United states
 Environmental Protection

 Agency
EMERGENCY PLANNING AND COMMUNITY

    RIGHT-TO-KNOW ACT SECTION 313
    EPCRA/TRI TRAINING MATERIALS:




                 Spring 1999

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     EMERGENCY PLANNING AND
  COMMUNITY RIGHT TO KNOW ACT
  (EPCRA) OVERVIEW AND PURPOSE
              WHY EPCRA?
Key hazardous chemical releases
 •  Bhopal, India (1984)
 •  Institute, West Virginia (1985)
Increased public concern
Worker right-to-know laws
 •  OSHA Hazard Communication Standard (HAZCOM)
State right-to-know laws

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             EPCRA OVERVIEW
Purpose of Emergency Planning
 •  Protect public health and safety, and the environment
 •  Integrate with local emergency planning efforts
Purpose of Community Right-to-Know
 •  Support and focus state and local planning activities
 •  Increase community awareness of chemical hazards
 •  Support chemical accident and pollution prevention
   initiatives
EPCRA OVERVIEW
• Summary Chart of EPCRA Requirements for RY 1998 (as of
January 1,1999)
SECTION
301-303
304
311
312
313
COVERAGE/
TOPIC
Emergency
PlMning
Emergency
Notification
Hazardous
Chemical
Inventory
Hazardous
Cbemk»l
Inventory
Toxic
Chemical
Release
Reporting
REQUIREMENT
LEPC Emergency Plan,
EHS Notification
Accidental Release
Reportinz
MSDSl or List of
Chemicals
Inventories, Hazards,
and Locations
(Tier 1 or II)
Total Annual Release,
Waste Management &
Source Reduction Data -
PPA (Form R)
RELEVANT
CHEMICAL LIST
3St Extremely
Hazardous
Substances
EHSs and CERCLA
S102(a) Substances
OSHA Hazardous
Chemicals
(No Specific List)
OSHA Hazardous
Chemicals
(No Specific List)
Over
oOO Toxic
Chemicals and
Chemical Categories
THRESHOLDS
Specified Threshold
Planning Quantities
(TPO: 1 to 10,000 Ibs.)
Specified ReportaMe
Quantities
10,000 Ibs.; or, if EHS,
500 Ib*. or TPQ •
whichever is lower
10,000 Ibs.; or, if EHS,
500 Ibs. or TPQ -
whichever is lower
25,000 Ibs.
manufactured or
processed! 10,000 Ibs.
otherwise used
SUBMIT TO
SERC"
LEPC
SERC"
LEPC
SERC-
LEPC
Local Fire Dept.
SERC"
LEPC
Local Fire Dept.
EPA
State
• or TERC, 55 FR 30632 (July 26, 1990)

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          EPCRA SECTIONS 301 - 303
           EMERGENCY PLANNING
 EMERGENCY PLANNING REQUIREMENTS
         (EPCRA SECTIONS 301 - 303)
Section 301:
Section 302:
Section 303:
Establish State Emergency Response
Commissions (SERCs), designate local
emergency planning districts, and appoint
Local Emergency Planning Committees
(LEPCs) for each district

Designate extremely hazardous substances
(EHSs) and threshold planning quantities and
notification requirements for covered facilities
Develop local emergency response plans

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         EMERGENCY PLANNING
             INFRASTRUCTURE
 How state and local emergency planning infrastructure is
 established
 • Governor designates state emergency response
   commission (SERC) and SERC membership; or Tribal chief
   executive officer designates tribal emergency response
   commission (TERC)
 • SERC designates local emergency planning districts within
   state
 • SERC appoints members of local emergency planning
   committee (LEPC) for each planning district
     » Membership includes industry, police department, fire
      department, elected officials, and the general public
EXTREMELY HAZARDOUS SUBSTANCES
            (EPCRA SECTION 302)
 Selection criteria are based on acute lethal toxicity
 356 chemicals currently designated as EHSs
  •  Overlap of 138 chemicals with CERCLA hazardous
    substances
 EPA can revise the list by adding or deleting
 Substances identified in 40 CFR part 355

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FACILITY NOTIFICATION REQUIREMENTS
             (EPCRA SECTION 302)
  Facilities subject to emergency planning requirements
   •  Any facility (e.g., warehouses, manufacturers) that:
      » Has a quantity of EHS present at any one time that meets
        or exceeds specified threshold planning quantity (TPQ),
        PI
      » Is designated for participation by SERC
 EMERGENCY PLANNING REQUIREMENTS
          (EPCRA SECTIONS 302 - 303)
   Planning notification
   • Notify SERC or TERC and LEPC
   • Designate facility emergency coordinator
   • Supply LEPC with planning information, as requested
   • Coordinate emergency response planning with community
                                                 10

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           EPCRA SECTION 304
EMERGENCY RELEASE NOTIFICATION
                                            11
EMERGENCY RELEASE NOTIFICATION
Releases of EHSs (40 CFR 355) or Hazardous Substances (40
CFR 302.4) in a reportable quantity (RQ)
 •  RQ set by U.S. EPA through rulemaking
 •  If RQ not set by EPA, statutory RQ of one pound applies
 •  RQ is specified quantity released within a rolling 24-hour
   period
                                            12

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       REGULATED SUBSTANCES
                              Section 313
                              Chemicals
                              (Over 600)
         CERCLA
     Hazardous Substances
           (739)
                                                 13
EMERGENCY RELEASE NOTIFICATION
Initial immediate notification (via telephone, radio, or in person)
 •  For EPCRA section 304 chemicals & CERCLA section 103
   chemicals, notify:
    » SERCs or TERCs of any state or Tribe likely to be
      affected by release
    » Emergency coordinators for LEPCs of any area likely to
      be affected by release
 •  For CERCLA section 103 chemicals only, notify:
    » National Response Center (NRC)
Follow-up written notifications required for non-transportation
related releases
                                                  14

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EMERGENCY RELEASE NOTIFICATION

Reduced reporting for continuous releases
 •  Initial notification to the SERC, LEPC, and/or NRC
 •  Initial written follow-up to SERC, LEPC, and/or EPA regional
   offices
 •  One-time written follow-up report to EPA regional office one
   year later (for CERCLA hazardous substances only)
 .  Subsequent notification of any statistically significant
   increases or other changes in the release
                                                     15
EMERGENCY RELEASE NOTIFICATION
 Releases that are "continuous" and "stable in quantity and rate"
  •  "Continuous"
     » Occurs without interruption or abatement; or
     » Is routine, anticipated, intermittent, and incidental to normal
      operations or treatment processes
  •  "Stable in quantity and rate"
     » Is predictable and regular in amount and rate of emission
 Continuous releases exclude:
  •  Accidents
  •  System upsets and malfunctions
  •  Statistically predicted upsets

	16

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EMERGENCY RELEASE NOTIFICATION
• CERCLA section 103 versus EPCRA section 304
CERCLA Section 103 EPCRA Section 304
Chemicals Covered
Releases Covered
Notification
Requirements
CERCLA hazardous
substances
(40 CFR 302.4)
Any release into the
environment
NRC
CERCLA hazardous
substances
(40 CFR 302.4)
EPCRA Section 302 EHS
(Appendix A to 40 CFR
355)
Any release with
potential for exposure
to persons off-site
LEPC(s)
SERC(s)
TERC(s)
17

     EPCRA SECTIONS 311 - 312
HAZARDOUS CHEMICAL INVENTORY
          REPORTING
                              18

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        EPCRA SECTIONS 311 - 312
Chemical inventory reporting
 •  Section 311 - Material Safety Data Sheets (MSDSs)
 •  Section 312-Tier I or Tier II forms
                                                 19
         EPCRA SECTIONS 311 - 312
 Regulated facilities
  . Facilities subject to OSHA's HAZCOM (29 CFR 1910.1200)
     » No specific list of hazardous chemicals
     » HAZCOM applies to broad categories of chemicals,
      including any chemical that poses a physical or health
      hazard
                                                 20
                                                                       10

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        EPCRA SECTIONS 311 - 312
Regulated chemicals and reporting thresholds
 •  500 pounds or TPQ, whichever is less, for EHSs (include
   any EHS in a mixture)
 •  10,000 pounds for other OSHA hazardous chemicals
 •  Maximum quantity on-site at any one time
    » Must aggregate EHS quantities present in raw materials
     and all mixtures
                                               21
        EPCRA SECTIONS 311 - 312

Submit sections 311 and 312 information to:
 •  SERCorTERC
 •  LEPC
 •  Local fire department
                                                22

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        EPCRA SECTIONS 311 - 312
Reporting for mixtures
 •  Report on mixtures as a whole or by hazardous components
 •  Choose either reporting method
 •  Maintain consistent method for reporting under EPCRA
   sections 311 and 312
                                                 23
             MSDS REPORTING
           (EPCRA SECTION 311)
Section 311 reporting requirements
 •  Material Safety Data Sheets (MSDSs), or
 •  List of hazardous chemicals grouped by EPA's five physical
   and health hazard categories
    » Fire
    » Sudden release of pressure
    » Reactivity
    » Immediate (acute)
    » Delayed (chronic)
                                                24
                                                                      12

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             MSDS REPORTING
           (EPCRA SECTION 311)
Submit original list or copies of MSDSs within 90 days of
exceeding reporting thresholds

Update submission within 90 days of obtaining significant new
information
                                               25
     TIER I AND TIER II REPORTING
           (EPCRA SECTION 312)


Section 312 reporting requirements
 •  Report chemical information by five hazard categories on
   Tier I form
 •  Report chemical-specific information on Tier II form
   (optional under EPCRA, but required by many states)
 •  Submit reports annually on or before March 1 for previous
   calendar year's activities
                                               26

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Revised June 1990
                                                                                                                                   Page	of	pages
                                                                                                                       Form Approved OMB No. 2050-0072
TIER ONE
EMERGENCY AND HAZARDOUS
CHEMICAL INVENTORY
Aggregate Information by Hazard Type
                                                                                FOR
                                                                             OFFICIAL
                                                                                USE
                                                                               ONLY
                                                                                              DatcRecefwd
   Important:  Read instructions before completing form
Facility Identification
Name
Street
Citv
                           Countv
                                             State
                                                        .Zip.
SIC Code
                    Dun & Brad tt
                                                                   Reporting Period
                                                                           Emergency Contacts
                                                                                                                           Fran January I to December 11.19_
                                                                                   Name
                                                                                   Title
                                                                                   Phone
                                                                           24 Hour Phone

                                                                                   Name
                                                                                   Title
                                                                                   Phone
                                                                           24 Hour Phone
Owner/Operator
Mail Address
       Phone
                                                                                             Check If InCmtteii W«nr h ideannl tt OK t
                           .Wax
Hazard Type


       Fire
       Sudden Release
           of Pressure
           Reactivitv
                              Average
                               Dailv
                              Amount*
                                                  of davt
                                                  tin-Site
                                                                           General Location
                                                                                                                                 Cheek if rite plan n aaaxhta
            Immediate
               (acute)
             Delayed
            (Chronic)
Certification
                   (Read and sign after completing all sections)
1 certify under penalty of law that I have personally rumitied and am familiar with the
information lubmitled in pages one through	, and that bated on my inquiry ofthon
individual! responsible for obtaining the information. I believe that the submitted
information is true, accurate and complete.
          « aa< •fficlal tMe of m
                                «ujr OR •wajerfeferalM-'s authorized representative
                                                                                       *  Reporting Ranges
                                                                                Range     Weight Range in Pounds
                                                                                 Code
                                                                                  01
                                                                                  02
                                                                                  03
                                                                                  04
                                                                                  05
                                                                                  06
                                                                                  07
                                                                                  08
                                                                                  09
                                                                                  10
                                                                                  11
                                                                                          From ...
                                                                                                         To...
0
100
1000
10,000
100,000
1,000,000
10,000.000
50.000.000
100,000.000
500,000,000
1 billion
99
999
9,999
99,999
999,999
9,999,999
49,999.999
99.999.999
499.999.999
999.999.999
higher than 1 billion

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Page
                          pages
  Form Approved OMB No. 2050-0072
Tier Two
EMERGENCY
AND
HAZARDOUS
CHEMICAL
INVENTORY
Specific
Information
by Chemical
Facility Identification
Name
Street
City
SIC Code
Cou
nty State Zip
Dun & Brad Number

FOR
OFFICIAL
USE
ONLY


|ID# 1


|_Date Received 1

Important: Read all instructions before completing form
Chemical Description
CAS
Trade
Secret
Chem. Name

Check all [] []
that apply Pure Mix
EHS Name
U [] [] []
Solid Liquid Gas EHS

CAS
Trade
Secret
Chem. Name

Check all [] []
that apply Pure Mix
EHS Name
Solid Liquid Gas EHS

CAS
Trade
Secret
Chem. Name

Check all [] []
that apply Pure Mix
EHS Name
Solid Liquid Gas EHS


Owner/Operator Name
Name Phone ( )
Mail Address


Emergency Contact
Name Title
Phone ( ) 24 Hr. Phone ( )
Name Title
Phone ) 24 Hr. Phone ( )

Reporting Period From January 1 to December 31 , 19 	
Physical
and Health
Hazards
(check all that apply)
[} Fire
[ ] Sudden Release
of Pressure
[ ] Reactivity
[ ] Immediate (acute)
[ ] Delayed (chronic)
[] Fire
[ ] Sudden Release
of Pressure
[ ] Reactivity
[ j Immediate (acute)
[ ] Delayed (chronic)
[] Fire
[ ] Sudden Release
of Pressure
[ ] Reactivity
[ j Immediate (acute)
[ ] Delayed (chronic)
Inventory
Max. Daily
| | | Amount (code)

| | | Avg. Daily Amount
(code)
| | | | No. of Days
On-site (days)
Max. Daily
| | | Amount (code)

| I | Avg. Daily Amount
(code)
| | | | No. of Days
On-site (days)
Max. Daily
| | | Amount (code)

| | | Avg. Daily Amount
(code)
| | | | No. of Days
On-site (days)

[ ] Check if information below is identical to the information submitted last year.
i
fi | |
















Storage Codes and Locations
(Non-Confidential)
Storage Locations















































Certification (Read and sign after completing all sections)
1 certify under penalty of law that 1 have personally examined and am familiar with the information submitted in pages one through , and that based
on my inquiry of those individuals responsible for obtaining the information, 1 believe that the submitted information is true, accurate, and complete.
Name and official title of owner/operator OR owner/operator's
authorized representative
Signature Date signed
Optional
M
(]
n
Optional Attachments
] 1 have attached a site plan
] 1 have attached a list of site coordinate abbreviations
] 1 have attached a description of dikes and other
safeguards measures

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Gpage
                       pages

Tier Two
EMERGENCY
AND
HAZARDOUS
CHEMICAL
INVENTORY
Specific
Information
by Chemical
Form Approved OMB No. 2050-0072
Facility Identification
Name
Street
City County State Zip
SIC Code Dun & Brad Number


FOR I ID # |
OFFICIAL
USE | Date Received |
ONLY


Owner/Operator Name
Name Phone ( )
Mail Address

Emergency Contact
Name Title
Phone ( ) 24 Hr. Phone ( )
Name Title
Phone ( ) 24 Hr. Phone ( )

Important: Read all instructions before completing form 1 Reporting Period From January 1 to December 31, 19 	 1 U Check H Information below is identical to the information submitted last year.
Confidential Location Information Sheet

CAS# I I I

CAS# I I I


1 1 1 1 1 1 1 1 IChem. Name

11111(1 | 	 |Chem. Name


CAS# I I I

1 1 1 1 1 1 1 I IChem. Name

8 § S Storage Codes and Locations
I. I | (Confidential)
II I 1
Storage Locations













































Certification (Read and sign after completing all sections)
1 certify under penalty of law that 1 have personally examined and am familiar with the information submitted in pages one through , and that based
on my inquiry of those individuals responsible for obtaining the information, 1 believe that the submitted information is true, accurate, and complete.
Name and official title of owner/operator OR owner/operator's Signature Date signed
authorized representative
Optional
11
[]
[]
Optional Attachments
] 1 have attached a site plan
[ ] 1 have attached a list of site coordinate abbreviations
[ ] 1 have attached a description of dikes and other
safeguards measures

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        EPCRA SECTIONS 311 - 312
States may require facilities to:
 •  Submit Tier II form
 •  Submit state reporting forms
 •  Report lists of hazardous chemicals
 •  Report exact quantities
 •  Provide additional information (e.g., UN registry number)
States may set lower reporting thresholds
States may have a fee system
                                                  33
         EPCRA SECTIONS 311 - 312
Public availability of inventory information
 • EPCRA sections 311 and 312 information available to the
   general public upon request from SERC/TERC or LEPC
 • General public has the right to request, through the LEPC or
   SERC/TERC, additional information
                                                  34
                                                                        17

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     TOXICS RELEASE INVENTORY
      REPORTING REQUIREMENTS
          WHO MUST REPORT?
Facilities (Private- and Public-sector)
 • In covered SIC codes; 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

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 TRI REPORTING PROCESS
                            YES
                                            H
                                            O
Reporting ThresholdsJVletLForin_R^orni_A_Bgfliii]l£J-

  •MPOl': Manufacture (including import), procwi, or otherwise use




COVERED SIC CODES
| Industrial Sector SIC code |

Manufacturing 1 20-39
Metal mining
Coal mining
Electrical utilities
Treatment,
Storage, and
Disposal facilities
Solvent recovery
services
Chemical
distributors
Petroleum bulk
terminals
10 (except 1011, 1081, and 1094)
12 (except 1241)
4911, 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
4







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           FEDERAL FACILITIES
Federal facilities
 •  Owned or operated by Executive Branch agencies
    » No restrictions based on SIC code
    » Includes laboratories, prisons, parks, hospitals
 •  With 10 or more full-time employees (equivalent of 20,000
   hours per year)
 •  That exceed manufacture, or process, or otherwise use
   thresholds
 •  Agency responsible for reporting on activities at Federal
   facilities that are conducted by, for, or in support of the
   agency
                    SIC CODES
EPCRA Section 313 subjects facilities to reporting based on
classification of primary activities in the Standard Industrial
Classification (SIC) system (40 CFR 372.22)
On April 9,1997 (62 FR 17288) the North American Industry
Classification (NAIC) System was implemented
SIC codes are to be used until EPA transitions to new NAIC
system in future reporting years
A crosswalk exists between the SIC and new NAIC codes (see
62 FR 172188)

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        DEFINITION OF "FACILITY'
"Facility - all buildings, equipment, structures, and other
stationary items which are located on a single site or
contiguous or adjacent sites and which are owned or operated
by the same person (or by any person which controls, is
controlled by, or under common control with, such person)."
(EPCRA §329(4))
Establishment - an unique and separate economic unit of a
"facility"
Auxiliary facility - primarily supports another establishment's
activities
    MULTI-ESTABLISHMENT FACILITY
Three separate establishments located on contiguous/adjacent
property owned by same person(s), is one facility under EPCRA
Generic Products Food
Processing
(SIC 2033)

i i
Generic Products
(SIC 01 61)

-I — | i

Farm




Gen. Prod. Warehouse
(SIC 4222)




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  MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
 •  Federal facilities and 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)
           AUXILIARY FACILITY
Non-contiguous and non-adjacent to a covered establishment
Primary function is to support a covered establishment's
activities (e.g., warehouses, laboratories)
Assumes SIC code of covered establishment for reporting
purposes
Employee and threshold determinations are separate!
                                                   10

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           AUXILIARY FACILITY
                   ACME Mfg. Facilities
          (Warehouse is auxiliary facility of ACME Mfg.)
          ACME
          Mfg.
          (SIC 2015)
                                                     11
          EMPLOYEE THRESHOLD



10 full-time employee (20,000 hours) threshold

 • Worked at or directly for facility
 • Includes operational staff, administrative staff, contractors,
   dedicated sales staff, company drivers, off-site direct
   corporate support
 • Does NOT include contract drivers, janitorial contractors,
   off-site corporate overhead (indirect) support

Determinations based on available time management
systems/data
                                                     12

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 THRESHOLDS TRIGGERING SECTION 313
                   REPORTING

i A facility meeting all criteria must file a Form R report for a
  Section 313 chemical if the facility:
   •  Manufactured (including imported) more than 25,000
     pounds per year, or
   •  Processed more than 25,000 pounds per year, or
   •  Otherwise used more than 10,000 pounds per year
i Activity thresholds are mutually exclusive
i Threshold calculations are based on cumulative quantities per
  Section 313 chemical over the reporting year
                                                     13
    CATEGORIES OF MANUFACTURING
                    ACTIVITIES
  Manufacturing - generating a Section 313 chemical
   •  Intentionally producing chemicals for:
      » Sale
      » Distribution
      » On-site 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
                                                     14

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        MANUFACTURING WITHIN A
            CHEMICAL CATEGORY
  Chemical conversion within a metal or organic compound
  category must be counted towards the manufacturing
  threshold
  For Example:
   •  A copper mine converts copper sulfide to copper sulfate in
     its beneficiation operations
      » Copper sulfate, a member of the copper compounds
       category, is "manufactured"
                                                    15
CATEGORIES OF PROCESSING ACTIVITIES
  Processing - preparation of a Section 313 chemical for further
  distribution in commerce
   •  Using as a reactant to manufacture another substance or
     product
   •  Adding as a formulation component
   •  Incorporating as an article component
   •  Repackaging for distribution
       » Including quantities sent off-site for recycling
                                                     16

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            REPACKAGING AS A
          PROCESSING ACTIVITY
Repackaging a Section 313 chemical for distribution into
commerce is considered processing
 •  Repackaging includes transfer:
    » From container to tanker truck and vica versa
    » Between similar size containers
    » Via pipeline to/from a tank
 •  Repackaging does not include:
    » Sampling without repackaging
    » Relabeling
Repackaging without distribution into commerce is not
considered processing                	
17
               OTHERWISE USE
 Otherwise using - includes most activities that are not
 manufacturing or processing
  Examples
  .  Chemical processing aid (e.g., solvents)
  •  Manufacturing aid (e.g., lubricants, refrigerants)
  •  Ancillary activities (e.g., chemicals used to remediate
    wastes)
                                                     18

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     OTHERWISE USE (CONTINUED)
Otherwise use of a Section 313 chemical also includes
disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction on-site 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)

                                                     19
CALCULATING ACTIVITY THRESHOLDS
 Calculate total amount of Section 313 chemical INTENDED for a
 threshold activity

  •  Example:
     » A plant uses MEK to manufacture industrial adhesive for
      distribution in commerce. The plant adds 27,000 Ibs of
      MEK to the adhesive-making operation during the
      reporting year, but 3,000 Ibs are volitilized during the
      operation
     » 27,000 Ibs of MEK is processed, reporting required
                                                     20

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CALCULATING ACTIVITY THRESHOLDS

 Activities that do NOT constitute an activity threshold
 • Storage
 • Remediation of on-site contamination
 • Relabeling without repackaging
                                               21

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—<
         SECTION 313 CHEMICAL LIST
                         T
          SECTION 313 CHEMICAL LIST
     Dynamic, evolving list
     • Additions
     • Deletions
     • Modifications

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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 576 individual chemicals and
  chemical categories (40 CFR 372.65)
  Petition process to add or delete chemicals
       EPCRA SECTION 313 CHEMICAL
                    QUALIFIERS
   Qualifiers - Listed chemicals with parenthetic qualifiers subject
   to TRI reporting only if manufactured, processed, or otherwise
   used in specified form. Below are some examples:
CHEMICAL
Aluminum
Aluminum oxide
Asbestos
Isopropyl alcohol

Phosphorus
Saccharin
Hydrochloric acid
Sulturic acid
CASt         QUALIFIER
7429-90-5      Fume or dust
1344-28-1      Fibrous forms
1332-21-4      Friable forms
  67-63-0      Manufactured by strong acid
             process
7723-14-0      Yellow or white
  81-07-2      Manufacture only
7647-01-0      Acid aerosols
                                 i
7664-93-9	Acid aerosols	
                                                          m

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     METAL COMPOUND CATEGORIES
  Consider the entire weight of the compounds in the category
  when determining thresholds

  Include only the weight of the parent metal of the category (e.g.,
  copper for copper compounds) when calculating releases and
  other waste management quantities
DETERMINING THRESHOLDS FOR METAL
                  COMPOUNDS
Example
  A facility processes 200,000 pounds of a mixture containing
  10% zinc chromate and 15% chromium dioxide by weight

   •  Quantity toward chromium compounds threshold

        (10% + 15%) x (200,000) = 50,000 pounds

   •  Quantity toward zinc compounds threshold

        (10%) x (200,000) = 20,000 pounds

   •  25,000-pound processing threshold applies; chromium
     compounds are reportable and zinc compounds are not

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             NITRATE COMPOUNDS
• Water dissociable nitrate compounds category
   •  For threshold determinations, use the weight of the nitrate
     compound, but use only the weight of the nitrate ion portion
     when calculating releases and other waste management
     quantities

   •  Nitrate compounds are produced when nitric acid is
     neutralized

   •  Includes compounds like sodium nitrate, silver nitrate, and
     ammonium nitrate
      DETERMINING THRESHOLDS FOR
             NITRATE COMPOUNDS
Example

• 20,000 pounds of nitric acid (HNO3) are neutralized with sodium
  hydroxide (NaOH) in an on-site wastewater treatment system.
  Perform a threshold determination for nitrate compounds
  (water dissociable; in aqueous solution):

    Assume:

    • Neutralization 100% complete and generates sodium nitrate
     (NaNO3), which is released to a waterbody

    • Molecular weight (MW) of HNO3 = 63

    • MWofNaN03 = 85

    • 1 mole of HNO3 generates 1 mole of NaNO3           o

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     DETERMINING THRESHOLDS FOR
           NITRATE COMPOUNDS
Example (continued)
   Quantity of NaNO3 manufactured = quantity of HNO3
   neutralized x (MW of NaNOj/MW of HNO3)
   Quantity of NaN03 manufactured = 20,000 pounds x (85/63)
   Quantity of NaNO3 manufactured = 26,984 pounds
   The 25,000 pound manufacturing threshold is exceeded!
       CALCULATING RELEASES FOR
            NITRATE COMPOUNDS
Example (continued)
   Releases are reported on nitrate ion (NO3-) basis. Calculate the
   quantity of nitrate ion (MW of NO3- = 62) released to a
   waterbody:
   Pounds of NO3- = pounds of NaNO3 x (MW of NO3YMW of
                                NaN03)
   Pounds of NO3- = 26,984 pounds x (62/85)
   Pounds of NO3- = 19,682 pounds (rounded to 20,000 pounds)
                                               10

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  ORGANIC COMPOUND CATEGORIES
Consider the entire weight of the compounds in these
categories when determining thresholds

Include the entire weight of the compounds in the category
when calculating releases and other waste management
quantities for all compounds in these categories
                                                 11
     XYLENE AND XYLENEISOMERS
If data does not specify o~, m-, or p- isomers of xylene,
calculate thresholds, release and other waste management
quantities based on "xylene (mixed isomers)"

If data specifies o-xylene, m-xylene, or p-xylene individually,
calculate thresholds, release and other waste management
quantities based on the individual isomers

 • If thresholds are exceeded for more than one isomer,
   releases and other waste management quantities can be
   consolidated in one report as "xylene (mixed isomers)"
                                                 12

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          CHEMICALS MODIFIED
Hydrochloric acid (CAS # 7647-01-0), effective RY 1995

 •  Deleted non-aerosol forms of hydrochloric acid

    » Aerosol forms include any airborne hydrochloric acid
     (including mists, vapors, gases or fogs) droplets without
     regard to particle size

Sulfuric acid similarly modified, effective RY 1994
                                                  13
      ACID AEROSOLS THRESHOLD

              DETERMINATIONS


Acid Aerosols Generated in Storage Tanks
 • The amount of acid aerosol manufactured is determined by
   the average amount that exists in the atmosphere above the
   acid solution during the year.

Acid Aerosols Removed by Scrubbers
 • Non-aerosol forms of sulfuric/hydrochloric acid are not
   reportable under EPCRA Section 313; therefore, acid
   aerosols removed by scrubbers are converted to a non-
   reportabie form, the quantity removed by the scrubber
   should be reported as having been treated for destruction
                                                  14

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      ACID AEROSOLS THRESHOLD
             DETERMINATIONS
Sulfuric Acid Aerosols Formation in Stacks from Combustion
Processes

 •  Sulfuric acid aerosols are formed in flue gas during the
   combustion of fuel oil, coal, and other sulfur-containing
   fuels
 •  Water and sulfur trioxide, products of fuel combustion, react
   quickly to form sulfuric acid
 •  See Guidance for Reporting Sulfuric Acid (March 1998) for
   specific calculations
                                                 15
      ACID AEROSOLS THRESHOLD
             DETERMINATIONS

  Acid Reuse Systems (Sulfuric and hydrochloric acid only)
  • To calculate the amounts manufactured and otherwise used
    the facility may apply the total volume of acid in the system
    acid only once toward the threshold and the amount of
    virgin added to the system during the RY.

  Total System Volume + Total Virgin Acid Added
  = Amount Acid Aerosols Manufactured/Otherwise Used
     See Guidance for Reporting Sulfuric Acid (March 1998) for
     specific calculations
                                                 16

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             CHEMICALS MODIFIED
• Ammonia
   • Requires threshold determination and release and other
     waste management quantity calculations for aqueous
     ammonia from any source (i.e., anhydrous ammonia in
     water or water dissociable ammonium salts) be based on 10
     percent of the total ammonia present in aqueous solutions

   • Anhydrous ammonia - include 100% for thresholds and
     releases
      •> Including air releases from aqueous ammonia

   . EffectiveRY1994
                                                     17
             CHEMICALS MODIFIED
   Glycol ethers category
    .  Removed surfactant glycol ethers from category (59 FR
      34386, 7/5/94)
    .  Common glycol ethers still in category include:

         >. 2-Butoxyethanol (CAS # 111-76-2)

         .. Diethylene glycol monoethyl ether acetate
           (CAS #112-15-2)

         .. Diethylene glycol monobutyl ether (CAS # 112-34-5)

    .  Effective RY 1993
                                                      18

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             ADMINISTRATIVE STAYS
    No reporting required for the following chemicals until further
    notice
     •  2,2-Dibromo-3-nitrilopropionamide (DBNPA)
       (CAS # 10222-01-2)
        .. Effective RY 1995
     •  Hydrogen sulfide (CAS # 7783-06-4)
        .. Effective RY 1994
     •  Methyl mercaptan (CAS # 74-93-1)
        >. Effective RY 1994
                                                      19
             PROPOSED MODIFICATION
    Persistent Bioaccumulative Toxic (PBT) Chemicals
        Establish lower thresholds for PBT chemicals
        ••  10 or 100 pounds, except dioxin category (0.1 gram)
        Add chemical category for "Dioxin and Dioxin-
        like Compounds"
        Comments due March 8,1999
                                                      20
ll!l!ii!iiiiiimiii!iimii!iiii!iiiiiimimiiiiiiiiiimii!iiiiiiiiiiim^

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                                EXERCISE 1:
  CALCULATING RELEASES OF AMMONIA AND NITRATE COMPOUNDS

During the calendar year, a facility uses 200,000 pounds of nitric acid solution containing 50
percent (by weight) nitric acid (HNO3) in an etching process. All of the nitric acid is
eventually transferred to an on-site treatment facility as part of an aqueous waste stream. The
nitric acid is neutralized with pure (gaseous) anhydrous ammonia (NH3). The facility uses an
excess of ammonia to assure complete neutralization to pH 7 to 8. During the calendar year,
the facility used 30,000 pounds of ammonia. As a result of the treatment process, a nitrate
compound, ammonium nitrate (NH4NO3), is formed. The ammonium nitrate and any
remaining ammonia are then released to a waterbody.

Using the additional information below, complete questions a through d.

Assumptions

For simplicity, assume air emissions are zero.

Chemical Name                    Molecular Weights

Ammonium nitrate (NH4NO3)         = 80.04 Ib/lbmol
Ammonia (NH3)                    = 17.03 Ib/lbmol
Nitric acid (HNO3)                  = 63.01 Ib/lbmol
Nitrate ion (NO3-)                   = 62.01 Ib/lbmol

Chemistry Fundamentals

Nitric acid (HNO3) and anhydrous ammonia (NH3) are monovalent and react in a 1:1 ratio.
One mole of NH3 is used to neutralize each mole of HNO3 treated. When neutralized with
anhydrous ammonia, nitric acid (HNO3) produces ammonium nitrate (NH4NO3) in a 1:1
ratio. These substances are monovalent, so for each mole of HNO3  neutralized, one mole of
NH4NO3 is produced. As indicated in the following formula:
Therefore, 63.01 pounds of nitric acid reacts with 17.03 pounds of ammonia to produce
80.04 pounds of ammonium nitrate (which contains 62.01 pounds of nitrate ion).

a)  Based on the above scenario and information available, determine which toxic
chemicals would be subject to EPCRA section 313 threshold and release
determinations.

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b) Calculate the quantity of nitric acid applied towards threshold determinations and
   release calculations.
c) Calculate the quantity of ammonia applied towards threshold determinations and
               release calculations.
d)  Calculate the quantity of ammonium nitrate applied towards threshold
determinations and release calculations.

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   SECTION 313 REPORTING
            EXEMPTIONS
       SECTION 313 EXEMPTIONS
Originally designed for manufacturing facilities to:
 • Reduce 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 to certain limited
circumstances

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        SECTION 313 EXEMPTIONS
Types of exemptions
 •  De minimis
 -  Article
 •  Laboratory activities
 •  Motor vehicle maintenance
 •  Routine janitorial or facility grounds maintenance
 •  Structural components
 •  Personal use
 •  Intake water and air
         DE MINIMIS EXEMPTION
The quantity of a Section 313 chemical in a mixture or other
trade name product is eligible for the exemption if the chemical
is:
 •  An OSHA-defined carcinogen present at a concentration of
   less than 0.1% by weight
    or
 •  Any other Section 313 chemicals present at a concentration
   of less than 1% by weight

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           DE MINIMIS EXEMPTION
                   How It Works
  De minimis exemption can apply to:
   •  Chemicals in mixtures or other trade name products
     processed or otherwise used
   •  Chemicals unintentionally manufactured as impurities that
     remain in products
   •  Chemicals imported in mixtures or other trade name
     products
           DE MINIMIS EXEMPTION
                   How It Works
• De minimis exemption does not apply to:
   •  Manufacturing chemicals (in most cases)
   •  Manufacturing chemicals as by-products
   •  Unintentionally manufacturing chemicals
      » As by-products of waste treatment or fuel combustion

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            DE MINIMIS EXEMPTION
                    How It Works
   De minimis exemption does not apply to:

    •  Wastes and waste streams that are processed or otherwise
      used

    •  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
            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)
ACME CHEMICALS
  Toluene in cleaning mixture is below de minimis concentration
  and is eligible for the exemption

                                                     8

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               DE MINIMIS EXEMPTION
                          How It Works
    Processing a Section 313 chemical in a mixture to below the de minimis
    concentration does not exempt the chemical from threshold determinations and
    release and other waste management calculations
 Raw Material
 Primer Mixture
 (90% Toluene)
 Toluene > 1%

 •  De minimis exemption does not apply

 •  Threshold determination required

 •  Release and other waste management
    calculations required
                                                           Paint Products
                                                           (<1%Toluene)
                                   i:
  Toluene <1%

     De minimis exemption does not apply

 I • Threshold determination required


 l'
                                      Release and other waste management
                                      calculations still required           9
               DE MINIMIS EXEMPTION
                          How It Works
    Processing a Section 313 chemical in a mixture to above the de
    minimis concentration triggers threshold determinations and release
    and other waste management calculation requirements


                                                         Petroleum
                                                         products
                                                         containing
Crude oil
containing trace
amounts of
toluene
            EB  EB   BB

            ffl
                                                         concentrated
                                                         toluene
Toluene < 1%

   De minimis exemption can apply

   Do not include in threshold

   Do not include in release and other waste
   management calculations
                                 I Toluene > 1%

                                     De minimis exemption does not apply
                                     Threshold determination required
i:
i-
                                     Release and other waste management
                                     calculations
10

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           ARTICLE EXEMPTION
"Article" is defined as a manufactured item that:

 •  Is formed into a specific shape or design during
   manufacture; and

 •  Has end-use functions dependent in whole or in part on its
   shape or design during end-use; and

 •  Does not release a Section 313 chemical under normal
   processing or use conditions at a facility

The quantity of a Section 313 chemical used to manufacture an
article is not exempt
                                                     11
           ARTICLE EXEMPTION
                  How It Works


Releases from an article may negate the exemption. To
maintain the article status, total releases from all like items
must be:
 •  In a recognizable form
 •  Recycled or
 •  Less than or equal to 0.5 pounds (may be rounded down to
   zero)
If more than 0.5 pounds of a Section 313 chemical is released
from all like Kerns in a non-recognizable form and is not
recycled, none of the items meet the article exemption.
                                                     12

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           ARTICLE EXEMPTION
                  How It Works
Example:
Wire is cut to specified lengths. Wastes include off-spec cuts
and dust.

 •  Dust and off-spec cuts not recognizable as articles, released
   from like items in quantities more than 0.5 pounds, and not
   recycled, negate the article status

 •  Generation of off-spec cuts that are recognizable as articles
   will not, by itself, negate the article status
                                                     13
 LABORATORY ACTIVITY 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

Laboratories, themselves, are not exempt

Section 313 chemicals used in specialty chemical production,
pilot plant scale operations, and laboratory support operations
are not eligible for the exemption
                                                     14

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   LABORATORY ACTIVITY EXEMPTION
  Definition of technically qualified individual (40 CFR 720.3(ee))

   • Capable of understanding the health and environmental
     risks associated with the chemical substance which is used
     under his or her supervision because of education, training,
     or experience, or a combination of these factors;

   • Responsible for enforcing appropriate methods of
     conducting scientific experimentation, analysis, or chemical
     research to minimize such risks; and

   • Responsible for the safety assessments and clearances
     related to the procurement, storage, use, and disposal of the
     chemical substance as may be appropriate or required
     within the scope of conducting a research and development
     activity.
   LABORATORY ACTIVITY EXEMPTION
                    How It Works
Section 313 chemicals manufactured, processed, or otherwise
used in these laboratory activities are eligible for the exemption

• Sampling and analysis

• Quality assurance

• Quality control
                                                       16

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   LABORATORY ACTIVITY EXEMPTION
                    How It Works
Section 313 chemicals manufactured, processed, or otherwise
used in these laboratory activities are NOT exempt
• Specialty chemical production
• Pilot-scale plant operations
• Support services
   • Photo processing
   • Equipment maintenance / cleaning
                                                     17
      MOTOR VEHICLE MAINTENANCE
                    EXEMPTION
   Section 313 chemicals used to maintain motor vehicles
   operated by the facility are eligible for the exemption
   Motor vehicles eligible for the exemption include cars, trucks,
   and forklifts
   Motor vehicle maintenance includes:
   •  Body repairs
   •  Parts washing and  plating
   •  Fueling and adding other fluids (e.g., ethylene glycol)
                                                     18

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  ROUTINE JANITORIAL OR FACILITY
 GROUNDS MAINTENANCE EXEMPTION

 Section 313 chemicals contained in products used for non-
 process related routine janitorial or facility grounds
 maintenance are eligible for the exemption
  • Phenol in bathroom disinfectants
  • Pesticides in lawn care products
 Section 313 chemicals used in the following activities are not
 exempt
  • Facility equipment maintenance
  • Cleaning or maintenance activities that are integral to the
   production process of the facility
                                                    19
STRUCTURAL COMPONENT EXEMPTION
 Section 313 chemicals that are part of structural components of
 a facility are eligible for the exemption provided the structure is
 not process related
  • Copper in pipe used in construction of employees'
    bathroom facilities
  • Metals, pigments, and solvents in paint applied to facility
    structure
                                                    20

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   OTHER SECTION 313 EXEMPTIONS
Section 313 chemicals contained in non-process related items
for employee personal use
 •  HCFC 22 in air conditioners used solely for employee
   comfort
 •  Chlorine used to treat on-site potable water
 •  Phenol in a facility medical dispensary
Section 313  chemicals found in intake water and air
                                                  21

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                        EXERCISE #2: THRESHOLD QUIZ

Purpose:      Familiarize participants with the criteria for TRI reporting, including thresholds
             for manufacturing, processing or otherwise using listed chemicals, which
             determine whether or not a facility must submit a Form R for a listed chemical.

Take-Away:  Knowledge and understanding of TRI reporting thresholds.

Instructions:  Read each question carefully. Using your knowledge of TRI reporting thresholds,
             choose the best of the four answers.

1.     A facility begins the reporting year with an inventory of 24,600 pounds of copper
       sheets for its decorative mail box manufacturing operation, all of which is used in
       the reporting year. All sheets are cut and grinded into different diameters during
       the processing operation which generated less than 10 pounds of fugitive emissions
       of copper during the reporting year. In addition, the facility  processes 500 pounds
       of copper ingots into wire which is sold to an electronics firm. However, the 500
       pounds of copper ingots were obtained  by on-site reuse of the scrap copper
       generated from the mail box manufacturing operation. Is this facility's processing
       of copper subject to EPCRA Section 313 reporting and why?

       a.     No,, because, the facility is reprocessing 500 pounds of copper, only a total of
             24,600 pounds of copper would be applied to the 25,000  pound threshold
             determination for processing.
       b.    No, because the scrap was reused, the article exemption from threshold
             determinations is maintained for all uses of copper.
       c.    Yes, because 24,600 pounds of copper sheets and 500 pounds of copper ingots
             were both processed, therefore the facility exceeded the 25,000 pound processing
             threshold.
       d.    No, because the 24,600 pounds of copper sheets were present in the facility prior
             to the reporting year, it is not calculated for threshold determinations. Only
             amounts newly added to the facility are calculated for threshold determinations.

 2.     A facility processes 100,000 pounds of a mixture containing 25% zinc chromate, and
       25% chromium dioxide by weight. For purposes  of Section 313 reporting, how
       much zinc and chromium were processed?

       a.     25,000 pounds zinc compounds, and 25,000 pounds of chromium compounds
       b.     25,000 pounds zinc, and 25,000 pounds chromium
       c.     25,000 pounds zinc, and 50,000 pounds chromium
       d.     25,000 pounds zinc compounds, and 50,000 pounds chromium compounds

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3.     A facility buys a solution containing 29 percent 1,1,1-trichloroethane and processes
       it as a constituent of a cleaning solution that they sell in retail stores. The 1,1,1-
       trichloroethane is present in final product at 0.5 percent. The product is packaged
       into one-gallon containers.  What amounts of the 1,1,1-trichloroethane in mixtures
       must the facility consider for threshold determinations?

       a.     Any amount used within the facility during the reporting year, except the amount
             distributed through retail outlets to consumers, must be considered processed.
       b.     Because the mixture was otherwise used, it is not eligible for the de minimis
             exemption. The quantity used must be applied to the otherwise use threshold.
       c.     Because the mixture was received and processed in concentrations above the de
             minimis for 1,1,1-trichloroethane, all quantities must be applied to the processing
             threshold.
       d.     Only amounts distributed into commerce need to be considered towards the
             processing threshold, and because these quantities  are present below  the de
             minimis concentration, they are exempt.

4.     Which of the following qualifies as a section 313 reporting exemption?

       a.      Like "articles" that release over 10 pounds of a section 313 chemical, not
              recovered, under regular normal processing or use.
       b.     Painting process equipment at the facility.
       c.      Chemical use in non-process related routine janitorial or facility grounds
              maintenance.
       d.     Laboratory support activities.

5.     During the reporting year, your facility receives 20,000 pounds of chlorine in
       solution. 10,000 pounds of the chlorine is transferred to a tank to make a bleaching
       mixture, where its concentration drops below the de minimis level, which is then
       sold and distributed in commerce. 5,000 pounds of the original mixture is used to
       treat the drinking water consumed by employees.  The remaining 5,000 pounds of
       the original mixture is used throughout the plant to clean process equipment.
       Wastewater from the cleaning and bleach production operations is released with
       chlorine levels well below the de minimis level. Which of the following is true?

       a.      All uses of the chlorine are subject to section 313 reporting because the
              concentration of the received mixture is well above the de minimis level and the
              threshold limit for otherwise use has been met.
       b.     Only the use of chlorine for drinking water is exempt from section 313 reporting.
       c.     Only the drinking water and cleaning operations will be exempt from section 313
              reporting due to the personal use and routine maintenance exemptions,
              respectively.
       d.     The drinking water and cleaning uses are covered under the personal use and
              routine maintenance exemptions, respectively. The bleach production operation
              and the wastewater generated in conjunction with this operation are not exempt
              from section 313  reporting; however, the wastewater from the cleaning operations
              are exempt.

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s^2^*j
:O QXQCO2QC
].— —
1
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^ wn i oi
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~ ^ d
             TRI REPORTING PROCESS
 Identify toxic
  chemicals
 manufactured,
 processed, or
otherwise used at
   the site
 Determine the
  quantity of
  Section 313
  chemicals
 and how they are
 manufactured,
  processed, or
otherwise used on-
    site

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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
        DETERMINING THRESHOLDS
  Identify Chemicals and
       Concentrations:

               MSDS

        Specifications

        Waste Profiles

    Process Knowledge

Other References (AP-42,
          Merck Index)

    Supplier Notification
Collect Data to Calculate
Thresholds:

Inventory Records

Throughput/Production Data

Purchase Records

EPCRA or Other Env. Reports

Ask the User

Call the Vendor

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 DETERMINING CONCENTRATIONS OF
         SECTION 313 CHEMICALS
Chemical component - include in threshold "each listed Section
313 chemical known to be present" at a concentration greater
than the de minimis limits (EPCRA §313 (g)(1)(C))

 •  "Known" - knowledge based on MSOS, analytical data,
   process knowledge, labeling, literature, other vendor-
   supplied information, or existing analysis

 •  If concentration is unknown, threshold determination for the
   Section 313 chemical is not required (40 CFR 372.30(b)(3))
      SUPPLIER NOTIFICATION FOR
 MIXTURES AND OTHER TRADE NAME
                   PRODUCTS

Supplier Notification - requires suppliers to facilities described
in 40 CFR 372.22 to:
 •  Identify Section 313 chemical(s) by name and CAS number
 •  Identify Section 313 chemical(s) as being subject to EPCRA
    Section 313 requirements
 •  Provide concentration (or range) of Section 313 chemicals
    in mixtures and other trade name products (not wastes)
 •  Provide notification at least annually in writing or attached
    to the MSDS
 •  Update notification when changes occur
 •  Only facilities in SIC codes 20-39 must initiate the
    notification                   	

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   DETERMINING CONCENTRATIONS IN
    MIXTURES OR OTHER TRADE NAME

                    PRODUCTS

• Include a Section 313 chemical in the threshold determinations
  if you know:
   •  Exact concentration - use concentration provided
   •  Upper bound - use upper limit
   •  Range - use the midpoint of the range
   •  Lower bound - subtract out other known constituents,
     create a range, and use the midpoint of range
Note: Thresholds are based on weight in pounds.
     DETERMINING CONCENTRATIONS
                    IN WASTES
  De minimis exemption does not apply to wastes that are
  processed or otherwise used

  If concentration is exact, upper bound, range, or lower bound,
  use the guidance for mixtures and other trade name products

  If concentration is below detection limit, use engineering
  judgment:

   •  If the Section 313 chemical is expected to be present,
     assume 1/2 of full detection limit

   •  If the Section 313 chemical is not expected to be present,
     assume 0

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  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
   (manufactured and otherwise used)
 •  Section 313 chemicals that are otherwise used on-site,
   recycled, then processed

Section 313 chemicals should not be counted twice towards the
same activity threshold
   WATCH FOR DOUBLE COUNTING!!!
For threshold determinations, Section 313 chemicals reused or
recycled at a facility: count original amount used only once

 •  Note: Section 313 chemicals 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
                                                     10

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  MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
 •  Multi-establishment facility
    » Apply threshold determination on aggregate amount of
      chemicals used at facility
    » Able to file separate Form R reports for each
      establishment if they are distinct economic entities
      (must be designated as part of a facility on Form R)
    » Report ah releases and other waste management
      activities of reportable Section 313 chemicals
    » Avoid double-counting of chemicals involved in intra-
      facility transfers
                                                    11
       CALCULATING THRESHOLDS
Consider all activities
 • Chemicals used in neutralization, refrigerants, cleaners,
   paints, lubricants (for non-vehicles), fuel (for non-vehicles),
   refractory bricks
 • Consider all sources
 • Purchasing/Inventory Control
 • Contractors
 • Bulk deliveries
 • Capital purchases
 • "Credit card" or "emergency" purchases
                                                    12

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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
                                                   13
OPTIONAL SECTION 313 THRESHOLD DETERMINATION WORKSHEET
Farilirv Name: QMW CHEMICAL Date Worksheet Prpnared: 2/13/99
Toxic Chemical or Chemical
Reporting Year: 1998
Pategorv: Toluene Prepar«»H Rv- .ISP



Step 1. Identify amounts of the toxic chemical manufactured, processed, or otherwise used.
Mnture Name or Other Identifier

2. Yellow Safety Paint
. Parts Washer Fluid




Subtotal:
Information
Source
Purchasine
Vendor
Purchasine





b* Weight
50

40





Total Weight
10,000
30.000
111,000





Amount of the Lined Toxic Chemical b> Acthit) (in Ibs
Manufactured







(A) Ibs.
Procf.*ed







(BJ Ih*.
Otherwjie 1'ieil
5,(MMl
1AMJ





(0 10^«> Ibs.

Step 2. Identify exempt forms of the toxic chemical that have been included in Step 1 .
Mature Name as Listed Above
1. YcUow Safet\ Paint
2.
3.
4.

6.
7
Subtotal:
Applicabk
Exempt ion
Siruct. Como.







Nnle Fraction or Percen
Exempt 
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        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 burden
                                                      15
              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
All records used to complete Form R must be kept for three
years (40 CFR 372.10)
EPA will review records during a data quality audit          ] 5

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                                  EXERCISE #3
                IDENTIFYING EPCRA SECTION 313 CHEMICALS
Purpose:
Familiarize participants with use of the Common Synonyms document.
Develop ability to cross-reference chemical names and to identify correctly
Section 313 chemicals.
Take-Aways:
Experience with Common Synonyms document.
Understanding of nuances of chemical compositions.
Materials:
Common Synonyms document
Material Safety Data Sheets (MSDS)
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.  Your Common
Synonyms document will assist you.  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 as listed in the Common Synonyms document.

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                                  IDENTIFYING EPCRA SECTION 313 CHEMICALS
MSDS Name
Section 313 Chemical(s) Name
Concentration
                                                                                               Notes

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                  MEADOWBRQOIC COMPANY

                    SPELTER. WEST VIRGINIA 2643B


                  RAW MATERIAL SUPPLIER DATA SHEET

   I.  TRADE NAME CRUDE ZINC OXIDE

      CHEMICAL NAME    ZINC OXIDE       EPA/GAS 1314-1J-2

      MANUFACTURER                      MEADOWBROOK COMPANY
                                        DIV OF T.  L. DIAMOND & CO., INC.

  SPECIFICATIONS         CRAPE A               CRAPE B

  Zu                     50-591                601*681
  Fe                      1-31                  1-31
  Al                     .8-3.51               .8-3.51
  Pb                    0.1-0.5 Avg. 0,2      0.1-0.5 Avg.0.21
  Cl                    0.0-0.31              0.0-0.31
  Ol              Less Than  .01      L««» ^i«n    .01
  Cu                    0.04-0.40             0.04-0.40

 II.  NON TOXIC SOLID MATERIAL WITH A PARTICLE SIZE RANGE
      UP TO 1/4 INCH.

 III.  SPECIFIC GRAVITY  5.6             „
      APPARENT DENSITY  130-160 LBS/CU FOOT
      NON SOLUABLE TN WATER NON VOLATILE
      LIGHT GRAY, ODORLESS COARSE POWDER

 IV.  NO FIRE OR EXPLOSION HAZARD.  CAN REACT WITH MAGNESIUM
      OR CARBON WHEN HEATED.

   V.  NO PARTICULAR HEALTH HAZARD, TLV (S) FOR PRINCIPLE
       INGREDIENT
      PEL 5 Mg/M' FOR ZINC OXIDE FUME

 VI.  TfOH REACTIVE AT AMBIEWT  EXCEPT WITH MINERAL ACIDS

 VII.   SPILL OR LEAK PROCEDURES
      Clean up & return  to labeled  containers

VII.   PERSOKAL PROTECTION
       Nloah respirator   suggested for comfort when
       is dry  & dusty

   HANDLERS  SHOULD WEAR  GLOVES  AND SAFETY  GOGGLES.
                                                31T752514S     Pfltt.02

 IIN 13 '96 1.1:48

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          3M General Offices

          3M Center
          St. Paul. Minnesota 55144.1000
          612/733-1110
CT 2192  .7

 PAGE   1

127*3
MATERIAL  SAFETY
DATA SHEET
 DIVISION:  INDUSTRIAL MINERAL DIVISION
 TRADE NAME:
   3M BRAND ROOFING GRANULES (WAUSAU, WI)

 3H I.D.  NUMBER:  98-0111-1216-0  98-0111-1217-8  98-0111-1218-6  98-0111-1219-4
                  98-0111-1220-2  98-0111-1221-0  98-0111-1222-8  98-0111-1223-6
                  98-0111-1252-5  98-0111-1253-3  98-0111-1278-0  98-0111-1288-9
                  98-0111-1290-5  98-0111-1292-1  98-0111-1293-9  98-0111-1294-7
                  98-0111-1318-4  98-0111-1319-2  98-0111-1320-0  98-0111-1321-8
                  98-0111-1322-6  98-0111-1323-4  98-0111-1324-2  98-0111-1325-9
                  98-0111-1348-1  98-0111-1444-8  98-0111-1445-5  98-0111-1446-3
                  98-0111-1447-1  98-0111-1448-9  98-0111-1449-7  98-0111-1450-5
                  98-0111-1451-3  98-0111-1452-1  98-0111-1453-9  98-0111-1454-7
                  98-0111-1457-0  98-0111-1484-4  98-0111-1488-5

 ISSUED:  SEPTEMBER 13.  1994
 SUPERSEDES:  NOVEMBER 23.  1993
 DOCUMENT:  10-0170-0
1 . INGREDIENT
PLAGIOCLASE FELDSPAR 	
QUARTZ 	
POTASSIUM FELDSPAR 	
SODIUM SILICATE 	
KAOLIN 	
CARBON BLACK 	
CHROMIUM OXIDE (TRIVALENT CHROMIUM)
HYDROTREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES 	
RUTILE TITANIUM DIOXIDE 	
IRON OXIDE (FE203) 	
ZINC FERRITE 	
C.A.S. NO. PERCENT
. . None 30 . 0
.. 14808-60-7" 25
. . None y 20
.. 1344-09-8 , <
.. 1332-58-7>/ <
.. 1333-86-4 "j <
. . 1308-38-9 * <
. . 64742-52-5' <
. . 1317-80-2 - <
. . 1309-37-1 ^ <
.. 12063-19-3 <

35
35
75
S.(
S.i
0.
0.
0.
0.
0.
0.

0


1
I





  NOTE: THE AMOUNT OF DUST GENERATED WHILE HANOLIN8 THESE ROOFING GRANULES IS
        EXPECTED TO VARY DEPENDINS ON THE USER'S OPERATION. THE LEVEL OF
        RESPIRABLE CRYSTALLINE SILICA IS EXPECTED TO BE LESS THAN 15% OF THE
        RESPIRABLE DUST.

  THIS PRODUCT CONTAINS THE FOLLOWINO TOXIC CHEMICAL OR CHEMICALS SUBJECT TO THE REPORTI
  REQUIREMENTS OP SECTION 313 OP TITLE III OP THE EMERGENCY PLANNING ANDCOMHUNITY RIGHT-
  ACT OP 19M AND *• CPU PART 37Zt
    CHROMIUM OXIDE (TRIVALENT CHROMIUM)
    ZINC FERRITE
it









PHYSICAL DATA
BOILING POINT* 	
YAPOR PRESSURES 	
YAPOR DENSITY: 	
EVAPORATION RATE:. 	 	
SOLUBILITY IN HATER: 	
SP. GRAVITY: 	
PERCENT VOLATILE: 	
VOLATILE ORGANICS: 	 ,


. . . . N/A
, . . . N/A
. . . . N/A
. . . . N/A
. . . . N/A
.... 2.6-2.7
. . . . N/A
. . . . N/A

  Abbreviation*.  N/D - Net Determined   N/A -  Not Applicable

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                                                                           07-08
          3M Genera! Offices                                                  12744

r2192  -7   3M Center
 PACE    2   st. Paul. Minnesota 55144-1000
          612/733-1110
MATERIAL SAFETY
DATA SHEET
3M
 MSDS:  3M BRAND ROOFING GRANULES CHAUSAU,  WI)
 SEPTEMBER 13,  1994                                                   PAGE:  2 of  5


                                      (continued)

      VOC LESS H20 & EXEMPT SOLVENT  N/A
      pH: 	  SL BASIC
      VISCOSITY: 	  N/A
      MELTING POINT	  N/A
      APPEARANCE AND ODOR:   Granules, Various colors, slightly  oily odor
      FLASH POINT:	  N/A
      FLAMMABLE LIMITS - LEL: 	  N/A
      FLAMMABLE LIMITS • UEL: 	  N/A
      AUTOIGNITION TEMPERATURE: ...  N/A
      EXTINGUISHING MEDIA:
        Non-combustible. Choose material suitable for surrounding fire.
      SPECIAL FIRE FIGHTING PROCEDURES:
        Not applicable
      UNUSUAL FIRE AND EXPLOSION HAZARDS:
        No unusual fire or explosion hazards are anticipated.

   
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         3M General Offices

         3M Center
         St. Paul. Minnesota 55144.1000
         S12/733-J110
                                                                             07-08
                                                                            12745
                                                                            CT 2192 -7

                                                                             PAGE   3
MATERIAL SAFETY
DATA SHEET
USDS: 3N BRAND ROOFING GRANULES CWAUSAU, NX)
SEPTEMBER 13, 19W
                                                                        PA8E:   3 of  5
      EKE CONTACT:
        Immediately flush  eyes  with large amounts  of  water.  Sat immediate
        madieal attantion.

      SKIN CONTACT:
        Mo naad for first  aid is anticipatad  in tha avant of skin contact.

      INHALATION:
        If signs/symptoms  occur/ remove  parson to  frash air. If
        signs/symptoms continua, call  a  physician.

      ZF SWALLOWED:
        Drink two  glassas  of water.  Call a  physician.
       EYE PROTECTION:
        Avoid aya  contact.  Tha following should ba worn alona or in
        combination,  as appropriate/  to pravant aya contact:  Wear safety
        glassas  with  sida shields.

       SXZN PROTECTION:
        Avoid prolonged or repeated skin contact..
      VENTILATION PROTECTION:
        If exhaust ventilation is not available,
        protection .
                                                   sa appropriate respiretory
       RESPIRATORY PROTECTION:
         Avoid breathing of dust.  Select on* of ths following NIOSH approved
         respirators basad on airborna concentration of contaminants end in
         accordance with OSHA regulations:  half •mask dust respirator.

       PREVENTION OP ACCIDENTAL INOESTION:
         Wash hands after handling and befora eating.
                   STORAGE:
         Not applicable.

       FIRE AND EXPLOSION AVOIDANCE:
         Net applicable.
                                 EXPOSURE LIMITS
                                                 as quartz rasp,
  Abbreviations t  N/D -  Not  Determined  N/A -  Not  Applicable

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r 2192

PAGE
3M General Offices

3M Center
St. Paul. Minnesota 55144-1000
612/733-1110
                                                                            07-08
                                                                           12746
MATERIAL SAFETY
DATA SHEET
                                                    3M
 MSOS: 3« BRAND ROOFZN6 GRANULES CWAUSAU, WI)
 SEPTEMBER 13, 1994
PAGE:
                                                                      of   5
 ^^PRECAUTIONARY INFORMATION
                            (eontinu«d)
                                EXPOSURE LIMITS
INGREDIENTS
QUARTZ 	

POTASSIUM FELDSPAR 	
SODIUM SILICATE 	
KAOLIN 	

KAOLIN 	
CARBON BLACK 	
CARBON BLACK 	
CHROMIUM OXIDE (TRIVALENT CHROMIUM)

CHROMIUM OXIDE (TRIVALENT CHROMIUM)

HYDROTREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES 	
HYDROTREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES 	
RUTILE TITANIUM DIOXIDE 	
RUTILE TITANIUM DIOXIDE 	
IRON OXIDE (FE203) 	

IRON OXIDE (FE203) 	 	

IRON OXIDE (FE203) 	

ZINC FERRITE 	
VALUE UNIT
0.1 mg/rnS
as quartz resp.
NONE NONE
NONE NONE
2 mg/m3
respirabla dust.
10 mg/m3
3.5 mg/ra3
3.5 mg/m3
0.5 mg/m3
as Cr
0.5 mg/m3
as Cr

5 mg/B»3

1 0 mg/m3
10 mg/m3
10 mg/m3
5 mg/m3
as Fe
10 mg/m3
as fume
5 mg/m3
as Fe
NONE NONE*
TYPE AUTH SKIN*
TWA OSHA
dust
NONE NONE
NONE NONE
TWA AC6IH

TWA OSHA
TWA AC6IH
TWA OSHA
TWA ACGIH

TWA OSHA


TWA CMRG

STEL CMRG
TWA ACGIH
TWA OSHA
TWA ACGIH

TWA OSHA

TWA ACGIH

NONE NONE
          « SKIN NOTATION:  Listed substances indicated with "Y" under  SKIN refer to
          tha potential contribution to the overall exposure by the  cutaneous route
          including mucous membrane and eye, either by airborne or,  more particularly,
          by direct contact with the substance.  Vehicles can altar  skin absorption.

          SOURCE OF EXPOSURE LIMIT DATA:                      .      .
          - ACGIH: American Conference of Governmental Industrial Hygienists
          - OSHAi Occupational Safety and Haelth Administration
          - CMRGt Chemical Manufacture Recommended Guidelines
          - NONE:  Nona Established

                     PnTft                                                    	


       EYE CONTACT:
         May cause eye irritation if dust gets into eyes.

       SKIN CONTACT:                            M     , .     .   .
         No adverse health effects are expected from skin contact.

       INHALATION:                                 _, ,.
         Single overexposure,  above recommended guidelines, may causa:
   Abbreviations:  N/D  -  Not  Determined  N/A  • Not Applicable

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          3M General Offices

          3M Center
          St. Paul. Minnesota 55144-1000
          612/733-1110
MATERIAL SAFETY
DATA SHEET
                                                                      07-08
                                                                     12747
                                                                            CT 2192  -7
                                                                              PMC   5
 MSDS: 3N BRAND ROOFING GRANULES (WAUSAU, WI)
 SEPTEMBER 13, If94
                                                                 PAGE:  5 of  5
                                      (continued)
             Irritation (upper respiratory):  signs/symptoms can include
             soreness of the nose and throat,  coughing and sneezing.
        Prolonged  or repeated overexposure,  above recoa
        may causa:
                                                  indad guidelines.
              Silicosis:  signs/symptoms  can include shortness of breath and
              persistent  coughing.

              Pnaumpconiosis  (general):  signs/symptoms can include persistent
              coughing end shortness  of  breath.

       ZF SWALLOWED:
         Ingastion is not e likely  route of exposure to this product.

       CANCER:
         QUARTZ SILICA (14808-60-7) is a potential cancer hazard causing lung
         tumors by the inhalation end intratracheal routes of exposure in
         laboratory animal studiesCNTP anticipated human carcinogen, IARC
         probable human carcinogen  2A, Calif. Proposition 65).
HEADING

INGREDIENTS

ENVIRON. DATA

PKECAUT. INFO.
                         SECTION CHANGED SINCE  NOVEMBER 23, 1993 ISSUE

                         SECTION CHANGED SINCE  NOVEMBER 23, 1993 ISSUE

                         SECTION CHANGED SINCE  NOVEMBER 23, 1993 ISSUE

                         SECTION CHANGED SINCE  NOVEMBER 23, 1993 ISSUE
       HEALTH KAZO. DATA SECTION CHANGED SINCE  NOVEMBER 23, 1993 ISSUE
  Abbreviations:   H/D - Not Determined   N/A  -  Not Applicable

      The information on this Data Sheet represents our current data  ana oesx
      opinion as  to  the proper usa in handling of this material under normal
      conditions.  Any usa of the material which is not in conformanca with this
      Data  Sheet  or  which involves using tha material in combination  with any
      other material or any other process is tha responsibility of tha user.

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                          MATERIAL SAFETY  DATA SHEET
Seated Air Corporation
£iigiiK«r»d ProauclB Olviftton
•OO«Sr>«™in Tnon. Oinouor CTO«tO (203) 791 JSOO
                                              l-A
                                              Page i  of 6
                                              Issued  4/97
    EMERGENCY TELEPHONE NO:
       (203) 791-3500 M-F 8:30-5:00 ET
       CHEMTREC 1-800-424-9300 (for Chemical Emergency"
       spill, leak, fire exposure or accident, 24 hours)
    SECTION 1 - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
     Product Name:
     Chemical Name:
     Trade Name:
     Chemical Family:
     Chemical Formula:
INSTAPAK • COMPONENT "A"
Polymethylene Polyphenylisocyanate
Polymeric MDI
Aromatic Isocyanates
N.A.
SECTION 2 - COMPOSITION / INFORMATION ON
Harardous Ingredients:
Polymeric Diphenyimethane
Diisocyanate ("polymeric" MDI)
Contains:
4,4'-Diphenyimethane diisocyanate
(4,4'-MDl; CAS 101-68-8; « 45% )
Other MDI isomers and oligomers
CAS No.
9016-87-9


INGREDIENTS
Wt.% OSHA-PEL
100 N.E.
0.02 ppm
(Ceiling)
N.E.

ACGIH-TLV
N.E.
0.005 ppm
(TWA)
N.E.
; SECTION 3 - HAZARDOUS IDENTIFICATION
                                     EMERGENCY OVER VIEW

     Health Hazards: Irritating to eyes, respiratory system and skin. Inhalation at levels above the
     occupational exposure limit could cause respiratory sensitization. The onset of the respiratory symptoms
     may be delayed for several hours after exposure. A hyper-reactive response to even minimal
     concentrations of MDI may develop in sensitized persons. Sensitized persons should not be exposed to
     any mixture containing unreacted MDI.

     Physical Hazards: Reacts slowly with water to produce carbon dioxide which may rupture closed
     containers. This reaction accelerates at higher temperatures.

     Appearance:  Dark brown liquid.

     Odor: Slightly aromatic (musty).
      Note:  Read the entire MSDS for a more thorough evaluation of the hazards.
                                                     N f. • NOT ESTABUSMCO  N A • NOT APFIICASLI A I • ACTIVE

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Sealed Air Corporate i
                  — -                                                         Issued 4/97
Erx)iii««nn Products Oiwxon
 ; c*a Sn«"-a« *"o« ii.-ourv C" :6*iO  2031 791 3500
    ! SECTION 4 - FIRST AID MEASURES
     Inhalation-  Remove from further exposure and obtain medical attention. Treatment is symptomatic for
     primary irritation or difficulty in breathing.  If breathing is labored, oxygen should be administered fa-
     qualified personnel.  Apply artificial respiration if breathing has ceased or shows signs of failing.
     Asthmatic-like symptoms, if manifested, may develop immediately, or be delayed for up to several hours.

     Skin Contact: Wash affected area thoroughly with soap and water. Launder contaminated clothing
     thoroughly before reuse.  If irritation, redness, or a burning sensation develops and persists, obtain medical
     advice.

     Eye Contact:  Flush with copious amounts of water for at least 15 minutes, holding lids open with fingers.
     If irritation  persists, repeat flushing. Refer individual to a physician for immediate follow-up.

     Ingesnon:  Do NOT induce vomiting.  Provided the patient is conscious, wash out mouth with water then
     give  I or 2 glasses of water to drink.  Refer person to medical personnel for immediate attention.

     Note to Physicians:  Symptomatic and supportive therapy as needed.  Following severe exposure medical
     follow-up should be monitored for 48 hours. Pulmonary disorders may be aggravated by overexposure.
     SECTION 5 - FIRE-FIGHTING MEASURES
     Fiash Point:  390° F (199° C) [Pensky-Manens Closed Cup]
     Flammable Limits (lower): Not available
     Flammable Limits fupperV Not available

     Extinguishing Media: Carbon dioxide (CO2), dry chemical, or chemical foam. If water is used, large
     quantities are required. Contain run-off water with temporary barriers.

     Fire and Explosion  Hazards:  Containers may burst under intense heat Avoid water contamination in
     closed containers; carbon dioxide is evolved which can cause pressure build-up. Caution: Reaction
     between water and hot isocyanate can be vigorous.

     Special Fire  Fighting Procedures: Firefighters must wear self-contained breathing apparatus to protect
     against toxic and irritating vapors; full protective clothing should also be worn.

     NFPA Hazard Coder        Health:          2
                               Flammability:    1
                               Reactivity:       1
                               Special Hazard:  None
     SECTION 6 - ACCIDENTAL RELEASE MEASURES
     Evacuate area surrounding the spill and prevent further leakage, spillage or entry into drains. Eye and skin
     protection should be worn during spill cleanup and ventilation maintained. If the potential for airborne
     concentrations of MDI above the PEL exists, then respiratory protection should be worn.
                                                          Nft.NOTCSTAMjSMCO NA..NOTA*W.!CA«U Al -ACTIVf ING«Ol£Nf

                                 ..~. ~ ,mm,«M ..r.o. mat ,t „ accurate to mt M« fcnowMdg* & SMMd Air Coraontion Th« o*ta on tn.s sr««<

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                                                                                    I-A
Seated Air Corporation                                                        Lsued4°/97
Emj»Mina Ptoauca Otvuion
• 0 Old Sn«m«t rneR.. Oiroury. CT 06110. (203) 791 -3500
     SECTION 6 - ACCIDENTAL RELEASE MEASURES (continued)
     Contain and cover spill with loose absorbent (earth, sand, sawdust or other absorbent materiaj), or
     absorbent pillows, pads or socks. Collect absorbed material in open containers or plastic bags, and treat
     with deactivating solution (90% water, 8% concentrated ammonia. 2% detergent). Allow to stand
     uncovered for 48-72 hours to permit carbon dioxide to escape and solidification to occur. Wash spiil area
     with deactivating solution and let stand for IS minutes or longer. Dispose of spilled material properly.
     SECTION 7 - HANDLING AND STORAGE
     Storage Temperature:  Min. 50° F (10° C) Max. 100° F (38° C)

     Average Shelf Life:  6 months

     Special Sensitivity:  Reacts with moisture to produce carbon dioxide gas.

     Precautions to be Taken in Handling and Storage:  Do not store drums uncovered outdoors.  Do not reseal
     containers unless it is certain that no moisture contamination has occurred. Do not breathe vapors or allow
     skin contact.
     SECTION 8 - EXPOSURE CONTROLS/PERSONAL PROTECTION
     Exposure'Limits:       OSHA-PEL:   4,4'-Diphenylmethane diisocyanate;    Ceiling = 0.02 ppm
                           ACGIH-TLV:  4,4'-Diphenyimethane diisocyanate;    TWA * 0.005 ppm

     HMTS Hazard Code:        Health           3
                               Flammability    1
                               Reactivity       1
                               PPE             B    (Personal Protective Equipment)

     Respiratory Protection: Due to the low vapor pressure of this material, the PEL is not likely to be
     exceeded under normal conditions.  If the material is heated or spilled in a confined area, respiratory
     protection should be worn.  Because of their short life and lack of breakthrough indicators, cartridge type
     respirators equipped for organic vapors are generally not recommended for use with isocyanates. They
     can b« used for short term emergency situations at concentrations below the PEL where the presence of
     adequate breathing oxygen can be assured. Where concentrations exceed the PEL, air supplied respirators
     must be used.

      Eve Protection: Goggles or safety glasses with side shields.

      Protective Clothing:  Chemical resistant butyl rubber, nitrile rubber, neoprene, or other suitable protective
      gloves.

      Ventilation: Use local exhaust ventilation if necessary to maintain  levels below the PEL.  For guidance on
      engineering controls refer to the ACGIH publication "Industrial 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-Place Chemicals" bulletin before
      handling Instapak* chemicals.                                             	________
                                                           N C . NOT £STA«USH«0 N A. . NOT AWI.ICABLI » I • »CTwe :NG«EOie*T
                                                                           o« S««l«d A.f Conwr«tiO«. Tht a«l on tms intt

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 Sealed Air Corporation
                                              i-A
                                              Page 4 of 6
                                              Issued 4/97
 • C 0>a Sn*»"i»r Iron . Oinowv C-:6»10. 2:3i:3'-:SW
  SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES
  Form:  Liquid
  Color  Dark brown
  Qdor  Slightly aromatic (musty)
  Vapor  Density (Air » IY.  8.5
  Molecular Weight:  Approx. 350
  Melting Point: N. E.
             Roiling Point:  406° F (208° C)
             Vapor Pressure: < 10** mm Hg @ 25° C (for Polymeric MDI)
             Specific Gravity:  1.24 @ 25* C
             Bulk Density  10 J ibs/gal
             % Volatile bv Volume:  Nil
             Solubility in Water Not soluble. Reacts slowly with water
             to liberate C0j«>s.
  SECTION 10 - STABILITY AND REACT! V ITY
  Stability:  Stable under normal conditions. Avoid temperatures above 1 10° F (43° C) or below 40° F (4° C).
  Polymerization: May occur at elevated temperatures in the presence of moisture, alkalies, tertiary amines and
  metal compounds.
  Conditions to Avoid: Contact with moisture and other materials which contain active hydrogen.
  Incompatible Materials: Water, amines, strong bases and alcohols. The reaction with water is slow at
  temperatures less than 1 20°F (49°C) but is accelerated at higher temperatures.
  Hararrinus Decomposition Products:  Highly unlikely under normal industrial use. Exposure to fire or extreme
  heat may generate oxides of carbon, oxides of nitrogen, and traces of hydrogen cyanide.
  ! SECTION 11 - TOXICOLOGICAL INFORMATION
   Polymeric MDI:
                 LD^Oral:
                     , Dermal:
                     , Inhalation:
>15,800 mg/kg (rat)
>5000 mg/kg (rabbit)
 370 • 490 mg/mJ/4 hours (rat) for an aerosol of polymeric MDI
   Primary Route*si of Exposure:  Skin contact from liquid. Inhalation. However, due to the low vapor pressure, -
   overexposure is not expected under normal conditions unless material is heated or used in a poorly ventilated
   area.

   Inhalation: This product is a respiratory irritant and potential respiratory sensmzer. Inhalation of vapor or
   aerosol at levels above the occupational exposure limit can cause respiratory sensitization. Symptoms may
   include irritation to the eyes, nose, throat, and lungs, possibly combined with dryness of the throat, tightness of
   chest and difficulty in breathing.  The onset of respiratory symptoms may be delayed for several hours after
   exposure. A hyper-reactive response to even minimal concentrations of MDI may develop in sensitized persons.
   Sensitized persons should be removed from any further exposure. Persons with asthma-type conditions or other
   chronic respiratory diseases should be excluded from working with MDI. In a single evaluation of 5 men
   occupationally exposed to MD! and hydrocarbon solvent vapors under conditions where adequate ventilation or
   other safety precautions were not used, neuropsychologic findings were attributed to MDI.

   Skin Contact: May cause irritation or rash. Can  cause skin discoloration.  Repeated and/or prolonged contact
   may result in skin sensitization. There is limited evidence from laboratory tests that skin contact may play a r' -
   in respiratory sensitization. This data reinforces  the need to prevent direct skin contact and the importance 01
   protective gloves.
                                                           tj.c ' rtor OT*tufrf N.A.>NOTA»»UCMLI * i. • »cnvt INOMC
T«,, miermatwfl «fum.iftM »«inout warranty. ticxnMOOf .moMO. txc«ot mat it a accurate to tn«
                      	—- r     i  r

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                                                                                      [-A
Sealed Air Corporahuii
        raoueu Oivnion
          n» . 0»ncu«v CT 3M10 203) '91-3500
i SECTION 11 - TOXICOLOGICAL INFORMATION (continued)
 Eve Contact-  Liquid can cause eye irritation, tearing, reddening and swelling.  Permanent qpmeal injury is
 unlikely. Exposure to MD1 vapors in excess of 0.02 ppm may cause irritation.

 Ingestion:  Ingestion is unlikely.  Based on the acute oral LD«0, this 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 MDI aerosol either at concentrations of 0, 6.2, 1, or 6 mg/m;
 (which corresponds to MDI levels equal to the OSHA-PEL, 5 times the OSHA-FEL and 30 times the OSHA-
 PEL).  No adverse effects were observed at 0.2 mg/mj concentrations. At the I mg/mjconcentration, minimal
 nasal and lung irritant effects were seen. Only at the top concentration (6 mg/m1) was there an increased
 incidence of benign tumor of the lung (adenoma) and one malignant tumor (adenocarcinoma). Overall, the
 tumor incidence, both benign and malignant, and the number ofanimais with tumors were not different. The
 increased incidence of lung tumors is associated with prolonged respiratory irritation and the concurrent
 accumulation of yellow material in the lung.  In the absence of prolonged exposure to high concentrations
 leading to chronic irritation and lung damage,  it is highly unlikely that tumor formation will occur.

 Carcinogenicitv: The ingredients of this product (>0.1%) are not classified as carcinogenic by ACGIH or IARC,
 not regulated as carcinogens by OSHA and not listed as carcinogens by NTP.

 Mutagenicity: There is no substantial evidence of mutagenic potential.

 Reproductive Effects: No adverse reproductive effects are anticipated.

 Teratogenicity and Fetotoxicity: No birth defects were seen in two independent animal (rat) studies.
 Fetotoxiciry was observed at doses that were extremely toxic (including lethal) to the mother. The dose that
 produced this effect (1.2 ppm) is 60 times higher than the OSHA-PEL.  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.


 1 SECTION 12 - ECOLOGICAL INFORMATION

  Environmental Fate and Distribution: 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
  inert and non-biodegradable solids.

  Aquatic Toxicity:
         LCW:             >1000 mg/1 (Zebra fish) At the highest level of 1000 mg/l, there were no deaths.
         EC* (24 hour):    > 1000 mg/1 (Daphnea magna)
         EC*:             >100mg/l(E.Coli)
  SECTION 13 - DISPOSAL CONSIDERATIONS
   Incinerate or dispose of in accordance with existing federal, state and local environmental control regulations.
   This material is not a hazardous waste under RCRA 40 CFR 261  when disposed of in its purchased form. Small
   quantities should be treated with deactivation solution outlined in Section 6.  Refer to the "Recommendations for
   the Safe Use and Handling of Instapak* Foam-m-Place Chemicals" bulletin for additional information
   concerning disposal of wastes and empty containers. Chemical waste, regardless of quantity, should never be
   poured into drains, sewer: or waterways.

                                                           N I . NOT MTASUSHfO NA .NOT AMICABLE A I- ACTIVE INGHSOI6N

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••<»
Sealed Air Corporation
                                                                              Page 6 of 6
                                                                                   4/97
•: OKSSw-i" r-s. Cj
                 CT ;6»lfl .203) "9' 3500
 i SECTION 14 - TRANSPORT INFORMATION
 DOT: Containers less than 5,000 pounds are not regulated.

 IMP: Not regulated.

 IATA/ICAQ Class:  Not regulated.

 Reportable Quantity fROV 5.000 Ibs. for Methylene diphenyi diisocyanate (MDI), CAS #101-68-8 (» 45% of
 product).
 SECTION 15 - REGULATORY INFORMATION
 QSHA Status: This product is considered hazardous under the Federal OSHA Hazard Communication Standard
 29CFR 1910.1200.

 TSCA Status: All ingredients are listed or are not required to be listed.

 SARA 302 Extremely Hazardous Substances: None
SARA 3 i
             ! 1 Hazard Cateories:
                                    Immediate (acute) Health Hazard
                                    Delayed (chronic) Health Hazard
                                    Reactive Hazard
  SARA 313 Listed Ingredients:  This product contains the following chemicals subject to the reporting
  requirements:  1 00% Diisocyanate compounds (Category Code N 1 20).

  RCRA Status: 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
     PA    Pennsylvania Hazardous Substance List
                                                     NJ   New Jersey Hazardous Substance List
  The appropriate state agency should be contacted for further details on regulatory requirements for the substances
  shown below.
Ingredient
Methylene bisphenyi isocyanate (MDI)
(Benzene. 1 , l'-methylenebis(4-] isocyanato-)
                                                   CAS No.
                                                   101-68-8
                                                                   Wt. %
                                                                     45
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24-HOUR EMERGENCY ASSISTANCE      GENERAL ASSISTANCE          NFPA FIRE HAZARD

3P America(In Ohio)-.800-362-8059  216-441-8106 (Technical)    Flammability: 3
     (Outside Ohio):800-321-8642  216-586-8023 (MSDS)         Health       : 1
CHEMTREC Assistance:800-424-9300                              Reactivity   : 0
                                                              Spl.Hazards:
MSDS Number > 3079                     version t ; 2
MANUFACTURER/SUPPLIER:
BP Oil Company
ADDRESS:      200 Public Square, Cleveland, OH  44114-2375

*««»«...«».«»*..«.»..  PRODUCT IDENTIFICATION  — ««-««-««««»»«»«-«—ID-
TRADE NAME:
LIGHT RAFFINATE
Date: 10/01/93

CAS NUMBER:         64741-84-0
SYNONYM(S):
  SOLVENT REFINED NAPHTHA, LIGHT CS-11; NAPHTHA
CHEMICAL FAMILY:
  PETROLEUM HYDROCARBONS
MOLECULAR FORMULA:  MIXTURE
MOLECULAR WEIGHT:   NA
PRODUCT CODE:       P 0947
HIERARCHY:          030.000

..»»».«»«».»».*»««»«»«»  PRODUCT HAZARD SUMMARY  »—«»««----«»«»*«--—PH-
HEALTH
  DANGER!
  HARMFUL OR FATAL IF SWALLOWED.
  ASPIRATION HAZARD IF SWALLOWED—CAN ENTER LUNGS AND CAUSE DAMAGE.
  VAPORS MAY BE HARMFUL.
  MAY BE IRRITATING TO THE SKIN, EYES AND RESPIRATORY TRACT.
  HEATED MATERIAL MAY CAUSE THERMAL BURNS.

FLAMMABILITY
  WARNING!
  FLAMMABLE LIQUID & VAPOR.
                ^^^•^^•^•^^^»^»^»^B^»M»«W^»     ••^^^^^•^•••^•^•^•^•^•^•^•^•^••^^•^•^•^^'•^^^^^*^-™^"—*"^^*^™^^^ •••••I
REACTIVITY
  STABLE.

*.«»*».»...«»«»«.  PRODUCT HEALTH HAZARD INFORMATION   ».—-«-—«—--HH-
INGESTION:
PRACTICALLY NON-TOXIC  (ACUTE  EXPOSURE).  Aspiration  into lungs may cause
pneumonitis.  May cause gastrointestinal disturbances.   Symptoms may  include
irritation, nausea, vomiting  and diarrhea.  Exposure may cause symptoms
similar to those listed under "Inhalation"  (see Inhalation Section).
 ^^^.^ •»•.••••••••»•••••• — — — ••••••••••» — • — — — — — —.__ _H.—IJ»J»^»^^^"»*"--—"••11"""~"~'~'~"—~*^*^**^**~™^~~**'
SKIN:
PRACTICALLY NON-TOXIC  (ACUTE  EXPOSURE).  MODERATELY  TO  SEVERELY IRRITATING.
Repeated or prolonged contact may result in defatting,  redness, itching,  pain,
inflammation, cracking and possible secondary  infection.  Absorption  from
prolonged  or massive skin contact may cause poisoning.   Contact with  heated
material may cause thermal burns.

EYE:
SLIGHTLY  IRRITATING.  Exposure to vapors,  fumes or mists may  cause irritation.
Contact with heated material  may cause thermal burns.

-------
= =========»=z === = =  PERSONAL PROTECTION INFORMATION  =»-«»«»»»«»=«s«pl =
SYE PROTECTION:
A   d eye contact with this material.  Wear safety glasses or chemical
g^_^les.  Provide an eyewash station in the work area.

SKIN PROTECTION:
Prevent skin contact.  Wear gloves found to be impervious under conditions of
use.  Additional protection may be necessary to prevent skin contact including
use of apron, armcovers, face shield,- boots, or full body protection.  A
safety deluge shower should be located in the work area.

RESPIRATORY PROTECTION:
If exposure limits are exceeded or if irritation is experienced, NIOSH
approved respiratory protection should be worn,  ventilation and other forms
of engineering controls are often the preferred means for controlling chemical
exposures.  Respiratory protection may be needed for non-routine or emergency
situations.

*»».«.««..«.....«.,.,...  PHYSICAL PROPERTIES  »»»»-»»»»»»..—...»..,.pR.
BOILING POINT:  55 - 115.5 C (131-240 P)
SPECIFIC GRAVITY:  0.69
MELTING POINT:  NA
% VOLATILE:  100
VAPOR PRESSURE:  1 PSI
EVAPORATION RATE (WATER-1):  ND
VAPOR DENSITY (AIR-1):  ND
VISCOSITY:  2 CP
% ^OLUBILITY IN WATER:  NEGLIGIBLE
0(   10L/WATER PARTITION COEFFICIENT:
POun POINT:  ND
pH:  NA
APPEARANCE/ODOR:
            CLEAR LIQUID WITH A STRONG HYDROCARBON ODOR.

»..».,*.,..»......,,,.  FIRE AND EXPLOSION DATA  —-««»»«»»==»«»-»—FE»
FLASH POINT:  10.000 C (50 F)
AUTOIGNITION TEMPERATURE:-  ND
FLAMMABILITY LIMITS IN AIR (% BY VOL.) LOWER:
1.000
FLAMMABILITY LIMITS IN AIR (% BY VOL.) UPPER:
8.000
BASIC FIREFIGHTING PROCEDURES:
Use dry chemical, foam or carbon dioxide to extinguish fire.  Water may be
ineffective but should be used to cool fire-exposed containers, structures and
to protect personnel.  If leak or spill has not ignited, ventilate area and
use water spray to disperse gas or vapor and to protect personnel attempting
to stop leak.  Use water to flush spills away from sources of ignition.  Do
not flush down public sewers or other drainage systems.

UNUSUAL FIRE AND EXPLOSION HAZARDS:
vapors form flammable or explosive mixtures with air at room temperature.
vapor or gas may spread to distant ignition sources and flash back.  Dangerous
when exposed to heat or flame.  Runoff to sewer may cause fire or explosion
h?  rd.  Containers may explode in heat of fire.  Irritating, or toxic
su  cances may be emitted upon thermal decomposition.  Dangerous when exposed
to heat or flame.  Containers may explode in heat of fire,  vapors may
concentrate in confined areas.  Exposed firefighters must wear MSHA/NIOSH
approved self-contained breathing apparatus with full face mask and full
protective equipment.

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=== = = = = = = = = = = = ====r=.== = = = = = =  REACTIVITY DATA  »...•»•--»»— -—-——•RD-
STABILITY/ INCOMP ATIBILTY :
Stable.  Avoid contact with strong oxidizers.

HAZARDOUS REACTIONS/DECOMPOSITION PRODUCTS:
Combustion may produce CO, CO2 and reactive hydrocarbons.

3. «».»»»»«»«»««»»  ENVIRONMENTAL INFORMATION  »«.-•«•-»»•»«— —»»«EI«
SPILL OR RELEASE TO THE ENVIRONMENT:
If your facility or operation has -an "Oil or Hazardous Substance Contingency
Plan", activate its procedures.

— Take immediate steps to stop and contain the spill.  Caution should be
    exercised regarding personnel safety and exposure to the spilled material.

— For technical advice and assistance related to chemicals, contact CHEMTREC
   (800/424-9300) and your local fire department.

— Notify the National Response Center, if required.  Also notify appropriate
   state and local regulatory agencies, the LEPC and the SERC.  Contact the
   local Coast Guard if the release is into a waterway.
 *»«B^ «p^ MB «»•• «» «v^ ^ ^ M»«B^»^M»M» «»«• ^***^m^m •» •»•»«•» M> «I «••* ••• «• «• w» ^^ Ml M»^»«»M» MI M»^^^ ^ •» ^M» ^ •• ^^^^
 Emergency Action:
Keep unnecessary people away; isolate hazard area and deny entry.  Stay
upwind; keep out of low areas.   (Also see  Personal Protection  Information
section.) isolate for 1/2 mile in all directions if tank, rail car or tank
truck  is involved in fire.

 Spill or Leak Procedure:
Shut off ignition sources; no flares, smoking or flames  in hazard area,  stop
leak if you can do it without risk.  Water spray may reduce  vapor; but it may
not prevent ignition in closed spaces.  Small Spills:  Take  up with sand or
other  noncombustible absorbent material and place into containers for later
disposal.  Large Spills:  Dike far  ahead of liquid spill  for later disposal.


Any spill or release, or  substantial threat of  release,  of this material to
navigable water  (virtually any surface water) sufficient to  cause a visible
sheen  upon the water must be reported immediately to the National Response
Center (800/424-8802),  as required  by U.S. Federal Law.   Failure to report may
result in substantial civil and  criminal penalties.  Also contact the coast
Guard  and  appropriate state and  local regulatory agencies.
      st",  when discarded or disposed of,  is not •^'J^SLiJgJJJ?,;
 hazardous  waste  in Federal regulations;  however it could be characteristically
 hazardous  if it  is considered toxic,  corrosive, ign}$able, or reactive
 according  to Federal definitions (40  CFR 261).   Additionally, it could be
 designated as hazardous according to  state, regulations .  This ^bi££cefic°uad
 also become a hazardous waste if it is mixed with or comes in contact with a
 hazardous waste.   Check 40 CFR 261 to determine whetherit is a
 waste.   If it is  a hazardous waste, regulations at 40 CFR 262, 263, 264, 268
 and 270 apply.  Chemical additions, processing or o^*™1?8, ^f^f
 material may make the waste management information presented in this
 incomplete, inaccurate or otherwise inappropriate.
 The transportation,  storage, treatment, and f^P??-! °5 **s I?!!
 must be conducted in compliance with all applicable Federal, state, and
 regulations.

-------
SARA TITLE III INFORMATION:
Listed below are the hazard categories for the Superfuhd Amendments and
Reauthorization Act (SARA) Section 311/312 (40 CFR  370):
Immediate Hazard:  X
Delayed Hazard:    X
Fire Hazard:       X
Pressure Hazard:
Reactivity Hazard: -

ADDITIONAL ENVIRONMENTAL REGULATORY INFORMATION:
There may be specific regulations at the local,  regional or  state  level  that
pertain to this material.

,...«««»-«».  SPECIAL PRECAUTIONS/SUPPLEMENTAL  INFORMATION  =«««=«==««SP=
HANDLING/STORAGE:
Store in a well ventilated area away from  sources of ignition  and  incompatibles

EMPTY CONTAINERS:
Empty containers may contain toxic, flammable/combustible  or explosive residue
or vapors.  Do not cut, grind, drill, weld,  reuse or dispose containers  unless
adequate precautions are taken against these hazards.

,».»..».»«  TRANSPORTATION REQUIREMENTS (DOMESTIC LAND)  ==«™™«TR=
D.O.T. PROPER SHIPPING NAME  (49 CFR 172.101):  FLAMMABLE LIQUID,  N.O.S.
(NAPHTHA),  3, UN 1993, PG  I
D.O.T. HAZARD CLASS (49 CFR  172.101):                                   3
UN/NA CODE  (49 CFR 172.101): UN 1993
PACKING GROUP  (49 CFR 172.101): FLAMMABLE  LIQUID
BILL OF LADING DESCRIPTION (49 CFR 172.202):  FLAMMABLE LIQUID,  N.O.S.
(NAPHTHA),  3, UN 1993, PG  I
D.O.T. LABELS REQUIRED  (49 CFR 172.101):   FLAMMABLE LIQUID
D.O.T. PLACARDS REQUIRED  (49 CFR  172.504): FLAMMABLE LIQUID
 .«.»»»»>»»«   INGREDIENTS/HEALTH HAZARD INFORMATION  »»——»»««-«»««IN-
        COMPONENT           |     CAS NO.    |     %      |  EXPOSURE LIMITS - REF.
  — — . — -. — .« w ««,••«••»«• — — — — — — — — «•••«•• — — •• — — __ — — _ — ••••— « — • — — — — — » — — — —" — — — — — — — » — • — — "••""•' —
 Solvent Refined Naphtha, Light64741-84-0   99-100    100 ppm (1,370 mg/m3) TLV
                                                       (ACGIH)
 ..cs-ii                                               for VM a P naphtha
                                                      300 ppm (1,350. mg/m3) PEL
                                                      ; 400 ppm
                                                      (1,800 mg/m3) STEL  (OSHA)
                                                       for
                                                      VM s. P naphtha
                                                      350 mg/m3 TWA; 1800 mg/m3
                                                       15-minute
                                                      CEIL  (NIOSH) for petroleu
                                                      m
                                                      distillates  (naphtha)
 Hexane                        110-54-3      10-15     50 ppm  (176 mg/m3) TLV (A
                                                       CGIH)
                                                       50 ppm  (180 mg/m3) PEL (0
                                                       SHA)
                                                       50 ppm  (180 mg/m3) TWA (N
                                                       IOSH)

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Health Hazards:   Classified as a primary skin irritant.  Mild eye and
respiratory tract irritant.  Central nervous system depressant and
neurotoxin.
Pentane,  3-Methyl
                              96-14-0
10-15    500 ppm (1760 mg/m3) JLV
         (ACGIH);
         1000 ppm (3600 mg/m3) STE
         L (ACGIH);
         500 ppm (1760 mg/m3) PEL
         (OSHA);
         1000 ppm (3600 mg/m3) STE
         L (OSHA);
         350 mg/m3 TWA (NIOSH); 18
         00 mg/m3
         STEL (NIOSH) recommended
         for
         alkanes
HEXANE,  3-METHYL
Health Hazards: Irritating to mucous membranes.  Can be aspirated into the
lungs and absorbed through the skin.  May cause narcotic effects.

                              589-34-4       10-15    400 ppm' (1600 mg/tn3) TLV
                                                      (ACGIH);
                                                     500 ppm (2000 mg/m3) STEL
                                                       (ACGIH);
                                                      350 mg/m3 TWA  (NIOSH);  18
                                                     00 mg/m3
                                                     15-minute CEIL  (NIOSH)  fo
                                                     r
                                                     for alkanes
 Health  Hazards:   classified as an eye,  skin and mucous membrane irritant and
 central nervous  system depressant.

                               591-76-4       5-10     None established
 Heptane (C7 & higher)
                               142-82-5
 5-10     400 ppm (1640 mg/m3)-TLV;
           500 ppm
          (2050 mg/m3)  STEL (ACGIH)
          400 ppm (1600 mg/m3) PEL;
           500 ppm
          (2000 mg/m3)  STEL (OSHA)
          85 ppm (350 mg/m3) TWA; 4
          40 ppm
          (1800 mg/m3)  15-minute CE
          IL (NIOSH)
 Health Hazards:  Classified as a primary skin  irritant.  M1Jd "J*
 mucous membrane irritant.  Central nervous  system depressant and
 BUTANE, 2,2-DIMETHYL
                               75-83-2
  1-5-    500 ppm (1800 mg/m3) TLV
          & PEL;
          1000 ppm (3600 mg/m3) STE.
          L (ACGIH &

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INHALATION:
PRACTICALLY NON-TOXIC TO SLIGHTLY TOXIC.  May cause respiratory tract
i:   ;ation and pulmonary edema.  May cause harmful central nervous system
ettects.  Effects may include excitation, euphoria, headache, dizziness,
drowsiness, blurred vision, fatigue, tremors, convulsions, loss of
consciousness, coma, respiratory arrest and death.  Repeated or prolonged
exposures may cause behavioral changes and kidney and central nervous system
damage.


„.»».»»..»»»»».»»»»»»»  FIRST AID  mmmmmmmmmmmmmmmmmmmmmmmmm-m -*FA=
INGESTION:
DO NOT INDUCE VOMITING BECAUSE OF DANGER OF ASPIRATING LIQUID INTO LUNGS.  GET
IMMEDIATE MEDICAL ATTENTION.  If spontaneous vomiting occurs, monitor for
breathing difficulty.

SKIN CONTACT:
Remove contaminated clothing immediately,  wash area of  contact thoroughly
with soap and water.  Get medical attention  if irritation persists.  Thermal
burns require immediate medical attention.

EYE CONTACT:
Flush immediately with large amounts of water for  at least  15 minutes.
Eyelids should be held away from the eyeball to ensure thorough rinsing.  Get
medical attention if irritation persists.  Thermal  burns require  immediate
medical attention.
Rt   /e exposed person from source  of exposure.   If not breathing ,  ensure clear
airway and institute cardiopulmonary resuscitation (CPR).   If breathing is
difficult, administer oxygen  if  available.   Get immediate  medical  attention.

».«»=»»»».«»»=»»»  NOTES TO PHYSICIAN  a..-.-.————-— ==PN=
INGESTION:  The most important risk. to assess is the extent of aspiration of
the  product into the lungs since an acute chemical pneumonitis can rapidly
progress to respiratory failure.  Gasping,  coughing, and choking  are
presumptive evidence of aspiration.  It is suggested that all patients
suspected of hydrocarbon aspiration have base line chest x-rays.   Immediate
riospitalization should be considered for asymptomatic children with an
abnormal chest x-ray, obtunded or  hypoxic patients, intentional or massive
ingestions, and patients with abnormal chest x-rays with clinically
significant pulmonary disease.

Gastrointestinal symptoms are usually minor and pathological changes  of the
Uver  and kidney are reported to be uncommon in acute intoxications.
Decontamination  (induced emesis  or lavage) is controversial and should be
considered on the merits of  each individual case; of course the usual
precaution of an endotracheal tube should j>e considered prior to lavage.

Hydrocarbons may increase the sensitivity of the myocardium to catecholamines ;
electrocardiographic monitoring may be indicated and careful consideration
should be given to  the  selection of bronchodilators.

Ac   ?  central nervous  system signs and symptoms may result from large
 in^stions  or aspiration- induced hypoxia.
 INHALATION ABUSE:   Gasoline is one of the solvents used by         rs
 abusers.  These patients may present with acute and/or chronic central nervous
 system signs or symptoms.  They may also present with arrhythmias.

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                                                     OSHA); 350 mg/m3 TWA; 180
                                                     0 mg/m3
                                                     STEL  (NIOSH) recommended
                                                     for
                                                     alkalies
The OSHA Permissible Exposure Limits listed above were promulgated by OSHA in
1989.  This standard was vacated by the U.S. Court of Appeals for the Eleventh
Circuit.  Exposure limits defined in specific chemical standards found in
29 CFR 1910.1001-1048 are not covered by this ruling and are still
enforceable.


 REVISION DATE: Ol-oct-1993  REPLACES SHEET DATED:  17-aug-1990
 COMPLETED BY:                  BP OIL HSEQ DEPARTMENT

 .•» MB^ ^ «• «•• MB «»«»«•> •» «•» «• 4V ••<•••»*» ^••B ••»«•» 
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                         ran
                 TRI REPORTING
  THE EPCRA SECTION 313 REPORTING
                      PROCESS
Identify Section 313
  chemicaJs
 manufactured,
 processed, or
 otherwise used al
   the site
 Deicnnineihe
quantity of Section
 313 chemicals
and how they are
 manufactured.
 processed, or
otherwise used on-
    site
                                   Identify total
                                   releases and
                                   off-site transfers
 Identify other
waste management
   practices
                                   Identify pollution
                                    prevention
                                     activities

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         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
           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

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    TOOLS AND DATA SOURCES FOR
CALCULATING REPORTING ESTIMATES

 Process flow diagrams
 Waste management manifests, invoices, and waste profiles
 Environmental monitoring data
 Permit applications
 RCRA (BRS), NPDES, CAA, CERCLA and other env. reports
 Engineering calculations and other notes
 EPA guidance
 Sector notebooks
CALCULATING REPORTING ESTIMATES
 Consider all sources (routine and non-routine)
 Reasonable estimates are required by law
 Facility determines best approach
 Data and approach must be documented

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    TECHNIQUES FOR ESTIMATING
         CHEMICAL QUANTITIES
Use of monitoring data
Mass balance calculation
Use of emission factors
Engineering calculations
   ANALYSIS OF MONITORING DATA
Product of measured concentrations, volumetric flow rates, and
density equals pounds of chemical released per year
Most commonly used for wastewater (Discharge monitoring
reports (DMRs))
Use Basis of Estimate code "M" if calculations based primarily
on monitoring data

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     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: Esimating fugitive air emissions from storage
   containers and process equipment
USE OF PUBLISHED EMISSION FACTORS
 Values used to describe the quantity of chemical released as a
 function of:
 • Specific chemical used
 • Specific process used
 • Specific equipment used
 Available in Compilation of Air Pollutant Emission Factors (AP-
 42)
 Use Basis of Estimate code "E"
                                                 10

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     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"
                                                  11
           SIGNIFICANT FIGURES
 Significant figures should reflect the precision of the estimate
 • EPA recommends using two significant figures when
   reporting releases and other waste management estimates
 • If estimate is more precise, additional significant figures can
   be used
 • If estimate is less precise, can use one significant figure or
   a range code:
    »> A= 1-10 Ibs; B = 11-499 Ibs; C = 500-999 Ibs
                                                   12

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                  "NA" VS. "0'
Use "NA" (not applicable) when no possibility of Section 313
chemical being released to or othwerise managed as waste in
that media
 •  Example: Facility has no on-site landfill
Use "0" when no release to or other waste management in the
specific media occurs, but is possible
 •  Example: Discharge to water is zero; however, release
   possible if control equipment fails
 •  Must indicate a Basis of Estimate code (i.e., M, C, E, 0) for
   all numerical estimates, including "0"
                                                     13
            FUGITIVE EMISSIONS
Part 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
                                                     14

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              STACK EMISSIONS
Part II, Section 5.2: Stack or point-source air emissions
 •  Approach: ID potential sources -> ID data/tools -> estimate
 •  Data Sources/Tools
    » Air permit applications
    » CAA Title V air inventories
    » Process and production data
    - Engineering calculations
    » Mass balance
    » Emission factors
                                                    15
       WASTEWATER DISCHARGES
Part II, Section 5.3: Release to stream or water body and Part II,
Section 6.1: Discharges to POTW
 •  Approach: ID potential sources -> ID data/tools -> estimate
Potential release sources
 •  Wastewater treatment facility discharge
 •  Storm Drains
Data/Tools
 •  Monitoring, if available
 •  DMRs or other required monitoring data
 •  NPDES permits/permit applications
 •  Process knowledge and/or mass balance              . ,

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      CALCULATING WASTEWATER
                 DISCHARGES
Calculate the yearly pounds of methanol discharged using the
following data concerning wastewater discharges of methanol:
   Date
    3/1
    9/8
Cone. (mg/L)
   1.0
   0.2
Flow (MGD)
   1.0
   0.2
                                            Amt.flbs/dav)
                                               8.33
                                                 .33
                                      Average =  4.33
                   (4.33 Ibs/day) x (365 days/yr) = 1581 Ibs/yr
MGD = million gallons per day
1 mg/L = 8.33 Ibs/million gal
                                                   17
       RELEASED TO LAND ON-SITE
Part II, Section 5.4
    » 5.4.1 Underground Injection on-site to Class I Wells
    » 5.4.2 Underground Injection on-site to Class II-V Wells
Part II, Section 5.5: Releases to land
    ,> 5.5.1 A RCRA Subtitle C Landfills
    „ 5.5.1 B Other Landfills
    » 5.5.2  Land treatment/application farming
    » 5.5.3  Surface impoundment
    » 5.5.4  Other disposal
                                                    18

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      RELEASED TO LAND ON-SITE
Approach: ID potential sources -> ID data/tools ->estimate

Potential sources of release to land

 •  Landfills

 •  Surface Impoundments

 •  Spills

 •  Leaks

Data/tools:
 •  Operating records/analytical data
 •  Spill reports
 •  Process knowledge
                                                  19
 WASTE RELEASED TO LAND ON-SITE--
                 MIGRATION
Migration of a Section 313 chemical contained in waste
released (including disposal) may occur

 •  Migration of reportable chemical within one environmental
   medium (e.g., leachate from landfill)

    > Only required to report initial release of chemical to the
     environment

 •  Migration of chemical from one environmental medium to
   another (e.g., volatilization from a landfill) within the
   reporting year

    » Release estimates should be calculated  and reported for
     both media in Part II, Sections 5,6, and 8 of Form R
                                                  20
                                                                        7<

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  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
                                                      21
       ON-SITE WASTE MANAGEMENT
Examples of waste treatment (Section 7)Air pollution control
  devices (Section 7A)
   • Air Pollution control devices (Section 7A)
   • Wastewater treatment processes (Section 7A)
   • Energy recovery devices (Section 7B)
   • Recycling devices (Section 7C)
                                                      22

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    OFF-SITE WASTE MANAGEMENT
Approach: ID potential sources -> ID data/tools -> estimate
Potential sources of off-site waste management
 •  Identify final disposition of Section 313 chemical
    » Disposal
    » Waste treatment
    » Energy recovery
    .. Recycling
Data/tools
 •  Waste manifests and vendor receipts
 •  RCRA reports
 •  Waste characterization - analyses, profiles
23
      MAXIMUM QUANTITY ON-SITE


Part II, Section 4.1: Maximum amount on-site at any time during
the calendar year
 .  Based on amount in storage, process, and wastes
 •  Not the same as Tier II maximum amount on site
    » Tier II is usually by mixtures, Form R is chemical-specific
    » Tier II excludes hazardous wastes, Form R does not
Data sources
 •  Tier II records/calculations
 •  Waste inventory data
                                                   24

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                BEST PRACTICES
• Begin early
   •  Implement a program to gather "real-time" data
   •  Collect information throughout reporting year
• Team approach
   •  Include all relevant personnel (e.g., engineering,
     environmental, waste management, operations)
   •  Distribute the responsibility
                                                     25
     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
                                                     26
                                                                          1.

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          REFERENCE SOURCES
Estimating Releases and Waste Treatment Efficiencies
EPA Industry Guidance
AP-42: Compilation of Air Pollutant Emission Factors
Technology Transfer Network (http://www.epa.gov/ttn)
 .  AP-42
 •  Water 8/ChemDat 8 programs
 •  TANKS program
Perry's Chemical Engineer's Handbook; CRC Handbook of
Chemistry and Physics; Lange's Handbook of Chemistry
                                                 27

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              EXERCISE #4: USING BEST AVAILABLE INFORMATION
Available Information: The facility processes chromium above the reporting threshold and
must complete a Form R. A wastewater stream containing chromium enters a treatment system
where the metals are precipitated out and shipped off site for disposal as a sludge. The system
has been recently installed and the facility has documentation from the supplier of the system
that it will achieve 90% precipitation of chromium. The untreated wastewater contains chromium
but the concentration or quantity is unknown. Based on monitoring and flow data, the facility
discharged treated wastewater to a water body that is known to have contained 200 pounds of
chromium last year. The only available data on the sludge is TCLP1 analysis that indicates the
sludge contains 11 ppm chromium. One million pounds of sludge were generated and shipped off
site last year for disposal in a landfill.
Question: Based on the data available, estimate the quantity of chromium shipped off-site in the
sludge during the reporting year?
     Untreated Wastewater
Treated Wastewater with
      200 pounds Cr
                            Wastewater Treatment
                                   90% efficient
                                                                 Sludge
                                                             1,000,000 pounds
                                                                (11 ppm Cr)
        'If the total concentration of a reportable section 313 chemical is not known, but the teachable
 concentration, based on Toxicity Characteristic Leaching Procedure analysis is known, then the Dilution Factor
 Approach can be can be used as a tool to estimate total concentrations. This method provides a minimum value of
 the expected concentration of the chemical in the waste. The predictive equation is the following: CT=F*CL. Where:
 CT=Total concentration, CL=Leachate concentration, and F=factor to account for dilution. The F factor of '20'
 represents the dilution encountered in the TCLP: in the analysis, 2 liters of leaching solution is added to  100 grams
 of sample and assumes that all of the chemical of interest has been transferred to the solution.

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          OVERVIEW OF FORM R
                                                   p-—
      AUTOMATED TRI REPORTING
               SYSTEM (ATRS)
Voluntary option to submit form electronically
Forms submitted on diskette and loaded directly into EPA's TRI
Database
DOS and Windows versions available
ATRS may be used for original submissions and revisions
ATRS has built-in data validation program and pick lists
A signed cover letter is the sole paper requirement

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          OVERVIEW OF FORM R
Two principal types of information
 •  Facility-specific
 •  Chemical-specific
One form must be submitted to EPA and to the SERC/TERC for
each Section 313 chemical or chemical category exceeding
applicable thresholds
    PART I:  FACILITY INFORMATION
 Identifies the facility
 • Name and address
 • TRI facility identification number
 Provides key data for linking information to other databases
 • SIC code(s)
 • Identification numbers (RCRA, NPDES, Dun & Bradstreet,
   Underground Injection Control)
 Identifies key personnel
 • Technical contact
 • Public contact

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           PART I. SECTIONS 1 AND 2
Reporting year is the calendar year to which the reported information applies;
not the year in which the form is submitted
Trade secret submissions require substantiation
Two forms are required for trade secret submissions:
 •  One complete
 •  One "sanitized" version
Separate process for national security claims
PART 1. FACILITY' IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR 19 	
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you claiming the toxk chemkal identified on page 2 trade secret?
1 I Yes (An»»er qucition 2.2; 1 1 No Do not aniwer 2.2; go
' 	 ' Attach instantiation 	 to Section 3
formi)
2.2
Is this copy Q] SinitizeJ j |Un»«ni tiled
(Anmeronl) it "YES" in 2.1)



PART I. SECTION 3
• An original signature is required
• Name must be legible (printed or typed)
• Title of the official who signs is also required
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
1 hearbv cettifi that 1 have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted
information is'true and complete and that the amounts and values in this report are accurate based on reasonable estimates using
data a\ ailable to the prcparers of this report
N.me ind ufticl.l title of o«ner/op.nlnr or .enior min»gtiTient officiil: Sifnllure: Date llgned:


	
6
••


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PARTI
. SECTION 4.1
• All parts of the facility name and address are essential
• Mailing address required if different from street address
• TRI facility identification number (if a form was filed in a
previous reporting year) or "New Facility" (if reporting for the
first time)
SECTION 4. FACILITY' IDENTIFICATION
> . Facility or Establishment Name 1

Sirta

Cn\/Count>/Slale/7ip Code ]



TRI Facil«> ID Number 1

Facilin or Esublishmenl Name or Milling Add/TV 
a.j

gjft, I
t*~* I 7^Ct*e I
;«-•' I
ZipCafa I

PUT LABEL HERE


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   PART I. SECTION 4.2 THROUGH 4.4
Specify whether the form covers all or part of the facility
 •  Federal facilities check "c", GOCOs check only "a" or "b"
List name and phone number
 •  Technical contact - should be able to explain data to EPA
 •  Public contact - should be able to represent the facility's
   data to the public
SECTION 4. FACILITY IDENTIFICATION (Continued)
4.2
43
44
This report contains information for I — I An entire | — i Pan of a i — i A Federal
(In.port.in: check a orb. check c if applicable) 1— 1 facilit> >—> fool'tv 1— 1 f>°Bt>
Technical Contact Name
Public Contact Name


Telephone Number (include area code)|

Telephone Number (include area codell
0
PART I.
SECTION 4.5 THROUGH 4.6
• Enter 4-digit SIC code(s)
• Use SIC code(s) that best describes activities being
conducted, in decreasing order of significance
• Supply latitude and longitude coordinates
s SIC Codecs)
<4-digits)
46 Latitude

a.
Dcgnx-s
•BBBBVHBMB1
b. c. d. e. f.
Longitude
10
—^^^^^^^—^^^^^^^^^^^^—*—mm

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   PART I. SECTION 4.7 THROUGH 4.10
Enter the specified identification numbers or "NA" if not
applicable
 •  Enter Dun and Bradstreet number(s)
 •  EPA ID numbers (assigned mainly for RCRA-covered facilities)
 •  NPDES permit number(s)
 •  Underground Injection Well Code (UIC) I.D. number(s)
47
Dun A Bradslreet
Number(s) (* digits)
a
b
48
EPA Identification
Number(s) (RCRA
I.D. No.) (12
characters)
3
b
49
Facility NPDES
Permit Number(>) ('
characters
a
b
4 10
Underground
Injection Well Code
(1 1C) I.D. Number(s)
(12 digits)
a
b
                                                         11
               PART I. SECTION 5
Private-sector and GOCO facilities
 •  Enter complete name and Dun & Bradstreet number of parent
   company
Federal facilities
 •  Enter the complete name of department or agency for parent
   company (e.g., U.S. Department of Interior)
 •  Check "NA" for Dun & Bradstreet number of parent company
  SECTION 5. PARENT COMPANY INFORMATION
      Name of Parent Cotnpam | | NA
  5.2  Parow Coropanx 's Dun & Bradareet Number [ | NA (9 digits)
                                                         12

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       PART II: CHEMICAL-SPECIFIC
                   INFORMATION
  Identifies the Section 313 chemical and its uses at the facility
  -  Chemical identity
  •  Activities and uses of the Section 313 chemical
  •  Maximum amount on-site at one time
  Identifies quantities released and managed as wastes
  •  Total release of the Section 313 chemical to each medium
  •  Transfers of waste to off-site locations (excluding transfers
     for sale)
  •  On-site waste treatment methods and efficiency(ies)
  Identifies other waste management and source reduction
  activities
                           13
     PART II. SECTIONS 1 AND 2:  TOXIC
     CHEMICAL OR MIXTURE IDENTITY

SECTION 1. TOXIC CHEMICAL IDENTITY
1.1
1.2
1J
CAS Number (IMPORTANT Enler onh one number ex.
(Important: DO NOT complete thu
section if you completed Section Z below.)
KU) as it appears on the Section 113 list Enter categon code it reporting a chemical category)

Toxic Chemical or Chemical Catcgon Name (Important
Enter onl> one name exactli as it appears on the Section 3 1 3 list.)

Genetic Chemical Name (Important Complete onlv if Pan 1. Section 2 1 is checked "> a." Genenc name must be structurally descriptive.)


  Complete either Section 1.1 & 1.2 or Section 1.3 or Section 2
  Enter CAS number or category code and name of Section 313
  chemical or chemical category (except on "sanitized" form)
  Enter generic name only if claiming Section 313 chemical name as a
  trade secret (Section 1.3)
SECTION 2. MIXTURE COMPONENT IDENTITY
(Important: DO NOT complete this
section if >ou complete Section 1 above.)
          cal Name Provided b> Supplier (Inyonam; Maximum of 70 cbaraclos. including numbere. letters, spaces, and punctuauon.)
   If supplier claims trade secret, report generic name by supplier

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PART II. SECTION 3: ACTIVITIES AND USES
   OF THE CHEMICAL AT THE FACILITY
                   (GENERAL)

• Specify use(s) of the Section 313 chemical: manufacture,
  process, or otherwise use
• Report only activities taking place at reporting facility
• Check a[l applicable boxes
SECTION 3. ACTIVITIES AND I'SES OF THE TOXIC CHEMICAL AT THE FACILITY
(ImportMtt: Check all that appt})

«J~] Produce b-Q Import
Ifjjroduce or impon
C.{ 	 ] For on-site use/processing
dj~~] For ulc/disiranaion
f.j ] As * byproduct
f. [_J As an impurin
3.2] Procct* the totic chemic»l:
»^J As a reacum
bj^J .\s a formulation conponcnt
C.[ 1 As an anicie oomponcni
dj 1 Repackaging
3.3 | Otherwise UM the tuxk chcnkij
l^_J As a chemical processing aid
bj_J As a manufdduruig aid
C.j j Ancillar> or oiha use
                                                  15
 PART II. SECTION 4: MAXIMUM AMOUNT
   OF THE TOXIC CHEMICAL ON-SITE AT
           ANY TIME DURING YEAR

 •  Insert appropriate code from instructions indicating the
   maximum quantity on-site
 •  Use maximum total amount present at one time during
   reporting year, even if Section 313 chemical is present at more
   than one location at the facility
 •  Include amounts in storage, processes, and wastes (but not
   those amounts which have been previously land disposed)
SECTION 4. MAXIMl'.M AMOUNT OF THE TOXIC CHEMICAL ON-SITE
AT ANY TIME DURING THE CALENDAR YEAR
4.1
f (Enter Mo-digit code from instruction package )

                                                  16

-------
PART II. SECTION 5: QUANTITY OF THE
  TOXIC CHEMICAL ENTERING EACH
       ENVIRONMENTAL MEDIUM

Total aggregate releases of Section 313 chemical to the
environment from the facility during calendar year
 •  Report total releases of Section 313 chemical to each
   environmental medium
In column A, Total Releases, report total quantity
 • A range code can be used for quantities less than 1,000
   pounds)
    » A = 1 -10 pounds
    » B = 11 -499 pounds
    » C = 500 - 999 pounds
                                               17
PART II. SECTION 5:  QUANTITY OF THE
   TOXIC CHEMICAL ENTERING EACH
       ENVIRONMENTAL MEDIUM

 Basis of estimate codes
  • Monitoring data (M)
  • Mass balance (C)
  • Emission factor (E)
  . Other approaches and engineering estimates (O)
 Use the code for the method used to estimate the largest
 portion of the release
                                               18

-------
  PART II. SECTION 5: QUANTITY OF THE
     TOXIC CHEMICAL ENTERING EACH
          ENVIRONMENTAL MEDIUM
• Section 5.1 Fugitive or Non-Point Air Emissions
   •  Enter total fugitive releases of Section 313 chemical in column A,
     including leaks, evaporative losses, building ventilation, or other
     non-point air emissions

• Section 5.2 Stack or Point Air Emissions
   •  Enter total releases to air from point sources, including stacks,
     vents, pipes, ducts, storage tanks, or other confined air streams
SECTION 5. QUANTITY' OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIt'M

5.1
5.2
Fugitive or non-point air
emissions
Suck or point air emissions
DNA
DNA
A. Told Reieaw (»«••**
vnr) (tmtir migr IVwn
t-jtKrtau M- ntfcKM*)


B. Basaof
EHmite
(ntternrir)


C. % From
Slormn «ter

  PART II. SECTION 5: QUANTITY OF THE
     TOXIC CHEMICAL ENTERING EACH
          ENVIRONMENTAL MEDIUM
•  Section 5.3 Releases to Streams or Water Bodies

    •  Enter names of streams or water bodies to which your facility directly
      discharges the Section 313 chemical
    •  Enter total amount of releases to each receiving stream or water body in
      column A; include amounts from stormwater runoff, if available
    •  Indicate in column C the percentage of the total quantity (by weight) of the
      Section 313 chemical contributed by stormwater
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIVM
SJ
Discharges to reccmng streams or waicf
Mxics {enter one name per bo\!
StrcM «r Water B«4> Nwe
SJ.I
5_U
5J.J




A. Total Rete«ftc (pouo&Aev) (cntera^e
t'rofn instructions orestitnaic)



B. Bull »f E»iiM»tc




C. %FromStonM»«er


''O

-------
PART II. SECTION 5:  QUANTITY OF THE
  TOXIC CHEMICAL ENTERING EACH
        ENVIRONMENTAL MEDIUM
Section 5.4.1 Underground Injection to Class I wells
 •  Enter total amount of Section 313 chemical injected into Class I
   wells at facility in column A and basis of estimate code in column
   B
Section 5.4.2 Underground Injection to Class II - V wells
 •  Enter total amount of Section 313 chemical injected into Class II - V
   wells at facility in column A and basis of estimate code in column
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM

S.4.1
S.J.I
Underground injection! on-sile
10 CUu 1 Wells
Underground injections on-site
10 CUu II V Well,
DNA
DNA
A. Tola) ReleuK ip0""^


R Basis of
Estimite
(enle! uiJe)


C. '/« From
Stormnater


                                                   21



PART II. SECTION 5: QUANTITY OF THE TOXIC
CHEMICAL ENTERING EACH ENV. MEDIUM
• SectU
• 0
Ic
• Q
r(
ir
DPI 5.5 Releases to Land On-Site
ther disposal (5.5.4) includes spills or leaks of the Section 313 chemical to
nd
uantities of Section 313 chemicals released to air or water after initial
ilease to land (e.g., volatilization from surface impoundments) are not
icluded here
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM

5.5
5.5.1 A
5.5. IB
5.5.2
5.5.3
5.5.4
Disposal to land on-site
RCRA Subtitle C landfills
Other landfills
Land treatment/application
farming
Surface impoundment
Other disposal
A. Total Release (p«in.fc. B. Basis of Estimate

D
D
n
n
D
22



-------
 PART II. SECTION 6:  TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
             OFF-SITE LOCATIONS
  Includes both off-site location information and quantities of
  Section 313 chemicals transferred to off-site locations

  Report quantities of a Section 313 chemical sent off-site to any
  POTW or other location for recycling, energy recovery, waste
  treatment, or disposal
  Report only total quantity of a Section 313 chemical transferred
  off-site, not entire waste
  In Sections 6.1.A.1 and 6.2.A, Total Transfers, report total
  quantity
   •  A range code can be used for quantities less than 1,000
     pounds
      » A =  1 -10 pounds
      » B =  11 -499 pounds
      » C =  500 - 999 pounds
23


PART II. SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
OFF-SITE LOCATIONS
• Section 6.1 Discharges to Publicly Owned Treatment Works
• Enter total quantity of the Section 313 chemical transferred
to all POTWs and basis of estimate
SECTION t. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
fc.l.A Telal Quantity Transferred to POTWs and Basis of Estimate
i.LA.1 TMilTrvnfen (pounds/) carl 6M.A.J Buiirf Eai«tt
(enter range code or estimate) (enter code)


24


-------
  PART II. SECTION 6:  TRANSFERS OF THE
   TOXIC CHEMICAL IN WASTE STREAMS
            TO OFF-SITE LOCATIONS
 i Section 6.1.B  POTW Name and Location
    •  Include name and address of each POTW
    •  Photocopy page 3 if reporting discharges to more than 2
      POTWs (ATRS accommodates this without photocopying)
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1.
1 POTW Name

POTW Address
Cit>
6.1.1


Stale Count\ Zip
L I POTW Name

POTW Address
Cit>


Stall; County Zip
                                                   25
 PART II. SECTION 6: TRANSFERS OF THE
TOXIC CHEMICAL IN WASTE STREAMS TO
	OFF-SITE LOCATIONS	

• Section 6.2 Transfers to Other Off-Site Locations
   •  Include name, address, and EPA identification (RCRA ID) number
   •  Enter quantities, basis of estimate, and codes for multiple activities (waste
     treatment, disposal, recycling, and energy recovery) in Rows 1 through 4
   •  Photocopy page 4 if reporting more than 2 off-site transfer locations (ATRS
     accomodates this without photocopying)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
6 2 OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO }
Off-sire Location Name
Off-siic Address
Cii\
State
Couniv

A. Total Transfer* ( pounds/ \ ear)
(enter range code or estimate)
1
2

4
B. Basis of Estimate
(enicrcode)
]
2.
1
4

Zip

C. T)peof Waste T real men t Disposal/
Rcc\cling/Energj Reco>er> (enicrcode)
l.M
2M
3.M
4M
                                                   26

-------
  PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
 General waste stream type containing the Section 313
 chemical, treatment method(s), influent concentration range,
 estimate of treatment efficiency, and indication if information is
 based on operating data
 Report each waste treatment method that the Section 313
 chemical undergoes
   • Include even if method has no effect on Section 313
    chemical
  Only data element in Form R focusing on the entire waste
  stream rather than the Section 313 chemical in the waste
  stream

                                                    27




PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
^mmm



SECTION 7 A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
O Not Applicable (NA) - Cheek here if no on-site waste treatment is applied to my
waste stream containing the toiic chemical or chemical category.
	 "' t Range of
• Genoa) b U uu Tratmau Methods) Sequence Imluent
Wuw Slrewn [ana %-«J«rwlcr ccxie(j)| Concentration
(emer cooe)

;[=J ;[=);}={
m^a^m^^^^mi^f^^^^^^
d Wute
Treatment
EfHcienc;
EiumMC_
7A.1l!
-
Bmtat.mi
e. Based on
Operating
Data?
7A.le
Yet No
D D
.rn.mi.mmi
28
mmi


-------
   PART II. SECTION 7A:  ON-SITE WASTE

TREATMENT METHODS AND EFFICIENCY


•  Section 7A.a General Waste Stream
    •  Enter a waste stream code for each waste treatment method
      sequence
       » There are four waste stream types: Gaseous, Wastewater, Liquid
        Waste, Solid Waste
•  Section 7A.b Waste Treatment Method(s) Sequence
    •  Enter code(s) from EPA instructions document for on-site waste treatment
      method(s) used
    •  Enter code(s) regardless of whether waste treatment actually affected the
      Section 313 chemical
    •  Report waste treatment method(s) used on aggregate waste stream as single
      stream
      If applicable, enter codes in sequence in which they occur
                                                           29
   PART II. SECTION 7A:  ON-SITE WASTE
 TREATMENT METHODS AND EFFICIENCY
   Section 7A.c Range of Influent Concentration
    •  Use range of concentration of the Section 313 chemical in waste
      stream as it typically enters treatment equipment
    •  Enter code(s) for concentration ranges (parts per million) from
      EPA instructions document
   Section 7A.d Waste Treatment Efficiency Estimates
    •  Waste treatment efficiency expressed as percent removal of
      Section 313 chemical from waste stream through biological
      degradation, chemical conversion, or physical removal
       , Use overall efficiency of waste treatment sequence, not a specific
         waste treatment method
       , Use percent removal of Section 313 chemical only, not other
         constituents of the waste stream
                                                            30

-------
  PART II. SECTION 7A:  ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
  Section 7A.eBaj5ed on
   •  Check "yes" if efficiency estimate is based on monitoring from
     typical operating conditions

   •  Check "no" if efficiency estimate is based on published data for
     similar processes or equipment supplier's literature, or if the
     influent or effluent waste comparison or the flow rate was
     otherwise estimated
                                                   31
PART II. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
•
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
|_| Not Applicable (NA) • Check here if na on-sile waste treatment is applied to any
waste stream containing the toxic chemical or chemical category.
, i^aertl h HMK Tfewment Mrlho* »1 Sequmcc
»'«« Stream Itnle. J-clwr«)
7A.I.
W
7AJ.

7AJ.
A
«| rci 1 '| rci 1 «| PU 1
	 1 9 .r| C44 | 2 [ NA ")
:R:R:H
t Rutp u[
InOuenl
7A.lt
NA
7AJc
1
7AJc
1
d Watle
EffK-lefKV
7A.W
«
7AJ<1
99 *
7AJd
91 *
e Bued L.n
Ortmait
n»u^
7A.1*
Y« No
n n
7AJ«
Vts No
ST D
7AJe
Vw N«
a n


-------
PART II. SECTION 7B: ON-SITE ENERGY
            RECOVERY PROCESSES
Enter on-site energy recovery methods for Section 313
chemical

 •  Section 313 chemical must be combustible and have a significant
    heating value (e.g., 5,000 BTU/lb.)
 •  Combustion unit is integrated into an energy recovery system
    (e.g., industrial furnace, industrial kiln, or boiler)

Enter codes in descending order by quantities combusted
  SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
   CD Not Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
                  stream containing the toxic chemical or chemical category.
   EntTC Recottn Method* (enter J-charocter code
-------
   PHOTOCOPYING PAGES OF FORM R
 Form R pages may be photocopied if additional space is necessary to
 complete these sections (photocopying is not necessary with ATRS)
  •  Section 6.1: Transfers to POTWs
  •  Section 6.2: Transfers to Other Off-Site Locations
  •  Section 7A: Waste Treatment Methods and Efficiency
 When photocopying pages, you must complete the box on each page
 to indicate the number of copies you are attaching
 For the page being photocopied, enter in the left box the total number
 of pages submitted including the original

        original + number photocopied = total pages submitted
  •  In the second box, indicate the position of the individual page
 Example
If additional pages of Part II, Sections 6.2/7A are attached, indicate the total number of pages in this
box CJ and indicate which Part 11. Sections 6.2/7A page this is. here. D (example: 1.2.3. etc.)    •> t
                 ATRS SOFTWARE
 Advantages of completing Form R or Form A electronically
  •  Reduce risk of error by reporting sites
  •  Reduce data entry error by EPA
  •  Reduced data entry redundancy
  •  Photocopying sections of the Form R would not be required
  •  Menu-driven screens with special "hot" keys displayed
  •  "Pick lists" containing valid reporting codes
  •  "Real-time" error checking and validation
 Submission of forms on magnetic media is encouraged but not
 required                                                  ->/-

-------
              ATRS SOFTWARE
Technical Support
 •  Phone: 703-816-4434
 •  Fax: 703-816-4466
 •  e-mail: tris.user.support@epcra.org
                                                 37

-------
(IMPORTANT: Type or print; read instructions before completing form)
                                                                Form Approved OMB Number: 2070-0093
                                                                Approval Expires: 04/2000
                                                                           Page 1 of 5
         EPA
                            FORMR
                                             TOXIC CHEMICAL RELEASE
                                             INVENTORY REPORTING FORM
   United States
   Environmental Protection
   Agency
                     Section 313 of the Emergency Planning and Community
                     Right-to-Know Act of 1986, also known as Title III of the Superfund
                     Amendments and Reauthorization Act
  WHERE TO SEND COMPLETED FORMS:
                                EPCRA Reporting Center
                                P.O. Box 3348
                                Merrifield, VA 22116-3348
                                ATTN: TOXIC CHEMICAL RELEASE INVENTORY
                                 2. APPROPRIATE STATE OFFICE
                                   (See instructions in Appendix F)
                                                                                            Enter "X" here if this
                                                                                            is a revision
                                                                                           For EPA use only
 IMPORTANT:    See instructions to determine when "Not Applicable (NA)" boxes should be checked.
           PART I.  FACILITY IDENTIFICATION INFORMATION
           SECTION 1.     REPORTING YEAR
                                              19
           SECTION 2.    TRADE SECRET INFORMATION
  2.1
  Are you claiming the toxic chemical identified on page 2 trade secret?

  I  I  Yes (Answer question 2.2;   I  I  No   Do not answer 2.2;
       Attach substantiation                go to Section 3
       forms)
                                                                  2.2
                                       Is this copy l~l  Sanitized    l~l  Unsanitized

                                         (Answer only If "YES" in 2.1)
 SECTION 3.  CERTIFICATION  (Important: Read and sign after completing all form sections.)
 I  hereby certify that I have  reviewed the attached documents and that,  to the best of my knowledge and belief, the
 submitted information is  true and complete and that the amounts  and  values  in this report are  accurate based on
 reasonable estimates using data available to the preparers of this report.
 Itame and official title of o«inef/operator or senior management official:
                                                         Signature:
                                                                   Date signed:
                                                       TRIFadNty ID Number!
   SECTION 4. FACILITY IDENTIFICATION
                                                       FaciiiY or Establishment Name or Mailing Address Of different from street address) |
 4.1
Fadtv or Establishment Name I
 Street
                                                Maiing Address I


                                                Citv/County/State/ZioCode   V
  4.2
 This report contains Information for
       :  check a w b; check c if appfcabfe)
                    An entire
                    fadtty
                                 I   I
                                 —
                                                                          Part of a
                                                                Telephone Number (include area code)!
                                  A Federal
                                  faciity
  4.3
        Technical Contact Name
                                                                Telephone Number (include area code! I
  4.4
        Pubfe Contact Name
  4.5
  4.6
         Latitude
                    Degrees
                                 Mfrutes
                                              Seconds
                                                           Longitude
                                                                         Degrees
                                                                                   Minutes
                                                                                                         Seconds
  4.7
  Dun ft Bradstreet
  Humberts) (9 digits)
4.8
EPA Identification Numbers)
(RCRA LD. No.) (12 characters)
                                                            4.9
FacffityNPDES Permit
(Humberts) (9 characters)
                                                                                       4.10
Underground Injection Well Code
(UK) LD. Number(s) (12 digits)
                                                            a.
                               b.
   SECTION 5.  PARENT COMPANY INFORMATION
  5.1
        Name of Parent Company
                         n
        Parent Company's Dun & Bradstreet Number
                                     CD  NA
                           (9 digits)
 EPA Form 9350-1 (Rev. 04/97) - Previous eoTtions are obsolete.

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                                                                                                            Page 2 of 5
                          EPA FORM R
       PART II. CHEMICAL - SPECIFIC INFORMATION
                                                                                     TRI FACILITY ID NUMBER
                                                                                    Toxic Chemical, Category, or Generic Name
SECTION 1 TOXIC CHEMICAL IDENTITY
                                                           (Important: DO NOT complete this section if you
                                                           completed Section 2 below.)
 1.1
      CAS NUMBER  (IMPORTANT: Enter only one number exactly as it appears on the Section 313 list.  Enter category code if reporting a chemical category.)
 1.2
      Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
      Generic Chemical Name (Important: Completenly if Part I, Section 2.1 is checked "yes". Generic name must be structurally descriptive.)
1.3
SECTION 2. MIXTURE COMPONENT IDENTITY
                                                         (Important:  DO NOT complete this section if you
                                                         complete Section 1 above.)
 2.1
      Generic Chemical Name Provided by Supplier (Important:  Maximum of 7O characters, including numbers, letters, spaces, and punctuation.)
  SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
  (Important: Check all that apply.)
 3.1  Manufacture the toxic chemical:
                                  3.2  I   Process the toxic chemical:
                                          3.3  [Otherwise use the toxic chemical:
    a. I    I Produce  b. I    I  Import
          If produce or import:
  I    I   For on-site use/processing
d. I    I   For sale/distribution
e. I    I   As a byproduct
f. I    I   As an impurity
                                  a  I     I  As a reactant
                                  D- I     I  As a formulation component
                                  c. I     I  As an article component
                                  d. I    I  Repackaging
                                                                          a.
                                                   I As a chemical processing aid
                                           b. I     I As a manufacturing aid
                                           c. I     I Ancillary or other use
  SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE 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
                                           A. Total Release (pounds/year)(enter
                                              range from instructions or estimate)
                                                                   B. Basis of estimate
                                                                     (enter code)
                                                             C. % From Stormwater
 5.1
 5.2
 5.3
Fugitive or non-point
air emissions	
Stack or point
air emissions
                                   NA
                                   NA
Discharges to receiving streams or
water bodies (enter one name per box
      Stream or Water Body Name
5.3.1
5.3.2
5.3.3
5.4.1
 Underground Injection on-site
 to Class I Wells     	
NAD
5.4.2
 Underground Injection on-site
 to Class II-V Wells
NAD
       LU inioja ii-v nwciij            I       i                                -	
If additional pages of Part II, Section 5.3 are attached, indicate the total number of pages in this
and indicate which Part II, Section 5.3 page this is, here [	1      (example:  1,2,3, etc.)
 EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
                                                          Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.

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                          EPA FORM R
      PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                Page 3 of 5
                                                                           TRI FACILITY ID NUMBER
                                                                          Toxic Chemical. Category, or Generic Name
  SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
                                   NA
                              A. Total Release (pounds/year) (enter range
                                 code from instructions or estimate)
                                        B. Basis of Estimate
                                          (enter code)
5.5
         Disposal to land on-site
5.5.1A
RCRA Subtitle C landfills
D
5.5.IB
Other landfills
D
5.5.2
Land treatment/application
farming	
D
5.5.3
         Surface impoundment
                          D
5.5.4
 Other disposal
D
   SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
          6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
       6.1.A. Total Quantity Transferred to POTWs and Basis of Estimate
       6.1.A.1. Total Transfers (pounds/year)
      	(enter range code or estimate)
                                                          6.1.A.2 Basis of Estimate
                                                                 (enter code)
             | POTW Name
 6.1.B.
    POTW  Address
 City
                        State
                          County
Zip
6.1.B.
              POTW Name
  POTW Address
City
                        State
                         County
Zip
 If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
 in this box  I      I  and indicate which Part II, Section 6.1 page this is here I       I (example: 1,2,3, etc.)
 SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
 6.2	 OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
Off-Site Location Name
Off-Site Address
City
                        State
                         County
 Zip
Is location under control of reporting facility or parent company?
                                                                                      No
EPA Form 9350-1 (Rev. 04/97) - Previous edtoons are obsolete.
                                           Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.

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                          EPA FORM R
  PART II.  CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                          Page 4 of 5
                                                                                     TRI FACILITY ID NUMBER
                                                            Toxic Chemical. Category, or Generic Name
   SECTION 6. 2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (continued)
A. Total Transfers (pounds/year)
  (enter range code or estimate)
                   B. Basis of Estimate
                    (enter code)
                  C. Type of Waste Treatment/Disposal)
                    Recycling/Energy Recovery (enter code)
                                                                          1.M
                                                                          2.M
                                                                          3.M
                                                                          4.M
6.2	OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
Off-Site Location Name
Off-Site Address
City
           State
County
                                                                                               Zip
 Is location under control of reporting facility or parent company?
                                                                                Yes
                                                                                   No
   A. Total Transfers (pound/year)
     (enter range code or estimate)
                        B. Basis of Estimate
                          (enter code)	
                 C. Type of Waste Treatment/Disposal/
                   Recycling/Energy Recovery (enter code)
 1.
                                   1.
                                                                            1.M
 2.
             2.
                                                                            2.M
 3.
                                   3.
                                                                           3.M
 4.
                                   4.
                                                                            4.M
        SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
   I	1                •       /KIA\    Check here if no on-site waste treatment is applied to any
   I	I       Not Applicable (NA) -  waste stream containinq the toxic chemical or chemical category.
 a. General
 Waste Stream
 (enter code)
b. Waste Treatment Method(s) Sequence
[enter 3-character code(s)]
            c. Range of Influent
            Concentration
. Waste Treatment
Efficiency
 Estimate
e. Based on
 Operating Data?
                                                                           7A.1c
                                                                   7A.1d
                                             7A.1e
                                                                                                     Yes
                                                                                         No
                                                                                        n
                                                                            7A.2c
                                                                                          7A.2d
                                                                                                         7A.2e
                                                                                                     Yes       No
                                                                                                     n     n
                                                                            7A.3c
                                                                                          7A.3d
                                                                                                         7A.3e
                                                                               Yes
                                                                               n
                                                                                                                No
                                                                                                               n
                                                                            7A.4c
                                                                                          7A.4d
                                                                                   7A.4e
                                                                               Yes
                                                                               n
                                                                                                                No
                                                                                                               n
                                                                            7A.5c
                                                                                          7A.5d
                                                                                                          7A.5e
                                                                                                      Yes
                                                                                                      n
                                                                                         No
 If additional pages of Part II, Sections 6.2/7A are attached, indicate the total number of pages in this
 box I	1  and indicate which Part II, Sections 6.2/7A page this is, here,  dl   (example:  1.2.3. etc.)
 EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
                                         Range Codes: A= 1-10 pounds; B=11- 499 pounds; C= 500 - 999 pounds.

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                                                                                                                                     page 5 of 5
EPA FOI
PART II. CHEMICAL-SPECIFIC II
TRI FACILITY ID NUMBER
3MR
^FORMATION (CONTINUED) Tox'c Chemica|. Category, or Generic Name

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
nNot Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
stream containing the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code (s)]
1 I I
2 1 1 3 1 4 1
SECTION 7C. ON-SITE RECYCLING PROCESSES
I I Not applicable (NA) - Check here if no on-site recycling is applied to any waste
	 stream containing the toxic chemical or chemical category.
Recycling Methods [enter
M I 2
6I I 7
3-character code(s)]
3 1 4 | | 5
8 | 9 | | 10 I
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
AH quantity estimates can be reported
using up to two significant figures.
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
8.1O
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Quantity released
Quantity used for energy recovery
on-site
Quantity used for energy recovery
off-site
Quantity recycled on-site
Quantity recycled off-site
Quantity treated on-site
Quantity treated off-site
Column A Column B Column C Column D
Prior Year Current Reporting Year Following Year Second Following Year
(pounds/year) (pounds/year) (poundsTyear) (pounds/year)







Quantity released to the environment as a result of remedial actions,
catastrophic events, or one-time events not associated with production
processes (pounds/year)
Production ratio or activity index
Did your facility engage in any source reduction activities for this chemical during the reporting year? If not,
enter "NA" in Section 8.10.1 and answer Section 8.11.
Source Reduction Activities
[enter code(s)]




Methods to Identify Activity (enter codes)
a. b. c.
a. b. c.
a. b. c.
a. b. c.
Is additional optional information on source reduction, recycling, or pollution control activities YE^ No
included with this report? (Check one box) C 1 1 	 1
* Report releases pursuant to EPCRA Section 329(8) including "any spilling, leaking, pumping, pouring, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or disposing into the environment.* Do not include any quantity treated on-site or off-site.
EPA Form 9350 -1 (Rev. 04/97) - Previous editions are obsolete.

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            POLLUTION PREVENTION
            REPORTING
               II
POLLUTION PREVENTION HIERARCHY
            Disposal or Other
              Release to
             Environment

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POLLUTION PREVENTION ACT OF 1990



PPA mandates EPA to:

 •  Establish a pollution prevention office

 •  Establish a pollution prevention strategy

 •  Provide matching grants to states for programs to promote
   source reduction

 •  Establish a source reduction clearinghouse
 •  Collect source reduction and recycling data through TRI
   Form R reports

 •  Submit biennial program reports to Congress
            SOURCE REDUCTION
Source reduction means any practice "which (i) reduces the
amount of any hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released into the
environment (including fugitive emissions) prior to recycling,
treatment, or disposal; and (ii) reduces the hazards to public
health and the environment associated with the release of such
substances, pollutants, or contaminants."
                     Pollution Prevention Act of 1990
                          6603 (5)(A)

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              SOURCE REDUCTION
Excludes:
     "(A)ny practice that alters the physical, chemical, or
     biological characteristics or total volume of a hazardous
     substance, pollutant, or contaminant through a process or
     activity which itself is not integral to and necessary for the
     production of a product or the providing of a service."
                      Pollution Prevention Act of 1990
                      Section 6603(5)(B)
        THINGS TO REMEMBER WHEN
            COMPLETING SECTION 8
    Key concepts
        •  Waste streams

        •  Process streams
        •  Reportable recycling

        •  Source reduction activities

    Develop consistent definitions for key terms

        •  Across facility
        •  Across agency/company

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        PPA DATA ELEMENT
INSERT SECTION 8 OF FORM R

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     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
      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.
                                                    1(

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                    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 §329(8))
    » Includes fugitive and stack air emissions, releases to
      land, releases to water, underground injections, and on-
      stte and off-site disposal
    » Includes metals in wastes sent to a POTW as treated on-
      site or off-site (metals cannot be destroyed)
                                                       1
                    RELEASES
Section 8.1: Quantity Released (continued)
 • § 8.1 = §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
                                                        12

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            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,
      commercially available 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-site
     >» Quantity actually combusted in the energy recovery unit
       - not the quantity entering the unit
  •  A code reported in Section 7B indicates that Section 8.2
    should be calculated
  •  Possible data sources
     » Engineering process specifications
     » Mass balance calculations
     » Best engineering judgement

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            ENERGY RECOVERY
Section 8.3: Off-site energy recovery
 •  Quantity of Section 313 chemical that is transferred Qffcsjte
   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 M91) of Form R
    » Receipts from off-site facilities
    » RCRA hazardous waste manifests
                   RECYCLING
Section 8.4:  On-site recycling
 • Quantity of Section 313 chemical recycled on-site
     » Includes total quantity of Section 313 chemical
      recovered from the recycling process and made
      available for further use
 • Possible data sources
     » Engineering process specifications
     » Mass balance calculations
 • A code reported in Section 7C indicates that Section 8.4
   should be calculated
                                                       If.

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   CALCULATING QUANTITY RECYCLED
                   IN SECTION 8.4
Facility
                          Fugitive
                         Emissions
      Quantity
      Entering
Recycling
Operation
                         Unusable
                     Residues sent off-
                      site for disposal
Quantity
Recycled
                     RECYCLING
   Section 8.5: Off-site recycling
    •  Quantity of Section 313 chemical transferred ojtsjte for
      recycling
       » Includes total quantity of Section 313 chemical
         transferred lo 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)
                                                        18

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            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
j
\ *,

^ P^,Z eL WASTE TREATMENT
rj? j^x
^f' 	 	
Determine the total quantity of Section 313 chemical treated on-
site given the information below
rk..a«*it» \ Incinerator /
Quantity ,A _ ,,, / ^ onnii mr-t-
' >\ 99% / > 800 Ibs MEK
01 Mt* \ Efficient/ to landfill

Waste
Quantity Treat
of MEK — • > Sys
90% El



water
men* fc 9nn Ihc MFK
lem . toPOTW
Fficient
2(


                                                                         7i

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            WASTE TREATMENT
Solution
  •  Total quantity of MEK entering waste treatment

  _8JP_  +JPJL  _ 82,000 Ibs
  1-0.99  1-0.90

  •  Total quantity of MEK treated
  82,000 Ibs -1,000 Ibs = 81,000 Ibs
             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.A.1 and 6.2.A (i.e., off-site transfers for
       waste treatment)
        . Important: Assume all Section 6.1 .A.1 quantities are
          treated, except metals and metal compounds

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    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 on-site,
   recovered, or recycled
 •  Excludes quantities in Sections 8.1 through 8.7
                                                  23
 CALCULATING QUANTITY REPORTED
               IN SECTION 8.8
Facility
  (2)  W  Fu9«ive
         Emissions
               Catastrophic,
             One-time Release
    On-site
    Remedial
    Cleanup
    On-site
  Treatment,
Energy Recovery,
      or
   Recycling
        Off-site Transfers
           (1) + (2) + (4) = Total Section 8.8 Quantity

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     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
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

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                Exercise #5: Identifying Waste Streams
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

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            PRODUCTION RATIO
Use production ratio if Section 313 chemical usage is directly
proportional to a production level
   Equation
            Quantity of Product: Reporting Year
              Quantity of Product: Prior Year
   Example:
   Oven manufacturing
            40,000 ovens assembled (Current RY)
             35,000 ovens assembled (Prior RY)
 = 1.14
                                                     29
               ACTIVITY INDEX
Use activity index if Section 313 chemical usage is related to an
activity at the facility and not to a production level
   Equation
              Level of Activity : Reporting Year
                Level of Activity: Prior Year
     Example:
     Tank Washouts
                 60 Washouts (Current RY)
                  50 Washouts (Prior RY)
= 1.2
                                                     3(
                                                                         1.

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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
                                                     31
      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
                                                     32

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    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          33
         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
                                                     34

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    FORM R /FORM A SUBMISSION:
           GETTING IT RIGHT!
                   'IYIY
    ALTERNATE THRESHOLD RULE
EPA published Final Rule (40 CFR 372.27; 59 FR 61501,
11/30/94)
 •  Reduced reporting option for low annual reportable
   amounts
    » No Form R report
    » No release, other waste management, or source
     reduction reporting
    » Submit certification form (Form A) each year

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    ALTERNATE THRESHOLD RULE
Criteria for using alternate threshold
 •  Do not exceed 1,000,000 pounds manufactured, processed,
   or otherwise used, and
 •  Do not exceed 500 pounds of a Section 313 chemical
   equivalent to the sum of the quantities released, transferred
   off-site in wastes, combusted for energy recovery on- or off-
   site, recycled, or treated on-site.
     ALTERNATE THRESHOLD RULE
Recordkeeping
 •  All documentation to support the determination, including:
    » Inventory, purchasing, and sales records
    » Release calculations
    » Waste manifests or receipts
    » Other waste management data

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(IMPORTANT: Type or print; read instructions before completing form)    Form Approved: OMB #2070-0143 Form Expires: 05/31/93    Page 1 of 2
jh C D A United States
^jjjjf CZi^A\ Environmental Protection Agency
WHERE TO SEND 1 . EPCRA Reporting Center
THIS STATEMENT' p ° Box 3348
mi^iHitrotwi. MerrifielOA 22116.3348
ATTN: TOXIC CHEMICAL RELEASE
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
INVENTORY

Enter "X" here if
this is a revision

                   PART I.  FACILITY IDENTIFICATION INFORMATION
    SECTION 1.

   REPORTING
       YEAR
      19
                             SECTION 2.  TRADE SECRET INFORMATION
            2.1
                        2.2
                     Are you claiming the toxic chemical identified on page 2 trade secret?
Yes: Answer question 2.2 and
attach substantiation forms.
Np: Do not answer 2.2; continue
with Section 3.
                     If you answered yes in 2.1, is this copy:
                                                                          Sanitized
                                                                            Unsanitized
 SECTION 3.  CERTIFICATION (Important:  Please read and sign after completing the statement.)
 I hereby certify that to the best of my knowledge and belief, for the toxic chemical listed in this statement, the annual
 reportable amount as defined in 40 CFR 372.27(a), did not exceed 500 pounds for this reporting year and that the chemical
 was manufactured processed, or otherwise used in an amount not exceeding 1 million pounds during this reporting year.
 Name and official title of owner/operator or senior management official
 Signature
                                                         Date Signed
  SECTION 4.  FACILITY IDENTIFICATION
          Facility or Establishment Name
                                                                       TRI Facility ID Number |
          Mailing Address fif different from street address)
                                         State
                                                                             Zip Code
    4.1
          Street Address
                                   County
                                                        State
                                                                        Zip Code
    4.2
This report contains information for:
(Important: check c if applicable; a and b have been intentionally left blank)
    4.3
           Technical Contact
                                Name
                                                                                       ._,  A Federal
                                                                                     c-1—I    facility
                                                                               Telephone Number (include area code)
  EPA Form 9350-2 (Rev. 11/94)

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(IMPORTANT: Type or print; read instructions before completing form)
                                                                                 Page 2 of 2
 ^ C D A   United States
  iX C •  AV  Environmental Protection Agency
                                    TOXIC CHEMICAL RELEASE INVENTORY
                                                        FORMA
 SECTION 4. FACILITY IDENTIFICATION (Continued)
  4.4
Intentionally left blank
  4.5
SIC Code
(4-digit)
                      a.
                                  b.
                                               c.
                                                   d.
                                                                         e.
                                                 f.
  4.6
Latitude
and
Longitude
                                      Latitude
                        Degrees
Minutes
Seconds
Degrees
                                                                            Longitude
Minutes
Seconds
  4.7
Dun & Bradstreet Number(s)  (9 digits)
  4.8
 EPA Identification Number(s) (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)
  SECTION 5.  PARENT COMPANY INFORMATION
  5.1
         Name of Parent Company
             NA
  5.2
         Parent Company's Dun & Bradstreet Number
        D  NA
             (9 digits)
                               PART II.  CHEMICAL IDENTIFICATION
  SECTION 1. TOXIC CHEMICAL IDENTITY
  1.1
         CAS Number (Important: Enter only one number exactly as it appears on the Section 313 list. Enter category code if reporting a chemical category.)
  1.2
         Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as it appears on the Section 313 list.)
  1.3
         Generic Chemical Name (Important: Complete only if Parti, Section 2.1 is checked "yes." Generic Name must be structurally descriptive.)
  ^FPTIfiN •>  MIYTIIRF rOMPONFNTinFNTITY   (Important:  DO NOT complete this
  SECTION 2.  MIX 1UHE CUMPONtN I lUtIM III Y   section if you complete Section 1 above.)
  2.1
        Generic Chemical Name Provided by Supplier (Important: Maximum of 70 characters, including numbersjetters, spaces, and punctuation.)
EPA Form 9350-2 (Rev. 11/94)

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                   OVERVIEW:
             FORM R VS.  FORM A
 Form R
Form A
    Standard Reporting
    Method

    Use for all levels of
    releases and other waste
    management
    Report releases, other
    waste management, and
    source reduction
    activities
    Recordkeeping
    Requirements
   Alternate Reporting
   Method

   Use for low annual
   reportable amounts
   (<500 Ibs.)

   Submit Certification
   Form

   Recordkeeping
   Requirements
WHY IT'S IMPORTANT TO GET IT RIGHT
 Using TRI Data
  •  EPA is required to make non-trade secret data available to
    the public through an on-line database (operated by
    National Library of Medicine)
  •  Data are widely available on Internet
  •  Data are available in other forms (reports, CD-ROM)

  •  All states receive data; some will make it available
    electronically
                                                       10

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  EPCRA SECTION 313 ENFORCEMENT
Current enforcement trends
 •  Shift from simply identifying non-reporting facilitites to
   facilities submitting poor quality data
 •  Focus on multi-media inspections (i.e., across Agency
   programs)
 •  Assign pollution prevention-related supplemental
   environmental projects (SEPs)
    » In FY 1997, Region 5 negotiated SEPs in 17 EPCRA
      cases, which resulted in a 400,000 pound drop in total
      releases in Region
                                                   11
  EPCRA SECTION 313 ENFORCEMENT
Examples
 • Shell Oil Company ($430,000)
    » Non-reporting under EPCRA sections 304 & 313
 • Koch Refining ($585,000)
    » Data quality violations
 • Conagra, Inc. ($70,000 + SEP)
    » Result of multimedia inspection
 • Sara Lee Corp. ($118,000 +SEP)
    » Non-reporting under EPCRA sections 304 & 313
      Must conduct EPCRA and CERCLA section 103 audits at
      all 140 U. S. facilities
i:

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  EPCRA SECTION 326: CIVIL ACTIONS
Any person may bring civil action on their own behalf against a
private-sector facility owner or operator for:

 •  Failure to submit emergency follow-up notices under
   Section 304

 •  Failure to submit an MSDS or a list of MSDS chemicals

 •  Failure to complete or submit Tier I/I I inventories

 •  Failure to complete or submit Form Rs or Form As
                                                    13
  EPCRA SECTION 326: CIVIL ACTIONS
State and local governments may bring a civil action against a
private-sector facility owner or operator for:
 • Failure to notify the SERC regarding coverage under the
   emergency planning and notification requirements
 • Failure to make releveant emergency planning information
   available as requested by the LEPC
 • Failure to submit MSDS or list of hazardous chemicals
 • Failure to prepare or submit Tier l/ll inventories
Any SERC or LEPC may bring a civil action against a facility for
failure to submit Teir II information upon request

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       COMMONLY MADE ERRORS
Threshold determination errors
Completion errors
Release estimation errors
Off-site transfers reporting errors
Other waste management and source reduction errors
Federal facility name and/or parent company name errors
                                                      If
     THRESHOLD DETERMINATIONS
Helpful hints for conducting accurate threshold determinations
 • Apply chemicals to correct threshold activity
 • Avoid missing a Section 313 chemical by considering: all
   avenues a chemical may enter a facility; chemical qualifiers;
   chemical synonyms; or on-site manufacturing
 • Consider quantities of Section 313 chemicals in mixtures or
   other trade name products
 • Recognize the limitations of eligibility for exemptions
Results of incorrect theshold determinations
 • No form is submitted when one is required
 • Federal facility does not meet requirements of EO 12856   16

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      FORM COMPLETION CHECKLIST
  Helpful hints for completing the Form R/Form A
   • Complete all required sections of a current, valid form
   • Verify trade secret information (if applicable)
   • Correctly identify the Section 313 chemical using the correct
     CAS number and correct listed TRI name
   • Use the NA indicator for data elements that are not relevent
   • Indicate the correct reporting year
   • Verify latitude/longitude coordinates
   • Clearly identify revisions or duplicate submissions
   • Sign hardcopy of forms or certification letters for electronic 17
     submissions	
FORM COMPLETION CHECKLIST (CONT'D)
•  Result of completion errors
   •  Delay in processing of form
   •  Form prevented from being entered into the database
•  To avoid completion errors, use EPA's AtRS software
   •  ATRS will prompt the user to complete required sections
   •  ATRS will require the use of NA as a terminating indicator or
      to denote data elements that are not relevent

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            RELEASE ESTIMATES
Helpful hints for accurate release estimates
 •  Differentiate fugitive from stack emissions
 •  Zero air emissions for VOCs are unlikely
 •  Always use your best available information
 •  Estimate the quantity of Section 313 chemical, not the
   entire waste stream
 •  Check your math
 •  Document your work!
Result of release estimation errors
 •  Suspect release estimates
             OFF-SITE TRANSFER
                  REPORTING

Helpful hints for accurate off-site transfer reporting
 • Do not report intra-facility transfers as off-site transfers
 • Report the quantity of Section 313 chemical transferred, not
   the entire transfer quantity
 • Identify waste treatment, disposal, recycling, and energy
   recovery activities correctly
Results of off-site transfer errors
 • Incorrect estimates (e.g., over-estimates)
 • Misclassification of facility's handling of Section 313
   chemicals in wastes
                                                      2(
                                                                           h

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 WASTE MANAGEMENT AND SOURCE
         REDUCTION-SECTION 8.1
Helpful hints for reporting quantity released, Section 8.1

 •  Include off-site disposal quantities (reported in Section 6.2),
   on-site releases (reported in Sections 5.1 through 5.5), and
   releases to POTWs for metals and metal compounds only
   (reported in Section 6.1)

 •  Do not include non-production-related, one-time events
   (e.g., catastrophic or remedial releases/transfers)
    » These should be reported in Section 8.8
                                                     21
  WASTE MANAGEMENT AND SOURCE
      REDUCTION-SECTIONS 8.2-8.7
For on-site energy recovery (Section 8.2), on-site recycling
(Section 8.4), and on-site treatment (Section 8.6):

 •  Report the quantity of Section 313 chemical actually
   recovered, recycled, or treated, not the total amount
   entering the recovery, recycling, or treatment unit

For off-site energy recovery (Section 8.3), off-site recycling
(Section 8.5), and off-site treatment (Section 8.7):

 •  Conversely, report the total quantity sent off-site for
   recovery, recycling, or treatment
    » You are not required to know the efficiency of the off-site
      unit
                                                     22

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 WASTE MANAGEMENT AND SOURCE
                 REDUCTION


Helpful hints for Sections 8.2-8.7
 •  Energy recovery, Sections 8.2 and 8.3
    »  Report only for substances with significant heat value
      (do not report halons, metals, or metal compounds)
    »  Do not include incineration activities
 •  Metals and metal compounds cannot be destroyed;
   therefore, do not report quantities in Sections 8.6, or 8.7
  WASTE MANAGEMENT AND SOURCE
        REDUCTION-SECTION 8.8
Helpful hints for reporting catastrophic and remedial releases
and transfers, Section 8.8
 • Section 8.8 is exclusive of Sections 8.1 through 8.7 (do not
   include Section 8.8 quantities in Sections 8.1 through 8.7)
 • Section 8.8 quantities should be included in Sections 5-7 (as
   appropriate)

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             FEDERAL FACILITY
              IDENTIFICATION
Helpful hints for federal facilities
 •  Correctly identify department or agency
 •  Check box c. in Part I, Section 4.2 (or enter "F" on the ATRS
   software)
 •  Correctly identify GOCO
 •  Use SIC codes in Part I, Section 4.5 that best describes the
   facility's activities
Results of incorrect federal facility identification
 •  Double-counting
 •  Form entered into TRI database improperly
                                                    25
          SUBMITTING REVISIONS
Revisions can be made electronically or in hardcopy
 •  Hardcopy revisions must be made in blue or black ink on a
   copy of the form originally submitted
 •  Magnetic media revisions must be accompanied by a newly
   signed cover letter
For revisions made for reporting year 1991 or later, mark an "X"
in the space marked "Enter "X" here if this is a revision" on
pagel
Provide a new original signature and date for each revision
Send to the EPCRA Reporting Center and to the appropriate
state agency                                         _
                                                                        1.

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(IMPORTANT: Type or print; read instructions before completing form)
                                                                Form Approved OMB Number: 2070-0093
                                                                Approval Expires: 04/2000
                                                                                                  Page 1 of 5
         EPA
                            FORMR
                                                                   TOXIC CHEMICAL RELEASE
                                                                   INVENTORY REPORTING FORM
   United States
   Environmental Protection
   Agency
                     Section 313 of the Emergency Planning and Community Right-to-Know
                     Act of 1986, also known as Title III of the Superfund Amendments and
                     Reauthorization Act
 WHERE TO SEND COMPLETED FORMS:
                               EPCRA Reporting Center
                               P.O. Box3348
                               MerrifiekJ, 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 j
 IMPORTANT:    See instructions to determine when "Not Applicable (NA)" boxes should be checked.
           PART I.  FACILITY IDENTIFICATION INFORMATION
           SECTION 1.     REPORTING YEAR
                                              19   98
           SECTION 2.     TRADE SECRET INFORMATION
  2.1
 Are you claiming the toxic chemical identified on page 2 trade secret?
                                ] No  Do not answer 2.2;
                                       go to Section 3
      forms)	
r~j Yes (Answer question 2.2;
    Attach substantiation
  2.2
Is this copy       Sanitized

 (Answer only If "YES" in 2.1)
                                                                                                      Unsanitized
 SECTION 3.   CERTIFICATION  (Important: Read and sign after completing all form sections.)
 Name and official title of owner/operator or senior management official:
                                                         Signature:
                                                                                         Date signed:
   SECTION 4. FACILITY IDENTIFICATION
                                                       TRI Facility ID Number)
                                                                        20190WRLSC12034
 4.1
       Facility or Establishment Name
                                                Facility or Establishment Name or Mailing Address (if different from street address) |
         We Release Company
Street!
      PO Box 313
                                                Hailing Address |
                                                                   NA
 :ity/County/State/Zip Code |
    Releaseville/  Formar/  VA/   20190
                                                Cily/County/State/Zip Code   |
  4.2
This report contains Information for.
(Important: check a fir b; check c if applicable)
                                          An entire
                                          facility
    I—I   Part of a
    1—'   facility
                            A Federal
                            facility
  4.3
 Technical Contact Name
                                                                Telephone Number (include area code)
  4.4
        Public Contact Name
                                                                Telephone Number (include area code) |
                           John  Q. Tactless
                                                                     NA
  4.5
        SIC Code (s) (4 digits)
                             25
                                         b.  1021
                                                            NA
                                                                        d.
                                                                                         e.
  4.6
         Latitude
                    Degrees
                    NA
                                 Minutes
                                 31
                                              Seconds
                                     17
                                                           Longitude
                                                                   Degrees
                                                                          N15
                                                                                          Minutes
                                                                                          11
                                                                                                          Seconds
                                                                                                         30
  4.7
 Dun & Bradstrect
 Number(s) (9 digits)
                               4.8
                           EPA Identification Number(s)
                           (RCRA I.D. No.) (12 characters)
                                                            4.9
Facility NPDES Permit
Numbers) (9 characters)
                4.10
Underground Injection Well Code
(UIC) I.D. Number(s) (12 digits)
        NA
                               a.
                             AKD919762270
                                                                 NA
                                                                                            NA
  b.
                             20190WRLSC12034
   SECTION 5. PARENT COMPANY INFORMATION
  5.1
        Name of Parent Company
                               NA
  5.2
        Parent Company's Dun & Bradstreet Number
                                          NA
                                                 (9 digits)
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.

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                                                                                                             Page 2 of 5
                               EPA  FORM R
        PART II.  CHEMICAL -  SPECIFIC INFORMATION
                                                                                      TRI FACILITY ID NLMBfft
                                                                                 20190WRLSC12034
                                                                                     Toxic Chemical, Category, or Generic Name
                                                                                        Xylene
 SECTION 1.TOXIC CHEMICAL  IDENTITY
                                                            (Important: DO NOT complete this section if you
                                                            completed Section 2 below.)
  1.1
       CAS NUMBER (IMPORTANT: Enter only one number exactly as it appears on the Section 313 list. Biter category code if reporting a chemical catego
                                                                                                    ry.)
         1330-20-7
 1.2
       Toxic Chemical or Chemical Category Name (Important: Enter only one name exactly as il appears on the Section 31 3 list.)
          Xylene
 1.3
       Generic Chemical Name (Important: Complete only il Rarl I, Section 2,1 is checked 'yes'. Generic name must be structurally descriptive.)
           Thin-to-Win  Lacquer Thin
 SECTION 2. MIXTURE COMPONENT IDENTITY
                                                          (Important:  DO NOT complete this section if you
                                                          complete Section 1 above.)
 2.1
       Generic Chemical Name Provided by Supplier (Important: Maximum ot 70 characters, including numbers, letters, spaces, and punctuation.)
 SECTION 3.  ACTIVITIES AND USES OF THE TOXIC  CHEMICAL AT THE FACILITY
              (Important: Check all that  apply.)
c. |x   I   For on-site use/processing
d. | x  I   For sale /dist ribut ion
e. I    I   As a byproduct
f. I    I   As an impurity
                                  a-  I    I  Asareactant
                                  b.  |    |  As a formulation component
                                  c.  I    I  As an article component
                                  d.  I    I Ftepackaging
                                            a- I     I  As a chemical processing aid
                                            b. I     I  As a manufacturing aid
                                            c. |     |  Ancillary or other use
   SECTION  4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME DURING THE
                   CALENDAR YEAR
 4.1
  [  02     (Enter two-digit code from  instruction package.)
    SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH  ENVIRONMENTAL MEDIUM
                                            A. Total Release (pounds/year)(enter
                                              range from instructions or estimate)
                                                                   B. Basis of estimate
                                                                     (enter code)
                                                              C. % From Siormwater
 5.1
 5.2
 5.3
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
NA
500
Discharges to receiving streams or
water bodies (enter one name per box)
      Stream or Water Body Name
5.3.1
   River Qua!
5.3.2
   Burning River
                                                   4016 Ibs.
5.3.3
   Lake Anne
                                                   0.8
                                                                                                  100
5.4.1
Underground Injection on-site
 to Class I Wells
5.4.2
 Underground Injection on-site
 to Class II-V Wells
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
                                                                  Range Codes: A = 1 -10 pounds; B = 11 - 499 pounds; C = 500 - 999 pounds.

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                                                                                               Page 3 of 5
                         EPA FORM R
     PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                         TRI FACILITY ID NUMEER
                                                                  20190WRLSC12034
                                                                         Toxic Chemical, Category, or Generic Name
 SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM
                                  NA
                              A. Total Release (pounds/year) (enter range
                                 code from instructions or estimate)
                                 B. Basis of Estimate
                                   (enter code)
5.5
         Disposal to land on-site
5.5.1 A
RCRA Subtitle C landfills
5.5.1B
         Other landfills
5.5.2
Land treatment /application
farming
5.5.3
Surface impoundment
5.5.4
 Ot her disposal
       6.1 .A. Total Quantity Transferred to POTWs and Basis of Estimate
       6.1.A.1. Total Transfers (pounds/year)
              (enter range code or estimate)
                                                        6.1.A.2  Basis of Estimate
                                                               (enter code)
            4016
 6.1.B.
             [POTWName
             Mukbegon Municipal Treatment
    POTW Address
 Qty
Mukbegon
                        State
Wasteaway
                   County
                                                                    Formar
               Zip
                    20190
6.1.B.
             | POTW Name
                       NA
  POTW Address
 City
                        State
                   County
               Zip
 If additional pages of Part II, Section 6.1 are attached, indicate the total number of pages
 in this box  |      |  and indicate which Part II, Section 6.1 page this is here |	~\ (example: 1,2,3, etc.)
  SECTION 6.2  TRANSFERS TO OTHER OFF-SITE LOCATIONS
 6.2
 OFF-SITE EPA IDENTIFICATION NUfvBER (FCRA ID NO.)
                                                                VAD919762270
Off-Site Location Name
                        Jones Treatment Center
Off-Site Address
                    999  Jones Rd.
Qty
Mukbegon
                        State
                               VA
                   County
Formar
                Zip
20190
Is location under control of reporting facility or parent company?
                                                                CHYes
                                                     No
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
                                          Range Codes: A = 1 -10 pounds; B = 11 • 499 pounds; C = 500 - 999 pounds.

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                          EPA FORM R
    PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                                     Page 4 of 5
                                                                                 TFJ FACILITY ID NUMBER
                                                                    20190WRLSC12034
                                                                  Toxic Chemical. Category, or Generic Name
                                                                                 Xylene
    SECTION 6. 2 TRANSFERS TO OTHER OFF-SITE LOCATIONS (continued)
 A. Total Transfers (pounds/year)
   (enter range code or estimate)
                           B. Basis of Estimate
                             (enter code)
                   C. Type of Waste Treatment/Disposal/
                    Recycling/Energy Recovery (enter code)
 1.   10,200
                                 1.
                          M
                                                          1.M
                                                                  24
 2.
                                2.
                                                          2.M
 3.
                    3.
              3.M
 4.
                    4.
              4.M
 6.2 	OFF-SITE EPA IDENTIFICATION NUMBER (RCRA ID NO.)
 Off-Site Location Name
 Off-Site Address
 City
                    State
 County
                                                                                        Zip
  Is location under control of reporting facility or parent company?     |     | Yes
                                                                                       No
    A. Total Transfers (pound/year)
      (enter range code or estimate)
                                B. Basis of Estimate
                                 (enter code)
                 C. Type of Waste Treatment/Disposal/
                   Recycling/Energy Recovery (enter code)
  1.
    SAMPLE
                    flORM
                       ERRORS
2.
  3.
                      3.
 4.
                      4.
                                                                       4.M
  If additional pages of Part II, Section 6.2 are attached, indicate the total number of pages in this
  box I     I  and indicate which Part II, Section 6.2 page this is, here. I     I (example:  1.2.3. etc.)
        SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
               nNot Applicable (NA) - Check here if no on-site waste treatment is applied to any
       	waste stream containing the toxic chemical or chemical category.
 a. General
   Waste Stream
   (enter code)
         b. Waste Treatment Method(s) Sequence
           [enter 3-character code(s)]
            c. Range of Influent
             Concentration
                                                                                d. Waste Treatment
                                                                                  Efficiency
                                                                                  Estimate	
e. Based on
Operating Data?
  7A.1a
7A.1b

 3  r
 6
                  F18
                                    P12
Pll    |
                                    P17
                   P21
                                                                       7A.1C
                                                                                   7A.1d
   7A.1e
                                                                                   75   %
                                       Yes        No
                                       B      n
   7A.2a
             7A.2b
                                                                       7A.2C
                                                                        7A.2d
                                           7A.2e
                                                                                   66
                                                                                    Yes       No

                                                                                    D       [1
  7A.3a
7A.3b


 3

 6
               7A.3c
                                                                                   7A.3d
   7A.3e
                                                                                                Yes       No
                                                                                                D       D
  7A.4a
7A.4b

 3

 6
                                                                       7A.4C
                            7A.4d
                                                                                                 7A.4e
                                                                                               Yes      No
                                                                                               n      c
  7A.5a
             7A.5b
                                                                       7A.5c
                                                                        7A.5d
                                           7A.5e
                                                                                                Yes       No
EPA Form 9350-1 (Rev. 04/97) - Previous editions are obsolete.
                                              Range Codes: A= 1-10 pounds; 6=11-499 pounds; C= 500 - 999 pounds.

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                                                                                                   page 5 of 5
                               EPA FORM R
         PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED)
                                                                                  TR FACILITY ID NUMBfft
                                                                                 20190WRLSC12034
                                                                          Toxic Chemical, Category, or Generic Name
                                                                            mercury
         If additional copies of page 4  are attached, indicate the total number of pages in this
         box   |     |   and indicate which page 4 this is, here.   |     |   (example:  1,2,3, etc.)
        SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
          Not  Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
                                 stream containing the toxic  chemical or  chemical category.	
     Biergy Recovery Methods [enter 3-character code (s)]

                        I   2  '
   U02
                                  NA
      J    3   [
        SECTION 7C. ON-SITE RECYCLING PROCESSES
         Not applicable (NA) - Check here if no. on-site recycling is applied to any waste
                                  stream containing the toxic chemical or chemical category.
      Recycling Methods [enter 3-character code(s)]

                        2

                        7
Ull
                        U12
        U13
                                                                4
                                                                       NA
        rtf i u L£ [is :L: £ : :
 All quantity estimates can be reported
 using up to two significant figures.
                                        iuimnl
                                      Prior Year
                                     (pounds/year)
                                                      INE^TE a • s
                   Column B
              Current Reporting Year
                  (pounds/year)
  Column C
Following Year
 (pounds/year)
                                            1
           J5
             10
Second Following Year
   (pounds/year)
8.1
  Quantity released
                 220
 15,698
                                                                                               17,582
8.2
  Quantity used for energy recovery
  on-site
                                           2,000
8.3
  Quantity used for energy recovery
  off-site	
                                           NA
                                                             NA
                                                                            NA
                                                    NA
8.4
  Quantity recycled on-site
500
                                                            500
                                                                             500
                                                                                                500
8.5
  Quantity recycled off-site
                                           900
                                                            900
                                  900
                                                    900
8.6
  Quantity treated on-site
                                          9,000
                 NA
                                  11,400
                  12,800
8.7
  Quantity treated off-site
                                          514
                                                            4016
                                                                        1,000
                                                     1,000
8.8
  Quantity released to the environment as a result of remedial actions,
  catastrophic events, or one-time events not associated with production
  processes  (pounds/year)
8.9
       Production ratio or activity index
                                                                         1.12
8.10
   Did your facility engage in any source reduction activities for this chemical during the reporting year? If not,
   enter "NA" in Section 8.10.1 and answer Section 8.11.
          Source Reduction Activities
                [enter code(s)]
                                    Methods to Identify Activity (enter codes)
8.10.1
            NA
                                       a.
                                                          b.
8.10.2
                                       a.
                                                               b.
8.10.3
                                       a.
                                                               b.
8.10.4
                                       a.
                                                               b.
 8.11
  Is additional optional information on source reduction, recycling, or pollution control activities
  included with this report? (Check one box)
                                                                                               YES    NO
* Report releases pursuant to EPCRA Section 329(8) including "any spilling, leaking, pumping, pouring, emitting, emptying, discharging,
  injecting, escaping, leaching, dumping, or disposing into the environment." Do not include any quantity treated on-site or off-site.
EPA Form 9350 -1 (Rev. 04/97) - Previous editions are obsolete.

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       INFORMATION RESOURCES
ADDITIONAL INFORMATION ABOUT TRI
 EPA Regional and State TRI Contacts
  •  Check the Forms and Instructions booklet
 RCRA, Superfund & EPCRA Hotline
 (800) 424-9346 or (703) 412-9810 (local or international)
  •  Regulatory assistance
  •  Information on availability of EPA publications
  •  Information on EPA's electronic resources

-------
    EPA ELECTRONIC MAILING LISTS
                   (LISTSERVER)
To subscribe to an electronic mailing list (listserver), send e-mail to:
listserver@unixmail.rtpnc.epa.gov.
Leave subject line blank or include only a period < . >
Text: subscribe   
subscribe epa-waste2 John Smith
Some mailing lists are:
 • epa-tri2: Toxic Release Inventory Federal Registers
 • hotline_oswer: RCRA. Suoerfund & EPCRA Monthly Hotline Report and
   Updates
 • epa-r2-press: EPA press releases
 • epa-meetings2: EPA meeting notification
 • oppt-newbreak: OPPT Library daily news service
  DOCUMENT DISTRIBUTION CENTERS
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1-800-490-9198
http://www.epa.gov/ncepihom/
index.html
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(202)512-1800
Fax: (202) 512-2250
http://www.gpo.gov
National Technical Information
Service (NTIS)
(800) 553-6847
(703) 605-6000 (DC Metro area)
http://www.ntis.gov

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PUBLIC ACCESS TO TRI - ONLINE ACCESS
  Right-to-Know Network (RTK NET)
  • Modem: (202) 234-8570; Information (OMB Watch): (202) 234-8494;
    Internet: http://www.rtk.net
  ENVIROFACTS Database Internet Site
  http://www.epa.gov/enviro
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  The Chemical Scorecard (EOF) - Internet Site
  http://www/scorecard.org
  TOXNET - Internet Site http://www.nlm.nih.gov or
  http://toxnet.nlm.nih.gov
  • Information and Registration for Non-Web access: (301) 496-6531
  • Nominal access charge
            PUBLIC ACCESS TO TRI
  TRI Reports (EPCRA Hotline and EPA TRI Web Site)
  • TRI Public Data Release Annual Report
  • TRI Public Data Release State Fact Sheets
  TRI CD-ROM (GPO/NTIS)
  State Data Diskettes (GPO)
  TRI User Support Service: (202) 260-1531

-------
               TRI HOMEPAGE
EPA Toxic Release Inventory: Community Right-to-Know
Homepage (http://www.epa.gov/opptintr/tri/)
 •  General information on the TRI program, program and
   phase development, program updates, and TRI contacts
 •  Accessing and using TRI data, state fact sheets, and public
   data releases
 •  Links to TRI forms, reporting requirements, and guidance
   documents
 •  Listing of TRI Chemicals
   SECTION 313 GENERAL GUIDANCE
Toxic Chemical Release Inventory Reporting Forms and
Instructions
Automated TRI Reporting System (ATRS)
EPCRA Section 313 Questions and Answers
Consolidated List of Chemicals Subject to Reporting Under the
Act (Title III List of Lists)
 • Most recent version on Internet:
   http://www.epa.gov/swercepp/pubs.html
Common Synonyms

-------
  SECTION 313 TECHNICAL GUIDANCE
Industry-Specific Technical Guidance Documents, including:
 •  Food Processing
 •  Metal and Coal Mining
 •  TSD and Solvent Recovery
 •  Petroleum and Chemical Distribution
 •  Electricity Generating Facilities
Chemical-Specific Guidance Documents, including:
 •  Sulfuric Acid, Glycol Ethers, Nitrate Compounds
Estimating Releases and Waste Treatment Efficiencies for the
Toxic Chemical Release Inventory Form
   SECTION 313 TECHNICAL GUIDANCE
  Technology Transfer Network (TTN)
  • Internet: http://www.epa.gov/ttn/
      » Compilation of Air Pollutant Emission Factors (AP-42)
      » Water 8/ChemDat 8 programs
      » TANKS program
   • Help Desk (919) 541-5384

-------
POLLUTION PREVENTION INFORMATION
  OPPT Pollution Prevention (P2) Internet Site
  • http://www.epa.gov/opptintr
  Enviro$en$e Information Network
  • User support (703) 908-2007
  • http://es.epa.gov
  Pollution Prevention Information Clearinghouse (PPIC)
  • (202)260-1023

-------