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

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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
 •  Plasticlzers
 •  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-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

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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

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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

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      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

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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
  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

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      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

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        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

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        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

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 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

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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

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      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

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  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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

-------