United States Office of Information March 2002
Environmental Protection Analysis and Access
Agency
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS
Reporting Year 2001
Spring 2002
Module 1: TRI Overview
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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
2001, for reports due on July 1,2002. 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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TOXICS RELEASE INVENTORY
REPORTING REQUIREMENTS
(EPCRA SECTION 313)
CONTACT INFORMATION
ABT ASSOCIATES CONTACTS
Adam Burke
(617) 349-2774
adam_burkeQabtassoc.com
Hilary Eustace
(617)349-2767
hilary_eustace9abtas8oc.com
Trey Kellett
(617) 520-3571
trey_kellettQabtassoc.com
Alice Tome
(301)913-0552
alice.tomeO abtassoc.com
Lia Crompton
(617) 349-2719
lia_cromptonOabtassoc.com
Cheryl Keenan
(617) 349-2778
cheryLkeenanCabta88oc.com
Bill Norton
(617) 349-2788
bill_nortoneabtassoc.com
A-2
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CONTACT INFORMATION
EASTERN RESEARCH GROUP CONTACTS
Leslie Crawford Molly Merrifield
(770) 420-9580 (703) 633-1639
ie8lie.crawford9erg.com molly_merrifield@erg.com
Kurt Rindfusz Torsten Rothman
(703) 633-1676 (863) 699-9125
kurt.rindfusz9erg.com torllynestrato.net
Doug Spengel John Wilhelmi
(703) 633-1605 (781) 674-7312
doug.spengelderg.com john.wilhelmi©erg.com
A-3
WHO MUST REPORT?
Facilities (Private- and Public-sector)
• In covered primary SIC code(s) or Federal facilities; and
• With 10 or more full-time employees (equivalent of 20,000
hours per year); and
• That exceed manufacture, or process, or otherwise use
thresholds for each Section 313 chemical
A-4
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WHAT TO REPORT?
File a TRI report for each Section 313 chemical
exceeding an activity threshold
Submit to U.S. EPA, and either designated state
officials or designated tribal office by July 1st for
preceding calendar year's activities
• July 1,2002 (January 1 - December 31,2001 activities)
A-5
TRI REPORTING PROCESS
YES
T«n Employ***?
(20,000 hours)
MPOU
Section 313
Crwmicob?
YES
YES
YES
o
•MPOU: Menufa(Anr"du^inv(>f1),l>rac)M>oraltMnm»uM
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COVERED SIC CODES
^^H Industrial Sector Primarv SIC Code ^H
Manufacturing
Metal mining
Coal mining
Electrical utilities
Treatment,
Storage, and
Disposal facilities
Solvent recovery
services
Chemical
distributors
Petroleum bulk
terminals
20-39
10 (except 1011, 1081, and 1094)
12 (except 1241)
491 1 , 4931 , and 4939, limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce
4953, limited to RCRA Subtitle C permitted or interim
status facilities
7389, limited to facilities primarily engaged in solvent
recovery services on a contract or fee basis
5169
5171
A-7
FEDERAL FACILITIES
• Federal facilities (covered by Executive Order 13148)
• Owned or operated by Executive Branch agencies
» No restrictions based on SIC code
» Includes federal prisons, national parks, federal hospitals
• With 10 or more full-time employees (equivalent of 20,000
hours per year)
• That exceed manufacture, or process, or otherwise use
thresholds
• Agency responsible for reporting on activities at Federal
facilities that are conducted by, for, or in support of the
agency
A-8
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SIC CODES
Section 313 subjects facilities to reporting based on
classification of primary activities in the Standard
Industrial Classification (SIC) system (§372.22)
On April 9,1997 (62 FR17288), the North American
Industry Classification (NAIC) System was
implemented
SIC codes are to be used until EPA transitions to
new NAIC system in future reporting years
An OMB crosswalk exists between the SIC and new
NAIC codes (see 62 FR 172188)
A-9
DEFINITION OF 'TACILITY"
"Facility - all buildings, equipment, structures, and
other stationary items which are located on a single
site or contiguous or adjacent sites and which are
owned or operated by the same person (or by any
person which controls, is controlled by, or under
common control with, such person)." (EPCRA
§329(4))
Establishment - unique and separate economic unit
of a "facility" (§372.3)
Auxiliary facility - primarily supports a covered
establishment's activities at another facility
A-10
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MULTI-ESTABLISHMENT FACILITY
Three separate establishments located on contiguous/adjacent
property owned by same person(s), Is one facility under EPCRA
(§372.22(b))
Malorltv
Covered
establish-
ments >50%
Plurality
Greatest %
Generic Products Food
Processing
(SIC 2033)
l= - z ?• =
^11 Z*
^"i i
Generic Products Farm
(SIC 0161)
Gen. Prod. Warehouse
(SIC 4222)
A-11
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
• Federal facilities and federal contractors (GOCOs)
| DOT
Coast Guard
HUD
Contractor 1
DOE
_..-"""
Contractor
2
Ex. 1: Two separate reporting facilities
(HUD and DOT including Coast Guard)
Ex. 2: One reporting facility
(DOE)
A-12
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AUXILIARY FACILITY
Non-contiguous and non-adjacent to a covered
establishment
Primary function is to support a covered
establishment's activities at another facility (e.g.,
warehouses, laboratories)
Assumes SIC code of covered establishment for
reporting purposes
Employee and chemical activity threshold
determinations are separate!
A-13
AUXILIARY FACILITY
ACME Mfg. Facilities
(Warehouse Is auxiliary facility of ACME Mfg.)
Sluntta'*
Towing
Mfg.
(SIC 2015)
A-14
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EMPLOYEE THRESHOLD
10 full-time employees (20,000 hours) (§§372.3 and
372.22(a))
• Worked at or directly for facility
• Includes operational staff, administrative staff, contractors,
dedicated sales staff, company drivers, off-site direct
corporate support
• Does NOT include contract drivers or janitorial contractors
Determinations based on available time management
systems/data
A-15
THRESHOLDS TRIGGERING EPCRA
SECTION 313 REPORTING
Section 313 chemicals that are listed as persistent,
bioaccumulative, and toxic (PBT) are subject to separate and
lower thresholds (§372.28)
A facility meeting the SIC code (or Federal facility) and
employee criteria must file a TRI report for a non-PBT Section
313 chemical if the facility (§372.25):
• Manufactured (including imported) more than 25,000 pounds per
year, or
• Processed more than 25,000 pounds per year, oj-
• Otherwise used more than 10,000 pounds per year
Activity thresholds are calculated Independently
Threshold calculations are based on cumulative quantities per
Section 313 chemical over the reporting year
A-16
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THRESHOLDS TRIGGERING EPCRA
SECTION 313 REPORTING
If a facility manufactures, processes, or otherwise
uses any chemicals that are listed as persistent,
bioaccumulative, and toxic (PBT), the threshold
quantity is one of the following per Section 313
chemical or category per year (§372.28):
Threshold Level Tvne of PBT Chemical
100 pound*
10 pounds
0.1 grams
Persistent and bioaccumulative
Highly persistent and highly bioaccumulative
Dloxln and dtoxln-llke compounds
A-17
CATEGORIES OF MANUFACTURING
ACTIVITIES
Manufacturing (§372.3) • generating a Section 313
chemical
• Intentionally producing chemicals for:
-Sale
» Distribution
» On-stte use or processing (e.g., intermediates)
• Coincidentally producing chemicals as impurities or
byproducts:
» At any point at the facility, including waste treatment and
fuel combustion
• Importing
» "Cause" to be Imported
A-18
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CATEGORIES OF PROCESSING ACTIVITIES
Processing (§372.3) - preparation of a Section 313
chemical for distribution in commerce
• Using as a reactant to manufacture another substance or
product
• Adding as a formulation component
• Incorporating as an article component
• Repackaging for distribution
» Including quantities sent off-site for recycling
• As an impurity
A-19
REPACKAGING AS A
PROCESSING ACTIVITY
Repackaging a Section 313 chemical for distribution in
commerce is considered processing
• Repackaging includes transfer:
» From container to tanker truck and vice-versa
» Between similar size containers
» Via pipeline to/from a tank
• Repackaging does not include:
» Sampling without repackaging
» Re-labeling
Repackaging without distribution into commerce is not
considered processing
A-20
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OTHERWISE USE
Otherwise using (§372.3) - includes most activities
that are not manufacturing or processing
• Examples
» Chemical processing aid (e.g., solvents)
» Manufacturing aid (e.g., lubricants, refrigerants)
» Ancillary activities (e.g., chemicals used to remediate
wastes)
A-21
OTHERWISE USE (CONTINUED)
Otherwise use of a Section 313 chemical also
includes on-site disposal, stabilization (without
subsequent distribution in commerce), or treatment
for destruction if:
• Section 313 chemical was received from off-site for the
purposes of further waste management, or
• Section 313 chemical was manufactured as a result of waste
management activities on materials received from off-site
for the purpose of further waste management
Waste management activities include recycling,
combustion for energy recovery, treatment for
destruction, waste stabilization and release
(including disposal)
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CALCULATING ACTIVITY THRESHOLDS
Calculate total amount of Section 313 chemical to a
threshold activity
• Example:
» A plant uses MEK to manufacture liquid industrial
adhesive for distribution in commerce. The plant adds
27,000 pounds of MEK to the liquid adhesive-making
operation during the reporting year, but 3,000 pounds are
volatilized during the operation
» 27,000 pounds of MEK is processed, reporting required
A-23
CALCULATING ACTIVITY THRESHOLDS
Activities that, alone, do NOT constitute an activity
threshold
• Storage
• Remediation of on-site contamination (does not include
chemicals manufactured during remediation)
• Re-labeling without repackaging
• Direct reuse onsite
• On-site recycling
• Transfers sent off-site for further waste management (not
including recycling)
Note: These activities may not be exempt from reporting if
threshold is exceeded through other activities.
A-24
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EPCRA SECTION 313
REPORTING EXEMPTIONS
SECTION 313 EXEMPTIONS
Designed to reduce the burden of reporting
associated with small or ancillary chemical uses
If an exemption applies, then the amount of a
Section 313 chemical subject to the exemption does
not have to be included in:
• Threshold determinations
• Release and other waste management reporting
• Supplier notification
Recognize that exemptions only apply in certain
limited circumstances
"<^~™—^^^™
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SECTION 313 EXEMPTIONS
Types of exemptions (§372.38)
• Deminimis
• Articles
• Laboratory activities
• Otherwise use exemptions
» Motor vehicle maintenance
» Routine janitorial or facility grounds maintenance
» Structural components
» Personal use
» Intake water and air
• Mining (extraction activities and overburden)
B-3
DE MINIMIS EXEMPTION
The quantity of a non-PBT Section 313 chemical in a
mixture or other trade name product is eligible for
the exemption if the chemical is:
• Any non-PBT Section 313 chemicals present at a
concentration of less than 1% by weight (§372.38(a))
or
• An OSHA-defined non-PBT carcinogen present at a
concentration of Jess than 0.1% by weight
B-4
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption can apply to non-PBT
chemicals:
• In mixtures or other trade name products processed or
otherwise used
• Only two manufacturing activities:
» Coincidentally manufactured as impurities that remain in
products
» Imported in mixtures or other trade name products
B-5
DE MINIMIS EXEMPTION
How It Works
De minimis exemption does not apply to:
• Manufacturing chemicals (in most cases)
» Manufacturing chemicals as by-products
» Coincidentally manufacturing chemicals
- As by-products of waste treatment or fuel
combustion
• Section 313 chemicals listed as persistent, bioaccumulative,
and toxic (PBT) (except for supplier notification)
B-6
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption does not apply to:
• Wastes and waste streams, from non-exempt sources, that
are processed or otherwise used
» Wastes received from off-site for purposes of on-site
incineration
• Releases and other waste management activities from
mixtures or other trade name products that are not
associated with a processing or otherwise use activity
» Material storage not associated with processing or
otherwise use activities
B-7
DE MINIMIS EXEMPTION
How It Works
• De minimis concentration for toluene is 1.0% (not an OSHA
carcinogen)
Cleaning
Mixture
0.5% Toluene
(exempt)
Raw Material ___
Mixture
90% Toluene
(not exempt)
Toluene in cleaning mixture is below de minimis concentration
and is eligible for the exemption
B-8
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DE MINIMIS EXEMPTION
How It Works
Processing a non-PBT Section 313 chemical In • mixture to below the d» mlnlmlt
concentration does poj exempt the chemical from threshold determinations and
release and other waste management calculations
Raw Material
Primer Mhrturw
(90% Toluan«)
Toluene 21%
• Of mlnlmlt exemption do«t not apply
• ThFMhold determination required
• Release and other watt* management
calculation* required
Paint Product*
(<1%Toluene)
Toluene <1%
• D* mlnlmlt exemption does not apply
• Threehold datarmlnatlon required
a Retee.se and other waste management
calculations still required
B-9
DE MINIMIS EXEMPTION
How It Works
Processing a non-PBT Section 313 chemical In a mixture to above the
do mlnlmls concentration triggers threshold determinations and
release and other waste management calculation requirements
Crude oil
containing trace
amount* of
toluene
Toluene <1%
• De mlnlmlt exemption can apply
• Do not Include In threshold
• Do not Include In release and other waste
management calculations
Petroleum
products
containing
concentrated
toluene
Toluene >1%
De mlnlmlt exemption does not apply
I • Threshold determination required
' • Release and other waste management
I calculations required B-10
i:
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ARTICLES EXEMPTION
"Article" is defined (§372.38(b)) as an item that is
already manufactured and:
• Is formed into a specific shape or design during
manufacture; and
• Has end-use functions dependent in whole or in part on its
shape or design during end-use; and
• Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility
The articles exemption does not apply to the
manufacture of articles
B-11
ARTICLES EXEMPTION
How It Works
Releases of a Section 313 chemical from an article may
negate the exemption. To maintain the article status,
total releases from all like Items must be:
• In a recognizable form; or
• Recycled, directly reused; or
• 0.5 pounds or less (may be rounded down to zero)
If more than 0.5 pounds of a Section 313 chemical are
released from all like items in a non-recognizable form
and are not recycled or directly reused, none of the Kerns
meet the articles exemption
B-12
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ARTICLES EXEMPTION
Examples
Wire is cut to specified lengths. Wastes include off-spec
cuts and dust
• Generation of off-spec cuts that are recognizable as articles
will not, by itself, negate the article status
• Dust and off-spec cuts not recognizable as articles, with
greater than 0.5 pounds of a Section 313 chemical released,
and not recycled or directly reused, negate the article status
Fluorescent light bulbs are installed containing mercury.
The used bulbs are crushed in an enclosed container
prior to recycling
• Crushing bulbs prior to disposal is not considered release
during use; exemption is not negated
B-13
ARTICLES EXEMPTION
Examples
Pipe is cut to specified lengths. Wastes include off-
spec cuts and dust
• Facility estimates that from all uses of the same type of pipe
over the reporting year, a total of 2 pounds of chromium
releases and 0.3 pounds of nickel releases occur
• Because total chromium releases are greater than 0.5
pounds over the reporting year, the articles exemption is
negated for all uses of the pipe including both the chromium
and nickel in the pipe (even though total nickel releases
were less than 0.5 pounds)
B-14
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LABORATORY ACTIVITIES EXEMPTION
Section 313 chemicals manufactured, processed, or
otherwise used in certain laboratory activities,
performed under the supervision of a technically
qualified individual, may be eligible for the
exemption (§372.38(d))
Activity must occur in a laboratory to be exempt
Laboratories, themselves, are not exempt
B-15
LABORATORY ACTIVITIES EXEMPTION
Definition of technically qualified individual (§720.3(ee))
• Capable of understanding the health and environmental
risks associated with the chemical substance which is used
under his or her supervision because of education, training,
or experience, or a combination of these factors;
• Responsible for enforcing appropriate methods of
conducting scientific experimentation, analysis, or chemical
research to minimize such risks; and
• Responsible for the safety assessments and clearances
related to the procurement, storage, use, and disposal of the
chemical substance as may be appropriate or required
within the scope of conducting a research and development
activity.
B-16
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LABORATORY ACTIVITIES EXEMPTION
How It Works
• Section 313 chemicals manufactured, processed,
or otherwise used in these laboratory activities
are eligible for the exemption
• Sampling and analysis
• Quality assurance
• Quality control
B-17
LABORATORY ACTIVITIES EXEMPTION
How It Works
• Section 313 chemicals manufactured, processed,
or otherwise used in these laboratory activities
are NOT exempt
• Any activities conducted outside laboratories
• Specialty chemical production
• Pilot-scale plant operations
• Support services
• Photo processing
• Equipment maintenance/cleaning
B-18
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MOTOR VEHICLES EXEMPTION
Section 313 chemicals otherwise used to maintain
motor vehicles operated by the facility are eligible
for the exemption (§372.38(c)(4))
Examples of motor vehicles eligible for the
exemption include cars, trucks, airplanes, and
forklifts
Examples of exempt motor vehicle maintenance:
• Body repairs
• Parts washing and plating
• Fueling and adding other fluids (e.g., ethylene glycol)
B-19
ROUTINE JANITORIAL OR FACILITY
GROUNDS MAINTENANCE EXEMPTION
Section 313 chemicals contained in products otherwise
used for non-process related routine janitorial or facility
grounds maintenance are eligible for the exemption
(§372.38(cX2))
• Phenol in bathroom disinfectants
• Pesticides in lawn care products
Section 313 chemicals otherwise used in process-related
activities are not exempt
• Facility equipment maintenance
• Cleaning or maintenance activities that are integral to the
production process of the facility
B-20
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STRUCTURAL COMPONENT EXEMPTION
The otherwise use of Section 313 chemicals, that are
part of structural components of a facility, are
eligible for the exemption provided the structure is
not process related (§372.38(c)(1))
• Copper in pipe used in construction of employees'
bathroom facilities
• Metals, pigments, and solvents in paint applied to facility
structure
B-21
OTHER EPCRA SECTION 313 EXEMPTIONS
Section 313 chemicals contained in non-process
related items for employee personal use
(§372.38(c)(3))
• HCFC-22 in air conditioners used solely for employee
comfort
• Chlorine used to treat on-site potable water
• Phenol in a facility medical dispensary
Section 313 chemicals found in intake water (e.g.,
process water and non-contact cooling water) and
air (e.g., used as compressed air) (§372.38(c)(5))
B-22
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SIC CODE-SPECIFIC EXEMPTIONS
SIC Code 12: Coal mining extraction activities are exempt
from threshold determinations and release reporting
(§372.38(g))
• Coal extraction: the physical removal or exposure of ore,
coal, minerals, waste rock, or overburden prior to
benef iciation, and encompasses all extraction-related
activities prior to benef iciation (§372.3)
SIC Code 10: Chemicals in metal mining overburden that
are processed or otherwise used are specifically exempt
from TRI reporting (§372.38(h))
• Overburden: unconsolidated material that overlies a
deposit of useful materials or ores (§372.3)
B-23
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DETE
^•V
KMININ( r THRESHOLD!
TRI REPORTING PROCESS
Stepl
Identify «ection
313 chemicals and
determine the
quantity
manufactured,
processed, of
otherwise used at
the site.
*
Step 2
If the quantities
of section 313
chemicals
exceed the
reporting
thresholds,
reporting Is
required/
Identity total
releaiet «nd
off-site tr&nsfers
V
Identify other
management
practices
•If reporting thresholds are not exceeded, no reporting is necessary.
Identify source
reduction
activities
Complete
C-2
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DETERMINING THRESHOLDS
Identify what Section 313 chemicals are handled on-
site
Identify concentrations of Section 313 chemicals
Collect data and calculate quantities towards each
threshold
C-3
DETERMINING THRESHOLDS
Identify Chemicals and Collect Data to Calculate
Concentrations: , Thresholds:
MSDS
Specifications
Inventory Records
Throughput/Production Data
Waste Profiles Purchase Records
Process Knowledge EPCRA or Other Env. Reports
Other References (AP-42, Ask the User
Merck Index)
Call the Vendor
Supplier Notification
C-4
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SECTION 313 CHEMICALS AND CHEMICAL
CATEGORIES
• Original list developed from Maryland "High
Production Volume" and New Jersey "Right to
Know" chemical lists
• Current list contains over 600 individual chemicals
and chemical categories (See Table II of the EPA's
TRI Reporting Forms and Instructions document)
• Petition process to add or delete chemicals or forms
of chemicals (EPCRA Section 313(e))
C-5
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 (see Table II of
EPA's TRI Reporting Forma and Instructions document):
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 Only manufacturers using strong
acid process
Phosphorus 7723-14-0 Yellow or white
Saccharin 81-07-2 Manufacture only
Hydrochloric acid 7647-01-0 Acid aerosols
Sulfuric acid 7664-93-9 Acid aerosols
Vanadium 7440-62-2 Except when contained in alloy
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SECTION 313 CHEMICALS
Calculate threshold determinations and releases and
other waste management estimates by multiplying
the percentage of a Section 313 chemical by the total
amount of the mixture, other trade name product, or
waste
• Example: 80,000 pounds of a solvent containing benzene
was used on-site at the facility to clean machinery. The
solvent contains 10% benzene.
» 80,000 Ibs. X10% s 8,000 Ibs. of benzene otherwise used
C-7
COMPOUND CATEGORIES
Count together all compounds that fall within a category,
even if different compounds within a category are used in
separate operations
• Example: If a facility processes 20,000 pounds of 2-Butoxyethanol
in one operation and 10,000 pounds of 2-(2-Butoxyethoxy)ethanol
In another operation during the reporting year
» 30,000 pounds of glycol ethers have been processed.
Reporting for glycol ethers category Is required
Consider the entire weight of the compounds in the
category when determining thresholds
• Calculations for release and other waste management estimate are
different for metal and nitrate compounds
C-8
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SUPPLIER NOTIFICATION FOR
MIXTURES AND OTHER TRADE NAME
PRODUCTS
Supplier notification (§372.45) - requires suppliers to
facilities described in §372.22 (i.e., covered facilities)
to:
• Identify Section 313 chemical(s) by name and CAS number
• Identify Section 313 chemical(s) as being subject to Section
313 requirements
• Provide concentration (or range) of Section 313 chemicals
in mixtures and other trade name products (not wastes)
• Provide notification at least annually in writing or attached
to the MSDS
• Update notification when changes occur
• Only facilities In primary SIC codes 20-39 must Initiate the
notification
09
DETERMINING CONCENTRATIONS IN
MIXTURES OR OTHER TRADE NAME
PRODUCTS
Include a Section 313 chemical in the threshold
determinations if you know (§372.30(b)(3)):
• Exact concentration - use concentration provided
• Upper bound - use upper limit
• Range - use the midpoint of the range
• Lower bound - subtract out other known constituents,
create a range, and use the midpoint of range
Note: Thresholds are based on weight in pounds,
except for dioxins and dioxin-like compounds
C-10
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DETERMINING CONCENTRATIONS
IN WASTES
De mlnlmls exemption does not apply to wastes that
are processed or otherwise used
If concentration is exact, upper bound, range, or
lower bound, use the guidance for mixtures and
other trade name products
If concentration is below detection limit, use
engineering judgment:
• If the Section 313 chemical is expected to be present, you
could assume 1/2 of full detection limit
• H the Section 313 chemical is not expected to be present,
you could assume 0
C-11
MEETING MULTIPLE THRESHOLDS
There are many situations where one Section 313
chemical must be counted towards multiple activity
thresholds
• Section 313 chemicals manufactured or Imported on-site, then
used or Incorporated Into a product (processed)
• Section 313 chemicals formed during destruction of wastes
received from off-site and subsequently destroyed on-slte
(manufactured and otherwise used)
• Section 313 chemicals that are otherwise used on-site, recycled,
then processed
Section 313 chemicals should not be counted twice
towards the same activity threshold
C-12
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WATCH FOR DOUBLE COUNTING WITHIN
THE SAME ACTIVITY THRESHOLD!!!
• For threshold determinations, Section 313 chemicals
reused or recycled at a facility: count original
amount used only once (§372.25(e))
• Note: Section 313 chemicals sent off-site for recycling and
returned to the facility are considered new materials and
counted for threshold determinations
• For materials in use from previous years: count only the
quantity added during current reporting year
C-13
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
• Multi-establishment facility (§372.30(c))
» Apply threshold determination on aggregate amount of
chemicals used at facility
» Able to file separate Form R reports for each
establishment if they are distinct economic entities (must
be designated as part of a facility on Form R)
» Report all releases and other waste management
activities of reportable Section 313 chemicals
» Avoid double-counting of chemicals involved in intra-
facility transfers
C-14
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CALCULATING THRESHOLDS
• Consider all activities
• Consider all sources
• Identify the avenues through which mixtures and
trade name products enter your facility
• Purchasing/Inventory control
• Contractors
• Bulk deliveries
• Capital purchases
• "Credit card" or "emergency" purchases
• Chemicals used In neutralization, refrigerants, cleaners,
paints, lubricants (for non-vehicles), fuel (for non-vehicles),
refractory bricks
C-15
ORCHESTRATING DATA COLLECTION
Methods for orchestrating data collection
• Coordinate with purchasing/vendors
• Develop inventory controls
• Require requisition or "sign out" procedure for Section 313
chemicals
• Take year-end inventories
Identify ALL chemical purchasing and usage
Threshold determination worksheets for both PBT
and non-PBT Section 313 chemicals
C-16
-------
EXAMPLE: EPCRA S*C*M 313 No»PBT CV
FadltyNum: OMMlPHEMrrAI.
rtbf IbMhoU WocUiert
Twk Chcnfcil or Omk
D«le WorUMet Prepared:
FrapwdBy: JJSi»
Stepl
(C-C,)
Conf«re to Umrtioldi lortKOam 313 reportUc.
C-17
MANAGEMENT PRACTICES
Begin early
• Implement a program to gather "real-time" data on usage
• Searches for historical information can be difficult
Use a team approach
• Include all relevant personnel (e.g., engineering,
environmental, operations)
• Spread the work
C-18
-------
RECORDKEEPING
Detailed records
• Improve reporting accuracy and data quality
• Reduce replication of effort from year to year
Well-labeled calculations and assumptions
• Serve as standard operating procedures (SOPs) for future
years
• Ensure consistency from year to year, especially if
personnel responsible for reporting change
EPA will review records during a data quality audit
C-19
TRI REPORTING SOFTWARE
For the Reporting year (RY) 2001, EPA is distributing
two types of reporting software to assist facilities in
reporting to the Toxics Release Inventory (TRI).
The TRI-Made Easy (TRI-ME) Reporting Software was
distributed to a limited number of facilities for a pilot
in RY 2000. It is now available to all facilities for RY
2001.
The Automated TRI Reporting Software (ATRS) is the
traditional reporting software that has been
distributed by EPA for a number of years.
For RY 2001, facilities may report using either ATRS
or TRI-ME; however, EPA plans to transition from
ATRS to TRI-ME in the near future.
C-20
-------
TRI REPORTING SOFTWARE
Both ATRSttnd TRI-ME \N\\\ be distributed via CD ROM to all
facilities that have reported to TRI in the last two reporting
years. The software will also be available to download from
EPA's website at www.epa.gov/tri.
The TRI-ME software is an interactive, intelligent, user-friendly
software program that assist facilities in determining and
completing their TRI reporting obligations. In contrast, while
ATRSallows facilities to complete the Form Rs and As on their
personal computers, it provides much less guidance and
assistance.
Both TRI-ME and ATRSaHovi users to access and search the
TRI Assistance Library (TRIAL). TRI-ME is intelligently linked to
TRIAL so that the user can view pre-selected TRI definitions
and guidance from TRIAL that are relevant to specific TRI-ME
screens.
C-21
OVERVIEW OF FORM R, PART I
Two principal types of information
• Facility-specific
• Chemical-specific
One form must be submitted to EPA and to the
SERC/TERC for each Section 313 chemical or
chemical category exceeding applicable thresholds
(§372.30(a))
C-22
-------
PARTI: FACILITY INFORMATION
Identifies the facility
Provides key data for linking information to other
databases
Identifies key personnel
C-23
PART I. SECTIONS 1 AND 2
Reporting year Is the calendar year to which the reported Information
applies; not the year In which the form Is submitted
Trade secret submissions require substantiation (40 CFR 350)
Two forms are required for trade secret submissions:
• One complete
• One "sanitized" version
PART I FACILITY IDENTIFICATION NFORMATON
SECTION 1. REPORTMQYEAR
SECTION 2. TRADE SECRET MFORMATON
2.1
Mcnt?
DV»» (*romr qimtton M; fl No Donotaraww
£2
tothtooopy D (MM D UIWMM
(AnMM only H •¥£•• hi 1.1)
C-24
-------
PART I. SECTION 3
An original signature is required
Name must be legible (printed or typed)
Title of the official who signs is also required
SECTIONS. CBmFKATONOmpoitenl: B««d md dgn after oompfating m foon Motion*.)
indlh«ttot»b«rtdf^
tra Mcuntotandon
C-25
PART I. SECTION 4.1
• All parts of the facility name and address are essential
• Mailing address required if different from street address
• TRI facility identification number (if a form was filed in a
previous reporting year) or "New Facility" (if reporting for the
first time)
• All establishments at one facility should use the same TRI
facility identification number (if reporting separately)
SECTION*. FACUTYDENnRCATION
4.1
C-26
-------
PART I. SECTION 4.1
Federal facilities
• Enter name of Federal department or agency standard
acronym followed by the site name
C-27
PART I. SECTION 4.2 THROUGH 4.4
• Specify whether the form covers all or part of the facility
• Federal facilities and QOCOs also check either "c" or "d,"
but not both
• List name and phone number
• Technical contact - should be able to explain data to EPA
• Public contact - should be able to represent the facility's
data to the public
SECTION 4. FACOJTYDENnnCATION(ConUnuMl)
4.2
4.3
4.4
TW« rsport contain* infomntion tor i-iAmnilri br-i Rutrti 1-1 AFMml dnooco
(hndintolMOktafcotackclwleibto) *-U tatty bU tatty CU tatty " U Qoco
TwhnlMl Contact NMM
PubUe Contact NMIW
r«taphon*Nur««(lnclud.«n.ood.) |
rtUphon»NimbvOnduc)(arMa>d>) |
C-28
-------
PART I. SECTION 4.5 THROUGH 4.6
Enter covered 4-diqit SIC code(s)
• Enter primary SIC code in first box (a.)
• Enter other covered SIC codes in decreasing order of
significance
Supply latitude and longitude coordinates
4J6
4Jt
SKCod*
-------
PART I. SECTION 5
Private-sector and GOCO facilities
• Enter complete name and Dun & Bradstreet number of parent
company
Federal facilities
• Enter the complete name of department or agency for parent
company (e.g., U.S. Department of Interior)
• Check "NA" for Dun & Bradstreet number of parent company
SECTIONS. PARENT COMPANY INFORMATION
5.1
Piiwl Carftn/t Din * BndttMl Win**
D
NA
(tdgto)
C-31
PARTH: CHEMICAL-SPECIFIC
INFORMATION
Identifies
• Section 313 chemical and its uses at the facility
• Quantities released or otherwise managed as wastes
• Waste management and source reduction activities
• Maximum quantity of the Section 313 chemical on site at
one time
C-32
-------
PART H. SECTIONS 1 AND 2: TOXIC
CHEMICAL OR MIXTURE IDENTITY
Complete either Sections 1.1 & 1.2 or Section 1.3 or Section 2
Enter CAS number or category code and name of Section 313
chemical or chemical category (except on "sanitized" form)
Enter generic name only if claiming Section 313 chemical name
as a trade secret (Section 1.3)
SECTION 1. TOXK CHEMICAL DENTITY
1.1
1.2
C-33
PART H. SECTIONS 1 AND 2: TOXIC
CHEMICAL OR MIXTURE IDENTITY
If supplier claims trade secret, report generic name
by supplier
SECTION 2. MKTURE COMPONENT BCNTirY ' T —J °°IWT
(te»fcCI<«MN«MPie>ldrtb>SqM">"l»*t''rt™«d70d»iK«iii.l^^
C-34
-------
PART H. SECTION 3 OF THE FORM R:
ACTIVITIES AND USES OF THE CHEMICAL AT
THE FACILITY
• Specify use(s) of the Section 313 chemical: manufacture,
process, or otherwise use
• Report only activities taking place at reporting facility
• Check all applicable boxes
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Craekaltluopply)
3.1| Itanutaotm tta todo dMntfoBk
•Q Produce bQ Import
H produce or Import:
d. Q FarMWdMrtxtion
•>. Q Axbypradud
f. D A»«nkr»Mlty
3^( Proem M»l<>itc d»mlc^:
a. D Atiiwdirt
b. Q A« a fonrnfcftlon oomporMnl
C. O Ai«n»rt!ci« component
d. LJ RipadnglnQ
•. CH A»»nlmpiity
3J] oltanrlMUHth*l«dech«iilad:
b. D AuiranJKturingdcl
C. Q AndUuy or other UH
C-35
-------
EXERCISE #1
IDENTIFYING EPCRA SECTION 313 CHEMICALS
Purpose:
Familiarize participants with the chemical lists in Table 2 of EPA's TRI
Forms and Instructions document.
Ability to identify correctly Section 313 chemicals from MSDSs,
Take-Aways:
Materials:
Understanding of nuances of chemical compositions.
TRI Reporting Forms and Instructions document
Material Safety Data Sheets (MSDSs)
Instructions: Attached is a package of chemicals, chemical compounds, and chemical
mixtures present at your facility. Determine if any of these chemicals or
parts of these chemicals is on the EPCRA Section 313 list. If you
determine that a chemical or component of a product or mixture is on the
list present at or above the appropriate de minimis level, prepare a list of
the appropriate Section 313 chemicals and CAS numbers.
-------
IDENTIFYING EPCRA SECTION 313 CHEMICALS
MSDS Name
Section 313 Chemical(s) Name
Concentration
Notes
-------
MEADOWBRODK COMPANY
SPELTER. WCST YlftBlNIA 2C43B
RAW MATERIAL SUPPLIER DATA SHEET
I. TRADE NAME CRUDE ZINC OXIDE
CHEMICAL HAME ZINC COTE ZPA/GAS LJ14-1J-2
MANUFACTURER HEADOWBROOK COMPANY
DX7 OF T. L. DIAMOND & CO., INC.
SPECIFICATIONS GRADE A
£a 50-591 601-681
Fe 1-31 1-3X
Al .8-3.51 .8-3.31
tt> 0.1-0.3 Avc. 0.2 0.1-O.5 Avg.O.ZZ
Cl 0.0-0.31 0.0-O.31
C4 L«*s Than .01 L**m Tbaa .01
Cu 0.04-0.40 0.04-O.40
II. NON TOXIC SOLID MATERIAL WITH A PARTICLE SIZE RANGE
UP TO 1/4. INCH.
III. SPECIFIC CRAVTTY 5.6.
AFPAREHT DEHSITY 130-160 LBS/CU FOOT
NON SQLUABLE 127 VAZER NOR VOLATILE,
LIGHT GRAY, ODORLESS COARSE PONDER
IV. NO FOE OR EXPLOSION HAZARD. CAN REACT VTXH MAGNESIUM
OR CARBON WHEN HEATED.
V. NO PARTICULAR HEALTH HAZARD, TLV (S) FOR PRINCIPLE
INGREDIENT
PEL 3 Hg/M' FOR ZINC OXIDE FUME
VI. TON REACnVC AT AMBH2TT £XCLM WITH MINERAL ACIDS
VII. SPILL OR * jyy PROCEDURES
C!MB up & recurn co Lftbtlftd containera
VII. PERSONAL PROTECTION
Nlosh respirator sti««»cad for comfort when material
is dry & duaey
HANDLERS SHOULD WEAR GLOVES AND SAFETY
31775251*5 PBBE.8B
JIN 12 '« iX:^a
-------
3M Central Offlcts
3M Ccnitr
St. Paul. Minnesota 55144.1000.
612/733-1110
CT
12?«3
MATERIAL SAFETY
DATA SHEET
DIVISION: INDUSTRIAL MINERAL DIVISION
TRADE NAME:
3H BRAND ROOFING GRANULES (VAUSAU, WI3
JH 1.0. NVKSER:
98-0111-1216-0
96-4111-1220-2
98-OU1-12S2-5
98-0111-1290-5
98-0111-1318-*
98-0111-1322-*
98-0111-1348-1
98-0111-1447-1
98-0111-1451-3
98-0111-1457-0
ISSUED: SEPTEMBER 13. 1994
SUPERSEDES t NOVEMBER 23. 199S
OOCWKNTt 10-0170-0
98-0111-1217-8 98-OU1-1218-* 98-0111-1219-4
98-0111-1221-0 98-0111-1222-S 98-0111-1223-*
98-0111-1253-3 98-0111-1278-0 98-0111-1288-9
98-0111-1292-1 91-0111-1293-9 98-0111-1294-7
98-0111-1319-2 98-0111-1320-0 98-0111-1321-0
98-0111-1323-4 98-0111-1324-2 98-0111-1325-9
98-0111-1444-8 98-0111-1445-5 98-0111-1444-3
98-0111-1448-9 98-0111-1449-7 98-0111-1450-5
98-0111-1452-1 98-OU1-145S-9 98-0111-1454-7
98-0111-1484-4 98-0111-1488-5
-TT IMBREniENT
C.A.S. MO^
«•""•«•"*
38.0
25
20
PUGIOCLASE FELDSPAR ..-..-- ,
QUARTZ 14888-40-7*
POTASSIUM FELDSPAR M«n« /
SODIUM SILICATE . IS**-?*''^
KAOLIN JSI'ff'Zw'
CARBON BLACK 1333-84-4 ^
CHROMIUM OXIDE CTRIVALENT CHROMIUM) . . 1308-38-9 *
HYDROTREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES 7*.7*,2:52:5'
RUTILE TITANIUM DIOXIDE *31Z~S8"? Z
IRON OXIDE (FE203) ?-S0':5?:1,
ZINC FERRITE 120*3-19-3
NOTE: THE AMOUNT OF OUST GENERATED WHILE HAMDLIN8JTHESE ROOFIH0 6RAMULES IS
EXPECTED TO VARY OEPENDXN83 OH THE USER'S OPERATION. THE LEVEL OF
RESP1RABLE CRYSTALLINE SILICA IS EXPECTED TO BE LESS THAN 152 OF THE
RESPIRABLE OUST.
Oft CKERZCAL3 SUBJECT TOTRX REPORTI
^PUmNXHO AM8CO»WIIXTY RIGHT-
35.0
35
25
5.0
5.0
0.
0.
0.
0.
0.
THIS PRODUCT COHTAXNS THE F01AOM1NB TOXXC
RtaVIRDlENTS OF SECTZOH 313 07 TTT1X ZZZ Of THE
ACT OF 198ft AXB 4* OK PART 37Zs
CHROMIUM OXIDE (TRZVALENT CHROMIUM)
ZINC FERRITE
tOILINO POZHTt M/A
7APOR PRCSSm< M/A
7APOH OCMZTYs N/A
ETAPORATXON RATti N/A
SOtUBZLZTY IX WATOLi H/A
S». CRAfTTT:
PERCENT TOLATZLCt
TOLAHUC OROANZeSs
Abbreviation*i N/D • Not D«t«r«in«d N/A - Hat Aoolic«bl«
-------
3M General Offices 127&28
**«"•••
3M Canter
5L Paul. Minnesota ::!44.1COO
512/733-11:0
MATERIAL SAFETY
DATA SHEET
USDS: 3« BRAND ROOFING GRANULES CWAUSAU, W13
SEPTEHBER 13, Iff* PA8E,
70C LESS H20 & EXERPT SOLVENT N/A
pHs ......................... SL BASIC
TXSMSXT*: .................. N/A
MELTING POINT ................ N/A
APPEARANCE AND ODOR: Granule., Various colors. sliohtly oiiy odor
rIRE AND EX^Lii J!&H HAZARD DATA ^— ^^^
FLASH POINT: ................. N/A
FLAIDUBLE LUIXTS • LKL: ..... N/A
FLAMIIABLE LZKX7S • UTti ..... N/A
AUTOXSNXTXON TEHPERATUKEs ... N/A
EXZZM60ZSHZNB HEDXAs
Hen-eo«fau«tible. Cheese material suitable fer surroundino fir*.
SPECIAL FTJtX FZCBTXItO PROCEDVRCSs
Net aoolieaele
UHVSUAL TIRE AMD EXPLOSION HAZARDS:
He unusual fire or •xolosien hazards are anticipated.
REACTIVITY DATA
STABILX7T: Stable
XHCanPATZBZLXTT * tUOOIALS TO AVOIBs
Net aselieable.
KA2AROOVS POLrHPtTZATIOMi Will Net Occur
HAZARDOUS OCC021POSXTXOR PROfiUCl A *
. INFORMATIDN
SPILL RESPONSE:
Observe orecautions freei other sections. Collect availed Material.
Use wet sweeoino. eeaveund or water to aveid dusting.
RECORHEHOED DISPOSAL t
Disoese Q+ waste ereduct in a sanitary landfill.
Sine* regulations vary, consult asvlieabla regulations or authorities
before disaosal.
EKYXROIOIENTAL OAXAs
Net detereuLned.
REGULATORY XNPORKATIONs
U.S. EPA Hexsrdous Waste Nuabar « None (Net U.S. EPA Hazardous). In
that event of an uncontrolled release of this Material, the user
should determine if the release) qualifies aa a reeertable quantity.
EPCRA HAZARD CLASS:
FIXE KAZAKH: No PRESSURE: Ne REACTTTITT: No ACUTE: Yes CHROMIC: Yea
"-* «-* •—« M/A - Mat Aaalicable
-------
3M General Offlcss 127«58
JM Center
SL Paul. Minnesota 55144.1 CCC
6IV733.li to „„„ .7
'Mi 3
MATERIAL SAFETY
DATA SHEET
GRANULES
PABEi 3 of 5
ETC CONTACT:
laewdiateiy flush eyea with large eawunts of water. Get Imaedlite
medical attention.
SXZN CONTACT:
No neeo for first aid is anticipated in the) event of skin contact.
ZNRALATXOMs
If signs/sy«ato»s occur, reomve oerson ta fresh air. If
signs/synptoas continue, call a ohysician.
17 SHALLOWED*
Drink twe glasses of water. Call a physician.
7. PRECAUTIONARY INFORMATION ""
CTE PROTECTSONt
Avoid eye contact. The following should be worn alone or in
cesfliriatien. as appropriate. to prevent eye contact: Wear safety
glasses with side shields.
SXZN PROTECTION s
Avoid prolonged or repeated skin contact..
7ENTZLATXON PROTECTION:
If exnaust ventilation is not available, usa appropriate respiratory
protection.
PKOTECTZOHt
Avoid breathing of dust. Select on* of tha following NZOSH approved
respirators- basad on airborne concentration of centssdnants and in
accordance, with OSHA regulations i haif-mmsk duart rosairaxor.
pxcrcBTZON. or ACCZDEMTAI. ZHOESTZONI
Wash hands after handling and before eating.
Nat applicable.
FTRC AND EXPLOSION ATOZBANCEs
Net applicable.
EXPOSURE LZBZTS
•uaiMjflroiroi ^si an—sgiffl
QUARTZ 0.1 mg/mS TWA ACSZH
as ouartx reap, dust
Abbreviations i N/0 - Not Oatarninad N/A - Not Applicable
-------
:M G«narai Offices
.. -5-07 -
- Zl9Z JM Center
9»G£ - SL Paul. Minnesota 55144.1000
512/733-ntO
MATERIAL SAFETY
DATA SHEET
MBS: 3K BSAHO ROOrXNG GXANVLCS (tfAVSAV, WZJ
SSPTS1BCR 13,
POTASSIUM FELDSPAR NOHE~NOMENONE HONE
SOOZUM SILICATE NONE NONE NONE NONE
-------
3M Gfintrai Offlcw
3M Conttr
Si Paul. Minnesota 55144-1000
612/733-1110
07-08
12757
MATERIAL SAFETY
DATA SHEET
PAGE
5°2«H8 ouuraus CWAUSAU, wx:
13, 1994
PAGE: 5 of 5
Irritation (uooar
saranaaa of tha no
- MOns/syaatoas can ineluda
«nd throat, coughing and snaazing.
Prolonged or roeaatad ovaraatoesura. abava
nay causa<
guidelines.
Silicaaisi signs/syvatoss can ineluda shortness of breath and
persistent ceugning.
can ineluda earsistant
laaxtra to thia product.
Pneumceniosis (general): «.«.»,,
caugning and shortness of braath.
IT SHALLOWED,
Ingeation is not a likely routs of
CANCER:
QUARTZ SILICA (14808-40-73 is a oetantial cancer hazard causing lung
tumors by tha inhalation and intratraehaal routes of exoesure in
laboratory animal studiaaCNTP anticipated huaan carcinogen. IARC
probable huaait carcinogen ZA. Calif. Proposition 65).
HEADING SECTION CHANCED SINCE NOVEMBER 23. 1993 ISSUE
INGREDIENTS SECTION CHANCED SINCE NOVEMBER 23. 1993 ISSUE
EMTIRON. DATA SECTION CHANCED SXHCE NOVEMBER 23. 1993 ISSUE
PKECAUT. IHFO. SECTION CHANCED SINCE NOVEMBER 23. 1993 ISSUE
HEALTH KAZfi. DATA SECTION CHANCED SINCE NOVEMBER 23. 1993 ISSUE
Abbraviatienai H/0 - Nat Oatarminad N/A - Nat Aaolicabla
Tha inToraataon en tnia Data Shaa« r»oroaanta our currant data and baaT
ooinion mm to tha oroear uaa in hanaling of this aatarial unaar normal
eonditiena. Any uaa of tha natarial which is nat in canformanea with thia
0-ata Shaar or which invoivaa using tha natarial in coaoination with any
" ' — mfv~ ••**— -«--«•• -i« th» r*«aanaibility of tha uaar.
-------
MATERIAL SAFETY DATA SHEET
-Sealed Air Corporation
I-A
Page i of 6
Issued 4/97
cosm-isoo
EMERGENCY TELEPHONE NO:
(203) 791-3500 M-F 8:30-5:00 ET
CHEMTREC 1-800-424-9300 (for Chemical Emergency
spill, leak, fire exposure or accident 24 hours)
SECTION 1 - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Product Name:
Chemical Name:
Trade Name:
Chemical Family:
Chemical Formula:
INSTAPAK • COMPONENT "A"
Porymethyiene Polvphenviisocyanate
Polymeric MDI
Aromatic Isocyanaies
N.A.
SECTION 2 - COMPOSITION / INFORMATION ON
H*«rd«U< tn»r«ii«l«-
Polymeric Diphenyimethane
Diisocyanate ("polymeric" MDI)
Contains:
4,4>-Diphenyimethane diisocyanate
(4.4--MDI; CAS 101-68-8: s 45% )
Other MDI isomers and oligomers
PAS No
90I6-S7-9
INGREDIENTS
Wt% QSKA.PPL
100 N.E.
0.02 ppm
(Ceiling)
N.E.
i
ACGTH-TIV
N.E.
0.005 ppm
(TWA)
N.E.
SECTION 3 - HAZARDOUS IDENTIFICATION
Health Hazards: Irritating to eves, resnirainrv
occupational exposure limit could cause respir
ERYIEW
system and skin. Inhalation at levels above the
atorv sensitization. The onset of the respiratory symptoms
may be delayed for several hours after exposure. A hyper-reactive response to even minimal
concentrations of MDI may develop in sensitized persons. Sensitized persons should not be exposed to
any mixture containing unreacted MDI.
Piw
-------
•Oft
Seated Air Corporation
cr :unii«n .,r.M >»,t it it tccurlt* 10 in* (
•«*.
,!"•» »rt
i inowMW o« SMMC AW Caroorwicm. Tht ona on •"•«
-------
I-A
Seated Air Corooraiion
l,>imm*mHinmMOi mmi
SECTION 6- ACCIDENTAL RELEASE MEASURES (continued) I
Contain and cover spiil with loose absorbent (earth, sand, sawdust or other absorbent material), or
absorbent pillows, pads or socks. Collect absorbed material in open containers or plastic bags, and treat
with deactivating solution (90% water. 8% concentrated ammonia. 2% detergent). Allow to stand
uncovered for 48-72 hours to permit carbon dioxide to escape and solidification to occur. Wash spill area
with deactivating solution and let stand for 15 minutes or longer. Dispose of spilled material properly.
SECTION 7-HANDLING AND STORAGE 1
r Min. 50* F (10* Q Max. 100* F (ir C)
Average .Sfreif Life; 6 months
Special gensirivirvr Reacts with moisture to produce carbon dioxide gas.
Precaution* to be Taken in Hand ting and Storage; Do not H0re dTPCM UTlCOYtrfd ffUtdOOff Donotresesi
containers unless tt is certain that no moisture contamination has occurred. Do not breathe vapors or allow
skin contact.
SECTION 8 - EXPOSURE CONTROLS/PERSONAL PROTECTION
Limits: OSHA-PEL; 4.4'-DiphenvlraetnanedJisocyanate; CeiUng-0.02 pom
ACGIH-TLY: 4.4'-Dipnenyimethanediisocyanate; TWA-0.005ppm
HMTS Wirsra Coder Health 3
Flam nubility 1
Reactivity 1
PPE B (Personal Protective Equipment)
Respiratory Pmreetion- Due to the low vapor pressufeof this matenai. the PEL is not likely to be
exceeded under normal conditions.
.
protection should be worn. Because of their short life and lack of breakthrough indicators, cartridge type
respirators equipped for organic vapors are generally not recommended for use with, isocyanates. They
can be used for short term emergency situations at concentrations below the PEL where the presence of
adequate breaming oxygen can be assured. Where concentrations exceed the PEL, air supplied respirators
must be used.
Fve Pmteerionr Goggles or safety glasses with side shields.
vg Clothing- Chemical resistant butyl rubber, nitriie rubber, neoprene, or other suitable protective
gloves,
Ventilation; Use local exhaust ventilation if necessary to maintain levels betow the PEL. For guidance en
engineering controls refer to the ACCIH publication -Industrial Ventilation''.
Other- Eyewash station, safety shower and deactivating solution should be available. Refer to the
-Recommendations for the Safe Use and Handling of Instapak* Foam-in-P!ace Chemicals" bulletin betore
handling instaoak* chemicals.
-------
I-A
Seated Air Corporation Page 4 of 6
Issued 4/97
{ SECTION 9 - PHYSICAL AMD CHEMICAL PROPERTIES
Form- Liquid BotKny Point* 406* F (20S* C)
Caian, Dark brown Vaunt- P~™,n~ < 1 0* mm Hg @ 25° C (for Poiymeric MDP,
<">dg"" Slightly aromatic (musty) Snaring fi.»vmr 1.24@22*C
Vapor Pen«tv (Air « I V 8.5 Bn»k Pan«fryj IQJ Ibs/gll
Molecular Wei^hr AppTOX. 350 % Volatile hv Volume^ Nil
Po?m? N. E. Solubility in w«t»t- Not soluble. Reacts slowly with water
to liberate CO? £>
| SECTION 10 - STABILITY AND REACTIVITY
Stability Stable under normal conditions. Avoid temperatures above i 1 0* F (43* C) or beiow 40* F (4° C).
Pntvmgriygttoir May occur at elevated temperatures in the presence of moisture, alkalies, ternary amines and
metal compounds.
Conditions to Avoid; Contact wiw moisture and other nweriais which cc*namacave hydrogen.
Incompatible M*ttrn\v Water, aminm*. mmy k*mm* «««4 .W^t^l* Tfl* rCKSSOtt widt water is slow at
temperatures less than 120*F (49*Q but is accelerated at higher temperatures.
H«yarrinti« DeeomBMttton Prnduety Highly unlikely under normal industrial use. Exposure to fire or extreme
heat may generate oxides of carbon, oxides of nitrogen, and traces of hydrogen cyanide.
{ SECTION 1 1 - TOXICOLOGICAL INFORMATION
Polymeric
LD^ Oral: > 1 5.800 mg/lcg (rat)
LD^ Oermai: >5000 mg/kg (rabbit)
LCw, Inhalation: 370 - 490 mg/mJ/4 hours (rat) for an aerosol of polymeric MDI
Primary RoutefOof gypomrer Skin contact from liquid. Inhalation. However, doe to the low vapor pressure, -
overexposure is not expected under normal conditions unless material is heated or used in a pooriy ventilated
area.
Inhalation; This product is a respiratory irritant and potential respiratory sensrdzer. Inhalation of vapor or
aerosol at levels above the occupational exposure limit can cause respiratory seaamzation. Symptoms may
include irritation to the eyes, nose, throat, and lungs, possibly combined with dryness of the throat, tightness of
chest arid difficulty in breathing. The onset of respiratory symptoms may be delayed tor several hours after
exposure. A hypeiKeacuve response to even minimal coutemiauciui of MDI may develop in sentmrrd person:
Sensitized persons should be removed from any further exposure. Persemwimasmma<
-------
I-A
Seated Air Corporation
(><••. OwOM* CTJIIIO K3J 1'-35CO
. SECTION 11 - TOXICOLOGICAL INFORMATION (continued)
Eve render Liquid can cause eye irritation, tearing, reddening and swelling. Permanent cpmeai injury is
unlikely. Exposure to MD! vapors in excess of 0.02 ppm may cause irritation.
{ngestion is unlikely. Based on the acute orai LD««, (his product is considered practically non-toxic by
mgestion. Ingestion can cause irritation and corrosive action in the mouth, stomach and digestive tract.
Chronic Effects; A study was conducted where groups of rats were exposed for 6 hours/day, 5 days/week for a
lifetime to atmospheres of respirable polymeric MOI aerosol either at concentrations of 0, 02, 1, or 6 mg/mj
(which corresponds to MDI levels equal to the OSHA-PEL, 5 times the OSHA-FcLand 30 times the OSHA-
PEL). No adverse effects were observed at 0.2 mg/m* concentrations. At the I mg/mj concentration, minimal
nasal and lung irritant effects were seen. Only at the top concentration (6 mg/nV) was there an increased
incidence of benign tumor of the lung {.adenoma) and one malionant tumor (adenocarcinoma). Overall, the
tumor incidence, both benign and malignant, and the number of animals with tumors were not different. The
increased incidence of lung tumors is associated with prolonged respiratory irritation and the concurrent
accumulation of yellow material in the lung. In the absence of prolonged exposure to high concentrations
leading to chronic irritation and lung damage, tt is highly unlikely that tumor formation will occur.
Careinoggnteitv! The ingredients of this product (>0.1%) are not classified as carcinogenic by ACGIH or 1ARC.
not regutated as carcinogens by OSHA and not listed as carcinogens by NTP.
Mutayenieitv There is no substantial evidence of mutagenic potential.
Reproductive Effects: No adverse reproductive effects are anticipated.
Teratogenieiry and Fetotoxicityj No birth defects were seen in two independent animal (rat) studies.
Fetotoxiciry was observed at doses that were extremely toxic (including lethal) to the mother. The dose that
produced this effect ( 1 .2 ppm) is 60 times higher than the OSHA-PEL. Fetotoxicity was not observed at doses
that were not maternally toxic. The doses used in these studies were maximal, respirable concentrations well in
excess of the defined occupational exposure limits.
SECTION 12 - ECOLOGICAL INFORMATION
Environmental Fate and Dfctnhmion- It is unlikely that significant environmental exposure in the air or water
will arise, based on consideration of the production and use of the substance.
Persistence and Degradation? Immiscible with water, but will react with water to produce carbon dioxide, and
men and non-biodegradable solids.
Aauatic Torteitvr
LC^ > 1000 my \ (Zebra tlsh) At the highest level of 1 000 rng/1, there were no deaths.
EC* (24 hour): > 1000 my I (Daphne* magna)
EC*: >IOOmg/l(E.Coii)
I SECTION 13 - DISPOSAL CONSIDERATIONS
Incinerate or dispose of in accordance with existing federal, state and local environmental control regulations.
This material is not a hazardous waste under RCRA 40 CFR 26 1 when disposed of in its purchased form. Small
quantities should be treated with deactivatton solution outlined in Section 6. Refer to the "Recommendations tor
the Safe Use and Handling of Instapak' Foam-m-Place Chemicals" bulletin for additional information
concerning disposal of wastes and empty containers. Chemical waste, regardless of quannry, should never oe
pourea into drains, sewers or waterways.
• 'CT.VI .NCMO
*°
-------
Seated Air Corporation
cr ruto
I-A
Page 6 of 6
Issued 4/97
SECTION U - TRANSPORT INFORMATION
QQL Containers less than 5.000 pounds are not regulated.
FMO: Not regulated.
IATA/ICAO ria«f Not regulated.
RCMnafaic Quantity fRQ); 5.000 Ibs. for Methyiene diphenyl diisoeyanate (MOIXCAS #l01-o"M (»45% of
product).
SECTION 15 - REGULATORY INFORMATION
QSHA Status: This product is considered hazardous under the Federal OSHA Hazard Communication Standard
:9CFR!9!0.1200.
TSCA Status- All ingredients are listed or are not required to be listed.
SARA ?0? Frtretneiv Hazardous Substances; None
SARA '"•"*?- Hazard Categoric- Immediate (acute) Health Hazard
Delayed (chronic) Health Hazard
Reactive Hazard
SARA *n Listed Ingredients- This product contains the following chemicals subject to the reporting
requirements: 100% Oiisocyanate compounds (Category Code N120).
Sl?t"*- Discarded product is not a hazardous waste under RCRA. 40 CFR 261. when disposed of in its
purchased form.
i SECTION 16 - OTHER INFORMATION
The following states have regulations that apply to the use of this product.
MA Massachusetts Hazardous Substance List NJ New Jersey Hazardous Substance List
PA Pennsylvania Hazardous Substance List
The-appropnate state agency should be contacted for further details on regulatory requirements for the substance:
shown beiow.
Ingredient
Methyiene bisphenyi isocyanate(MDl)
(Benzene. !.r-methylenebis(4-] isocyanato-)
CAS No.
101-68-8
Wt %
45
Sectioms) Revised: Format change
Primed on recycled paper (50% secondary material.
minimum 10% pest consumer) usmf vegetable based inte
M-3 Re*-4/97
-------
Material Safety Data Sheet
708-438-7800
Section!
IXAOCNAMi
DOT SHIFTING MAMC
Section 2
Hazardous. Ingredients-
norpholiB*
X NA 1719
lQB-91-9
IOO-37-e
% BrCSUKODRUA
< 3S TIM: 20 pp» CtkiaJ
< 30 TIM: iO pp* (skin)
< 40 TUA: 10 pp« (skin)
Sectona
Physical Dale:
JB.
iftle-
ClMf*
gtUw liquid
SoefiOfUi
Fire- & Explosion Hazard Data
ruSHfOMT|kMEIH
13SF TCC
IB
SfKLU BtE TOHTINCf
should tmr full protective gwr itcludiag *»lf e«rUi««d
UNUSUAL FIXE AND EZnOSIONHAZAlO:
Mew k»ou»
SecHonSi
Reactivtty Data
Slroag «eidt* oiidizisg tgnts
toooas
of Mrfem 1
GRACE Dearborn
iDKbtoM W. tGnwiGs. -Cow.. ^X3 CStrwwe Suwt. Id. Zurich. «. 60047 (708)438.1800
-------
Section6
HeoJth-Hozontlnf orrrratiorr
Exposure level mot established for product. See Seetioe 2 for
• - - - - through skis absorptioa.
INHALATION: lahalatioa of eist eag irritate respirator? passages.
ZNGE5T20N: Hareful if swallowed.
SKIN CONTACT: Proloaged or freeueat skia eoataet will cause irritation
aad sag eawse eheeical boras. Possible skin
EMCKCENCT AND FUST AO MOCBXJW
IHHALATXJW:
INK3TIOK:
to fresh air aad treat
give water to dilute aad contact phosieiaa
SKIN CONTACT: Uasb uithsoap * water. Reeove ceataeiaated clothing aad
wash before reuse.
EYE CONTACT: flush with water for 15 eiautes aad swjt eotfical atteatioa.
Section 7
Special Pratectian inrfarrnatian
amet
Uo»9 sleeve work skirt
Sections
Spill or Leak Procedures
SIEK TO ua 9 ttaatM n i
£xtlaauisft all *laee« i« the violiitfl. Uear protective cloifciw
chemical resistasl overstaoes. Dik* spill a*4 soak up as M isert
material. Flush area of spill with water.
abseroeat
WASTE DISPOSAL MiTHOO
Dispose of is aecordavee uitb federal* state a«d local rsjulatieas.
This product is sot forwtlattd uith ebeoieals subject to the repertisf
reouireeeits of Section 313 of the Eeergeaca Planxag aid Cooevsitg
Right-toH<»ou Aot of 1W asd of 40 CFR 372?
Product is eoasidered as EPA igaitablr haxardous waste* 0001 <40 CFR
Product does not coatai* ivgreditsts with CBCU reportael* «tattitits.
Section 9
Special Precautions
PRECAUTIONS TO KtUON M HANOtMG AND STOUOi
Store containers closed asd awag free, ertrcee teeperatares.
OTHER PRECAUTIONS
?OR 1HDUSTRIAU USE ONLY. KEEP OUT OF REACH OF OOLOREN.
HtCMKEOIT: R.
D«t
GRACE Dearborn
Dearborn OMston W '.. GIDCS & Ce. • Conn.. 300 Genaec 3mt. lab Zuridi IL 60047 (7081 ^38-1800
-------
CWJYOK IHDUSTRIES, INC.
P.O. Box 26447
Tecpc, AZ 8S2S5
Phone: 800-255-3423
602-258-2402
Date: Kay 1, 1990
MATERIAL SAFETY DATA SHEET
TtTiixtf itriTtTt n»TtttitttTt»tTt ttitttiit
- PRODUCT IDENTIFICATION
*«««»*«*
ITTIT»TTTTIIITITrTIIlI»TI
Procuc: Nine: AL-S(R) DE-ICINC FLUID
General/Generic ID: Glycol-AlcoMi Sola:ion
rrrrrtTit ecCT]ON H - HAZARDOUS INGREDIENTS ««««• -
TZXTI CX1IS
INGREDIENT
CAS NO
107-21-1
67-63-0
CASNAHE
Wol
ee
Ethylene Clycoi» 107-21-1 !,2-EUaneSiol
Isosropyl Alcohol 67-63-0 2-Pro?anol <10
'S-,-£j£c: to reporting requircKnts of Section 313 of SARA Title III
IITTIITTTZITTTTTfTI
PROPERTY
Ir.UUl Boiling Point
Specific Gravity (H2C*1)
Vapor Density
Percent Volatiles
Ey voluae
Appearance and Odor
Vapor Pressure
Solubility in Water * by Vt.
Evaporation Rate
• SECTION III - PHYSICAL DATA
REFINEMENT
Product
Heavier Than Air
Ingredients with initial
Boiling points below 425 deg F
Product
Butyl Acetate * 1
pa
•••••••
SOppa
TLV (UKITS)
50 pp.
ceiling vapor
400 ppo 400 pps
ICASURLIENT
256 beg F (124 &9 C} €760 cs Kg
1.09S I 68 deg F (20 deg C)
2.5 (Air«l)
100%
Colorless liquid, faint alcohol odor
9.4 M HS I 68 des F (20 eta C)
100)
>1.00
(R) Registered Tradeaark of Canyon Industries, Inc.
Past 1 of S
-------
i*»TTrr»TTi»tttiiTTT»«*T*TTTT»rrT»TTi»»TT» SECTION IV • FIRE AND EXPLOSION DATA *«**»*»««*
Flash Point: 138 deg F (Pensky-nartens, ASTH 93)
Flammable Units
in Air,* by Volume: Component (lowest) Lower: 2.0 Upper: 12.7
Extinguishes Media: Vatcr, Fog or Carton Dioxide or Dry Chemical
Special Fire Fighting
Procedures: Do not spray fires directly. A solid stress of water directed into not, turn in; liquid can
cause frothing. Use self-contained breathing apparatus and protective clothing.
Unusual Fire and
Explosion Hazards: None
NFPA Ha:ard Rating: Health: 1 Fire: 2 Reactivity: 0
TTTT»T»rT»ttT»»»»«»»¥»T«mtiT»m»TTTTTiyT»» SECTION V - "HEALTH HAZARD DATA "*"T"'"TlTtTTTT"T™TT'"T"T"t"-TTT"tTT
Permissible Exposure Level (PEL): SO ppa
Threshold Liait Value (TLV): SO ppa
EFFECTS OF OVEREXPOSURE FOR PRODUCT:
Eyes: Can cause irritation, redness, tearing.
Skin: Can cause irritation. Prolonged or repeated contact can cause irritation, defatting,
dermatitis.
Breathing: Excessive inhalation of vapors can cause nasal and respiratory irritation.
Swallowing: Hay cause abdominal discomfort and pain, dizziness, malaise, lumbar pain, oliguria, uremia,
and central nervous system depression. Severe kidney damage accompanies gross cverexposure.
Chronic effects
of Ovtresposure: Inhalation of Bists may produce signs of central nervous system effects, particularly
dizziness and nystagmus.
Other Health
Hazards: None currently known.
EMERGENCY AND FIRST AID PROCEDURES:
If swallowed: If conscious, give two glasses of water, induce vomiting by sticking finger down throat. Call a
physician mediately. Never give anything by mouth to an unconscious person.
If on skin: Remove contaminated clothing and thoroughly wash exposed area with soap and water. Launder
contaminated clothing before reuse.
If in eyes: Flush with large amounts of water, lifting upper and lower lids occasionally. Get medical attention.
If inhaled: If affected, remove individual to fresh air. If breathing is difficult, administer oxygen. If
breathing has stopped, give artificial respiration. Keep person warm, quiet, and get medical
attention.
Tti»»f IITTTInmnmnmnmrmnn-nnn SECTION VI • REACTIVITY DATA '
HAZARDOUS POLYKRIZATION: Mill not occur Conditions to Avoid: None
STABILITY: Stable Conditions to Avoid: Heat, sparks, and open flsaes
IHCCtfATIBILlTY: Strong oxidizing agents (e.g. nitric and sulfuric acids, permanganates, etc.)
HAZARDOUS CQ5UST10N OR -^ te
DECOrWSITIOM PRODUCTS: Burning may product toxic materials: Carbon dioxide and/or carbon lonoxide, etc.
Page 2 of 3
-------
t>xzxxTTJiziixxx,xzixxTXTiixxxxiTtiTTTTri
SECTION VII - SPILL OR LEAR PROCEDURES
STEPS TO 8E TAKEN IF KATERIAL
IS RELEASED OR SPILLED: -Year suitable protective equipment.
-Stall spills snould be flushed with large quantities of water.
-Larger spills should be collected for disposal.
VASTE DISPOSAL METHOD: Incinerate in a furnace where percittes under appropriate Feceral, State, sr.d local
regulations. See Section IX.
TTZXXXXXXTXZXZXXXXXXrXXXXXXXXXXXXXXXXX SECTION VIII - SPECIAL PROTECTION INFORMATION «*«»*««*«»»«TTXXITXX*XX»»««IT«XXXX
RESPIRATORY PROTECTION: Self-contained breathing apparatus in high concentrations.
VENTILATION Provide sufficient nechanical (general) and/or local exhaust ventilation to oaintain exposure
belovTLV(s).
PROTECTIVE GLOVES: Wear resistant gloves such as: Rubber, Plastic, Neoprene, 8una-N.
EYE PROTECTION: Chemical splash goggles in coapliance wit*) OSXA regulations are advised.
OTHER PROTECTIVE
Eye bsth and safety shower .
IZXXXZTZXZZXXXXXXXITXXXXIXIXXXXXXTXXtXXXXXXX SECTION IX - SPECIAL PRECAUTIONS
PRECAUTIONS TO 8E TAKEN IN HANDLING AND STORAGE:
Keep away froa heat, sparks and open f laces.
Nay be fatal if swallowed.
Do not breathe list. Avoid prolonged or repeated breathing of vapor.
Avoid contact with eyes.
vash thoroughly after handling.
Keep container closed. Do not store in open or unlabeled containers.
FOR INDUSTRIAL IS CM.Y
OTHER PRECAUTIONS: Where heavy concentrations of a fine list arc present, a respirator should be used to
prevent inhaling list particles. Containers of this material cay be hazardous when
eaptied. Since emptied containers retain product residues (vapor, liquid, and/or solid),
all hazard precautions given in this data sheet cost be observed.
The information contained herein is believed to be accurate but is not warranted to be whether originating with
Canyon Industries, Inc. or not. The information is presented solely for consideration, investigation, and
verification. Recipients are advised to confiri in advance of need that the information is current, applicable,
and suitable to their circumstances.
Page 3 of 3
-------
EXERCISER: DETERMINING THRESHOLDS
MANUFACTURING CASE STUDY
Using the information in the exercise, complete the following tasks to determine which
chemicals will require you to prepare a TRI report.
1. Identify each listed Section 313 chemical or chemical category manufactured, processed,
and/or otherwise used at the facility that you should evaluate for threshold
determinations.
2. Use the attached threshold determination worksheets to determine which toxic chemicals
meet or exceed an applicable threshold for manufacture, process, or otherwise use.
3. Prepare Part n, Sections 1,2 and 3 of Form R for each Section 313 chemical that exceeds
an applicable threshold.
Make any necessary assumptions and be prepared to identify the assumptions you have made and
the approach you used in completing this exercise.
Facility Description and Chemical Usage
Darcy Corp. operates adjacent plants at a site in central Ohio: Plant 1 manufactures industrial
refrigeration units and Plant 2 manufactures molded plastic components for a variety of
consumer product applications. Plant 1 employs a staff of 1,600 employees. Plant 2 employs a
staff of 800 full-time employees. The two plants operate independently.
Plant 1 uses Hi-Copper Brass Tubing (90.0 percent copper, 9.2 percent zinc) in the manufacture
of the air conditioners' components. The tubing is cut, bent into the appropriate shapes, and
welded into the air conditioning units. Plant 1 estimates that these activities generate over 0.5
pounds of copper releases to air and water. The purchasing department indicates that Plant 1
received 100,000 pounds of Hi-Copper Brass Tubing in the reporting year.
One of the refrigerants used by Plant 1 in its products is HCFC-22 (>98.0 percent pure). The
A100 series of refrigeration units use HCFC-22. In the reporting year, the facility produced 240
of these units, each of which contains 100 pounds of HCFC-22. Information provided by the
HCFC-22 supplier indicates that they delivered 20,000 pounds to the site's HCFC-22 storage
tank in the reporting year. Inventory records for the HCFC-22 storage tank indicated that the
tank contained 15,000 pounds at the beginning of the reporting year and 9,000 pounds at the end
of the reporting year.
Plant 1 paints certain refrigeration unit components using a paint that contains 10-weight percent
methyl ethyl ketone (MEK), a solvent. Paint booth logs indicate Plant 1 used 110,000 pounds of
this paint in these painting operations.
Plant 2 uses a resin in an injection molding process to make various plastic components.
Inventory records indicate that the facility used 300,000 pounds of the resin in the reporting year.
-------
The resin contains 4-weight percent of barium hydroxide and 1.5 percent elemental zinc.
Information obtained from the vendor indicates that during the curing of the resin, 1 pound of
anhydrous ammonia is generated for each 100 pounds of resin used.
Inventory records indicate that 10,000 pounds of an adhesive that contains 12-weight percent
MEK was used as a solvent in the adhesive application operations in the reporting year.
In the reporting year, a contractor painted the exterior and interior of all buildings on site. The
contractor reported that their paint usage in the reporting year was 20,000 pounds, containing 5-
weight percent MEK.
In the reporting year, remediation of soil contaminated with 1,1,1-trichloroethane and 2-butanone
(MEK) was conducted with a soil vapor extraction (SVE) system. After being processed through
an activated carbon adsorption unit that is 99 percent efficient in capturing the organic emissions,
the exhaust from the SVE system is emitted to the air through a stack. The SVE system is
estimated to extract from the ground and send to the activated carbon adsorption unit 20 pounds
of 1,1,1-trichloroethane and 10 pounds of MEK every month. The carbon is replaced every 10
months and the spent carbon is sent to ACME for incineration.
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
x (if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent
by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction
or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction
or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
Pajj«20f5
TRI Faculty ID Number
Toxfc Chemical. Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete thi» section if you completed Section 2 below.)
1.1
Eaa*flfifroMnuffl^
1.2
1.3
Gan«rtc Chemical N«rne (Important Complrti only »Pert1,See«on2.1 tediecfced'Vei''. Generic Ntmemurf be ihuetoMllydMorfr^)
1.4 Distribution of Each Member of the Dloxin and Dioxln-llke Compound* Category.
(If there are any nunbare In ba»s 1-17, then »vary«eMn
be reported In percentages and me Mai should equal 100%. If you do not have spadetton data available, Indicate NA.)
1 2 3 4 S « 7 • 9 10 11 12 13 14 15 16 17
NA
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section If you completed Section 1 above.)
2.1
GentfcO^ttf Name Rwided by Suppler (taporort
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important1 Check afl that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
Produce b. I import
c.
d
e.
f.
If produce or Import
For on-sfte use/processing
ForsateWbtrttxJdon
As a byproduct
As an impurity
a.
b.
c.
d.
e.
Asareactant
As a formulation component
As an article component
Repackaging
As an Impgrtty
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
5.1
5.2
5.3
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
A, Total Release (pounds/year)
(Enter range code or estimate")
& Basis of Estimate
(enter coda)
C. % From Stormwatar
Discharges to receiving streams or
water bodes (enter one name per box)
Stream or Water Body Name
5.3.1
5.3.2
5.3.3
if additional pages of Part It. Section Mare attached, Indicate the total number of pages m this box
and indicate the Part i, Section S3 page number m this box. I I (example: 1,2,3, etc.)
EPA Form 9350-1 (Rev. 01/2001) - Previous edfflons are obsolete.
* For Dfoxln or Dtodn-ilce compounds, report In grams/year
' Range Codas: A* 1 -10 pounds; 8« 11- 499 pounds C= 500 - 999 pounds.
-------
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
Pa0«2of5
TRl Facility ID Number
Toxte Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this section If you completed Section 2 below.)
1.1
CAS Number (imperteiit&^(lm|xirt«^
1.3
CoH^
1.4 Distribution of Each Mambar of th» Dloxln and Dloxln-llka Compound* Category.
(If than am any number* In boxes 1-17, then every field must be fltod In wftti either 0 or sorr»i«i*w between 0.01 ami 100. DIsirtbutiori should
be reported In percentages and twttal should eo^iat 100%. If you eta rot have speclattan data avaiabteJrKflcateNA.)
1234 $ « 7 a 9 10 11 12 13 14 15 16 17
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO WTowplstattris section If you completed Section 1 above.)
2.1
GeMrfcCh
Pitted by S^^fbnp^
SECTION 3. ACnVFTIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check «U 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
c.
d
e.
i
tf produce or Import
For c«vsae use/processing
For sateAUibuflon
As a byproduct
Asanlmpurty
a.
b.
e.
d.
a.
Asareactant
As a formulation component
As an arVda component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Andttary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
X Total Release (pounds/year)
(Enter range code or estimate'*)
a Basis of Estimate
(enter code)
C. % From Storm water
FHigMva or non-point
Dischargas to reoaMng streams or
water bodies (enter one name par box)
Stream or Water Body Name
tf additional pages of Part B.SecBon Mara attachad. bxttcate the total number of pages hi this box
am] lrxfi(^etrM Part I, Section SJpag«numt>er In thJstxtx. I I (example: 1 A3, etc.)
S'A Form 9350-1 (Rav. 01/2001) - Previous adttons are obsolete.
* For Dtadn or Dloxln-lka compounds, report In grams/year
1 Range Codes: A» 1 -10 pounds; B« 11- 499 pounds; C= 500 - 999 pounds.
-------
Pag*2of5
EPA FORM R
PART il. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Tcodc Chemical, Category or Generic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important: DO NOT complete this **ctlon If you completed Section 2 below.)
1.1
CAS Number (Important Ent» only (»«numb«f«ac%M»ipp«^
1.2
Toxic Ch«mic«l
-------
TRI RELEASE AND OTHER WASTE
MANAGEMENT REPORTING
THE EPCRA SECTION 313 REPORTING
PROCESS
Slept
Step 2
Identify section
determine the
quantity
manufactured,
processed, or
otherwise used at
the site.
HttM quantities
of section 313
exceed the
thresholds,
reporting is
required'
If reporting thresholds are not exceeded, no reporting Is necessary.
Identify tots)
releases and
off-site transfer*
E-2
-------
SECTION 313 REPORTING
Importance of a structured process for release and
other waste management reporting
• Ensures accurate data
• Reduces burden in completing Form R report
» Systematic approach reduces redundancy over time
» Team approach distributes responsibility
• Ensures compliance with TRI reporting requirements
E-3
REPORTING METHOD
Identify potential release and other waste management
sources
Identify available data and tools
Collect data
Estimate quantity of chemical being released and
otherwise managed as waste
Document your work
E-4
-------
TOOLS AND DATA SOURCES FOR
CALCULATING REPORTING ESTIMATES
• Process flow diagrams
• Waste management manifests, invoices, and waste
profiles
• Environmental monitoring data
• Permit applications
• RCRA (BBS), NPDES, CAA, CERCLA and other env.
reports
• Engineering calculations and other notes
• EPA guidance
E-5
CALCULATING REPORTING ESTIMATES
Consider all sources (routine and non-routine)
Reasonable estimates required by law
Facility determines best approach
Data and approach must be documented
E-6
-------
TECHNIQUES FOR ESTIMATING
CHEMICAL QUANTITIES
Use of monitoring data (M)
Mass balance calculation (C)
Use of emission factors (E)
Engineering calculations (O)
Use the code on the Form R for the method used to
estimate the largest portion of the release
E-7
ANALYSIS OF MONITORING DATA
Product of measured concentrations, volumetric
flow rates, and density equals pounds of chemical
released per year
Most commonly used for wastewater (Discharge
monitoring reports (DMRs))
Use Basis of Estimate code "M" if calculations based
primarily on monitoring data
E-8
-------
MASS BALANCE CALCULATION
Mass Balance is based on the law of conservation of
mass
Input + Generation = Output + Amount Reacted +
Accumulation
Most useful in simple situations
Use Basis of Estimate code "C"
• Example: Estimating wastewater releases from process
E-9
USE OF PUBLISHED EMISSION FACTORS
Emission factors are used to describe the quantity of
chemical released as a function of:
• Specific chemical used
• Specific process used
• Specific equipment used
Available in Compilation of Air Pollutant Emission
Factors (AP-42)
Use Basis of Estimate code "E" only when chemical-
specific emission factor is used
E-10
-------
ENGINEERING CALCULATIONS
Calculations based on best engineering
judgment/assumptions
Calculations based on process knowledge
Use of non-chemical-specific emission factors
Use of non-published emission factors
Use Basis of Estimate code "O"
E-11
NON-PBT CHEMICAL ESTIMATES
Values for non-PBT Section 313 chemicals must be
entered in whole numbers
• EPA allows using two significant figures when reporting
releases and other waste management estimates
• If estimate Is more precise, additional significant figures
should be used based on precision of data used to calculate
the estimate
• For estimates of non-PBT Section 313 chemicals under
1,000 pounds, a range code can be used:
» A= 1-10 pounds; B = 11-499 pounds; C = 500-999 pounds
E-12
-------
"NA" VS. "0"
Use "NA" (not applicable) when no possibility of the Section
313 chemical being released to or otherwise managed as waste
in that media (e.g., facility has no on-site landfill) or when no
release to or other waste management in the specific media
occurs
Use "0" when no release occurs or < 0.5 pounds of a non-PBT
Section 313 chemical from a waste stream is directed towards
that medium
• Example: Discharge to water Is zero; however, release possible if
control equipment falls
• Must Indicate a Basis of Estimate code (I.e., M, C, E, O) for all
numerical estimates, Including "0"
E-13
PART n. SECTION 4: MAXIMUM AMOUNT
OF THE TOXIC CHEMICAL ON-SITE AT
ANY TIME DURING YEAR
• Insert appropriate code from instructions indicating the
maximum quantity on-site
• Use maximum total (non-exempt) amount present at one time
during reporting year, even if the Section 313 chemical is
present at more than one location at the facility
• Include amounts in storage, processes, and wastes (but not
those amounts which have been previously land disposed)
SECTION 4, HAXMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE
AT ANYTME DURMG THE CALENDAR YEAR
4.1
(Enter two-dlgH code fromlnstmdton package.)
E-14
-------
PART II. SECTION 4: MAXIMUM AMOUNT
OF THE TOXIC CHEMICAL ON-SITE AT
ANY TIME DURING YEAR
• Part II, Section 4.1: Maximum amount on-site at any
time during the calendar year
• Based on amount in storage, process, and wastes
• Not the same as Tier II maximum amount on site
» Tier II is usually by mixtures, Form R is chemical-specific
» Tier II excludes hazardous wastes, Form R does not
• Data sources
• Tier II records/calculations
• Waste Inventory data
E-15
PART H. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Report total releases of the Section 313 chemical to
each environmental medium on-site
In column A, Total Release, report total quantity
• A range code can be used for non-PBT Section 313
chemical quantities less than 1,000 pounds
» A = 1 -10 pounds
» B = 11 -499 pounds
» C = 500 - 999 pounds
E-16
-------
PART H. SECTION 5: ON-SITEAIR
EMISSIONS
• Section 5.1 Fugitive or non-point air emissions
• Enter total fugitive releases of the Section 313 chemical In column
A, including leaks, evaporative losses, building ventilation, or other
non-point air emissions
• Section 5.2 Stack or point air emissions
• Enter total releases to air from point sources, including stacks,
vents, pipes, ducts, storage tanks, or other confined air streams
SECTIONS. OJAmTTYOFTHETOMCCHEWCALENTERIW EACH ENVIRONMENTAL MEDIUM
5.1
Fu0lttw or noo-polnt Blr
DMA
DMA
A.*
1-111
FUGITIVE EMISSIONS
Part II, Section 5.1: Fugitive or non-point air
emissions
• Approach: ID potential sources -> ID data/tools -> estimate
Data sources/tools
• Engineering calculations
• Emission factors
• Monitoring data
• Mass balance
E-18
-------
STACK EMISSIONS
Part II, Section 5.2: Stack or point-source air
emissions
• Approach: ID potential sources -> ID data/tools -> estimate
• Data sources/tools
» Air permit applications
. CAA Title V air inventories
» Process and production data
» Engineering calculations
» Mass balance
» Emission factors
E-19
PART H. SECTION 5: ON-SITE
WASTEWATER DISCHARGES
Section 5.3 Releases to streams or water bodies
• Enter names of streams or water bodies to which your facility directly
discharges the Section 313 chemical. If there Is no name, enter the closest
stream or water body with a name
• Enter total amount of releases to each receiving stream or water body In
column A; Include amounts from stormwater runoff, If available
• Indicate In column C the percentage of the total quantity (by weight) of the
Section 313 chemical contributed by stormwater
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERMQ EACH ENVRONMENTAL MEDIUM
Strain or WMw Body
E-20
-------
WASTEWATER DISCHARGES
Part II, Section 5.3: Release to stream or water body
and Part II, Section 6.1: Discharges to POTW
• Approach: ID potential sources -> ID data/tools -> estimate
Potential release sources
• Wastewater treatment facility discharge
• Storm drains
Data/tools
• Monitoring, if available
• DMRs or other required monitoring data
• NPDES permits/permit applications
• Process knowledge and/or mass balance
E-21
CALCULATING WASTEWATER
DISCHARGES
Recommended approach: Calculate the yearly
pounds of methanol discharged using the following
data concerning wastewater discharges of methanol:
Date Cone. frno/U Fiow (MGD) Amt.flbsydavl
3/1 1.0 1.0 8.33
9/8 0.2 0.2 .33
Averages 4.33
(4.33 IbsJday) x (365 days/yr.) = 1581 IbsJyr.
MGD = million gallons per day
1 mg/L = 8.33 IbsVmillion gal
E-22
-------
PART II. SECTION 5: ON-SITE INJECTION
WELLS
Section 5.4.1 Underground injection to Class I wells
• Enter total amount of Section 313 chemical Injected Into Class I
wells at facility In column A and basis of estimate code In column
B
Section 5.4.2 Underground injection to Class II - V wells
• Enter total amount of Section 313 chemical Injected into Class II - V
wells at facility in column A and basis of estimate code In column
B
SECTION 5. QUANTITY OF THE TOXK CHEMICAL ENTERMG EACH ENVIRONMENTAL MEDIUM
&4.1
DMA
DMA
E-23
PART H. SECTION 5: RELEASES TO LAND
ON-SITE
Section 5.5 Releases to land on-site
• Other disposal (5.5.4) Includes spills or leaks of the Section 313 chemical to
land
• Quantities of Section 313 chemicals released to air or water during the
reporting year of the Initial release to land (e.g., volatilization from surface
Impoundments) are not Included here
SECTIONS. QUMfrnYOFTHETO)OCCHEMCM.ENrERINaEACHENVMONHENTALHEnUH
5.5-1*
S.S.1B
5JJ
5.5.4
OtfwrtandM*
Undt
SurfM* Impoundment
OttwrdtyOMl
E-24
-------
RELEASED TO LAND ON-SITE
Approach: ID potential sources -> ID data/tools ->
estimate
Potential sources of release to land
• Intentional storage or disposal in on-site units
• Spills
• Leaks
Data/tools:
• Operating records/analytical data
• Spill reports
• Process knowledge
E-25
CHEMICAL MIGRATION GUIDANCE
Migration of reportable chemical within one
environmental medium (e.g., from land to land:
landfill leaching into soil)
• Only required to report initial release of chemical to the
environment
Migration of chemical from one environmental
medium to another (e.g., from land to air:
volatilization from a lagoon) within the reporting year
• Release estimates should be calculated and reported for all
media in Part II, Sections 5,6, and 8 of Form R
E-26
-------
WASTE RELEASED TO LAND ON-SITE--
STORAGE
Storage of wastes on the land
• Regular shipment schedule
» Must transfer the waste off-site before that reporting year's
Form R report is submitted or July 1, whichever comes first
» Report material transferred off-site during the year In Part II,
Section 6 of Form R
• No regular shipment schedule
» Report material added to pile that remains on-site during the
year as the quantity released to land, Part II, Section 5.5.4 of
Form R
E-27
PART H. SECTION 6: TRANSFERS TO OFF-
SITE LOCATIONS
i Includes both off-site location information and quantities of
Section 313 chemicals transferred to off-site locations
i Report quantities of a Section 313 chemical sent off-site to any
POTW or other location for recycling, energy recovery, waste
treatment, or disposal
i Report only total quantity of a Section 313 chemical transferred
off-site, not entire waste
i In Sections 6.1 and 6.2, Total Transfers, report total quantity
• A range code can be used for non-PBT Section 313
chemical quantities less than 1,000 pounds
» A = 1 • 10 pounds
» B = 11 -499 pounds
» C = 500 - 999 pounds
E-28
-------
PART H. SECTION 6: TRANSFERS TO
POTWs
Section 6.1 Discharges to publicly owned treatment
works
• Enter total quantity of the Section 313 chemical transferred
to all POTWs and basis of estimate
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL M WASTES TO OFF-SITE LOCATIONS
8.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTW»)
C.1.A Total OuMitttyTran*fMT»dto POTWt and Bnls of ErtmaU
1.1X1 TcM TrwirtOT (poundtfyMf)
(«
-------
PART H. SECTION 6: TRANSFERS TO
OTHER OFF-SITE LOCATIONS
Section 6.2 Transfers to other off-site locations
• Include name, address, and EPA Identification (RCRA ID) number
• Enter quantities, basis of estimate, and codes for multiple activities (waste
treatment, disposal, recycling, and energy recovery) In Rows 1 through 4
• Photocopy page 4 If reporting more than 2 off-site transfer locations
(TRI-ME/ATRS accommodates this without photocopying)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
•J. OFWriE EPA BENTIFCATION NUMBER (RCHAD NO.) |
Oft*** Location NUM |
(MiOiAddM. |
Oty|
totooiUonim
| St*| | Coirty
dH eontal d raporUni taeMy or pmnl a
(•ntor rang* ooo* or Mllmale)
1.
1
J.
4.
1 1*1
xnp«r*T D Y«i O No
B. ButootEltlnMt*
(enter code)
1.
I
3.
4.
IS3J
C Typ» o« W««b> Trantnwnt W«poMl/
nocydlnoyEnorgy Rooovwy(«it«r cod*)
1.M
1M
3M
4.M
E-31
OFF-SITE WASTE MANAGEMENT
Approach: ID potential sources -> ID data/tools -> estimate
Potential sources of off-site waste management
• Identify final disposition of the Section 313 chemical
» Disposal
» Waste treatment
» Energy recovery
» Recycling
Data/tools
• Waste manifests and vendor receipts
• RCRA reports
• Waste characterization - analyses, profiles
E-32
-------
PART H. SECTION 7: ON-SITE WASTE
MANAGEMENT
Examples of on-site waste management (Section 7)
• Air pollution control devices (Section 7A)
• Wastewater treatment processes (Section 7A)
• Energy recovery devices (Section 7B)
• Recycling devices (Section 7C)
E-33
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
Report each waste treatment method that the Section 313
chemical undergoes
• Include even if method has no effect on the Section 313 chemical
Only data element in Form R focusing on the entire waste
stream rather than the Section 313 chemical in the waste
stream
SECTION 7 A. ON-SIIE WASTE TREATMENT METHODS AND EFFKENCY
D NotAppncabtoffU) - ChMk h«« H QS WMlto wMto tr
w««t»rtm«m containing th«toidcchMnlc«l of ch«nlcalcat^ofy.
ntl» applied to Miy
7A.1l
7A.1C
7A.M
7X1.
E-34
-------
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.a General waste stream
• Enter a waste stream code for each waste treatment method
sequence
» There are four waste stream types: Gaseous, Wastewater, Liquid
Waste, Solid Waste
• Section 7A.b Waste treatment method(s) sequence
• Enter code(s) from EPA's TRI Reporting Forms and Instructions document for
on-slte waste treatment method(s) used
• Enter code(s) regardless of whether waste treatment actually affected the
Section 313 chemical
• Report waste treatment method(s) used on aggregate waste stream as single
stream
• If applicable, enter codes In sequence In which they occur
E-35
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.c Range of influent concentration
• Use range of concentration of the Section 313 chemical in waste
stream as K typically enters treatment equipment
• Enter code(s) for concentration ranges (parts per million) from
EPA's TRI Reporting Forms and Instructions document
• Section 7A.d Waste treatment efficiency estimate
• Waste treatment efficiency expressed as percent removal of the
Section 313 chemical from waste stream through biological
degradation, chemical conversion, or physical removal
. use overall efficiency of waste treatment sequence, not a specific
waste treatment method
- Use percent removal or destruction of Section 313 chemical only, not
other constituents of the waste stream
E-36
-------
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.e Based on Operating Data?
• Check "yes" if efficiency estimate is based on monitoring from
typical operating conditions
• Check "no" if efficiency estimate is based on published data for
similar processes or equipment supplier's literature, or if the
Influent or effluent waste comparison or the flow rate was
otherwise estimated
E-37
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Procedures for using two lines of data to enter 9 or more
sequential waste treatment methods
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
NotAppBeable(NA) - Cteck tara M 02 OMte watt* trwtniMt to applied to my
waste strMffl containing th» toxic chemical oc chemical category.
7AJ*
NA
7AJe
M %
7AJd
81 %
YM NQ
YM Ho
BT D
YM No
El D
E-38
-------
PART n. SECTION 7B: ON-SITE ENERGY
RECOVERY PROCESSES
• Enter on-site energy recovery methods for Section 313
chemical
• Section 313 chemical must be combustible and have a significant
heating value (e.g., 5,000 BTU/lb.)
• Combustion unit Is integrated Into an energy recovery system
(e.g., Industrial furnace, industrial kiln, or boiler)
• Enter codes in descending order by quantities combusted
SECTION 7B. CM-SITE ENERGY RECOVERY PROCESSES
D Not Applteabte(NA) • ChMkhcralf noon-«lta*n*rgyr*cov*ryli*>pll«dtoinywMt*
•trawn containing ttw toxte ehwnlal or ctwmlcal category.
E-39
PART H. SECTION 7C: ON-SITE
RECYCLING PROCESSES
Enter methods used for on-site recycling of the Section 313
chemical
• Codes for recycling methods used are found in EPA's TRI
Reporting Forms and Instructions document
• Do not include energy recovery processes
Enter codes in descending order by quantities recycled
SECTION TC. ON-SITE RECYCUNO PROCESSES
D Not Applicant* (NA) . Ctndclnf»Mnooo-«lt»t»eycHnal»»ppU«dto«nyw»«t»
•tmm containing tin toxic chtmlcil or ch«mlc«l category.
E-40
-------
PHOTOCOPYING PAGES OF FORM R
Form R pages may be photocopied if additional space is
necessary to complete these sections (photocopying is not
necessary with TRI-ME/ATRS)
• Section 6.1: Transfers to POTWs
• Section 6.2: Transfers to Other Off-Site Locations
• Section 7A: Waste Treatment Methods and Efficiency
When photocopying pages, you must complete the box on
each page to indicate the number of copies you are attaching
For the page being photocopied, enter in the left box the total
number of pages submitted including the original
original + number photocopied « total pages submitted
• In the second box, Indicate the position of the Individual page
If •ddiOonal pM«f of P»rt II, Section 6J/7A tit attached, Indicate the total number of pases In this
box m ud Indicate which Part II, Sections &2/7A page this b, here. O) (example: 1.2_5. etc.)
E-41
BEST PRACTICE: RECORDKEEPING
Importance of good recordkeeping
• Detailed records improve reporting accuracy and data
quality
• Well-labeled calculations and engineering assumptions
serve as standard operating procedures for future years
» Reduce replication
» Ensure consistency
Requirements
• All records used to complete Form R reports must be kept
for three years (40 CFR 372.10)
• EPA will review records during a data quality audit
E-42
-------
REFERENCE SOURCES
Estimating Releases and Waste Treatment Efficiencies
EPA Industry Guidance located at http://www.epa.gov/tri
AP-42: Compilation of Air Pollutant Emission Factors located at
http://www.epa.gov/ttn/chief
Technology Transfer Network located at http://www.epa.gov/ttn
• AP-42
• WATER9 program
- Updates WATERS, CHEMDAT8, and CHEM9
• TANKS program
Perry's Chemical Engineer's Handbook; CRC Handbook of
Chemistry and Physics; Lange's Handbook of Chemistry
E-43
-------
OVER
POLLUTIO
REPORTIN
NTION
POLLUTION PREVENTION HIERARCHY
Disposal or Other
Release to
Environment
F-2
-------
THINGS TO REMEMBER WHEN
COMPLETING SECTION 8
Key concepts
• Waste streams
• Process streams
• Reportable recycling
• Source reduction activities
Facilities should apply these concepts consistently
• Across facility
• Across agency/company
F-3
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
• Column A - Prior Reporting Year Estimate
• Column B - Current Reporting Year Estimate
• Column C - Next Reporting Year Projection
• Column D - Following Reporting Year Projection
F-4
-------
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
• Quantity of a Section 313 chemical reported in Sections 8.1
through 8.7 does not include releases (including on-site
and off-site disposal) and other off-site waste management
activities resulting from remedial actions, catastrophic
events, or one-time events not associated with production
process. These quantities should be reported in Section 8.8
only
F-5
RELEASES
Section 8.1: Quantity released
• Quantity of a Section 313 chemical "released"
» Definition of release: "...any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing...into the
environment..." (EPCRA Section 329(8))
» Includes fugitive and stack air emissions, releases to
land, releases to water, underground injections, and on-
site and off-site disposal
» Includes metals in wastes sent to a POTW (metals
cannot be destroyed)
F-6
-------
RELEASES
Section 8.1: Quantity released (continued)
• Section 8.1 = Sections 5 + 6.2 (disposal only) + 6.1 (for
metals and metal compounds only) - 8.8 (release or off-site
disposal only)
• Possible data sources
» Data and calculations from Sections 5 and 6 of Form R
F-7
ENERGY RECOVERY
Sections 8.2 and 8.3: On-site and off-site energy
recovery
• Things to remember about energy recovery
» Combustion unit (e.g., industrial furnace, industrial kiln,
or boiler) must be integrated into an energy recovery
system
» Section 313 chemical must have significant heating
value (e.g., 5,000 BTU/lb.)
» Section 313 chemicals that are, or are contained in,
traditional fuels should not be reported as combusted
for energy recovery
-------
ENERGY RECOVERY
Section 8.2: On-site energy recovery
• Quantity of Section 313 chemical used for energy recovery
on-slte
» Quantity actually combusted in the energy recovery unit
- nof the quantity entering the unit
• A code reported in Section 7B indicates that an estimate
should be calculated for Section 8.2
• Possible data sources
» Engineering process specifications
» Mass balance calculations
» Best engineering Judgement p-9
ENERGY RECOVERY
Section 8.3: Off-site energy recovery
• Quantity of Section 313 chemical that is transferred off-site
for energy recovery
» Includes total quantity of Section 313 chemical
transferred off-site for energy recovery purposes - not
quantity actually combusted off-site
• Possible data sources
» Section 6.2 (codes M56 and M92) of Form R
» Receipts from off-site facilities
» RCRA hazardous waste manifests
F-10
-------
RECYCLING
Section 8.4: On-site recycling
• Quantity of Section 313 chemical recycled on-slte
» Includes total quantity of Section 313 chemical
recovered from the recycling process and made
available for further use
• Possible data sources
» Engineering process specifications
» Mass balance calculations
• A code reported in Section 7C indicates that an estimate
should be calculated for Section 8.4
F-11
CALCULATING QUANTITY RECYCLED
IN SECTION 8.4
Facility
Fugitive Air
Emissions
Quantity
Entering
Recycling
Operation
i
r
Unusable
Residues sent off-
site for disposal
Quantity
Recycled
-------
RECYCLING
Section 8.5: Off-site recycling
• Quantity of Section 313 chemical transferred off-site for
recycling
» Includes total quantity of Section 313 chemical
transferred to off-site locations for recycling
• Possible data sources
» Section 6.2 of Form R (only for recycling destinations)
» Receipts from off-site recycling facilities
» RCRA hazardous waste manifests
» RCRA hazardous waste report (BRS)
F-13
WASTE TREATMENT
Section 8.6: Quantity treated on-site
• Quantity of Section 313 chemical treated on-site
» Includes all quantities of Section 313 chemical destroyed
• Possible data sources
» Calculations used to complete Section 7A of Form R
• Remember to include quantities that are actually
destroyed (or converted to a non-listed form), not
just removed from the waste stream
F-14
-------
WASTE TREATMENT
Section 8.7: Off-site waste treatment
• The amount of Section 313 chemical that is transferred off-
site for waste treatment
» Includes all quantities of Section 313 chemical
transferred to off-site facilities for waste treatment
• Possible data sources
» Sections 6.1 and 6.2 (i.e., off-site transfers for waste
treatment)
• Important: Assume all Section 6.1 quantities are
treated, except metals and metal compounds
F-15
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8: Remedial, catastrophic, or one-time
releases
• Quantity of Section 313 chemical released into the
environment or transferred off-site as a result of:
» Remediation
» Catastrophic events (e.g., earthquake, hurricane, fire,
floods)
» One-time events not associated with production
processes (e.g., pipe rupture due to unexpected weather)
• Does not include Section 313 chemicals treated, recovered
for energy, or recycled ON-SITE
• Excludes quantities in Sections 8.1 through 8.7 F"16
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CALCULATING QUANTITY REPORTED
IN SECTION 8.8
Facility
(2)
Fugitive Air
Emissions
On-site
Remedial
Cleanup
(3)
On-site
Treatment,
Energy Recovery,
or
Recycling
Off-site I
Transfers
(1) + (2) + (4) SB Total Section 8.8 Quantity
F-17
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8 (continued)
• Possible data sources
» Quantities reported in Part II, Sections 5 and 6
» Accident investigation reports
» Inventory reconciliation
» Mass balance calculations
» Monitoring reports (e.g., pH, discharge monitoring
reports, continuous emissions monitoring)
» CERCLA reports filed with the National Response Center
» Release notification reports required under EPCRA
Section 304
F-18
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SOURCE REDUCTION AND OTHER WASTE
MANAGEMENT ACTIVITIES
Important points regarding Sections 8.1 through 8.8
• Sum of the quantities in Sections 8.1 through 8.7 equals the
total quantity of the Section 313 chemical "entering any
waste stream (or otherwise released into the environment)
prior to recycling, treatment, or disposal." (PPA Section
6607(b)(1))
• Quantities reported in Sections 8.1 through 8.7 are exclusive
of each other
• Sum of Sections 8.1 through 8.7 is mutually exclusive of the
quantity in Section 8.8
F-19
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PRODUCTION RATIO OR ACTIVITY INDEX
Section 8.9: Production ratio or activity index
• A ratio of production or activity involving the Section 313
chemical in the reporting year to production or activity in
the previous year
• Allows quantities of the Section 313 chemical reported in
Sections 8.1 through 8.7 in the current year to be compared
to quantities reported In the prior year
• Production ratio or activity Index is determined by dividing
the level of production (or activity) in the current year by the
level of production (or activity) in the prior year
• Select methodology least likely to be affected by potential
source reduction activities
F-21
PRODUCTION RATIO
Use production ratio if Section 313 chemical usage
is related to a production level
• Equation
Quantity of Product: Current Reporting Year
Quantity of Product: Prior Reporting Year
Example:
Oven manufacturing
40,000 ovens assembled (Current RY) _ ^ ^4
35,000 ovens assembled (Prior RY)
F-22
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ACTIVITY INDEX
Use activity index if Section 313 chemical usage is
related to an activity and not to a production level
• Equation
Level of Activity: Current Reporting Year
Level of Activity: Prior Reporting Year
Example:
Tank washouts
60 Washouts (Current RY)
50 Washouts (Prior RY) _ ] 2
F-23
PRODUCTION RATIO OR ACTIVITY INDEX
• Possible data sources
• Production reports
• Maintenance records for otherwise used chemicals
• Waste minimization section of the RCRA hazardous waste
report
• State/corporate pollution prevention reports
F-24
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SOURCE REDUCTION ACTIVITIES
Section 8.10
• Source reduction practices used with respect to the Section
313 chemical at the facility and the methods used to identify
those activities
• This section includes only those source reduction activities
implemented during the reporting year
» Only include activities that reduce or eliminate quantities
reported in Sections 8.1 through 8.7
F-25
SOURCE REDUCTION ACTIVITIES
Section 8.10 (continued)
• Possible data sources
» Standard operating procedures
» Process changes or equipment changes (e.g.,
replacements, adjustments)
» Raw material changes
» Work orders for process changes
» Product redesign specifications
» Audit reports and follow-up actions
» Waste minimization section of the RCRA hazardous
waste report
» State/corporate pollution prevention reports
-------
OPTIONAL INFORMATION
Section 8.11
• Facility should Indicate whether additional optional
information on source reduction, recycling, or pollution
control activities is included with the report
• A one-page summary is encouraged
• Facility can provide information on previous years' activities
• EPA and others use this information for granting awards
and recognition to companies and employees
F-27
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FORM A SUBMISSION
ALTERNATE THRESHOLD RULE
If alternate threshold criteria met:
• Form R report is not required
• No release, other waste management, or source reduction
reporting
• Submit certification statement (Form A)
Final rule published in 1994 (§372.27; November 30,
1994; 59 FR 61501)
Does not apply to PBT chemicals
G-2
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(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number 2070-0143
Approval Expires: 01/31/2003 Page 1 of
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifiekl. VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if this
Is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer 2.2;
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in 2.1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best of my knowledge and beDef, for each toxic chemical listed in the statement the annual reportabte
amount as defined in 40 CFR 37227 (a), did not exceed 500 pounds for this reporting year and that the chemical was
manufactured, processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
Name and official title of owner/operator or senior management official:
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
4.1
TRI Facility ID Number
Facility or Establishment Name
Facility or Establishment Name or Mailing Address(if different from street address)
Street
City/County/State/Zip Code |
City/State/Zip Code
Country (Non-US)
4.2
This report contains information for. (Important: check c or d if applicable)
c.
A Federal
facility
GOCO
4.3
Technical Contact Name
Telephone Number (include area code]
4.4
Intentionally ten Wank
4.5
SIC Code (s) (4 digits)
4.6
Latitude
Degrees
Minutes
Seconds
Longitude
Degrees
Minutes
Seconds
4.7
Dun & Bradstreet
Number(s) (9 digits)
4.8
EPA Identification Number
(RCRA I.D. No.) (12 characters)
4.9
Facility NPDES Permit
Number(s) (9 characters)
4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
b.
b.
SECTIONS. PARENT COMPANY INFORMATION
5.1
Name of Parent Company
NA
n
5.2
Parent Company's Dun & Bradstreet Number
NA
EPA Form 9350-2 (Rev. 01/2001) - Previous editions are obsolete.
-------
IMPORTANT: Type or print; read instructions before completing form
Page ___ of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION TRIFID:
Do not use this form for reporting PBT chemicals including Oioxin and Dioxin-like Compounds*
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important Enter only one number exactly as H appears on me Section 3131st Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important Enter only one name exactly as it appears on the Section 313 list)
1.3
Generic Chemical Name (Important Complete only if Part 1. Section 2.1 is checked "yes'. Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important DO NOT complete this section If you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report ___ of
1.1
CAS Number (Important Enter only one number exactly as it appears on the Section 3131st Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important Enter only one name exactly as It appears on the Section 313 list)
1.3
Generic ChemkalNanw(hTip«tant&XTiplete Miry tf Part 1,Sedk)n 2.1 is cr^cfcedyM*. Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section If you completed Section 1 above.)
2.1
Generic Chemical Name Provided by SuppBer (Important Maximum of 70 characters, including numbers, tetters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important Enter only one number exadty as It appears on me Section 3131st Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important Enter only one name exactly as > appears on the Section 313 list)
1.3
Generic Chemical Name (Important Complete only if Part 1. Section 2.1 to checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important DO NOT complete this section If you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Suppler (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important Enter only one number exactly as It appears on the Section 313 ist Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important Enter only one nameexadly as it appears on me Section 313 list)
1.3
Generic Chemical Name (Important Complete only if Part 1. Section 2.1 Is checked >s'. Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important DO NOT complete this section If you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters. Including numbers, tetters, spaces, and punctuation.)
* See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dtoxin and Dioxin-like Compounds)
EPA Form 9350-2 (Rev. 01/2001) - Previous editions are obsolete. (Make additional copies of this page, if needed)
-------
ALTERNATE THRESHOLD RULE
Criteria for submitting a Form A
• Do not exceed 1,000,000 pounds manufactured, processed,
or otherwise used; and
• Do not exceed 500 pounds for the total annual reportable
amount for a Section 313 chemical. Equivalent to the sum
of the quantities calculated for Sections 8.1 - 8.7 of the Form
R
G-7
POP QUIZ
You manufacture 100,000 pounds of a non-PBT
Section 313 chemical. You sell 99,950 pounds as a
product. You emit 25 pounds out a stack, and send
25 pounds off-site for disposal. Do you meet the
criteria for submitting a Form A?
You use 50,000 pounds of nitric acid as a cleaner.
The entire amount is neutralized in your on-site
wastewater treatment operation and there are no air
or water releases. Do you meet the criteria for
submitting a Form A?
G-8
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ALTERNATE THRESHOLD RULE
Recordkeeping
• All documentation to support the determination, including:
» Detailed records
» Well-labeled calculations and assumptions
• All records used to determine eligibility to file the Form A
must be kept for a period of 3 years from the date of the
submission of the certification statement (§372.10(d))
G-9
OVERVIEW:
FORM R VS. FORM A
Form R • Form A
• Standard reporting • Alternate certification
method statement
• For all Section 313 • Not allowed for PBT
chemicals chemicals
• Report releases, other • Use for total reportable
waste management, and amounts not exceeding
source reduction activities 500 pounds
• Recordkeeping • Recordkeeping
requirements requirements
G-10
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