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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. FinalSupplementary Guide for Reporting to the National Pollutant Release InventoryAlternate 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 balanceall lead that was In the coal Is emitted through the stack Emission factormultiply 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 PROCESSREVISITED 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 ------- |