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
-------
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
-------
<
SECTION 313 CHEMICAL LIST
T
SECTION 313 CHEMICAL LIST
Dynamic, evolving list
Additions
Deletions
Modifications
-------
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
-------
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
-------
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
-------
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^
-------
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.
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
IDENTIFYING EPCRA SECTION 313 CHEMICALS
MSDS Name
Section 313 Chemical(s) Name
Concentration
Notes
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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««<
-------
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
-------
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
-------
[-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
-------
<»
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
Section(s) Revised: Format change
Printed on recycled paper (SOS secondary material,
minimum I OS post consumer) using vegetable based inks.
M-3 Rev. 4/97
Hi.. MOT CSTAMJSMO HJk. NOT AWUCAOC1 A I *CTIVf IN4S««OIHT
-------
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-------
t,«» X, SMCI1L MICAUTI3MS «
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STOtAGC: GtOUNO ANO ftONQ ALL TIAN^CI ANO STOtAGt CBUI'MNT; JSI H0>
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AtSA «WIMfa MLTK. AN AUTOMATIC S*tXN*CXNrmTtRr 09TSXBt.Qt
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?AL TUXCITT C?1TSX:. L350J > 5 0/«C 1/1.0 BATS OX!3 AT THIS OCSACf
LCVCL* CON SI OH Iff T8 lit NO «J*f T HA*- SLIGHTLY TJlIC i.JSO ON
SIMCL1 CSS? LPffL TfSTXNC AT 5 ft/Kfr«
TOIICITT (JAllITS)r LOSOl '> 2 fi/tft C/10 tAU XTS OXfO AT THI
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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 SWALLOWEDCAN 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.
-------
=== = = = = = = = = = = = ====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)
-------
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 &
-------
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.
-------
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 »«»
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
"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
-------
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 . ,
-------
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
-------
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<
-------
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
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
POLLUTION PREVENTION
REPORTING
II
POLLUTION PREVENTION HIERARCHY
Disposal or Other
Release to
Environment
-------
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)
-------
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
-------
PPA DATA ELEMENT
INSERT SECTION 8 OF FORM R
-------
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(
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
(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-1I facility
Telephone Number (include area code)
EPA Form 9350-2 (Rev. 11/94)
-------
(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)
-------
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
-------
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:
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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)
-------
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.
-------
(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
II 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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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
RCRA, Superfund & EPCRA Hotline
(800) 424-9346
(703) 412-9810 (DC Metro area)
Fax (703) 412-3333
http://www.epa.gov/epaoswer/hotline
National Center for Environmental
Publications and Information (NCEPI)
1-800-490-9198
http://www.epa.gov/ncepihom/
index.html
U.S. Government Printing Office (GPO)
(202)512-1800
Fax: (202) 512-2250
http://www.gpo.gov
National Technical Information
Service (NTIS)
(800) 553-6847
(703) 605-6000 (DC Metro area)
http://www.ntis.gov
-------
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
EPA's - TRI Internet Site http://www.epa.gov/opptintr/tri/
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
------- |