&EHV
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 3 :TRI Update
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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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TRI UPDATE
TRI UPDATE
TRI expansion
Chemical list changes
Reporting form changes
Guidance
Form R submissions/revisions
N-2
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INDUSTRY EXPANSION
In 1997, TRI added seven new industries (metal mines,
coal mines, electricity generating facilities, petroleum
bulk terminals, chemical distributors, solvent recyclers, &
hazardous waste treatment and disposal facilities)
• First Form R reports were due by July 1,1999 (for RY '98)
• EPA has prepared guidance documents for specific
industries
• New supplier notification requirements for facilities in SIC
codes 20-39
• EPA revised definition of "otherwise use" to include on-site
disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction of wastes received
from off-site
N-3
INDUSTRY EXPANSION
EPA considering petition to add SIC code 45,
Transportation By Air (February 10,1998; 63 FR
6691)
• EPA also considering modification to the motor vehicle
exemption and other exemptions
N-4
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CHEMICAL LIST CHANGES
Phosphoric acid deleted, effective RY1999
Chromium compounds qualifier added: (except for
chromite ore mined in the Transvaal Region of South
Africa and the unreacted ore component of the chromite
ore processing residue (COPR)) (May 11,2001)
Vanadium (except when contained in alloy) and vanadium
compounds added, effective RY 2000
Certain PBT chemicals added, effective RY 2000, in the
PBT final rule (October 29,1999; 64 FR 58666)
N-5
CHEMICAL LIST CHANGES
Final rule designates lead and lead compounds as
PBT chemicals (January 17,2001; 66 FR 4500)
• Lead (except when contained in stainless steel, brass and
bronze alloys): 100 pound threshold
• Lead compounds: 100 pound threshold
• Reporting begins RY 2001, Form R reports due by July 1,
2002
N-6
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CHEMICAL LIST CHANGES
Proposal to add diisononyl phthalate (DINP)
category, a plasticizer (September 5,2000; 65 PR
53681; extension of comment period to February 2,
2001 - November 21,2000; 65 PR 69888)
N-7
REPORTING FORM CHANGES
New for RY 2000
• New Federal Information Processing Standards (PIPS)
codes for Section 6.2 transfers to foreign countries
• New identifier (check box) for GOCOs (government owned
contractor operated facilities)
• New section for distribution of each member of the dioxin
and dioxtn-like compounds category In Part II, Section 1.4
• New option to check "Processing as an impurity" in Part II,
Section 3.2
• First SIC code box identified as primary SIC code
N-8
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GUIDANCE
New TRI guidance documents for the following
industries:
• Presswood and Laminated Products Industry
• Rubber and Plastics Manufacturing
• Printing, Publishing and Packaging Industry
• Textile Processing Industry
• Leather Tanning and Finishing Industry
• Semiconductor Industry
• Spray Application and Electrodeposition of Organic
Coatings
• Food Processors
N-9
GUIDANCE
Aqueous Ammonia
Dioxin and Dioxln-like Compounds Category
Chlorophenols
Certain glycol ethers
EBDC
Hydrochloric acid aerosols
Lead and Lead Compounds
Mercury and Mercury Compounds
Nicotine and Salts
Nitrate compounds
Pesticides and Other Persistent Bioaccumulative Toxic (PBT)
Chemicals
Polychlorinated alkanes
Polycyclic aromatic compounds
Strychnine and salts
Sulfurlc acid aerosols
Wafarin and salts N-10
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TRI REPORTING SOFTWARE
For the Reporting year (RY) 2001, EPA is distributing
two types of reporting software to assist facilities in
reporting to the Toxics Release Inventory (TRI).
The TRI-Made Easy (TRI-ME) Reporting Software was
distributed to a limited number of facilities for a pilot
in RY 2000. It is now available to all facilities for RY
2001.
The Automated TRI Reporting Software (ATRS) is the
traditional reporting software that has been
distributed by EPA for a number of years.
For RY 2001, facilities may report using either ATRS
or TRI-ME; however, EPA plans to transition from
ATRS to TRI-ME in the near future.
N-11
TRI REPORTING SOFTWARE
Both ATRS and TRI-ME w\\\ be distributed via CD ROM to all
facilities that have reported to TRI in the last two reporting
years. The software will also be available to download from
EPA's website at www.epa.gov/fri.
The 77W-ME software is an interactive, Intelligent, user-friendly
software program that assist facilities In determining and
completing their TRI reporting obligations. In contrast, while
ATRS allows facilities to complete the Form Rs and As on their
personal computers, it provides much less guidance and
assistance.
Both TRI-ME and ATRS allow users to access and search the
TRI Assistance Library (TRIAL). TRI-ME is intelligently linked to
TRIAL so that the user can view pre-selected TRI definitions
and guidance from TRIAHhat are relevant to specific TRI-ME
screens.
N-12
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COMPARISON OF TRI-ME VERSUS ATRS
FOR RY2001
Guides the user through the process of determining
whether they must report based on their SIC code
and number of employees. Helps determine the
primary SIC code. (TRI-ME)
Guides facilities through process of determining
whether they exceed the chemical activity
thresholds. (TRI-ME)
Allows users to access and search TRIAL. (TRI-ME
& ATRS)
Intelligently linked to TRIAL. (TRI-ME & ATRS)
Allows users to load or import their facility
information and chemical names from RY1999 or
RY2000. (TRI-ME & ATRS) N-13
COMPARISON OF TRI-ME VERSUS ATRS
FOR RY2001
Allows users to load or import their facility information and
chemical names from years prior to RY 1999. (ATRS)
Allows users to load or import their prior year quantitative
information on releases and waste transfers. (ATRS)
Guides facilities in completing the Form R and A by explaining
each element of the form through a questionnaire format.
(TRI-ME)
Allows expert TRI users to bypass most of the TRI-ME guidance
and directly enter the data into the forms (not applicable to
ATRS).
Allows users to directly enter data into the forms on a
computer screen. (TRI-ME & ATRS)
N-14
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COMPARISON OF TRI-ME VERSUS ATRS
FORRY2001
Streamlines the completion of Form R, Part II, section 7a
information on waste treatment methods. (TRI-ME)
Prevents facilities from making common errors while
completing the Form R and A (TRI-ME & ATRS)
Checks (validates) the forms to identify critical and potential
errors that should be corrected before submitting the forms to
EPA. (TRI-ME & ATRS {some})
Allows users to print their forms on paper or to create a
diskette (using the same file format from RY 2000). (TRI-ME &
ATRS)
Allows users to submit their forms to EPA electronically over
the Internet via EPA's Central Data Exchange. (TRI-ME)
N-15
TRI MADE EASY (TRI-ME) (cont.)
TRI-ME is integrated with EPA's Central Data Exchange (CDX),
the Agency's central portal for environmental data
Registration- Pre-populates facility ID information, MyCDX
messaging
Security- Your information is protected by username and
password (and secret question/answer) that you create
User Support-1-888-890-1995
Provides burden reduction - saves time over conventional
submission methods using a freeware Internet browser
• Signed, TRI-ME generated paper certification still needs to be sent
via US Postal Service, FedEx, etc.
N-16
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TRI ASSISTANCE LIBRARY
TRI Assistance Library (TRIAL) is with EPA's
Automated TRI Reporting Software (TRI-ME/ATRS).
TRIAL is a self-contained help system that includes:
• Electronic versions, or links to electronic versions, of the
statutes, regulations, executive orders, chemical-specific
guidance documents, and industry-specific guidance
documents
• Keyword and full text search capabilities on these guidance
documents
• Links to the EPA websites, including EPA's homepage, TRI
website, and other useful websites that will assist with TRI
reporting
N-17
FORM R SUBMISSIONS/REVISIONS
Reminder:
To be included in the TRI Explorer version
distributed with the most current TRI data release,
voluntary revisions must be submitted by July 31 of
the same year as the reporting deadline
N-18
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FORM R SUBMISSIONS/REVISIONS
Reminder:
Form R submitted to replace previously filed Form A
• Considered to be a late submission of a Form R and a
request for a withdrawal of the previously filed Form A
• Do not check the revision box!
N-19
THRESHOLD GUIDANCE
Reminder:
Section 313 chemicals coincidentally manufactured
(including from exempt otherwise use activities)
must be considered towards the manufacturing
threshold
• Acid aerosols and metal compounds manufactured as by-
products of fuel combustion
N-20
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THRESHOLD GUIDANCE
Reminder:
• For threshold determinations, the definitions of
"manufacture," "process," and "otherwise use" currently
do not include Section 313 chemicals that are:
• Remediated
• Demolished
• Treated in wastes generated on site
• Stored
• Recycled on-slte for use on-site
• Transfers sent off-site for further waste management (not
including recycling)
• These activities do not constitute threshold activities N-21
EXEMPTION GUIDANCE
Reminder:
• Section 313 chemicals in gasoline used to refuel
motor vehicles not operated by the facility are
considered processed and do not qualify for the
motor vehicle maintenance exemption
• Laboratory activities exemption only applies to
certain activities that take place in a laboratory
N-22
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EPCRA SECTION 313
LIST OF TOXIC CHEMICALS
SECTION 313 LIST OF CHEMICALS
AND CHEMICAL CATEGORIES
Current list contains over 600 individual chemicals
and chemical categories (§372.65)
Dynamic, evolving list
• Additions
• Deletions
• Modifications
Petition process to add or delete chemicals or forms
of chemicals
0-2
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SECTION 313 CHEMICAL QUALIFIERS
• Qualifiers - Listed chemicals with parenthetic qualifiers subject
to TRI reporting only if manufactured, processed, or otherwise
used in specified form (§372.25(g)). Below are some examples:
CHEMICAL CAS# QUALIFIER
Aluminum
Aluminum oxide
Asbestos
Isopropyl alcohol
Phosphorus
Saccharin
Sulf uric acid
Vanadium
Barium Compounds
7429-90-5 Fume or dust
1344-28-1 Fibrous forms
1332-21-4 Friable forms
67-63-0 Only manufacturers using strong
acid process
7723-14-0 Yellow or white
81-07-2 Manufacture only
7664-93-9 Acid aerosols
7440-62-2 Except when contained in alloy
N040 Does not include barium sulfate
0-3
CHEMICALS ADDED BY THE PBT
CHEMICAL RULE
Additions to TRI list effective January 1,2000,
reports due July 1,2001
• Benzo(g,h,i)perylene
• Benzo(j,k)fluorene (fluoranthene) & 3-methylcholanthrene
added as part of polycyclic aromatic compounds (PACs)
category
• Octachlorostyrene
• Pentachlorobenzene
• Tetrabromobisphenol A (TBBPA)
• Dioxin and dioxin-like compounds category
• Vanadium compounds (not a PBT chemical)
O-4
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CHEMICAL LIST DELETIONS
Phosphoric acid deleted - effective RY1999 (June
27, 2000; 65 FR 39552)
Chromite ore mined in the Transvaal Region of
South Africa and the unreacted ore component of
the chromite ore processing residue (COPR) deleted
- effective RY 2000 (May 11, 2001; 66 FR 24066)
Petitions to delete denied
• Methyl ethyl ketone (MEK)
• Methyl isobutyl ketone (MIBK)
• Acetonitrile
0-5
MODIFIED CHEMICAL LISTINGS
Vanadium (fume or dust) is now vanadium (except
when contained in alloy)
• Effective RY 2000
Ammonia
» Requires threshold determination and release and other
waste management quantity calculations for aqueous
ammonia from any source (i.e., anhydrous ammonia placed
in water or water dissociable ammonium salts) be based on
10% of the total ammonia present in aqueous solutions
• Anhydrous ammonia - include 100% for thresholds and
releases
» Including air releases from aqueous ammonia
• Effective RY 1994
0-6
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MODIFIED CHEMICAL LISTINGS
Glycol ethers category
• Removed surfactant glycol ethers from category (July 5,
1994; 59 PR 34386)
• Common glycol ethers still In category include:
» 2-Butoxyethanol (CAS # 111-76-2)
» DIethylene glycol monoethyl ether acetate
(CAS # 112-15-2)
» DIethylene glycol monobutyl ether (CAS #112-34-5)
• Effective RY 1993
O-7
NITRATE COMPOUNDS
Water dissociable nitrate compounds category
• For threshold determinations, use the weight of the entire
nitrate compound
• Calculate only the weight of the nitrate ion portion when
calculating releases and other waste management
quantities
• Nitrate compounds are produced most commonly when
nitric acid is neutralized
• Includes compounds like sodium nitrate, silver nitrate, and
ammonium nitrate
0-8
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DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
Example:
• 20,000 pounds of nitric acid (HNO3) are neutralized with
sodium hydroxide (NaOH) in an on-site wastewater
treatment system. Perform a threshold determination for
nitrate compounds (water dissociable; in aqueous
solution):
Assume:
» Neutralization 100% complete and generates sodium
nitrate (NaNO,), which Is released to a waterbody
» Molecular weight (MW) of HNO, = 63
» MW of NaNO3 = 85
» 1 mole of HNO3 generates 1 mole of NaNO3
O-9
DETERMINING THRESHOLDS FOR
NITRATE COMPOUNDS
Example (continued):
Quantity of NaNO3 manufactured = quantity of HNO3
neutralized x (MW of NaNOg/MW of HNO,)
Quantity of NaNO3 manufactured = 20,000 Ibs. x (85/63)
Quantity of NaNO3 manufactured = 26,984 Ibs.
The 25,000 pound manufacturing threshold is exceeded!
O-10
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CALCULATING RELEASES FOR
NITRATE COMPOUNDS
Example (continued):
Releases are reported on nitrate ion (NO3~) basis. Calculate the
quantity of nitrate ion (MW of NO3- = 62) released to a
waterbody:
Lbs. of NO3- = Ibs. of NaNO3 x (MW of NO3-/MW of
NaNO3)
Lbs. ofNO3-= 26,984 Ibs. x (62/85)
Lbs. of NO3- = 19,682 Ibs. (rounded to 20,000 Ibs.)
0-11
OTHER NON-METAL COMPOUND
CATEGORIES
Consider the entire weight of the compounds in
these categories when determining thresholds
Include the entire weight of the compounds in the
category when calculating releases and other waste
management quantities for all compounds in these
categories
0-12
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XYLENE AND XYLENEISOMERS
If data do not specify o-, m-, or p- isomers of xylene,
calculate thresholds, release and other waste
management quantities based on "xylene (mixed
isomers)"
If data specifies o-xylene, m-xylene, or p-xylene
individually, calculate thresholds, release and other
waste management quantities based on the
individual isomers
• If thresholds are exceeded for more than one isomer,
releases and other waste management quantities can be
consolidated in one report as "xylene (mixed isomers)"
Same logic applies to cresol, toluene diisocyanates
O-13
ADMINISTRATIVE STAYS
No reporting required for the following chemicals
until further notice
• 2,2-Dibromo-3-nitrilopropionamide (DBNPA)
(CAS # 10222-01-2)
» Effective RY1995
• Hydrogen sulfide (CAS # 7783-06-4)
» Effective RY 1994
• Methyl mercaptan (CAS # 74-93-1)
» Effective RY 1994
O-14
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EXERCISE 5*
CALCULATING RELEASES OF AMMONIA AND NITRATE COMPOUNDS
During the calendar year, a facility uses 200,000 pounds of nitric acid solution containing 50
percent (by weight) nitric acid (HNO3) in an etching operation. All of the nitric acid is eventually
transferred to an on-site treatment facility as part of an aqueous waste stream. The nitric acid is
neutralized with pure (gaseous) anhydrous ammonia (NH3). The facility uses an excess of
ammonia to assure complete neutralization to pH 8. During the calendar year, the facility used
30,000 pounds of ammonia. As a result of the treatment process, a nitrate compound, ammonium
nitrate (NHiNOs), is formed. The ammonium nitrate and any remaining ammonia are then
released to a waterbody.
Using the additional information below, complete questions a through d.
Assumptions
For simplicity, assume air emissions are zero.
Chemical Name Molecular Weights
Ammonium nitrate (NH4NO3) = 80.04 Ib/lbmol
Ammonia (NH3) = 17.03 Ib/lbmol
Nitric acid (HNO3) = 63.01 Ib/lbmol
Nitrate ion (NO3') = 62.01 Ib/lbmol
Chemistry Fundamentals
Nitric acid (HNO3) and anhydrous ammonia (NH3) are monovalent and react in a 1:1 ratio. One
mole of NHj is used to neutralize each mole of HNO3 treated. When neutralized with anhydrous
ammonia, nitric acid (HNO3) produces ammonium nitrate (NH4NO3) in a 1: 1 ratio. These
substances are monovalent, so for each mole of HNO3 neutralized, one mole of NH4NO3 is
produced. As indicated in the following formula:
Therefore, 63.01 pounds of nitric acid reacts with 17.03 pounds of ammonia to produce 80.04
pounds of ammonium nitrate (which contains 62.01 pounds of nitrate ion).
a) Based on the above scenario and information available, determine which Section 313
chemicals would be subject to TRI threshold and release determinations.
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b) Calculate the quantity of nitric acid applied towards threshold determinations and
release calculations.
c) Calculate the quantity of ammonia applied towards threshold determinations
and release calculations.
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d) Calculate the quantity of ammonium nitrate applied towards threshold
determinations and release calculations.
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ACID AEROSOL AND FUEL
COMBUSTION REPORTING
ACID AEROSOLS
Sulfuric acid/hydrochloric acid (acid aerosols
including mists, vapors, gas, fog, and other airborne
forms of any particle size)
Sulfuric acid listing modified, effective RY1994
Hydrochloric acid listing modified, effective RY 1995
P-2
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ACID AEROSOLS THRESHOLD
DETERMINATIONS
Manufacture (e.g., acid aerosols manufactured from
non-aerosol acid solutions and as by-products of
combustion)
Processing (e.g., acid aerosol or a reaction product
is incorporated into a product for distribution into
commerce)
Otherwise Use (e.g., acid aerosol used, such as
spray application for etching, cleaning, neutralizing,
without incorporation into a product)
P-3
ACID AEROSOLS THRESHOLD
DETERMINATIONS
Closed-loop acid reuse systems (sulf uric and
hydrochloric acid only)
• Acid aerosol manufactured and otherwise used
• Simplified method of estimating quantity for threshold
determination:
Total Amount of + Total Virgin Acid
Acid In Reuse System Added In RY
- Amount Acid Aerosols Manufactured/Otherwise Used
See EPA's Guidance for Reporting Sulf uric Acid (Ret. 1)
and Guidance for Reporting Hydrochloric Acld(Re1.6) for
specific calculations
P-4
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ACID AEROSOLS TREATMENT FOR
DESTRUCTION
Acid aerosols removed by scrubbers
• Acid aerosols removed by scrubbers are converted to a
non-reportable form
• Report the quantity removed by the scrubber as treatment
for destruction
P-5
ACIDS FORMED DURING COMBUSTION
Hydrochloric acid aerosols and hydrogen fluoride form during
the combustion of fuels/wastes containing chlorine and
fluorine
• See EPA's EPCRA Section 313 Industry Guidance:
Electricity Generating Facilities (Ref. 2) for emission factors
Sulfuric acid aerosols form in stacks from combustion
processes of fuel oil, coal, and other sulfur-containing fuels
• Sulfur trioxide, a product of fuel combustion, can react
quickly to form sulfuric acid in the presence of moisture
• See EPA's EPCRA Section 313 Guidance for Reporting
Sulfuric Acid (Re1.1) for specific calculations
P-6
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COMBUSTION
Section 313 chemicals may be coincidentally
manufactured during combustion of:
• Oil
• Coal
• Natural gas
• Waste
• Other materials
P-7
COMBUSTION - MANUFACTURING
Examples of manufactured chemicals:
• Hydrochloric acid aerosol, sulfuric acid aerosol
• Hydrogen fluoride
• Metal compounds and metals (e.g., vanadium compounds,
mercury)
• Organics
• PBT chemicals such as dioxin, PACs, mercury
De minimis does not apply
Most other exemptions do not apply
P-8
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COMBUSTION - OTHERWISE USE
Combustion of fuel is also otherwise used
De minimis (non-PBT chemicals only) and other
exemptions could apply to chemicals in the fuel
Example:
• 1,2,4-trimethylbcnzene and n-hexane in No. 2 fuel oil (Ref. 2)
P-9
COMBUSTION & METAL COMPOUNDS
Metal compounds and elemental metals in fuel are
typically converted to metal oxide form
Elemental metal may also be manufactured (e.g.,
mercury)
If no other data available, assume compound is
lowest weight oxide that could be manufactured
from metal
Example:
• Nickel in fuel -> Assume NiO not Ni2O3 is manufactured
P-io
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COMBUSTION & METAL COMPOUNDS
Amount of metal compound manufactured is
determined by the total weight of the compound,
not the parent metal
Be comprehensive: include all metal compounds
and all combustion units and any other activities
that may manufacture metal compounds
Releases and other waste management estimates
are based on the weight of the parent metal
p-11
METAL COMPOUNDS
• Example calculation:
• During the year, a facility bums 70,000 tons of coal with a
manganese (Mn) concentration of 141 micrograms/gram
(ppm)
Lowest weight Mn oxide compound manufactured = MnO
Molecular weight Mn = 55
Molecular weight MnO = 71
• Does the facility exceed the manufacturing threshold for
manganese compounds?
P-12
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METAL COMPOUNDS
Amount MnO manufactured
= amount coal x concentration Mn x
= 70,000 tons x 2,000 IbsJton x 141 ppm x 71/55
= 25,483 Ibs. manganese compounds
Threshold exceeded
P-13
METAL COMPOUNDS IN COAL
Sources of data for calculating amounts manufactured
* Fuel analysis, fuel specifications, or other supplier information
• U.S. Geological Survey's (USGS) coal quality data base. Available at
http://energy.er.usgs.gov/products/databases/CoalQual/
• Electrical Power Research Institute's (EPRI) PISCES data base on
coal constituents
• Tables in EPA's EPCRA Section 313 Industry Quittance: Electricity
Generating Facilities (Ref. 2)
• EPA's EPCRA Section 313 Guidance on Reporting Toxic Chemicals:
Mercury and Mercury Compounds (Ref. 4)
• EPA's Mercury/£/? (Ref. 5)
• EPA'9 EPCRA Section 313 Guidance for Reporting Releases and
Other Waste Management Quantities of Toxic Chemicals: Lead and
Lead Compounds (Ref. 7)
P-14
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METAL COMPOUNDS IN OIL
Sources of data for calculating amounts
manufactured
• Producer's fuel analysis, fuel specifications, or other
producer information
• Tables in EPA's EPCRA Section 313 Industry Guidance:
Electricity Generating Facilities (Ref. 2)
• EPA's EPCRA Section 313 Guidance for Reporting Releases
and Other Waste Management Quantities of Toxic
Chemicals: Lead and Lead Compounds (Ref. 7)
P-15
ORGANICS
Organics may be released during combustion (e.g.,
PACs, formaldehyde)
Manufacture of formaldehyde and releases of other
organics
• See emission factors in EPA's EPCRA Section 313 Industry
Guidance: Electricity Generating Facilities (Ref. 2)
For more information on PACs:
• EPA's Guidance for Reporting Toxic Chemicals in the
Pot/cyclic Aromatic Compounds Category (Ref. 3)
P-16
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RELEASES FROM COMBUSTION
Sources of data:
• Monitoring data
• Facility derived emission factors
• Emission factors in EPA's EPCRA Section 313 Industry
Guidance: Electricity Generating Facilities (Ref. 2)
• Emission factors in EPA's EPCRA Section 313 Guidance for
Reporting Toxic chemicals Within the Dloxin and Dioxin-llke
Compounds Category (Ref. 8)
P-17
COMBUSTION ASH
Combustion ash may contain manufactured metals
and metal compounds.
Ash released on-site (e.g., land disposal, fugitive air
emissions)
• Do minimis exemption does not apply to manufacture of
metals and metal compounds as by-products
• Ash used on-site to construct roads or berms should be
reported as otherwise use and as release to land: other
disposal (Section 5.5.4 of Form R)
P-18
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COMBUSTION ASH
Ash sent off-site to be managed as a waste should
be reported in Section 6.2
• Example:
» Ash sent off-site for direct application to land as roadfill
Ash sent off-site for direct reuse is not reported on
the Form R
• Example:
» Ash used to manufacture concrete blocks
- Ash considered distributed into commerce and,
therefore, processed
- De minimls exemption can apply
P-19
REFERENCES
For more information:
1. Guidance for Reporting Sulfuric Acid. U.S. EPA, Office of Pollution
Prevention and Toxics. March 1998. Available at
http^/www.epa.govArl
2. EPCRA Section 313 Industry Guidance: Electricity Generating
Facilities. U.S. EPA, Office of Pollution Prevention and Toxics.
February 2000. Available at http://www.epa.gov/trl
3. Guidance for Reporting Toxic Chemicals In the Polycycllc Aromatic
Compounds Category. U.S. EPA, Office of Information Analysis and
Access. August 2001. http://www.epa.gov/tri
4. EPCRA Section 313 Guidance on Reporting Toxic Chemicals:
Mercury and Mercury Compounds. U.S. EPA, Office of Information
Analysis and Access, August 2001. Available at
http://www.epa.gov/tri
5. Mercury ICR. U.S. EPA, Unified Air Toxics Website. 1999, Raw data
available June 2000. Available at
http://www.epa.gov/ttnuatw1/combust/utiltox/utoxpg.htmWDA2
P-20
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REFERENCES
6. Guidance for Reporting Hydrochloric Acid. U.S. EPA, Office of
Information Analysis and Access. December 1999.
http://www.epa.gov/tri
7. EPCRA Section 313 Guidance for Reporting Releases and Other
Waste Management Quantities of Toxic Chemicals: Lead and Lead
Compounds. U.S. EPA, Office of Environmental Information.
December 2001. http://www.epa.gov/tri
8. EPCRA Section 313 Guidance for Reporting Toxic Chemicals within
the Dloxln and Dloxln-llke Compounds Category. U.S. EPA, Office
of Information Analysis and Access. December 2000.
http://www.epa.gov/tri
P-21
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METAL AND METAL COMPOUND
REPORTING
SECTION 313 METALS
Certain metals and metal compounds are Section
313 chemicals
• Examples:
» Elemental metals: chromium, nickel, manganese, cobalt,
silver, arsenic, copper
» Metal compound categories: zinc compounds, selenium
compounds, nickel compounds, chromium compounds,
vanadium compounds
» Individually listed metal compounds: sodium
fluoroacetate, calcium cyanamide, lithium carbonate,
molybdenum trioxide, titanium tetrachloride
Q-2
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SECTION 313 METALS WITH QUALIFIERS
i Metals and metal compounds can have qualifiers:
• Zinc (fume or dust)
• Aluminum (fume or dust)
• Vanadium (except when contained in an alloy)
» Beginning RY 2000, reports due by July 1,2001
• Aluminum oxide (fibrous forms)
i All compounds within a metal category are
reportable unless specifically excluded
• Barium sulfate
• Certain copper phthalocyanine compounds
Q-3
SECTION 313 METAL COMPOUND
CATEGORIES
Consider the entire weight of the compounds in the
category when determining activity thresholds
Include only the weight of the parent metal of the
category (e.g., copper for copper compounds) when
calculating releases, off-site transfers, and other
waste management activities
Q-4
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SECTION 313 METALS
AND COMPOUND CATEGORIES
Elemental metals and metal compound categories
are separately listed chemicals under Section 313
• Separate activity threshold determinations
• Report for each listing (e.g., nickel or nickel compound
category) only if the threshold for each listing is exceeded
• If threshold exceeded for both the elemental metal and
metal compound category (e.g., nickel and nickel
compounds), you have options to report separately or file
one combined report
» If combined, file as metal compound category
Q-5
DETERMINING THRESHOLDS FOR METAL
COMPOUNDS
Multiple compounds within a mixture example
A facility processes 200,000 pounds of a mixture
containing 10% zinc chromate and 15% chromium
dioxide by weight
• Quantity toward chromium compounds threshold
(10% + 15%) x (200,000) = 50,000 Ibs.
• Quantity toward zinc compounds threshold
(10%) x (200,000) = 20,000 Ibs.
• 25,000-pound processing threshold applies; chromium
compounds are reportable and zinc compounds are not
Q-6
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METAL CYANIDE COMPOUNDS
A metal cyanide compound such as cadmium
cyanide will require separate reporting under both
cadmium and cyanide*
• For reporting the metal, use the entire weight of the
compound for threshold determinations, and only the
weight of the metal portion of the compound for release and
other waste management reporting.
• For reporting cyanide, use the weight of the entire
compound for threshold determinations, and also the
weight of the entire compound for release and other waste
management reporting.
* The qualifier for cyanide compounds states: X+Ctt, where
X=H+ or any other group where a formal dissociation may
occur. For example, KCN or Ca(CN)2
Q-7
VANADIUM AND VANADIUM COMPOUNDS
PBT rule modifies the listing for vanadium:
• Vanadium, with the qualifier "fume or dust," has been on
the list of Section 313 chemicals since 1987
• Qualifier now reads "except when contained in an alloy"
» "Alloy" does not include slags, crystalline structures,
ores
» EPA is reviewing what actions to take regarding alloys
PBT rule adds vanadium compounds to the TRI list
«
Neither vanadium (except when in an alloy) or
vanadium compounds are PBT chemicals
Q-8
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VANADIUM
Vanadium is used to produce various alloys
• Prior to becoming part of the alloy, vanadium Is a listed
chemical
• Once part of the alloy, vanadium Is not a listed chemical
• However, if vanadium is removed from the alloy, it is
reportable
Q-9
VANADIUM COMPOUNDS
Manufacturing
• Fuel combustion - metal oxides manufactured
• Concentrations of listed metals are in the EPA's TRI
Guidance for Electricity Generating Facilities (U.S. EPA,
Office of Pollution Prevention and Toxics, February 2000)
• Vanadium compounds are new to the list!
» 9 - 43 ppm V in coal (Ref. 2)
» 1.5 ppm V in fuel oil #2 (Ref. 3)
» 73 ppm V in fuel oil #6 (Ref. 3)
» 0.0023 IDS. per million standard cubic feet natural gas
(Ref. 1)
» Assume V2O3 manufactured
Q-10
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VANADIUM AND VANADIUM COMPOUNDS
REFERENCES
• For more information on vanadium see:
1. Compilation of Air Pollutant Emission Factors (AP-42), Volume 1, Fifth
Edition. U.S. EPA, Office of Air Quality Planning and Standards. Available
at http://vnvw.epa.gov/ttiVchlaf/ap42/1ndex.htrnl
2. Milliard, H. The Materials Flow of Vanadium In the United States, U.S.
Department of the Interior, Bureau of Mines, Information circular 9409;
1994. Available at
http://mlnerals.usg8.gov/mlnerals/pub8/commodlty/vanadlum
3. Total Petroleum Hydrocarbon (TPH) Criteria Working Group Association
for the Environmental Health of Soils, Volume 2, Appendix 1; 1998.
Available at http://www.aeh8.coin/pubtlcatlon8/catalog/tph.htrn
Q-11
MANUFACTURING ACTIVITIES
Manufacturing
• Electroplating: metals and metal compounds manufactured
• Fume or dust: machining manufactures zinc (fume or dust)
• Importing copper ore: manufacturing copper compounds
• Beneficiation of ore: chemical reactions manufacture metals
and metal compounds
• Wastewater treatment: metal compounds may be
manufactured in reduction or precipitation steps
Q-12
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PROCESSING ACTIVITIES
Processing
• Metals and metal compounds extracted from ores
distributed into commerce
• Metals are incorporated into a wide variety of products
including motor vehicles, consumer products, industrial
equipment, and various other products
• Alloys are mixtures of elemental metals. Metals in alloy
products distributed into commerce
• Metals sent off-site for recycling or reuse
Q-13
OTHERWISE USE ACTIVITIES
Otherwise using
• Fabricating and/or using tooling
• Installation of process-related equipment and piping (e.g.,
constructing storage tanks)
• Use of ash and waste rock for land contouring, structural
backfill, or soil building
• Metal compounds are often constituents of coolants,
biocides, and other liquid mixtures used on-site
Q-14
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DETERMINING THRESHOLDS AT MINES
Mines
• Use ore analyses, literature, geochemical knowledge, etc.
• No knowledge of metal compound type • assume lowest
weight oxide
Q-15
DETERMINING THRESHOLDS FOR ALLOYS
Industrial processing of alloys
• Includes stainless steels, nickel superalloys, brasses,
aluminum alloys, and carbon steels
• Use alloy specifications in addition to MSDSs to improve
precision
• Be comprehensive:
» Some carbon steels and aluminum alloys may contain
manganese above de minimis
Q-16
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ARTICLES EXEMPTION TEST
Articles exemption is often inappropriately used!
• A useful rule of thumb Is that when metal Is melted,
machined, or ground, articles exemption usually NOT
applicable
• The manufacture of an article does not qualify
Q-17
STRUCTURAL COMPONENT
EXEMPTION TEST
Structural components need to pass a test to be
exempt. Test has 2 criteria:
• Is part of the facility structure; and
• Is NOT process related
Non-process-related structural items eligible for the
exemption:
• Potable water pipes and other non-process-related pipes
and structures
Processed-related items/uses NOT eligible for the
exemption:
• Refractory brick, process-related pipes, anodes used in
electroplating, grinding wheels, and metal working tools ...
Q~18
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FORM R: AIR EMISSIONS
Fugitive air emissions (Section 5.1)
• Ambient air monitoring can Indicate emissions occurring
• Paniculate emission data combined with speclation can be used to
estimate emissions
• Capture efficiencies of control equipment can be helpful
Stack air emissions (Section 5.2)
• Many techniques available:
» Use of sampling data, adjusting permit estimates to actual
production, back-calculation from control device efficiencies
and quantity of dust collected, and engineering estimates
• Emissions factors available from AP-42 and WATER9
Q-19
FORM R: WASTEWATER DISCHARGES
Wastewater discharges (Sections 5.3,6.1, and 6.2)
• Calculate based on wastewater flows and measured
concentrations (e.g., NPDES/SPDES monitoring
requirements, permit applications)
• For metals not measured, consider engineering estimate
(e.g., use ratio of metals in process and measured metal
quantity)
Q-20
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FORM R: OFF-SITE WASTE TRANSFERS
• It's critical to be comprehensive!
• Potential off-site waste transfers of reportable metals
• Hazardous waste
• Non-hazardous waste (e.g., waste oil and coolant)
• Trash
• Scrap metal (reuse vs. recycle)
• Exercise caution when using TCLP data
Q-21
WASTE MANAGEMENT OF METALS
Generally, metals cannot be treated or combusted
for energy recovery for Sections 6 and 8 of Part II of
the Form R
• Metals are elements and cannot be destroyed
• Exceptions include conversions to non-listed chemicals
» Examples:
- Barium chloride (included in barium compounds
category) converted to barium sulfate (not included)
- Molybdenum trioxide converted to molybdenum
carbonate
- Titanium tetrachloride converted to titanium dioxide
Q-22
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WASTE MANAGEMENT OF METALS
For metals in wastes sent off-site for solidification/
stabilization
• Use code M41 - Solidification/Stabilization-Metals and Metal
Compounds only
• Do NOT use code M40 - Solidification/Stabilization
For metals in wastewater sent off-site for treatment
(not to a POTW)
• Use code M62 - Wastewater Treatment (Excluding POTW)-
Metals and Metal Compounds only
• Do NOT use code M61 - Wastewater Treatment (Excluding
POTW)
Q-23
OFF-SITE RECYCLE OR REUSE?
Metal sent off-site for direct reuse:
• No contaminants removed
• Considered processing
• De minimis exemption applies
• Not reported on Form R
Q-24
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OFF-SITE RECYCLE OR REUSE?
Materials sent off-site for recycling:
• Considered processing
• De minimis exemption does NOT apply
• Report on Form R in Sections 6.2 and 8.5
Q-25
FORM R: SECTION 7A, ON-SITE WASTE
TREATMENT
Part II, Section 7A: On-site waste treatment methods
and efficiency
• Report any waste treatment step through which a reportable
chemical passes including removal
Air pollution control equipment and wastewater
treatment typically reported
Q-26
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FORM R: SECTION 8
Consistency with data reported on other parts of Form
R is critical
• Quantity Released: §8.1 = §5 + §6.2 (disposal codes only) +
§6.1 (metals and metal compounds only) - §8.8 (release or off-
site disposal only)
• Off-Site Recycling: §8.5 = §6.2 (recycling codes only) - §8.8
(off-site recycling)
• On-Site & Off-Site Energy Recovery: §8.2 = NA and §8.3 = NA
• On-Site & Off-Site Waste Treatment: §8.6 = NA and §8.7 = NA
» Remember exceptions when treatment of metals can
occur!
Q-27
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MAINTENANCE CHEMICALS
AND OTHERWISE USE
DON'T FORGET ABOUT OTHERWISE USE!
Otherwise use chemicals related to facility
maintenance activities are easily overlooked and
not accounted for in threshold determinations
Identify otherwise use activities even if a
manufacturing and/or processing threshold has
been exceeded for a Section 313 chemical
• Releases and waste management activities would be
reportable
Develop tools to identify and account for the
otherwise use of these chemicals in mixtures or
trade name products R.2
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WHAT CHEMICALS ARE OTHERWISE USED
AT YOUR FACILITY?
List chemicals otherwise used at your facility and
how they are used:
R-3
MAINTENANCE CHEMICALS AND
OTHERWISE USE
Otherwise uses of Section 313 chemicals include:
• Maintaining process-related equipment and structures
• Cleaning process-related equipment, parts, and
structures
• Waste treatment
• Process-related building cooling/heating
• Process-related fuel use
R-4
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MAINTENANCE CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used for maintenance of process equipment and
structures:
• Xylene in paint applied to process equipment
• Zinc compounds in lubricating oils
• Metal alloys in parts tooling and equipment repair
• Metal compounds in welding rods used to repair
equipment and structures
• Metal compounds in refractory bricks used to line
furnaces
R-5
CLEANING CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used for cleaning process equipment and
structures:
• 1,2,4-trimethy I benzene in diesel fuel used to clean bulk
storage tanks
• Phenol in paint strippers
• Dichlorofluoromethane in contact cleaners
• Glycol ethers in aqueous-based cleaning solutions
R-6
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ADDITIONAL CHEMICALS
OTHERWISE USED
Examples of Section 313 chemicals otherwise
used at facilities:
• HCFC-22 used to refrigerate product before sale
• Ammonia used to treat process water
• Ethylbenzene in fuel used to power process equipment
• Ethylene glycol sprayed on coal piles to prevent
freezing
• Pesticides used in cooling towers to prevent algae
R-7
OTHERWISE USE
CHEMICAL EXEMPTIONS
For Section 313 chemicals otherwise used for
maintenance or cleaning of non-process-related
equipment and structures, the following may
apply:
• Routine janitorial or facility grounds maintenance
exemption
» Example: Xylene In cleaners used to clean the employee
cafeteria
• Structural component exemption
» Example: Toluene in paint used to paint the employee
recreation center
R-8
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OTHERWISE USE
CHEMICAL EXEMPTIONS
Motor vehicle exemption if the chemical is used to
maintain motor vehicles operated by the facility
• Example:
» Xylene in engine degreasers used to maintain the
facility motor vehicles
Personal use exemption if the chemical is
contained in non-process related items solely for
employee personal use
• Example:
» Chlorine to treat on-site drinking water
R-9
ARTICLES EXEMPTION
For Section 313 chemicals contained in like items
(e.g., tools) otherwise used for maintenance of
equipment and structures:
• Articles exemption provided that the item:
» Is formed into a specific shape or design during
manufacture; and
» Has end-use functions dependent in whole or in part on its
shape or design during end-use; and
» Does not release a Section 313 chemical under normal
processing or otherwise use conditions at a facility (£ 0.5
pounds)
R-10
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ACCOUNTING TIPS FOR OTHERWISE USE
CHEMICALS
• Develop methods for orchestrating data
collection of mixtures and trade name products
being otherwise used
• Coordinate with purchasing/vendors
• Develop inventory controls
• Require maintenance logs for process equipment
• Require requisition or "sign out" procedure for Section
313 chemicals from tool cribs and supply rooms
• Take year-end inventories
R-11
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GETTING IT RIGHT: AVOIDING COMMON
ERRORS
WHY IT'S IMPORTANT TO GET IT RIGHT
i Using TRI data
• EPA is required to make data available to the public on-line
• Data are available on-line through TRI Explorer, Envirofacts,
the National Library of Medicine, and non-EPA databases
• Data are available in other forms (paper reports)
• All states receive data; some make it available electronically
S-2
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EPCRA SECTION 313 ENFORCEMENT
Current enforcement trends
• Shift from simply identifying non-reporting facilities to
facilities submitting poor quality data
• Focus on multi-media inspections (i.e., examine obligations
under multiple statutes)
• Encourage self-disclosure through EPA's audit policy
• Assign pollution prevention-related supplemental
environmental projects (SEPs)
» In FY98,36% of EPCRA penalty actions included a SEP.
Most SEPs of any regulatory program
S-3
EPA AUDIT POLICY
Audit Policy enhances environmental protection
through incentives for companies to self-police,
disclose and correct violations
Companies that satisfy the Policy's criteria are
eligible for up to 100% reductions in otherwise
applicable penalties
Since implemented in 1995, over 1,500 companies
have self-disclosed violations at over 6,065 facilities
under the policy
S-4
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EPA AUDIT POLICY
Conditions to qualify (nine criteria):
• Systematic Discovery of the Violation through Environmental Audit or Due
Diligence
• Voluntary Discovery
• Prompt Disclosure
• Discovery and Disclosure Independent of Government or Third Party
Plaintiff
• Correction and Remediation
• Prevent Recurrence
• No Repeat Violations
• Other Violations Excluded
• Cooperation
For more information, including a copy of the Audit Policy
(revised in May 2000), visit:
http://es.epa.gov/oeca/ore/apolguid.html
EPCRA SECTION 313 ENFORCEMENT
Companies violating any statutory or regulatory
requirement are subject to penalties of up to $27,500
per day per violation
Companies subject to citizen suits and could also be
liable for attorney fees and litigation costs
Government's penalty is determined by applying the
Enforcement Response Policy (ERP) to each
violation
Violations are assessed per chemical or obligation
and per year
S-6
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EPCRA SECTION 313 ENFORCEMENT
National Nitrate Initiative! 350 companies paid over $1.7 million
in penalties and agreed to audit over 1000 facilities for failing to
report coincidentally manufactured nitrate compounds
generated from nitric acid treatment. Similarly situated
companies self disclosing under EPA's Audit Policy pay no
penalty. The final report detailing the results of the nitrate
initiative is available at:
http;/Avww.epa.qov/oeca/ore/toed/nitrate.html
Steeltech vs. U.S. EPA. 273 F.3d (6th Cir. 20011: U.S. Court of
Appeals for the Sixth Circuit upholds EPA's use of the EPCRA
5313 Enforcement Response Policy (ERP) in imposing $61,736
penalty and confirms that EPCRA is a strict liability statute —
lack of knowledge about regulatory obligations is no defense.
Available at
http://pacer.ca6.uscourts/qov/opinions.pdf/01 a041 Qp-06.pdf
S-7
EPCRA SECTION 313 ENFORCEMENT
In re Bituma-Stor Inc.. EPCRA-7-99-0045 (2001): Respondent
assessed $59,576 penalty for failing to file 3 Form Rs and 1 Tier
II (EPCRA 312) Form, despite "blemish-free" environmental
compliance history. Available at:
http://www.epa.gov/alihomep/orders/bituma3.pdf
In re Dow Chemical. EPCRA-9-99-0030 (2000): Respondent
assessed $100,000 penalty for failing to file 9 Form Rs.
Available at: http://www.epa.aov/alihomep/orders.dow.pdf
S-8
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EPCRA SECTION 326: CIVIL ACTIONS
Any person may bring civil action on their own
behalf against a private-sector facility owner or
operator for:
• Failure to submit emergency follow-up notices under
EPCRA Section 304
• Failure to submit an MSDS or a list of MSDS chemicals
• Failure to complete or submit Tier l/ll inventories
• Failure to complete or submit Form Rs or Form As
S-9
COMMONLY MADE ERRORS
Threshold determination errors
Completion errors
Release estimation errors
Off-site transfers reporting errors
Other waste management and source reduction
errors
Federal facility name and/or parent company name
errors
S-10
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THRESHOLD DETERMINATIONS
Helpful hints for conducting accurate threshold
determinations
• Apply chemicals to correct threshold activity
• Distinguish between metals and metal compounds
• Consider all avenues a chemical may enter a facility;
chemical qualifiers; chemical synonyms; and on-site
manufacturing
• Recognize the limitations for exemptions
Results of incorrect threshold determinations
• No form is submitted when one is required
• Federal facility does not meet requirements of EO 13148
S-11
FORM COMPLETION CHECKLIST
Helpful hints for completing the Form R/Form A
• Complete all required sections of a current, valid form
• Correctly identify the Section 313 chemical using the correct
CAS number and correct listed TRI name
• Use the NA indicator for data elements that are not relevant
• Indicate the correct reporting year
• Clearly identify revisions
• Sign hardcopy of forms or certification letters for electronic
submissions
S-12
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FORM COMPLETION CHECKLIST (CONT'D)
To avoid completion errors, use EPA's reporting
software (TRI-ME or ATRS)
• Software will prompt the user to complete required sections
• Software will conduct validation check to ensure Form R is
complete
Result of completion errors
• Violation
• Form prevented from being entered Into the database
S-13
RELEASE ESTIMATES
Helpful hints for accurate release estimates
• Always use your best available information
• Estimate the quantity of Section 313 chemical, not the entire
waste stream
• Differentiate fugitive from stack emissions
• Zero air emissions for VOCs are unlikely
• Watch out for releases of Section 313 chemicals with
qualifiers
• Check your math and document your work!
Result of release estimation errors
• Incorrect release estimates and inconsistencies from year to
year S-14
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OFF-SITE TRANSFER
REPORTING
Helpful hints for accurate off-site transfer reporting
• Do not report Intra-facllltv transfers as off-site transfers
• Report the quantity of Section 313 chemical transferred, not
the entire transfer quantity
• Identify waste treatment, disposal, recycling, and energy
recovery activities correctly
Results of off-site transfer errors
• Incorrect estimates (e.g., over-estimates)
• Misclassif(cation of facility's handling of Section 313
chemicals in wastes
S-15
WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTION 8.1
Helpful hints for reporting quantity released, Section
8.1
• Include off-site disposal quantities (reported In Section 6.2),
on-site releases (reported in Sections 5.1 through 5.5), and
releases to POTWs for metals and metal compounds only
(reported In Section 6.1)
• Do not include non-production-related, one-time events
(e.g., catastrophic or remedial releases/transfers)
» These should be reported In Section 8.8
S-16
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WASTE MANAGEMENT AND SOURCE
REDUCTION-SECTIONS 8.2-8.7
• For on-site waste management:
• Report the quantity off Section 313 chemical actually
recovered for energy, recycled, or treated, not the total
amount entering the energy recovery, recycling, or
treatment unit
• For off-site waste management:
• Conversely, report the total quantity sent off-site for
recovery, recycling, or treatment
» You are not required to know the efficiency of the off-site
unit
S-17
WASTE MANAGEMENT AND SOURCE
REDUCTION
Energy recovery
• Do not report halons, metals, or metal compounds
• Do not include incineration activities
Treatment
• Metals and metal compounds cannot be destroyed;
therefore, do not report as treated on or off-site
Catastrophic and remedial releases and transfers
• Section 8.8 quantities should be included in Sections 5-7 (as
appropriate), but not in Sections 8.1-8.7
S-18
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FEDERAL FACILITY
IDENTIFICATION
Helpful hints for Federal facilities
• Correctly identify if GOCO or Federal facility submission in Part I,
Section 4.2 of Form R
» Check box c. if Federal facility
» Check box d. if GOCO
• Correctly identify department or agency
• Use SIC codes in Part I, Section 4.5 that best describe the facility's
activities
• Use EPA's new EPCRA Section 313 Questions and Answers
Addendum for Federal Facilities (U.S. EPA, Office of Environmental
Information, May 2000)
Results of incorrect Federal facility identification
• Double-counting
S-19
SUBMITTING REVISIONS
Revisions can be made in hardcopy
• Hardcopy revisions must be made in blue ink on a copy of
the form originally submitted
For revisions made for reporting year 1991 or later, mark an "X"
in the space marked "Enter "X" here if this is a revision" on
pagel
Provide a new original signature and date for each revision
Send to EPA's EPCRA Reporting Center and to the appropriate
state agency
For RY 2001 withdrawal and revisions processes, visit the TRI
website at
http://www.epa.gov/tri/guide_docs/2002/rev_wthdrl.pdf
S-20
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EXERCISE #6:
TRI KNOWLEDGE QUIZ
Purpose: Familiarize participants with the criteria for TRI reporting, including thresholds for
manufacturing, processing, or otherwise using listed chemicals, which determine whether
or not a facility must submit a Form R for a listed Section 313 chemical or chemical
category.
Take-A ways: Knowledge and understanding of TRI reporting thresholds.
Instructions: Read each question carefully. Using your knowledge of TRI reporting thresholds, choose
the best of the four answers.
1. A facility processes 21,000 pounds of formaldehyde each calendar year. It also imports and then
otherwise uses 9,000 pounds of formaldehyde annually. In addition, each year the facility
receives 15,000 pounds of solution that contains 34% formaldehyde by weight and repackages it
for distribution and sale. The firm is in SIC code 2834, ships over 600 pounds of formaldehyde
in wastes off-site for disposal, and has 20 full-time employees. Assuming these values remain the
same over the next five years, under Section 313 this firm:
a. Must report for each calendar year.
b. Does not have to report for each calendar year, because the thresholds are not met.
c. Will not be required to report for each calendar year because it does not manufacture the
chemical.
d. Is not required to report because it employs less than 25 full-time employees.
Fifteen thousand (15,000) pounds of a listed chemical is purchased in the current reporting year
and is used in a re-circulating cooling jacket. This quantity remains in use indefinitely and no
additional quantity is added in subsequent years. Are you required to report for this chemical and
if so, for what year?
a. Do not consider this type of material at all because it is a purchased compound.
b. The use of the compound must be considered towards the otherwise use threshold for the
current reporting year only.
c. The use of the compound must be considered for the current reporting year and every
reporting year thereafter, until the mixture is replaced.
d. Consider only a part of the total amount the current reporting year, and a part every .
reporting year thereafter, for the life of the mixture.
-------
3. A facility produces nitrate compounds as a result of its waste treatment operations, and transfers
the nitrate compounds to an off-site location, where all of the Section 313 chemical is extracted
and recycled. Which of the following is true?
a. The facility can exclude amounts of the nitrate compound from threshold determinations
and release estimation because the source qualifies for the de minimis exemption.
b. Coincidental production of the nitrate compounds is not covered under Section 313,
therefore the facility need not consider this source of chemical production towards
thresholds and estimation of off-site transfers.
c. The facility need not consider this source for thresholds and estimation of off-site
transfer because all of the listed chemical is eventually recycled.
d. The facility must include all amounts of the nitrate compounds coincidentally produced
in threshold determinations and release and other waste management calculations if it
exceeds a threshold.
4. Ten times per year, a facility receives chlorine in 1 ton cylinders. Half of the chlorine mixture is
transferred to a tank to make a bleaching mixture, where its concentration drops below the de
minimis level, which is then sold and distributed in commerce. One fourth of the original mixture
is used to treat the drinking water consumed by employees. The remaining one fourth of the
original mixture is used throughout the plant to clean process equipment. Wastewater from the
cleaning and bleach production operations is released with chlorine levels well below the de
minimis level. Which of the following is true?
a. All uses of the chlorine are subject to Section 313 reporting because the concentration of
the received mixture is well above the de minimis level and the threshold limit for
otherwise use has been met.
b. Only the use of chlorine for drinking water is exempt from Section 313 reporting.
c. Only the drinking water and cleaning operations will be exempt from Section 313
reporting due to the personal use and routine maintenance exemptions, respectively.
d. The drinking water and cleaning uses are covered under the personal use and routine
maintenance exemptions, respectively. The bleach production operation and the
wastewaters generated in conjunction with this operation are not exempt from Section
313 reporting; however, the wastewaters from the cleaning operations are exempt.
-------
5. A facility processes 100,000 pounds of a mixture containing 25% zinc chromate, and 25%
chromium dioxide by weight. For purposes of Section 313 reporting, how much zinc and
chromium were processed?
a. 25,000 pounds zinc compounds, and 25,000 pounds of chromium compounds
b. 25,000 pounds zinc, and 25,000 pounds chromium
c. 25,000 pounds zinc, and 50,000 pounds chromium
d. 25,000 pounds zinc compounds, and 50,000 pounds chromium compounds
6. If a chemical on Section 313 list has a "qualifier," it means that it is subject to TRI reporting
when manufactured, processed, or otherwise used
a. In the thresholds specified (i.e., its reporting threshold is higher or lower than that for
other chemicals).
b. In the specified form or activity.
c. Within the specified SIC code industries.
d. Except when used at federal facilities.
7. For aqueous ammonia, what percentage of the total ammonia present is applied to threshold
determinations?
a. 100%
b. 10%
c. 1%
d. 20%
8. A facility buys a solution containing 29% 1,1,1-trichloroethane and processes it as a constituent
of a cleaning solution that they sell in retail stores. The 1,1,1-trichloroethane is present in final
product at 0.5%. The product is packaged into one-gallon containers. What amounts of the
1,1,1-trichloroethane in mixtures must the facility consider for threshold determinations?
a. Any amount used within the facility during the reporting year, except the amount
distributed through retail outlets to consumers, must be considered processed.
b. Because the mixture was otherwise used, it is not eligible for the de minimis
exemption. The quantity used must be applied to the otherwise use threshold.
c. Because the mixture was received and processed in concentrations above the de minimis
for 1,1,1-trichloroethane, all quantities must be applied to the processing threshold.
d. Only amounts distributed into commerce need to be considered towards the processing
threshold, and because these quantities are present below the de minimis concentration,
they are exempt.
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9. Which of the following qualifies as a Section 313 reporting exemption?
a. Like "articles" that release over 10 pounds of a Section 313 chemical, not recovered,
under regular normal processing or use
b. Painting process equipment at the facility
c. Chemical use in non-process related routine janitorial or facility grounds maintenance
d. Laboratory support activities
10. In order to file a Form A Report, you must manufacture or process or otherwise use no more than
one million pounds of the Section 313 chemical and you must have
a. Less than 1,000 pounds of total releases and other waste management estimates of the
Section 313 chemical.
b. No more than 500 pounds of total releases and other waste management estimates of the
Section 313 chemical.
c. No more than 100 pounds of total releases and other waste management estimates of the
Section 313 chemical.
d. No more than 50 pounds of total releases and other waste management estimates of the
Section 313 chemical.
11. My facility manufactured .009 pounds of dioxin and dioxin like compounds in our combustion
units, and also incorporated 11.4 pounds of mercury into thermometers sent to a customer's
facility in Canada during the reporting year. Have I exceeded any thresholds?
a. No. The facility doesn't exceed the threshold for dioxin and dioxin like compounds and
the thermometers qualify for the articles exemption. Therefore, no thresholds have been
exceeded.
b. The facility must report for mercury, but does not exceed the threshold for dioxin
compounds.
c. The facility must report for dioxin and dioxin like compounds, but since the mercury is
going to another country, it doesn't have to report for mercury.
d. The facility must report for both dioxin and dioxin like compounds and mercury.
12. At Fred's custom oils manufacturing facility during the reporting year, 55 pounds of polycyclic
aromatic compounds (PACs) are manufactured in the combustion unit, 45 pounds of PACs are
processed in the lubricants, and 5 pounds of PACs are otherwise used by contractors that are
constructing a new manufacturing plant. Does Fred need to report for PACs?
a. No, none of the thresholds have been exceeded during the reporting year.
b. Yes, since 5+45 + 55 equals 105 pounds, Fred must report for PACs.
c. Yes, the processing and otherwise use activities both exceed a threshold.
d. Yes, Fred has to report, but he doesn't have to consider the contractors because they
aren't employed directly by Fred's company.
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Information Resources
TR1 HOMEPAGE
EPA's Toxics Release Inventory Homepage at
http://www.epa.gov/tri
• General information on the TRI Program and Program
development
• Information on how to use the TRI data
• Access to TRI data (e.g., public data release, state fact
sheets, links to TRI databases)
• Guidance documents for newly added industries and
Section 313 chemicals
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TRI REPORTING SOFTWARE
• TRI Made Easy (TRI-ME)
• New Software
• Intelligent software tool that guides facilities in determining
whether they have to report, and in completing forms.
• Automated TRI Reporting Software (ATRS)
• Electronic versions of TRI forms
• RY2001 will probably be the last year (will be replaced by TRI-
ME)
• TRI Assistance Library (TRIAL)
• Indexed, searchable collection of key guidance documents
•To be mailed to all TRI-reporting facilities in Spring
2002
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SECTION 313 GENERAL GUIDANCE
Toxic Chemical Release Inventory Reporting Forms and
Instructions. U.S. EPA, Office of Information Analysis and
Access. Available at http://www.epa.gov/tri
EPCRA Section 313 Questions and Answers (Revised 1998
Version). U.S. EPA, Office of Pollution Prevention and Toxics.
December 1998. Available at
http://www.epa.gov/tri/guidance.htm
Common Synonyms for Chemicals Listed Under Section 313 of
EPCRA. U.S. EPA, 1995.
Consolidated List of Chemicals Subject to Reporting Under the
Act (Title III List of Lists). U.S. EPA, Office of Solid Waste and
Emergency Response. November 1998. Available at
http://www.epa.gov/tri/guidance.htm
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SECTION 313 GENERAL GUIDANCE
Emergency Planning and Community Right-to-Know Act-
Section 313: Final Guidance for Reporting Releases and Other
Waste Management Activities of Toxic Chemicals: Lead and
Lead Compounds
The Final Lead Guidance document is at:
http://www.epa.govftri/guide_docs/2001/pb_finaLguide.pdf
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SECTION 313 TECHNICAL GUIDANCE
• Industry-specific technical guidance documents such as:
• EPCRA Section 313 Reporting Guidance for Rubber and Plastics
Manufacturing. U.S. EPA, Office of Environmental Information.
August 2001. Available at http://www.epa.gov/lri/guldance.htm
• Guidance for the most recently added industries, available at
http://www.epa.govAnYguidance.htm
• Chemical-specific guidance documents, such as:
• Guidance for Reporting Sulfurlc Add. U.S. EPA, Office of Pollution
Prevention and Toxics. March 1998. Available at
http://www.epa.gov/tri/guldance.htin
• List of Toxic Chemicals within the Glycol Ethers Category. U.S.
EPA, Office of Environmental Information. December 2000.
Available at http://www.epa.gov/tri/guidance.htm
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SECTION 313 TECHNICAL GUIDANCE
Technology Transfer Network (TIN)
• Internet: http://www.epa.gov/ttn/
• Help Desk (919) 541 -5384
• Compilation of Air Pollutant Emission Factors (AP-42)
• WATER9 program
• Updates WATERS, CHEMDAT8, and CHEM9
• TANKS program
T-7
ON-LINE ACCESS TO TRI DATA
TRI Explorer
• http://www.epa.gov/triexplorer
ENVIROFACTS Data Warehouse
• http://www.epa.gov/enviro/
TOXNET (National Library of Medicine)
• http://toxnet.nlm.nih.gov
Right-to-Know Network (RTK NET)
• Modem: (202) 234-8570; Information: (202) 234-8494; Internet:
http://www.rtk.net
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PUBLIC ACCESS TO TRI
TRI Reports and Data (EPA TRI Web Site)
• TRI Public Data Release Annual Report
• TRI Public Data Release State Fact Sheets
• State Data files
• http://www.epa.gov/tri
TRI User Support Service: (202) 260-1531
EPCRA Call Center: (800) 424-9346 or (703) 412-9810
T-9
DOCUMENT DISTRIBUTION CENTERS
RCRA, Superfund & EPCRA Call Canter
(800)424-0346
(703) 412-9810 (DC Metro area)
TDD (800) 553-7672 or
TDD Washington, DC Area Local
(703)412-3323
Fax (703) 412-3333
http://www.epa.gov/epaoswer/hotline
U.S. Environmental Protection Agency
Ariel Rlos Building
1200 Pennsylvania Avenue, N.W.
Attn: TRI Documents
MC:2844
Washington, DC 20460
(202)564-9554
Email: TRIDOCSOepa.gov
T-10
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POLLUTION PREVENTION INFORMATION
OPPT Pollution Prevention (P2) Internet Site
• http://www.epa.gov/opptintr/p2home/index.html
Enviro$en$e Information Network
• BBS modem (703) 908-2092; User support (703) 908-2007
• http://es.epa.gov/index.html
Pollution Prevention Information Clearinghouse
(PP1C)
• (202)260-1023
• http://www.epa.gov/greenbuildings/library/libppic.htm
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EPA ELECTRONIC MAILING LISTS
(LISTSERVER)
i To subscribe to an electronic mailing list (listserver), send e-mail
to: listserver®unixmail.rtpnc.epa.gov
i Subject line: leave blank
i Text: SUBSCRIBE
SUBSCRIBE EPA-WASTE JOHN SMITH
i Some mailing lists are:
• EPA-TRI2: Toxic Release inventory Federal Registers
• HOTLINE_OSWER: RCRA. Suoerfund & EPCRA Monthly
Hotline Report and Updates
• EPA-PRESS: EPA press releases
• ERA-MEETING: EPA meeting notification
• OPPT-NEWSBREAK: OPPT Library daily news service
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