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 2: PBT Reporting
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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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REPORTING REQUIREMENTS FOR
PERSISTENT, BIOACCUMULATIVE, AND
TOXIC (PBT) CHEMICALS: AN
OVERVIEW
THE PBT RULE
PBT chemical rule published in the Federal Register
(October 29,1999; 64 FR 58666)
Rule applies beginning RY 2000, reports due July 1,
2001
Rule adds new chemicals to the TRI list
Rule identifies a subset of chemicals (PBT
chemicals) with lower thresholds and special
reporting requirements (§372.28)
H-2
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PBT CHEMICALS
Eighteen chemicals and chemical categories are
subject to the PBT chemical rule:
Pesticides - Aldrin, Chlordane, Heptachlor, Isodrin,
Methoxychlor, Pendimethalin, Toxaphene, and Trifluralin
Aromatics - Benzo(g,h,i)perylene, Polycyclic aromatic
compounds (PAC) category, Dioxin and dioxin-like
compounds category, Hexachlorobenzene,
Octachlorostyrene, Pentachlorobenzene, Polychlorinated
biphenyls (PCB), and Tetrabromobisphenol A (TBBPA)
Metals - Mercury and Mercury compounds
H-3
PBT CHEMICALS AND THRESHOLDS
Manufacture, process, and otherwise use thresholds:
100lbs./yr- Aldrin Polycyclic Aromatic Cmpds.
Methoxychlor Tetrabromobisphenol A
Pendimethalin Trifluralin
10lbs./yr- Chlordane Benzo(g,h,i)perylene
Heptachlor Hexachlorobenzene
Mercury Mercury compounds
Toxaphene Octachlorostyrene
Isodrin Pentachlorobenzene
PCBs
0.1 g/yr - Dioxin and dioxin-like compounds
H-4
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PBT CHEMICALS
The following chemicals were NOT designated as
PBT chemicals for RY 2000:
Vanadium (except when contained in alloy)*
Vanadium compounds*
Lead"
Lead compounds**
* Vanadium has a new qualifier and vanadium compounds is a
new non-PBT listing
** A separate rulemaking has designated lead and lead
compounds as PBT chemicals beginning RY 2001
H-5
PBT CHEMICALS AND EXEMPTIONS
The cte minimis exemption has been eliminated for
PBT chemicals except for purposes of supplier
notification
Users of mixtures must use best readily available
information to determine the PBT chemicals present and
their concentrations
No other Section 313 regulatory exemptions were
modified or restricted by the PBT chemical rule
H-6
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PBT THRESHOLDS
The combination of the low thresholds and no cte
minimis exemption means that a thorough review of
chemical activities may be needed to achieve
compliance with the PBT chemical rule
Impurities need to be evaluated regardless of concentration
Chemicals used in low volumes need to be considered
H-7
SUPPLIER NOTIFICATION
The supplier notification requirements have not changed
The de minimis exemption still applies to supplier
notification
Suppliers can claim a chemical constituent trade secret
and provide a generic chemical name
If the facility has no information to identify the constituent as a
PBT chemical, the threshold should be 25,000/10,000 pounds
based on the activity
If the facility has information that the constituent is a PBT chemical
but does not know which PBT chemical activity threshold applies
(i.e., 0.1 gram, 10 pounds, or 100 pounds), the 100 pound threshold
should be used
H-8
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PBT REPORTING
EPA has modified the Form R for PBT chemicals
Part II, Section 1.4 has been added to Form R
» Allows for reporting the distribution of each member of
the dioxin and dioxin-like category as percentages
among the 17 category members
When reporting on dioxin and dioxin-like category, ATRS
will automatically recognize units of measure as grams
ATRS will allow for decimal reporting for PBT chemicals
(e.g., 9.3 pounds)
H-9
PBT REPORTING
For PBT chemicals, EPA is requiring more precise reporting:
EPA has prohibited use of Form As
EPA has prohibited use of range codes for reporting releases and
other waste management quantities
H-10
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DATA PRECISION
Report releases and other waste management
quantities at a level of precision supported by the
data and estimation techniques used
If 157.243 pounds calculated, report 157.243,157.24,157.2,
157,160, or 200 pounds depending on accuracy/quality of
data and estimation techniques used
For PBT chemicals, 0.1 pound is the smallest
amount required to be reported (except for dioxin
and dioxin-like compounds)
Estimates < 0.05 pounds can be rounded down to zero
pounds
H-11
DATA PRECISION
For dioxin and dioxin-like compounds, 100
micrograms (equals 0.0001 grams) is the smallest
amount required to be reported
Estimates < 50 micrograms (equals 0.00005 grams) can be
rounded to zero grams
Report releases and other waste management
quantities at a level of precision supported by the
data and estimation techniques used
If 1.57243 grams calculated, report 1.57243,1.5724,1.572,
1.57,1.6, or 2 grams depending on accuracy/quality of data
and estimation techniques used
H-12
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POLYCYCLIC AROMATIC COMPOUNDS
(PACs) AND BENZO(G,H,I)PERYLENE
PACs AND BENZO(G,H,I)PERYLENE
PBT activity threshold
PAC category threshold: 100 pounds
Benzo(g,h,i)perylene threshold: 10 pounds
3-Methylcholanthrene and Benzo(j,k)fluorene
(fluoranthene) are being added as members of the PAC
category
All members (new and old) of the newly expanded PAC
category are PBT chemicals
Benzo(g,h,i)perylene is an individually listed polycycljc
aromatic hydrocarbon (PAH) that is a PBT chemical
Not a member of PAC category
1-2
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POLYCYCLIC AROMATIC COMPOUNDS
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(j)f!uoranthene
Benzo(k)fluoranthene
Benzo(j,k)fluorene (fluoranthene)*
Benzo(r,s,t)pentaphene
Benzo(a)phenanthrene (chrysene)
Benzo(a)pyrene
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenzo(a,h)anthracene
7H-Dibenzo(c,g)carbazole
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7,12-Dimethylbenz(a)anthracene
lndeno(1,2,3-cd)pyrene
3-Methylcholanthrene*
5-Methylchrysene
1-Nitropyrene
* Newly listed (October 29, 1999; 64 FR
58666)
I-3
SOURCES OF POLYCYCLIC AROMATIC
COMPOUNDS
Coal
Fuel oil and other petroleum products
Asphalt
Creosote wood treatment
I-4
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POLYCYCLIC AROMATIC COMPOUNDS
PACs are found in coal, fuel oil and other petroleum
products
Default concentrations (weight-based)
10 ppm in No. 2 fuel oil (Ref. 5)
2,461 ppm in No. 6 fuel oil (Ref. 2)
Also present in other fossil fuels, petroleum products, coal tars,
etc.
Considered otherwise used if combusted on-site
Considered processed if distributed in fuels, petroleum
products, and other products
I-5
POLYCYCLIC AROMATIC COMPOUNDS
PACs are also coincidentally manufactured during
the combustion of fossil fuel
Default air emission factors:
1.12 pounds per million tons of coal combusted in a boiler
with air pollution controls (Ref. 3)
3.15 x10~5 pounds per million standard cubic feet natural gas
burned in a utility boiler (Refs. 3,4)
0.0165 pounds per million gallons of No. 6 fuel oil burned in
a utility boiler (Ref. 3)
I-6
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POLYCYCLIC AROMATIC COMPOUNDS
Additional factors for coal and oil combustion
available in Locating And Estimating Air Emissions
From Sources OfPolycyclic Organic Matter (Ref. 4)
Includes several factors available for different types of coal,
types of boilers, and different types of air pollution control
Contains emission factors for several members of the PAC
category, benzo(g,h,i)perylene, and other chemicals
1-7
BENZO(G,H,I)PERYLENE
Benzo(g,h,i)perylene is a separately listed polycyclic
aromatic hydrocarbon
Similar to PACs and found in same materials
Benzo(g,h,i)perylene is not a member of the PAC category
Default concentrations
0.05 ppm in No. 2 fuel oil (Ref. 5)
26.5 ppm in No. 6 fuel oil (Ref. 2)
Present in other fossil fuels, petroleum products, coal tars,
etc.
1-8
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BENZO(G,H,I)PERYLENE
Benzo(g,h,i)perylene is coincidentally manufactured
during the combustion of fossil fuel
Default air emission factors:
0.027 pounds per million tons coal combusted in a boiler
with air pollution controls (Ref. 3)
0.00226 pounds per million gallons of No. 6 fuel oil burned
in a boiler (Ref. 3)
1-9
PACs AND BENZO(G,H,I)PERYLENE
EXERCISE
A facility transitioned from combusting No. 6 fuel oil to
combusting No. 2 fuel oil during the reporting year. The facility
combusted 3,000 gallons of No. 6 fuel oil and 1,000,000 gallons
of No. 2 fuel oil in an utility boiler.
Has an activity threshold been exceeded?
Assume No. 6 fuel oil has a density of 8.0 pounds per gallon
and No. 2 fuel oil has a density of 7.0 pounds per gallon.
1-10
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PACs AND BENZO(G,H,I)PERYLENE
For more information:
1. Draft Guidance for Reporting Toxic Chemicals: Polycyclic Aromatic
Compounds Category. U.S. EPA, Office of Information Analysis and
Access. 2000. Available at http://www.epa.gov/tri
2. Using Systematic and Comparative Analytical Data to Identify the Source
of an Unknown Oil on Contaminated Birds. Wang, Z. et al. Journal of
Chromatography A. Volume 775, pp. 251-265.1997.
3. Compilation of Air Pollutant Emission Factors (AP-42), Volume 1, Fifth
Edition, Chapters 1.1,1.3, & 1.4. U.S. EPA, Office of Air Quality Planning
and Standards. 1998. Available at
http://www.epa.gov/ttn/chief/ap42/index.html
4. Locating And Estimating Air Emissions From Sources Of Polycyclic
Organic Matter. U.S. EPA, Office of Air Quality Planning and Standards.
1998. Available at http://www.epa.gov/ttn/chief/le/index.htnil
5. Transport and Fate ofnon-BTEX Petroleum Chemicals in Soil and
Groundwater. American Petroleum Institute, API Publication Number 4593.
1994. Available at http://global.ihs.com/
1-11
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DIOXIN AND DIOXIN-LIKE
COMPOUNDS (DLCs)
DIOXIN AND DIOXIN-LIKE COMPOUNDS
PBT activity threshold: 0.1 gram
Dioxin and dioxin-fike compounds (DLCs) category
qualifier reads:
"Manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the dioxin
and dioxin-like compounds are present as
contaminants in a chemical and if they were created
during the manufacturing of that chemical."
Qualifier designed to focus on new environmental loadings
of dioxin and DLCs
J-2
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Category includes polychlorinated dioxins and
furans with chlorine in at least the 2, 3, 7, and 8
positions
Dibenzo-p-dioxin Dibenzofuran
J-3
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Reporting must be based on total weight in grams of the
members of the dioxin and DLCs category
Quantities of dioxin and DLCs entered on the Form R or into ATRS
must be in grams by weight
Some literature contains information about dioxin and
DLCs emissions in terms of grams TEQ (toxicity
equivalency)
Do not use in threshold determinations
Do not report these values on Form R
TEQs are based on toxicity equivalency factors (TEFs) for
dioxins and DLCs, not just the weight
TEFs - estimates of the toxicity of dioxin and DLCs relative to the
toxicity of 2,3,7,8-TCDD
J-4
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Form R Part II, Section 1.4 allows for reporting the distribution
of each member of the dioxin and DLCs category as
percentages among the 17 category members. This is only
required if such information is available from the facility's data
used to report
Allows conversion of reported quantity into individual chemical
estimates and TEQs
List is in EPA's TRI Reporting Forms and Instructions document
1.4 Distribution of Each Member of the Dioxin and Dtoxin-llke Compounds Category.
(If there ire «ny numbers In boxes 1-17. th«n every field must be filled In with either 0 or some number between 0.01 and 100.
Distribution should be reported In percentages and the lotil should equal 100%. If you do not have speclatlon dall syllable. Indicate
NAJ1 2 345*78 9 10 11 12 13 14 18 1S 17
NAl
J-5
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Calculating Section 1.4 using EPA's default emission factors for oil-fired utility boilers
No.
1
2
3
A
5
6
7
6
6
Member Name
1. 2.3.4.0. 7,8-HpCBF
1,2.3.4,7,8.6-HpCBF
1. 1.3.4.7 .S-HxCDF
1, 2.3,6.7 ,8-HxCBF
1. 2,3,7 ,8,9-HxCDF
2,3.4.6,7.ft-HxfiBF
1.2,3.4 ,7 ,8-HxCBB
14.3.6,7 .8-HxfiBB
1, 2,3,7 ,8.9-HxCBB
concen&ation
(p&L oil)
164
0
76.5
15.4
0
23.6
634
(55.6
79.7
Relative
Percentage
5.16%
6%
2.4TC
1.11%
6%
6.75%
1.S6U
2.d7%
2.51%
/Vo.
10
\\
12
13
14
15
16
17
Member Name
1, 2.3.4,6.7 ,6-HpCDD
1,2 .3,4.6,7 ,6.9-OCDF
1, 2.3.4.6,7 ,6.§-6CBB
1, 2,4.7 ,6-PeCBF
2,3,4,7.8-PeCDF
1, 2,3.7 .6-P«CBB
2.3.7,6-TCBF
2,37,6-TCDB
Concentration
(pgA. oil)
477
0
2655
64.1
49.3
24.7
6
6
Relative
Percentage
15.01%
0%
64.65%
2.02%
1.55%
0.78%
6%
0%
Source: EPA's Ouldtnct for Reporting Toxic Chtmlctlt within tht Dioxin tnd Dhxin-Hkt Compounds
Ca(eoory(Ref. 1).
1.4 Distribution of Each Member of the Dioxin and Oloxin-like Compound* Category.
(If there ire «ny numbere In boxes 1-17. then every Held must be IWed In w«h emer 0 or some number between 001 and 100
Distribution should be reported In percentign and the tot»l should equal 100%. If you do not have speclaton dan available, indicate
NA.)1 234S67S 9 10 11 12 13 14 16 16 17
0 |o.75|l.
.997.07 2.S1
| 7.07 \ 1.55 10.78| 0 | 0
J-6
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Example calculation of emissions fora system that
emits 1 gram per year of Octachlorodibenzofuran
(ODCF) and 1 gram per year of 1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dioxin
Correct quantity to report on Form R is 2 grams
TEQ quantity is 0.0101 grams (TEFs are 0.0001 and 0.01)
J-7
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Dioxin and DLCs may be manufactured when chlorine-
containing materials are involved in combustion or other
high-temperature processes
Default air emission factors (Ref. 1):
1.71 nanograms of dioxin and DLCs per kilogram of coal
combusted in an utility boiler (equivalent to 1.55 grams per
million tons)
3.1786 nanograms of dioxin and DLCs per liter of fuel oil
combusted in an utility boiler (equivalent to 0.0120 grams
per million gallons)
12.2 nanograms of dioxin and DLCs per kilogram of
hazardous waste combusted in a boiler or industrial furnace
(other than a cement kiln) (equivalent to 11.1 grams per
million tons)
J-8
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Additional default air emission factors (Ref.1):
89.78 nanograms of dioxin and DLCs per kilogram of copper
scrap fed to a secondary copper smelter (equivalent to
0.0815 grams per thousand tons)
16.24 nanograms of dioxin and DLCs per kilogram of wood
(dry wt.) combusted in an utility boiler (equivalent to 14.73
grams per million tons)
2.4 nanograms of dioxin and DLCs per kilogram of wood
waste and bark (as fired) at pulp mills or lumber and wood
product industry facility boilers (equivalent to 2.2 grams per
million tons)
J-9
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Additional default factors (Ref.1):
105.7 picograms of dioxin and DLCs per liter of waste water
from bleached chemical pulp mills discharged to surface
water (equivalent to 0.400 grams per billion gallons)
500 nanograms of dioxin and DLCs per kilogram of waste
water sludge from bleached chemical pulp mills (equivalent
to 0.454 grams per thousand tons)
J-10
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
What needs to be done to exceed the 0.1 gram
activity threshold?
64,500 tons of coal need to be combusted in an utility boiler
to exceed the threshold
8.33 million gallons of fuel oil need to be combusted in a
utility boiler to exceed the threshold
1,230 tons copper scrap need to be fed to a secondary
copper smelter
J-11
DIOXIN AND DIOXIN-LIKE COMPOUNDS
For more information:
1. Guidance for Reporting Toxic Chemicals within the Dioxin
and Dioxin-llke Compounds Category. U.S. EPA, Office of
Information Analysis and Access. 2000. Available at
http://www.epa.gov/tri
2. Exposure and Human Health Reassessment of 2,3,7,8-
Tetrachlorodibenzo-p-dioxin (TCDD) and Related Compounds.
Part 1: Estimating Exposure to Dioxin-Like Compounds.
Volume 2: Sources of Dioxin-Like Compounds in the United
States. U.S. EPA, Office of Research and Development. 2000.
Available at
http://www.epa.gov/ncea/pdfs/dioxin/part1and2.htm
J-12
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MERCURY AND MERCURY COMPOUNDS
MERCURY AND MERCURY COMPOUNDS
PBT activity threshold:
- 10 pounds for mercury
10 pounds for mercury compounds
Mercury compounds are present in crude oil, fuel oils, and coal
Combustion of fuels is expected to be the main source of mercury
reporting
Mercury may be present in mined ores
K-2
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MERCURY AND MERCURY COMPOUNDS
Manufacturing
Fuel combustion
Metal mining and beneficiation
Petroleum refining
K-3
MERCURY AND MERCURY COMPOUNDS
Processing
Petroleum refineries and bulk petroleum stations
Coal mining and metal mining and beneficiation
Carbon black and coke production
Cement and clay products
Fabricated metal products
Electronic and electrical products (e.g., bulbs, switches,
batteries)
Other products (e.g., thermometers)
K-4
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MERCURY AND MERCURY COMPOUNDS
Otherwise use
Chlor-alkali production
Cement and clay products
Fabricated metal products
Electrical products (e.g., bulbs, switches, batteries)
Other products (e.g., thermometers)
K-5
MERCURY AND MERCURY COMPOUNDS
Mercury concentrations in light bulbs (Ref. 3):
Less than 40 milligrams per 4-foot fluorescent bulb
45-75 milligrams per high intensity discharge lamps
8-25 milligrams in sodium lamps
Use of bulbs - generally articles exempt
Articles exemption negated if > 0.5 pounds of Section 313
chemical released (and not recycled) during reporting year
from all like items
K-6
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MERCURY AND MERCURY COMPOUNDS
Mercury concentrations in coal and other materials:
Use the best readily available data. Usually, ICR data for
your facility if available
If ICR data for your facility not available, choices are:
» Develop an average from ICR data for the type of coal that your
facility burns (e.g., Pennsylvania bituminous) (Ref. 5)
» EPA's EPCRA Section 313 Industry Guidance: Electricity
Generating Facilities (Ref. 2)
» U.S. Geological Survey's (USGS) coal quality data base (Ref. 4)
» Other data
K-7
MERCURY AND MERCURY COMPOUNDS
Default concentrations in ash (Ref. 2):
No. 6 Fuel oil ash: 1 ppm as Hg; 1.04 ppm as Hg2O
Coal fly ash: 12 ppm as Hg; 12.5 ppm as Hg2O
Coal bottom ash: 4.2 ppm as Hg; 4.37 ppm as Hg20
K-8
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MERCURY AND MERCURY COMPOUNDS
Default air emission factors (Ref. 6):
Fluorescent lamp manufacturing: 8 Ibs./ton mercury
(uncontrolled)
Fluorescent lamp crushing: 1.9 Ibs./billion lamps (fabric
filter, carbon adsorber)
Thermometer manufacturing: 18 Ibs./ton mercury
(uncontrolled)
Coke production: 60 Ibs./million ton coke (fabric filter,
electrostatic precipitator (ESP))
Lime manufacture: 3.0 Ibs./million ton lime (fabric filter)
Carbon black manufacture: 300 Ibs./million ton carbon black
(fabric filter)
K-9
MERCURY AND MERCURY COMPOUNDS
Default air emission factors (Ref. 7):
Primary copper smelting: 78 lbs./million ton metal
Steel mill - electric arc furnace: 72 Ibs./million ton scrap feed
Ferrous foundries: 350 Ibs./million ton metal charged
Glass manufacture: 100 Ibs./million ton silica (particulate
matter (PM) control)
Brick manufacture, coal-fired: 96 Ibs./million ton brick
(uncontrolled)
Industrial/hazardous waste incinerators: 5.4 Ibs./thousand
ton waste incinerated
K-10
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MERCURY AND MERCURY COMPOUNDS
For more information:
1. Draft Guidance for Reporting Toxic Chemicals: Mercury and Mercury Compounds
Category. U.S. EPA, Office of Information Analysis and Access. 2000. Available at
http://www.epa.gov/tri
2. EPCRA Section 313 Industry Guidance: Electricity Generating Facilities. U.S. EPA,
Office of Pollution Prevention and Toxics. 2000. Available at http://www.epa.gov/trl
3. Mercury Study Report to Congress Volume II: An Inventory of Anthropogenic Mercury
Emissions In the United States. U.S. EPA, Office of Air Quality Planning and
Standards and Office of Research and Development. 1997. Available at
http://www.epa.gOv/ttnuatw1/112nmerc/mercury.html
4. U.S. Geological Survey Coal Quality (Coalqual) Database: Version 2.0. U.S. Geological
Survey. 2000. Available at http://energy.er.usgs.gov/products/databases/CoalQual/
5. Mercury ICR. U.S. EPA, Unified Air Toxics Website. 2000. Available at
http://www.epa.gov/ttnuatw1/combust/utiltox/utoxpg.htmWDA2
6. Locating A Estimating Air Emissions from Sources of Mercury and Mercury
Compounds. U.S. EPA, Office of Air Quality Planning and Standards, 1997. Available
at http://www.epa.gov/ttn/chlef/le/lndex.html
7. Final - Supplementary Guide for Reporting to the National Pollutant Release
Inventory-Alternate Thresholds-2000. Environment Canada, Pollution Data Branch.
2000. Available at http://www.ec.gc.ca/pdb/nprl/2000/lndex.htrnWGdocs
K-11
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PESTICIDES
PESTICIDES
RY 2000 PBT listed pesticides:
Pendimethalin
Trifluralin
Methoxychlor
Heptachlor
Toxaphene
Isodrin
Aldrin
Chlordane
All of these pesticides were already on the list of TRI
chemicals
L-2
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PESTICIDES
Potential reporting facilities include:
Manufacturers of the pesticides
Processors of the pesticides
TSDFs that manage pesticide-containing wastes may be
otherwise using the pesticides
EPA does not expect any additional reports on these
pesticides from users of pesticides
Most of these pesticides would not be used at reporting
facilities
Even if a reporting facility used one of these pesticides, the
use may qualify for the facility and grounds maintenance
exemption if use not process related
L-3
PENDIMETHALIN
PBT activity threshold: 100 pounds
Pendimethalin, also known as benzenamine, is
currently being used as an insecticide and herbicide
Primarily used as a herbicide on crops
58 pendimethalin products registered for agricultural,
domestic, and commercial uses and is applied by
broadcasting, directed spray and soil treatment
Releases of pendimethalin are expected to occur
from manufacturing, formulation, packaging, and
disposal activities associated with its use
L-4
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TRIFLURALIN
PBT activity threshold: 100 pounds
Trifluralin is a herbicide used primarily on cotton and
soybean crops
Releases of trifluralin are expected to occur from
manufacturing, formulation, packaging, and disposal
activities associated with its use
L-5
METHOXYCHLOR
PBT activity threshold: 100 pounds
Methoxychlor is an insecticide used to control
insects on agricultural crops, livestock, grain
storage, home gardens, and pets
Methoxychlor may be applied to large areas such as
beaches, estuaries, and marshes for control of flies
and mosquito larvae
It may also be used for spray treatment of garbage
and sewage areas
L-6
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HEPTACHLOR
PBT activity threshold: 10 pounds
Heptachlor was used as a broad-spectrum
insecticide on crops, home and gardens, and as a
seed treatment
Most uses of heptachlor were banned by EPA in
1978
Presently used to control fire ants in buried, pad-mounted
electric power transformers and in underground cable
television and telephone cable boxes
Manufacture in U.S. ceased in 1997
L-7
TOXAPHENE
PBT activity threshold: 10 pounds
Toxaphene was used as an insecticide since the late
1940s to control pests on cotton, vegetables,
livestock and poultry, and soybeans
Most domestic uses of toxaphene banned in 1990,
but still used as an insecticide on bananas and
pineapples in Puerto Rico and the Virgin Islands
L-8
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ISODRIN
PBT activity threshold: 10 pounds
Isodrin is an insecticide no longer manufactured or
used commercially in the U.S.
Isodrin may also be coincidentally manufactured
from coal mining, foundries, waste incineration, and
nonferrous metals manufacturing
L-9
ALDRIN
PBT activity threshold: 100 pounds
Aldrin was used as a soil insecticide on crops
beginning in the 1950s
Aldrin is not manufactured or used under any
circumstances in the U.S.
L-10
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CHLORDANE
PBT activity threshold: 10 pounds
Chlordane was used as a broad-spectrum insecticide
on:
Crops
Gardens
Landscaping
Termite and ant control
All end uses of chlordane were banned by EPA in
1988; however, still manufactured for export until
1997
L-11
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OTHER PBT CHEMICALS
OTHER PBT CHEMICALS
Polychlorinated biphenyls (PCBs)
Tetrabromobisphenol A (TBBPA)
Hexachlorobenzene (HCB)
Pentachlorobenzene
Octachlorostyrene (OCS)
M-2
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POLYCHLORINATED BIPHENYLS (PCBs)
PBT activity threshold: 10 pounds
Most manufacture of PCBs banned in 1976
Further restrictions on the use of PCBs
M-3
POLYCHLORINATED BIPHENYLS (PCBs)
Current and/or former products containing PCBs:
Dielectric agents
Heat transfer agents
Lubricants
Flame retardants
Plasticizers
Waterproofing materials
Used oils
M-4
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POLYCHLORINATED BIPHENYLS (PCBs)
Manufacturing
PCBs may be manufactured as a product of incomplete
combustion (PICs)
Processing
Recycling or reuse of PCBs
Otherwise use
Installation of PCBs into electrical equipment
On-site treating or disposing PCB-contaminated waste
received from off-site
Combusting PCB-contaminated oil
M-5
POLYCHLORINATED BIPHENYLS (PCBs)
Not manufacturing, processing, or otherwise use
On-site disposal or treatment of PCBs not received from off-
site
Off-site shipment of PCBs for disposal or treatment
M-6
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POLYCHLORINATED BIPHENYLS (PCBs)
Default air emission factors (Ref. 2):
Municipal waste combustion 5.5 Ibs./ million ton waste
burned
Medical waste incineration 46.5 Ibs./million ton waste
burned
Other biological incineration 46.5 Ibs./million ton waste
burned
Sewage sludge incineration 10.8 Ibs./million ton dry sludge
burned
Scrap tire incineration 378 Ibs./million ton tire burned
M-7
POLYCHLORINATED BIPHENYLS (PCBs)
Default air emission factors (Ref. 1):
Landfill waste gas flare 6.10 x 10-" Ib./million Btu heat input
Incineration (refuse derived fuel (RDF)) 180 Ibs./million ton
RDF burned
M-8
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POLYCHLORINATED BIPHENYLS (PCBs)
For more information:
1. Draft Guidance for Reporting Toxic Chemicals: Pesticides
and Other Persistent Bioaccumulativo Toxic (PUT)
Chemicals. U.S. EPA, Office of Information Analysis and
Access. 2000. Available at http://www.epa.gov/tri
2.1990 Emissions Inventory of Section 112(c)(6) Pollutants.
U.S. EPA. 1998. Available at
http://www.epa.gov/ttncaaa1/t3/meta/m23804.html
M-9
TETRABROMOBISPHENOL A (TBBPA)
PBT activity threshold: 100 pounds
TBBPA - flame retardant used in plastics and
engineering resins for printed circuit boards and
computer equipment
TBBPA is used in manufacturing polymers, such as
Acrylonitrile Butadiene Styrene (ABS)
Epoxy and polycarbonate resins
High-impact polystyrene
Phenolic resins
Adhesives
Unsaturated polyester resins
Thermoplastic polyesters
M-10
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TETRABROMOBISPHENOL A
TBBPA - used as a flame retardsnt two ways
Reactive TBBPA - chemically bound to a polymer backbone.
TBBPA ceases to exist, except for some small residual
amounts
» Used in a liquid epoxy mixture to make printed circuit
boards
Additive TBBPA - added to mixture, but not reacted. TBBPA
retains its chemical identity
» TBBPA concentrations can exceed 15% in some ABS
resins
M-11
TETRABROMOBISPHENOL A
What facilities are impacted?
Manufacturers and processors of TBBPA
Processors of plastics containing TBBPA, such as
manufacturers of printed circuit boards and computer
housings
Waste management facilities
Facilities using computers that contain TBBPA in
their housings not impacted
Probably qualify for the articles exemption
M-12
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HEXACHLOROBENZENE (HCB)
PBT activity threshold: 10 pounds
Up until 1985, manufactured as a pesticide/fungicide
used to treat wheat seeds, onions, and sorghum
Manufactured as an impurity or formed as a by-
product during production of maleic anhydride and
propazine, pentachlorophenol, pesticides,
chlorinated organic chemicals, chlorine gas
Impurity in pesticides (Ref. 4):
1,000 ppm in Dacthal
50 ppm in chlorothalonil and picloram
1 ppm in atrazine and simazine
100 ppm in lindane
500 ppm in pentachloronitrobenzene
M-13
HEXACHLOROBENZENE (HCB)
May be manufactured in refining operations
May be manufactured in coal-fired boilers
1.2 Ibs./million ton coal burned in an utility boiler (Ref. 2)
0.16 lb./million ton coal burned in an industrial boiler (Ref. 2)
Other combustion
Wood/bark waste combustion 0.12 lb./million ton wood
waste burned (Ref. 2)
M-14
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HEXACHLOROBENZENE (HCB)
Incineration of waste manufactures HCB (Ref. 2):
58 Ibs./million ton municipal waste burned (single
chamber/waterwall with electrostatic precipitator (ESP)/dry
scrubber)
1.714 Ibs./million ton biomedical waste incinerated
0.66 Ib./million ton dry sewage sludge incinerated
538 Ibs./million ton wood waste/municipal refuse burned
(uncontrolled)
M-15
HEXACHLOROBENZENE (HCB)
May be manufactured in the production of carbon
tetrachloride, perchloroethylene, trichloroethylene,
ethylene dichloride, and 1,1,1-trichloroethane
Usually found in the still bottoms from chlorinated organic
chemical purification
Is emitted to air from from chlorinated organic chemical
purification (Ref. 3)
» 81.0 Ibs. emitted/thousand ton carbon tetrachloride
produced
» 86.2 Ibs. emitted/thousand ton perchloroethylene
produced
M-16
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HEXACHLOROBENZENE (HCB)
May be manufactured during high-temperature
processes involving chlorine atoms
Cement manufacturing
» 0.34 Ib./million ton clinker produced (controlled) (Ref. 2)
M-17
HEXACHLOROBENZENE (HCB)
Manufactured at metal foundries/smelters
Magnesium production - magnesium chloride reduced at
carbon electrode and produces chlorinated organics (Ref.1)
M-18
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HEXACHLOROBENZENE (HCB)
For more information:
1. Draft Guidance for Reporting Toxic Chemicals: Pesticides and Other
Persistent Bioaccumulative Toxic (PBT) Chemicals. U.S. EPA, Office of
Information Analysis and Access. 2000. Available at http://www.epa.gov/tri
2. FinalSupplementary Guide for Reporting to the National Pollutant
Release InventoryAlternate Thresholds-2000. Environment Canada,
Pollution Data Branch. 2000. Available at
http://www.ec.gc.ca/pdb/npri/index.html
3. Estimation of National Hexachlorobenzene Emissions for 1990. U.S. EPA,
Office of Air Quality Planning and Standards. 1993.
4. 1990 Emissions Inventory of Section 112(c)(6) Pollutants. U.S. EPA,
Emissions, Monitoring and Analysis Division and Air Quality Strategies and
Standards Division. 1998. Available at
http://www.epa.gov/ttncaaa1/t3/meta/m23804.html
M-19
PENTACHLOROBENZENE
PBT activity threshold: 10 pounds
Manufactured and processed as an intermediate in
pentachloronitrobenzene production
Pentachlorobenzene is an impurity in
pentachloronitrobenzene
Pentachlorobenzene also found in wastes from
pentachloronitrobenzene production
M-20
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PENTACHLOROBENZENE
Any high-temperature process involving chlorine
may manufacture pentachlorobenzene
Waste incinerators, cement kilns, and secondary copper
production
Pentachlorobenzene is expected to be found where
HCB found
M-21
OCTACHLOROSTYRENE
PBT activity threshold: 10 pounds
No commercial uses known
Possible byproduct of chlorine production,
chlorination reactions, and metal product/finishing
operations
Manufactured by the high-temperature incineration
of chlorinated hydrocarbons
Octachlorostyrene expected to be found where HCB
found
M-22
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