O-
dimethyl ester phosphorothioic acid)
Oxydiazon (3-{2.4-Dichloro-5-(l -methylethoxy)phenyl]-5-
(1,1 -dimethylethyl)-! J,4-oxadiazol-2(3H )-one)
Oxyfluorfen
Ozone
p-Anisidine
p-Chloro-o-toluidine
1.0
1.0
1.0
,0.1
1.0

1.0
0.1
1.0
1.0
1.0
1.0
0.
0.
0.
0.
0.
0.
1.0
0.1
0.1
0.1
0.1
1.0
1.0
1.0
0.1
1.0
1.0
0.1
1.0
0.1
0.1

1.0
1.0

O.I
0.1
1,0
1.0
0.1
0.1
1.0
1.0
1.0

10
1.0

1.0

1.0
1.0
1.0
0.1


X








X
X
X
X
X
X

X
X
X
X


X
X



X

X

X






X
X




X















X





X
X
X

X

X

X


X
X



X








X



X



















U031



U176
UI77
U172
Ulll
UI74
P082

P084


U179


U165




U169



P081




U052

U328
U222
U239



P087








April 15, 1998
A-ll

-------
TRI FORM R GUIDANCE DOCUMENT
             METAL MINING FACILITIES
106-47-8
104-12-1
120-71-8
106-44-5
100-25-4
100-01-6
156-10-5
106-50-3
106^42-3
123-63-7
1910-42-5
56-38-2

1114-71-2
40487-42-1

76-01-7
87-86-5
57-33-0
79-21-0
594-42-3
52645-53-1


85-01-8
108-95-2
26002-80-2


57-41-0
75^4-5
7803-51-2
7664-38-2
7723-14-0
85-44-9
1918-02-1
" 88-89-1
51-03-6
29232-93-7

1336-36-3
9016-87-9
7758-01-2
128-03-0
137-41-7
41198-08-7

7287-19-6

23950-58-5
1918-16-7

1120-71-4
709-98-8
2312-35-8
107-19-7
p-Chloroaniline
p-Chlorophenyl isocyanate
p-Crcsidine
p-Cresol
p-Dinitrobenzene
p-Nitroaniline :
p-Nitrosodiphenylamine
p-Phenylencdiamme
p-Xylene
Paraldehyde
Paraquat dichloride
Parathion [Phosphorothioic acid, O,O-diethyl-O-{4-
nitrophcnyl) ester]
Pebulate (Butylcthylcarbamothioic acid S-propyl ester)
Pendimethalin (N-( 1 -Ethylpropyl>3,4-dimethyl-2,6-
dinitrobcnzenamine)
Pentachloroethane
Pentachlorophenol (PCP)
Pentobarbilal sodium
Peracetic acid
Perchloromethyl mercaptan
Permethrin(3-(2.2-Dichioroethenyl)-2J-
dimethylcyclopropane carboxylic acid, (3-
phenoxyphenyl)methyl ester)
Phenanthrene
Phenol
Phenothrin (2 J2-Dimethyl-3-(2-methy)-l -
propeny!)cyclopropanecarboxyiic acid (3-
phenoxyphcnyl)mcthyi ester)
Phenytoin
Phosgene
Phosphine
Phosphoric acid
Phosphorus (yellow or white)
Phthalic anhydride j
Picloram
Picric acid
Piperonyl butoxide
Pirimiphos methyl (O-(2-(Diethylamino)-6-methyl-4-
pyrimidinyl)-O.O-dimethyl phosphorothioate)
Polychlorinated biphenyls (PCBs)
Polymeric diphenylmethane diisocyanate
Potassium bromate
Potassium dtmethyldithiocarbamate
Potassium N-methyldithiocarbamate
Profenolbs (O-(4-Bromo-2-chlorophenyl)-O-ethyl-S- i
propvlphosphorothioale)
Prometryn (N.N"-Bis( 1 -methylethyl)-6-methylthio- 1 .3.5-
triazine-2 .4-diamine)
Pronamide
Propachlor (2-Chloro-N-( I -methylethyl)-N-
phenylacetamide)
Propane sultone
Propanil(N-(3.4-Dichlorophenyl)propanamide)
Propargite
Propargyl alcohol
0.1
1.0
0.1
.0
Vo
.0
.0
.0
.0
.0
.0
.0

1.0
1.0

1.0
0.1
1.0
1.0
1.0
1.0


1.0
1.0
1.0


0.1
.0
.0
.0
.0
.0
1.0
1.0
1.0
1.0

0.1
1.0
0.1
1.0
1.0
1.0

1.0

1.0
1.0

0.1
1.0
1.0
1.0
X X P024


X* U239
X
X X P077


X* U239
X U182

X X P089

X X


X X U184
X X






X
X U188




X P095
X P096


X X U190





X


X
X




X X U192


X U193


X P102
April 15, 1998
A-12

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TRI FORM R GUIDANCE DOCUMENT
METAL MINING FACILITIES
31218-83^1


60207-90-1

123-38-6
1 14-26-1
115-07-1
75-56-9
75-55-8
110-86-1
91-22-5
106-51-4
82-68-8
76578-14-8

10453-86-8


78-48-8
81-07-2
94-59-7
78-92-2
7782-49-2
74051-80-2

7440-22^1
122-34-9
26628-22-8
1982-69-0

1 28-04-1
62-74-8
7632-00-0
132-27-4
131-52-2
' 100-42-5
96-09-3
7664-93-9
2699-79-8
35400-43-2

34014-18-1

3383-96-8
5902-51-2

75-65-0
127-18-4
961-11-5

64-75-5
7696-12-0


7440-28-0
April 15, 1998
Propetamphos (3-
[(Ethylaniino)niethoxyphosphinothioyl]oxy]-2-butenoic
acid, 1-methylethyl ester)
Propiconazole (1 -[2-(2,4-Dichlorophenyl)-4-pK>pyM ,3-
dk>xolan-2-y!]-methyl-l H-l ,2,4,-triazole)
Propionaldehydc
Propoxur [Phenol, 2-(l-methylethoxy>, methylcarbamate]
Propylene (Propcne)
Propylene oxide
Propylcneimine
Pyridine
Quinoline
Quinone
Quintozene (Pentachloronitrobenzene)
Quizalofop-cthyl(2-[4-[(6-Chloro-2-
quinoxalinyl)oxy]phenoxy] propanoic acid ethyl ester)
Resmethrin ([5-{Phenylmetb.yl)-3-furanyI]methyl 22-
dimethyl-3-(2-methyl- 1 -
propenyl)cyclopropanecarboxylate])
S,STS-Tributyltrithiopbosphate (DEF)
Saccharin (manufacturing)
Safrole
sec-Butyl alcohol
Selenium
Sethoxydim (2-[ 1 -(Ethoxyimino) butyl]-5-[2-
(ethylthio)propyl]-3-hydroxyl-2-cyclohexen-l-one)
Silver
Simazine
Sodium azide
Sodium dicamba (3.6-Dichloro-2-methoxybenzoic acid.
sodium salt)
Sodium dimethyldithiocarbamate
Sodium fluoroacetate
Sodium nitrite
Sodium o-phenylphenoxide
Sodium pentachiorophenate
Sn-rene
Styrene oxide
Sulfuric acid
Sulfuryl fluoride (Vikane)
Sulprofos (O-Ethyl O-[4-
(methylthio)phenyljphosphorodithioic acid S-propyl ester)
Tebuthiuron (N-[5-( 1 ,1 -Dimethylethyl)- 1 3,4-thiadiazoi-2-
y])-N.N'-dimethylurea)
Temephos
Terbacil (5-Chloro-3-(l.l -dimethyleth\l)-6-methyl- 2.4
(lH.3H)-pyrimidinedione)
tert-Butyl alcohol
Tetrachloroethylene(Perchloroethylene)
Tetrachlorvinphos [Phosphoric acid. 2-chloro-l-(2.3.5-
trichlorophen\l) etheny] dimethyl ester]
Tetracycline hydrochloride
Tetramethrin(2.2-Dimethyl-3-(2-rnethyl-l-
propenyl)cyclopropanecarboxylic acid (1.3.4.5,6.7-
hexahydro-1 .3-dioxo-2H-isoindo]-2-yl)methyl ester)
Thallium
A-13
1.0


1.0
\
1.0
1.0 X X
1.0
0.1
0.1 X
.0 XX
.0
.0 X
.0 XX
.0

1.0


1.0
0.1 X
0.1 X X
1.0
1.0 X X
1.0

1.0 X X
1.0
1.0
1.0

1.0 X
1.0 X
1.0
0.1
1.0
0.1
0.1
1.0
1.0
1.0

1.0

1.0
1.0

1.0
0.1 X X
1.0

1.0
1.0


1.0 X X










P067
U196

U197
U185






U202
U203






P105



P058

























-------
TRI FORM R GUIDANCE DOCUMENT
            METAL MINING FACILITIES
148-79-8
62-55-5
28249-77-6

59669-26-0
23564-05-8
23564-06-9

79-19-6
62-56-6
137-26-8
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
26471-62-5
8001-35-2
10061-02-6
110-57-6
43121-43-3

2303-17-5
68-76-8

101200-48-0

1983-10-4
2155-70-6
52-68-6

76-02-8
79-01-6
75-69-4
57213-69-1
121-44-8
'" 1582-09-8

26644-46-2

639-58-7
76-87-9
126-72-7
72-57-1
51-79-6
7440-62-2
50471-44-8

108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
7440-66-6
12122-67-7

!
Thiabcndazoie(2-(4-Thiazolyl>lH-benzimidazolc)
Thioacetamide
Thiobencarb (Carbamic acid, dicthylthio-. S-(p-
chlorobenzyl))
Thiodicarb
Th lophanate-methyl
Thiophanate ethyl ([1,2-Phenylenebis
(iminocarbonothioyl)] biscarbamic acid diethyl ester)
Thiosemicarbazidc
Thiourea
Thiram
Thorium dioxide
Titanium tctrachloride
Toluene
ToIuene-2,4-diisocyanate !
ToIuene-2 ,6-diisocyanate
Toluene diisocyanate (mixed isomers)
Toxaphene
trans-l,3-Dichloropropene :
trans- 1 ,4-Dichloro-2-butene
Triadimefon (1 -(4-Ch1orophenoxy>3.3-dimethy1-l -{1H-
1 JM-triazol-1 -yl>2-bufanone)
Triallate
Triaziquone [2,5-Cyclohexadiene-l,4-dione. 2,3,5-tris(l»
aziridinyl)-]
Tribenuron methyl (2-(4-Methoxy-6-methyl-l ,3.5-triazin-2-
yl}-methylamino)carbonyl)amino)sultbnylK methyl ester)
Tributyltin fluoride
Tributyltin methacrylate
Trichlortbn fPhosphonic acid, (2,2.2-trichloro-l-
hydroxyethyl)-.dimethyl ester]
Trichioroacetyl chloride
Trich loroethylene
Trichlorofluoromethane (CFC-1 1 ) '
Triclopyr triethylammonium salt
Tricthylamine
Tritluralin [Benezeneamine. 2.6-dinitro-N.N-dipropyl-4-
(trilluoromethyl)-]
Triforine (KN'-{ 1 ,4-Piperazinediylbis(2 2 2-
Irichloroethylidene)] bistbrmamidc)
Triphenyltin chloride
Triphenyltin hydroxide
Tris(2.3-dibromopropyl) phosphate
Trvpan blue
Urethane (Ethyl carbamate)
Vanadium (fume or dust)
Vinclozolin (3-(3.5-Dichlorophenyl)-5-ethenyl-5-methvl*
2.4-oxazolidinedione) ;
Vinvl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride
Xylene (mixed isomers)
Zinc (fume or dust)
Zineb [Carbamodithioic acid. 1 .2-ethanedivlbis-, zinc
complex)
1.0
0.1 X
1.0
•
'1.0 X X
1.0 X X
1.0

1.0 X
0.1 X
1.0 X
1.0
1.0
1.0 X X
0.1
0.1
0.1 X
0.1 X X
0.1 X
1.0
1.0

1.0 X X
1.0

1.0

1.0
1.0
1.0

1.0
0.1 X X
1.0 X X
1.0
1.0 X
1.0

1.0

1.0
1.0
0.1 X X
0.1 X
0.1 X
1.0 X
1.0

0.1
0.1
0.1 X X
i.o x x
i.o .x
1.0 X
1.0


U218






PI 16
U219
U244


U220


U223
PI 23














U228
U121








U235
U236
U238





U043
U078
U239



April 15, 1998
A-14

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TRI FORM R GUIDANCE DOCUMENT                METAL MINING FACILITIES
              as mixed isomers (sum)
April 15, 1998                       A-15

-------

-------
TRI FORM R GUIDANCE DOCUMENT
                               METAL MINING FACILITIES
                                     APPENDIX B
            LIST OF ACTIVITIES THAT FALL UNDER EACH SIC CODE
                                 IN MAJOR GROUP 10   .-

    Major group 10, metal mining, includes establishments primarily engaged in mining,
    developing mines, or exploring for metallic minerals (ores). These ores are valued
    chiefly for the metals contained, to be recovered for use as such, or as constituents of
    alloys, chemicals, pigments, or other products. This major group also includes all ore
    dressing and beneficiating operations, whether performed at mills in conjunction with
    mines, or at mills, such as custom mills, operated separately from the mines served.
    These include mills that crush, grind, wash, dry, sinter, calcine, or leach ore, or perform
    gravity separation or flotation operations (U.S. OMB,  1987).

    When performed by operators of the properties, exploration under preliminary phases of
    operation should be classified according to the type of ore expected to be found.
    Exploration performed on a contract or fee basis is classified in Industry 1081 (U.S.
    OMB, 1987).
    1011  Iron ores:
Establishments primarily engaged in mining, beneficiating, or
otherwise preparing iron ores and manganiferous ores valued
chiefly for their iron content.  This industry includes production
of sinter and other agglomerates except those associated with
blast furnace operations. Blast furnaces primarily engaged in
producing pig iron from iron ore are classified in
Manufacturing Industry 3312.
    1021  Copper ores:
Establishments primarily engaged in mining, milling, or
otherwise preparing copper ores. This industry also includes
establishments primarily engaged in the recovery of copper
concentrates by precipitation and leaching of copper ore.
Establishments primarily engaged in the recovery of refined
copper by leaching copper concentrates are classified in
Manufacturing,  Major Group 33.
    1031  Lead and zinc
          ores:
Establishments primarily engaged in mining, milling, or
otherwise
preparing lead ores, zinc ores, or lead-zinc ores.
April 15, 1998
               B-l

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 TRI FORM R GUIDANCE DOCUMENT
                                METAL MINING FACILITIES
    1041   Gold ores:
Establishments primarily engaged in mining gold ores from
lode3 deposits or in the recovery of gold from placer deposits
by any method.  In addition to ore dressing methods such as
crushing, grinding, gravity concentration, and froth flotation,
this industry includes amalgamation, cyanidation, and the
production of bullion at the mine, mill, or dredge site.
    1044  Silver ores:
Establishments primarily engaged in mining, milling, or
otherwise preparing silver ores.  The production of bullion at
the mine or mill site is included.
    1061  Ferroalloy ores,
Establishments primarily engaged in mining, milling, or
otherwise
          except vanadium: preparing ferroalloy ores, except vanadium.  The mining of
                           manganiferous ores chiefly valued for their iron content is
                           classified in Industry 1011.  Establishments primarily engaged
                           in mining vanadium ore are classified in Industry 1094, and
                           those mining titanium ore are classified in Industry 1099.
    1081  Metal mining
          services:
Establishments primarily engaged in performing metal mining
services
for others on a contract or fee basis, such as the removal of
overburden, strip mining for metallic ores, prospect and test
drilling, and mine exploration and development.
Establishments which have complete responsibility for
operating mines for others ort a contract or fee basis are
classified according to the product mined rather than as metal
mining services. Establishments primarily performing hauling
services are classified in Division E, Transportation.
    1094  Uranium-radium- Establishments primarily engaged in mining, milling, or
                           otherwise                 ,
           vanadium ores,   preparing uranium-radium-vanadium ores.
    1099  Miscellaneous
Establishments primarily engaged in mining, milling, or
otherwise
       3 A lode is defined as a vein of metal ore.
April 15, 1998
               B-2

-------
TRI FORM R GUIDANCE DOCUMENT
                             METAL MINING FACILITIES
          metal ores, not
          elsewhere

          classified:
preparing miscellaneous metal ores, not elsewhere classified.
Production of metallic mercury by rurnacing or retorting at the
mine
site is also included.
April 15, 1998
              B-3

-------
TRI FORM R GUIDANCE DOCUMENT
METAL MINING FACILITIES
                                 APPENDIX C
                       INFORMATION SOURCE ONLINE
   Code of Federal Regulations, 40 CFR                 •
   http://www.epa.gov/epacfr40

   CHEMDAT8/WATER8
   http://www.epa.gov/ttr^chief7software.html#water8

   Clearinghouse for Inventories and Emission Factors (CHIEF)
   http://www. epa.gov/ttn/chief/

   Compilation of Air Pollutant Emission Factors (AP-42)
   http://www.epa.gov/ttn/chief/ap42etc.html

   EPA homepage
   http://www.epa.gov

   Federal Registers
   http://www.epa.gov/EPA-TRI

   MSDSs                                      i
   gopher ://gopher. chem. Utah, edu: 70/11 /MSDS

   TANKS
   http://www.epa.gov/ttn/chief/tanks.httnl

   TOXNET
   http://tamas.nlm.nih.gov/~boyda/htdocs/TOXNET/factsheets/toxnet.htm]

   TRI homepage
   http://www.epa.gov/opptintr/tri
April 15, 1998
                                      B-4

-------