SECTION 313 REPORTING:
ISSUE PAPER
Clarification and Guidance
for the
Metal Fabrication Industry
Office of Toxic Substances
U.S. Environmental Protection Agency
January 1990
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ERRATA SHEET
for
Section 313 Reporting: Issue Paper
Clarification and Guidance
for the
Metal Fabrication Industry
Published by Office of Toxic Substances, US Environmental
Protection Agency, January 1990.
Page 16- Oxygen Cutting Releases
The values in the table for chromiun (Cr) were too high by a
factor of ten. The correct values are listed below.
Oxyacetylene Cutting Oxymethane Cutting
of Carbon Steel of Carbon Steel
Listed Percent Ibs 313 metal emitted Ibs 313 metal emitted
Section Metal per million feet of per million feet of
313 Metal in Fume cut plate (1" thick) cut plate (1" thick)
Cr 0.02 0.28 0.2
USEPA, Office of Pollution Prevention and Toxics
Environmental Assistance Division, Toxic Release Inventory Branch
(TS-799)
December 21, 1992
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TABLE OF CONTENTS
Page
I. Introduction 1
II. Standard Industrial Classification (SIC) Codes Applicable to
Metal Fabrication 3
III. Clarification of Section 313 Policy Issues of Interest to
the Metal Fabrication Industry 5
Compounds and Mixtures 5
Special Qualifier: "Fume or Dust" 6
Chemical Categories 7
De Minimis Exemption 9
Article Exemption 10
Reuse and Recycle Exceptions 11
Estimating Emissions from Metal Welding and Oxygen Cutting
Operations 13
Estimating Emissions from Solvent Degreasing Operations 17
Estimating Emissions from Chromium Electroplating Operations ... 21
IV. Select Questions and Answers on Issues Faced by the Metal
Fabrication Industry 24
Determining Whether or Not to Report: Facility 24
Determining Whether or Not to Report: Listed Chemicals 24
Mixtures 26
Supplier Notification 26
Activities and Uses of the Chemical at the Facility 27
Exemptions 29
Releases of the Chemical 31
V. Bibliography of Reference Sources 32
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I. INTRODUCTION
This Issue Paper has been prepared to assist establishments in the metal
fabricating industry to comply with the reporting requirements of section 313
of the Emergency Planning and Community Right-to-Know Act (Title III of the
Superfund Amendments and Reauthorization Act of 1986, Public Law 99-499).
Under section 313, facilities that meet all three of the following criteria
are required to report releases to the air, water, and land as well as
transfers of wastes containing any listed toxic chemical to off-site
locations:
• The facility has 10 or more full-time employees;
• The facility is included in Standard Industrial
Classification (SIC) codes 20 through 39 (thus including all
metal fabricating establishments grouped under SIC code 34);
and
• The facility manufactured (defined to include imported),
processed, or otherwise used in the course of a calendar
year any listed chemical in quantities greater than the set
threshold. The thresholds for manufacturing or processing a
listed toxic chemical or chemical category are 25,000
pounds. The otherwise use threshold is 10,000 pounds.
This document includes a clarification of threshold determinations and
reporting requirements for metal fabricators which describes, in detail, the
more complex issues involved in section 313 reporting. Questions and answers
have been selected from the EPA document, Toxic Chemical Release Inventory
Questions and Answers (EPA 560/4-90-003), to address reporting issues and
problems typically encountered by metal fabricators. Finally, this document
contains a list of reference materials and documents that may be of use in
obtaining emission factors and other information to develop release estimates.
The following statements represent clarifications of threshold
determinations and reporting requirements associated with processing and use
of covered toxic chemicals by metal fabricators (for a more thorough
explanation of these clarifications, see Section III of this document):
• Metal alloys are solid mixtures. Any alloy containing
a listed toxic chemical above the de minimis
concentration must be evaluated for threshold
determinations and release calculations.
• Metal "articles" are exempt from threshold
determinations if, during normal processing or
otherwise use activities, no toxic chemical-is
released. Neither the disposal of solid wastes that
are recognizable as the processed article nor the
recycle of wastes constitute releases that would
negate the article status of the metal item.
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• Welding metal parts (e.g., welding of steel plates)
requires Che facility to determine whether releases
occur from the metal items being joined, as well as
the toxic chemical components of the welding rods. If
no releases occur from the joined metal parts
themselves, then only the toxic chemical(s) contained
in the welding rods are subject to threshold and
release determinations.
• Fume or dust is the qualifier for three listed toxic
chemicals (aluminum, vanadium, and zinc). Threshold
determinations are based on the amount of the chemical
manufactured, processed, or otherwise used only as a
fume or dust. Zinc compounds, distinct from zinc
(fume or dust), are reportable as members of the zinc
compound category. Zinc compounds released in
particulate form are not considered zinc (fume or
dust).
While the information contained in this document is the most up-to-date
guidance available from EPA, no new policy information is contained here that
is not represented in other EPA documents.
If you have specific circumstances or situations for which you need
additional EPA guidance, contact your Regional section 313 coordinator or call
the Emergency Planning and Community Right-Co-Know Information Hotline at 1-
800-535-0202, or in Washington, D.C. and Alaska 202-479-2449.
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II. STANDARD INDUSTRIAL CLASSIFICATION (SIC) CODES OF METAL FABRICATION
In general, metal fabricators are classified in the Standard Industrial
Classification (SIC) codes of Major Group 34, which includes "Fabricated Metal
Products, Except Machinery and Transportation Equipment." The complete
listing of SIC codes within this group is provided on the next few pages.
Multiple SIC codes may apply to facilities which perform several types
of manufacturing operations. For further information about the classification
of establishments, consult the Standard Industrial Classification Manual. (PB
87-100012) published by the Executive Office of Management and Budget. The
manual is available for purchase from: National Technical Information
Service. 5285 Port Royal Road. Springfield, VA 22161 (703-487-4650).
Major Group 34. Fabricated Metal Products, Except Machinery and
Transportation Equipment
This major group includes establishments engaged in fabricating ferrous
and nonferrous metal products, such as metal cans, tinware, handtools,
cutlery, general hardware, nonelectric heating apparatus, fabricated
structural metal products, metal forgings, metal stampings, ordnance (except
vehicles and guided missiles), and a variety of metal and wire products, not
elsewhere classified.
[Note that: Certain important segments of the metal fabricating
industries are classified in other major groups of the SIC code system. These
include: machinery in Major Groups 35 and 36; transportation equipment,
including tanks, in Major Group 37; professional scientific and controlling
instruments, watches, and clocks in Major Group 38; and jewelry and silverware
in Major Group 39. Establishments primarily engaged in producing ferrous and
nonferrous metals and their alloys are classified in Major Group 33.]
341 METAL CANS AND SHIPPING CONTAINERS
3411 Metal Cans
3412 Metal Shipping Barrels, Drums, Kegs, and Pails
342 CUTLERY, HANDTOOLS, AND GENERAL HARDWARE
3421 Cutlery
3423 Hand and Edge Tools, Except Machine Tools and Hardware
3425 Saw Blades and Handsaws
3429 Hardware, Not Elsewhere Classified
343 HEATING EQUIPMENT, EXCEPT ELECTRIC AND WARM AIR; AND PLUMBING FIXTURES
3431 Enameled Iron and Metal Sanitary Ware
3432 Plumbing Fixture Fittings and Trim
3433 Heating Equipment, Except Electric and Warm Air Furnaces
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344 FABRICATED STRUCTURAL METAL PRODUCTS
3441 Fabricated Structural Metal
3442 Metal Doors, Sash, Frames, Molding, and Trim
3443 Fabricated Plate Work (Boiler Shops)
3444 Sheet Metal Work
3446 Architectural and Ornamental Metal Work
3448 Prefabricated Metal Buildings and Components
3449 Miscellaneous Structural Metal Work
345 SCREW MACHINE PRODUCTS, AND BOLTS, NUTS, SCREWS, RIVETS, AND WASHERS
3451 Screw Machine Products
3452 Bolts, Nuts, Screws, Rivets, and Washers
346 METAL FORCINGS AND STAMPINGS
3462 Iron and Steel Forgings
3463 Nonferrous Forgings
3465 Automotive Stampings
3466 Crowns and Closures
3469 Metal Stampings, Not Elsewhere Classified
347 COATING, ENGRAVING. AND ALLIED SERVICES
3471 Electroplating, Plating, Polishing, Anodizing, and Coloring
3479 Coating, Engraving, and Allied Services, Not Elsewhere Classified
348 ORDNANCE AND ACCESSORIES, EXCEPT VEHICLES AND GUIDED MISSILES
3482 Small Arms Ammunition
3483 Ammunition, Except for Small Arms
3484 Small Arms
3489 Ordnance and Accessories, Not Elsewhere Classified
349 MISCELLANEOUS FABRICATED METAL PRODUCTS
3491 Industrial Valves
3492 Fluid Power Valves and Hose Fittings
3493 Steel Springs, Except Wire
3494 Valves and Pipe Fittings, Not Elsewhere Classified
3495 Wire Springs
3496 Miscellaneous Fabricated Wire Products
3497 Metal Foil and Leaf
3498 Fabricated Pipe and Pipe Fittings
3499 Fabricated Metal Products, Not Elsewhere Classified
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III. CLARIFICATION OF SECTION 313 POLICY ISSUES OF INTEREST TO THE METAL
FABRICATION INDUSTRY
This section of che issue paper provides in-depth descriptions of some of
the more complex issues involved in section 313 reporting for the metal
fabrication industry.
For some issues, such as de minimis and article exemptions, multiple
factors become involved in determining threshold and release information.
These issues have generated many inquiries and requests for clarification from
facilities, particularly metal fabricators. To help facilities better
understand these complex issues, comprehensive written interpretations are
provided.
COMPOUNDS AND MIXTURES
1. Definition of Compounds
A "compound" is any combination of two or more chemicals that is the
result (in whole or in part) of a chemical reaction. In the formation of a
compound, the reactant chemicals loose their individual chemical identities.
2. Definition of, Mixtures
A "mixture" is any combination of two or more chemicals, if the
combination is not, in whole or in part, the result of a chemical reaction.
In a mixture, the individual components retain their identities. Mixtures
include any combination of a chemical and associated impurities.
Metal alloys are solid mixtures because the individual metals in the
alloy retain their chemical identity. Any such mixture containing a listed
toxic chemical at or above the de minimis concentration is subject to
threshold determinations. Release of the mixture is considered a release of
the toxic chemical(s) contained in the mixture. The quantity of metal
released can be estimated based on the percent by weight of each toxic
chemical in the mixture.
3. ^f^tVTf**8 Must be Considered for Section 313 Reporting
Threshold and release determinations for section 313 reporting must
include the amount of the listed toxic chemical•present above the de minimis
concentration in all mixtures processed or otherwise used by the facility
unless otherwise exempted. If a listed toxic chemical is present in a mixture
at or above the de minimis concentration, only the amount of the toxic
chemical, and not the mixture itself, is subject to threshold and release
determinations.
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The distinction between a compound and mixture is important because it
affects the amount of the metal which is considered in making threshold
determinations and release calculations. If a listed metal is present in an
alloy (i e., solid mixture), only the weight of the listed metal is subject to
threshold determinations and release calculations. If a listed metal is
present in the form of a listed metal compound (e.g., zinc oxide), the entire
weight of the metal compound is subject to threshold determinations for the
applicable metal compound category (e.g., zinc compounds), however, release
determinations would be calculated for the parent metal only (e.g., pounds of
zinc).
4. Supplier Notification and Concentration Ranees Provide Information for
Reporting
The section 313 supplier notification requirements are designed to
provide chemical users with information on the identities and concentrations
of listed toxic chemicals present in the mixtures that they use. There can
still be situations, however, when a facility may not have this information
for a mixture. If a facility knows that a mixture contains a toxic chemical,
but no concentration information is provided by the supplier, then the
facility does not have to consider the chemical present in the mixture for
purposes of threshold and release determinations. However, if a facility
owner/operator only knows the lower bound concentration of a toxic chemical
present in a mixture, the owner/operator should base the threshold
determination on that lower bound concentration number. If only a range of
concentrations is available for a toxic chemical present in a mixture, the
owner/operator should use an average of the low and high concentrations
numbers for threshold determinations.
SPECIAL QUALIFIER: "FUME OR DUST"
Three listed toxic chemicals (aluminum, vanadium, and zinc) have the
qualifier, "fume or dust". When these chemicals are manufactured, processed,
or otherwise used, including as part of an alloy, a different approach is used
to make threshold determinations. Only the amount of these chemicals that are
manufactured, processed, or otherwise used as a fume or dust is subject to
threshold determinations. Manufacturing, processing, or otherwise using these
chemicals in any other form is not reportable under section 313. Zinc
compounds, distinct from zinc (fume or dust), are reportable as members of the
zinc compound category. In most cases, only the generation of a fume or dust
(i.e., manufacturing) would be a reportable activity, because there are few
processing or otherwise use activities that utilize these chemicals in a fume
or dust form.
To make threshold determinations for these chemicals, the amount of fume
or dust generated for each chemical, including chemicals contained in an alloy
mixture, are totalled. Because the chemical is being manufactured-into a dust
or fume, the manufacturing threshold of 25,000 pounds is applied and the de
minimis exemption does not apply
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For example, a facility manufactures metal posts and uses over 150,000
pounds of solid aluminum slabs over the reporting year. During the processing
of the aluminum slabs into posts, 11,000 pounds of fumes and dust are
generated from the cutting, grinding, and polishing of the aluminum which is
either released as fugitive emissions or is disposed in an off-site landfill.
For threshold determinations, only the 11,000 pounds of aluminum generated in
the form of fume and dust would be applied to the 25,000 pound manufacturing
threshold. Therefore, the threshold for aluminum in a fume or dust form is
not exceeded and a Form R is not required for this toxic chemical.
CHEMICAL CATEGORIES
1. All Compounds in a Listed Chemical Category are Aggregated for Threshold
Determinations
Toxic chemical categories listed under section 313 require a different
approach when making threshold and release determinations. For a chemical
that is included in a listed metal compound category, the total weight of that
chemical compound, not just the parent metal, is used in making threshold
determinations. A facility will need to calculate the total weight of all
compounds that are in the category, sum the amounts involved throughout the
facility in each threshold activity, and compare the totals to the applicable
thresholds.
For example, 30,000 pounds of nickel chloride are used in a plating bath
during the reporting year. The nickel, which is 40 percent of the compound,
is incorporated on steel plates, while the chloride remains in the plating
bath. Even though only the nickel is incorporated on the steel plates, the
facility is processing nickel chloride, which is a metal compound within the
nickel compound category. The total weight of the nickel chloride processed
during the reporting year is considered for threshold determinations.
Therefore, the facility must submit a Form R for the nickel compound category
and must report all releases from nickel compounds in terms of the parent
metal, nickel.
A compound in a listed chemical category which is present in a mixture
below the de minimis concentration, based on the total weight of the compound
in the mixture, is exempt from threshold and release calculations under
section 313. Again, all individual members of a chemical category must be
totalled to determine if the chemical category has met or exceeded the de
minimis concentration in a mixture.
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2. Make Threshold Determinations for Listed Toxic Chemicals Separately from
Listed Chemical Category
The section 313 list contains some listed substances chat are also
members of a listed chemical category. Threshold determinations for a
specifically listed toxic chemical are calculated separately from the
threshold determinations for the chemical category. For example, C.I. Direct
Brown 95 (CAS number 16071-86-6), a copper-based pigment, which is
specifically listed on the section 313 list, is also a member of the copper
compound category. Because it is specifically listed, a facility must make a
threshold determination for C.I. Direct Brown 95 and a separate threshold
determination for all other copper compounds that meet the criteria for that
metal compound category which are not specifically listed under section 313.
Threshold determinations are calculated separately for a specifically
listed metal and compounds that are members of the associated metal compound
category. For example, a facility converts 12,000 pounds of lead (processing
the listed metal) to form 15,000 pounds of lead oxide (manufacturing the
listed compound category) . Separate threshold determinations are made for
these chemicals and these activities, and, therefore, the 25,000 pound
thresholds for processing or manufacturing would not be exceeded for either
the lead or the lead compounds.
3 . Calculate Releases Based on Parent Metal For Metal Compound Categories
Once a reporting threshold is met for a metal compound category, releases
of compounds are calculated based on the pounds of the parent metal released,
rather than the total weight of the compound. EPA adopted this approach
because it is difficult to calculate releases of potentially numerous
compounds within a metal compound category, and because there are often
methods and data for monitoring the parent metal but not the compound(s) .
4 . Optional Form R Submission for Parent Metal and Associated Metal Compound
Category
If both the parent metal and the associated metal compound category
exceed their respective thresholds, one section 313 reporting Form R may be
filed, which covers all releases of the parent metal from activities involving
both the parent metal and the metal compound category. This approach of
reporting releases on a single Form R may be easier for facilities whose
operations involve conversions between the listed metal and members of a
listed metal compound category. For example, if a facility processes 30,000
pounds of lead and otherwise uses 13,000 pounds of lead oxide, the facility
could submit one Form R for lead and lead compounds. On this Form R, the
facility would report on all activities involving lead and lead compounds and
all releases of the parent metal, lead. This option, preferred by EPA, is
available to facilities, although separate reports may be filed if desired.
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DE MINIMIS EXEMPTION
The de mininis exemption allows facilities to discount certain minimum
concentrations of listed toxic chemicals in mixtures they process or otherwise
use in threshold and release determinations for section 313 reporting. This
de minimis level is 0.1 percent by weight for OSHA defined carcinogens and 1
percent by weight for all other section 313 listed toxic chemicals. De
minimis levels for chemical categories apply to the total concentration of all
chemicals in the category within a mixture, not the concentration of each
individual category member within the mixture.
1. Processing or Use of a Mixture
If a listed toxic chemical is present in a mixture at a concentration
below the de minimis level, this amount of the toxic chemical is not subject
to threshold determination, release reporting, or supplier notification
requirements.
For processes where the chemical concentration fluctuates above and below
the de minimis level, the de minimis exemption applies to the process stages
where the de minimis level is not exceeded. This application is further
described in the general section of the Toxic Chemical Release Inventory
Reporting Form R and Instructions document (EPA 560/4-90-007).
2. Manufacture of the Listed Chemical In, fl M.ft.yf'^e
The de minimis exemption does not apply to manufacture of a toxic
chemical. One exception applies to the toxic chemical which is created
(manufactured) as an impurity and remains in the product distributed in
commerce at below the de minimis levels; the amount remaining in the product
Is exempt from threshold determinations. However, any amount that is
separated from the product (e.g., ends up in a wastestream) is subject to
threshold and release determinations regardless of the concentration in the
wastestream.
Example of Coincidental Manufacture as a Waste Byproduct:
A small amount of aluminum fumes is manufactured as a reaction
byproduct during an arc welding process. The aluminum fumes are
collected as a waste and disposed on site. Aluminum (fume or dust)
is a listed toxic chemical under section 313. The amount of
aluminum fumes generated and removed as waste must be included in
threshold and release determinations, even if the aluminum fumes
were present below the de minimis level in the process stream where
it was manufactured or in the wastestream to which it was separated.
The de minimis exemption also does not apply to situations where the
manufactured chemical is released or transferred to waste streams and thereby
diluted to below the de minimis level.
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3. De Minimis Levels Impact Supplier Notification Requirements
If che toxic chemical in a product (mixture or trade name product) is
present below the de minimis level for that toxic chemical, supplier
notification is not required for that chemical in the mixture.
ARTICLE EXEMPTION
Listed toxic chemicals contained in articles that are processed or
otherwise used are exempt from threshold determinations. Manufacturing an
article is not exempt. For a material to be exempt as an article, an item
must meet all of the following three criteria in the section 313 article
definition; that is, the item must be one:
i) Which is formed to a specific shape or design during
manufacture;
ii) Which has end use functions dependent in whole or in
part upon its shape or design during end use; and
iii) Which does not release a toxic chemical under the normal
conditions of processing or otherwise use of the item at
the facility.
If, as a result of processing or otherwise use, an item retains its
initial thickness or diameter, in whole or in part, then it meets the first
part of the definition. If the item's basic dimensional characteristics are
totally altered during processing or otherwise use, the item would not meet
the first part of the definition. An example of items that do not meet the
definition would be items which are cold extruded, such as lead ingots formed
into wire or rods.
However, cutting a manufactured item into pieces which are recognizable
as the article does not change the original exemption as long as the diameter
and the thickness of the item remain the same and no release of the toxic
chemical occurs. For example, metal wire may be bent or cut into smaller
pieces and sheet metal may be cut, punched, stamped, or pressed without losing
the article status as long as there is no change in the diameter of the wire
or the thickness of the sheet metal.
An important aspect of the article exemption is the criteria for what
constitutes a release of a toxic chemical. Any processing or use of an
article that results in generation of a waste containing the chemical is
considered a release which negates the exemption. Cutting, grinding, melting,
or other processing of a manufactured item could result in a release of a
toxic chemical during normal conditions of use and, therefore, negate the
item's exemption as an article.
A facility which receives an article for further processing that
incorporates a toxic chemical into che arcicle may retain the exemption for
the article. However, the toxic chemical incorporated into the article will
not be exempt. For example, a facility chat receives steel bolts (articles)
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and plates them with chromium (processing). The boles retain the exemption as
an article, however, the use of chromium does not meet the definition of an
article and, therefore, is subject to threshold and release determinations
However, there are two circumstances for which releases may not negate
the exemption of the item as an article:
• If the resulting waste containing a listed toxic chemical is
100 percent recycled or reused, on-site or off-site, then the
article exempt status is maintained. For section 313
purposes, wastes containing toxic chemicals are not reportable
on Form R if the toxic chemical(s) in the waste is reused or
recycled, on-site or off-site.
• If the processing or otherwise use of all similar manufactured
items results in a total release of less than 0.5 pound of a
toxic chemical to any environmental media in a calendar year,
EPA will allow this release quantity to be rounded to zero and
the manufactured items remain exempt as articles. Facilities
should 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 of a toxic
chemical from the processing or otherwise use of all like
articles.
REUSE AND RECYCLE EXCEPTIONS
Reuse or recycling of a listed toxic chemical can impact threshold
determinations, article exemption status, reporting of off-site transfers, and
supplier notification.
1. Processing or Otherwise Use of Toxic Chemicals in an On-Slte
Recycle/Reuse Operation May Be Exempt From Threshold Determinations
Quantities of a toxic chemical that are present in an on-site
recycle/reuse operation at the beginning of the reporting year are not counted
toward a threshold determination for that reporting year. This exemption
prevents the facility from counting the same amount of a toxic chemical every
time it cycles through the on-site operation. However, the amount of a toxic
chemical that is nevly added to a process system during the reporting year is
counted in the threshold determination.
For example, a facility purchases 24,600 pounds of copper sheets for its
decorative mail box manufacturing operation. As part of this operation, all
the copper sheets are cut, grinded and polished, negating the copper sheets'
exemption as an article. In addition, the facility processes 500 pounds of
copper ingots into wire which the facility sells to an electronics firm.
However, this 500 pounds of copper ingocs was obtained by on-site reuse of
scrap copper generated in the form of shavings and dust from the decorative
mail box manufacturing operation. The scrap copper was melted and reformed
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into ingots and the facility cold extruded the ingots into the copper wire.
Despite the reuse of the copper, only 24,600 pounds of copper would be applied
to the processing threshold determination. Therefore, the facility does not
exceed the processing threshold for copper.
2. Article Status Is Maintained If All Releases Are Reused or Recycled
An important aspect of the article exemption is the criteria for what
constitutes a release of a toxic chemical. Any processing or otherwise use of
an article that results in generation of a waste containing the toxic chemical
can be considered a release which negates the article exemption. Cutting,
grinding, melting, or other processing or use of a manufactured item could
result in a release of a toxic chemical during normal conditions of use, and
therefore, could negate the exemption as an article. However, if the
resulting waste containing a listed toxic chemical is 100 percent recycled or
reused, on-site or off-site, then the article status is maintained and no
section 313 reporting would be required for that toxic chemical. Wastes
containing toxic chemicals are not reportable under section 313 if the toxic
chemical contained in the waste is reused or recycled, on-site or off-site.
3. Do Not Report Aiiovncs Sent Off-Site for Reuse or Recycling As Off-Site
Transfers
If a toxic chemical is sent off-site for purposes of reuse or recycling,
the location and amount of the chemical do not have to be reported on Form R
as an off-site transfer. EPA requires the identification of all other toxic
chemicals in wastes which are transferred off-site for final disposal. Off-
site reuse or recycling activities, however, are more closely related to
facility products distributed in commerce.
4. Supplier Notification Applies to Chemicals Sent Off-Site for Reuse or
Recycling
While the off-site location to which a toxic chemical is sent for reuse
or recycling does not have to be reported on Form R, supplier notification is
still required to be provided to the off-site location, if the location is a
manufacturing facility in SIC codes 20-39 or a facility that distributes to
facilities in SIC codes 20-39.
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ESTIMATING EMISSIONS FROM METAL WELDING AND OXYGEN CUTTING OPERATIONS
Metal fabrication facilities that conduct welding operations will need to
estimate emissions that occur from these operations. When making a threshold
determination, the facility uses the total weight of the metal being processed
not just the immediate area being cut. First, the facility will need to
determine if emissions are occurring from the metals being welded, in addition
to emissions from the welding rods used in the welding process. Releases of
listed toxic chemicals and chemical categories must be estimated for welding
operations both to develop fugitive air release data and to identify whether
the releases from the base material exceed 0.5 pounds per year and therefore
negate the article status of the material welded.
The materials contained in the welding rod or electrode will make up much
of the release from welding activities. However, oxyacetylene and oxymethane
cutting of metals will produce emissions primarily from the base material
(i.e., the material being welded). The method for developing emission
estimates is, therefore, strongly dependent on the type of operation
performed.
Metal Welding Releases
The amount of each section 313 listed metals released from welding rods
may be estimated as follows:
release numbir of might of the rod that emission factor conversion factor
of lilted • rods uiad z la eonaunad or dapoaitad z z ( 1 ton )
matal during year (Iba of aatarial danoaitadl ( Iba of ^"ft*!*?1! ' 200° >*•
(lha/jraar) (roda/yaac) red used tons material dapoaitad
Emission factors for section 313 listed metals applicable to several
types and classes of electrodes are provided in the tables that follow. These
data represent average fume generation rates and percent metal in the fume
taken from Tables 2.2 and 2.18 from Fi"i"»«f »md Gases in the Welding Environment
(see bibliography).
If the electrodes your facility uses are not listed, you may use emission
factors for a similar electrode and adjust the calculated release values based
on the composition of the electrodes you use.
Electrode composition information for development of welding release
estimates can often be obtained from Material Safety Data Sheets,
manufacturer's specifications, and American Welding Society (AWS) Electrode
Specifications. Flux composition is often considered proprietary so only the
composition of the weld deposit is provided for many covered or flux cored
electrodes.
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Shielded Metal Arc Covered Electrodes (5/32")
Carbon and Low Alloy Steel
Electrode
class
E6010
E6013
E7018
E7024
E8018 C3
Average fume
generation
race . g/kg*
35.9
20.
21.1
10.0
16.9
% 313 metal
in fumes
1 Mn
3.2
4.9
4.1
6.2
7.2
Ni
Cu Cr |
Ibs 313 metal released per
tn total metal deposited
I Mn Ni Cu Cr |
2.3
2.0
1.8
1.2
1.2
Shielded Metal Arc Covered Electrodes (5/32")
Stainless Steel and High Alloy
Average fume
Electrode generation
class rate . e/ke*
E316-15
E316-16
E410-16
ENi-CI
ENi-Cu2
Inconel 625
Haynes C-276
Haynes 25
9.6
9.2
12.9
12.9
10.1
9.2
14.2
8.9
% 313 metal
in fumes
| Mn
7.7
8.8
5.2
0.3
2.1
4.6
0.3
4.6
Ni Cu
1.1
1.5
<0.1
6.9 <0 . 1
4.2 6.2
0.7 5.9
1.1
1.8
Cr |
5.8
6.5
2.5
6.9
Ibs 313 metal released per
tn total metal deposited
Mn
1
1
1
0
0
0
0
0
.5
.6
.3
.1
.4
.8
.1
.8
Ni
0
0
<0
1
0
0
0
0
.2
.3
.02
.8
.8
.1
.3
.3
Cu
<0
1
1
.02
.2
.1
Cr
1
1
0
1
.1
.2
.7
.2
Electrode
class
E70T-1
E70T-4
E70T-5
Flux Cored Electrodes (3/32")
Carbon and Low Alloy Steel
Average fume
generation
rate. g/kg*
12.1
13.3
21.0
% 313 metal
in
Mn
9.2
3.9
11.1
Ni
Cu
Cr I I Mn
<0.01
Ibs 313 metal released per
tn total metal deposited
Ni Cu Cr |
2.2
0.8
4.7
Flux Cored Electrodes (3/32")
Stainless Steel
Electrode
class
E316LT-3
Average fume
generation
rate. g/kg*
9.6
% 313 metal
in fumes
Mn
7 3
Ni Cu
1.1
Cr
12.5
Ibs 313 metal released per
tn total metal deposited
| Mn Ni Cu Cr I
1.4 0.2
2.4
g/kg - grams of fume per kilogram of total deposited metal.
-------
-15-
Gas Metal Arc Solid Electrodes (0.045")
Carbon Steel
Electrode
class
E70S-3
E70S-5
Average'fume
generation
rate. g/kg*
5.1
4.0
% 313 metal
in fumes
| Mn Ni
5.3
5.8
Cu
0.7
1.8
Cr
Ibs 313 metal released per
tn total metal deposited
| Mn Ni Cu Cr I
0.5
0.5
0.1
0.1
Gas Metal Arc Solid Electrodes (0.045") (0.035" for Haynes C-276)
Stainless Steel and High Alloy
Electrode
.class
ERNiCu-7
Inconel 625
Haynes 25
Haynes C-276
Average fume
generation
rate. g/kg*
2.0
0.9
1.4
7.0
% 313 metal
in fumes
ttn
1.
15.
1.
1
4
0
Pi
22
27
7
32
.1
.2
.1
.5
Cu
44
0
.4
.7
C)T
<0
15
14
8
I
.01
.4
.9
.2
Ibs 313 metal released per
total metal deposited
| Mn
0.04
0.4
0.1
Ni
0.9
0.5
0.2
4.6
Cu
1.8
0.01
Cr
0.3
0.4
1.2
Electrode
class
ER4043
ER5356
Gas Metal Arc Solid Electrodes (3/64*)
Aluminum
Average fume
generation
rate. g/kg*
10.7
72.3
% aluminum Ibs"aluminum released per
ftlil fi"1?ff ton total metal deposited
46.2 9.9
38.0 54.9
Electrode
class
ERCu
ERCuAl-A2
Gas Metal Arc Solid Electrodes (0.045")
Copper
Average fume
generation
rate. g/kg*
4.9
8.1
% copper Ibs copper released per
in fumes ton total metal deposited
66.0 6.5
70.5 11.4
g/kg - grams of fume per kilogram of total deposited metal.
-------
-16-
Oxvgen Cutting Releases
The following release races are based on information contained in Fumes
and Gases in the Welding Environment (see bibliography). The values shown are
calculated based on the percent metal in the fume and a fume generation rate
of 2.1 grams per meter for oxyacetylene cutting and 0.037 grams per inch for
oxymethane cutting. Releases are affected by the percent of the listed
section 313 chemical present in the metal. The values for carbon steel -are
presented below.
Release rates for oxyacetylene cutting were found to increase and
decrease proportionally with changing plate thickness (e.g., cutting a 2 inch
plate would result in twice the release rate shown in the table below). Rates
of release for oxymethane cutting are independent and not affected by plate
thickness.
Oxyacetylene Cutting Oxymethane Cutting
of Carbon Steel of Carbon Steel
Listed Percent Ibs 313 metal emitted Ibs 313 metal emitted
Section Metal per million feet of per million feet of
313 Metal in Fume cut plate (1" thick) cut plate d" thick)
Ba 0.01 0.14 0.1
Mn 0.3 4.2 2.9
Cr 0.2 2.8 2.0
Ni 0.05 0.7 0.5
Al 0.02 0.3 0.2
V <0.01 <0.14 <0.1
Cu 0.1 1.4 1.0
.Zn <0.1 <1.4 <1.0
Co 0.02 0.3 0.2
Total annual releases of each of the listed section 313 chemicals in the
plate would be found by multiplying the emission factor by the total amount of
cut plate (in million feet/year).
-------
-17-
ESTIMATING EMISSIONS FOR SOLVENT DECREASING OPERATIONS
Many facilities use organic solvents to remove grease, oil, loose metal
chips, and dirt from metal products, equipment, and tools. In the process of
degreasing. organic solvents may be intermixed with air, heated to boiling, or
agitated which will cause the solvent to volatilize. Many organic solvents
used in degreasing are listed under section 313 (e.g., methyl chloride,
perchloroethylene, trichloroethylene, methyl chloroform,
trichlorotrifluoroethane). Facilities that use an organic solvent degreaser
containing a toxic chemical must estimate emissions if the reporting threshold
for otherwise use (10,000 pounds per calendar year) has been exceeded for that
chemical.
Emission estimates may be calculated from the following information:
• Emission factors to translate activity information into fugitive
emission estimates;
• Facility activity rate or volume information (e.g., amount of
product produced, fuel used); and
• Efficiency information on emission control devices to allow
estimation of net releases to the air after emissions pass through
control devices.
The basic fugitive emission estimation formula is:
E - R x EF x (1 - C/100),
where E is the emission estimate for the source, R is the facility
activity rate or volume. EF is the emission factor, and C is the control
devices efficiency.
The table on the following pages has been excerpted from Toxic Air
Pollutant Emissions Factors - A Compilation For Selected Air Toxic Compounds
And Sources (EPA-450/2-88-006a), and contains information on the following
section 313 substances: trichlorotrifluoroethane, trichloroethylene, methyl
chloride, perchloroethylene, and methyl chloroform. For each type of
degreasing operation, the table provides a brief description of the specific
solvent degreasing process and the relevant Standard Industrial Code (SIC
Code) if available, the emission source and appropriate Source Category Code
(SCC), the chemical name and CAS number of the emitted pollutant, the
estimated emission factor, and relevant notes. These emission factors should
only be used if no site-specific or otherwise more accurate data is available
to the facility.
Pollutant emission factors are provided in terms of mass of pollutant per
mass of product produced, generally kilogram per kilogram (kg/kg), and were
derived from a variety of methods, such as source tests, theoretical
calculations, or a combination of the two; so that there is considerable
variation in the quality of the emission factors presented. These estimates
are further clarified by the identification of emission reduction techniques
or controls in place within the degreasing operation used to develop these
emission factors. The notes column provides details on methodology and
assumed pollution reduction techniques.
-------
-18-
INDUSTRIAL PROCESS
Decreasing operations
using MC
Decreasing operations
using MC
Degrees ing operations
using MC
Degress ing operations
using MC
Decreasing operations
using MC
using MC
Degreaslng operations
using MC
Degress ing operations
using MC
Degreasing operations
ualng PCE
Degraaslng operations
using PCE
Degress Ing operations
using PCE
Oagresaing operations
ualng PCE
Dagreaaing operations
using PCE
Oegreaalng operations
ualng PCE
SIC
CODE EMISSION SOURCE
Open top vapor
dagraaaara
Open top vapor
degreesere
Conveyorlxed vapor
degreeaer
Conveyorized vapor
dagraaser
Cold cleanera
Cold cleanera
7530 Carburetor cleanera
7530 Carburetor cleaners
Open top vapor
degreaaara
Open top vapor
decreaaars
Convayorized vapor
dagreaier
Conveyorized vapor
degraaser
Cold cleanera
Cold claanera
sec
40100204
40100204
40100224
40100224
40100302
40100302
40100302
40100302
40100203
40100203
40100223
40100223
40100304
40100304
POLLUTANT
Methylene
chloride
Methylene
chloride
Methylene
chloride
Methylene
chloride
Methylene
chloride
Methylene
chloride
Methylene
chloride
Methylene
chloride
Perchloro-
ethylene
Ferchloro-
ethylene
Perchloro-
ethylene
Perchloro-
ethylene
Perchloro-
ethylane
Perchloro-
athylene
CAS
NUMBER
75092
7S092
75092
75092
75092
75092
75092
75092
127184
127164
127184
127184
127184
127184
EMISSION FACTOR
0 93 kg emit. /kg fresh
(virgin) MC used
0 89 kg emit /kg fresh
(virgin) MC uaed
0 96 kg emit /kg freah
(virgin) MC uaed
0 91 kg emit /kg freah
(virgin) MC used
0 89 kg emit /kg fresh
(virgin) MC uaed)
0 87 kg emit /kg fresh
(virgin) MC uaed
0 89 kg emit /kg fresh
(virgin) MC uaed
0 76 kg emit /kg freah
(virgin) MC used
0 93 kg/kg of fresh
(virgin) PCE used
0 89 kg/kg of fresh
(virgin) PCE uaed
0.96 kg/kg of fresh
(virgin) PCE uaed
0 91 kg/kg of fresh
(virgin) PCE used
0 78 kg/kg of fresh
(virgin) PCE used
0 76 kg/kg of fresh
(virgin) PCE uaed
NOTES
Uncontrolled, considers
recycle, materiel balance
Controlled by refrigerated
freeboard chiller, conaidera
recycle, material balance
Uncontrolled, conalders
recycle, material balance
Controlled by carbon
adaorbar or refrigerated
freeboard chiller, considers
recycle, material balance
Uncontrolled, considers
recycle, based on material
balance
Controlled =07 freeboard
ratio t drainage rack with
15 aacond drain time,
considers recycle, metenal
balance
Uncontrolled, considers
recycle, material balance
Controlled by water cover,
conaldars recycle, material
balance
Uncontrolled, based on
material balance
Controlled by refrigerated
freeboard chiller, based on
material balance
Uncontrolled, baaed on
material balance
Controlled by carbon
adaorbar or refrigerated
freeboard chiller, based on
material balance
Uncontrolled, based on
material balance
Controlled by 0 7 freebouid
ration and drainage rack
•1th 15 aacond drain lime,
baaed on material balance
-------
-19-
INDUSTRIAL PROCESS
Degreaaing opacations
ualns TCE
Dagreealng operations
using TCE
Degreasing operation!
using TCE
Degreaaing oparatlona
using TCE
Dagraailng operations
using TCE
Degreasing operations
using TCE
Degceaaing opaxatlona
using methyl chloroform
Dagraaalng operations
using methyl chloroform
Degreasing operations
ualng methyl chloroform
Dogreaaing operations
using methyl chloroform
Degreasing operations
using methyl chloroform
Degreaslng operations
using methyl chloroform
Degreaelng operatlona
nutria mat.hvl chloroform
SIC
CODE EHISSIOH SOURCE
Open top vapor
degraaaera
Open top vapor
degreaeera
Conveyorlzed vapor
dagreeser
Conveyorlxad vapor
degraaaar
Cold cleanera
Cold cleanera
Entire process
Cold cleaner
Cold cleaner
Open top vapor
degreasera
Open top vapor
degzeeaera
Conveyorized vapor
degraasar
Conveyorlsed vapor
depressor
sec
40100205
40100205
40100223
4010022S
40100306
40100306
40100202
40100202
40100222
40100222
POLLUTANT
Trichloro-
•thylene
Trlchloro-
athylene
Trichloro-
athylana
Trlehloro-
ethylene
Trichloro-
ethylene
Trlchloro-
ethylene
Dlozana, 1,4-
Hathyl
chloroform
Methyl
chloroform
Methyl
chloro£o CD
Methyl
chloroform
Methyl
chloroform
Methyl
chloroform
CAS
NUMBER EMISSION FACTOR
79016 0.93 kg/kg fraih
(virgin) TCE used
79016 0.89 kg/kg fraah
(virgin) TCE used
79016 0.96 kg/kg fresh
(virgin) TCE used
79016 0.91 kg/kg freah
(virgin) TCE ueed
79016 0 84 kg/kg freeh
(virgin) TCE used
79016 0.82 kg/kg fresh
(virgin) TCE used
123911 0.03 Ill/ton methyl
chloroform
71556 O.B6 kg/kg (fresh)
virgin solvent used
715S6 0.84 kgAg (fresh)
virgin solvent used
71SS6 0.93 kgAg (fresh)
virgin solvent used
71336 0.89 kgAg (fresh)
virgin eolvant uaed
71SS6 0.96 kgAg (freah)
virgin solvent used
71356 0.91 kgAg (fresh)
virgin solvent uaed
MOTES
Uncontrolled, based on
material balance
Controlled by above or below
freexing refrigerated
freeboard chiller, based on
material balance
Uncontrolled, baeed on
material balance
Controlled by carbon
absorber or refrigerated
freeboard chiller, based on
material balance
Uncontrolled, based on
material balance
Controlled by 0.7 freeboard
ratio and drainage rack with
IS second drain time, based
on material balance
Baaed on 3 percent weight In
methyl chlorofona
Uncontrolled, considers
recycle, baaed on material
balance
Controlled by 0.7 freeboard
ratio * drainage rack with
IS second drain time,
considers recycle, besed on
material .balance
Uncontrolled, considers
recycle, based on material
balance
Controlled by refrigerated
freeboard chiller, considers
recycle, baaed on material
balance
Uncontrolled, considers
recycle, based on material
balance
Controlled by cerbon
freeboard chiller, considers
recycle, materiel balance
-------
-20-
IHOUSTRIAL PROCESS
SIC
CODE EMISSION SOURCE
SCC
POLLUTANT
CAS
NUMBER EMISSION FACTOR
NOTES
Degreasing operations
using trichloro-
brlfluoroethane
Degreesing operations
using trichlorotri-
fluoroethane
Degreasing operations
using trichlorotri-
fluoroathana
Dagreasing operations
using trlchlorotri-
fluoroethane
Digressing operations
using trlchlorotri-
fluoroethane
Degreasing operations
using trichlorotrl-
fluoroathane
Cold cleaner
Cold cleaner
Open top vapor
degreesera
Open top vapor
degreasera
Conveyorized vapor
degreasera
Conveyorlsed vapor
degreaser
Trichlorotrl-
fluoroethane
Trichlorotrl-
fluoroethane
40100207 Trichlorotrl-
fluoroethane
40100207 Trichlorotri-
fluoroethane
40100298 Trichlorotri-
fluoroethone
40100298 Trichiorotri-
fluoroethane
761131 0.88 kg/kg fresh
(virgin) solvent used
761131 0.86 kg/kg freah
(virgin) solve uaed
761131 0.93 kg/kg freah
(virgin) aolvent uaed
761131 0.89 kg/kg fraah
(virgin) aolvent used
761131 0.96 kg/kg fresh
(virgin) aolvent used
761131 0.91 kg/kg fresh
(virgin) solvent uaed
Uncontrolled, considers
recycle, based on material
balance
Controlled -0.7 freeboard
ratio + drainage rack with
IS second drain time,
considers recycle, material
balance
Uncontrolled, conaidars
recycle, baaed on material
balance
Controlled by refrigerated
freeboard chiller, considers
recycle, based on material
balance
Uncontrolled, considers
recycle, based on material
balance
Controlled by carbon
adaorber or refrigerated
freeboard chiller, considers
recycle, material balance
Source- Tozlc Air Pollutant Emission Factors — A Compilation for Selected Air Toxic Compounds and Sources. EPA 4SO/2-88-006a. Office of Air Quality Planning
and Standards. October 1988. HTIS PB 89-135644.
-------
-21-
ESTIMATING EMISSIONS FROM CHROMIUM ELECTROPLATING OPERATIONS
Chromium electroplating and anodizing operations range in size from small
shops, with one or two tanks that are operated only a few hours per week, to
large shops with several tanks that are operated 2U hours a day, 7 days a
week. These operations can also be separated into captive shops that are part
of a larger manufacturing operation, or job shops that perform these services
for many different clients.
Electroplating consists of the immersion of the base item into a plating
solution, and the passing of a direct current through the solution, causing a
metal to deposit out of the solution and onto the item. There are two types
of electroplating: hard, in which a relatively thick Layer of chromium is
deposited directly on the base metal (usually steel) for use in engine
components, marine hardware, plastic molds, zinc die castings, industrial
rolls, and hydraulic cylinders and rods; and decorative, in which the base
material is plated with a layer of nickel prior to the addition of a
relatively thin layer of chromium, for use in automotive trim, metal
furniture, bicycles, hand tools, and plumbing fixtures.
Chromic acid anodizing consists of the immersion of the base metal,
usually aluminum, in a chromic acid solution and the application of
electricity to produce a film of chromium deposit on the base metal, for use
in aircraft parts and architectural structures that are subject to high stress
and corrosion.
Emissions of chromic acid mist occur due to the inefficiency of the
hexavalent chromium plating process. Only about ten to twenty percent of the
electric current applied to the solution is actually used in the deposition of
the chromium on the item. The vast majority of the electric current is
consumed in the evolution of hydrogen gas, with the resultant liberation of
gas bubbles, which burst at the surface of the plating solution, forming a
fine mist of chromic acid droplets.
The table on the following pages has been excerpted from Locating and
Estimating Air Emissions from Sources of Chromi""1 (Supplement) (EPA-450/2-89-
002), and presents uncontrolled emission data for twelve chromium plating
operations -- ten hard (Plants A - J) and two decorative (Plants K and L).
Process parameters (chromic acid concentration and temperature of the plating
baths) were monitored, and appeared to be representative of typical operation
values for conventional chromium plating operations. These emission factors
should only be used if no site specific or otherwise more accurate data is
available to the facility.
Based on this test data, an uncontrolled emission factor of 10 milligrams
of hexavalent chromium per ampere-hour (mg/Ah) (0.15 grain per ampere-hour
[gr/Ah]) is considered to be representative of uncontrolled emissions from a
hard chromium electroplating operation. An uncontrolled hexavalent emission
factor of 2 mg/Ah (0.03 gr/Ah) is considered to be representative of
uncontrolled emissions from a decorative chromium electroplating operation.
(A more conservative estimate was selected for this emission factor due to the
limited data available).
-------
-22-
UNCONTROLLED EMISSION DATA FOR TOTAL AND HEXAVALENT CHROMIUM FROM
CHROMIUM PLATING OPERATIONS'
Process Conditions Actual Gas
No. of
Plant Tanks
Hard chromium plating
Plant Ab-32 1
Plant B°3 2
Plant Cd-3* 4
Plant De-35 1
Plant Ec-36 1
Plant Ff-37 1
Plant Gc'38 1
Plant He-39 1
Plant I1-*0 2
Total Tank
Surface Area,
»2 (ft2)
5.8
(63)
2.5
(27)
8.4
(90)
5.2
(56)
3.4
(37)
1.8
(20)
1.4
(1.5)
5.5
(60)
9.0
(99)
Flow Rate,
Ampere- m3/mln
Hours (ft3/min)
14,000 226
(7,970)
14,400 152
(5,390)
20,000 339
(12,000)
19,800 177
(6,260)
11.700 190
(6,670)
12,200 128
(4,540)
8,900 95
(3,360)
3,440 242
(8,540)
8,530 290
(10,300)
Mass Emission
Rate, kg/h (Ib/h)
Total Cr
0.029
(0.064)
0.008
(0.018)
a
0.076
(0.167)
a
a
a
0.009
(0.019)
0.100
(0.221)
Cr*b
0.026
(0.057)
0.015
(0.033)
0.039
(0.085)
0.076
(0.168)
0.031
(0.069)
0.083
(0.183)
0.024
(0.053)
s
8
0.090
(0.199)
Process Cr*6 Emission
Rate, mg/A«h (gr/A»h)
4.0 (0.06)
3.2 (0.05)
4.6 (0.07)
9.1 (0.14)
6.3 (0.10)
16.3 (0.25)
6.5 (0.10)
3.6 (O.'06)h
22.5 (0.35)
(continued)
-------
-23-
Plant
Plane Jc-*1
Average
Process Conditions
Total Tank
No. of Surface Area, Ampere -
Tanks m2 (ft2) Hours
3 6.6 8,790
(71)
Actual Gas
Flow Rate,
m3""1"
(ft3/rain)
512
(18,100)
Mass Emission
Rate, kg/h (Ib/h)
Total Cr
0 044
(0.097)
Cr+b
0.046
(0.102)
Process Crt6
Rate, mg/A»h
15.5
9.8
Emission
(gr/A.h)
(0.24)
(0 15)
Decorative chromium plating
Plant Kc-«
Plant Lc-*3
Average
1
1
22.6
(240)
2.9
(30.8)
97,000
6,500
683 e
(24,100)
70
(2,470)
0.066
(0.145)
0.004
(0.008)
2.0 (0.03)
1.3 (0.02)
1.6 (0.02)
performed b the Naval Energy and
" All tests were performed by EPA except for the Plant H test which was
Environmental Support Activity, Port Hueneme, California.
b Ampere-hour and mass emission rate values are based on an average of four test runs.
0 Ampere-hour and mass emission rate values are based on an average of three test runs.
d Ampere-hour and mass emission rate values are based on an average of six test runs.
• Total chromium emissions were not determined.
f Ampere-hour and mass emission rate values are based on an average of five test runs.
8 Hexavalent chromium emissions were not reported.
h Not included in average value because data are based on total chromium.
1 Ampere-hour and mass emission rate values are based on an average of 11 test runs.
Chromic Acid Anodizing Operations
An uncontrolled emission factor of 0.0006 kilogram of hexavalent chromium per hour per square foot of tank
surface (0.00012 pound per hour per square foot of tank surface area) is appropriate to characterize emissions from
chromic acid anodizing.
Source: Locating and Estimating Air Emissions from Sources of Chromium (Supplement).
August 1989
EPA 450/2-89-002.
-------
-24-
IV. SELECT QUESTIONS AND ANSWERS ON PROBLEMS FACED BY THE METAL FABRICATION
INDUSTRY
[Noce: The numbers next to the questions refer to their location in
the EPA document Toxic Chemical Release Inventory Questions and
Answers: 1990 Update (EPA 560/4-90-003).]
DETERMINING WHETHER OR NOT TO REPORT: FACILITY
45. Must a facility Include welding rods, solders, and the metals being
joined during a welding or soldering job in threshold determination?
Yes, however, if no releases occur from the Joined metal parts themselves they
may be considered articles and only the welding rods or solder must be
assessed for threshold purposes.
49. If a facility manufactures 19,000 pounds, processes 18,000 pounds, and
imports 7,000 pounds of chemical X during 1989, is it required to report for
chemical X?
For 1989, the facility would have to report chemical X because it would have
exceeded the manufacture threshold of 25,000 pounds (19,000 (manufacturing) +
7,000 (importing) - 26,000). Note that importing is the equivalent of
manufacturing and therefore the amounts must be added together for threshold
determinations.
53. An airplane engine repair shop (generally SIC 7699) owns an "auxiliary"
facility at a separate location that does metal plating (generally SIC 3471 --
Plating of Metals and Formed Products). Would the plating facility be exempt?
According to the SIC code manual, this plating facility would not be
"auxiliary" but would be considered a separate operating establishment
conducting a manufacturing activity. It would, therefore, need to make the
employee and activity threshold determinations and report, if appropriate,
because it falls between SIC codes 20-39.
DETERMINING WHETHER OR NOT TO REPORT: LISTED CHEMICALS
57. We use a chemical with a CAS number not on the list of section 313 toxic
chemicals. There are similar chemicals on the list, but none with the same
CAS number. How can I be sure I don't have to report?
As a general rule, the facility should focus on the available CAS number of
chemicals present at the facility and compare them to the CAS number listing
of reportable sections 313 chemicals. Be aware, however, that a complex
mixture, such as naphtha, has a specific CAS numbers itself, but may also be
composed of listed section 313 chemicals. Therefore, the facility should use
all available information at the facility, not just the CAS number, when
attempting to identify reportable chemicals in materials. Also, certain
specific chemicals (e.g., copper chloride) may not appear in the CAS number
list but are reportable under a compound category listing (e.g., copper
compounds).
-------
-25-
59. A facility processes aluminum, vanadium, and zinc. These three chemicals
are listed under section 313 with the qualifier "fume or dust." Is this
processing operation subject to reporting?
If the processing of these substances generated (i.e., manufactured) any
fume or dust during its operation or if the three substances were processed or
otherwise used, at any time, as a fume or dust in the operation, the
processing would constitute a reportable use of a listed section 313 toxic
chemical. The manufacturing, processing, or otherwise use of these substances
in fume or dust form would be subject to threshold determinations.
60. If an item on the section 313 list incorporates chemicals with multiple
CAS numbers (e.g., nickel compounds), how is the CAS number of the item
described?
Do not enter a CAS number in such cases. Instead, enter NA in the space for
the CAS number in Part III, Section 1.2 of Form R. The individual chemical
members of a listed category are not required to be, and should not be,
identified in the report.
61. Do the chemical categories such as nickel compounds include all
compounds, even those which have not been associated with adverse health
effects? What is the authority for this decision?
The section 313 list established by Congressional legislation included
categories. EPA interprets these listings to mean all compounds of nickel for
example, regardless of whether specific toxicological problems have been
identified for a specific compound in the category.
77. I use copper wire in one of my products. I cut it and bend it and then
heat seal it into a glass bulb. How do I consider the copper wire for section
313 reporting?
First, the wire would remain an article if no releases of copper (e.g., dusts)
occur during manufacture of the glass bulbs. If the wire is not an article,
then for an element such as copper, both copper metal and copper compounds are
subject to section 313 reporting. First determine the form of copper in the
wire. If it is pure copper wire, the entire weight of the wire must be used.
If it is an alloy, the weight percent times the wire weight must be used. If
there are copper compounds, the entire weight of each copper compound must be
used for threshold determination.
81. For section 313 reporting, a catalyst contains 61 percent total nickel.
which includes 26 percent free nickel and nickel contained in compounds.
Should the threshold determination be based on the 61 percent total nickel?
The 61 percent total nickel cannot be used in the threshold determinations.
Nickel compounds are a listed category, therefore the full weight of nickel
compounds must be used in the threshold determination for nickel compounds. A
separate threshold determination is required for the free nickel since nickel
is a separately listed chemical under section 313.
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85. A product is immersed into a placing bath containing nickel chloride
(NiCl). This is done to bond nickel to the product prior to distribution in
commerce. Nickel is incorporated into the final product (processed) whereas
the chloride remains in the plating bath (otherwise used). Since nickel
chloride is reportable under the nickel compound category of section 313,
which threshold applies for this situation?
The threshold determination is made based on the total amount of nickel
chloride processed and the report will be filed for nickel compounds.
MIXTURES
91. If a facility only knows the range of concentration of a section 313
chemical in a mixture, are they required to use the upper bound concentration
to determine threshold as stated in the February 16, 1988 Federal Register?
Use of the average or midpoint of the range will avoid overestimating
emissions. If a metal mixture contains a range of 1 to 10 percent of three
metals together, how can this information be used to determine thresholds?
The final rule does not discuss ranges, it only says that the upper bound
should be used "if the person knows only the upper bound concentration". If a
range is available, using the midpoint or average value is reasonable. For
the combination of three chemicals, the facility should split the range among
the three chemicals based on the knowledge that they have, so the total equals
10 percent. They do not have to assume 10 percent maximum for each chemical.
SUPPLIER NOTIFICATION
94. Is a facility subject to supplier notification requirements if it
distributes products containing more than the de minlmis level of a listed
metal compound?
Yes, if you distribute these products to other manufacturers or processors,
and you are in SIC Codes 20-39, you are subject to the supplier notification
requirements. Articles and consumer products are exempt from supplier
notification.
95. Do supplier notification requirements apply only to a situation where the
customer is In SIC code 20 through 39 and has more than 10 employees?
A company is responsible for providing supplier notification to a covered
facility within SIC codes 20-39 and with 10 or more employees, and to
customers who in turn may sell or distribute to a "covered facility." Such a
customer may be a wholesale distributor who is not in SIC codes 20 - 39 but
sells to other manufacturing facilities.
110. If a mixture contains a chemical compound that is a member of a
reportable section 313 chemical category, how should that be addressed on the
supplier notification? Is it acceptable to provide the percent of the parent
metal?
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If a mixture contains a chemical compound (i.e.. 12% zinc oxide) that is
a member of a reportable chemical category (i.e., zinc compounds), the
supplier is required to notify his customers that the mixture contains a zinc
compound at 12% by weight. Supplying only the weight percent of the parent
metal (zinc) does not fulfill the requirement, but may be done to aid
receiving facilities in estimating releases. The customer muse be told the
weight percent of the entire compound for threshold determinations.
ACTIVITIES AND OSES OF THE CHEMICAL AT THE FACILITY
125. A process at a facility draws steel rods into a smaller diameter. Is
this manufacture, process, or otherwise use? How do I report?
This activity is considered processing because the toxic chemical remains
incorporated in the final product distributed in commerce. Only apply the
amount of each chemical in the rods processed toward the applicable activity
threshold if the toxic chemical is present above the de minimis level.
128. We have purchased in excess of 100,000 pounds of aluminum material in
block fora to make a mold which stays on site. When making the mold, fumes
and dust are a byproduct. Do we report aluminum as the chemical?
Aluminum appears on the list of chemicals as "aluminum (fume or dust)". You
must determine if you manufacture, process, or use aluminum fume or dust. In
this case, you are not processing or using, but do "manufacture* aluminum fume
or dust coincidentally as a byproduct of making molds. Therefore, you must
report for aluminum (fume or dust) if you exceed the 25,000 pound
manufacturing threshold for the reporting year.
129. A facility melts aluminum ingots, reshapes them, and injects them into a
die to form parts. Does the 25,000 pounds processing threshold apply to the
amount of molten aluminum processed?
For calendar year 1989, the 25,000 pounds threshold applies to the amount of
aluminum fume or dust generated at the facility, not the aluminum in molten
(liquid) or solid form. Therefore, the facility must determine whether they
produce more than 25,000 pounds of aluminum fume or dust air emissions in
their processing operation.
130. A remanufacturer of auto engines cleans the engine parts and thereby
produces a lead-containing waste (from gasoline lead deposits). Are they a
manufacturer, processor, or otherwise user of lead compounds?
The facility neither manufactures, processes, nor otherwise uses lead. Lead
is not incorporated into products for distribution nor is it a manufacturing
aid or a processing aid as those terms are defined. Lead in the waste would
not be included for threshold determination.
132. If a solvent is used in a process and 85 percent evaporates but
15 percent stays vith product, is this processing or use? The 15 percent was
not necessarily intended to stay with the product.
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In this case, the entire quantity of the solvent should be considered
"otherwise used" and subject to the 10,000 pound threshold. If the solvent
was intended to remain in the product, this would be processing.
133. Is soldering light bulbs using lead solder considered processing of the
solder?
Yes, it incorporates the solder into a product for distribution in commerce.
134. An electroplating facility uses metal cyanide compounds in their
electroplating operations. Are they processing or using those cyanide
compounds, and how do they determine whether they meet the threshold and which
threshold applies?
The parent metal from the metal cyanide compound is plated onto a substrate
electrochemically, leaving the cyanide as waste product. The parent metal is
"processed", while the cyanide is "otherwise used". Metal cyanides are
reportable under section 313 as both cyanide compounds and metal cyanides.
Select the threshold based on the action that involves the portion of the
compound that identifies the category (i.e., cyanide for cyanide compounds).
The total weight of the compound counts for both the metal cyanides threshold
and the cyanide compound threshold.
138. A facility uses a chrome anode in an electroplating bath of sulfuric
acid to plate chrome onto fabricated metal. Chromium compounds are generated
in the bath and some chrome is deposited onto the fabricated metal part. The
unutilized compounds are sent to the facility's waste treatment process, where
hexavalent chromium is reduced to trivalent chromium. How are these reduced
compounds counted for section 313 threshold determination?
The threshold determination for chromium compounds is based upon the
amount of chromium compounds generated in the plating bath. Any subsequent
transformations of hexavalent to trivalent chromium compounds as a result of
waste treatment does not affect the threshold determination. To do so would
involve double counting.
139. A company processes a galvanized sheet metal containing elemental zinc,
not a zinc compound. When the sheet metal is processed it generates zinc
dust, all of which is captured and sent off-site for recycle. Can the company
claim an exemption because the sheet metal remains an article, or must it do a
threshold determination because it has coincidentally manufactured zinc (fume
or dust)?
Though the sheet metal remains an article during the processing of the
sheet metal, zinc (fume or dust), a listed chemical, is manufactured. This
release negates the article exemption. The recycle/reuse exemption does not
apply to cases of manufacture. The company would have to make a threshold
determination based upon the quantity of zinc dust generated. The amount sent
off-site for recycle is not reporcable, being the equivalent of a product sold
in commerce. Any amount not recycled would also be a reportable release.
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141.- 'Paint containing listed chemicals is applied to a product and becomes -
part of-an article. Does the 25,000 pound threshold apply? What about the
volatile chemicals from the painting operation -- are they "otherwise used."
thus subject to the 10,000 pound threshold?
Yes to both questions. This is a case in which listed chemicals in the
same mixture may have different uses and, therefore, different thresholds.
The listed chemicals that are incorporated as part of the coating are
"processed,• whereas the volatile solvents in the paint are "otherwise used"
because they are not intended to be incorporated into the article.
152. Hov is routine maintenance defined In the exemption list? Is equipment
maintenance included?
Equipment maintenance such as the use of oil or grease is not exempt. 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 to maintain lawns, in
the same form and concentration commonly distributed to consumers. Painting
of equipment is exempt because the paint becomes part of the structure of the
facility.
EXEMPTIONS
154. The "structural component" exemption from section 313 reporting covers
the small amounts of abraded/corroded metals from pipes and other facility
equipment. Would the structural component exemption apply to equipment which
regularly suffers abrasion, such as grinding wheels and metal working tools?
What criteria can a facility use to decide which pieces of equipment are
structural components and which are not?
The section 313 structural components exemption would not apply to
grinding wheels and metal working tools. These items are intended to wear
down and to be replaced because of the nature of their use. The structural
component exemption applies to passive structures and equipment such as pipes.
The abrasion/corrosion includes normal or natural degradation, such as occurs
in pipes, but not active degradation, such as occurs in a grinding wheel.
155. A facility uses welding rods to maintain its equipment. The painting of
equipment is exempt because the paint is intended to become part of the
structure. Are welding rods used to maintain equipment exempt because the
materials are intended to become part of the facility?
Welding rods used to repair and maintain equipment would be exempt from
reporting under section 313 because they are becoming a fixed part of the
structure of the facility. In this way, they are similar to paint, and unlike
some replaceable maintenance materials like oil or grease. The term
"facility" includes all buildings, equipment, structures and other stationary
items located on a single site, or on contiguous or adjacent sites.
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174. A facility uses a chemical mixture that contains a toxic chemical. If
the maximum and minimum concentrations listed on the MSDS range above and
below the de minimis concentration levels, how can the facility determine
quantities for section 313 compliance?
The amount of the chemical in the mixture that is present above the de minimis
level and therefore counts toward the threshold, can be assumed to be
proportional to the ratio of the above-de minimis concentration range to the
overall concentration range. The concentration of the chemical in the mixture
that is not exempt is the average of the de minimis level and the maximum
concentrat ion.
178. A facility cuts metal sheets containing nickel, releasing fumes. It
then further grinds the metal to its final shape, producing grindings. For
the sheets to retain their article status, releases must be less than 0.5
pound/year to any media. Does this cut-off value apply to aggregate releases
of the same type of item being processed or used in the same way or to
releases from all manners of processing or use of the same type of item?
The 0.5 pound/year release cut-off value applies to aggregate releases
from the same type of item being processed or used in all manners at the
facility. This value applies to the total aggregate releases of the toxic
chemical from both steps of the process. The various shapes resulting from
the cutting are "the same type of item" as the initial sheet. Thus any
releases from grinding should be added to those from cutting.
180. Ve take copper wire, cut it, and wind it around smaller spools. Is the
wire still an article?
If there is no release of a toxic chemical during normal processing of the
copper wire, then the wire remains an article.
181. I run a metal fabrication facility, SIC code 34. If I cut the metal
sheets and send the shavings off-site for reuse, can I consider the metal
sheets articles?
If the shavings that are formed during the cutting are the sole releases, and
if all the shavings are sent off-site for reuse, and the thickness of the
metal sheet does not change during processing, then the metal sheets are still
considered articles and are exempt.
182. Is bar stock that is used to make precision tuned parts an article and
thus exempt from section 313 reporting? The bar stock is processed to produce
parts that in whole or in part retain the basic dimensional characteristic of
the bar stock. The production of the part itself is dependent upon the
specific shape and dimension of the bar stock.
Bar stock is an article if its basic dimensional characteristics are
maintained in whole or in part in the finished product and zero releases
occurring during processing. If the end product is totally different in
diameter or thickness, then the bar stock would not be an article.
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183. Can facilities which extrude copper bars or rods into wire treat the bar
or rod as an article?
No, an article has end use functions dependent in whole or in part upon its
shape or design during end use. The end use function is dependent upon the
copper being in the shape of the wire, so the copper bar cannoc be considered
an article. If you are changing the shape or form of an item substantially,
you are processing the chemicals; the article exemption no longer applies.
RELEASES OF THE CHEMICAL
192. Is the disposal of wastes such as dusts, shavings, or turnings that
result from grinding or drilling of metal items considered "releases of toxic
chemicals"?
Yes, such releases of "non-recognizable" solid wastes such as dusts, shavings,
or turnings are considered releases of toxic chemicals.
197. A facility discharges waste containing listed section 313 metals to an
on-site cooling pond. The metals accumulate and settle over time, and the
water is then drained from the cooling pond, leaving the heavy metal sludge.
The sludge is then dredged and sent off-site to a recycler. How should this
be reported?
The ultimate disposal of listed chemicals from the facility during the
reporting year must be reported. Chemicals remaining in the sediments are
"released to land." Chemicals sent to a receiving stream when the waste water
is drained are "released to water." Materials dredged and sent off-site for
recycle of the chemical are not reported as a release or transfer; others sent
off-site not for recycle are reported as a "transfer off-site."
201. Our facility paints metal cabinets and the paint solvents contain a
listed toxic chemical. The system consists of a closed vacuum vented painting
room and a closed oven room vented by an oven stack. Is the vent to the
outside of the building over the painting room a "releases from building
ventilation systems" fugitive emission?
No, fugitive releases are emissions that are not in a confined directional air
flow. Since your building vent system over the painting room is a confined
air stream, it can be combined with the oven stack as a stack or point
emission in Part III, Section 5.2 of Form R.
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V. BIBLIOGRAPHY OF REFERENCE SOURCES
Fumes and Gases in the Weldine Environment. 1979, American Welding Society,
P.O Box 351040, Miami, FL 33135, phone (305) 443-9353 ($48 for members, $64
for non-members) .
NIOSH Criteria For * fio^onmionriori Standard: Welding. Brazing,
Cutting. April 1988, National Institute for Occupational Safety and Health,
1-800-356-4674, no charge.
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (EPA 560/4-88-002). Suggested methods on the
development of release estimates and waste treatment efficiency calculations
required on Form R. Available from: Superintendent of Documents, Government
Printing Office, Washington, DC 20402-9325, (202) 783-3238, Stock Number:
055-000-00270-3, $11.00.
Compilation of Air Pollution Emission Factors, Volyqe 1. Stationary Point and
Area Sources. Fourth Edition (AP-42). Available from: Superintendent of
Documents, Government Printing Office, Washington, DC 20402-9325, (202) 783-
3238, Stock Number: 055-000-00251-7, $20.00.
Locating and Estimating Air Emissions from Sources of Chropi|'"^ f Supplement) .
August 1989, (EPA 450/2-89-002). Available from: National Technical
Information Service (NTIS) . 5285 Port Royal Road. Springfield, Virginia
22161, (703) 487-4650, Stock Number: PB 90-103243, $15.95.
EPA Development Docttn|ents for Effluent Limitation Guidelines are available
from NTIS or the Government Printing Office. These documents contain
industry- specific information concerning chemicals in wastewater.
NTIS #
Coil Coating. Phase I. (EPA 440/1-82-071) PB83-205542
Coil Coating. Phase II - Can Making. (EPA 440/1-83-071) PB84-198647
Electroplating -- Pretreatment. (EPA 440/1-79-003) PB80-196488
Electroplating -- Copper. Nickel.
Chrome, and Zinc. (EPA 440/1-74-003A) PB-238834/F
Metal Finishing. (EPA 440/1-83-091) PB84-115989
Copper Forming. (EPA 440/1-84-074) PB84-192459
A complete list of the industries is available from: Superintendent of
Documents Government Printing Office, Washington, D.C. 20402, (202) 783-
3238. All Development Documents for Effluent Limitation Guidelines are
available for review and inspection at the EPA Regional Office Libraries.
Toxic Air Pollutant Emission Factors -- A Compilation for Selected Air Toxic
Compounds and Sources. (EPA 450/2- 88 -006a) October 1988. Available from:
National Technical Information Service (NTIS), 5285 Port Royal Road,
Springfield, Virginia 22161, (703) 487-4650, Stock Number: PB 89-135644.
EPA has published a group individual guidance documents that target activities
industries who primarily process or otherwise use listed toxic chemicals. The
following are relevant to Che metal fabrication industry and are available for
no charge from: Section 313 Document Distribution Center, P.O. Box 12505,
Cincinnati, OH 45212.
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Estimating Chemical Releases from Roller. Knife, and Gravure Coating.
(EPA 560/4-88-004j) February 1988.
Estimating Chemical Releases from Eleccrodeoosition of Organic Coatings.
(EPA 560/4-88-004c) January 1988.
Estimating Chemical Releases from Electroplating Operations.
(EPA 560/4-88-004g) January 1988.
Estimating Chemical Releases from Spray Applications of Organic Coatings.
• m * t± f m A M 4«4*« • t • « 4* j« «•
(EPA 560/4-88-004d) January 1988.
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