United States Office of Information March 2001
Environmental Protection Analysis and Access
Agency
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS
Reporting Year 2000
Spring 2001
TWO-DAY WORKSHOP
Module 1: TRI Overview
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RY2000 EPCRA/TRI Training for All Industries
Falls Church, VA
March 7-8, 2001
Wednesday. March 7
Morning
7:30 - 8:00 Registration
8:00 - 8:10 Introduction - EPCRA/TRI Regional Representative
Welcoming remarks
Overview of Regional technical assistance
8:10-9:10 A. Toxics Release Inventory Reporting Requirements (EPCRA Section 313) -
Robert Costa, SAIC
This presentation provides an overview of the TRI reporting criteria, focusing on threshold
determinations and key terms (e.g., facility, manufacture, process, otherwise use). The
presentation also provides a general overview of the chemical list, including chemical
categories and qualifiers.
9:15-10:00 B. Section 313 Reporting Exemptions- Jeff Kohn, SAIC
This presentation addresses reporting exemptions (e.g., de minimis, article, structural
component, routine janitorial/facility maintenance, personal use, laboratory activity, motor
vehicle maintenance, intake air and water, coal extraction activity, metal mining
overburden.
10:00-10:15 Break
10:15-11:00 C. Determining Thresholds - Robert Costa, SAIC
This session discusses methods for identifying EPCRA Section 313 chemicals, compiling
usage information, and organizing the information to facilitate making threshold
determinations.
• Exercise #1 - Identifying EPCRA Section 313 chemicals using MSOSs
11:00-12:00 D. Exercise #2: Threshold Determinations - Jeff Kohn, SAIC
A comprehensive workshop based on a mock facility; this exercise reinforces the
morning's discussion of threshold determinations and reporting exemptions. Course
participants will identify the EPCRA Section 313 chemicals used at the facility, complete
threshold determination worksheets and perform threshold determinations.
12:00-1:00 LUNCH
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Afternoon
1:00 - 2:30 E. TRI Release and Other Waste Management Reporting - Robert Costa, SAIC
This presentation focuses on a coordinated approach for collecting the information
necessary for accurate release calculations and determining off-site transfer activities.
2:30 - 2:45 Break
2:45 - 3:45 F. Overview of Pollution Prevention Reporting - Jeff Kohn, SAIC
This presentation provides an overview of the PPA, explains how that law affects EPCRA
Section 313 reporting, and reviews the data elements in Part II, section 8 of Form R.
• Exercise #3: Identifying PPA waste streams
3:45-4:00 G. Form A Submission - Jeff Kohn, SAIC
This presentation provides additional information on submitting a Form A certification
statement.
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Thursday. March 8
Morning
8:00 - 8:45 H. Reporting Requirements for Persistent, Bioaccumulative, and Toxic (PBT)
Chemicals: An Overview - Robert Costa, SAIC
This session reviews the new persistent, bioaccumulative, and toxic chemicals (PBT)
rulemaking. This presentation will also overview which exemptions will not apply for PBTs.
This presentation will introduce the chemicals subject to the new PBT thresholds, and
discusses in what types of processes and mixtures PBT chemicals will be found, how to
estimate the quantities of PBT chemicals, and where to go for additional information.
8:45 - 9:15 I. Polycyclic Aromatic Compounds (PACs) and Benzo(g,h,i)perylene - Jeff Kohn,
SAIC
• Exercise #4: Calculating thresholds for PACs and benzo(g,h,i)perylene
9:15-9:45 J. Dioxin and Dioxin-like Compounds (DLC) - Jeff Kohn, SAIC
9:45 - 10:15 K. Mercury and Mercury Compounds - Robert Costa, SAIC
10:15 -10:30 L. Pesticides - Robert Costa, SAIC
10:30 -11:00 M. Other PBT Chemicals - Robert Costa, SAIC
11:00-12:00 LUNCH
Afternoon
12:00-12:30 N. TRI Update - Robert Costa, SAIC
This presentation focuses on TRI form and procedural changes for experienced TRI filers.
Descriptions include changes to the Form R/Form A, the TRI Forms and Instructions
document, the Automated Form R Reporting Software (ATRS), and submission
deadlines,
12:30-1:30 O. EPCRA Section 313 List of Toxic Chemicals -Jeff Kohn, SAIC
This presentation provides a review of the EPCRA Section 313 chemical list and
interpretive guidance issues.
• Chemical list additions, deletions, and modifications
• Reporting guidance: Ammonia, Nitrate Compounds, Acid Aerosols (HCI, H2S04)
• Exercise #5 - Calculating releases of ammonia and nitrate compounds
1:30-1:45 Break
1:45 - 2:15 P. Acid Aerosol and Fuel Combustion Reporting - Robert Costa, SAIC
This session focuses on threshold and release determination calculations for acid
aerosols and fuel combustion. In particular, this session will focus on coincidental
manufacture of chemicals in combustion processes, including metal compounds and acid
aerosols. Aerosol discussions will emphasize situations where aerosols could be
produced from processing solutions.
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Thursday. March 8 - Continued
2:15-2:45 Q. Metal and Metal Compounds Reporting -Jeff Kohn, SAIC
This presentation focuses on reportable metals, and how they are commonly counted for
threshold and release and other waste management purposes. The session will focus on
the use of metal for products distributed into commerce (processing), and uses of metal
on-site, such as to build new tanks and equipment (otherwise use). This presentation
also describes how the article exemption applies to metal containing materials and
wastes.
2:45-3:00 Break
3:00 - 3:15 R. Maintenance Chemicals and Otherwise Use Activities - Robert Costa, SAIC
This presentation provides a review of chemicals used to maintain facility operations.
Often chemicals are overlooked that are not used directly in facility operations, such as
chemicals used to clean equipment. This presentation is designed to provide attendees
with ideas and tools for accounting for these chemicals, and how exemptions may or may
not apply depending on their use.
3:15 - 4:00 S. Getting It Right: Avoiding Common Errors - Jeff Kohn, SAIC
This session will review common errors in TRI reporting. As appropriate, EPA Regional
and/or State representatives will discuss their TRI programs and technical assistance
resources, including enforcement and compliance assurance activities.
• Exercise #6 - TRI Knowledge Quiz
4:00 - 4:30 T. Burning Questions and Closing Remarks - Jeff Kohn, SAIC
This concluding session will address any outstanding issues that developed during the
training seminar. Sources for additional guidance on TRI reporting will also be identified.
• Remaining issues; questions and answers
• EPA guidance documents
• Hotlines, bulletin boards, industry groups, trade associations
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TRAINING DISCLAIMER
This document was developed for the sole purpose of helping potential reporters
understand and comply with the reporting requirements of section 313 of the Emergency
Planning and Community Right-To-Know Act (EPCRA). Nothing in this document is intended
to independently alter, supplement, or revoke the statutory and/or regulatory requirements
imposed by EPCRA section 313 and the applicable regulations at 40 CFR 372, et seq. Although
these training materials provide an overview of the section 313 reporting requirements, facilities
should consult the statute and regulations when developing threshold determinations and
calculating releases and other waste management amounts. Facilities should be aware that EPA
also provides guidance documents containing both sector specific guidance and guidance on
specific elements of the EPCRA section 313 program. Covered facilities are encouraged to
consult these guidance documents for additional assistance. Facilities may also receive
specifically for Reporting Year 2000, for reports due on July 1, 2001. Facilities should be aware
that EPA may promulgate regulatory changes to the EPCRA section 313 program that may alter
reporting requirements for future reporting years.
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TOXICS RELEASE INVENTORY
REPORTING REQUIREMENTS
(EPCRA SECTION 313)
WHO MUST REPORT?
Facilities (Private- and Public-sector)
• In covered primary SIC code(s) or Federal facilities; and
• With 10 or more full-time employees (equivalent of 20,000
hours per year); and
• That exceed manufacture, or process, or otherwise use
thresholds for each Section 313 chemical
A-2
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WHAT TO REPORT?
File a TRI report for each Section 313 chemical
exceeding an activity threshold
Submit to U.S. EPA, and either designated state
officials or designated tribal office by July 1st for
preceding calendar year's activities
• July 1,2001 (January 1 - December 31,2000 activities)
A-3
TRI REPORTING PROCESS
Ten Employees?
(20,000 hours)
MPOIT
Section 313
Chemicals?
MPOU*
Thresholds
Exceeded?
YES
o
"D
YES
YES
YES,
•MPOU: Manufacture (including import), process, or otherwise use
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COVERED SIC CODES
^^B Industrial Sector Primary SIC Code ^|
Manufacturing
Metal mining
Coal mining
Electrical utilities
Treatment,
Storage, and
Disposal facilities
Solvent recovery
services
Chemical
distributors
Petroleum bulk
terminals
20-39
10 (except 1011, 1081. and 1094)
12 (except 1241)
491 1 , 4931 , and 4939, limited to facilities that
combust coal and/or oil for the purpose of generating
electricity for distribution in commerce
4953, limited to RCRA Subtitle C permitted or interim
status facilities
7389, limited to facilities primarily engaged in solvent
recovery services on a contract or fee basis
5169
5171
A-5
FEDERAL FACILITIES
Federal facilities (covered by Executive Order 13148)
• Owned or operated by Executive Branch agencies
» No restrictions based on SIC code
» Includes federal prisons, national parks, federal hospitals
• With 10 or more full-time employees (equivalent of 20,000
hours per year)
• That exceed manufacture, or process, or otherwise use
thresholds
• Agency responsible for reporting on activities at Federal
facilities that are conducted by, for, or in support of the
agency
A-6
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SIC CODES
Section 313 subjects facilities to reporting based on
classification of primary activities in the Standard
Industrial Classification (SIC) system (§372.22)
On April 9,1997 (62 FR17288), the North American
Industry Classification (NAIC) System was
implemented
SIC codes are to be used until EPA transitions to
new NAIC system in future reporting years
An OMB crosswalk exists between the SIC and new
NAIC codes (see 62 FR 172188)
A-7
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 - unique and separate economic unit
of a "facility" (§372.3)
Auxiliary facility - primarily supports a covered
establishment's activities at another facility
A-8
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MULTI-ESTABLISHMENT FACILITY
Three separate establishments located on contiguous/adjacent
property owned by same person(s), is one facility under EPCRA
(§372.22(b))
Covered
establish-
ments >50%
Plurality
Greatest %
Generic Products Food
Processing
(SIC 2033)
i i
E-Z- ^ 'Z- ?•
Z ?.^Z
i
Generic Products Farm
(SIC 01 61)
Gen. Prod. Warehouse
(SIC 4222)
A-9
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
• Federal facilities and federal contractors (GOCOs)
1
DOT
Coast Guard
HUD
Contractor 1
DOE
__---"
Contractor
2
Ex.1: Two separate reporting facilities
(HUD and DOT including Coast Guard)
Ex. 2: One reporting facility
(DOE)
A-10
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AUXILIARY FACILITY
Non-contiguous and non-adjacent to a covered
establishment
Primary function is to support a covered
establishment's activities at another facility (e.g.,
warehouses, laboratories)
Assumes SIC code of covered establishment for
reporting purposes
Employee and chemical activity threshold
determinations are separate!
A-11
AUXILIARY FACILITY
ACME Mfg. Facilities
(Warehouse is auxiliary facility of ACME Mfg.)
ACME
Mfg. '—
(SIC 2015)
A-12
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EMPLOYEE THRESHOLD
10 full-time employees (20,000 hours) (§§372.3 and
372.22(a))
• Worked at or directly for facility
• Includes operational staff, administrative staff, contractors,
dedicated sales staff, company drivers, off-site direct
corporate support
• Does NOT include contract drivers or janitorial contractors
Determinations based on available time management
systems/data
A-13
THRESHOLDS TRIGGERING EPCRA
SECTION 313 REPORTING
Section 313 chemicals that are listed as persistent,
bioaccumulative, and toxic (PBT) are subject to separate and
lower thresholds (§372.28)
A facility meeting the SIC code (or Federal facility) and
employee criteria must file a TRI report for a non-PBT Section
313 chemical if the facility (§372.25):
• Manufactured (including imported) more than 25,000 pounds per
year, or
• Processed more than 25,000 pounds per year, or
• Otherwise used more than 10,000 pounds per year
Activity thresholds are calculated independently
Threshold calculations are based on cumulative quantities per
Section 313 chemical over the reporting year
A-14
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THRESHOLDS TRIGGERING EPCRA
SECTION 313 REPORTING
If a facility manufactures, processes, or otherwise
uses any chemicals that are listed as persistent,
bioaccumulative, and toxic (PBT), the threshold
quantity is one of the following per toxic chemical or
category per year (§372.28):
Threshold Level Type of PBT Chemical
100 pounds
10 pounds
0.1 grams
Persistent and bioaccumulative
Highly persistent and highly bioaccumulative
Dioxin and dioxin-like compounds
A-15
CATEGORIES OF MANUFACTURING
ACTIVITIES
Manufacturing (§372.3) - generating a Section 313
chemical
• Intentionally producing chemicals for:
» Sale
» Distribution
» On-sfte use or processing (e.g., intermediates)
• Coincidentally producing chemicals as impurities or
byproducts:
» At any point at the facility, including waste treatment and
fuel combustion
• Importing
» "Cause" to be imported
A-16
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CATEGORIES OF PROCESSING ACTIVITIES
Processing (§372.3) - preparation of a Section 313
chemical for distribution in commerce
• Using as a reactant to manufacture another substance or
product
• Adding as a formulation component
• Incorporating as an article component
• Repackaging for distribution
» Including quantities sent off-site for recycling
• As an impurity
A-17
REPACKAGING AS A
PROCESSING ACTIVITY
Repackaging a Section 313 chemical for distribution
in commerce is considered processing
• Repackaging includes transfer
» From container to tanker truck and visa versa
» Between similar size containers
» Via pipeline to/from a tank
• Repackaging does not include:
» Sampling without repackaging
» Re-labeling
Repackaging without distribution into commerce is
not considered processing
A-18
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OTHERWISE USE
Otherwise using (§372.3) - includes most activities
that are not manufacturing or processing
• Examples
» Chemical processing aid (e.g., solvents)
» Manufacturing aid (e.g., lubricants, refrigerants)
» Ancillary activities (e.g., chemicals used to remediate
wastes)
A-19
OTHERWISE USE (CONTINUED)
Otherwise use of a Section 313 chemical also
includes on-site disposal, stabilization (without
subsequent distribution in commerce), or treatment
for destruction if:
• Section 313 chemical was received from off-site for the
purposes of further waste management, or
• Section 313 chemical was manufactured as a result of waste
management activities on materials received from off-site
for the purpose of further waste management
Waste management activities include recycling,
combustion for energy recovery, treatment for
destruction, waste stabilization and release
(including disposal)
A-20
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CALCULATING ACTIVITY THRESHOLDS
Calculate total amount of Section 313 chemical to a
threshold activity
• Example:
» A plant uses MEK to manufacture liquid industrial
adhesive for distribution in commerce. The plant adds
27,000 pounds of MEK to the liquid adhesive-making
operation during the reporting year, but 3,000 pounds are
volatilized during the operation
» 27,000 pounds of MEK is processed, reporting required
A-21
CALCULATING ACTIVITY THRESHOLDS
Activities that, alone, do NOT constitute an activity
threshold
• Storage
• Remediation of on-srte contamination
• Re-labeling without repackaging
• Direct reuse onsite
• On-site recycling
* Transfers sent off-site for further waste management (not
including recycling)
A-22
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EPCRA SECTION 313
REPORTING EXEMPTIONS
SECTION 313 EXEMPTIONS
Designed to reduce the burden of reporting
associated with small or ancillary chemical uses
If an exemption applies, then the amount of a
Section 313 chemical subject to the exemption does
not have to be included in:
• Threshold determinations
• Release and other waste management reporting
• Supplier notification
Recognize that exemptions only apply in certain
limited circumstances
B-2
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SECTION 313 EXEMPTIONS
Types of exemptions (§372.38)
• Deminimis
• Articles
• Laboratory activities
• Otherwise use exemptions
» Motor vehicle maintenance
» Routine janitorial or facility grounds maintenance
» Structural components
• Personal use
• Intake water and air
• Mining (extraction activities and overburden)
B-3
DE MINIMIS EXEMPTION
The quantity of a non-PBT Section 313 chemical in a
mixture or other trade name product is eligible for
the exemption if the chemical is:
• Any non-PBT Section 313 chemicals present at a
concentration of less than 1% by weight (§372.38(a))
or
• An OSHA-defined non-PBT carcinogen present at a
concentration of less than 0.1% by weight
B-4
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption can apply to non-PBT
chemicals:
• In mixtures or other trade name products processed or
otherwise used
• Only two manufacturing activities:
» Coincidentally manufactured as impurities that remain in
products
» Imported in mixtures or other trade name products
B-5
DE MINIMIS EXEMPTION
How It Works
De minimis exemption does not apply to:
• Manufacturing chemicals (in most cases)
» Manufacturing chemicals as by-products
» Coincidentally manufacturing chemicals
- As by-products of waste treatment or fuel
combustion
• Section 313 chemicals listed as persistent, bioaccumulative,
and toxic (PBT) (except for supplier notification)
B-6
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DE MINIMIS EXEMPTION
How It Works
De minimis exemption does not apply to:
• Wastes and waste streams, from non-exempt sources, that
are processed or otherwise used
» Wastes received from off-site for purposes of on-site
incineration
• Releases and other waste management activities from
mixtures or other trade name products that are not
associated with a processing or otherwise use activity
» Material storage not associated with processing or
otherwise use activities
B-7
DE MINIMIS EXEMPTION
How It Works
De minimis concentration for toluene is 1.0% (not an OSHA
carcinogen)
Cleaning
Mixture
0.5% Toluene
(exempt)
Raw Material
Mixture
90% Toluene
(not exempt)
D
ACME CHEMICALS
• Toluene in cleaning mixture is below de minimis concentration
and is eligible for the exemption
B-8
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DE MINIMIS EXEMPTION
How It Works
Processing a non-PBT Section 313 chemical in a mixture to below the cfe 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%
• Oe minimis exemption does not apply
• Threshold determination required
• Release and other waste management
calculations required
Paint Products
(<1%Toluene)
Toluene <1%
• Oe minimis exemption does not apply
• Threshold determination required
• Release and other waste management
calculations still required
B-9
DE MINIMIS EXEMPTION
How It Works
Processing a non-PBT Section 313 chemical in a mixture to above the
cfe minimis concentration triggers threshold determinations and
release and other waste management calculation requirements
Crude oil
containing trace
amounts of
toluene
ffl ffl ffl ffl
BB
T\ 53
Petroleum
products
containing
concentrated
toluene
Toluene <1%
• De minimis exemption can apply
• Do not include in threshold
i:
i:
Toluene >1%
Oe minimis exemption does not apply
Threshold determination required
Do not include in release and other waste ' • Release and other waste management
management calculations I
calculations required
B-10
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ARTICLES EXEMPTION
"Article" is defined (§372.38(b)) as an item that is
already manufactured and:
• Is formed into a specific shape or design during
manufacture; and
• Has end-use functions dependent in whole or in part on its
shape or design during end-use; and
• Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility
The articles exemption does not apply to the
manufacture of articles
B-11
ARTICLES EXEMPTION
How It Works
Releases of a Section 313 chemical from an article may
negate the exemption. To maintain the article status,
total releases from all like items must be:
• In a recognizable form; or
• Recycled, directly reused; or
• 0.5 pounds or less (may be rounded down to zero)
If more than 0.5 pounds of a Section 313 chemical are
released from all like items in a non-recognizable form
and are not recycled or directly reused, none of the items
meet the articles exemption
B-12
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ARTICLES EXEMPTION
Examples
Wire is cut to specified lengths. Wastes include off-spec
cuts and dust
• Generation of off-spec cuts that are recognizable as articles
will not, by itself, negate the article status
• Dust and off-spec cuts not recognizable as articles, with
greater than 0.5 pounds of a Section 313 chemical released,
and not recycled or directly reused, negate the article status
Fluorescent light bulbs are installed containing mercury.
The used bulbs are crushed in an enclosed container
prior to recycling
• Crushing bulbs prior to disposal is not considered release
during use; exemption is not negated
B-13
ARTICLES EXEMPTION
Examples
Pipe is cut to specified lengths. Wastes include off-
spec cuts and dust
• Facility estimates that from all uses of the same type of pipe
over the reporting year, a total of 2 pounds of chromium
releases and 0.3 pounds of nickel releases occur
• Because total chromium releases are greater than 0.5
pounds over the reporting year, the articles exemption is
negated for all uses of the pipe including both the chromium
and nickel in the pipe (even though total nickel releases
were less than 0.5 pounds)
B-14
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LABORATORY ACTIVITIES EXEMPTION
Section 313 chemicals manufactured, processed, or
otherwise used in certain laboratory activities,
performed under the supervision of a technically
qualified individual, may be eligible for the
exemption (§372.38(d))
Activity must occur in a laboratory to be exempt
Laboratories, themselves, are not exempt
B-15
LABORATORY ACTIVITIES EXEMPTION
Definition of technically qualified individual (§720.3(ee))
• Capable of understanding the health and environmental
risks associated with the chemical substance which is used
under his or her supervision because of education, training,
or experience, or a combination of these factors;
• Responsible for enforcing appropriate methods of
conducting scientific experimentation, analysis, or chemical
research to minimize such risks; and
• Responsible for the safety assessments and clearances
related to the procurement, storage, use, and disposal of the
chemical substance as may be appropriate or required
within the scope of conducting a research and development
activity.
B-16
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LABORATORY ACTIVITIES EXEMPTION
How It Works
• Section 313 chemicals manufactured, processed,
or otherwise used in these laboratory activities
are eligible for the exemption
• Sampling and analysis
• Quality assurance
• Quality control
B-17
LABORATORY ACTIVITIES EXEMPTION
How It Works
• Section 313 chemicals manufactured, processed,
or otherwise used in these laboratory activities
are NOT exempt
• Any activities conducted outside laboratories
• Specialty chemical production
• Pilot-scale plant operations
• Support services
• Photo processing
• Equipment maintenance/cleaning
B-18
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MOTOR VEHICLE MAINTENANCE
EXEMPTION
Section 313 chemicals otherwise used to maintain
motor vehicles operated by the facility are eligible
for the exemption (§372.38(c)(4))
Examples of motor vehicles eligible for the
exemption include cars, trucks, airplanes, and
forklifts
Examples of exempt motor vehicle maintenance:
• Body repairs
• Parts washing and plating
• Fueling and adding other fluids (e.g., ethylene glycol)
B-19
ROUTINE JANITORIAL OR FACILITY
GROUNDS MAINTENANCE EXEMPTION
Section 313 chemicals contained in products otherwise
used for non-process related routine janitorial or facility
grounds maintenance are eligible for the exemption
(§372.38(c)(2))
• Phenol in bathroom disinfectants
• Pesticides in lawn care products
Section 313 chemicals otherwise used in process-related
activities are not exempt
• Facility equipment maintenance
Cleaning or maintenance activities that are integral to the
production process of the facility
B-20
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STRUCTURAL COMPONENT EXEMPTION
The otherwise use of Section 313 chemicals, that are
part of structural components of a facility, are
eligible for the exemption provided the structure is
not process related (§372.38(c)(1))
• Copper in pipe used in construction of employees'
bathroom facilities
• Metals, pigments, and solvents in paint applied to facility
structure
B-21
OTHER EPCRA SECTION 313 EXEMPTIONS
Section 313 chemicals contained in non-process
related items for employee personal use
(§372.38(c)(3))
• HCFC-22 in air conditioners used solely for employee
comfort
• Chlorine used to treat on-site potable water
• Phenol in a facility medical dispensary
Section 313 chemicals found in intake water (e.g.,
process water and non-contact cooling water) and
air (e.g., used as compressed air) (§372.38(c)(5))
B-22
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SIC CODE-SPECIFIC EXEMPTIONS
SIC Code 12: Coal mining extraction activities are exempt
from threshold determinations and release reporting
(§372.38(g))
• Coal extraction: the physical removal or exposure of ore,
coal, minerals, waste rock, or overburden prior to
beneficiation, and encompasses all extraction-related
activities prior to beneficiation (§372.3)
SIC Code 10: Chemicals in metal mining overburden that
are processed or otherwise used are specifically exempt
from TRI reporting (§372.38(h))
Overburden: unconsolidated material that overlies a
deposit of useful materials or ores (§372.3)
B-23
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DETE
fcMININC r THRESHOLD
TRI REPORTING PROCESS
Identify S«*on
313 chemicals
man^adured,
processed, or
othemrise used at
(he site
Determine the
quantity of Section
313 chemicals
and how
they are
manufactured,
processed, or
otherwise used
on-ste
Identify total
releases and
off-site transfers
Identify pollution
prevention
activities
Complete
Form
^=3=
C-2
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DETERMINING THRESHOLDS
• Identify what Section 313 chemicals are handled on-
site
• Identify concentrations of Section 313 chemicals
• Collect data and calculate quantities towards each
threshold
C-3
DETERMINING THRESHOLDS
Identify Chemicals and Collect Data to Calculate
Concentrations: . Thresholds:
MSDS
Specifications
Inventory Records
Throughput/Production Data
Waste Profiles Purchase Records
Process Knowledge EPCRA or Other Env. Reports
Other References (AP-42, Ask the User
Merck Index)
Call the Vendor
Supplier Notification
C-4
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SECTION 313 CHEMICALS AND CHEMICAL
CATEGORIES
• Original list developed from Maryland "High
Production Volume" and New Jersey "Right to
Know" chemical lists
• Current list contains over 600 individual chemicals
and chemical categories (See Table II of the EPA's
TRI Reporting Forms and Instructions document)
• Petition process to add or delete chemicals or forms
of chemicals (EPCRA Section 313(e))
C-5
SECTION 313 CHEMICAL QUALIFIERS
• Qualifiers - Listed chemicals with parenthetic qualifiers subject to TRI
reporting only if manufactured, processed, or otherwise used in
specified form (§372.25(g)). Below are some examples (see Table II of
EPA's TRI Reporting Forms and Instructions document):
CHEMICAL CASff QUALIFIER
Aluminum 7429-90-5 Fume or dust
Aluminum oxide 1344-28-1 Fibrous forms
Asbestos 1332-21-4 Friable forms
Isopropyl alcohol 67-63-0 Manufactured by strong acid process
Phosphorus 7723-14-0 Yellow or white
Saccharin 81-07-2 Manufacture only
Hydrochloric acid 7647-01-0 Acid aerosols
Sulfuric acid 7664-93-9 Acid aerosols
Vanadium 7440-62-2 Except when contained in alloy
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SECTION 313 CHEMICALS
Calculate threshold determinations and releases and
other waste management estimates by multiplying
the percentage of a Section 313 chemical by the total
amount of the mixture, other trade name product, or
waste
• Example: 80,000 pounds of a solvent containing benzene
was used on-stte at the facility to clean machinery. The
solvent contains 10% benzene.
» 80,000 IDS. X10% = 8,000 IDS. of benzene otherwise used
C-7
COMPOUND CATEGORIES
Count together all compounds that fall within a category,
even if different compounds within a category are used in
separate operations
• Example: If a facility processes 20,000 pounds of 2-Butoxyethanol
in one operation and 10,000 pounds of 2-{2-Butoxyethoxy)ethanol
in another operation during the reporting year
» 30,000 pounds of glycol ethers have been processed.
Reporting for glycol ethers category is required
Consider the entire weight of the compounds in the
category when determining thresholds
• Calculations for release and other waste management estimate are
different for metal and nitrate compounds
C-8
-------
SUPPLIER NOTIFICATION FOR
MIXTURES AND OTHER TRADE NAME
PRODUCTS
Supplier notification (§372.45) - requires suppliers to
facilities described in §372.22 (i.e., covered facilities)
to:
• Identify Section 313 chemical(s) by name and CAS number
• Identify Section 313 chemical(s) as being subject to Section
313 requirements
• Provide concentration (or range) of Section 313 chemicals
in mixtures and other trade name products (not wastes)
• Provide notification at least annually in writing or attached
to the MSDS
• Update notification when changes occur
• Only facilities in primary SIC codes 20-39 must initiate the
notification
C-9
DETERMINING CONCENTRATIONS OF
SECTION 313 CHEMICALS
Chemical component - include in threshold "each
listed Section 313 chemical known to be present"
(EPCRA Section 313(g)(1)(C)) at a concentration
greater than the de minimis limits
• "Known" - knowledge based on MSDS, 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 (§372.30(b)(3))
C-10
-------
DETERMINING CONCENTRATIONS IN
MIXTURES OR OTHER TRADE NAME
PRODUCTS
Include a Section 313 chemical in the threshold
determinations if you know (§372.30(b)(3)>:
• Exact concentration - use concentration provided
• Upper bound - use upper limit
• Range - use the midpoint of the range
• Lower bound - subtract out other known constituents,
create a range, and use the midpoint of range
Note: Thresholds are based on weight in pounds,
except for dioxins and dioxin-like compounds
C-11
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, you
could assume 1/2 of full detection limit
• If the Section 313 chemical is not expected to be present,
you could assume 0
C-12
-------
MEETING MULTIPLE THRESHOLDS
There are many situations where one Section 313
chemical must be counted towards multiple activity
thresholds
• Section 313 chemicals manufactured or imported on-site, then
used or incorporated into a product (processed)
• Section 313 chemicals formed during destruction of wastes
received from off-site and subsequently destroyed on-site
(manufactured and otherwise used)
• Section 313 chemicals that are otherwise used on-site, recycled,
then processed
Section 313 chemicals should not be counted twice
towards the same activity threshold
C-13
WATCH FOR DOUBLE COUNTING WITHIN
THE SAME ACTIVITY THRESHOLD!!!
• For threshold determinations, Section 313 chemicals
reused or recycled at a facility: count original
amount used only once (§372.25(e))
• Note: Section 313 chemicals sent off-site for recycling and
returned to the facility are considered new materials and
counted for threshold determinations
• For materials in use from previous years: count only the
quantity added during current reporting year
C-14
-------
MULTI-ESTABLISHMENT FACILITY
Determining how facilities report
• Multi-establishment facility (§372.30(c))
» Apply threshold determination on aggregate amount of
chemicals used at facility
» Able to file separate Form R reports for each
establishment if they are distinct economic entities (must
be designated as part of a facility on Form R)
» Report all releases and other waste management
activities of reportable Section 313 chemicals
» Avoid double-counting of chemicals involved in intra-
facility transfers
C-15
CALCULATING THRESHOLDS
Consider all activities
Consider all sources
Identify the avenues through which mixtures and
trade name products enter your facility
• Purchasing/inventory control
• Contractors
• Bulk deliveries
• Capital purchases
• "Credit card" or "emergency" purchases
• Chemicals used in neutralization, refrigerants, cleaners,
paints, lubricants (for non-vehicles), fuel (for non-vehicles),
refractory bricks
C-16
-------
ORCHESTRATING DATA COLLECTION
Methods for orchestrating data collection
• Coordinate with purchasing/vendors
• Develop inventory controls
• Require requisition or "sign out" procedure for Section 313
chemicals
• Take year-end inventories
Identify ALL chemical purchasing and usage
Threshold determination worksheets for both PBT
and non-PBT Section 313 chemicals
C-17
EXAMPLE: EFCRA Sectkw 313 Non-PBT Chemical Reporting Threshold Worksheet
Facility Nne: QMMCHEM'fAI. n.>.w.rL.k»>p».««»i-
Tone Chearical or Chemical
CueKoryr Tolmc; Prrf*rrA K*- JSP
Step 1. Identify amomits of the tone chemical maaafactared. processed, or otherwise used.
Mbtare Nvae or (Mer UeMiner
1. Joe's Deoreaser
I Ye*o»S*1etvPaM
3. Parts Washer Fluid
4.
5.
*,
7.
Subtotal:
"^ZS" k^,
Purchaskiq SO
VertJor 5
PtaUiaMn 40
TtblWefekt
«•«*)
10,000
30000
10.000
liriirr'-f-lii Hill ITrTlT n-n'-"-j 1 rTtj (!• It I )
MaaiifananJ
(A) ll«.
PllmjacJ
(» •».
OOKrwocUicd
5.000
1 500
4.000
(0 10.SOO ita.
Step 2. Id^ty ttmpt form* of to tow cbem^totttmvebtt included in Step I.
Mature Tt*mt M I jtTni Afcorc
l. Ye*few Safety paint
2.
i
4.
S-
-------
MANAGEMENT PRACTICES
Begin early
• Implement a program to gather "real-time" data on usage
• Searches for historical information can be difficult
Use a team approach
• Include all relevant personnel (e.g., engineering,
environmental, operations)
• Spread the work
C-19
RECORDKEEPING
Detailed records
• Improve reporting accuracy and data quality
• Reduce replication of effort from year to year
Well-labeled calculations and assumptions
• Serve as standard operating procedures (SOPs) for future
years
• Ensure consistency from year to year, especially if
personnel responsible for reporting change
EPA will review records during a data quality audit
C-20
-------
AUTOMATED TRI REPORTING
SYSTEM (ATRS)
Voluntary option to submit form electronically
Forms submitted on diskette and loaded directly into
EPA's TRI Database
Windows 95, 98, NT and 2000 versions available
ATRS has built-in data validation program and pick
lists
A signed ATRS - generated cover letter is the sole
paper requirement
C-21
OVERVIEW OF FORM R, PART I
Two principal types of information
• Facility-specific
• Chemical-specific
One form must be submitted to EPA and to the
SERC/TERC for each Section 313 chemical or
chemical category exceeding applicable thresholds
(§372.30(a))
C-22
-------
PARTI: FACILITY INFORMATION
Identifies the facility
Provides key data for linking information to other
databases
Identifies key personnel
C-23
PART L 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 L FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
tnyouitmmytxluKchmutiacraiBlmfagcZttlt
sttntl
D Yes (Answer question ZZ: (~~| No DonxaiiMr
i2
Is this copy O SMmd O Uns»n*i»d
(Ansver only if -YES- in 2.1)
C-24
-------
PART I. SECTION 3
An original signature is required
Name must be legible (printed or typed)
Title of the official who signs is also required
SECTIONS. CERTIFICATION (Important Read and sign after completing all form sections.)
Ihi^ certify aw (have review the attached doaments and that, to t^
submitted Mormation is me and complete and thai the amounts and values in thisrepert are accurate based on
reasonable eafrnates using data avalabte to the preparers of this report
Signature
Cute signed:
C-25
PART I. SECTION 4.1
• All parts of the facility name and address are essential
• Mailing address required if different from street address
• TRI facility identification number (if a form was filed in a
previous reporting year) or "New Facility" (if reporting for the
first time)
• All establishments at one facility should use the same TRI
facility identification number (if reporting separately)
SECTION 4. FACILITY IDENTIFICATION
4.1 1
=_!
TRtF*e»yO Number
Cfc^CowwrfStaWZiD Cod
. J
rninmrMMn-IKt
c-
26
-------
PART I. SECTION 4.1
Federal facilities
• Enter name of Federal department or agency standard
acronym followed by the site name
SECTION 4. FAOUTY IDENTIFICATION
4.1
ILS.
Cit Plant
C-27
PART I. SECTION 4.2 THROUGH 4.4
Specify whether the form covers all or part of the facility
- -Federal facilities and GOCOs also check either "c" or "d,"
but not both
List name and phone number
• Technical contact - should be able to explain data to EPA
• Public contact - should be able to represent the facility's
data to the public
SECTION 4. FAOUTT IDENTIFICATION (Continued)
4.2
4.3
4.4
Ttts report cartons information for.
i— i
b U
Panofa
i AFedaai
PubGe Contact Mvne
refe|ihoneNun
-------
PART I. SECTION 4.5 THROUGH 4.6
Enter covered 4-digit SIC code(s)
• Enter primary SIC code in first box (a.)
• Enter other covered SIC codes in decreasing order of
significance
Supply latitude and longitude coordinates
4.5
4.6
SCCode(s)(4-digits)
Latitude
M«y
a.
OegTMS
Wnuui
b.
Seconds
C.
Longitude
d.
Degrees
e.
Minus
f.
Seconds
C-29
PART I. SECTION 4.7 THROUGH 4.10
Enter the specified identification numbers or "NA" if
not applicable
• Enter Dun and Bradstreet numbers)
• EPA ID numbers (assigned to RCRA-covered facilities)
• NPDES permit numberisl
• Underground Injection Well Code (UIC) I.D. numbers)
4.7
Dun & Bradstreet
Humberts) 0 digits)
a.
b.
4.8
EPA Identification
Numbers) (RCRA
I.D. No.) (12
characters)
a.
b.
4.9
Facility NPDES
Permit Numbers)
(9 characters
a.
b.
4.10
Underground
Injection Well Code
(UIC) I.D. Humberts)
(12 digits)
a.
b.
C-30
-------
PART I. SECTION 5
Private-sector and GOCO facilities
• Enter complete name and Dun & Bradstreet number of parent
company
Federal facilities
• Enter the complete name of department or agency for parent
company (e.g., U.S. Department of Interior)
• Check "NA" for Dun & Bradstreet number of parent company
SECTIONS. PARENT COMPANY MFORMATON
5.1
QI rtnft Connpwiy
PMM Catfmft Dun 1 BradsMM Nutter
DMA (
C-31
PARTH: CBDEMICAL-SPECIFIC
INFORMATION
Identifies
• Section 313 chemical and its uses at the facility
• Quantities released or otherwise managed as wastes
• Waste management and source reduction activities
• Maximum quantity of the Section 313 chemical on site at
one time
C-32
-------
PART II. SECTIONS 1 AND 2: TOXIC
CHEMICAL OR MIXTURE IDENTITY
Complete either Sections 1.1 & 1.2 or Section 1.3 or Section 2
Enter CAS number or category code and name of Section 313
chemical or chemical category (except on "sanitized" form)
Enter generic name only if claiming Section 313 chemical name
as a trade secret (Section 1.3)
SECTION 1. TOXIC CHEMICAL IDENTITY
1.1
1.2
ToiChB»ialorar-alC«gByltaK(tafnrt« E«ori»m ran* Martyrs it a««»n on t*SK»on 313 itt)
CenericCI«..mJII»Ktartirt: Co***erirlP.itISeaa
-------
PART H. SECTION 3 OF THE FORM R:
ACTIVITIES AND USES OF THE CHEMICAL AT
THE FACILITY
• Specify use(s) of the Section 313 chemical: manufacture,
process, or otherwise use
• Report only activities taking place at reporting facility
• Check ah applicable boxes
SECTION S. ACTIVITIES AND USES OF THE TOXIC CHEMCAL AT THE FACILITY
3.1|
Produce.bQ
C. Q For on-siu usafenassing
d. Q ForuWdBHuion
e. D Asab^mdua
f. Q As«iini|u*y
a.
a. CD AsiraiOan
(V. Q] As.famUaboncotTxxn
CP I 1 ftS Ml IfliflB M
-------
EXERCISE #1
IDENTIFYING EPCRA SECTION 313 CHEMICALS
Purpose:
Familiarize participants with the chemical lists in Table 2 of EPA's TRI
Forms and Instructions document.
Ability to identify correctly Section 313 chemicals from MSDSs.
Take-Aways:
Understanding of nuances of chemical compositions.
Materials:
TRI Reporting Forms and Instructions document
Material Safety Data Sheets (MSDSs)
Instructions:
Attached is a package of chemicals, chemical compounds, and chemical
mixtures present at your facility. Determine if any of these chemicals or
parts of these chemicals is on the EPCRA Section 313 list. If you
determine that a chemical or component of a product or mixture is on the
list present at or above the appropriate de minimis level, prepare a list of
the appropriate Section 313 chemicals and CAS numbers.
-------
IDENTIFYING EPCRA SECTION 313 CHEMICALS
MSDS Name
Section 313 Chemical(s) Name
Concentration
Notes
-------
MEAOOWBROaiC COMPANY
3PELTEH. WEST VIRB1MIA 26433
RAW MATERIAL SUPPLIER DATA SHEET
I. TRADE NAME CRUDE ZINC OXIDE
CHEMICAL HAKE ZINC CXHJE JEPA/CAS 1J2A-U-2
MANUFACTURER MEADOHBROOK COMPANY
017 OF T. L. DIAMOND & CO., INC.
SPECIFICATIONS GRADE A CRAPE B
50-591 60X-68Z
1-31 1-3*
.8-3,51 .3-3.5X
0.1-0.5 Avg. 0.2 0.1-0.5 Avg.0.22
0.0-0.31 0.0-0.3Z
Than .01 L««« Ib«a .01 .
Cu 0.04-0.40 ' 0.04-O.40
LI. MON TOXIC SOLID MATERIAL WITH A PARTICLE SIZE RANGE
UP TO 1/4 INCH.
:il. SPECIFIC GRAVITY 5.5.
APPAREtrr DENSITY 130-160 LBS/CU FOOT
HON SOLUABLE IN WATER NOR VOLATILE
LIGHT GRAY, ODORLESS COARSE POWDER
IV. NO FIRE OR EXPLOSION HAZARD. CAM REACT WITH MAGNESIUM
OR CARBON WHEN HEATED.
V. NO PARTICULAR HEALTH HAZARD, TLV (S) FOR PRINCIPLE
INGREDIENT
PEL 2 Hs/M« FOR ZINC OXIDE FUME
VI. TON REACTIVE AT AHBZEST EXCEPT WITH MXHESAL ACIDS
II. SPILL OR LEAK PROCEDURES
CLun up & return to lAbttied contiiriera
I. PE1SOKAL PROTECTION
Nlosh respirator sugxescad for comfort when nacerlal
i* dry & duscy
HANDLERS SHOULD WEAR CLOVES AND SAFETY COCCLES.
-------
3M G«n«rai Offices
3M Center
St Paul. Minnesota 55144.1000
S12/733-1110
12743
MATERIAL SAFETY
DATA SHEET
MIMERAL DIVISION
3M BRAND ROOFING GRANULES CWAUSAU. WI)
311 t.O. NUMBER:
9J-OU1-1290-5
98-0111-1311-0
9B-0111-1322-*
98-0111-1348-1
91-0111-1447-1
91-0111-1451-3
91-0111-1457-0
XSSVCBs SEPTEMBER 13. 1994
SUPERSEDES: NOVEMBER 23, 1993
DOCUJUDfTs 10-0170-0
!»-««f-l|17-8 91-OU1-121S-* 91-0111-
98-0111-1221-0 9S-0111-1222-8 91-0111-
9«-0 HI- 1253-5 91-0111-1278-0 98-0111-
98-0111-1292-1 91-0111-1293-9 98-0111-
98-0111-1319-2 98-0111-132D-0 98-0111-
98-0111-1323-4 98-0111-1324-2 98-0111-
98-0111-1444-8 91-0111-14*5-5 98-0111-
98-0111-1441-9 91-0111-1449-7 91-0111-
98-0111-1452-1 98-0111-1453-9 91-0111-
98-0111-1414-4 98-0111-1418-5
1225-4
1281-9
1294-7
1321-8
1325-9
1450-5
1454-7
rf.A.S.
PLAOIOCLASE FELDSPAR Nc.._.
QUARTZ 14808-60-7 •
POTASSIUM FELDSPAR None /
SODIUM SILICATE 1344-09-8'
KAOLIN 1332-58-7'/
CARBON BLACK 1333-86-4"}
CHROMIUM OXIDE CTRIVALENT CHROMIUM) . . 1308-38-9 '
HYDROTREATED HEAVY NAPHTHENIC
PETROLEUM DISTILLATES 64742-52-5'
RUTILE TITANIUM DIOXIDE ,«<. 1317-80-2-
IRON OXIDE (FE203) 1309-37-1^
ZINC FERRITE 12063-19-3
30.0
25
20
35.0
35
25
5.0
5.0
0.
0.
0.
0.
0.
0.
NOTT: THE AMOUNT OF OUST GENERATED WHILE HANOLINB THESE ROOFIN9 GRANULES IS
EXPECTED TO VARY OEPENDXNS OK THE USER'S OPERATION. THE LEVEL OP
RESPIRABLE CRYSTALLINE SILICA IS EXPECTED TO BE LESS THAN 15Z OP THE
RESPIRABLE DUST.
THZS PRODUCT COXXAIKS THE FOLUKXN8 TOXZC
OR
CCALS SUBJECT 70 THI RCPORTX
RTQUIRDIEHTS OP SKZXOI 313 OT TXTUE IZZ Or THE EHEROENCT PUUtHZHB AMDCOaHTOin RIGHT-
ACT OF 19M AND «• OK PART 372s
CHROMIUM OXIDE (TRIVALENT CHROMIUM)
ZINC FERRITE
£. PHYSICAL DATA
80XLZR8 POZKTs
VAPOR PRESSURE!......
YAPOK DEUZTTs ......
ETAPORATZOI RATEs....
3CLU8ILITT la HATBs
SP. CRAYITT:.........
PtKCCNT YOLATZLEs ...
YQ&ATZLE OROANZCSs .,
H/A
N/A
N/A
N/A
N/A
2.6-2.7
N/A
N/A
Abbreviation* s N/D - Net Oetemined N/A - Not Aaoiicable
-------
:: 2*92
USE
3M General Offices
3.M Center
SL Paut. Minnesota :=!44-'
-------
07-08
3M General Offices 12745
3M Center
SL Paut. Minnesota 5514&.1CCC
S12/T33-J:iO CT 2192 -r
MATERIAL SAFETY
DATA SHEET
nS03; 3H BRAND ROOFZH8 GRAJTOLZS CWAOSAU, WI3
•" 13, 1994 PASEx 3 o-f
CXZ CONTACT:
laawdiately flush eyea with large aawunts of w«t«r. G«t
aadical attantion.
SXZX COXTACT:
Ho n««e for first aid is antieisatad in th« avant of skin contact.
XnULATZOHs
If saonsysyavtess occur, raaova oarsan to frash air. If
signs/syweten eantinu*, call a ohyaician.
IT SVALLOffCBs
Drink twa glassas of water. Call a physician.
EZZ FROTECTXOHt
Avoid eye contact. The following should be worn alone or in
combination, as appropriate, ta prevent eye contact: Wear safety
glasses with side shields.
SXZB
Avoid prolonged or rooeatad skin contact..
VENX1LAXICM PKOTZCTZOMx
If exnausrc vanrilation is not available, use aaarooriata rosairatory
0retee«xan.
Avoid braathing of dust. Select one of the following NIOSH approved
respirators- based on airborne concentration of contaadnants and in
ice- with OSHA regulationsi hal-r-wask dust respirator.
OF ACCZOEBTAL XNUBSXlOtfs
Wash hands after handling and before eating.
BBBvOa^BMaaamaaiaBiaBf ea^L^Da!eai«i6aC2
Hat applicable.
AND C3VLOSXON ATOXOANCCs
Nat applicable.
EXFOSURZ
; TuanniPTM VAtng tmir rm AOT| SKIH«
PLA8IOCLASE FEUSPAK NONE NONE NONE NOME
QUARTZ 0.1 no/PS TWA ACSZH
as Quartz reap, dust
- Nat Applicable
-------
3M General Offices
:.M Center
SL Paut. Minnesota 55144.:COO
512/733-1^0
07-08
127*6
MATERIAL SAFETY
DATA SHEET
».
SEPTSlBOl 13,
GRANULES CWAUSAU,
PAGE: 4 of 5
rnmmr-ru** BD70STOI LXRXTS
POTASSIUM FELDSPAR
SODIUM SILICATE .
KAOLIN
KAOLIN
CARBON BLACK '.'.'.'.'.'.'.'.'.'
CARION BLACK
CHROMIUM OXIDE CTRIVALENT CHROMIUM) . .
CHROMIUM OXIDE CTRIVALENT CHROMIUM) ..
HYDROTREATED HEAVY NAPHTHEHIC
PETROLEUM DISTILLATES
HYDROTREATEO HEAVY NAPHTHEHIC
PETROLEUM DISTILLATES
RUTILE TITANIUM DIOXIDE
WTILE TITANIUM DIOXIDE
IRON OXIDE CFE20S)
IRON OXIDE CFE2033
IRON OXIDE CFE203)
ZINC FERRITE
12
*AU*r — SHU
o.i mg/mi
9m auartr reao.
NONE NOME
NONE NONE
2ffttv/t»3
rosoirable dust.
1 0 ma/a?
SS ' mm/m\
35 mm/m&
0.5 RQ/a3.
as Cr
O.S ng/wS
as Cr
5 mg/a5
10 mg/mS
10 mv/aJ
Iff nv/aS
1 0 no/sS
as ftia*
NONE NONE*
f»A OSHA
dust
NOME MOUC
unuc MRUB
fiunc nunc
TUA APr>TU
TUA ncuA
1 •"* UdHA
mAf-JSTM
TWA OSHA-
TWA ACSIH
TWA OSHA
TWA CMR8
STEL CMRS
m ACSIH
TWA QSHA
TWA ACSIH
TWA OSHA
TWA ACSIH
NONE NONE
* SXXX NOTATION* Lasted substances indicated with "Y* under SKIN refer to
the ootential contribution te the overall exposure by the cuteneeus route
including mucous aeatorana and eyo> either by eirborne or, more particulariy
by direct contact with the- substance. Vehicles can altar skin absorption.
sooxcc or EXPOSCW LZRZT DATAI
• ACQIHt Aewrican Conference of Governaental Industriel Hysienists
______ ____________ ..
Oeeuaational Safety and Health Administration
* CMRSt Chaaacal Manufacture geeoiaeeiiiJad Quidelines
- NOME: Nona Established
8. HEALTH HAZARD PATA
CZ2 C8HTACT:
May cauaa eye irritation if dust gets into eyas.
SKXH CONTACT:
No adverse health effects are •xsacted frost skin contact.
ZKKALATXONs
Single overexoosure . above recommnded guidelines, aey cause:
Abbreviations t N/D - Hot Determined N/A - Not Applicable
-------
3M General Offices 12767
3U Center
SL PwL Minnesota 55144.1000
612/733-1 1 10
CT
MATERIAL SAFETY
DATA SHEET
rtSOS; 3H Bum ROOTIHB GRANULES CWAUSAU, WZJ
SEFTEHBE* 13, 1ft» PAQE: 5 of 5
Irritation (ueear resairatary) i signs/ayavtoas can ineluda
of the nose and throat* coughing and sneezing.
Prolonged er r«0aatad ev«r«zBe«ur«, abava raeoaaandad guidalinaa*
nay eauaat
Silieeaiat *ian«/ay«etemi can ineluda snartnaaa o+ braath and
parslaxanx eauonina.
Pnatoweanieaia (ganaral}: signa/ayaotoaa can ineluda oaraxatant
cauonina «nd shartnaax vf braath.
zr swusnot
-Inoaataen is not a likaly routa of •xaoatira to this product.
QUARTZ SILICA U4f08-«0-7) is a potential canear hazard causino lung
tuaors by tna inhalation and intratraehaal routas of osaoauro in
laboratory eniaal studiaaCNTF antieioatad huaan carcinogen. I ARC
probable huaan careinogan ZA, Calif. Prooaaition 65).
SECTION CHANCE DATES
HEAD1HO SKrZOH CHAHBO SZXCE NOVEMBER 23, 1993 ISSUE
ZR6UOZCHZS &1CII8M CHAKOTO SZRCS NOVEMBER 23. 1993 ISSUE
EHTIROH. DATA' SCCIZOH CHANGED SIKCE NOVEMBER 23. 1993 ISSUE
PJttCAUT. IHTO. - SieZZOll CHAHBED SIHCE NOVEMBER 23. 1993 ISSUE
HEALTH HAZB. DATA SXC7ZOH CHAHOEO SIHCE NOVEMBER 23. 1995 ISSUE
Abbraviatienas H/D - Mot Determined N/A • Hat Aealicabla
The xnrorBataon on tni« Data Shoot rvoreaonTS our current eaxa ana beax
oainion ea to the ereoar uaa in haneling o* this aatarial unoar normal
cenditiena. Any usa o-f *ha naxoraal which is no-t in conforaanca with thia
" " ' ' • - -*—• ——— --» -- <•—•*«»*ian with eny
-------
MATERIAL SAFETY DATA SHEET
-Seated \\r Corporation
EMERGENCY TELEPHONE NO:
I-A
Page i of 6
Issued 4/97
(203) 791-3500 M-F 8:30-5:00 ET
CHEMTREC 1-800-424-9300 (for Chemicai Emergency*
spill. leak, fire exposure or accident. 24 hours)
| SECTION 1-CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
Product Name:
Chemical Name:
Trade Name:
Chemicai Family:
Chemical Formula:
INSTAPAK • COMPONENT "A"
Porymetnylene Poiypfaenyiisocyanate
Polymeric MO!
Aromatic Isocvanates
N.A.
SECTION 2 - COMPOSITION / INFORMATION ON
Harardous ingredient?!
Polymeric Oiphenyimethane
Diisocyanate( "polymeric" MOI)
Contains:
4,4'-Diphenylmethane diisocyanate
(4.4--MDI; CAS 1 0 1-68-8: s 45%)
Other MDI isomers and oligomers
CAS Ntv
9016-87-9
INGREDIENTS
Wt.% QSHA.PPT
100 N.E,
0.02 ppm
(Ceiling)
N.E.
i
ACCTH-TTV
N.E.
0.005 ppm
(TWA)
N.E.
SECTION 3 - HAZARDOUS IDENTIFICATION
EMERGENCY OVERVIEW
Health Hazards: Irritating to eyes, respiratory system and skin. Inhalation at leveis 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 Hazard^ 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.
•• (. • NOT tSTASUSMCO' MA . «»OT A*n.lCMtC At
-------
• ,.
Seated Atr Corporation Iss- rt 4/97
79 inw—*« *«a> i*.-**» C* tM'O 203179* 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 breaming is labored, oxygen should be administered b>
qualified personnel. Apply artificial respiration if breathing has ceased or shows signs or* failing.
Asthmatic- like symptoms, if manifested, may develop immediately, or be delayed for up to several hours.
Skin igntaer 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.
Eve Contact: Flush with copious amounts of water for at least 1 5 minutes, holding lids open with fingers.
If irritation persists, repeat flushing. Refer individual to a physician for immediate follow-up.
- Do NOT induce vomiting. Provided the patient is conscious, wash out mouth with water then
iive 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
Peinr 390* F (199» Q [Pensky-Martens Closed Cupj
Flammable Limits t lowen: Not available
Flammable Limits ( tiapertt Not available
Extinguishing Media: Carbon dioxide (CO?) . dry chemical, or chemical foam. If water is used, large
quantities are required. Contain run-off water with temporary barriers.
Fire sna Emtnw'on Hararrfy 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.
Fire Fffitiny Procedures- Firefighters must wear self-contained breathing apparatus to protect
against toxic and irritating vapors; full protective clothing should also be worn.
MPPA Hazard r
-------
eo§
Seated Air Corporaiion
•3 OB
[SECTION 6 - ACCIDENTAL RELEASE MEASURES (continued)
Contain and cover spill with loose absorbent (earth, sand, sawdust or other absorbent material), or
absorbent pillows, pads or socks. Collect absorbed material in open containers or plastic bags, and treat
with deactivating solution (90% water. 8% concentrated ammonia. 2% detergent). Allow to stand
uncovered for 48-72 hours to permit carbon dioxide to escape and solidification to occur. Wash spill area
with deactivating solution and let stand for 15 minutes or longer. Dispose of spilled material properly.
SECTION 7 . HANDLING AND STORAGE
1 Min. 50* F (10- Q Max. 100* F (38» C)
Average gfrgif Life: 6 months
i ggnsitivitv! Reacts with moisture to produce carbon dioxide gas.
n*
to he Taken in RanrHin^ and Storage; Do not store drums uncovered outdoors. Do not resesi
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
OSHA-PEL: 4.4t-0iphenyiraethanediisocyanate: Ceiling - 0.02 ppra
ACGIH-TLV: 4,4t-OiphenylmethanediisocyanaiB; TWA -0.005 pom
Coder Health 3
Flammafailiry 1
Reactivity I
PPE B (Personal Protective Equipment)
^rvr^prv PrmgerioTr Due to the low vapor pressure of this material, die 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 eauipped for organic vapors are generally not recommended for use with isocyanates. They
can be used for short terra emergency situations at concentrations below the PEL where the presence or
adequate breathing oxygen can be assured. Where concentrations exceed the PEL. air supplied respirators
must be used.
Fv» Pmygerionr Goggles or safety glasses with side shields.
Chemical resistant butyl rubber, nitrite rubber, neoprene, or other suitable protective
gloves.
V^srion: Use local exhaust ventilation if necessary to maintain levels betew the PEL. For guidance en
engineering controls refer to the ACGIH publication -Industrial Ventilation .
Other: ^vewash station, saferv shower and deactivating solution should be available. Refer to the
^mn^aati^n^orthe Sa^e Use and Handling of Instaoak' Foam-m-Place Chemicals" bulleun oetore
hanoiinz Instaoak' chemicals.
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I-A
Seated Air Corporation Page 4 of 6
r i i- i u~ Issued 4/97
c.*. cum»» errata
j SECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES
Form; Liquid BoiHny Poimr 406* F (208* C)
Color- Dark brown _ Vaaor Pre«tifg < ICT* mm Hg <§ 25* C (for Polymeric MDP.
Odor? Slightly aromatic (musty) ~ * Sneeme Gravity? 1.24@25*C
Vapor Density { Atr » t Y 8.5 Bntlr Demirv lfl.3 Ibs/gti
Moteeohr Weiyfrr AppTOX. 350 % Volatile bv Volume; Nil
Pemc N. E. Solubility m Water? Not soluble. Reacts slowly with water
•totibemeCOjsn.
SECTION 10 - STABILITY AND REACTIVITY
Stability: Stable under normal conditions. Avoid temperatures above II 0* F (43* C) or betew 40* F (4* C).
Potymgrnation; May occur ax elevated temperatures in the presence of moisture, alkalies, ternary amines and
metal compounds.
Condition* to Avoid; <"'rt!ffHT *""** m«t«tmii *jfit ntt»»^mn^f^\^ <**Hl frf^nm IfflV* HyfJTPgfn.
tnefMTOaribte Mmrn\r WMBT. amine*. man^ bases and aigahak. T6« reaction With WttBT IS slow at
temperatures less than 1 20*F (49^ but is acceierated at higher temperatures.
Pmduea; Highly unlikcry under nofPttl UKJmi ui usfc Exposure to fire or extreme
heat may generate oxides of carbon, oxides of nitrogen, and traces of hydrogen cyanide.
{ SECTION II - TOXICOLOGICAL INFORMATION
Potvmen'e MPTr
LO^Oni: >!5JOOmg/kg(rat)
LD^ Dermal: >5000 mg/kg (rabbit)
LC^, Inhalation: 370 - 490 mg/mV4 hours (rat) for an aerosol of polymeric MDI
•
Primary Rontefrt of &iit»urer 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
ares.
Inhalarion; Thh pmdnet « a r«pifgmiy irrrnnr and pmeimai regptramry «gii«iriye* Inhalation ofvapor Of
aerosol at levels above the occupational exposure limit can cause respiratory sensinzation. Symptoms may
include uiiudoa to the eyes, nose, throat, and lungs, possibly combined with dryness of the throat, tightness o f
chest and diflfcniry m breaming. The onset of respiratory symptoms may be delayed for several hours after
exposure. A hypeMetctive response to even minunai concentrations of MDI may develop in sensitized penon:
Sensitized petsomshouM be renioved from any funher exposure. Persons widiasrfima-cype conditions or other
chronic respiratory diseases should be excluded from woritingwidtMDI. In a single evaluation of 5 men
occupationaily exposed to MDI and hydrocarbon solvent vapors under conditions where adequate ventilation or
other safety precautions were noj used, nearopsychoiogic findings were attributed to MDI.
May f JIPT* irritation or rash. (Tan **ni5y skin dtsrol^rnrion • Pi*fff*iiTfiJ and/or prolonged contact
may result in skin sensttization. There is limited evidence from laboratory tests that skin contact may piayar~
in respiratory sensinzation. This data reinforces the need to prevent direct skin contact and the importance o\
-------
-Sealed Air Corpora turn pa?e -
Issued 4/9 /
T :uto ;
•SECTION 11 - TOXICOLOGICAL INFORMATION (continued)
Eve Camaer Liquid can cause eye irritation, tearing, reddening and swelling. Permanent cpmeai injury is
unlikely. Exposure to MO! vapors in excess of 0.02'ppm may cause irritation.
IngKTlQP.: Ingestion is unlikely. Based on the acute oral LD», this product is considered practically non-toxic by
mgestion. Ingestion can cause irritation and corrosive action in the mouth, stomach and digestive tract.
Chrome gffeets- 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 0.0.2.1. or 6 mg/rrr
(which corresponds to MDI levels equal to the OSHA-PEL. 5 times the OSHA-FHL and 30 times the OSHA-
PEL). No adverse effects were observed at 0.2 mg/ma concentrations. At the t mg/ma concentration, minimal
nasal and lung irritant effects were seen. Only at the top concentration (6 mg/ma) was mere an increased
incidence of benign tumor of the lung^adenomaj and one malignant tumor (adenocarcinoma). Overall, the
tumor incidence, both benign and malignant and the number of animals whit 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 iung. In the absence of prolonged exposure to high concentrations
leading to chronic irritation and iung damage, it is highly unlikely that tumor formation wtil occur.
Lareinotfenieiry The ingredients of this product (>0.1%) are not classified as carcinogenic by ACGIH or I ARC.
not regulated as carcinogens by OSHA and not listed as carcinogens by NTP.
Mutayenieitv There is no substantial evidence of mutagenic potential.
Renreduetive Effects; No adverse reproductive effects are anticipated.
TeratQgenieitv and Fetetoxieiry- No birth defects were seen in two independent animal (rat) studies.
Fetotoxtcity 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, respirabie concentrations weii in
excess of the defined occupational exposure limits.
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- (mmiscibie with water, but will react with water to produce carbon dioxide, and
men and non-biodegradable solids.
Aotiatie Toxieitv:
LC*; > 1000 my 1 (Zebra tlsh) At the highest level of 1000 mg/i, there were no deaths.
EC* (24 hour): > 1000 mg/1 (Daphnea magna)
EC*. >lOOmg/i(E.Coii)
JSECTION 13 - DISPOSAL CONSIDERATIONS
Incinerate or dispose of in accordance with existing federal, state and local environmental control regui*
This material is not a hazardous waste under RCRA 40 CFR 261 when disposed of in its purchased for
quantities should be treated with deacuvatton solution outlined in Section 6. Refer to the "Recommr
she Safe Use and Handling of Instaoax" Foam-m-P!ace Chemicals" bulletin for additional informal-
concerning disposal of wastes and empty containers. Chemical waste, regardless of quantity, shor
pourea into drains, sewer: or waterways.
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»••. I-A
Seated Mr Corporation Page 6 of 6
.—" ... Issued 4/97
i SECTION 14 . TRANSPORT INFORMATION
POT Containers less than 5.000 pounds are not regulated.
tfrfO: Not regulated.
UTA/TCAO C!a«- Not regulated.
ggponafaig Quantity (HOY. 5.000 Ibs. for Methyiene dipfaenyi diisocyanaie (MDIX CAS #101-614 (* 45% of
product).
SECTION 15 - REGULATORY INFORMATION
OSHA *tan«- This product is considered hazardous under the Federal OSHA Hazard Communication Standard
:9CFR!9i0.i:OQ.
u. All ingredients are listed or are not required to be listed.
SARA *0* FrtreinejY HBTiinfflin ^"t^***ieeg None
5AR A * •' ••* I ? tJayarrf Categories- Immediate (acute) Health Hazard
Delayed (chronic) Health Hazard
Reactive Hazard
5ARA ?i* Listed tngredjjgnts; This product contains the following chemicals subject to the reporting
requirements: ! 00% Oiisocyanate compounds (Category Code N120).
RCRA gratis: Discarded product is not a hazardous waste under RCRA. 40 CFR 261, when disposed of in its
purchased rarm.
; SECTION 16 - OTHER INFORMATION
The following states have regulations that apply to the use of this product.
MA Massachusetts Hazardous Substance List NJ New Jersey Hazardous Substance List
PA Pennsylvania Hazardous Substance List
The-appropnate state agency should be contacted for further details on regulatory requirements for the substance:
shown oeiow.
CAS No Wt.%
Methyiene faisphenyitsocyanate(MOl) 101-68-8 45
(Benzene. i.r-raetfayienebis(4-] isocyanato-)
Secnoms) Revised: Format change Primed on recycled paper (50% secondary material.
mmnnum 10% post consumer) using vegetable based :nlu
M-3
-------
9SK
Material Safety Data Sheet EPS TOM>TIW>
Section]
TRADE NAM!"
Product I dentificafiarr
ptooucrnrpf
COOEIOBtt.
DOT SHIPPING NAME
Section 2
Ho2nrdaus: Ingredients-
rterpholin*
110-91-9
•
10S-91-5
100-37-6
C 25 TUA: 20 pp« <«kin>
< 30 TUA: 10 pp» (skis)
C 40 TUA: 10 pp« (skin)
X HA 1719
Section 3
Physical Data
p«l« gcllou liatiid
Section 4
f-ire Sc Explosion Hi
Data
RASH POINT (»ME1>fOOU$CO)
135 F TtC
towet
10
no
SKOAL FIIE ncmnie pt
Firefighter* should uetr full protective geir including self cnrUined
UNUStUlFtKEANOaPIOSiONHAZAtO:
Nme kvoua
Sections
Reactivity Data
«?tthli
INCOMmnSUTT fM
Stresg *oidc. oiidiziag tgnts
HAiUlOOUS DECOMPOSITION PttOOUOS
Qisd»s of earbOB £ nitroge*
HAZARDOUS POCTMEKIZA11ON
CONDITIONS TO AVOID
GRACE Dearborn
Dwnfcom ONfaten W R. Gtoee 4 Cc. - Cow.. 200 Gerwee SJTW. lake Zurich. IL 60047 {70S) 438-1800
-------
Section 6
HeoitfrH'
".1 nf omrcxiiorr
Exposure level sot established for product. See Seetio* 2 for coepeaest
i»«orMtio». Exposure-Ma ooeur through sfcis absorptioa.
EFFECTS OFOVEKBVOSUtb
IKHALATXOH: Isbalatios of «ist sag irritate respirators passages.
IHGCSTION: Harsful if sualloued.
SKIM CONTACT: Prolosoed or frequeat skis eostact uill cause irritation
asd say eause cheeicai burss. Possible sfcis sessitizer.
rntrr&rT-
ZMMLATXOH: ItMev* «^f«etad parson ta fFcsfa air aitf trvat
tWSESntJH: If eotscious, §iv* inter ta dilute aad coatiet plijsiciaa
SKIN CONTACT: Uasb with soap i uater. Reseve eostas^sated clothing asd
tush before reuse.
EYE COHTACT: Flush uitb uater for IS •isvtes ae« sec* eedical attestios.
Section?
Soeciai Prctectian Jntarmatian
U5f RtfOXTPtOIEwlUN (SrKIrT TTFQ
Jig
EYE
sleeve uork shirt ae4 p«ats*
Sections
STEPS TO tMCE?
Spill or Leak Procedures
Extisouisb all flaee* is tfce vioisitg. ttsar protective elethiso isoiudiso
chesical resistast overshoes. Dike spill as* soak up os as isert absorbest
•aterial. Flush area of spill «lth uater.
W*SJE OtSPOSUMETNOO
Dispose of in aeeordasc* with feseral* stat» a«tf local reevlatiess.
This product is sot foreulstctf irith coeoicals subject to the repertisf
requirewsts of Seetios 313 of the Eoergeseg Plassiag *sd Coeeusitg
Right-to-KMu Act of 1986 asd of 40 CFR 372T
Product is eessitferetf as EPA igsitabl» Aasartfous uasto* 0001 (40 CFR 261J
Product does sot cwrtais ivgrvdieats uitb CESCLA resortak4» qoastities.
Section 9
Special Precnulians
PRECAUTIONS TO SCUKB4 M HANOUN6ANOS1OM6C
Store eestaiiers closed asd aua$ fro* e
teooeratores.
OmERPKECAUnONS
IHOUSTRtAL USE ONLY. KEEP OUT OF REACH OF OOL0REH.
MEMKEOtT: R. Ruthe
DATE: 1/24/92
Dearborn
OMdan W ?. Grace & Cs. - Com.. 300 Gcnaee isw*. UAe Zuriek II60047 (7081 438.1800
-------
ONYOK INDUSTRIES, INC.
P.O. Box 26447
Tope, AZ 85225
Phone: 200-255-3423
602-255-2402
Date: May i, 1990
MATERIAL SAFETY DATA SHEET
TTtTxzTTXTTrrzrzxrxxxzzTxxTzxxxxxxxxxxxxxx cr
1 - PRODUCT IDENTIFICATION
Product Naae: AL-5(R) DE-ICING FLUID
General/Generic ID: Clyccl-Alcohoi Solution
ITTTXXTXTrXSTTXXXXXXXXXXXZTXXXZXXXXXXXXXZX C£CTIOM II - HA2ARDCUS INGREDIENTS
INGREDIENT
Ethylene Glycsi*
Isaprspyl
XXXXI CXXXX
CASMC
107-21-1
67-63-0
CftSNttE
1,2-Ethaaediol
2-Prcpanol
V.'ol PEL
25 50pps
<10 400 ppa
TLV (WITS)
SOppa
ceiling vapcr
400 pps
'Subject to reporting re^Jireaents of Section 313 of SARA Title III
IITXXTXXTXIXXXTXXXXrTXTTXTTTTXTXTXXXrXXXTZXXTX
PROPERTY
Initial Soiling Point
Specific Gravity (H2Csi)
Vapor Density
Percent Volstiles
By voluae
Appearance and Odor
Vapor Pressure
SoluMlity in Vater % by vt.
Evaporation Rate
SECTION III - PHYSICAL DATA
REFINEJtMT
rCTTXTTZI
XXXXXIXXXXXXIXXXIXXXXTtXT
Product
Heavier Than Air
Ingredients with initial
Boiling points below 425 deg F
Product
Butyl Acetate = 1
MEASUREMENT
256 deg F (124 Jfeg C) 6760 as Hj
1.095 I 68 deg F (20 dea C)
2.5 (Air«l)
10K
Colorless liquid, faint alcohol odor
9.4 «a Hg e 63 deg F (20 deg C)
100*
>1.00
(R) Registered Trademark of Canyon Industries, Inc.
Page 1 of 3
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SECTION iv - FIRE AND EXPLOSION DATA
Flashpoint: 138tiesF (Pensky-flartens, ASTtt93)
Flaaaable Halts
* in Air, * by Voluae: Coaponent (lowest) Lower: 2.0 Upper: 12.7
Extinguishing Media: Water, Fog or Garten Dioxide or Dry CJiesical
Special Fire Fighting
Procedures: Do not spray fires directly. A solid streaa of water cirectes into net, turn in; liquid can
cause frothing. Use self-contained breathing apparatus and protective clotrur.;.
Unusual Fire and
Explosion Hazards: None
NFPA Haiard Rating: Health: 1 Fire: 2 Reactivity: 0
TTTr«T*x*«*»»ifii*ift*»ii»i*»**i»**iiifm** SECTION V •"HEALTH KA2ARD DATA wi**"*"*****"""**"*1*"**"1.™*"
Peraissible Exposure Level (PEL): SO ppa
Ttvesnald Licit Value (TLV): JQ ppa
EFFECTS Of OVEREXPOSURSFOR PRODUCT:
Eyes: Can cause irritation, redness, tearing.
Skin: Can cause irritation. Prolonged or repeated contact can cause irritation, defatting,
deraatitis.
Breathing: Excessive inhalation of vapors can cause nasal and respiratory irritation.
Swallowing: May canst abdoainal discomfort and pain, dizziness, talaise, lua&ar pain, ollguria, ureaia,
and central nervous systei depression. Severe kidney daaage accaotpanies cross cverexposure.
Chronic effects
of Ova-exposure: Inhalation of aists aay produce signs of central nervous systei effects, particularly
dizziness and nystagmus.
Other Health
Hazards: None currently know.
EMERGENCY AND FIRST AID PROCEDURES:
If swallowed: If conscious, give two glasses of water, induce vomiting ay sticking finger down throat. Call 2
physician mediately. Never give anything by mouth to an unconscious person.
If on skin: Remove contaminated clothing and thoroughly wash exposed area with soap and water. Launder
contaminated clothing before reuse.
If in eyes: Flush with large aaounts of water, lifting upper and lower lids occasionally. Get oedical attention.
If inhaled: If affected, rewve individual to fresh air. If breathing is difficult, adainister oxygen. If
breathing has stopped, give artificial respiration. Keep person wara, quiet, and get aedical
attention.
1 SECTION VI - REACTIVITY DATA «*W»»WT*TT«T««TTTIT»«T«»TTW««««I«TT
HAZARDOUS PXYltSJ2ATI»: Mil not occur Conditions to Avoid: None
STABILITY: Stable Conditions to Avoid: Heat, sparks, and open flases
IMCWAHEILm: strong oxidizing agents (e.g. nitric and suit uric acids, peraanganates, etc.)
HAZARDOUS COSSnON OR
Burning aay produce toxic cat trials: Carbon dioxide and/or carbon •onoxide, etc.
Page 2 of 3
-------
STEPS TO BE TAKEN IF MTERIAl
IS RELEASED OR SPILLED: -wear suitable protective eqaipaent.
-Small spills snould be flushed with large quantities of water.
-larger spills should be collected for disposal.
WSTE DISPOSAL «£THOD: Incinerate in a furnace where peraittes under appropriate Fecerai, State, snd local
regulations. See Section IX.
rrrttZ*»T.,T,TT.,TT,>T.X,«,,.mm*S,
PROTECTION INFORKflTXS)
ESPIRATCRY PROTECTION: Self-contained breathing apparatus in high concentrations.
VENTILATION: Provide sufficient aechanical (general) and/or local exhaust ventilation to maintain exposure
below TLV (s).
P80TECTIVE GLOVES: Wear resistant gloves such as: Rubber, Plastic, Neoprene, Euna-N.
RE PROTECTION: Cheaical splash goggles in compliance with OSKA regulations are advised.
CTS8 PROTECTIVE
SHIPMENT: Eye bath and safety shower.
mTXXTZXXZXXXXXXXXXXXIXIItXXXIXXIXIXXZXrXXX S£Q|JQ|j J)( . SPECIAL PRECAUTIONS »««»*»»»*»"*«»tXXTXXXXXTXXTTTTXXXXXX»XXXX
PRECAUTIONS TO BE TAKEN IN KANDLINC AND STORAGE:
Keep away froa heat, sparks and open f lasts.
Ray be fatal if swallowed.
Do not breathe »ist. Avoid prolonged or repeated breathing of vapor.
Avoid centact with eyes.
wash thoroughly after handling.
Keep container closed. Do not store in open or unlabeled containers.
FOR INDUSTRIAL USE ONLY
OTHER PRECAUTIONS: Vhere heavy concentrations of a fine list are present, a respirator should be used to
prevent inhaling aist particles. Containers of this aatenal may be hazarccus vhen
esptied. Since eoptied containers retain product residues (vapor, liquid, and/or solid),
all hazard precautions given in this data sheet wst be observed.
>tItXXXXXXZIXXTXXTXXXXXXXXXXXXXXIX*rXXZ
-------
EXERCISE #2: DETERMINING THRESHOLDS
MANUFACTURING CASE STUDY
Using the information in the exercise, complete the following tasks to determine which
chemicals will require you to prepare a TRI report.
1. Identify each listed Section 313 chemical or chemical category manufactured, processed,
and/or otherwise used at the facility that you should evaluate for threshold
determinations.
2. Use the attached threshold determination worksheets to determine which toxic chemicals
meet or exceed an applicable threshold for manufacture, process, or otherwise use.
3. Prepare Part II, Sections 1,2 and 3 of Form R for each Section 313 chemical that exceeds
an applicable threshold.
Make any necessary assumptions and be prepared to identify the assumptions you have made and
the approach you used in completing this exercise.
Facility Description and Chemical Usage
Darcy Corp. operates adjacent plants at a site in central Ohio: Plant 1 manufactures industrial
refrigeration units and Plant 2 manufactures molded plastic components for a variety of
consumer product applications. Plant 1 employs a staff of 1,600 employees. Plant 2 employs a
staff of 800 full-time employees. The two plants operate independently.
Plant 1 uses Hi-Copper Brass Tubing (90.0 percent copper, 9.2 percent zinc) in the manufacture
of the air conditioners' components. The tubing is cut, bent into the appropriate shapes, and
welded into the air conditioning units. Plant 1 estimates that these activities generate over 0.5
pounds of copper releases to air and water. The purchasing department indicates that Plant 1
received 100,000 pounds of Hi-Copper Brass Tubing in the reporting year.
One of the refrigerants used by Plant 1 in its products is HCFC-22 (>98.0 percent pure). The
A100 series of refrigeration units use HCFC-22. In the reporting year, the facility produced 240
of these units, each of which contains 100 pounds of HCFC-22. Information provided by the
HCFC-22 supplier indicates that they delivered 20,000 pounds to the site's HCFC-22 storage
tank in the reporting year. Inventory records for the HCFC-22 storage tank indicated that the
tank contained 15,000 pounds at the beginning of the reporting year and 9,000 pounds at the end
of the reporting year.
Plant 1 paints certain refrigeration unit components using a paint that contains 10-weight percent
methyl ethyl ketone (MEK), a solvent. Paint booth logs indicate Plant 1 used 110,000 pounds of
this paint in these painting operations.
Plant 2 uses a resin in an injection molding process to make various plastic components.
Inventory records indicate that the facility used 300,000 pounds of the resin in the reporting year.
-------
The resin contains 4-weight percent of barium hydroxide and 1.5 percent elemental zinc.
Information obtained from the vendor indicates that during the curing of the resin, 1 pound of
anhydrous ammonia is generated for each 100 pounds of resin used.
Inventory records indicate that 10,000 pounds of an adhesive that contains 12-weight percent
MEK was used as a solvent in the adhesive application operations in the reporting year.
In the reporting year, a contractor painted the exterior and interior of all buildings on site. The
contractor reported that their paint usage in the reporting year was 20,000 pounds, containing 5-
weight percent MEK.
In the reporting year, remediation of soil contaminated with 1,1,1-trichloroethane and 2-butanone
(MEK) was conducted with a soil vapor extraction (SVE) system. After being processed through
an activated carbon adsorption unit that is 99 percent efficient in capturing the organic emissions,
the exhaust from the SVE system is emitted to the air through a stack. The SVE system is
estimated to extract from the ground and send to the activated carbon adsorption unit 20 pounds
of 1,1,1-trichloroethane and 10 pounds of MEK every month. The carbon is replaced every 10
months and the spent carbon is sent to ACME for incineration.
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
REPORTABLE SUBTOTAL
Percent by
Weight
Total
Weight
(Ibs.)
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable) .
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
•
Otherwise
Used
•
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent
by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
REPORTABLE SUBTOTAL
Total
Weight
(ibs.)
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction or
Percent Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
#
Mixture Name or
Other Identifier
Information
Source
Percent by
Weight
Total
Weight
(Ibs.)
REPORTABLE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
EXEMPTION SECTION
#
Mixture Name or
Other Identifier
Exemption
Note Fraction
.or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
THRESHOLD DETERMINATION WORKSHEET
Reporting Year:
Chemical:
Mixture Name or
Other Identifier
eor
ler
^•••MHMi^HBi
^^^**mimmmmmm
IMBHMI^HBKB
REPORTA1
••MMHHMHIII^
Information
Source
•»>i~>~*~«_M_
Percent by
Weight
MMMMMi^HH^
Total
Weight
(Ibs.)
••HKKBH^H^M
^••••^•••^iMBH
3LE SUBTOTAL
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
•
Otherwise
Used
EXEMPTION SECTION
Mixture Name or
Other Identifier
Exemption
Note Fraction
or Percent
Exempt
(if applicable)
EXEMPT SUBTOTAL
TOTAL (REPORTABLE - EXEMPT)
REPORTING THRESHOLD
Amount of Chemical by Activity (Ibs.)
Manufactured
Processed
Otherwise
Used
-------
Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Fadlity 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 Nuit^ (Important Erteronfr one nunterexa^
1.2
Toxic Chemical or Chemical Categofy Name (Inyortant Enter only one name exacltf as it appears on the Section 3131st)
u
. Generic Name must be atncturaBy tesayfra.)
\A Distribution of Each Member of the Dioxin and Dioxin-like Compounds Category.
(tf there are any numbers in boxes 1-17, then every field must be filed In with either 0 or some number between 0.01 and 100. Distribution should
be repotted In percentages and 8» total should equal 100%. If you do not have spedafion data avaHable. Indicate NA.)
1 2 3 4 5.6 78 9 10 11 12 13 14 15 16 17
MAI
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section If you completed Section 1 above.)
11
Generic Chemical Mama Piwtfed by Suppfarflm^^
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Check all that apply.)
11 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3
Otherwise use the toxic chemical:
Produce
Import
If produce or import
For on-slte use/processing
For saie/d&irfbutlon
As a byproduct
As an impurity
a.
b.
c.
d.
e.
Asareactant
As a formulation component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manufacturing aid
Ancillary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year*)
(Enter range code or estimate")
R Basis of Estimate
(enter code)
C. % From Stormwater
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
MA
Discharges to receiving streams or
water bodes (enter one name per box)
Stream or Water Body Name
111
113
(iddHonal pages of Part B. Section 5J are attached, Indicate the toWnumber of pages In this box
ndMteate the Part B, Section 5J page number In tWs box. I I (example: 1 A3, etc.)
EPAForn 9350-1 (Rev. 01/2001) - Previous edffions are obsotete.
* For Dioxin or Dtodn-fike compounds, report in grams/year
' Range Codes: A= 1 -10 pounds; 8= 11- 499 pounds: C= 500 - 999 pounds.
-------
Page 2 of 5
EPA FORM R
PART II. CHEMICAL-SPECIFIC INFORMATION
TRI Facility ID Number
Toxic Chemical, Category or Genetic Name
SECTION 1. TOXIC CHEMICAL IDENTITY
(Important DO NOT coonptete this section If you con^Urted Section 2 below.)
1.1
>qipMre<»te
1.2
1.3
rtmt Complete only* Part I.Sacfan lib checked >»'.
t be struct^ dMofrlgM.)
1.4 Distribution of Each Member off the Dtoxin and Dtamvllke Compounds Category.
(If there are any numbers In boms 1-17, then way fcW must be fifed In with eHher 0 or sornenuntter between 0.01 and 100. OistAufion should
be reported m percentages and •» total should equal 100%.» you do not haw specfattan data avateWe. Indicate NA.)
1234 5 6 7 8 9 10 11 12 13 14 15 16 17
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section If you completed Section 1 above.)
2.1
GemChH^NawhowM by Soppier Oa?erte*U^^
SECTION 3. ACTIVmES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important Check* that apply.)
3.1 Manufacture the toxic chemical:
Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
a. [ | Produce b. | | import
d.
e.
t
For on
As a byproduct
AsanknpurRy
a.
D.
&
d.
Asareadant
As a formUabon component
As an article component
Repackaging
As an impurity
As a chemical processing aid
As a manirfactunng aid
Anc«ary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
5.3
water bodes (enter one name par box)
Stream or Water Body Name
A. Total Release (pounds/year*)
(Enter range code or estimate")
Discharges to receiving streams or
a Baste of Estimate
(enter code)
C. % From Stonrtwatef
53.1
5.12
5JU
pages of Part i.Sftcaon Mare attached. torJcate the total number of pages hi tfate box
amliri<»n53p»genuntf)erlnlMsbox [ | (example: 1 A3,etc.)
B»A Form 93SO-1 (Rw. 01/2001). Previous edOtons are obsolete.
*ForDksdnaaoxirt-lkea)mpc)unds,reporlingrarrs/y€^
** Range Codes: A= 1 -10 pounds; B= 11- 499 pounds: C= 500 - 999 pounds.
-------
Page 2 of 5
EPA FORM R
PART if. 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 Hunter (Importart Enter only oronuirtaf
\2
Tone Chewed or O»mieal Category Name (Important Enter only ona name easily a» it appear»cnlheSadion313fat)
Generic Chemical Name (Important Complete only it Part 1, Section 2.1 b checked >s'. Generic Name roust be anrturaMr desoyfere.)
HI
Distribution of Each Member of the Dioxin and Oioxin-like Compounds Category.
(»there are any numbers In boxes 1-17, then every field must be filed In wHh either 0 or sonronimber between 6.01 and 100. DisWbuttonshoiW
be reported In percentages and t» total should equal 100%. If you do rot have spedatton data available, Indicate NA.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section If you completed Section 1 above.)
11
>*d«dbySu(?*«r(lmportOTt
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important Check all that apply.)
3.1 Manufacture the toxic chemical:
3.2 Process the toxic chemical:
3.3 Otherwise use the toxic chemical:
Produce
Import
c.
d.
e.
I
If produce or import
For on-sfte use/processing
For sale/distribution
As a byproduct
As an impurity
a.
b.
c.
d.
e.
Asareactant
As a formulation component
As an article component
Repackaging
As an Impurity
As a chemical processing aid
As a manufacturing aid
AncUary or other use
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ONSITE AT ANY TIME DURING THE CALENDAR YEAR
(Enter two-digit code from instruction package.)
SECTION 5. QUANTITY OF THE TOXIC CHEMICAL ENTERING EACH ENVIRONMENTAL MEDIUM ONSITE
A. Total Release (pounds/year*)
(Enter range code or estimate**)
a Baste of Estimate
(enter code)
C. % From Stormwater
5.1
Fugitive or non-point
air emissions
Stack or point
air emissions
NA
Discharges to receiving streams or
water bodes (enter one name per box)
Stream or Water Body Name
'KMttonal pages of Part U, Section 5.3 are attached. hxUcatt the total number of pages m this box
Mbidcate the Part H, Section 53 page number In this box. I I (example: 1 A3, etc.)
B*Form 9350-1 (Rev. 01/2001) - Previous edtoons are obsolete.
* For Dtoxin or Dioxin-Ske compounds, report in grams/year
" Range Codes: A= 1 -10 pounds; B= 11- 499 pounds; C= 500 - 999 pounds.
-------
TRI RELEASE AND OTHER WASTE
MANAGEMENT REPORTING
THE EPCRA SECTION 313 REPORTING
PROCESS
UanHy Section
313
IMmnins8»
quwdyof
Section 313
chmkab
and how they are
fnvnufadmd.
CompMa
Forms
E-2
-------
SECTION 313 REPORTING
importance of a structured process for release and
other waste management reporting
• Ensures accurate data
• Reduces burden in completing Form R report
» Systematic approach reduces redundancy over time
> Team approach distributes responsibility
• Ensures compliance with TRI reporting requirements
E-3
REPORTING METHOD
• identify potential release and other waste management
sources
• Identify available data and tools
• Collect data
• Estimate quantity of chemical being released and
otherwise managed as waste
• Document your work
E-4
-------
TOOLS AND DATA SOURCES FOR
CALCULATING REPORTING ESTIMATES
i Process flow diagrams
i Waste management manifests, invoices, and waste
profiles
i Environmental monitoring data
i Permit applications
i RCRA (BRS), NPDES, CAA, CERCLA and other env.
reports
i Engineering calculations and other notes
i EPA guidance
E-5
CALCULATING REPORTING ESTIMATES
i Consider all sources (routine and non-routine)
! Reasonable estimates are required by law
Facility determines best approach
Data and approach must be documented
E-6
-------
TECHNIQUES FOR ESTIMATING
CHEMICAL QUANTITIES
Use of monitoring data (M)
Mass balance calculation (C)
Use of emission factors (E)
Engineering calculations (O)
Use the code on the Form R for the method used to
estimate the largest portion of the release
E-7
ANALYSIS OF MONITORING DATA
Product of measured concentrations, volumetric
flow rates, and density equals pounds of chemical
released per year
Most commonly used for wastewater (Discharge
monitoring reports (DMRs))
Use Basis of Estimate code "M" if calculations based
primarily on monitoring data
E-8
-------
MASS BALANCE CALCULATION
Mass Balance is based on the law of conservation of
mass
Input + Generation = Output + Amount Reacted +
Accumulation
Most useful in simple situations
Use Basis of Estimate code "C"
• Example: Estimating wastewater releases from process
E-9
USE OF PUBLISHED EMISSION FACTORS
Emission factors are used to describe the quantity of
chemical released as a function of:
• Specific chemical used
• Specific process used
• Specific equipment used
Available in Compilation of Air Pollutant Emission
Factors (AP-42)
Use Basis of Estimate code "E" only when chemical-
specific emission factor is used
E-10
-------
ENGINEERING CALCULATIONS
Calculations based on best engineering
judgment/assumptions
Calculations based on process knowledge
Use of non-chemical-specific emission factors
Use of non-published emission factors
Use Basis of Estimate code "O"
E-11
NON-PBT CHEMICAL ESTIMATES
Values for non-PBT Section 313 chemicals must be
entered in whole numbers
• EPA allows using two significant figures when reporting
releases and other waste management estimates
• If estimate is more precise, additional significant figures
should be used based on precision of data used to calculate
the estimate
• For estimates of non-PBT Section 313 chemicals under
1,000 pounds, a range code can be used:
» A= 1-10 pounds; B = 11-499 pounds; C = 500-999 pounds
E-12
-------
"NA" VS. "0"
Use "NA" (not applicable) when no possibility of the Section
313 chemical being released to or otherwise managed as waste
in that media (e.g., facility has no on-site landfill) or when no
release to or other waste management in the specific media
occurs
Use "0" when no release occurs or < 0.5 pounds of a non-PBT
Section 313 chemical from a waste stream is directed towards
that medium
• Example: Discharge to water is zero; however, release possible if
control equipment fails
• Must indicate a Basis of Estimate code (i.e., M, C, E, O) for all
numerical estimates, including "0"
E-13
PART II. SECTION 4: MAXIMUM AMOUNT
OF THE TOXIC CHEMICAL ON-SITE AT
ANY TIME DURING YE AR
• Insert appropriate code from instructions indicating the
maximum quantity on-site
• Use maximum total amount present at one time during
reporting year, even if the Section 313 chemical is present at
more than one location at the facility
• Include amounts in storage, processes, and wastes (but not
those amounts which have been previously land disposed)
SECTION 4. MAXMUM AMOUNT OF THE TOXIC CHEMCAL OM-SITE
AT AMY TME OURMG THE CALENDAR YEAR
4.1
| | (EMvtn>4gtcode tern tetucSonpaacagL)
——^^•^^•••••i^^^^^^B
E-14
-------
PART H. SECTION 4: MAXIMUM AMOUNT
OF THE TOXIC CHEMICAL ON-SITE AT
ANY TIME DURING YEAR
• Part II, Section 4.1: Maximum amount on-site at any
time during the calendar year
. Based on amount in storage, process, and wastes
• Not the same as Tier II maximum amount on site
» Tier II is usually by mixtures, Form R is chemical-specific
» Tier II excludes hazardous wastes, Form R does not
• Data sources
• Tier II records/calculations
• Waste inventory data
E-15
PART H. SECTION 5: QUANTITY OF THE
TOXIC CHEMICAL ENTERING EACH
ENVIRONMENTAL MEDIUM
Report total releases of the Section 313 chemical to
each environmental medium on-site
In column A, Total Release, report total quantity
• A range code can be used for non-PBT Section 313
chemical quantities less than 1,000 pounds
» A = 1 -10 pounds
» B = 11 -499 pounds
» C = 500 - 999 pounds
E-16
-------
PART H. SECTION 5: ON-SITEAIR
EMISSIONS
• Section 5.1 Fugitive or non-point air emissions
• Enter total fugitive releases of the Section 313 chemical in column
A, including leaks, evaporative losses, building ventilation, or other
non-point air emissions
• Section 5.2 Stack or point air emissions
• Enter total releases to air from point sources, including stacks,
vents, pipes, ducts, storage tanks, or other confined air streams
SECTIONS. QUANTITY OF THE TOMC CHEMCAL ENTERING EACH ENVIRONMENTAL MEDIUM
5.1
Fugitive or notvpoint air
emissions
DNA
Suck or point air
emissions
DMA
FUGITIVE EMISSIONS
Part II, Section 5.1: Fugitive or non-point air
emissions
• Approach: ID potential sources
Data sources/tools
• Engineering calculations
• Emission factors
• Monitoring data
• Mass balance
• ID data/tools —> estimate
E-18
-------
STACK EMISSIONS
Part II, Section 5.2: Stack or point-source air
emissions
• Approach: ID potential sources -> ID data/tools -> estimate
• Data sources/tools
> Air permit applications
» CAA Title V air inventories
» Process and production data
» Engineering calculations
» Mass balance
» Emission factors
E-19
PART H. SECTION 5: ON-SITE
WASTEWATER DISCHARGES
Section 5.3 Releases to streams or water bodies
• Enter names of streams or water bodies to which your facility directly
discharges the Section 313 chemical. If there is no name, enter the closest
stream or water body with a name
• Enter total amount of releases to each receiving stream or water body in
column A; include amounts from stormwater runoff, if available
• Indicate in column C the percentage of the total quantity (by weight) of the
Section 313 chemical contributed by stormwater
SECTION 5. QUANTITY OF THE TOXIC CHEMrCAL ENTERING EACH ENVIRONMENTAL MEDIUM
Discharges to receiving steams or
SMMi or Water Body Name
E-20
-------
WASTEWATER DISCHARGES
Part II, Section 5.3: Release to stream or water body
and Part II, Section 6.1: Discharges to POTW
• Approach: ID potential sources -> ID data/tools -> estimate
Potential release sources
• Wastewater treatment facility discharge
• Storm drains
Data/tools
• Monitoring, if available
• DMRs or other required monitoring data
• NPDES permits/permit applications
• Process knowledge and/or mass balance
E-21
CALCULATING WASTEWATER
DISCHARGES
Recommended approach: Calculate the yearly
pounds of methanol discharged using the following
data concerning wastewater discharges of methanol:
Date Cone. fmq/U Flow (MGD) Amt(lbsJdav)
3/1 1.0 1.0 8.33
9/8 0.2 0.2 .33
Average= 4.33
(4.33 IbsJday) x (365 days/yr.) = 1581 IbsJyr.
MGD = million gallons per day
1 mg/L = 8.33 IDS ./million gal
E-22
-------
PART D. SECTION 5: ON-SITE INJECTION
WELLS
Section 5.4.1 Underground injection to Class I wells
• Enter total amount of Section 313 chemical injected into Class I
wells at facility in column A and basis of estimate code in column
B
Section 5.4.2 Underground injection to Class II -V wells
• Enter total amount of Section 313 chemical injected into Class II - V
wells at facility in column A and basis of estimate code in column
B
SECTION S. QUANTITY OF THE TOXIC CHEMCAL ENTERING EACH ENVIRONMENTAL MEDIUM
Underground: Infections on-
saw to Class I Watts
stt* lo Cbss «-v Wans
DNA
DNA
E-23
PART H. SECTION 5: RELEASES TO LAND
ON-SITE
Section 5.5 Releases to land on-site
• Other disposal (5.5.4) includes spills or leaks of the Section 313 chemical to
land
• Quantities of Section 313 chemicals released to air or water during the
reporting year of the initial release to land (e.g., volatilization from surface
impoundments) are not included here
SECTION 5. QUANTITY OF THE TOXIC CHEMCAL ENTERING EACH ENVKOMIENTM. MEDIUM
S.S
S.5.1A
S.5.1B
5J.2
5.5.3
5.5.4
Disposal to land on-skc
RCRA Subtitle C landfite
Other landfills
Land treatment/application
fanning
Surface impoundment
Other disposal
NA
a
a
n
a
a
A-ToMMMin..**
jn|l«l«iiiil|m«»«-
*«««•»» i n
a. BtriiafESBMIi
fenttfaxk)
E-24
-------
RELEASED TO LAND ON-SITE
Approach: ID potential sources -> ID data/tools ->
estimate
Potential sources of release to land
• Intentional storage or disposal in on-site units
• Spills
• Leaks
Data/tools:
• Operating records/analytical data
• Spill reports
• Process knowledge
E-25
CHEMICAL MIGRATION GUIDANCE
Migration of reportable chemical within one
environmental medium (e.g., from land to land:
landfill leaching into soil)
• Only required to report initial release of chemical to the
environment
Migration of chemical from one environmental
medium to another (e.g., from land to air:
volatilization from a lagoon) within the reporting year
• Release estimates should be calculated and reported for all
media in Part II, Sections 5,6, and 8 of Form R
E-26
-------
WASTE RELEASED TO LAND ON-SITE-
STORAGE
Storage of wastes on the land
• Regular shipment schedule
» Must transfer the waste off-site before that reporting year's
Form R report is submitted or July 1, whichever comes first
» Report material transferred off-site during the year in Part II,
Section 6 of Form R
• No regular shipment schedule
» Report material added to pile that remains on-site during the
year as the quantity released to land, Part II, Section 5.5.4 of
Form R
E-27
PART II. SECTION 6: TRANSFERS TO OFF-
SITE LOCATIONS
i Includes both off-site location information and quantities of
Section 313 chemicals transferred to off-site locations
i Report quantities of a Section 313 chemical sent off-site to any
POTW or other location for recycling, energy recovery, waste
treatment, or disposal
i Report only total quantity of a Section 313 chemical transferred
off-site, not entire waste
i In Sections 6.1 and 6.2, Total Transfers, report total quantity
• A range code can be used for non-PBT Section 313
chemical quantities less than 1,000 pounds
» A= 1 -10 pounds
» B = 11 - 499 pounds
» C = 500 - 999 pounds
E-28
-------
PART H. SECTION 6: TRANSFERS TO
POTWs
Section 6.1 Discharges to publicly owned treatment
works
• Enter total quantity of the Section 313 chemical transferred
to all POTWs and basis of estimate
SECTON6. TRANSFERS OF THE TOXIC CHEMCALM WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
6.1JV Totrf Quantity Transfemd to POTWs and Basis of Estimate
t.ijk.1 TouiTnramipoinfctyMr)
(fttr rang* code or etiniMe)
S.1JL2 BofeatEsttiMl
(mar code)
E-29
PART n. SECTION 6: TRANSFERS
TO POTWs
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 CHEMCALM WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTWs)
.,u IrarwiUK
POTW Address
Cty |swe{ \Coum
cm iPOTWNam
POTW Address
09 |satej |c«rty
1*1
1*1
E-30
-------
PART H. SECTION 6: TRANSFERS TO
OTHER OFF-SITE LOCATIONS
Section 6.2 Transfers to other off-site locations
• Include name, address, and EPA identification (RCRA ID) number
• Enter quantities, basis of estimate, and codes for multiple activities (waste
treatment disposal, recycling, and energy recovery) in Rows 1 through 4
• Photocopy page 4 if reporting more than 2 off-site transfer locations (ATRS
accommodates this without photocopying)
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
Si OfF-SITC EP» DENTIXM10II NUMBER (ROWBNOJ |
On-s*>Loc*tonNaaie|
OtsikMfeB |
«*! l*-l 1^1 1*1 23J
Itbc*lionlindirc«mlofn9aflkitlic«qrorpiranlconpin}7 O Yes O No
A. Tottltonsfentpwnfcryeir)
(ertef range code or esknMe)
1.
2.
3.
4.
B. Basis alfstiaat*
(enter code)
1.
2.
3.
4.
C. Typ« of Waste Tre»um« Disposal/
1M
2M
)M
4M
E-31
OFF-SITE WASTE MANAGEMENT
Approach: ID potential sources -> ID data/tools -> estimate
Potential sources of off-site waste management
• Identify final disposition of the Section 313 chemical
» Disposal
» Waste treatment
» Energy recovery
» Recycling
Data/tools
• Waste manifests and vendor receipts
• RCRA reports
• Waste characterization - analyses, profiles
E-32
-------
PART H. SECTION 7: ON-SITE WASTE
MANAGEMENT
Examples of on-slte waste management (Section 7)
• Air pollution control devices (Section 7A)
• Wastewater treatment processes (Section 7A)
• Energy recovery devices (Section 7B)
• Recycling devices (Section 7C)
E-33
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
Report each waste treatment method that the Section 313
chemical undergoes
• Include even if method has no effect on the Section 313 chemical
i Only data element in Form R focusing on the entire waste
stream rather than the Section 313 chemical in the waste
stream
SECTION 7A. OM-STTE WASTE TREATMENT METHODS AMD EFFICIENCY
MotAppBcaMeOW) - Check here if nfiorwite waste treatment is applied to any
waste stream containing the tone chemical or chemical category.
TA.'
7A.M
Ye» Ho
D D
E-34
-------
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's TRI Reporting Forms and Instructions document for
on-srte waste treatment method(s) used
• Enter code(s) regardless of whether waste treatment actually affected the
Section 313 chemical
• Report waste treatment method(s) used on aggregate waste stream as single
stream
• If applicable, enter codes in sequence in which they occur
E-35
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.c Range of influent concentration
• Use range of concentration of the Section 313 chemical in waste
stream as it typically enters treatment equipment
- Enter code(s) for concentration ranges (parts per million) from
EPA's TRI Reporting Forms and Instructions document
• Section 7A.d Waste treatment efficiency estimate
• Waste treatment efficiency expressed as percent removal of the
Section 313 chemical from waste stream through biological
degradation, chemical conversion, or physical removal
» Use overall efficiency of waste treatment sequence, not a specific
waste treatment method
» Use percent removal of Section 313 chemical only, not other
constituents of the waste stream
E-36
-------
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Section 7A.e Based on Operating Data?
• Check "yes" if efficiency estimate is based on monitoring from
typical operating conditions
• Check "no" if efficiency estimate is based on published data for
similar processes or equipment supplier's literature, or if the
influent or effluent waste comparison or the flow rate was
otherwise estimated
E-37
PART H. SECTION 7A: ON-SITE WASTE
TREATMENT METHODS AND EFFICIENCY
• Procedures for using two lines of data to enter 9 or more
sequential waste treatment methods
SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY
D Not AppGcaMe (MA) - Check here if na on-site waste treatment is applied to any
waste stream contiining the tone chtmicjl or chemical category.
E-38
-------
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
D Not Applicable (NA) • Check here if no on-site energy recovery is applied to any waste
stream containing the tone chemical or chemical category.
E-39
PART H. SECTION 7C: ON-SITE
RECYCLING PROCESSES
Enter methods used for on-site recycling of the Section 313
chemical
• Codes for recycling methods used are found in EPA's TRI
Reporting Forms and Instructions document
• Do not include energy recovery processes
Enter codes in descending order by quantities recycled
SECTION 7C. ON-SITE RECYCLING PROCESSES
D Not Applicable (NA) - Check here if no on-site recycling is applied to any waste
stream containing the toxic chemical or chemical category.
E-40
-------
PHOTOCOPYING PAGES OF FORM R
• Form R pages may be photocopied if additional space is
necessary to complete these sections (photocopying is not
necessary with ATRS)
• Section 6.1: Transfers to POTWs
• Section 6.2: Transfers to Other Off-Site Locations
• Section 7A: Waste Treatment Methods and Efficiency
• When photocopying pages, you must complete the box on
each page to indicate the number of copies you are attaching
• For the page being photocopied, enter in the left box the total
number of pages submitted including the original
original + number photocopied = total pages submitted
• In the second box, indicate the position of the individual page
If additiMu! pases of P»rt II, Sections 6O/7A are attached, indicate the total number of pages in this
boi EJ ««l indicate which Part II, Sections &2/7A pate Out is, here. Q (example: 1.2J. etc.)
E-41
BEST PRACTICE: RECORDKEEPING
Importance of good recordkeeping
• Detailed records improve reporting accuracy and data
quality
• Well-labeled calculations and engineering assumptions
serve as standard operating procedures for future years
» Reduce replication
» Ensure consistency
Requirements
• All records used to complete Form R reports must be kept
for three years (40 CFR 372.10)
• EPA will review records during a data quality audit
E-42
-------
REFERENCE SOURCES
Estimating Releases and Waste Treatment Efficiencies
EPA Industry Guidance located at http://www.epa.gov/tri
AP-42: Compilation of Air Pollutant Emission Factors located at
http://www.epa.gov/ttn/chief
Technology Transfer Network located at http:7Awww.epa.gov/ttn
• AP-42
• WATERS program
. Updates WATERS, CHEMDAT8, and CHEM9
• TANKS program
Perry's Chemical Engineer's Handbook; CRC Handbook of
Chemistry and Physics; Lange's Handbook of Chemistry
E-43
-------
OVER
POLLUTION PREVENTION
REPORTING??!
POLLUTION PREVENTION HIERARCHY
Disposal or Other
Release to
Environment
F-2
-------
THINGS TO REMEMBER WHEN
COMPLETING SECTION 8
Key concepts
• Waste streams
• Process streams
• Reportable recycling
• Source reduction activities
Develop consistent definitions for key terms
• Across facility
• Across agency/company
F-3
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
• Column A - Prior Reporting Year Estimate
• Column B - Current Reporting Year Estimate
• Column C - Next Reporting Year Projection
• Column D - Following Reporting Year Projection
F-4
-------
• Insert Form R (Page 5) here.
F-S
m Insert Form R {Page 5) here.
F-6
-------
RELEASES AND OTHER WASTE
MANAGEMENT
Part II, Sections 8.1 through 8.7 of Form R
• Quantity of a Section 313 chemical reported in Sections 8.1
through 8.7 does not include releases (including on-site
and off-site disposal) and other off-site waste management
activities resulting from remedial actions, catastrophic
events, or one-time events not associated with production
process. These quantities should be reported in Section 8.8
only
F-7
RELEASES
Section 8.1: Quantity released
• Quantity of a Section 313 chemical "released"
» Definition of release: "...any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing...into the
environment..." (EPCRA Section 329(8))
» Includes fugitive and stack air emissions, releases to
land, releases to water, underground injections, and on-
site and off-site disposal
» Includes metals in wastes sent to a POTW (metals .
cannot be destroyed)
F-8
-------
RELEASES
Section 8.1: Quantity released (continued)
• Section 8.1 = Sections 5 + 6.2 (disposal only) + 6.1 (for
metals and metal compounds only) - 8.8 (release or off-site
disposal only)
• Possible data sources
» Data and calculations from Sections 5 and 6 of Form R
F-9
ENERGY RECOVERY
Sections 8.2 and 8.3: On-site and off-site energy
recovery
• Things to remember about energy recovery
» Combustion unit (e.g., industrial furnace, industrial kiln,
or boiler) must be integrated into an energy recovery
system
» Section 313 chemical must have significant heating
value (e.g., 5,000 BTU/lb.)
» Section 313 chemicals that are, or are contained in,
traditional fuels should not be reported as combusted
for energy recovery
F-10
-------
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 an estimate
should be calculated for Section 8.2
• Possible data sources
» Engineering process specifications
».Mass balance calculations
» Best engineering judgement F-H
ENERGY RECOVERY
Section 8.3: Off-site energy recovery
• Quantity of Section 313 chemical that is transferred off-site
for energy recovery
» Includes total quantity of Section 313 chemical
transferred off-site for energy recovery purposes - not
quantity actually combusted off-site
• Possible data sources
» Section 6.2 (codes M56 and M92) of Form R
» Receipts from off-site facilities
» RCRA hazardous waste manifests
F-12
-------
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 an estimate
should be calculated for Section 8.4
F-13
CALCULATING QUANTITY RECYCLED
IN SECTION 8.4
Facility
Fugitive Air
Emissions
Quantity
Entering
Recycling
Operation
i
Unusable
Residues sent off-
site for disposal
Quantity
Recycled
F-14
-------
RECYCLING
Section 8.5: Off-site recycling
• Quantity of Section 313 chemical transferred off-site for
recycling
» Includes total quantity of Section 313 chemical
transferred to off-site locations for recycling
• Possible data sources
» Section 6.2 of Form R (only for recycling destinations)
» Receipts from off-site recycling facilities
» RCRA hazardous waste manifests
» RCRA hazardous waste report (BRS)
F-15
WASTE TREATMENT
Section 8.6: Quantity treated on-site
• Quantity of Section 313 chemical treated on-site
» Includes all quantities of Section 313 chemical destroyed
• Possible data sources
» Calculations used to complete Section 7A of Form R
• Remember to include quantities that are actually
destroyed (or converted to a non-listed form), not
just removed from the waste stream
F-16
-------
WASTE TREATMENT
• Section 8.7: Off-site waste treatment
• The amount of Section 313 chemical that is transferred off-
site for waste treatment
» Includes all quantities of Section 313 chemical
transferred to off-site facilities for waste treatment
• Possible data sources
» Sections 6.1 and 6.2 (i.e., off-site transfers for waste
treatment)
• Important: Assume all Section 6.1 quantities are
treated, except metals and metal compounds
F-17
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8: Remedial, catastrophic, or one-time
releases
• Quantity of Section 313 chemical released into the
environment or transferred off-site as a result of:
» Remediation
» Catastrophic events (e.g., earthquake, hurricane, fire,
floods)
» One-time events not associated with production
processes (e.g., pipe rupture due to unexpected weather)
• Does not include Section 313 chemicals treated, recovered
for energy, or recycled ON-SITE
• Excludes quantities in Sections 8.1 through 8.7 F'18
-------
CALCULATING QUANTITY REPORTED
IN SECTION 8.8
Facility
u
(2) C
f On*
[ Rem
V Clea
Off-site .
Transfers
Production ^_
Process
Fugitive Air
P Emissions
^ On-site
site >. (3) Treatment,
nup J or
_— -^ Recycling
(4)
Catastrophic,
One-time Release
~^^~^-S-^^
d)
1
Ml -4- l")\ 4. IA\ — Tnt-al Qo/-f!nn ft ft riiiinfitw
F-19
REMEDIAL, CATASTROPHIC, OR
ONE-TIME RELEASES
Section 8.8 (continued)
• Possible data sources
» Quantities reported in Part II, Sections 5 and 6
» Accident investigation reports
» Inventory reconciliation
» Mass balance calculations
» Monitoring reports (e.g., pH, discharge monitoring
reports, continuous emissions monitoring)
» CERCLA reports filed with the National Response Center
» Release notification reports required under EPCRA
Section 304
F-20
-------
SOURCE REDUCTION AND OTHER WASTE
MANAGEMENT ACTIVITIES
Important points regarding Sections 8.1 through 8.8
• Sum of the quantities in Sections 8.1 through 8.7 equals the
total quantity of the Section 313 chemical "entering any
waste stream (or otherwise released into the environment)
prior to recycling, treatment, or disposal." (PPA Section
6607(b)(1))
• Quantities reported in Sections 8.1 through 8.7 are exclusive
of each other
• Sum of Sections 8.1 through 8.7 is mutually exclusive of the
quantity in Section 8.8
F-21
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' J Exercise #3: Identifying Waste Streams
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I
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| P.O."
-
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•<-
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Product
F-22
-------
PRODUCTION RATIO OR ACTIVITY INDEX
Section 8.9: Production ratio or activity index
• A ratio of production or activity involving the Section 313
chemical in the reporting year to production or activity in
the previous year
• Allows quantities of the Section 313 chemical reported in
Sections 8.1 through 8.7 in the current year to be compared
to quantities reported in the prior year
• Production ratio or activity index is determined by dividing
the level of production (or activity) in the current year by the
level of production (or activity) in the prior year
• Select methodology least likely to be affected by potential
source reduction activities
F-23
PRODUCTION RATIO
Use production ratio if Section 313 chemical usage
is related to a production level
• Equation
Quantity of Product: Current Reporting Year
Quantity of Product: Prior Reporting Year
Example:
Oven manufacturing
40,000 ovens assembled (Current RY) =114
35,000 ovens assembled (Prior RY)
F-24
-------
ACTIVITY INDEX
Use activity index if Section 313 chemical usage is
related to an activity and not to a production level
• Equation
Level of Activity: Current Reporting Year
Level of Activity: Prior Reporting Year
Example:
Tank washouts
60 Washouts (Current RY)
50 Washouts (Prior RY) - 1 2
F-25
PRODUCTION RATIO OR ACTIVITY INDEX
Possible data sources
• Production reports
• Maintenance records for otherwise used chemicals
• Waste minimization section of the RCRA hazardous waste
report
• State/corporate pollution prevention reports
F-26
-------
SOURCE REDUCTION ACTIVITIES
Section 8.10
• Source reduction practices used with respect to the Section
313 chemical at the facility and the methods used to identify
those activities
• This section includes only those source reduction activities
implemented during the reporting year
» Only include activities that reduce or eliminate quantities
reported in Sections 8.1 through 8.7
F-27
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 p-28
-------
OPTIONAL INFORMATION
Section 8.11
• Facility should indicate whether additional optional
information on source reduction, recycling, or pollution
control activities is included with the report
• A one-page summary is encouraged
• Facility can provide information on previous years' activities
• EPA and others use this information for granting awards
and recognition to companies and employees .
F-29
-------
FORM A SUBMISSION
ALTERNATE THRESHOLD RULE
If alternate threshold criteria met:
• No Form R report
• No release, other waste management, or source reduction
reporting
• Submit certification statement (Form A) each year
Final rule published in 1994 (§372.27; November 30,
1994; 59 FR 61501)
Does not apply to PBT chemicals
G-2
-------
(IMPORTANT: Type or print; read instructions before completing form)
Form Approved OMB Number. 2070-0143
Approval Expires: 01/31/2003 Pa9e JLof.
United States
Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY
FORMA
WHERE TO SEND COMPLETED FORMS: 1. EPCRA Reporting Center
P.O Box 3348
Merrifiekl,VA 22116-3348
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE
(See instructions in Appendix F)
Enter "X" here if this
is a revision
For EPA use only
Important: See instructions to determine when "Not Applicable (NA)" boxes should be checked.
PART I. FACILITY IDENTIFICATION INFORMATION
SECTION 1. REPORTING YEAR
SECTION 2. TRADE SECRET INFORMATION
2.1
Are you darning the toxic chemical identified on page 2 trade secret?
Yes (Answer question 2.2;
Attach substantiation forms)
No (Do not answer Z2;
Go to Section 3)
2.2
Is this copy
Sanitized
Unsanitized
(Answer only if "YES" in Z1)
SECTION 3. CERTIFICATION (Important: Read and sign after completing all form sections.)
I hereby certify that to the best of my knowledge and belief, for each toxic chemical listed in the statement the annual reportabte
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 tide of owner/operator or senior management office t
Signature:
Date Signed:
SECTION 4. FACILITY IDENTIFICATION
TRI Facility ID Number
Faciity or Establishment Mane |
Facility or Establishment Name or Mailing Address
-------
IMPORTANT: Type or print read instructions before completing form
Page of
EPA FORM A
PART II. CHEMICAL IDENTIFICATION TRIFID:
Do not use this form for reporting PBT chemicals including Dioxin and Dioxin-like Compounds*
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of ___
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 Complete only if Part 1, Section 2.1 is checked 'yes*. Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important Enter only one number exactly as it appears on the Section 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 Complete only if Part 1, Section 2.1 is checked "yes" Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report ___ of __
1.1
CAS Number (Important Enter only one number exactly as it appears on the Section 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)
13
Generic Chemical Name (Important Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important: DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
SECTION 1. TOXIC CHEMICAL IDENTITY
Report of
1.1
CAS Number (Important Enter only one number exactly as it appears on the Section 313 list Enter category code if reporting a chemical category.)
1.2
Toxic Chemical or Chemical Category Name (Important Enter «iry fx» name exactly as it appears on the Seefon 313 list)
Generic Chemical Name (Important Complete only if Part 1, Section 2.1 is checked "yes". Generic Name must be structurally descriptive.)
SECTION 2. MIXTURE COMPONENT IDENTITY (Important DO NOT complete this section if you completed Section 1 above.)
2.1
Generic Chemical Name Provided by Supplier (Important Maximum of 70 characters, including numbers, letters, spaces, and punctuation.)
* See the TRI Reporting Forms and Instructions Manual for the list of PBT Chemicals (including Dioxin and Dioxin-like Compounds)
EPA Form 9350-2 (Rev. 01/2001) - Previous editions are obsolete. (Make additional copies of this page, if needed)
-------
ALTERNATE THRESHOLD RULE
Criteria for submitting a Form A
• Do not exceed 1,000,000 pounds manufactured, processed,
or otherwise used; and
• Do not exceed 500 pounds for the total annual reportable
amount for a Section 313 chemical. Equivalent to the sum
of the quantities calculated for Sections 8.1 - 8.7 of the Form
R
G-7
POP QUIZ
You manufacture 100,000 pounds of a non-PBT
Section 313 chemical. You sell 99,950 pounds as a
product You emit 25 pounds out a stack, and send
25 pounds off-site for disposal. Do you meet the
criteria for submitting a Form A?
You use 50,000 pounds of nitric acid as a cleaner.
The entire amount is neutralized in your on-site
wastewater treatment operation and there are no air
or water releases. Do you meet the criteria for
submitting a Form A?
G-8
-------
ALTERNATE THRESHOLD RULE
Recordkeeping
• All documentation to support the determination, including:
» Detailed records
» Well-labeled calculations and assumptions
• All records used to determine eligibility to file the Form A
must be kept for a period of 3 years from the date of the
submission of the certification statement (§372.10(d))
G-9
OVERVIEW:
FORM R VS. FORM A
Form R • Form A
• Standard reporting • Alternate certification
method statement
• For all Section 313 • Not allowed for PBT
chemicals chemicals
• Report releases, other • Use for total reportable
waste management, and amounts not exceeding
source reduction activities 500 pounds
• Recordkeeping • Recordkeeping
requirements requirements
G-10
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