United States Office of Information March 2002
Environmental Protection Analysis and Access
Agency
EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT SECTION 313
EPCRA/TRI TRAINING MATERIALS
Reporting Year 2001
Spring 2002
Module 2: PBT and Lead 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
2001, for reports due on July 1,2002. Facilities should be aware that EPA may promulgate
regulatory changes to the EPCRA section 313 program that may alter reporting requirements for
future reporting years.
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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 applied beginning RY 2000
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, Isodrfn,
Methoxychlor, Pendimethalin, Toxaphene, and Trlfluralin
• Aromatics - Benzo(g,h,l)perylene, Polycyclic aromatic
compounds (PAC) category, Dioxin and dloxin-llke
compounds category, Hexachlorobenzene,
Octachlorostyrene, Pentachlorobenzene, Polychlorlnated
blphenyls (PCB), and Tetrabromobisphenol A (TBBPA)
• Metals - Mercury and Mercury compounds
H-3
PBT CHEMICALS AND THRESHOLDS
Manufacture, process, and otherwise use thresholds:
• 100lbsJyr- Aldrin Polycyclic Aromatic Cmpds.
Methoxychlor Tetrabromobisphenol A
Pendimethalin Trlfluralin
• 10lbs7yr- Chlordane Benzo(g,hrl)perylene
Heptachlor Hexachlorobenzene
Mercury Mercury compounds
Toxaphene Octachlorostyrene
Isodrln Pentachlorobenzene
PCBs
• 0.1 g/yr - Dioxin and dloxln-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*
* 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 de minlmis 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 de
mlnlmls exemption means that a more thorough
review of chemical activities may be needed to
achieve compliance with the PBT chemical rule
• Impurities need to be evaluated regardless of concentration
• As always, chemicals used In low volumes need to be
considered
H-7
SUPPLIER NOTIFICATION
The supplier notification requirements have not changed
The de mlnlmls 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, based on the activity, the 25,000/10,000 pound
threshold may be used
• 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
may 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
» Requires reporting of the distribution of each member of the
dloxln and dloxln-llke category as percentages among the 17
category members If the data are available
• When reporting on dioxln and dloxln-like category, TRI-ME/ATRS
will automatically recognize units of measure as grams
• TRI-ME/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 (Part II, Sections 5,6 of
FormR)
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,l)perylene threshold: 10 pounds
3-Methylcholanthrene and Benzo(j,k)fluorene
(fluoranthene) were added as members of the PAC
category
All members (new and old) of the expanded PAC category
are PBT chemicals
Benzo(g,h,l)perylene Is an Individually listed polycyclic
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)anthracane
B»nzo(b)fluoranthan»
Benzo(J)fluoranthena
Benzo(k)fluoranth*na
Banzo(J,k)fluoran* (fluoranthena)*
Benzo(r,a,t)p«ntaph«n*
Benzo(a)phenanthren« (chryaana)
Banzo(a)pyrana
Dlbanz(a,h)aerldina
Dlb«nz(a,j)acrldln«
Dlbenzo(a>h)anthracena
7H-Dlb«nzo(c,g)carbazol0
Dlbanzo(a,a)fluoranthana
Dlbenzo(a,e)pyrane
Dlbenzo(a,h)pyrana
Dlbanzo(a,l)pyrena
7,12-Dlmathylbanz(a)anthracana
lndeno(1,2,3-cd)pyrane
3-Methylcholanthrene*
5-Methylchryaene
1-Nltropyrana
* 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
1-4
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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* 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 Of Polycyclic Organic Matter (Ret 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 transltioned 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. Quldanca for Reporting Toxic Chamlcala: Polycyelle Aromatic Compound*
Category. U.S. EPA, Office of Information Analytic and Aecees. August
2001. Available at http:7Avww.apa.gov/trl
2. Ualng Syatamatlc and Comparatlvf Analytical Data to Identify tha Source
of an Unknown OH on Contaminated Blrda. Wang, Z. «t al. Journal of
Chromatography A. Voluma 775, pp. 251-265.1907.
3. Compilation of Air Pollutant Emlaalon Factora (AP-42), Voluma 1, Fltth
Edition, Chaptara 1.1,1.3, & 1.4. U.S. EPA, Offlct of Air Quality Planning
and Standards. 1094. Avallabla at
http://www.epa.gov/ttn/chlef/ap42/lndex.html
4. Locating And Eat/mating Air Emlaalona From Sourcaa Of Polycyelle
Organic Mattar. U.S. EPA, Offlea of Air Quality Planning and Standard*.
1998. Avallabla at http://www.apa.gov/ttn/chlaf/la/lndax.html
5. Tranaport and Fata of non-BTEX Patrolaum Chamleala In Soil and
Oroundwatar. American Patrolaum Institute, API Publication Number 4593.
1994. Avallabla at http://global.lhs.com/
M1
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DIOXIN AND DIOXIN-LIKE
COMPOUNDS (DLCs)
DIOXIN AND DIOXIN-LIKE COMPOUNDS
PBT activity threshold: 0.1 gram
Dioxfn and dioxin-like 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
1
8,
J-3
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Reporting must be based on total weight in grams of the
members of the dloxin and DLCs category
• Quantities of dloxin and DLCs entered on the Form R or Into
TRI-ME/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
dioxin and DLCs, not just the weight
• TEFs - estimates of the toxicity of dloxin 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 requires reporting of the distribution
of each member of the dloxin and DLCs category at
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 TEQa
• List Is In EPA's TRI Reporting Form* and Instruction* document
• Do not check NA unless you are reporting for dloxin and DLCs
1.4 Attribution of Each Mambar of «ha Dloxin and tMoxIn-UK* Compounds Category.
(If tan M wy mtm In torn M7. fin my Hd nut b* Mid It •» •*•> 0 or Mm nuifar Mmn M1ind100.0UMufeniha«l»iq>oiMdln
wd ta «M «»M «Ml 100%. H yw do M tan VNMkn dm MM* McM NA.)
J-5
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Calculating Sactlon 1.4 ualng EPA'a dafault amlaalen factor* (or oll-flrad utility bollara
Wo.
Concentration
(POt oil)
RtlttVf
P»rc»nt»gt
No.
MtmbirNtmt
Conctntrttton
RUfltvt
U,3,4,e.7,B-HpCDF
164
8.1 6%
10
1 ,2,3,4 ,e,7,B-HpCDD
477
19.01%
0%
11
U.3,4,8,7.8,0-OCDF
0%
76.5
2.41%
12
205S
84.85%
1 £3,6.7 A-HlCDF
35^
1.11%
13
1i,3.7,8-P»COF
64.1
2.02%
0%
14
2,3,4,7,8-P»CDF
49.3
146%
233
0.75%
18
1 ,2,3,7 ,8-P«CDD
24.7
0.78%
U,3.4,7.8-H)CDD
63.3
1.88%
18
0%
142,3,6,7,8-H)CDD
6S.8
2.07%
17
2J.73-TCDD
0%
78.7
251%
Sourea: EPA'a OuMtaet for ^porting ToiAo Cit*nlc4* within «M Dloxin tnd Dhudn-ttkt Compound!
. 1).
Witrlbutkxi of Each Mambarof UM Dtoxln and Oloxln-tlka Compound* Catagory.
»M
i 2
INAO"
3 4 8 e 7 S 9 10 11 12 13 14 18 U 17
0 |2.41|1.11
0 |0.75|1.99|2.07|2.51|1S.OO| 0 |64.6SJ 2.02 1 1,55 |o.78| 0 | 0 |
J-6
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DIOXIN AND DIOXIN-LIKE COMPOUNDS
Example calculation of emissions for a system that
emits 1 gram per year of Octachlorodibenzofuran
(OCDF) and 1 gram per year of 1,2,3,4,6,7,8-
Heptachlorodibenzo-p-dloxin
• Correct quantity to report on Form R Is 2 grams
• Do not use the TEQ quantity, which Is 0.0101 grams (TEFs
are 0.0001 and 0.01)
J-7
DIOXIN AND DIOXIN-LIKE COMPOUNDS
Dioxln 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 dloxln and DLCs per kilogram of coal
combusted In an utility boiler (equivalent to 1.55 grams per
million tons)
• 3,178.6 nanograms (or 3.1786 plcograms) 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 dloxln 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 dloxln 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 dloxln 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 million 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
Examples of activities that 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 Dloxln
and Dloxln-llke Compounds Category. U.S. EPA, Office of
Information Analysis and Access. December 2000. Available at
http://www.epa.gov/trl
2. Exposure and Human Health Reassessment of 2,3,7,8-
Tetrachlorodlbonzo-p-dloxln (TCDD) and Related Compounds.
Part 1: Estimating Exposure to Dtoxln-Uke Compounds.
Volume 2: Sources ofDIoxIn-LIke Compounds In the United
States. U.S. EPA, Office of Research and Development. 2000.
Available at
http://www.epa.gov/ncea/pdfs/dioxln/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 beneficlatlon
• Petroleum refining
K-3
MERCURY AND MERCURY COMPOUNDS
Processing
• Petroleum refineries and bulk petroleum stations
• Coal mining and metal mining and beneficlatlon
• 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 bums (e.g., Pennsylvania bituminous) (Ref. 5)
» EPA's EPCRA Section 313 Industry Guidance: Electricity
Generating Facilities (Ref. 2)
» U.S. Geological Surveys (USQS) 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 Hg20
• Coal fly ash: 12 ppm as Hg; 12.5 ppm as Hg2O
• Coal bottom ash: 4.2 ppm as Hg; 4.37 ppm as Hg2O
K-8
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MERCURY AND MERCURY COMPOUNDS
Default air emission factors (Ref. 6):
• Fluorescent lamp manufacturing: 8 IbsTton mercury
(uncontrolled)
• Fluorescent lamp crushing: 1.9 Ibs^blllion lamps (fabric
filter, carbon adsorber)
• Thermometer manufacturing: 18 IbsJton mercury
(uncontrolled)
• Coke production: 50 lbs./mlllfon ton coke (fabric filter,
electrostatic preclpltator (ESP))
• Lime manufacture: 3.0 IbsVmllllon ton lime produced
(natural gas-fed vertical kiln)
• Carbon black manufacture: 300 Ibs7mllllon ton carbon black
(fabric filter)
K-9
MERCURY AND MERCURY COMPOUNDS
Default air emission factors (Ref. 7):
• Primary copper smelting: 78 lbs./mllllon ton metal
• Steel mill - electric arc furnace: 72 IbsVmillion ton scrap feed
• Ferrous foundries: 348 lbs./milllon ton metal charged
• Glass manufacture: 100 lbs./mlllion ton silica (partlculate
matter (PM) control)
• Brick manufacture, coal-fired: 96 IbsJmlllion 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 . Guidance for Reporting Toxic Chemlcalt: Mtreuiy utd Mercury Compound*
Category, U.S. EPA, Office of Information Analysis and Access. August 2001.
Available at http://www.apa.BOV/ti1
2. EPCRA Section 313 Industry Guidance: Electricity Generating Facilities. U.S. EPA,
Offlcs of Pollution Prevention and Toxics. 2000. Available at http://www.spa.gov/trl
3. Mercury Study Report to Congnu Volume II: An Inventory of Anthropogenic Mercury
Emlielon* In the United Statee. U.S. EPA, Off let of Air Quality Planning and
Standards and Office of Research and Development 1987. Available at
http://www.sDa.gov/nn/«tw/1 12nm*rc/msrcury.html
4. U.S. Geological Survey Coal Quality (Coalqual) Datmoaee: Verelon 2.0. U.S. Geological
Survey. 2000. Available at http://eittrgy.sr.uaga.gov/producta/databaaea/CoalQual/
5. Mercury KR. U.S. EPA, Unified Air Toxics Website. 2000. Available at
http://www.apa.gov/ttniutw1/combusVuUltox/utoxpg.htmMDA2
6. Locating A Eetlmating Air Emletlont from Source* of Mercury and Mercury
Compound*. U.S. EPA, Office of Air Quality Planning and Standards, 1 997. Available
at http://www.epa.gov/ltn/chleMs/lndsx.html
K-11
7.
http-V/www.ec.gc.ca/pdb/nprl/nprl_gdocs_s.cfm
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PESTICIDES
PESTICIDES
RY 2000 PBT listed pesticides:
• Pendlmethalin
• 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 is currently being used as an
insecticide and herbicide
• Primarily used as a herbicide on crops
• 58 pendlmethalln 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
-------
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
-------
OTHER PBT CHEMICALS
OTHER PBT CHEMICALS
Polychlorinated biphenyls (PCBs)
Tetrabromobisphenol A (TBBPA)
Hexachlorobenzene (HCB)
Pentachlorobenzene
Octachlorostyrene (OCS)
M-2
-------
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
• Plasticlzers
• Waterproofing materials
• Used oils
M-4
-------
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-slte treating or disposing PCB-contaminated waste
received from off-site
• Combusting PCB-contamtnated 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
-------
POLYCHLORINATED BIPHENYLS (PCBs)
Default air emission factors (Ref. 2):
• Municipal waste combustion 5.5 IbsJ million ton waste
burned
• Medical waste Incineration 46.5 IbsJmllllon ton waste
burned
• Other biological Incineration 46.5 IbsJmllllon ton waste
burned
• Sewage sludge Incineration 10.8 IbsJmlllion ton dry sludge
burned
• Scrap tire Incineration 3.78 IbsVmllllon ton tire burned
M-7
POLYCHLORINATED BIPHENYLS (PCBs)
Default air emission factors (Ref. 1):
• Landfill waste gas flare 6.10 x 10^ Ibymilllon Btu heat Input
• Incineration (refuse derived fuel (RDF)) 180 IbsJmillion ton
RDF burned
M-8
-------
POLYCHLORINATED BIPHENYLS (PCBs)
For more information:
1. Guidance for Reporting Toxic Chemicals: Pesticides and
Other Persistent Bloaccumulatlve Toxic (PBT) Chemicals.
U.S. EPA, Office of Information Analysis and Access.
August 2001. Available at
http://www.epa.gov/tri/guidance.htm
2. 1990 Emissions Inventory of Section 112(c)(6) Pollutants.
U.S. EPA. 1998. Available at
http://www.epa.gov/ttncaaa1A3/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
-------
TETRABROMOBISPHENOL A
TBBPA - used as a flame retardant 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
-------
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
propazlne, pentachlorophenol, pesticides,
chlorinated organic chemicals, chlorine gas
• Impurity in pesticides (Ref. 4):
• 1,000 ppm In Dacthal
• 50 ppm In chlorothalonll and plcloram
• 1 ppm In atrazlne and slmazlne
• 100 ppm In llndane
• 500 ppm In pentachloronltrobenzene
M-13
HEXACHLOROBENZENE (HCB)
May be manufactured In refining operations
May be manufactured in coal-fired boilers
• 1.2 Ibs7mlllion ton coal burned In an utility boiler (Ref. 2)
• 0.16 IbVmilllon ton coal burned In an Industrial boiler (Ref. 2)
Other combustion
• Wood/bark waste combustion 0.12 IbJmIIlion ton wood
waste burned (Ref. 2)
M-14
-------
HEXACHLOROBENZENE (HCB)
Incineration of waste manufactures HCB (Ref. 2):
• 58.0 Ibsymllllon ton municipal waste burned (single
chamber/waterwall with electrostatic preclpltator (ESPXdry
scrubber)
• 1.71 Ibsymllllon ton blomedlcal waste Incinerated
• 0.660 Ibymlllion ton dry sewage sludge Incinerated
• 538 Ibsymllllon ton wood waste/municipal refuse burned
(uncontrolled)
M-15
HEXACHLOROBENZENE (HCB)
May be manufactured in the production of carbon
tetrachlorlde, perchloroethylene, trichloroethylene,
ethylene dichlorlde, and 1,1,1-trIchloroethane
• Usually found In the still bottoms from chlorinated organic
chemical purification
• Is emitted to air from chlorinated organic chemical
purification (Ref. 3)
» 81.0 IDS. emitted/thousand ton carbon tetrachloride
produced
» 86.2 Ibs. emitted/thousand ton perchloroethylene
produced
M-16
-------
HEXACHLOROBENZENE (HCB)
May be manufactured during high-temperature
processes involving chlorine atoms
• Cement manufacturing
» 0.34 IbVmilllon ton clinker produced (controlled) (Ref. 2)
Manufactured at metal foundries/smelters
• Magnesium production - magnesium chloride reduced at
carbon electrode and produces chlorinated organlcs (Ref.1)
M-17
HEXACHLOROBENZENE (HCB)
For more information:
1. Guidance for Reporting Toxic Chemicals: Pesticides and Other Persistent
Bloaccumulatlve Toxic (PBT) Chemicals. U.S. EPA, Office of Information
Analysis and Access. August 2001. Available at http://Www.epa.gov/trl
2. Final—Supplementary Guide for Reporting to the National Pollutant
Release Inventory—Alternate Thresholds-2000 and Emission Factor and
Database for Alternate Threshold Substances. Environment Canada,
Pollution Data Branch. 2000. Available at
http://www.ec.gc.ca/pdb/nprl/lndex.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/Hncaaa1/l3/meta/m23804.html
M-18
-------
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-19
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-20
-------
OCTACHLOROSTYRENE
PBT activity threshold: 10 pounds
No commercial uses known
Possible byproduct of chlorine production,
chlorlnation reactions, and metal product/finishing
operations
Manufactured by the high-temperature incineration
of chlorinated hydrocarbons
Octachlorostyrene expected to be found where HCB
found
M-21
-------
Lead and Lead Compounds:
The New Lead Rule
TOPICS
Sources of lead and lead compounds
Overview of the reporting changes
Alloy qualifications
Exemptions
Threshold determinations (example calculations)
Release and other waste management reporting
(example calculations)
TRI homepage http://www.epa.gov/tri
U-2
-------
LEAD AND LEAD COMPOUNDS
• Elemental lead is rarely found in nature; it
most commonly occurs as the mineral
galena (lead sulfide [PbS])
• Typically combined with other materials
for use as an alloy or a lead compound
• Types of lead compounds include:
• Organolead compounds
• Lead oxides
• Lead su If ides
• Lead salts
• Lead is obtained from mining and
recycling
U-3
LEAD IN RAW MATERIALS
• Raw materials processed by a variety of
facilities may contain metallic lead or lead
compounds:
• Metal ores
• Coal
• Wood
• Oil
• Oil products
» heating oils
» gasolines
• Use (including combustion) of materials
containing lead or lead compounds could
trigger TRI reporting.
U-4
-------
Typical Concentration of Lead in Raw
Materials and Quantity Required to Meet
100 Ib. Threshold*
Bituminous
coal
3 to 111
3.33xl07to
9.01xl05lbs
Subbituminous
coal
2.07 to 31
4.83xl07to
3.23xl06lbs
Lignite coal
3.73 to 9.8
2.68 x!07to
1.02xl07lbs
Wood
20
5.00xl06lbs
'Emergency Planning and Community Rlght-to-Know Act-Section 313: Guidance
for Reporting Releases and Other Waste Management Activities of Toxic U-5
Chemicals: Lead and Lead Compounds
COMBUSTION OF FUELS
CONTAINING LEAD
Metal compounds and elemental metals
in fuel are typically converted to metal
oxides during combustion
• This is considered to be manufacturing
If no other data are available, assume the
compound formed is the lowest molecular
weight metal oxide
Example:
a Lead in fuel -*• Assume PbO Is manufactured
(not PbO2, Pb3O4, etc.)
U-6
-------
LEAD RULE REPORTING
THRESHOLD
Reporting threshold lowered to 100
pounds for manufacturing, processing, or
otherwise use of lead (except In stainless
steel, brass and bronze alloys) or lead
compounds.
Effective for TRI reporting year 2001
(covering activities from January 1
through December 31, 2001), for reports
to be filed on or before July 1, 2002.
U-7
LEAD/LEAD COMPOUND
THRESHOLDS
• There is one TRI listing for lead, but three
reporting thresholds may apply:
• For all lead (including lead In stainless steel,
brass, and bronze alloys):
» 25,000 Ibs for manufacturing and processing
» 10,000 Ibs for otherwise use
• For lead not In stainless steel, brass, and
bronze alloys:
» 100 Ibs for manufacturing, processing, and
otherwise use
• For lead compounds, there is only one
threshold that applies:
» 100 Ibs for manufacturing, processing, and
otherwise use
U-8
-------
OTHER APPLICABLE PBT RULE
• PBT changes for lead (except in stainless
steel, brass and bronze alloys) and lead
compounds
• Eliminated the tie mlnlmis exemption for lead
and lead compounds
• Eliminated the use of the alternate threshold of
1,000,000 pounds and thus the Form A
certification statement
• Eliminated the use of range reporting in
Sections 5 and 6 of Part II the Form R
• Adds additional data reporting precision (e.g.,
to one-tenth of a pound where applicable)
U-9
DATA PRECISION
Scenario
Load contained in mixtures
What Is the Smallest
Quantity That TRI
Requires?
0.1 pounds
0.1 pounds
U-10
-------
ALLOY QUALIFICATION
• What is an alloy?
A solid mixture containing two or
more elements, at least one of which is a
metal.
Why the alloy qualification?
EPA deferred making a final decision
on the lower reporting threshold until a
scientific review of the alloy issues is
complete.
U-11
ALLOY QUALIFICATION
If you process or otherwise use lead only In
stainless steel, brass, and bronze alloys, the lead
rule has not changed your reporting
requirements.
• Remember, If some elemental lead is removed from
the qualified alloy, such as vaporization during
melting of an alloy, the 100 pound threshold applies
to the amount of read removed (e.g., processed)
from the alloy.
You may still report as you did before when you
exceed the 25,000 pound threshold for
manufacturing and processing or the 10,000
pound threshold for otherwise use.
The da mlnlmls exemption can still be taken: you
may still be eligible for the alternate threshold of
1,000.000 pounds and use of the Form A
certification statement If applicable, and range
reporting can be used In Sections 5 and 6 ofPart
II of the Form R.
U-12
-------
I
r
c
Examples in which lead-containing materials
nay be exempt* from threshold
leterminations and release calculations.
The Use of :
Bricks used to construct a building
Lead-acid batteries
Solder used to fix a part on a forklift
A lead-containing mixture used as a
reactant In a routine lab analysis
Plant/process Intake air or water
Charcoal for barbecues
Exemption
Activity Use - Structural
Article
Activity Use -Motor Vehicle
Laboratory Activities
Activity Use -
Process water and Intake all
Activity Use - Personal use
These exemptions do not apply whan manufacturing
U-13
THRESHOLD DETERMINATION
• Subsequent threshold determination
examples apply specifically to:
• Lead and load compounds => lead/lead
compound examples (2)
• Lead In alloys => alloy examples (2)
• Each example spans several slides:
• Each example group has an Introduction and
conclusion to Illustrate key points
• Each example answers the following questions:
» What amount of load or lead compounds
has been manufactured, processed, or
otherwise used?
» Has a threshold been exceeded?
U-14
-------
THRESHOLD DETERMINATIONS
• Stepl: Identify all activities where the chemical is
used at your facility
• Manufacturing
• Processing
• Otherwise use
• Step 2: Obtain or estimate chemical composition
data for raw materials and manufactured products
• Step 3: Calculate the amounts of the chemical
manufactured, processed, and otherwise used
• Step 4: Compare the calculated amounts used to
the respective threshold(s) to determine whether
any thresholds have been exceeded, I.e, whether
an EPCRA Section 313 Report is required
U-15
LEAD/LEAD COMPOUND
EXAMPLES
• Lead/lead compound examples #1 & #2:
• Facilities that manufacture, process, or
otherwise use both lead and lead compounds
• Goals:
• Apply the four basic steps for performing
threshold determinations for load compounds
• Determine whether an EPCRA Section 313
Report is required for each scenario
U-16
-------
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal is used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Questions:
1) What amount of lead was otherwise used?
2) Has a threshold for otherwise using lead been
exceeded?
3) What amount of lead compound* was
colncldentally manufactured?
4) Has the threshold for manufacturing lead
compounds been exceeded?
U-17
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal is used to fire
boilers. The coal contains lead at 7.00 ppmw.
Question 1: What amount of lead was
otherwise used?
U-18
-------
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal Is used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Question 1: What amount of lead was
otherwise used?
Lead in coal:
(13,600,000 pounds) (0.000700%) = 95.2 pounds
U-19
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal Is used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Question 2: Has a threshold for otherwise
using lead been exceeded?
Lead in coal:
(13,600,000 pounds) (0.000700%) = 95.2 pounds
No. 95.2 pounds is less than the 100 pound
threshold for otherwise using lead.
U-20
-------
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal la used to fire
boilers. The coal contains lead at 7.00 ppmw.
Assume for demonstration purposes In this
example that It Is elemental lead. However, In a
real analysis, It would probably be a lead
compound. Lacking better Information,
assume lowest-weight oxide - PbO.
Question 3: What amount of lead
compounds was colncldentally
manufactured?
U-21
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal is used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Question 3: What amount of lead
compounds was colncidentally
manufactured?
223 pounds PbO formed for every 207 pounds Pb used.
Total PbO formed • (95.2 pounds)(223/207)»103 pounds
U-22
-------
LEAD/LEAD COMPOUNDS EX. #1
• Consider a facility that otherwise uses
lead and manufactures lead compounds
during combustion:
• 13,600,000 pounds of coal Is used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Question 4: Has the threshold for
manufacturing lead compounds been
exceeded?
223 pounds PbO formed for every 207 pounds Pb used.
Total PbO formed = (95.2 pounds)(223/207) • 103 pounds
Yes. 103 pounds Is more than the 100 pound
threshold for manufacturing lead compounds.
U-23
POSSIBL
•F
le
E OUTCOMES
Outcome of Threshold
: *;\ Determination "
Thresholds not exceeded for
either lead or lead
compounds
Threshold exceeded for
lead, but not for lead
compounds
Threshold exceeded for lead
compounds, but not for lead
Thresholds exceeded for
both lead and lead
compounds
, What Type of Reporting Is
, >-',.^ "Required? r"<' ;
None
Report for lead, but not for
lead compounds *
Report for lead compounds,
but not for lead *
Report for both lead and leac
compounds, either on a
single form (for lead
compounds) or on two forms
(one for lead and the other
for lead compounds) *
Releases and waste management quantities for lead and
ad compounds are expressed as the parent metal, lead.
-------
LEAD/LEAD COMPOUNDS EX. #2
• Consider a facility that processes the following
two materials that Include lead or lead
compounds:
• 10,000,000 pound* of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint containing
"<2%" lead chromate Is applied to furniture
products.
• Questions:
1) What amount of /aadwas processed?
2) Has a threshold for processing lead been exceeded?
3) What amount of lead compounds were processed?
4) Has the threshold for processing lead compounds
been exceeded?
U-25
LEAD/LEAD COMPOUNDS EX. #2
• Consider a facility that processes the
following two materials that include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate Is applied to
furniture products.
Question 1: What amount of lead was
processed?
(10,000,000 pounds)(0.002%) = 200 pounds
U-26
-------
LEAD/LEAD COMPOUNDS EX. #2
• Consider a facility that processes the
following two materials that Include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate Is applied to
furniture products.
Question 2: Has a threshold for
processing toad been exceeded?
(10,000,000 pounde)(0.002%) = 200 pounds
Yes. 200 pounds Is more than the 100 pound
threshold for processing lead.
U-27
LEAD/LEAD COMPOUNDS EX. #2
• Consider a facility that processes the
following two materials that include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate Is applied to
furniture products.
Question 3: What amount of lead
compounds was processed?
U-28
-------
LEAD/LEAD COMPOUNDS EX. #2
u Consider a facility that processes the
following two materials that include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate Is applied to
furniture products.
Question 3: What amount of lead
compounds was processed?
(20,000 pounds)(2%) = 400 pounds
U-29
LEAD/LEAD COMPOUNDS EX. #2
• Consider a facility that processes the
following two materials that include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate is applied to
furniture products.
Question 4: Has the threshold for
processing lead compounds been
exceeded?
(20,000 pounds)(2%) = 400 pounds
Yes. 400 pounds Is more than the 100 pound
threshold for processing lead compounds, u-30
-------
POSSIBLE OUTCOMES
Outcome of Threshold
Determination
Thresholds not exceeded for
either lead or lead
compounds
Threshold exceeded for
lead, but not for lead
compounds
Threshold exceeded for lead
compounds, but not for lead
Thresholds exceeded for
both lead and lead
compounds
What Type of Reporting Is
Required?
None
Report for lead, but not for
lead compounds *
Report for lead compounds,
but not for lead *
Report for both lead and lead
compounds, either on a
single form (for lead
compounds) or on two forms
(one for lead and the other
for lead compounds) *
•Releases and waste management quantities for lead andy_31
lead compounds are expressed as the parent metal, lead.
LEAD/LEAD COMP. EX. KEY POINTS
• As appropriate, calculate two thresholds:
one for lead and one for lead compounds.
• Consider all known forms of lead
compounds in your threshold
determinations.
• Sometimes release calculations must be
done to determine thresholds.
• Do not add the lead within lead
compounds to your threshold for lead.
• Do not add usage of elemental lead to
your threshold for lead compounds.
• Base your threshold for lead compounds
on the total weight of the compounds, not
the lead within me compounds.
U-32
-------
LEAD ALLOY EXAMPLES
• Lead alloy examples #1 & #2:
• Facilities that process lead, in varying
amounts, both in and not in stainless steel,
brass, and bronze alloys
Goals:
• Follow the four basic steps for performing
threshold determinations for lead both in and
not in stainless steel, brass, and bronze alloys
• Determine whether an EPCRA Section 313
Report Is required for each scenario
U-33
LEAD THRESHOLD DETERMINATION FLOW
CHART
Activity Threshold! and Reporting Requirement* for Lead Related to
StilnleM Steel, Braaa or Bronze Alloy Qualifier
(Th<» now ch*rt <*<>•• not «ppiy to L»*d Compounds, • Mparatoly ll«t*d TRI eh*mlcaf)
Did the facility exceed the 100 Ib threshold
cotuidering only teid not in itainkis steel,
^ brass or bronze alloy?
f Did the facility exceed the 100 Ib threshold
conildcring only lead not in lUintesi steel,
I brass or bronze alloy?
YES
NO
\
No reporting for
lead required.
Muit ute Form R, without
nn|e reporting in Sections 5
•ndfiofPavtll.
Report relciies and (nuiifcn
from BOTH lad k. tUinleu
ueel, bnui or bronze tltoy
and lead not hi tuinleu
•Kel, bfi*i or bmnze altoy.
Miy use Form A or Form R;
range reporting can be uaed
in Section* 5 and 6 of Pan II.
Report icleuei nd trwufcn
from BOTH lead fa .tainle»
uccL bnai or broaie alloy
and lead not In atainleu
ileel, brew or bronze alloy.
U-34
-------
ALLOY EXAMPLE #1
Consider a facility that processes the
following two alloys that include:
• 20,000 pounds of lead In a stainless steel alloy.
• 275 pounds of lead In another alloy that Is not
stainless steel, brass, or bronze.
Questions:
1) What amount of lead was processed?
2) Has a threshold for processing (either 25,000
or 100 pounds) lead been exceeded?
U-35
ALLOY EXAMPLE #1
Consider a facility that processes the
following two alloys that include:
• 20,000 pounds of lead In a stainless steel alloy.
• 275 pounds of lead in another alloy that is not
stainless steel, brass, or bronze.
Question 1: What amount of lead was
processed?
Total processed = 20,000 + 275 = 20,275 pounds
U-36
-------
ALLOY EXAMPLE #1
Consider a facility that processes the
following two alloys that Include:
• 20,000 pounds of lead in a stainless steel alloy.
• 275 pounds of lead In another alloy that Is not
stainless steel, brass, or bronze.
Question 2: Has a threshold for
processing (either 25,000 or 100 pounds)
lead been exceeded?
Total processed » 20,000 + 275 = 20,275 pounds
Yes. Although the 25,000 pound threshold was not
exceeded, the 100 pound threshold was exceeded.
U-37
LEAD THRESHOLD DETERMINATION FLOW
CHART
Activity Trtreeholde and Reporting Requirement! for Leid Related to
Stalnleee Steel, Briee or Bronze Alloy Quellfler
(Thl« flow chun do»« not apply to LMd Compound*, i MpiriUly lltt«d Tfll chtmlol)
,^^
, • , ,;;
DU«»tefiUy«K*«4ihe IQOIbthmihold
Did die ficility citcud the 100 Ib thrcihold
coiuiderlng only letd not In italnleii steel,
brau or bronze llloy?
Muii UK Form R, wiibod
range reporting la Section* 5
•ixJ 6 of Pin H
Report reLeuei and trMiCen
from BOTH lead hi lUUDkeu
sic«L bnu or bronu alloy
and tMd MM !• itainku
iteel, bnu or bronze allay.
May UK Form A or Form R;
nm(« reponlni can be iued
iaSectk»»5aod6orpartIl.
Report nfeuei and tranifen
from BOTH lead to itainku
iieel, bnu or bronze alloy
•ad lead M* !• iluntcii
itecl, brut or hronic allby.
U-38
-------
ALLOY EXAMPLE #2
Consider a facility that processes the
following two alloys that include:
• 24,950 pounds of lead in a stainless steel alloy.
• 75 pounds of lead in another alloy that is not
stainless steel, brass, or bronze.
Questions:
1) What amount of lead was processed?
2) Has a threshold for processing (either 25,000
or 100 pounds) lead been exceeded?
U-39
ALLOY EXAMPLE #2
Consider a facility that processes the
following two alloys that include:
• 24,950 pounds of lead in a stainless steel alloy.
• 75 pounds of lead in another alloy that is not
stainless steel, brass, or bronze.
Question 1: What amount of lead was
processed?
Total processed = 24,950 + 75 = 25,025 pounds
U-40
-------
ALLOY EXAMPLE #2
Consider a facility that processes the
following two alloys that include:
• 24,950 pounds of lead In a stainless steel alloy.
• 75 pounds of lead in another alloy that Is not
stainless steel, brass, or bronze.
Question 2: Has a threshold (either 25,000
or 100 pounds) for processing lead been
exceeded?
Total processed = 24,950 + 75 = 25,025 pounds
Yes. 25,025 pounds Is more than the 25,000 pound
threshold for processing lead.
The 100 pound threshold was not exceeded.
U-41
LEAD THRESHOLD DETERMINATION FLOW
CHART
Activity Thrwholdt and Reporting R*qulrwn*nts for LMd Related to
SUInl*** Steal, Brat* or Brona Alloy Qualifier
(This flow chart dooa not apply to LMd Compound*, • ••paraUty llatad 7RI chMnleAf)
Did Ihc facility exceed the 100 ft> threshold
considering only lead IKX in sulnleu iteel,
brua or bronze alloy?
.NO
Muit me F'ann ft, without
n£|« repotting la Sectloai 5
ud6ornnii.
Rcfxvt releuea ud Iranifen
torn BOTH lead taiuloleu
Heel, brw or broou alloy
ud Ind Ml !• uililcu
lleel. trial or bronie illoy.
»
Hatiim imJm mil motm
U-42
-------
ALLOY EXAMPLE KEY POINTS
• Lead in stainless steel, brass, and bronze
alloys Is not exempt from TRI reporting:
the 25,000 and 10,000 pound thresholds
still apply.
• Count together all lead used at the facility
(regardless of whether It Is found In
stainless steel, brass, and bronze alloys)
when evaluating the 25,000 and 10,000
pound thresholds.
• Stainless steel, brass, and bronze alloys
contain lead, not lead compounds.
U-43
TRI REPORTING PROCESS
Stopl
Identify section
313 chemicals end
determine the
quantity
manufactured.
processed, or
otherwise used at
the site.
*
Stop 2
II tht quantities
o(MC«on313
chemicals
exceed the
reporting
thresholds,
reporting Is
required*
Identify total
releases and
off-site transfers
Identity other
waste
management
practices
*l< reporting thresholds are not exceeded, no reporting Is necessary.
Identify source
reduction
activities
Complete
Form
U-44
-------
EXAMPLE RELEASE CALCULATIONS
• Example calculations #1 and #2:
• Facilities that manufacture, process, or
otherwise use lead and lead compounds, but
not In stainless steel, brass, or bronze alloys
Goals:
• Review approaches for estimating releases and
characterizing waste management activities
• Address some specific Issues pertaining to the
new lead rule
U-45
EXAMPLE RELEASE CALCULATIONS
• Step 1: Identify all waste streams and
waste management activities for the
chemical
• On-site: air (fugitive and stack), surface water,
underground injection, land, and waste
management activities
• Off-site: POTW and transfers for treatment,
disposal, recycling, and energy recovery
• Step 2: Determine the most appropriate
approach for estimating releases and
amounts managed as waste
• Step 3: Calculate releases and amounts
managed as waste
U-46
-------
EXAMPLE RELEASE CALCULATION #1
• Consider a facility that otherwise uses
lead only in the following activity:
• 13,600,000 pounds of coal are used to fire
boilers. The coal contains lead at 7.00 ppmw.
• Questions: What amount of lead
compounds were manufactured? Was
the reporting threshold exceeded?
(13,600,000 pounds of coal}{0.000700% Pb) = 95.2 pounds Pb
223 pounds PbO formed for every 207 pounds Pb used.
Total PbO formed = (95.2 pounds)(223/207) = 103 pounds
Lead compounds threshold was exceeded.
U-47
EXAMPLE RELEASE CALCULATION #1
• Step 1: Identify release streams and
waste management activities
• Assume that the only release generated by the
boiler Is air emissions and the facility
determined that 0.25 pounds of lead were
present in the boiler ash
• Step 2: Determine approaches for
estimating releases
• Step 3: Calculate releases and amounts
managed as waste
U-48
-------
EXAMPLE RELEASE CALCULATION #1
• Options for estimating air releases from
the coal-fired boiler (assume it is
uncontrolled):
• Mass balance—all lead that was In the coal Is
emitted through the stack
• Emission factor—multiply the amount of coal
burned by a factor that estimates lead
emissions per ton of coal burned
• How do these approaches differ? Which
approach should be used?
U-49
EXAMPLE RELEASE CALCULATION #1
• Mass balance calculation:
Lead In coal: (13,600,000 pounds) (0.000700%) = 95.2 pounds
Assume all lead In the coal (less that In ash, 0.25 Ibs) Is
emitted through the stack: 94.95 pounds of lead emissions
• Emission factor calculation:
Total coal burned = 13,600,000 pounds = 6,800 tons
Emission factor = 0.0133 pounds lead emitted per ton burned
90.4 pounds of lead emissions
• Use your judgment to select most
appropriate approach based on the best
available information
Report releases and waste management activities
of lead only, even If reporting for lead compounds
U-50
-------
EXAMPLE RELEASE CALCULATION #2
• Consider a facility that processes the
following two materials that include lead
or lead compounds:
• 10,000,000 pounds of wood are processed. The
wood contains lead at 20 ppmw.
• In spray booths, 20,000 pounds of paint
containing "<2%" lead chromate is applied to
furniture products.
• Thresholds were exceeded for both lead
and lead compounds.
• Assume facility will submit one Form R
(for lead compounds).
U-51
EXAMPLE RELEASE CALCULATION #2
• For the wood processing, make the
following assumptions:
• All wood is processed In a closed system
• The only waste generated Is wood chips and
dusts, all of which are collected and sent to an
off-site wood-fired boiler
• For the spray painting, make the following
assumptions:
• All spraying is done with spray guns with a
transfer efficiency of 80%
• All spraying occurs in enclosed spray booths
• All spray booth exhaust is captured and vented
through particulate filters with 90% collection
efficiency
• Spent filters are disposed off-site u_5
-------
EXAMPLE RELEASE CALCULATION #2
• Calculation for processing of wood chips:
• Shipping logs Indicate that the facility sends
(on average) 6,500 pounds of wood wastes to
the wood-fired boiler per month
• Concentration of lead in wood is 20 ppmw
• What is the total quantity of lead sent to
the off-site wood-fired boiler?
• How would this amount be reported on
the Form R?
U-53
EXAMPLE RELEASE CALCULATION #2
i What is the total quantity of lead sent to
the off-site wood-fired boiler?
Total waste: (6,500 lbs/month)(12 months)=78,000 Ibs
Lead In waste: (78,000 lbs)(0.0020%)=1.6 Ibs
i How would this amount be reported on
the Form R?
• Elemental lead is not combusted and therefore
cannot be claimed as energy recovery
• In this case, lead in the waste wood chips and
dusts must be classified as an off-site transfer
for disposal
U-54
-------
EXAMPLE RELEASE CALCULATION #2
m Identify all release streams and waste
management activities
• What releases and waste management
activities should be included for the spray
painting?
• Remember the following assumptions:
• All spraying is done with spray guns with a
transfer efficiency of 80%
• All spraying occurs In enclosed spray booths
• Spray booth exhaust is vented through
particulate filters with 90% collection efficiency
• Spent filters are disposed off-site
U-55
EXAMPLE RELEASE CALCULATION #2
• Conceptual approach for characterizing
uses in the spray booth:
Air
Filters
-^Emissions
400 Ibs
PbCrO,
^Filter waste
Spray
booth
.Finished
product
Based on the information provided, how
much lead chromate do you think is at
each point in the process?
U-56
-------
EXAMPLE RELEASE CALCULATION #2
m Conceptual approach for characterizing
uses in the spray booth:
Emissions
Filter waste
Finished
320 Ibs product
Lead chromate In finished product:
(400 Ibs PbCrO4)(0.8)«320 Ibs PbCrO4
U-57
EXAMPLE RELEASE CALCULATION #2
• Conceptual approach for characterizing
uses in the spray booth:
••Emissions
Filter waste
Finished
product
320 Ibs
PbCr04
Lead chromate that flows to the Inlet of the air filters:
(400 Ibs PbCrO4H320 Ibs PbCrO4)=80 Ibs PbCrO4
U-58
-------
EXAMPLE RELEASE CALCULATION #2
• Conceptual approach for characterizing
uses in the spray booth:
Air
Filters
-••Emissions
400 Ibs
PbCrO,
[SOIbs
PbCrO.
72 Ibs
PbCrO.
•+Filter waste
Spray
booth
320 Ibs
PbCrO4
.Finished
product
Lead chromate collected by the air filters:
(80 Ibs PbCrO4 enter filters)(0.9)=72 Ibs PbCr04
U-59
EXAMPLE RELEASE CALCULATION #2
• Conceptual approach for characterizing
uses in the spray booth:
Air
Filters
8.0 Ibs
PbCrO,
-^Emissions
400 Ibs
PbCrO,
80 Ibs
PbCrO,
Spray
booth
72 Ibs
PbCrO4
•+> Filter waste
320 Ibs
PbCrO4
.Finished
product
Lead chromate emitted to the air:
(80 Ibs PbCrO4 enter fllters)-(72 Ibs PbCrO4 collected):
8.0 Ibs PbCrO4 of stack emissions
U-60
-------
EXAMPLE RELEASE CALCULATION #2
Question
Where does the
amount get reported
on the Form R?
How much should be
reported?
What was the basis
for determining this
amount (M,C,E,O)*?
Response for
Quantities In Air
Emissions
•Monitoring data, mass balance, emission factor, or
other approaches and engineering estimates
U-61
EXAMPLE
: RELEASE CALCULATION #2
, Question
Where does the
amount get reported
on the Form R?
How much should be
reported?
What was the basis
for determining this
amount (M,C,E,O)?
•• 'Response tor
Quantities In Air
Emissions
Section 5.2 (Part II)
Section 8.1 (Part II)
5.1 pounds of lead
O (Engingeering
calculations)
Lead chromate Is 64.1% lead by weight.
U-62
-------
EXAMPLE RELEASE CALCULATION #2
Question
Where does the
amount and activity
get reported on the
Form R?
How much should be
reported?
What was the basis
for determining this
amount (M.C.E.O)*?
Response for
Quantities In Filter
Waste
'Monitoring data, mass balance, emission factor, or
other approaches and engineering estimates
U-63
EXAMPLE RELEASE CALCULATION #2
Question
Where does the
amount and activity
get reported on the
Form R?
How much should be
reported?
What was the basis
for determining this
amount (M.C.E.O)?
Response for
Quantities In Filter
Waste
Section 6.2 (Part II)
Section 7A (Part II)
Section 8.1 (Part II)
46 pounds of lead
(plus amount from
wood chips sent to
boiler)
O (Englngeering
calculations)
Lead chromate Is 64.1% lead by weight.
U-64
-------
EXAMPLE RELEASE CALCULATION #2
Question
Where does the
amount get reported
on the Form R?
How much should be
reported?
What was the basis
for determining this
amount (M,C,E,O)*7
Response for
Quantities In Finished
Product
'Monitoring data, mass balance, emission factor, or
other approaches and engineering estimates
U-65
EXAMPLE RELEASE CALCULATION #2
Question
Where does the
amount get reported
on the Form R?
How much should be
reported?
What was the basis
for determining this
amount (M,C,E,O)?
Response for
Quantities in
Finished Product
NOWHERE!
NONE!
NOT APPLICABLE!
Those quantities used to make product count towards
thresholds but do not count towards releases. U"66
-------
KEY POINTS
• Identify all release points
For both lead and lead compounds, only
report releases and waste management
activities for lead
If thresholds for both lead and lead
compounds are exceeded, facilities may
submit a single Form R (for lead
compounds) that covers both
Classify releases and waste management
activities carefully on the Form R
• Lead cannot be destroyed and should never be
reported in Section 8 as being treated for
destruction
• Lead should not be reported in Section 8 for
energy recovery
Document calculations and assumptions
U-67
TRI REPORTING PROCESS—REVISITED
Step-I
Identify tectlon
313 chemlcalt and
determine the
quantity
manufactured,
proceaeed. or
other** ae uied at
me alt*.
*
Stop 2
II the quantltiet
of aectlon 313
ohemlcale
exceed tne
reporting
threaholda.
reporting li
required."
Identity total
reteaaei and
otl-ilte tranaferi
•If reporting threahotda are not exceeded, no raportlng la neceaaary.
Identity other
waate
management
practice!
Identity aouroa
reduction
actlvltlea
Complete
Form
U-68
------- |