United States Office of Information March 2001
Environmental Protection Analysis and Access
Agency
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS
Reporting Year 2000
Spring 2001
TWO-DAY WORKSHOP
Module 3: TRI Update
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TRAINING DISCLAIMER
This document was developed for the sole purpose of helping potential reporters
understand and comply with the reporting requirements of section 313 of the Emergency
Planning and Community Right-To-Know Act (EPCRA). Nothing in this document is intended
to independently alter, supplement, or revoke the statutory and/or regulatory requirements
imposed by EPCRA section 313 and the applicable regulations at 40 CFR 372, et seq. Although
these training materials provide an overview of the section 313 reporting requirements, facilities
should consult the statute and regulations when developing threshold determinations and
calculating releases and other waste management amounts. Facilities should be aware that EPA
also provides guidance documents containing both sector specific guidance and guidance on
specific elements of the EPCRA section 313 program! Covered facilities are encouraged to
consult these guidance documents for additional assistance. Facilities may also receive
specifically for Reporting Year 2000, for reports due on July 1,2001. Facilities should be aware
that EPA may promulgate regulatory changes to the EPCRA section 313 program that may alter
reporting requirements for future reporting years.
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TRI UPDATE
TRI UPDATE
TRI expansion
Chemical list changes
Reporting form changes
Guidance
Form R submissions/revisions
N-2
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INDUSTRY EXPANSION
TRI now covers seven new industries (metal mines, coal
mines, electricity generating facilities, petroleum bulk
terminals, chemical distributors, solvent recyclers, &
hazardous waste treatment and disposal facilities)
First Form R reports were due by July 1,1999
EPA has prepared guidance documents for specific
industries
New supplier notification requirements for facilities in SIC
codes 20-39
EPA revised definition of "otherwise use" to include on-site
disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction of wastes received
from off-site
N-3
INDUSTRY EXPANSION
EPA considering petition to add SIC code 45,
Transportation By Air (February 10,1998; 63 FR
6691)
EPA also considering elimination or modification of the
motor vehicle exemption and otherwise use exemptions
N-4
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CHEMICAL LIST CHANGES
Phosphoric acid deleted, effective RY 1999
Vanadium (except when contained in alloy) and
vanadium compounds added, effective RY 2000
Certain PBT chemicals added, effective RY 2000, in
the PBT final rule (October 29,1999; 64 FR 58666)
N-5
CHEMICAL LIST CHANGES
Final rule designates lead and lead compounds as
PBT chemicals (January 17,2001; 66 FR 4500)
Lead (except when contained in steel, brass and bronze
alloys): 100 pound threshold
Lead compounds: 100 pound threshold
Reporting begins RY 2001, Form R reports due by July 1,
2002
N-6
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CHEMICAL LIST CHANGES
Proposal to add diisononyl phthalate (DINP)
category, a plasticizer (September 5, 2000; 65 FR
53681; extension of comment period to February 2,
2001 - November 21, 2000; 65 FR 69888)
N-7
REPORTING FORM CHANGES
New for RY 2000
New Federal Information Processing Standards (FIPS)
codes for Section 6.2 transfers to foreign countries
New identifier (check box) for GOCOs (government owned
contractor operated facilities)
New section for distribution of each member of the dioxin
and dioxin-like compounds category in Part II, Section 1.4
New option to check "Processing as an impurity" in Part II,
Section 3.2
First SIC code box identified as primary SIC code
N-8
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GUIDANCE
New TRI guidance documents for the following
industries:
Rubber and Plastics Manufacturing
Printing, Publishing and Packaging Industry
Textile Processing Industry
Leather Tanning and Finishing Industry
Semiconductor Industry
Spray Application and Electrodeposition of Organic
Coatings
N-9
TRI ASSISTANCE LIBRARY
TRI Assistance Library (TRIAL) is with EPA's
Automated TRI Reporting Software (ATRS) for RY
2000. TRIAL is a self-contained help system that
includes:
Electronic versions, or links to electronic versions, of the
statutes, regulations, executive orders, chemical-specific
guidance documents, and industry-specific guidance
documents
Keyword and full text search capabilities on these guidance
documents
Links to the EPA websites, including EPA's homepage, TRI
website, and other useful websites that will assist with TRI
reporting
N-10
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TRI MADE EASY (TJRI-ME)
TRI-ME is an interactive, user-friendly, intelligent
software that guides facilities through the entire
EPCRA Section 313 reporting experience, including
one-stop guidance searching exercises, compliance
determination calculations, and forms completion
For facilities required to report, TRI-ME provides
links to guidance for each data element on the
reporting forms
For RY 2000, TRI-ME distribution will be limited to a
pilot release
N-11
FORM R SUBMISSIONS/REVISIONS
Reminder: .
To be included in the TRI Explorer version
distributed with the most current TRI data release,
voluntary revisions must be submitted by July 31 of
the same year as the reporting deadline
N-12
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FORM R SUBMISSIONS/REVISIONS
Reminder:
Form R submitted to replace previously filed Form A
Considered to be a late submission of a Form R and a
request for a withdrawal of the previously filed Form A
Do not check the revision box!
N-13
THRESHOLD GUIDANCE
Reminder:
Section 313 chemicals coincidentally manufactured
(including from exempt otherwise use activities)
must be considered towards the manufacturing
threshold
Acid aerosols and metal compounds manufactured as by-
products of fuel combustion
N-14
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THRESHOLD GUIDANCE
Reminder:
For threshold determinations, the definitions of
"manufacture," "process," and "otherwise use" currently
do not include Section 313 chemicals that are:
Remediated
Demolished
Treated in wastes generated on site
Stored
Recycled on-site for use on-site
Transfers sent off-site for further waste management (not
including recycling)
These activities do not constitute threshold activities N-15
EXEMPTION GUIDANCE
Reminder:
Section 313 chemicals in gasoline used to refuel
motor vehicles not operated by the facility are
considered processed and do not qualify for the
motor vehicle maintenance exemption
Laboratory activities exemption only applies to
certain activities that take place in a laboratory
N-16
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EPCRA SECTION 313
LIST OF TOXIC CHEMICALS
SECTION 313 LIST OF CHEMICALS
AND CHEMICAL CATEGORIES
Current list contains over 600 individual chemicals
and chemical categories (§372.65)
Top ten chemicals for RY1998 based on total waste
(from manufacturing facilities)
1. Zinc compounds 6. Toluene
2. Nitrate compounds 7. Xylene (mixed isomers)
3. Methanol 8. N-hexane
4. Ammonia 9. Copper compounds
5. Manganese compounds 10. Chlorine
O-2
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SECTION 313 LIST OF CHEMICALS AND
CHEMICAL CATEGORIES
Dynamic, evolving list
Additions
Deletions
Modifications
Petition process to add or delete chemicals or forms
of chemicals
0-3
SECTION 313 CHEMICAL QUALIFIERS
Qualifiers - Listed chemicals with parenthetic qualifiers subject
to TRI reporting only if manufactured, processed, or otherwise
used in specified form (§372.25(g)). Below are some examples:
CHEMICAL CAS* QUALIFIER
Aluminum 7429-90-5 Fume or dust
Aluminum oxide 1344-28-1 Fibrous forms
Asbestos 1332-21-4 Friable forms
Isopropyl alcohol 67-63-0 Manufactured by strong acid process
Phosphorus 7723-14-0 Yellow or white
Saccharin 81-07-2 Manufacture only
Sulfuric acid 7664-93-9 Acid aerosols
Vanadium 7440-62-2 Except when contained in alloy .
Barium Compounds N040 Does not include barium sulfate
0-4
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CHEMICALS ADDED BY THE PBT
CHEMICAL RULE
Additions to TRI list effective January 1, 2000,
reports due July 1,2001
Benzo(g,h,i)perylene
Benzo(j,k)fluorene (fluoranthene) & 3-methylcholanthrene
added as part of polycyclic aromatic compounds (PACs)
category
Octachlorostyrene
Pentachlorobenzene
Tetrabromobisphenol A (TBBPA)
Dioxin and dioxin-like compounds category
Vanadium compounds
O-5
CHEMICAL LIST DELETIONS
Phosphoric acid deleted - effective RY 1999 (June
27, 2000; 65 FR 39552)
Proposed for deletion
Chromite ore mined in the Transvaal Region of South Africa
and the unreacted ore component of the chromfte ore
processing residue (COPR) (final rule expected March 2001)
Petitions to delete denied
Methyl ethyl ketone (MEK)
Methyl isobutyl ketone (M1BK)
Acetonitrile
O-6
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MODIFIED CHEMICAL LISTINGS
Vanadium (fume or dust) is now vanadium (except
when contained in alloy)
Effective RY 2000
Ammonia
Requires threshold determination and release and other
waste management quantity calculations for aqueous
ammonia from any source (i.e., anhydrous ammonia in
water or water dissociable ammonium salts) be based on
10% of the total ammonia present in aqueous solutions
Anhydrous ammonia - include 100% for thresholds and
releases
» Including air releases from aqueous ammonia
Effective RY 1994
0-7
MODIFIED CHEMICAL LISTINGS
Glycol ethers category
Removed surfactant glycol ethers from category (July 5,
1994; 59 PR 34386)
Common glycol ethers still in category include:
» 2-Butoxyethanol (CAS # 111-76-2)
» Diethylene glycol monoethyl ether acetate
(CAS #112-15-2)
» Diethylene glycol monobutyI ether (CAS #112-34-5)
Effective RY 1993
O-8
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NITRATE COMPOUNDS
Water dissociable nitrate compounds category
For threshold determinations, use the weight of the entire
nitrate compound
Calculate only the weight of the nitrate ion portion when
calculating releases and other waste management
quantities
Nitrate compounds are produced most commonly when
nitric acid is neutralized
Includes compounds like sodium nitrate, silver nitrate, and
ammonium nitrate
O-9
DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
Example:
20,000 pounds of nitric acid (HNO3) are neutralized with
sodium hydroxide (NaOH) in an on-site wastewater
treatment system. Perform a threshold determination for
nitrate compounds (water dissociable; in aqueous
solution):
Assume:
» Neutralization 100% complete and generates sodium
nitrate (NaNO3), which is released to a waterbody
» Molecular weight (MW) of HNO3 = 63
»MWofNaN03 = 85
» 1 mole of HNO3 generates 1 mole of NaNO3
O-10
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DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
Example (continued):
Quantity of NaNO3 manufactured = quantity of HNO3
neutralized x (MW of NaNO^MW of HNO3)
Quantity of NaNO, manufactured = 20,000 Ibs. x (85/63)
Quantity of NaNO, manufactured = 26,984 Ibs.
The 25,000 pound manufacturing threshold is exceeded!
O-11
CALCULATING RELEASES FOR
NITRATE COMPOUNDS
Example (continued):
Releases are reported on nitrate ion (NO3-) basis. Calculate the
quantity of nitrate ion (MW of NO3- = 62) released to a
waterbody:
Lbs. of NO3 = Ibs. of NaNO3 x (MW of NO3VMW of
NaNO3)
Lbs. of NO3- = 26,984 Ibs. x (62/85)
Lbs. of NO3- = 19,682 Ibs. (rounded to 20,000 Ibs.)
O-12
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NON-METAL COMPOUND CATEGORIES
Consider the entire weight of the compounds in
these categories when determining thresholds
Include the entire weight of the compounds in the
category when calculating releases and other waste
management quantities for all compounds in these
categories
O-13
XYLENE AND XYLENEISOMERS
If data do not specify o-, m-, or p- isomers of xylene,
calculate thresholds, release and other waste
management quantities based on "xylene (mixed
isomers)"
If data specifies o-xylene, m-xylene, or p-xylene
individually, calculate thresholds, release and other
waste management quantities based on the
individual isomers
If thresholds are exceeded for more than one isomer,
releases and other waste management quantities can be
consolidated in one report as "xylene (mixed isomers)"
Same logic applies to cresol, toluene diisocyanates
O-14
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ADMINISTRATIVE STAYS
No reporting required for the following chemicals
until further notice
2,2-Dibromo-3-nitrilopropionamide (DBNPA)
(CAS #10222-01-2)
» Effective RY1995
Hydrogen suffide (CAS #7783-06-4)
» Effective RY 1994
Methyl mercaptan (CAS # 74-93-1)
» Effective RY 1994
O-15
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EXERCISE 5:
CALCULATING RELEASES OF AMMONIA AND NITRATE COMPOUNDS
During the calendar year, a facility uses 200,000 pounds of nitric acid solution containing 50
percent (by weight) nitric acid (HNO3) in an etching operation. All of the nitric acid is eventually
transferred to an on-site treatment facility as part of an aqueous waste stream. The nitric acid is
neutralized with pure (gaseous) anhydrous ammonia (NH3). The facility uses an excess of
ammonia to assure complete neutralization to pH 8. During the calendar year, the facility used
30,000 pounds of ammonia. As a result of the treatment process, a nitrate compound, ammonium
nitrate (NHUNOs), is formed. The ammonium nitrate and any remaining ammonia are then
released to a waterbody.
Using the additional information below, complete questions a through d.
Assumptions
For simplicity, assume air emissions are zero.
Chemical Name Molecular Weights
Ammonium nitrate (NHJSfOs) = 80.04 Ib/lbmol
Ammonia (NH3) = 17.03 Ib/lbmol
Nitric acid (HNO3) = 63.01 Ib/lbmol
Nitrate ion (NO3~) = 62.01 Ib/lbmol
Chemistry Fundamentals
Nitric acid (HNO3) and anhydrous ammonia (NH3) are monovalent and react in a 1:1 ratio. One
mole of NH3 is used to neutralize each mole of HNO3 treated. When neutralized with anhydrous
ammonia, nitric acid (HNO3) produces ammonium nitrate (NH4NO3) in a 1:1 ratio. These
substances are monovalent, so for each mole of HNO3 neutralized, one mole of Nt^NOs is
produced. As indicated in the following formula:
HNO3 + NH3 * NH4NO3
Therefore, 63.01 pounds of nitric acid reacts with 17.03 pounds of ammonia to produce 80.04
pounds of ammonium nitrate (which contains 62.01 pounds of nitrate ion).
a) Based on the above scenario and information available, determine which Section 313
chemicals would be subject to TRI threshold and release determinations.
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b) Calculate the quantity of nitric acid applied towards threshold determinations and
release calculations.
c) Calculate the quantity of ammonia applied towards threshold determinations
and release calculations.
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d) Calculate the quantity of ammonium nitrate applied towards threshold
determinations and release calculations.
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ACID AEROSOL AND FUEL
COMBUSTION REPORTING
ACID AEROSOLS
Suifuric acid/hydrochloric acid (acid aerosols
including mists, vapors, gas, fog, and other airborne
forms of any particle size)
Suifuric acid listing modified, effective RY 1994
Hydrochloric acid listing modified, effective RY 1995
P-2
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ACID AEROSOLS THRESHOLD
DETERMINATIONS
Manufacture (e.g., acid aerosols manufactured from
non-aerosol acid solutions and as by-products of
combustion)
Processing (e.g., acid aerosol or a reaction product
is incorporated into a product for distribution into
commerce)
Otherwise Use (e.g., acid aerosol used, such as
spray application for etching, cleaning, neutralizing,
without incorporation into a product)
P-3
ACID AEROSOLS THRESHOLD
DETERMINATIONS
Acid reuse systems (sulfuric and hydrochloric acid only)
Acid aerosol manufactured and otherwise used
Simplified method of estimating quantity for threshold
determination:
Total Amount of + Total Virgin Acid
Acid in Reuse System Added in RY
= Amount Acid Aerosols Manufactured/Otherwise Used
See EPA's Guidance for Reporting Sulfuric Acid(Ref. 1)
for specific calculations
P-4
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ACID AEROSOLS TREATMENT FOR
DESTRUCTION
Acid aerosols removed by scrubbers
Acid aerosols removed by scrubbers are converted to a
non-reportable form
Report the quantity removed by the scrubber as treatment
for destruction
P-5
ACroS FORMED DURING COMBUSTION
Hydrochloric acid aerosols and hydrogen fluoride form during
the combustion of fuels/wastes containing chlorine and
fluorine
See EPA's EPCRA Section 313 Industry Guidance:
Electricity Generating Facilities (Ref. 2) for emission factors
Sulfuric acid aerosols form in stacks from combustion
processes of fuel oil, coal, and other sulfur-containing fuels
Water and sulfur trioxide, products of fuel combustion, react
quickly to form sulfuric acid in the presence of moisture
See EPA's EPCRA Section 313 Guidance for Reporting
Sulfuric Acid (Ref. 1) for specific calculations
P-6
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COMBUSTION
Section 313 chemicals may be coincidentally
manufactured during combustion of:
Oil
Coal
Natural gas
Waste
Other materials
P-7
COMBUSTION - MANUFACTURING
Examples of manufactured chemicals:
Hydrochloric acid aerosol, sulfuric acid aerosol
Hydrogen fluoride
Metal compounds and metals (e.g., vanadium compounds,
mercury)
Organics
PBT chemicals such as dioxin, PACs, mercury
De minimis does not apply
Most other exemptions do not apply
P-8
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COMBUSTION - OTHERWISE USE
Combustion of fuel is also otherwise used
De minimis (non-PBT chemicals only) and other
exemptions could apply
Example:
1,2,4-trimethylbenzene and n-hexane in No. 2 fuel oil
P-9
COMBUSTION & METAL COMPOUNDS
Metal compounds and elemental metals in fuel are
typically converted to metal oxide form
Elemental metal may also be manufactured (e.g.,
mercury)
If no other data available, assume compound is
lowest weight oxide that could be manufactured
from metal
Example:
Nickel in fuel -» Assume NiO not Ni2O3 is manufactured
P-10
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COMBUSTION & METAL COMPOUNDS
Amount of metal compound manufactured is
determined by the total weight of the compound,
not the parent metal
Be comprehensive: include all metal compounds
and all combustion units and any other activities
that may manufacture metal compounds
Releases and other waste management estimates
are based on the weight of the parent metal
METAL COMPOUNDS
Example calculation:
During the year, a facility burns 70,000 tons of coal with a
manganese (Mn) concentration of 141 micrograms/gram
(ppm)
Lowest weight Mn oxide compound manufactured = MnO
Molecular weight Mn = 55
Molecular weight MnO = 71
Does the facility exceed the manufacturing threshold for
manganese compounds?
P-12
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METAL COMPOUNDS
Amount MnO manufactured
= amount coal x concentration Mn x MWMn0/MWMn
= 70,000 tons x 2,000 IbsJton x 141 ppm x 71/55
= 25,483 Ibs. manganese compounds
Threshold exceeded
P-13
METAL COMPOUNDS IN COAL
Sources of data for calculating amounts manufactured
Fuel analysis, fuel specifications, or other supplier information
U.S. Geological Survey's (USGS) coal quality data base. Available at
http://energy.er.usgs.gov/products/databases/CoalQual/
Electrical Power Research Institute's (EPRI) PISCES data base on
coal constituents
Tables in EPA's EPCRA Section 313 Industry Guidance: Electricity
Generating Facilities (Ref. 2)
EPA's Draft EPCRA Section 313 Guidance on Reporting Toxic
Chemicals: Mercury and Mercury Compounds (Ref. 4)
EPA's Mercury/CR (Ref. 5)
P-14
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METAL COMPOUNDS IN OIL
Sources of data for calculating amounts
manufactured
Producer's fuel analysis, fuel specifications, or other
producer information
Tables in EPA's EPCRA Section 313 Industry Guidance:
Electricity Generating Facilities (Ref. 2)
P-15
ORGANICS
Organics may be released during combustion )e.g.,
PACs, formaldehyde)
Manufacture of formaldehyde and releases of other
organics
See emission factors in EPA's EPCRA Section 313 Industry
Guidance: Electricity Generating Facilities (Ref. 2)
For more information on PACs:
EPA's Draft Guidance for Reporting Toxic Chemicals in the
Polycyclic Aromatic Compounds Category (Ref. 3)
P-16
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RELEASES FROM COMBUSTION
Sources of data:
Monitoring data
Facility derived emission factors
Emission factors in EPA's EPCRA Section 313 Industry
Guidance: Electricity Generating Facilities (Ref. 2)
P-17
COMBUSTION ASH
Combustion ash may contain manufactured metals
and metal compounds.
Ash released on-site (e.g., land disposal, fugitive air
emissions)
De minimi's exemption does not apply to manufacture of
metals and metal compounds as by-products
Ash used on-site to construct roads or berms should be
reported as release to land: other disposal (Section 5.5.4 of
Form R)
P-18
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COMBUSTION ASH
Ash sent off-site to be managed as a waste should
be reported in Section 6.2
Example:
» Ash sent off-site for direct application to land as roadfill
Ash sent off-site for direct reuse is not reported on
the Form R
Example:
» Ash used to manufacture concrete blocks
- Ash considered distributed into commerce and,
therefore, processed
- De minimis exemption can apply
P-19
REFERENCES
For more information:
1. Guidance for Reporting SuHuric Acid. U.S. EPA, Office of Pollution
Prevention and Toxics. March 1998. Available at
http://www.epa.gov/tri
2. EPCRA Section 313 Industry Guidance: Electricity Generating
Facilities. U.S. EPA, Office of Pollution Prevention and Toxics.
February 2000. Available at http://www.epa.gov/tri
3. Draft Guidance for Reporting Toxic Chemicals in the Polycyclic
Aromatic Compounds Category. U.S. EPA, Office of Information
Analysis and Access. November 2000. http://www.epa.gov/tri
4. Draft EPCRA Section 313 Guidance on Reporting Toxic Chemicals:
Mercury and Mercury Compounds. U.S. EPA, Office of Information
Analysis and Access, November 2000. Available at
http://www.epa.gov/tri
5. Mercury ICR. U.S. EPA, Unified Air Toxics Website. 1999, Raw data
available June 2000. Available at
http://www.epa.gov/ttnuatw1/combust/utiltox/utoxDg.htmltfDA2
P-20
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METAL AND METAL COMPOUND
REPORTING
SECTION 313 METALS
Certain metals and metal compounds are Section
313 chemicals
Examples:
» Elemental metals: chromium, nickel, manganese, cobalt,
silver, arsenic, copper
» Metal compound categories: zinc compounds, selenium
compounds, nickel compounds, chromium compounds,
vanadium compounds
» Individually listed metal compounds: sodium
fluoroacetate, calcium cyanamide, lithium carbonate,
molybdenum trioxide, titanium tetrachloride
Q-2
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SECTION 313 METALS WITH QUALIFIERS
i Metals and metal compounds can have qualifiers:
Zinc (fume or dust)
Aluminum (fume or dust)
Vanadium (except when contained in an alloy)
» Beginning RY 2000, reports due by July 1,2001
Aluminum oxide (fibrous forms)
Not all compounds within a metal category are listed
Barium sulfate
Certain copper phthalocyanine compounds
Q-3
SECTION 313 METAL COMPOUND
CATEGORIES
Consider the entire weight of the compounds in the
category when determining activity thresholds
Include only the weight of the parent metal of the
category (e.g., copper for copper compounds) when
calculating releases, off-site transfers, and other
waste management activities
Q-4
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SECTION 313 METALS
AND COMPOUND CATEGORIES
Elemental metals and metal compound categories
are separately listed chemicals under Section 313
Separate activity threshold determinations
Report for each listing (e.g., nickel or nickel compound
category) only if the threshold for each listing is exceeded
If threshold exceeded for both the elemental metal and
metal compound category (e.g., nickel and nickel
compounds), you have options to report separately or file
one combined report
» If combined, file as metal compound category
Q-5
DETERMINING THRESHOLDS FOR METAL
COMPOUNDS
Multiple compounds within a mixture example
A facility processes 200,000 pounds of a mixture
containing 10% zinc chromate and 15% chromium
dioxide by weight
Quantity toward chromium compounds threshold
(10% +15%) x (200,000) = 50,000 IDS.
Quantity toward zinc compounds threshold
(10%) x (200,000) = 20,000 Ibs.
25,000-pound processing threshold applies; chromium
compounds are reportable and zinc compounds are not
Q-6
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VANADIUM AND VANADIUM COMPOUNDS
PBT rule modifies the listing for vanadium:
Vanadium, with the qualifier "fume or dust," has been on
the list of Section 313 chemicals since 1987
Qualifier now reads "except when contained in an alloy"
» "Alloy" does not include slags, crystalline structures,
ores
» EPA is reviewing what actions to take regarding alloys
PBT rule adds vanadium compounds to the TRI list
Neither vanadium (except when in an alloy) or
vanadium compounds are PBT chemicals
Q-7
VANADIUM
Vanadium is used to produce various alloys
Prior to becoming part of the alloy, vanadium is a listed
chemical
Once part of the alloy, vanadium is not a listed chemical
Q-8
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VANADIUM COMPOUNDS
Manufacturing
Fuel combustion - metal oxides manufactured
Concentrations of listed metals are in the EPA's TRI
Guidance for Electricity Generating Facilities (U.S. EPA,
Office of Pollution Prevention and Toxics, February 2000)
Vanadium compounds are new to the list!
» 9 - 43 ppm V in coal (Ref. 2)
» 1.5 ppm V in fuel oil #2 (Ref. 3)
» 73 ppm V in fuel oil #6 (Ref. 3)
» 0.0023 Ibs. per million standard cubic feet natural gas
(Ref. 1)
» Assume V2O3 manufactured
Q-9
VANADIUM AND VANADIUM COMPOUNDS
REFERENCES
For more information on vanadium see:
1. Compilation of Air Pollutant Emission Factors (AP-42), Volume 1,
Fifth Edition. U.S. EPA, Office of Air Quality Planning and
Standards. Available at
http://www.epa.gov/ttn/chief/ap42/index.html
2. Milliard, H. The Materials Row of Vanadium in the United States,
U.S. Department of the Interior, Bureau of Mines, Information
circular 9409; 1994 Available at
http://minerals.usgs.gov/minerals/pubs/commodity/vanadium
3. Total Petroleum Hydrocarbon (TPH) Criteria Working Group
Association for the Environmental Health of Soils, Volume 2,
Appendix 1; 1998. Available at
http://www.aehs.com/publications/catalog/tph.htm
Q-10
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MANUFACTURING ACTIVITIES
Manufacturing
Electroplating: metals and metal compounds manufactured
Fume or dust: machining manufactures zinc (fume or dust)
Importing copper ore: manufacturing copper compounds
Beneficiation of ore: chemical reactions manufacture metals
and metal compounds
Wastewater treatment: metal compounds may be
manufactured in reduction or precipitation steps
Q-11
PROCESSING ACTIVITIES
Processing
Metals and metal compounds extracted from ores
distributed into commerce
Metals are incorporated into a wide variety of products
including motor vehicles, consumer products, industrial
equipment, and various other products
Alloys are mixtures of elemental metals. Metals in alloy
products distributed into commerce
Metals sent off-she for recycling or reuse
Q-12
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OTHERWISE USE ACTIVITIES
Otherwise using
Fabricating and/or using tooling
Installation of process-related equipment and piping (e.g.,
constructing storage tanks)
Use of ash and waste rock for land contouring, structural
backfill, or soil building
Metal compounds are often constituents of coolants,
biocides, and other liquid mixtures used on-site
Q-13
DETERMINING THRESHOLDS AT MINES
Mines
Use ore analyses, literature, geochemical knowledge, etc.
No knowledge of metal compound type - assume lowest
weight oxide
Q-14
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DETERMINING THRESHOLDS FOR ALLOYS
Industrial processing of alloys
Includes stainless steels, nickel superalloys, brasses,
aluminum alloys, and carbon steels
Use aljoy specifications in addition to MSDSs to improve
precision
Be comprehensive:
» Some carbon steels and aluminum alloys may contain
manganese above cfe minimis
Q-15
ARTICLES EXEMPTION TEST
Articles exemption is often inappropriately used!
A useful rule of thumb is that when metal is melted,
machined, or ground, articles exemption usually NOT
applicable
Articles that you manufacture typically do not qualify
Q-16
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STRUCTURAL COMPONENT
EXEMPTION TEST
Structural components need to pass a test to be
exempt Test has 2 criteria:
Is part of the facility structure; and
Is NOT process related
Non-process-related structural items eligible for the
exemption:
Potable water pipes and other non-process-related pipes
and structures
Processed-related items/uses NOT eligible for the
exemption:
Refractory brick, process-related pipes, anodes used in
electroplating, grinding wheels, and metal working tools
FORM R: AIR EMISSIONS
Fugitive air emissions (Section 5.1)
Ambient air monitoring can indicate emissions occurring
Particulate emission data combined with speciation can be
used to estimate emissions
Capture efficiencies of control equipment can be helpful
Stack air emissions (Section 5.2)
Many techniques available:
» Use of sampling data, adjusting permit estimates to
actual production, back-calculation from control device
efficiencies and quantity of dust collected, and
engineering estimates
Q-18
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FORM R: WASTEWATER DISCHARGES
Wastewater discharges (Sections 5.3, 6.1, and 6.2)
Calculate based on wastewater flows and measured
concentrations (e.g., NPDES/SPDES monitoring
requirements, permit applications)
, For metals not measured, consider engineering estimate
(e.g., use ratio of metals in process and measured metal
quantity)
Q-19
FORM R: OFF-SITE WASTE TRANSFERS
If s critical to be comprehensive!
Potential off-site waste transfers of reportable metals
Hazardous waste
Non-hazardous waste (e.g., waste oil and coolant)
Trash
Scrap metal (reuse vs. recycle)
Exercise caution when using TCLP data
Q-20
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WASTE MANAGEMENT OF METALS
Generally, metals cannot be treated or combusted
for energy recovery for Sections 6 and 8 of Part II of
the Form R
Metals are elements and cannot be destroyed
Exceptions include conversions to non-listed chemicals
» Examples:
- Aluminum (fume or dust) converted to a solution
- Barium chloride (included in barium compounds
category) converted to barium sulfate (not included)
- Molybdenum trioxide converted to molybdenum
carbonate
- Titanium tetrachloride converted to titanium dioxide
Q-21
WASTE MANAGEMENT OF METALS
For metals in wastes sent off-site for solidification/
stabilization
Use code M41 - Solidification/Stabilization-Metals and Metal
Compounds only
Do NOT use code M40 - Solidification/Stabilization
For metals in wastewater sent off-site for treatment
(not to a POTW)
Use code M62 - Wastewater Treatment (Excluding POTW)-
Metals and Metal Compounds only
Do NOT use code M61 - Wastewater Treatment (Excluding
POTW)
Q-22
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OFF-SITE RECYCLE OR REUSE?
Metal sent off-site for direct reuse:
No contaminants removed
Considered processing
De minimis exemption applies
Not reported on Form R
Q-23
OFF-SITE RECYCLE OR REUSE?
Materials sent off-site for recycling:
Considered processing
De minimis exemption does NOT apply
Report on Form R in Sections 6.2 and 8.5
Q-24
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FORM R: SECTION 7A, ON-SITE WASTE
TREATMENT
Part II, Section 7A: On-site waste treatment methods
and efficiency
Report any waste treatment step through which a reportable
chemical passes including removal
Air pollution control equipment and wastewater
treatment typically reported
Q-25
FORM R: SECTION 8
Consistency with data reported on other parts of Form
R is critical
Quantity Released: §8.1 = §5 + §6.2 (disposal codes only) +
§6.1 (metals and metal compounds only) - §8.8 (release or off-
site disposal only)
Off-Site Recycling: §8.5 = §6.2 (recycling codes only) - §8.8
(off-site recycling)
On-Site & Off-Site Energy Recovery: §8.2 = NA and §8.3 = NA
On-Site & Off-Site Waste Treatment: §8.6 = NA and §8.7 = NA
» Remember exceptions when treatment of metals can
occur!
Q-26
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MAINTENANCE CHEMICALS
AND OTHERWISE USE
DON'T FORGET ABOUT OTHERWISE USE!
Otherwise use chemicals related to facility
maintenance activities are easily overlooked and
not accounted for in threshold determinations
Identify otherwise use activities even if a
manufacturing and/or processing threshold has
been exceeded for a Section 313 chemical
Releases and waste management activities would be
reportable
Develop tools to identify and account for the
otherwise use of these chemicals in mixtures or
trade name products R_2
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WHAT CHEMICALS ARE OTHERWISE USED
AT YOUR FACILITY?
List chemicals otherwise used at your facility and
how they are used:
R-3
MAINTENANCE CHEMICALS AND
OTHERWISE USE
Otherwise uses of Section 313 chemicals include:
Maintaining process-related equipment and structures
Cleaning process-related equipment, parts, and
structures
Waste treatment
Process-related building cooling/heating
Process-related fuel use
R-4
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MAINTENANCE CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used for maintenance of process equipment and
structures:
Xylene in paint applied to process equipment
Zinc compounds in lubricating oils
Metal alloys in parts tooling and equipment repair
Metal compounds in welding rods used to repair
equipment and structures
Metal compounds in refractory bricks used to line
furnaces
R-5
CLEANING CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used for cleaning process equipment and
structures:
1,2,4-trimethylbenzene in diesel fuel used to clean bulk
storage tanks
Phenol in paint strippers
Dichlorofluoromethane in contact cleaners
Glycol ethers in aqueous-based cleaning solutions
R-6
-------
ADDITIONAL CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used at facilities:
HCFC-22 used to refrigerate product before sale
Ammonia used to treat process water
Ethylbenzene in fuel used to power process equipment
Ethylene glycol sprayed on coal piles to prevent
freezing
Pesticides used in cooling towers to prevent algae
R-7
OTHERWISE USE
CHEMICAL EXEMPTIONS
For Section 313 chemicals otherwise used for
maintenance or cleaning of non-process-related
equipment and structures, the following may
apply:
Routine janitorial or facility grounds maintenance
exemption
» Example: Xytene in cleaners used to clean the employee
cafeteria
Structural component exemption
» Example: Toluene in paint used to paint the employee
recreation center
R-S
-------
OTHERWISE USE
CHEMICAL EXEMPTIONS
Motor vehicle exemption if the chemical is used to
maintain motor vehicles operated by the facility
Example:
» Xylene in engine degreasers used to maintain the
facility motor vehicles
Personal use exemption if the chemical is
contained in non-process related items solely for
employee personal use
Example:
» Chlorine to treat on-site drinking water
R-9
ARTICLES EXEMPTION
For Section 313 chemicals contained in like items
(e.g., tooling) otherwise used for maintenance of
equipment and structures:
Articles exemption provided that the item:
» Is formed into a specific shape or design during
manufacture; and
» Has end-use functions dependent in whole or in part on its
shape or design during end-use; and
» Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility (< 0.5
pounds)
R-10
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ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
Develop methods for orchestrating data
collection of mixtures and trade name products
being otherwise used
Coordinate with purchasing/vendors
Develop inventory controls
Require maintenance logs for process equipment
Require requisition or "sign out" procedure for Section
313 chemicals from tool cribs and supply rooms
Take year-end inventories
R-11
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GETTING IT RIGHT: AVOIDING COMMON
ERRORS
WHY IT'S IMPORTANT TO GET IT RIGHT
Using TRI data
EPA is required to make non-trade secret data available to
the public on-line
Data are available on-line through TRI Explorer, Envirofacts,
the National Library of Medicine, and non-EPA databases
Data are available in other forms (paper reports)
» List of largest increasers/decreasers
All states receive data; some make it available electronically
S-2
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EPCRA SECTION 313 ENFORCEMENT
Current enforcement trends
Shift from simply identifying non-reporting facilities to
facilities submitting poor quality data
Focus on multi-media inspections (i.e., examine obligations
under multiple statutes)
Encourage self-disclosure through EPA's audit policy
Assign pollution prevention-related supplemental
environmental projects (SEPs)
» In FY98,36% of EPCRA penalty actions included a SEP.
Most SEPs of any regulatory program
S-3
EPA AUDIT POLICY
Audit Policy enhances environmental protection
through incentives for companies to self-police,
disclose and correct violations
Companies that satisfy the Policy's criteria are
eligible for up to 100% reductions in otherwise
applicable penalties
Since implemented in 1995, over 1,300 companies
have self-disclosed violations at over 5,430 facilities
under the policy
S-4
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EPA AUDIT POLICY
Conditions to qualify (nine criteria):
Systematic Discovery of the Violation through Environmental Audit or Due
Diligence
Voluntary Discovery
Prompt Disclosure
Discovery and Disclosure Independent of Government or Third Patty
Plaintiff
Correction and Remediation
* Prevent Recurrence
No Repeat Violations
Other Violations Excluded
Cooperation
For more information, including a copy of the Audit Policy
(revised in May 2000), visit:
http://es.epa.gov/oeca/ore/apolguid.html s-5
EPCRA SECTION 313 ENFORCEMENT
Companies violating any statutory or regulatory
requirement are subject to penalties of up to $27,500
per day
Companies subject to citizen suits and could also be
liable for attorney fees and litigation costs
Government's penalty is determined by applying the
Enforcement Response Policy (ERP) to each
violation
Violations are assessed per chemical or obligation
and per year
S-6
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EPCRA SECTION 313 ENFORCEMENT
National Nitrate Initiative: 350 companies paid over
$1.7 million in penalties and agreed to audit over
1000 facilities for failing to report coincidentally
manufactured nitrate compounds generated from
nitric acid treatment. Similarly situated companies
self disclosing under EPA's Audit Policy pay no
penalty.
Catalina Yachts. Inc.: Ordered to pay $108,792 for
failing to file seven Form Rs for acetone and styrene.
Burtin Urethane Corp.: Ordered to pay $120,000 for
failing to file 19 Form Rs for various chemicals.
S-7
EPCRA SECTION 326: CIVIL ACTIONS
Any person may bring civil action on their own
behalf against a private-sector facility owner or
operator for:
Failure to submit emergency follow-up notices under
EPCRA Section 304
Failure to submit an MSDS or a list of MSDS chemicals
Failure to complete or submit Tier l/ll inventories
Failure to complete or submit Form Rs or Form As
S-8
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EPCRA SECTION 326: CIVIL ACTIONS
State and local governments may bring a civil action
against a private-sector facility owner or operator
for:
Failure to notify the SERC regarding coverage under the
emergency planning and notification requirements
Failure to make relevant emergency planning information
available as requested by the LJEPC
Failure to submit MSDS or list of hazardous chemicals
Failure to prepare or submit Tier l/ll inventories
Any SERC or LEPC may bring a civil action against a
facility for failure to submit Tier II information upon
request s-9
COMMONLY MADE ERRORS
Threshold determination errors
Completion errors
Release estimation errors
Off-site transfers reporting errors
Other waste management and source reduction
errors
Federal facility name and/or parent company name
errors
S-10
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THRESHOLD DETERMINATIONS
Helpful hints for conducting accurate threshold
determinations
Apply chemicals to correct threshold activity
Distinguish between metals and metal compounds
Consider all avenues a chemical may enter a facility;
chemical qualifiers; chemical synonyms; and on-site
manufacturing
Recognize the limitations for exemptions
Results of incorrect threshold determinations
No form is submitted when one is required
Federal facility does not meet requirements of E013148
S-11
FORM COMPLETION CHECKLIST
Helpful hints for completing the Form R/Form A
Complete all required sections of a current, valid form
Correctly identify the Section 313 chemical using the correct
CAS number and correct listed TRI name
Use the NA indicator for data elements that are not relevant
Indicate the correct reporting year
Clearly identify revisions
Sign hardcopy of forms or certification letters for electronic
submissions
S-12
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FORM COMPLETION CHECKLIST (CONT'D)
To avoid completion errors, use EPA's ATRS
ATRS will prompt the user to complete required sections
ATRS will conduct validation check to ensure Form R is
complete
Result of completion errors
Violation
Form prevented from being entered into the database
S-13
RELEASE ESTIMATES
Helpful hints for accurate release estimates
Always use your best available information
Estimate the quantity of Section 313 chemical, not the entire
waste stream
Differentiate fugitive from stack emissions
Zero air emissions for VOCs are unlikely
Watch out for releases of Section 313 chemicals with
qualifiers
Check your math and document your work!
Result of release estimation errors
Incorrect release estimates and inconsistencies from year to
year S-14
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OFF-SITE TRANSFER
REPORTING
Helpful hints for accurate off-site transfer reporting
Do not report intra-facilitv transfers as off-site transfers
Report the quantity of Section 313 chemical transferred, not
the entire transfer quantity
Identify waste treatment, disposal, recycling, and energy
recovery activities correctly
Results of off-site transfer errors
Incorrect estimates (e.g., over-estimates)
Misclassification of facility's handling of Section 313
chemicals in wastes
S-15
WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTION 8.1
Helpful hints for reporting quantity released, Section
8.1
Include off-site disposal quantities (reported in Section 6.2),
on-site releases (reported in Sections 5.1 through 5.5), and
releases to POTWs for metals and metal compounds only
(reported in Section 6.1)
Do not include non-production-related, one-time events
(e.g., catastrophic or remedial releases/transfers)
» These should be reported in Section 8.8
S-16
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WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTIONS 8.2-8.7
For on-site waste management:
Report the quantity of Section 313 chemical actually
recovered for energy, recycled, or treated, not the total
amount entering the energy recovery, recycling, or
treatment unit
For off-site waste management:
Conversely, report the total quantity sent off-site for
recovery, recycling, or treatment
» You are not required to know the efficiency of the off-site
unit
S-17
WASTE MANAGEMENT AND SOURCE
REDUCTION
Energy recovery
Do not report halons, metals, or metal compounds
Do not include incineration activities
Treatment
Metals and metal compounds cannot be destroyed;
therefore, do not report as treated on or off-site
Catastrophic and remedial releases and transfers
Section 8.8 quantities should be included in Sections 5-7 (as
appropriate), but not in Sections 8.1-8.7
S-18
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FEDERAL FACILITY
IDENTIFICATION
Helpful hints for Federal facilities
Correctly identify if GOCO or Federal facility submission in Part I,
Section 4.2 of Form R
» Check box c. if Federal facility
» Check box d. if GOCO
Correctly identify department or agency
Use SIC codes in Part I, Section 4.5 that best describe the facility's
activities
Use EPA's new EPCRA Section 313 Questions and Answers
Addendum for Federal Facilities (U.S. EPA, Office of Environmental
Information, May 2000)
Results of incorrect Federal facility identification
Double-counting
S-19
SUBMITTING REVISIONS
Revisions can be made electronically or in hardcopy
Hardcopy revisions must be made in blue ink on a copy of
the form originally submitted
Magnetic media revisions must be accompanied by a newly
signed cover letter
For revisions made for reporting year 1991 or later,
mark an "X" in the space marked "Enter "X" here if
this is a revision" on page 1
Provide a new original signature and date for each
revision
Send to EPA's EPCRA Reporting Center and to the
appropriate state agency s.20
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EXERCISE #6:
TRI KNOWLEDGE QUIZ
Purpose: Familiarize participants with the criteria for TRI reporting, including thresholds for
manufacturing, processing, or otherwise using listed chemicals, which determine whether
or not a facility must submit a Form R for a listed Section 313 chemical or chemical
category.
Take-Aways: Knowledge and understanding of TRI reporting thresholds.
Instructions: Read each question carefully. Using your knowledge of TRI reporting thresholds, choose
the best of the four answers.
1. A facility processes 21,000 pounds of formaldehyde each calendar year. It also imports and then
otherwise uses 9,000 pounds of formaldehyde annually. In addition, each year the facility
receives 15,000 pounds of solution that contains 34% formaldehyde by weight and repackages it
for distribution and sale. The firm is in SIC code 2834, ships over 600 pounds of formaldehyde
in wastes off-site for disposal, and has 20 full-time employees. Assuming these values remain the
same over the next five years, under Section 313 this firm:
a. Must report for each calendar year.
b. Does not have to report for each calendar year, because the thresholds are not met.
c. Will not be required to report for each calendar year because it does not manufacture the
chemical.
d. Is not required to report because it employs less than 25 full-time employees.
2. Fifteen thousand (15,000) pounds of a listed chemical is purchased in the current reporting year
and is used in a re-circulating cooling jacket. This quantity remains in use indefinitely and no
additional quantity is added in subsequent years. Are you required to report for this chemical and
if so, for what year?
a. Do not consider this type of material at all because it is a purchased compound.
b. The use of the compound must be considered towards the otherwise use threshold for the
current reporting year only.
c. The use of the compound must be considered for the current reporting year and every
reporting year thereafter, until the mixture is replaced.
d. Consider only a part of the total amount the current reporting year, and a part every
reporting year thereafter, for the life of the mixture.
-------
A facility produces nitrate compounds as a result of its waste treatment operations, and transfers
the nitrate compounds to an off-site location, where all of the Section 313 chemical is extracted
and recycled. Which of the following is true?
a. The facility can exclude amounts of the nitrate compound from threshold determinations
and release estimation because the source qualifies for the de minimis exemption.
b. Coincidental production of the nitrate compounds is not covered under Section 313,
therefore the facility need not consider this source of chemical production towards
thresholds and estimation of off-site transfers.
c. The facility need not consider this source for thresholds and estimation of off-site
transfer because all of the listed chemical is eventually recycled.
d. The facility must include all amounts of the nitrate compounds coincidentally produced
in threshold determinations and release and other waste management calculations if it
exceeds a threshold.
Ten times per year, a facility receives chlorine in 1 ton cylinders. Half of the chlorine mixture is
transferred to a tank to make a bleaching mixture, where its concentration drops below the de
minimis level, which is then sold and distributed in commerce. One fourth of the original mixture
is used to treat the drinking water consumed by employees. The remaining one fourth of the
original mixture is used throughout the plant to clean process equipment. Wastewater from the
cleaning and bleach production operations is released with chlorine levels well below the de
minimis level. Which of the following is true?
a. All uses of the chlorine are subject to Section 313 reporting because the concentration of
the received mixture is well above the de minimis level and the threshold limit for
otherwise use has been met.
b. Only the use of chlorine for drinking water is exempt from Section 313 reporting.
c. Only the drinking water and cleaning operations will be exempt from Section 313
reporting due to the personal use and routine maintenance exemptions, respectively.
d. The drinking water and cleaning uses are covered under the personal use and routine
maintenance exemptions, respectively. The bleach production operation and the
wastewaters generated hi conjunction with this operation are not exempt from Section
313 reporting; however, the wastewaters from the cleaning operations are exempt.
-------
5. A facility processes 100,000 pounds of a mixture containing 25% zinc chromate, and 25%
chromium dioxide by weight. For purposes of Section 313 reporting, how much zinc and
chromium were processed?
a. 25,000 pounds zinc compounds, and 25,000 pounds of chromium compounds
b. 25,000 pounds zinc, and 25,000 pounds chromium
c. 25,000 pounds zinc, and 50,000 pounds chromium
d. 25,000 pounds zinc compounds, and 50,000 pounds chromium compounds
6. If a chemical on Section 313 list has a "qualifier," it means that it is subject to TRI reporting
when manufactured, processed, or otherwise used
a. In the thresholds specified (i.e., its reporting threshold is higher or lower than that for
other chemicals).
b. hi the specified form or activity.
c. Within the specified SIC code industries.
d. Except when used at federal facilities.
7. For aqueous ammonia, what percentage of the total ammonia present is applied to threshold
determinations?
a. 100%
b. 10%
c. 1%
d. 20%
8. A facility buys a solution containing 29% 1,1,1-trichloroethane and processes it as a constituent
of a cleaning solution that they sell in retail stores. The 1,1,1-trichloroethane is present in final
product at 0.5%. The product is packaged into one-gallon containers. What amounts of the
1,1,1-trichloroethane in mixtures must the facility consider for threshold determinations?
a. Any amount used within the facility during the reporting year, except the amount
distributed through retail outlets to consumers, must be considered processed.
b. Because the mixture was otherwise used, it is not eligible for the de minimis
exemption. The quantity used must be applied to the otherwise use threshold.
c. Because the mixture was received and processed in concentrations above the de minimis
for 1,1,1-trichloroethane, all quantities must be applied to the processing threshold.
d. Only amounts distributed into commerce need to be considered towards the processing
threshold, and because these quantities are present below the de minimis concentration,
they are exempt.
-------
9. Which of the following qualifies as a Section 313 reporting exemption?
a. Like "articles" that release over 10 pounds of a Section 313 chemical, not recovered,
under regular normal processing or use
b. Painting process equipment at the facility
c. Chemical use in non-process related routine janitorial or facility grounds maintenance
d. Laboratory support activities
10. In order to file a Form A Report, you must manufacture or process or otherwise use no more than
one million pounds of the Section 313 chemical and you must have
a. Less than 1,000 pounds of total releases and other waste management estimates of the
Section 313 chemical.
b. No more than 500 pounds of total releases and other waste management estimates of the
Section 313 chemical.
c. No more than 100 pounds of total releases and other waste management estimates of the
Section 313 chemical.
d. No more than 50 pounds of total releases and other waste management estimates of the
Section 313 chemical.
11. My facility manufactured .009 pounds of dioxin and dioxin like compounds in our combustion
units, and also incorporated 11.4 pounds of mercury into thermometers sent to a customer's
facility in Canada during the reporting year. Have I exceeded any thresholds?
a. No. The facility doesn't exceed the threshold for dioxin and dioxin like compounds and
the thermometers qualify for the articles exemption. Therefore, no thresholds have been
exceeded.
b. The facility must report for mercury, but does not exceed the threshold for dioxin
compounds.
c. The facility must report for dioxin and dioxin like compounds, but since the mercury is
going to another country, it doesn't have to report for mercury.
d. The facility must report for both dioxin and dioxin like compounds and mercury.
12. At Fred's custom oils manufacturing facility during the reporting year, 55 pounds of polycyclic
aromatic compounds (PACs) are manufactured in the combustion unit, 45 pounds of PACs are
processed in the lubricants, and 5 pounds of PACs are otherwise used by contractors that are
constructing a new manufacturing plant. Does Fred need to report for PACs?
a. No, none of the thresholds have been exceeded during the reporting year.
b. Yes, since 5 + 45 + 55 equals 105 pounds, Fred must report for PACs.
c. Yes, the processing and otherwise use activities both exceed a threshold.
d. Yes, Fred has to report, but he doesn't have to consider the contractors because they
aren't employed directly by Fred's company.
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INFORMATION RESOURCES
ADDITIONAL INFORMATION ABOUT TRI
i EPA Regional and State TRI Contacts
Check the TRI Form R and Instructions booklet
i RCRA, Superfund & EPCRA Hotline
(800) 424-9346 or (703) 412-9810 (DC Metro area)
Regulatory assistance
Information on availability of EPA publications
Information on EPA's electronic resources
T-2
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EPA ELECTRONIC MAILING LISTS
(LISTSERVER)
To subscribe to an electronic mailing list (listserver), send e-
mail to: listserver@unixmail.rtpnc.epa.gov
Subject line: leave blank
Text: SUBSCRIBE Oast name>
SUBSCRIBE EPA-WASTE JOHN SMITH
Some mailing lists are:
EPA-TRB: Toxic Release Inventory Federal Registers
HOTLINE_OSWER: RCRA. Superftind & EPCRA Monthly Hotline Report
and Updates
EPA-PRESS: EPA press releases
EPA-MEET1NG: EPA meeting notification
OPPT-NEWSBREAK: OPPT Library daily news service
T-3
DOCUMENT DISTRIBUTION CENTERS
RCRA, Superfund & EPCRA Hotline
(800)424-3346
(703) 412-9810 (DC Metro area)
Fax (703) 412-3333
http://www.epa.gov/epaoswer/hotline
National Service Center for
Environmental Publications (NSCEP)
1-800-490-9198
http://www.epa.gov/ncepiriom/
index.html
U.S. Government Printing Office (GPO)
(202) 512-1800
Fax: (202) 512-2250
http://www.gpo.gov
National Technical Information
Service (NTIS)
(800) 553-6847
(703) 605-6000 (DC Metro area)
http://www.ntis.gov
T-4
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ON-LINE ACCESS TO TRI DATA
TRI Explorer
http://www.epa.gov/triexplorer
ENVIROFACTS Database Internet Site
http://vww.epa.gov/enviro/html/ef_home.html
TOXNET (National Library of Medicine)
httpJftoxnetnlm.nih.gov
Right-to-Know Network (RTK NET)
Modem: (202) 234-8570; Information: (202) 234-8494; Internet:
http://www.rtk.net
T-5
PUBLIC ACCESS TO TRI
TRI Reports and Data (EPA TRI Web Site)
TRI Public Data Release Annual Report
TRI Public Data Release State Fact Sheets
State Data files
http://www.epa.gov/tri
TRI User Support Service: (202) 260-1531
EPCRA Hotline: (800) 424-9346 or (703) 412-9810
T-6
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TRI HOMEPAGE
EPA's Toxics Release Inventory Homepage at
http:7Awww.epa.gov/tri
General information on the TRI program and program
development
Information on how to use the TRI data
Access to TRI data (e.g., public data release, state fact
sheets, links to TRI databases)
Guidance documents for newly added industries and
Section 313 chemicals
Automated TRI Reporting Software (ATRS)
T-7
SECTION 313 GENERAL GUIDANCE
Toxic Chemical Release Inventory Reporting Form R and
Instructions. U.S. EPA, Office of Information Analysis and
Access. Available at http://www.epa.gov/tri
EPCRA Section 313 Questions and Answers (Revised 1998
Version). U.S. EPA, Office of Pollution Prevention and Toxics.
December 1998. Available at
http://www.epa.gov/tri/guidance.htm
Common Synonyms for Chemicals Listed Under Section 313 of
EPCRA. U.S. EPA, 1995.
Consolidated List of Chemicals Subject to Reporting Under the
Act (Title III List of Lists). U.S. EPA, Office of Solid Waste and
Emergency Response. November 1998. Available at
http://www.epa.gov/tri/guidance.htm
T-8
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SECTION 313 TECHNICAL GUIDANCE
Industry-specific technical guidance documents such as:
EPCRA Section 313 Reporting Guidance for Rubber and Plastics
Manufacturing. U.S. EPA, Office of Environmental Information. May
2000. Available at http://www.epa.gov/triyguidance.htm
Guidance for new industries, available at
http://www.epa.gov/tri/guidance.htm
Chemical-specific guidance documents such as:
Guidance for Reporting SuHuric Acid. U.S. EPA, Office of Pollution
Prevention and Toxics. March 1998. Available at
http://www.epa.gov/tri/guidance.htm
List of Toxic Chemicals within the Glycol Ethers Category. U.S.
EPA, Office of Environmental Information. December 2000.
Available at http://www.epa.gov/tri/guidance.htm
Estimating Releases and Waste Treatment Efficiencies for the Toxic
Chemical Release Inventory Form. U.S. EPA, 1988.
SECTION 313 TECHNICAL GUIDANCE
Technology Transfer Network (TIN)
Internet: http:7Awww.epa.gov/ttn/
Help Desk (919) 541-5384
Compilation of Air Pollutant Emission Factors (AP-42)
WATERS program
Updates WATERS, CHEMDAT8, and CHEM9
TANKS program
T-10
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POLLUTION PREVENTION INFORMATION
OPPT Pollution Prevention (P2) Internet Site
http://vww.epa.gov/opirtintr/p2home/index.html
Enviro$en$e Information Network
BBS modem (703) 908-2092; User support (703) 908-2007
http://es.epa.gov/index.html
Pollution Prevention Information Clearinghouse
(PPIC)
(202)260-1023
T-11
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SAMPLE TRI SUPPORTING DOCUMENTATION
The following is an example of a facility's documentation for TRI reporting. The
purpose of this documentation is to provide an example of a facility's operating
procedure, to ensure consistency and accuracy from year to year, and to meet the
recordkeeping requirements under 40 CFR 372.10.
The mock facility used in this example is the same facility described in Exercise
#2 of this training course - determining thresholds for Darcy Corp, a manufacturing
facility. This package includes sample documentation to support the threshold
determination, as well as documentation for release and other waste management
reporting. For simplicity, documentation for release and other waste management
reporting is only provided for methyl ethyl ketone (MEK). In reality, the facility would
also be required to create and maintain supporting documentation for the release and
other waste management reporting for the other two chemicals that exceeded a threshold
(copper and HCFC-22) as illustrated in Exercise #2 of the course.
This package is for you to take with you and review as an example of TRI
documentation. This documentation is merely an example and is specific to the mock
facility, Darcy Corp. Each TRI facility uses a unique set of data sources, calculations,
and assumptions, and is responsible for thoroughly documenting their threshold
determinations and release and other waste management reporting. For a list of the types
of records that should be maintained, see the EPA's TRI Reporting Forms and
Instructions document.
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SAMPLE TOXIC RELEASE INVENTORY
DOCUMENTATION
DARCY CORPORATION
RY2000
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TABLE OF CONTENTS
1. Facility Profile
2. Activity Threshold Determinations
A. Manufacture
B. Process
C. Otherwise Use
D. Remediation
3. Release and Other Waste Management Reporting
A. Methyl Ethyl Ketone (MEK)
B. Copper (Not included in sample)
C. HCFC-22 (Not included in sample)
4. Form R Reports
Appendices
A. Threshold Worksheets
B. Facility Data
C. MSDSs
D. Process Flow Diagram
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1. FACILITY PROFILE
Darcy Corp. operates adjacent plants at a site in central Ohio: Plant 1 manufactures
industrial refrigeration units (SIC Code 3585) and Plant 2 manufactures molded plastic
components for a variety of consumer product applications (SIC Code 3089). Although
the two plants operate independently, they are considered one facility under Section 313
of EPCRA. This is because they are adjacent, and are owned and operated by Darcy
Corporation whose corporate offices are located in Flint, Michigan. Plant 1 employs a
staff of 1,600 employees. Plant 2 employs a staff of 800 full-time employees. Therefore,
the employee hours at the facility exceed 10 or more full-time employee (or 20,000 hour
equivalent) threshold. Because the facility's operations are classified in covered SIC
codes and the full-time employee threshold is exceeded, the facility is required to perform
chemical threshold determinations for listed Section 313 chemicals. These activity
threshold determinations are described below.
2. ACTIVITY THRESHOLD DETERMINATIONS
The facility performed activity threshold determinations and concluded that the following
Section 313 chemicals exceeded a threshold:
Methyl ethyl ketone
HCFC-22
Copper (elemental)
The documentation for the threshold determinations is divided into four types of
activities: manufacturing, processing, otherwise using, and remediation. The remediation
operation is separately addressed because the Section 313 chemicals involved in that
operation do not meet the definition of manufacture, process, or otherwise use as
described below.
A. Manufacturing
Ammonia
Information obtained from the vendor of the resin (XYZ Acrylic Resin - see Appendix
B) indicates that during the curing of the resin used in injection molding at Plant 2,1 Ib
of anhydrous ammonia is generated for each 100 Ib of resin used. The amount of
anhydrous ammonia manufactured is calculated as follows:
1 Ib anhydrous ammonia manufactured/ 100 Ib of resin x 300,000 Ib resin = 3,000 Ib of
anhydrous ammonia manufactured. Therefore, ammonia is manufactured below the
25,000-lb threshold.
Zinc (fume or dust)
According to the MSDS (see Appendix C), the injection molding resin used at Plant 2
contains 1.5 percent elemental zinc. As discussed previously, the Hi-Copper Brass
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Tubing contains 9.2% zinc. Zinc is only reportable in the fume or dust form. Any
amount of zinc in the tubing or resin that becomes a fume or dust is counted towards the
manufacturing threshold. There are no data to indicate the quantity of zinc fume or dust
manufactured. However, the total amount of zinc in the resin and tubing is less than
25,000 Ib, as shown below:
Tubing: 9.2% x 100,000 Ib = 9,200 Ib
Resin: 1.5% x 300,000 lb = 4,500 Ib
Total =13,700 Ib
Therefore, even if all of the zinc in the resin and tubing was generated as a fume or dust,
which is highly unlikely, the total amount of zinc (fume or dust) manufactured is still be
well below the 25,000 Ib threshold.
B. Processing
The facility processed copper, HCFC-22, and barium compounds as discussed below.
Copper
Plant 1 uses Hi-Copper Brass Tubing in the manufacture of the air conditioners'
components. According to Matthew Good, Quality Assurance Manager (222-222-1 111),
the product specification for Hi-Copper Brass Tubing is 90.0 percent copper, and 9.2
percent zinc. Purchasing records (see Appendix B) indicate that Plant 1 received 100,000
Ib of Hi-Copper Brass Tubing in the reporting year. The tubing is cut, bent into the
appropriate shapes, and welded into the air conditioning units. Plant 1 estimates that
these activities release well over 0.5 pounds of copper to air and water. Therefore, the
articles exemption does not apply to the tubing.
The amount of copper processed is 90.0 wt% x 100,000 Ib = 90,000 Ib; therefore, copper
is processed in excess of the 25,000-lb threshold.
HCFC-22
One of the refrigerants used by Plant 1 in its A100 series refrigerant units is HCFC-22.
According to the MSDS, this product is >98.0 percent pure (see Appendix C for HCFC-
22 MSDS). According to Ernesto Puente, Darcy Corp financial department (222-222-
9999), the facility produced 240 units in the reporting year, and each unit contains 100 Ib
of HCFC-22. Purchasing records indicate that the supplier delivered 20,000 Ib to the
site's HCFC-22 storage tank in the reporting year. Inventory records for the HCFC-22
storage tank indicated that the tank contained 15,000 Ib at the beginning of the reporting
year and 9,000 Ib at the end of the reporting year (see Appendix B for purchasing and
inventory records). The facility used the purchasing and inventory records to determine
the amount of HCFC-22 processed, rather than the amount per unit times the number of
units. This calculation technique was used because EPA requires that facilities count the
entire amount prepared for distribution into commerce as processed.
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The amount of HCFC-22 processed is 20,000 Ib + (15,000 Ib - 9,000 Ib) = 26,000 Ib. The
concentration range is 98.0 to 100.0 %. The facility used the midpoint - 99.0%, per EPA
guidance. Therefore, the amount of HCFC-22 processed is 99.0 wt% x 26,000 Ib =
25,740 Ibs, which is in excess of the 25,000-lb threshold.
Barium Compounds
Plant 2 uses a resin (XYZ Acrylic Resin) in an injection molding process to make various
plastic components. Purchasing and inventory records indicate that the facility used
300,000 Ib of the resin in the reporting year. According to the MSDS (see Appendix C),
the resin contains 4 weight percent of barium hydroxide. The amount of barium
compounds processed is 4.0 wt% x 300,000 Ib = 12,000 Ib barium hydroxide. Barium
compounds are processed below the 25,000-lb threshold.
C. Otherwise Use
Methyl Ethyl Ketone
Plant 1 paints certain refrigeration unit components using a paint that contains 10 weight
percent methyl-ethyl-ketone (MEK), a solvent. Paint booth logs (see Appendix B)
maintained by boom operators indicate Plant 1 used 10,000 gallons to paint the
refrigeration units. Paint booth logs were used rather than purchasing records as the logs
more accurately reflect the amount of paint actually used. The MSDS (see Appendix C)
for the paint indicates that the density of the paint is 11 Ib/gallon. Therefore 110,000 Ib
of paint were used during the reporting year. The amount of MEK in the paint is 10.0
wt% x 110,000 Ib = 11,000 Ib.
Purchasing and inventory records indicate that 10,000 Ib of an adhesive (All Purpose
Adhesive No. 10) that contains 12 weight percent MEK (per MSDS, see Appendix C)
was used as a solvent in the adhesive application operations in the reporting year. The
amount of MEK otherwise used in paint and adhesive is calculated as follows: The
amount of MEK in the adhesive is 12.0 wt% x 10,000 Ib = 1,200 Ib MEK otherwise used.
In the reporting year, a contractor painted the exterior and interior of all buildings on site.
The contractor provided a letter (see Appendix B) reporting that their paint usage in the
reporting year was 20,000 Ib, containing 5 weight percent MEK. Painting facility
buildings is subject to the structural component exemption (see Question 94 of the
1998 EPCRA Section 313 Questions and Answers Document). Therefore, the 1,000 Ib of
MEK used in the paint by the contractors was not counted towards the otherwise use
threshold.
The total MEK otherwise used = 11,000 + 1,200 = 12,200 Ib, which exceeds the 10,000-
Ib threshold.
D. Remediation
hi the reporting year, remediation of soil contaminated with MEK was conducted with a
soil vapor extraction (SVE) system. The soil is processed through an activated carbon
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adsorption unit. Section 313 chemicals undergoing remediation are not included in
threshold determinations because remediated chemicals are not considered to be
manufactured, processed, or otherwise used (see Question 94 of the 1998 EPCRA Section
313 Questions and Answers Document). MEK releases from remediation will be
discussed in Section 3.
Calculations are also documented in the threshold determination worksheets in Appendix
A.
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3. RELEASE AND OTHER WASTE MANAGEMENT REPORTING
The threshold determination performed for Darcy Corp identified the need to file a Form
R for MEK, copper, and HCFC-22. For this sample documentation package, the
supporting documentation is provided for MEK only. The facility would be expected to
similarly document its release and other waste management reporting for copper and
HCFC-22 in this section as well.
The facility used a process flow diagram to identify releases and other waste management
activities. The diagram is in Appendix D.
A. Methyl Ethyl Ketone (MEK)
Part II, Section 5.1. Fugitive or Non-Point Air Emissions.
The sources of fugitive air emissions of MEK are the refrigeration unit
components painting, the adhesive application, and wastewater treatment. Each of these
is discussed below.
Refrigeration Unit Components Painting
As discussed in the thresholds section, 11,000 Ib of MEK are used in the painting
operation at Plant 1. Of these 11,000 Ib, 1,000 Ib of MEK were shipped off-site in wastes
from the painting operation (see Section 6.2). Also, 34 Ib of MEK were sent to the
wastewater treatment plant. This is the sum of the amount discharged to water (see
discussion on Section 5.3) and the amount released as a fugitive air emission from the
wastewater treatment plant (discussed later hi this section). Because there are no data to
indicate that any of the on-site process steps or waste treatment steps consume or destroy
MEK, it is assumed that the remaining 9,966 Ib is emitted as air emissions.
The painting operations are performed in booths with the air drawn through
particulate filters and exhausted out a stack. Paint booth design documents (maintained
by Elizabeth Fair, Paint Floor Manager (222-222-3344)) indicate that the capture
efficiency of the booth's air collection system was estimated to be 90 percent. Katherine
Bush, Environmental Air Quality Manager (222-222-1212), reviewed the air emissions
inventory and the related engineering assumptions. Using her process knowledge of the
painting operations, she determined that it would be more appropriate to assume that only
85 percent of the air emissions are stack emissions. The remaining 15 percent of the air
emissions are assumed to be fugitive (to account for fugitive air emissions from the paint
containers and from waste paint containers). Therefore, fugitive air emissions of MEK
from painting operations are estimated to be 15% x 9,966 Ib = 1,494.9 Ib.
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Adhesive Application
The adhesive (All Purpose Adhesive No. 10) is applied in an area with no air
exhaust to a stack. Because of worker exposure concerns, testing was performed in the
reporting year that determined that 84 percent of the MEK used in adhesive application
operations resulted in air emissions (see Appendix B for testing results). Twelve hundred
(1,200) Ib of MEK are used in adhesives at Plant 2, as calculated in the thresholds section
of this document. Because there is no air exhaust leading to a stack, all air emissions
from adhesive application are fugitive air emissions. Therefore fugitive air emissions
from adhesive application are 1,200 x 0.84 = 1,008 Ib.
Wastewater Treatment
All emissions from the wastewater treatment operation occur from the open-top
neutralization tank. Releases from an outdoor open-top tank are considered to be fugitive
air emissions, so all air emissions from the wastewater treatment operation will be
included in Section 5.1. The wastewater treatment system was modeled using EPA's
WATER9 program and this modeling indicated that 50% of MEK entering the system is
emitted as fugitive air emissions. Consequently, the fugitive air emissions of MEK from
the system are equivalent to the MEK wastewater discharge (50/50 split). This amount
(calculated in the discussion on Section 5.3) was 16.68 Ib. Therefore, 16.68 Ib of MEK
were emitted as fugitive air emissions from wastewater treatment.
Total fugitive air emissions of MEK are 1,494.9 + 1,008 + 16.68, or 2,519.58 Ib.
Given the overall precision of the data and methods of calculation used, the estimate is
rounded to two significant figures. Therefore, "2,500" is reported in Section 5.1. This
estimate was based on engineering calculations and assumptions, monitoring data and
mass balance calculations. Because the majority of the releases (1,494 Ib from
refrigeration unit painting) were based on the engineering assumption that 15% of the
total air emissions from painting were fugitive, "O" is entered as the basis of estimate in
column B.
Part II, Section 5.2. Stack or Point Air Emissions.
The primary sources of stack air emissions of MEK are the refrigeration unit
components painting and remediation. Each of these is discussed below.
Refrigeration Unit Components Painting
As discussed above, the painting operations resulted in 9,966 Ib of MEK emitted
to the air. Eighty five percent of these emissions are assumed to be stack air emissions.
Therefore, stack air emissions of MEK from painting operations are estimated to be
8,471.1 Ib.
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Remediation
The soil vapor extraction (SVE) unit used for remediation is estimated to extract
from the ground and send to the activated carbon adsorption unit 10 Ib of MEK every
month. The extracted amount is treated in an activated carbon adsorption unit that is 99
percent efficient in capturing the organic emissions. Stack air emissions of MEK are
calculated as follows:
10 Ib MEK into carbon unit per month x 0.01 Ib of MEK from carbon unit per Ib
of MEK into carbon unit x 12 months = 1.2 Ib of MEK emitted from the carbon unit.
In total, 8,471.1 + 1.2, or 8,472.3 Ib of MEK were emitted to the air via stacks or
point sources. Given the overall precision of the data and methods of calculation used,
the estimate is rounded to two significant figures. Therefore, "8,500" is reported in
section 5.2. Engineering assumptions concerning the fugitive/stack split were used to
estimate the bulk of this quantity; therefore "O" is entered as the basis of estimate in
column B.
Part II, Section 5.3. Releases to Water.
Process wastewater from the painting operations in Plant 1 is combined and
processed through a wastewater treatment facility. The wastewater treatment facility is a
one-step neutralization tank, where caustic is added to raise the pH above 6. After
treatment, the wastewater is discharged to Scioto River. Monitoring performed for the
discharge permit application indicated that MEK was present in the wastewater discharge
from the treatment system at 2.0 mg/1 and that a total of 1,000,000 gallons of wastewater
were discharged to the Scioto River in the reporting year. (See Appendix B for
monitoring results.) Because 1 mg/1 is equivalent to 8.34 Ib per million gallons, the MEK
concentration is 16.68 Ib per million gallons. Because 1,000,000 gallons of wastewater
were discharged to the Scioto River in RY2000,16.68 Ib of MEK were discharged to the
river; therefore, "17" is reported in Section 5.3. "M" is entered as the basis of estimate
because the estimate is based on monitoring data. "NA" is entered as the percentage from
stormwater, because all working areas are enclosed, and there was no information
indicating MEK was discharged as stormwater.
Part II, Section 5.4. Underground injection on-site.
The facility had no on-site underground injection unit; therefore, "NA" is reported
in Section 5.4.1 and 5.4.2.
Part II, Section 5.5.1. Landfill.
The facility had no on-site landfill; therefore, "NA" is reported in Section 5.5.1 A
and 5.5.IB.
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Part II, Section 5.5.2. Land treatment/application farming.
The facility had no on-site land treatment/application fanning unit; therefore,
"NA" is reported in Section 5.5.2.
Part II, Section 5.5.3. Surface Impoundments.
The facility had no on-site surface impoundments; therefore, "NA" is reported in
Section 5.5.3.
Part II, Section 5.5.4. Other Disposal
Based on a review of spill reports for RY 2000 (maintained in the "Spills" folder
of the "ENVIRO" file cabinet in the office of Kirsten Hersch, Environmental Health and
Safety Program Manager (222-222-8888)), no spills of MEK were identified. Because it
was certainly possible to spill or otherwise release MEK to land on-site; "zero" is entered
in Section 5.5.4. "O" is entered as the basis of estimate in column B because this
estimate was based on an engineering assumption.
Part II, Section 6.1. Discharges to publicly owned treatment works.
The facility did not discharge wastes to a POTW; therefore, "NA" is reported in
Section 6.1.
Part II, Section 6.2. Transfers to other off-site locations.
The facility had off-site transfers of MEK in wastes from painting, adhesive
application and remediation. All waste manifests and profiles mentioned in the following
discussion are kept in the "Hazardous Waste 2000" folder of the "ENVIRO" file cabinet
in the office of Kirsten Hersch, Environmental Health and Safety Program Manager (222-
222-8888). Quantities of MEK in wastes were calculated using the manifests and
profiles, and were reported in Table 4 of the Darcy Corp Annual Waste Summary, which
is presented in Appendix B.
Wastes from Plant 1's Painting Operation
According to the Darcy Corp Annual Waste Summary, 900 Ib of MEK in waste
paint were shipped to ACME Incineration (RCRA DD#OHD 123456789,1 Apple Street,
Akron, Smith County, OH, 99999) for incineration (M50). Also, 100 Ib of MEK in
paint-related waste (rags, empty containers, and waste filters) were shipped to Bob's
Landfill (RCRA ID# OHD000123456,2 Bee Street, Bloomington, Smith County, OH
99990) for disposal in a hazardous waste landfill (M72). Basis of estimate is "M"
(Monitoring) for both wastes because the quantities were obtained from hazardous waste
manifests and concentration information from analytical data contained in the waste
profiles.
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Plant 2 Adhesive Operations
According to the Darcy Corp Annual Waste Summary, 200 Ib of MEK in
adhesive-related waste was shipped to ACME for incineration (M50). Basis of estimate
is "M" (Monitoring) because the quantities were obtained from hazardous waste
manifests and concentration information from analytical data contained in the waste
profiles.
Empty waste adhesive containers are disposed of in the local sanitary landfill.
Because there are no data to indicate that MEK remains in the empty waste adhesive
containers and all MEK used has been counted, it is assumed that no MEK was
transferred off-site with these containers.
Contractor's Paint-Related Waste
As stated in the letter from the painting contractor (see Appendix B), 60 Ib of
MEK were present in the paint-related waste generated on site by the contractor. The
facility shipped this waste off site for disposal in a hazardous waste landfill during the
reporting year. This waste is exempt from reporting because the otherwise use activity is
subject to the structural component exemption.
Remediation Waste
According to the Darcy Corp Annual Waste Summary, only one shipment of spent
carbon was sent to ACME for incineration. The carbon was in service for 10 months
from August 1999 to June 2000. The SVE system is estimated to extract from the ground
and send to the activated carbon adsorption unit 10 Ib of MEK every month. Therefore,
100 Ib of MEK was fed to this carbon unit and it is 99 percent efficient in capturing the
organic emissions. The spent carbon contained 99 Ib of MEK. Basis of estimate is "O"
(Other) because the quantity was based on an engineering estimate.
The following table summarizes the entries in Section 6.2 of the Form R.
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Off-Site Location
ACME Incineration (RCRA
ID3OHD123456789, 1
Apple Street, Akron, Smith
County, OH, 99999)
Bob's Landfill (RCRA ID#
OHD0001 23456, 2 Bee
Street, Bloomington, Smith
County, OH 99990)
Quantity (Ib)
900 + 200 + 99
= 1,199 (report
1,200)
100
Type of Waste
Treatment,
Disposal, Recycling,
or Energy Recovery
M50
M72
Basis of
Estimate
M
M
Part II, Section 7A. On-site waste treatment methods.
Three waste treatment methods were applied to MEK-containing wastes. Each of
these is discussed below.
Painting operations are performed in booths with the MEK-containing air drawn
through particulate filters. Industrial hygiene monitoring performed in the paint booths
indicates that the concentration of MEK in the air to be in the range of 30 to 90 ppm;
therefore, range code 3 (1 to 100 ppm) is entered in 7A.1.C. The efficiency of a
particulate filter in removing MEK from the air is assumed to be negligible; therefore
zero is entered in 7A.1 .d. Because this efficiency estimate is based on engineering
knowledge versus operating data, "No" is entered in 7A.l.e. The following table
summarizes the 7A entries:
7A.l.a Stream
A (Air)
7A.1.D Treatment
Method
P12 (Filtration) or A06
(Mechanical
Separation)
7A.1.C
Influent
Cone.
3 (1 ppm
to 100
ppm)
7A.l.d
Eff. %
0
7AJ.e
Based on
Oper.
Data?
No
Process wastewater from the painting operations in Plant 1 is combined and
processed through a wastewater treatment facility. The wastewater treatment facility is a
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one-step neutralization tank, where caustic is added to raise the pH above 6. Monitoring
performed for the discharge permit application indicated that MEK was present in the
wastewater at 2 mg/1, which is approximately 2 ppm; however, the concentration of MEK
in the influent was twice this amount, or 4 mg/1; therefore, range code 3 (1 to 100 ppm) is
used for the influent concentration. While it is assumed that the efficiency of
neutralization in removing or destroying MEK is negligible, half of the MEK is lost
during the wastewater treatment process through evaporation based on WATER9
calculations, so the wastewater treatment process is 50% efficient at removing MEK.
Because this efficiency was calculated using WATER9 versus operating data, "No" is
entered in 7A.2.e. Therefore, the following information is entered into Section 7A:
7A.2.a Stream
W
(Wastewater)
7A.2.5 Treatment
Method
Cll (Neutralization)
7A.2.C
Influent
Cone.
3 (1 ppm
to 100
ppm)
7A.2.d
Eff. %
50
7A.2.e
Based on
Oper.
Data?
No
MEK is remediated from the soil using a soil vapor extraction process. The air
stream from this remediation process is directed through a carbon adsorption system that
is 99 percent efficient. The influent concentration to the adsorption unit is 50 ppm,
therefore, range code 3 (1 to 100 ppm) is used for the influent concentration. Because
this efficiency estimate is from the equipment manufacturer's specifications versus
operating data, "No" is entered in 7A.3.e. The following table summarizes the entries in
Section 7A:
7A.3.a Stream
A (Air)
7A.3.D Treatment
Method
P21 (Adsorption -
Carbon)
7A.3.C
Influent
Cone.
3(1 ppm
to 100
ppm)
7A.3.d
Eff. %
99
7A.3.e
Based on
Oper.
Data?
No
Part II, Section 7B. On-site energy recovery methods.
The facility did not operate any on-site energy recovery units; therefore, "NA" is
entered in Section 7B.
Part II, Section 7C. On-site recycling methods.
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The facility did not operate any on-site recycling units; therefore, "NA" is entered
in Section 1C.
Part II, Section 8, Source Reduction and Recycling Activities
The following entries were made in Sections 8.1-8.7. Calculations for Section 8 are
discussed below.
Section
8.1
8.2 - 8.6
8.7
Prior Year
(Column A)
12,000
NA
550
Current Year (Column B)
Calculated
11,107.36
NA
1,100
Reported
11,000
NA
1,100
Following Years (Col. C & D)
Calculated
13,328.83
NA
1,320
Reported
13,000
NA
1,300
Part II, Section 8.1-8.7, Column A.- Prior Years
The facility entered amounts from last year's Form R (i.e. the RY1999 Form R) in
Column B for all sections of Section 8. See RY1999 TRI Notebook for a detailed
discussion of the values.
Part II, Section 8.1, Column B. Quantity Released
The quantity reported in this section is the quantity reported in all of Section 5 plus the
quantity reported in Section 6.2 for which disposal codes (M10, M71, M72, M73, M79,
M90, M94, and M99) are listed plus the quantity reported in Section 6.1 for metals minus
the quantity reported in Section 8.8 that was released or disposed. In other words:
§8.1 = §5 + §6.1 (metals only) + §6.2 (disposal only) - §8.8 (release or disposal only).
§6.1 = 0 as discussed above.
§8.8 (release or disposal only) = 1.2 Ib as discussed below hi Part II, Section 8.8.
Therefore, §8.1 = §5.1 (fugitive air emissions) + §5.2 (stack air emissions) + §5.3
(discharges to water) + §6.2 (disposal only) - §8.8 (release or disposal only), or 2,519.58
+ 8,472.3 + 16.68 + 100- 1.2 = 11,107.36.
Given the overall precision of the data and methods of calculation used, the estimate is
rounded to two significant figures, 11,000 Ib, which is reported in Column B, Part II,
Section 8.1
Part II, Sections 8.2 and 8.3, Column B. Quantity Used for Energy Recovery On-Site
The facility did not use MEK for energy recovery on-site or transfer MEK off-site for
energy recovery purposes; therefore, "NA" is entered in Column B, Sections 8.2 and 8.3.
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Part II, Section 8.4 and 8.5, Column B. Quantity Recycled On-Site
The facility did not recycle any MEK on-site or send any MEK off-site for recycling;
therefore, "NA" is entered in Column B, Section 8.4 and 8.5.
Part II, Section 8.6, Column B. Quantity Treated On-Site
The facility did not treat (i.e., destroy or chemically convert) any MEK on-site; therefore,
"NA" is entered in Column B, Section 8.6.
Part II, Section 8.7, Column B. Quantity Treated Off-Site
The facility transferred 1,199 Ib of MEK off-site for incineration, as calculated in Section
6.2. However, 99 Ib of this MEK was in waste generated from remediation activities.
The MEK generated during remediation is reportable in Section 8.8, not in Sections 8.1-
8.7. The amount reported in Column B, Section 8.7 is 1,199 Ib - 99 Ib = 1,100.
Part II, Sections 8.1 8.7, Column C and D: Following Years
According to Ernesto Puente, Darcy Corp financial department (222-222-9999), the
facility expects to increase refrigeration unit production by 20% in RY 2001 to meet
customer demand. Because wastes containing-MEK are directly related to the number of
refrigeration units produced, the quantities in Sections 8.1-8.7, Column C are estimated to
increase by 20% in RY2001. Therefore, amounts reported in Sections 8.1-8.7, Column B
are multiplied by 1.2 to calculate the amounts reported in Sections 8.1-8.7, Column C.
These amounts are shown in the table at the beginning of Section 8.
At this time, the facility expects no further production increases for RY 2002; therefore,
the estimates in Sections 8.1-8.7, Column D will be the same as those in Sections 8.1-8.7,
Column C.
Part II, Section 8.8. Releases As A Result of Remedial Actions, Catastrophic Events,
Or One-Time Events Not Associated With Production Processes
The facility had the following releases and off-site transfers resulting from remediation:
Stack air emissions: 1.2 Ib
Off-site transfers: 99 Ib
Total: 100.2 Ib
Whole numbers must be reported for non-PBT chemicals, therefore 100 Ib is reported in
Section 8.8.
Part II, Section 8.9. Production ratio or activity index
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The amount of MEK that is generated as a waste is most closely related to the number of
refrigeration units produced. According to Ernesto Puente, Darcy Corp financial
department (222-222-9999), the plant produced 1.2 times as many refrigeration units in
2000 as it did in 1999. Therefore, 1.2 is reported in Section 8.9.
Part II, Section 8JO. Source reduction activities
The facility did not implement any source reduction for MEK during RY2000. "NA" is
entered in Section 8.10.
Part II, Section 8.11. Optional information
"No" is checked because no additional information is attached.
B. Copper (Not included in sample)
C. HCFC-22 (Not included in sample)
4. FORM Rs
(For purposes of this sample documentation, only the MEK Form R is provided. If this
were actual documentation, the facility would also include Form Rs for copper and
HCFC-22 in this section.)
Sample Documentation - Not For Use page 17
-------
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116 - 3348
Attn: Toxic Chemical Release Inventory
Magnetic Media Submission
To Whom It May Concern:
DARCY CORPORATION - COLUMBUS PLANT
145 SOUTH AVENUE
COLUMBUS
OH 43235
TRI Fac. ID: 145DA-RCYCO-RP432
02/12/2001
Enclosed please find one (1) microcomputer diskette containing toxic chemical release reporting information for:
DARCY CORPORATION - COLUMBUS PLANT
This information is submitted as required under Section 313 of the Emergency Planning and Community
Right-to-Know Act of 1986 and the Pollution Prevention Act of 1990.
We are submitting a total of 3 Chemical Report(s) for our facility.
These 3 chemical report(s) are described below:
Chemical Name
METHYL ETHYL KETONE
COPPER
CHLORODIFLUOROMETHANE
Report Year
2000
2000
2000
CAS Number
78933
7440508
75456
Report Type
5-page Form R
5-page Form R
5-page Form R
Our technical point of contact is:
EDWARD VETTER
Phone Number: (222)222-7777
and is available if any questions or problems arise in your processing of these diskettes.
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the
submitted information is true and complete and that the amounts and values in this report are accurate based on
reasonable estimates using data available to the preparers of this report.
Sincerely,
THOMAS JONES
PLANT MANAGER
-------
(IMPORTANT
or pnnt read instructions before completing form}
form Approved OMB Numoer 2070-0093
Approval Expires: 01/31/2003
Page 1 of S
EPA
FORM R
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
j United States Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986,
| Environmental Protection a)so known as j^ m of the §UperfunCj Amendments and Reauthorization Act
Agency
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
MemfieW, VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR 2000
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2:
Attach substantiation forms)
No (Do not answer 2.2:
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTIONS. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
information is true and complete and that the amounts and values in this report are accurate based on reasonable estimates
using data available to the p'reparers of this report.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
THOMAS JONES
PLANT MANAGER
06/11/2001
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number U50ARCYCORP432
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
OARCY CORPORATION COLUMBUS PLANT
OARCY CORPORATION - COLUMBUS PLANT
Street |
145 SOUTH AVENUE
Mailing Address
US SOUTH AVENUE
SUITE 320
City/County/State/ZiD Code
City/State/Zio Code
COLUMBUS
FRANKLIN
OH 43235-
COLUMBUS
OH 43235-
Country (Non-US)
4.2
This report contains information for
(Important: check a or b: check c or d if applicable) a-
An entire
facility b.
Part of a
facility
A Federal
facility d
GOCO
! 4.3
Technical Contact Name
EDWARD VETTER
Telephone Number (induce area code)|
(222)222-7777
4.4
Public Contact Name
KIRSTEN HERSCH
Telephone Numeer (include area code)
(222) 222-8888
4.5
SIC Code (s) (4 digits)
Primary
3585
3089
4.6
Latitude
Degrees
41
Minutes
Seconds
05
05
Longitude
Degrees
Minutes
Seconds
081
30
56
4.7
Oun & Bradstreet
Numbers) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
123456789
OHD987654321
a. OH0001234
a. NA
b.
b.
SECTION 5. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
DARCY CORPORATION
5.2
Parent Company's Dun & Bradstreet Number
NA
123456789
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete. Printed using ATRS for Windows 2000 version 5.03.00
2/15/2001
-------
Page 2 of S
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility 10 Numoer
14SDARCYCORP432
Toxic Chemical. Category or Genenc Name
METHYl ETHYt KETONE
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section if you completed Section 2 below.)
1.1
CAS Number llmpoftant: Enter only MM number «iaclty as it appears on ihe Section 313 (it. Ent« category code if reporting a ctwmul category.)
78933
1.2
Toiic Chanel or Chemical Category Neme (Important: Enter only or* nan* eiictty »it appears on ttw Section 313 list.)
METHYL ETHYL KETONE
1.3
Generic Chemical Name (Important Complete only if POT 1. Section 2.1 a checked 'yes'. Generic Nam mm bt nroeturadv desciiptiw.)
NA
1.4 Distribution of Each Member of the Oioxin and Dioxin-iike Compounds Category.
(If there are any numbers in boxes 1-17. then every field must be filled in with either 0 or some number between 0.01 and 100. Distribution should
be reported in percentages and the total should equal 100%. If you do not have spetiation data available, indicate NA.)
1 2 3 * 5 6 7 8 9 10 11 12 13 14 15 16 17
NA X
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Centre Chemical Nam Provided by Supplier (Important: Minimum of 70 characters, including numbers, letters, spaces, and punctuation.)
NA
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important Check all that apply.)
3.1
Manufacture the toxic chemical:
3.2
Process the toxic chemical:
3.3
Otherwise use the toxic chemical:
a.
Produce b.
Import
If produce or import:
For on-srte use/processing
For sale/distribution
As a byproduct
As an impurity
a.
b.
c.
d.
e.
As a reactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
emiiBeiiB
4.1
(Enter two-digit code .from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
I
5.2
5.3
Stack or point
air emissions
Discharges to receiving streams or
water bodies (enter one name per box)
Stream or Water Body Name
A. Total Release (pounds/year-)'
(Enter range code or estimate")
B. Basis of Estimate
(enter code)
C. % From Storrmwater
5.3.1
SCIOTO RIVER
17
M
NA.
5.3.2
5.3.3
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this box
and indicate the Part II, Section 5.3 page number in this box. I 1 I (example: 1,2.3. etc.)
EPA form 9350-URev. 01/2001) - Previous editions are obsolete.
For Oioxin or Obxin-like compounds, report in grams/year
" Range Codes: A* 1 -10 pounds; Ba 11-499 pounds: C= 500 - 999 pounds.
-------
Pag« 3 of 5
EPA FORM R
j PART II. CHEMICAL - SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Numoer
145DARCYCORP432
Toxic Chemical. Category or Generic Name
METHYL ETHYL KETONE
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE (Continued)
NA
A. Total Release (pounds/year*) (enter range
code** or estimate)
B. Basis of Estimate
(enter code)
5.4.1
Underground Injection onsite
to Class I Wells
NA
5.4.2
Underground Injection onsite
to Class II-V Wells
5.5.2
Land treatment/application
fanning
NA
5.5.3
Surface Impoundment
NA
5.5.4
Other disposal
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.A Total Quantity Transferred to POTWs and Basis of Estimate
6.1.A.1. Total Transfers (pounds/year*)
(enter range code** or estimate)
6.1.A.2 Basis of Estimate
(enter code)
NA
6.1.B.1
POTW Name
NA
POTW Address
City
State
County
Zip
6.1.B.2
POTW Name
POTW Address
City
State
County
Zip
If additional pages of Part II, Section 6.1 ant attached, indicate the total number of pages
in this box I i and indicate the Part II, Section 6.1 page number in this box
(example: 1,2,3, etc.)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
! 6.2.1 Off-Site EPA Identification Number (RCRA ID No.)
OHD123456789
Off-Site Location Name
ACME INCINERATION
Off-Site Address
1 APPLE STREET
j City
AKRON
State
OH
County
SMITH COUNTY
Zip
99999
Country
(Non-uS)
Is location under control of reporting facility or oarent company?
Yes
No
EPA Form 9350-1 (Rev 01/2001) - Previous editions are obsolete.
* For Oioxin or Dioxin-like compounds, report in grams/year
Range Codes: A = 1 -10 pounds: B = 11 - 499 pounds: C » 500 - 999 pounds.
-------
Pag* 4 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility 10 Number
145DARCYCORP432
Toxic Chemical. Category or Generic Name
METHYL ETHYL KETONE
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (Continued)
A. Total Transfers (pounds/year*)
. (enter range code" or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. 1200
1. M
1. M50
2. NA
2.
3.
3.
4.
6.2.2 Off-Site EPA Identification Number (RCRA ID No.)
OHD000123456
Off-Site location Name
BOB'S LANDFILL
Off-Site Address
2 BEE STREET
City
BLOOMINGTON
State
OH
County
SMITH COUNTY
Zip
99990-
Country
(Non-US)
Is location under control of reporting facility or parent company?
Yes
No
A. Total Transfers (pounds/year*)
(enter range code" or estimate)
B. Basis of Estimate
(enter code)
C. Type of Waste Treatment/Disposal/
Recycling/Energy Recovery (enter code)
1. 100
1. M
1. M72
I 2. NA
2.
2.
3.
3.
4.
4.
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
Not Applicable (NA) -
Check here if no on-site waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
General
Waste Stream
(enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
c. Range of Influent
Concentration
Waste Treatment
Efficiency
Estimate
Based on
Operating Data ?
P12
NA
7A.1c
7A.1d
7A.1e
0%
Yes No
C11
NA
7A.2C
7A.2d
7A.2e
Yes No
50%
P21
NA
7A.3C
7A.3d
7A.3e
Yes No
99%
7A.4C
7A.4d
7A.4e
Yes No
7A.Sc
7A.5d
7A.Se
Yes No
If additional pages of Part II, Section 6.2/7A are attached, indicate the total number of pages in this box
and indicate the Part II. Section 6.2/7A page number in this box: | 1 | (example: 1.2,3. etc)
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete.
For Dioxin or Dioxin-like compounds, report in grams/year
~ Range Codes: A - 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.
-------
Page s of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
TRI Facility ID Number
145DARCYCORP432
Toxic Chemical, Category or Generic Name
METHYL ETHYL KETONE
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) -
Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)]
2
SECTION 7C. ON-SITE RECYCLING PROCESSES
Not Applicable (NA) - Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category
Recycling Methods [enter 3-character code(s)]
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
Column A
Prior Year
(pounds/year*)
Column B
Current Reporting Year
(pounds/year*)
Column C
Following Year
(pounds/year*)
Column D
Second Following Year
(pounds/year*)
8.1
Quantity released'
12000
11000
13000
13000
8.2
Quantity used for energy recovery
onsite
NA
NA
NA
NA
8.3
Quantity used for energy recovery
offsite
NA
NA
NA
NA
8.4
Quantity recycled onsite
NA
NA
NA
NA
8.5
Quantity recycled offsite
NA
NA
NA
NA
8.6
Quantity treated onsite
NA
NA
NA
NA
8.7
Quantity treated offsite
550
1100
1300
1300
8.8
Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
100
8.9
Production ratio or activity index
0000001.20
Did your facility engage in any source reduction activities for this chemical during the reporting year? If not.
enter "NA" in Section 8.10.1 and answer Section 8.11.
8.10
Source Reduction Activities
(enter code(s)]
Methods to Identify Activity (enter cooes)
8.10.1
NA
a.
b.
8.10.2
8.10.3
a.
8.10.4
a.
b.
8.11
Is additional information on source reduction, recycling, or pollution control activities
included with this report ? (Check one box)
YES
NO
EPA Form 9350-1 (Rev. 01/2001) - Previous editions are obsolete. ' For Dioxin or Dioxin-like compounds, report in grams/year
'"Report releases pursuant to EPCRA Section 329(8) including "any spilling, leaking,
pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching.
dumping, or disposing into the environment." Do not include any quantity treated onsite.
-------
APPENDIX A:
THRESHOLD DETERMINATION WORKSHEETS
Sample Documentation - Not For Use
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year: 2000
Chemical: COPPER
#
1
Mixture Name or
Other Identifier
Hi-Copper Brass Tubing
Information
Source
Purchasing
Percent by
Weight
90.0
Total
Weight
(Ib)
100,000
REPORT ABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
Processed
90,000
90,000
Otherwise
Used
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
NA
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORT ABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
25,000
Processed
90,000
25,000
Otherwise
Used
10,000
Sample Documentation Not For Use
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year: 2000
Chemical: HCFC-22
#
1
Mixture Name or
Other Identifier
HCFC-22
Information
Source
Supplier
Percent by
Weight
99.0
Total
Weight
(Ib)
26,000
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
Processed
25,740
25,740
Otherwise
Used
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
NA
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
25,000
Processed
25,740
25,000
Otherwise
Used
10,000
Sample Documentation Not For Use
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year: 2000
Chemical: MEK
#
1
2
3
Mixture Name or
Other Identifier
Paint (AC Components)
All Purpose Adhesive No. 10
Paint (Buildings)
Information
Source
Paint booth logs
Inventory records
Contractor
Percent
by
Weight
10.0
12.0
5.0
Total
Weight
(Ib)
110,000
10,000
20,000
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
Processed
Otherwise
Used
11,000
1,200
1,000
13,200
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
Paint (Buildings)
Exemption
Structural Component
Note Fraction or
Percent Exempt
(ifapplicable)
100
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
25,000
Processed
25,000
Otherwise
Used
1,000
1,000
12,200
10,000
Sample Documentation - Not For Use
-------
Reporting Year: 2000
THRESHOLD DETERMINATION WORKSHEET
Chemical: BARIUM COMPOUNDS
#
\
Mixture Name or
Other Identifier
XYZ Acrylic Resin - Barium
Hydroxide
Information
Source
Inventory records
Percent by
Weight
4.0
Total
Weight
(Ib)
300,000
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
Processed
12,000
12,000
Otherwise
Used
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
NA
EXEMPT SUBTOTAL
Exemption
Note Fraction or
Percent Exempt
(if applicable)
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
25,000
Processed
12,000
25,000
Otherwise
Used
10,000
Sample Documentation - Not For Use
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year: 2000
Chemical: AMMONIA
#
1
Mixture Name or
Other Identifier
XYZ Acrylic Resin
Information
Source
Inventory records
Percent by
Weight
Total
Weight
(Ib)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
3,000
3,000
Processed
Otherwise
Used
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
NA
Exemption
Note Fraction
or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
3,000
25,000
Processed
25,000
Otherwise
Used
10,000
Sample Documentation Not For Use
-------
Reporting Year: 2000
THRESHOLD DETERMINATION WORKSHEET
Chemical: ZINC (FUME OR DUST)
#
1
2
Mixture Name or
Other Identifier
XYZ Acrylic Resin
Hi-Copper Brass Tubing
Information
Source
Inventory records
Purchasing
Percent by
Weight
1.5
9.2
Total
Weight
(Ib)
300,000
100,000
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ib)
Manufactured
4,500*
9,200*
13,700*
Processed
Otherwise
Used
EXEMPTION SECTION
#
1
Mixture Name or
Other Identifier
NA
Exemption
Note Fraction
or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ib)
Manufactured
13,700*
25,000
Processed
25,000
Otherwise
Used
10,000
* Based on assumption that 100% of zinc in these products would be produced in fume or dust form during use. Actually quantity of fume or dust
produced would be considerably less.
Sample Documentation - Not For Use
-------
APPENDIX B:
FACILITY DATA
Sample Documentation - Not For Use
-------
DARCY CORP.
Monthly Inventory Control System: MICS 5.0
File: MICS/CHEMINVEN.OO
Inventory End Date: 12/31/99
Print Out Date: 01/10/00
Item
HCFC-22
XYZ Acrylic Resin
All Purpose Adhesive No. 10
Unit
Ib
Ib
Ib
Inventory On-
Hand
15,000
45,000
1,200
Inventory End Date: 12/31/00
Print Out Date: 01/10/01
Item
HCFC-22
XYZ Acrylic Resin
All Purpose Adhesive No. 10
Unit
Ib
Ib
Ib
Inventory On-
Hand '
9,000
31,000
500
Sample Documentation Not For Use
-------
Darcy Corp.
CHEMICAL PURCHASE TRACKING SYSTEM
Chemical Purchases as of 01/10/01
Beginning Date: 1/1/00
Ending Date: 12/31/00
PRODUCT NAME
HCFC-22
XYZ Acrylic Resin
Hi-Copper Brass
Tubing
All Purpose
Adhesive No. 10
UNITS
Ib
Ib
Ib
Ib
JAN
1,500
23,000
5,000
900
FEB
1,900
22,000
5,000
800
MAR
1,200
24,500
5,000
650
APR
1,800
23,500
10,000
850
MAY
1,500
25,000
10,000
800
JUN
2,600
26,500
15,000
750
JUL
1,500
25,500
10,000
900
AUG
2,200
24,500
15,000
700
SEP
2,200
22,000
10,000
850
OCT
1,500
25,500
5,000
800
NOV
1,100
23,000
5,000
600
DEC
1,000
21,000
5,000
700
ANNUAL
TOTAL
20,000
286,000
100,000
9,300
Sample Documentation - Not For Use
-------
Paint Booth Log - 2000
Operators, please enter:
1) Amount of paint (in gallons) issued to you,
2) Issue date, and
3) your initials.
Paint Quantity
(gal)
670
720
730
710
720
760
740
690
700
750
710
730
710
660
Logged Out
1/2/2000
2/1/2000
3/3/2000
3/28/2000
4/15/2000
5/14/2000
6/8/2000
7/1/2000
7/21/2000
8/16/2000
9/3/2000
10/1/2000
11/8/2000
12/12/2000
Operator
MC
PE
MC
MC
MC
PE
ro
MC
PE
PE
PE
IB
MC
MC
Sample Documentation Not For Use
-------
January 28,2001
Darcy Corp.
145 South Ave,.Ste 220
Columbus, OH 43235
Phone: (222) 46-DARCY
Darcy Corp:
This letter is to inform you that Painters R Us Corp. used 20,000 Ib of paint, which has
been applied to the exterior often (10) Darcy Corp buildings. The total paint measured
contained 5% MEK. We generated 60 Ib of MEK in paint-related waste during the year
2000.
If you need any other information for your records, please do not hesitate to write or call
our customer service.
Sincerely,
Chrissy Heinz
Painters R Us Corp.
1237 W Dunbar Avenue, Suite 950
Louisville, KY 40207
Phone: (502)375-5880
Toll Free: 1-800-35 PAINT
Sample Documentation - Not For Use
-------
January 4, 2001
Darcy Corp.
145 South Ave, Ste 220
Columbus, OH 43235
Phone: (222) 46-DARCY
Darcy Corp:
This letter is to inform you that during the curing of XYZ Acrylic Resin, product number
XYZ-123, 1 Ib of anhydrous ammonia is manufactured for every 100 Ib of resin cured.
If you need any other information about our products, please do not hesitate to write or
call our customer service.
Sincerely,
Bruce Cobum
RESINS, Inc.
472 East Pontiac Drive, Suite 500
Lansing, MI 48911
Phone: (517)482-5000
Toll Free: 1-877-48 8-RESI
Sample Documentation - Not For Use
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AIR QUALITY CONSULTANTS
238 West Findlay Road
Columbus, Ohio 43234
July 12, 2000
Darcy Corp.
145 South Ave, Ste 220
Columbus, OH 43235
RE: Project #1020 - June 21,1999 Adhesive Application Monitoring
Darcy Corp,
At your request, Air Quality Consultants (AQS) conducted monitoring of your facility's
adhesive application area for MEK emissions on June 21, 2000. It was estimated that
84% of MEK contained in the adhesive was released as air emissions during adhesive
application.
If you have any questions or require further assistance, please do not hesitate to call me at
(222) 355-4582.
Sincerely,
AIR QUALITY CONSULTANTS
David Matthews
Industrial Hygienist
Enclosures
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Darcy Corp.
Monitoring data for Discharge Permit Application
Month
1/15/00
2/14/00
3/12/00
4/15/00
5/13/00
6/13/00
7/14/00
8/12/00
9/13/00
10/1 1/00
11/12/00
12/14/00
Flow (gpd)
4000
3,000
3,000
3,500
3,500
4,000
4,500
4,500
5,000
4,500
4,500
4,000
Concentration MEK
(mg/1)
~
2.0
.
Average gallons/ day = 4,000
Total annual flow = 4,000 gpd x 250 days of operation = 1,000,000 gallons
Sample Documentation - Not For Use
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Darcy Corp Annual Waste Summary
Table 4 - Summary of Wastes Containing MEK
Waste
Waste paint
Paint-related waste
Adhesive related
waste
Spent Carbon
Amount Waste
(Ib)
10,000
5,000
2,000
NA*
Cone.
9%
2%
10%
NA*
Amt MEK
Ob)
900
100
200
99
Destination
Acme Incineration
Bob's Landfill
Acme Incineration
Acme Incineration
Data are taken from hazardous waste manifests and profiles. Does not include wastes
generated by contractors.
* Calculations for MEK in spent carbon are based on the following data, provided by the Remediation
Team: 1 shipment of spent carbon was sent to ACME for incineration. The carbon was in service for 10
months from August 1999 to June 2000. The SVE system is estimated to extract from the ground and send
to the activated carbon adsorption unit 10 Ib of MEK every month. Carbon unit is 99 percent efficient in
capturing organic emissions. Therefore, the spent carbon contained 99 Ib of MEK.
Sample Documentation - Not For Use
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APPENDIX C:
MATERIAL SAFETY DATA SHEETS
Sample Documentation Not For Use
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EXAMPLE MSDS - NOT FOR USE
MATERIAL SAFETY DATA SHEET (MSDS)
FOR CHEMICAL EMERGENCY - SPILL, LEAK, FIRE, EXPOSURE, OR ACCIDENT,
CALL CHEMTREC 1-800-424-9300 DAY OR NIGHT
SECTION 1 - PRODUCT & COMPANY IDENTIFICATION
MANUFACTURER/SUPPLIER: ACME MANUFACTURING
Address: 2246 Industry Road
Chillicothe, OH 45601
Product Name: XYZ ACRYLIC RESIN
Item Number: . XYZ-123
Product Class/Use: Acrylic Resin
Prepared: September 13, 1999
SECTION 2 - INGREDIENTS/COMPOSITION
Ingredients (CAS NO.): Percent By Weight:
Hydroxyalkyl Methacrylate (27813-02-1) >10
Synthetic Rubber (126904-15-2) 10
Barium Hydroxide* (17194-00-2) 4
Zinc* (7440-66-6) 1.5
Proprietary ingredients balance
* Ingredient subject to the reporting requirements of SARA Section 313.
SECTION 3 - PHYSICAL DATA
Appearance: White Paste
Boiling Point (°F): >350°F
Vapor Density: Not established
Vapor Pressure: Less than 10mm at 8 T
Odor: Mild
Specific Gravity: Approximately 1.0
Solubility In Water: Slight
pH: Not applicable
SECTION 4 - FIRE AND EXPLOSION HAZARD DATA
Estimated NFPA Code:
Health Hazard: 2 Fire Hazard: 1
Reactivity Hazard 1 Specific Hazard: Does not apply.
SECTION 5 - REACTIVITY DATA
Product Stability: Product is stable under normal handling and storage conditions.
Incompatibilities: None.
Hazardous Polymerization: Will not occur.
SECTION 6 - HANDLING AND SPECIAL PRECAUTIONS
Eyes: Safety glasses or goggles.
Skin: Impermeable gloves recommended for prolonged or frequent use.
Ventilation: Does not apply.
SECTION 7 - HEALTH HAZARD DATA
Toxicity: Possible eye irritant.
Estimated oral LD50 more than 5000 mg/kg.
Estimated dermal LD50 more than 2000 mg/kg.
Primary Routes of Entry: None known.
Signs and Symptoms of Exposure: May cause dermatitis on prolonged contact in sensitive
individuals.
FICTIONAL MSDS - DO NOT USE THIS MSDS
Sample Documentation - Not For Use
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EXAMPLE MSDS - NOT FOR USE
MATERIAL SAFETY DATA SHEET (MSDS)
FOR CHEMICAL EMERGENCY - SPILL, LEAK, FIRE, EXPOSURE, OR ACCIDENT,
CALL CHEMTREC 1-800-424-9300 DAY OR NIGHT
SECTION 1 - PRODUCT & COMPANY IDENTIFICATION
CFC, INCORPORATED
12246 Erie Avenue
Cleveland, OH 44113
CHLORODIFLUOROMETHANE (HCFC-22)
HC-123
Halocarbon 22
February 12, 1998
MANUFACTURER/SUPPLIER:
Address:
Product Name:
Item Number:
Product Class/Use:
Prepared:
SECTION 2 - INGREDIENTS/COMPOSITION
Ingredients (CAS NO.): Percent By Weight:
Chlorodifluoromethane (75-45-6)* >98
* Ingredient subject to the reporting requirements of the Superfund Amendments and Reauthorization Act
(SARA) Section 313.
SECTION 3 - PHYSICAL DATA
Boiling Point (°F): -41.2°F
Vapor Density: 3.9kg/m3
Vapor Pressure: 138.1 psia
Appearance: Colorless, non-flammable gas
Odor: Slightly ethereal
Specific Gravity: 3.1
Solubility In Water: Slight
pH: Not applicable
SECTION 4 - FIRE AND EXPLOSION HAZARD DATA
Estimated NFPA Code:
Health Hazard: 1 Fire Hazard: 0
Reactivity Hazard: 0 Specific Hazard: Does not apply.
SECTION 5 - REACTIVITY DATA
Product Stability: Product is stable under normal handling and storage conditions.
Decomposition Products: If Chlorodifluoromethane is exposed to fire, it may bum yielding toxic products
(e.g., hydrogen fluoride, phosgene, hydrogen chloride, carbonyl fluoride).
Incompatibilities: The following materials are not compatible with Chlorodifluoromethane: sodium,
potassium, calcium, zinc, and magnesium powdered aluminum.
Hazardous Polymerization: Will not occur.
SECTION 6 - HANDLING AND SPECIAL PRECAUTIONS
Eyes: Safety glasses or goggles.
Skin: Impermeable gloves recommended for prolonged or frequent use.
Ventilation: Use with adequate ventilation.
SECTION 7 - HEALTH HAZARD DATA
Toxicity: Mutation in Microorganisms System Test (Salmonella typhimurium) = 33 ppm/24 hours.
Microsomal Mutagenicity Assay (Salmonella typhimurium) = 33 ppm/24 hours.
TCLo (inhalation, rat) = 50000 ppm/5hours (36 day); reproductive effects.
LC50 (inhalation, rat) = 35 pph/15 minutes.
LCLo (inhalation, dog) = 70 pph.
FICTIONAL MSDS - DO NOT USE THIS MSDS
Sample Documentation Not For Use
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EXAMPLE MSDS - NOT FOR USE
MATERIAL SAFETY DATA SHEET (MSDS)
SECTION 1 - PRODUCT IDENTIFICATION
Johnson Paints
121 Johnson Ave., S.W.
Cleveland, OH 44115
JP12 ACRYLIC POLYURETHANE
SECTION 2 - HAZARDOUS INGREDIENTS
Emergency telephone No. (800) 566-2902
Information telephone No (216) 45P-AINT
Prepared November 29,1999
CAS No.
64742-88-7
78-93-3*
123-86-4
14808-60-7
13463-67-7
1333-86-4
Ingredients
Mineral Spirits
Methyl ethyl ketone*
n-Butyl acetate
Quartz
Titanium Dioxide
Carbon Black
Weight per gallon (Ibs)
Solids by weight (%)
Solids by volume (%)
Flash point (°F)
NFPA rating (health - flammability -
reactivity)
JP10PW
Pure
White
JP10UW
Ultra
White
JP10B
Black
Percent by weight
2
10
10
15
30
11
76.5
62
56
2-3-0
2
10
10
25
20
1
11
75
60
56
2-3-0
2
10
15
45
2
11
74
59
56
2-3-0
* Ingredient subject to the reporting requirements of the Superfund Amendments and Reauthorization Act
(SARA) Section 313.
SECTION 3 - PHYSICAL DATA
See table above.
SECTION 4 - FIRE AND EXPLOSION HAZARD DATA
See table above.
SECTION 5 - HEALTH HAZARD DATA
Routes of Exposure:
Effects of Overexposure:
Signs and Symptoms of Overexposure:
SECTION 6 - REACTIVITY DATA
Product Stability:
Decomposition Products:
Incompatibilities:
Hazardous Polymerization:
Inhalation and/or skin or eye contact depending on conditions
of use.
Irritation of eyes, skin and respiratory system. May cause
nervous system depression.
Headache, dizziness, nausea, and loss of coordination are
indications of excessive exposure to vapors or mists.
Stable.
By fire: carbon dioxide, carbon monoxide, nitrogen oxides,
and possibility of hydrogen cyanides.
None known.
Will not occur.
SECTION 7 - HANDLING AND SPECIAL PRECAUTIONS
Eyes: Safety glasses or goggles.
Skin: Impermeable gloves recommended for prolonged or frequent use.
Ventilation: Local exhaust preferable.
FICTIONAL MSDS - DO NOT USE THIS MSDS
Sample Documentation - Not For Use
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EXAMPLE MSDS - NOT FOR USE
MATERIAL SAFETY DATA SHEET (MSDS)
FOR CHEMICAL EMERGENCY - SPILL, LEAK, FIRE, EXPOSURE, OR ACCIDENT,
CALL CHEMTREC 1-800-424-9300 DAY OR NIGHT
SECTION I - PRODUCT & COMPANY IDENTIFICATION
MANUFACTURER/SUPPLIER: ACME MANUFACTURING
Address: 2246 Industry Road
Chillicothe, OH 45601
Product Name: ALL PURPOSE ADHESIVE NO. 10
Item Number: AD-123
Product Class/Use: Box Adhesive
Prepared: July 12, 1999
SECTION 2 - INGREDIENTS/COMPOSITION
Ingredients (CAS NO.): Percent By Weight:
Proprietary ingredients 88
Methyl ethyl ketone (78-93-3)* 12
* Ingredient subject to the reporting requirements of the Superfund Amendments and Reauthorization Act
(SARA) Section 313.
SECTION 3 - PHYSICAL DATA
Appearance: Brown Liquid
Boiling Point (°F): >200°F
Vapor Density: Not established
Vapor Pressure: Not established
Odor: Mild, sweet
Specific Gravity: 1.2
Solubility In Water: Not established
SECTION 4 - FIRE AND EXPLOSION HAZARD DATA
Estimated NFPA Code:
Health Hazard: 1 Fire Hazard: 0
Reactivity Hazard 0 Specific Hazard: Does not apply.
SECTION 5 - REACTIVITY DATA
Product Stability: Stable.
Incompatibilities: Not established.
Hazardous Decomposition: Not established.
Hazardous Polymerization: Will not occur.
SECTION 6 - HANDLING AND SPECIAL PRECAUTIONS
Eyes: Safety glasses or goggles.
Skin: Rubber gloves recommended for prolonged or frequent use.
Ventilation: General dilution ventilation.
SECTION 7 - HEALTH HAZARD DATA
Toxicity: No data available.
Primary Routes of Entry: None known.
FICTIONAL MSDS - DO NOT USE THIS MSDS
Sample Documentation Not For Use
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APPENDIX D:
DARCY CORPORATION PROCESS FLOW DIAGRAM
Sample Documentation - Not For Use
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PLANT 2
Adhesive
1
Adhesive
Storage
Plant I
DARCY CORP
FLOW DIAGRAM FOR MEK
PLANT 1 *
Paint ^ Paint
Storage
t A
^ Paint
Booth
1
1
Process
Wastewater
1 >
|
Waste Paint
t
Rags, Empty
Containers, and
Filters
ACME
Incineration
Bob's
Landfill
1
Process Wastewater
J = Fugitive Air Emissions
I I - Slack Air Emissions
Adhesive
Application
i
Wastewater
Treatment
Scioto
River
1
Waste Adhesive
Storage
Empty Adhesive
Containers
Remediation
Spent Carbon
ACME
Incineration
District
Landfill
ACME
Incineration
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