EPA 560/4-90-014
June 1990
GUIDANCE FOR FOOD PROCESSORS
Section 313, Emergency Planning and
Community Right-to-Know Act
by
PEI ASSOCIATES, INC.
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-D8-0112
Work Assignment P2-25
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Pesticides and Toxic Substances
• 401 M Street, S.W.
Washington, D.C 20460
-------
DISCLAIMER
This report was prepared under contract to an agency of the United States Government.
Neither the United States Government nor any of its employees, contractors, subcontractors, or
their employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use or the results of such use of any information, apparatus,
product, or process disclosed in this report, or represents that its use by such third pany would
not infringe on privately owned rights.
Publication of the data in this document does not signify that the contents necessarily
reflect the joint or separate views and policies of each sponsoring agency. Mention of trade
names or commercial products does not constitute endorsement or recommendation for use.
ii
-------
ACKNOWLEDGEMENT
This report was prepared by PEI Associates, Inc. under the direction of Mr. Thomas K.
Corwin. The Project Officer for the Office of Toxic Substances' Chemical Engineering Branch
was Ms. Kathy Franklin.
PEI would like to acknowledge the contributions of the National Food Processors
Association and its member organizations who provided review comments on a preliminary draft
of this manual.
iii
-------
CONTENTS
&££
1. Introduction 1-1
2. Section 313 Reporting Requirements 2-1
Who Must Report 2-1
Thresholds 2-3
Exemptions 2-4
Listed Chemicals 2-8
What Must Be Reported 2-10
3. Overview of Section 313 Release Estimation 3-1
General Concepts 3-1
Common Reporting Problems 3-3
4. Release Estimation Scenarios in Food Processing 4-1
Water Treatment 4-3
Refrigerant Uses — .. - 4-5
Food Ingredients .. 4-6
Reactams 4-8
Catalysts 4-9
Extraction/Carrier Solvents 4-10
Cleaning/Disinfectant Uses 4-12
Wastewater Treatment .. 4-14
Fusigjcts 4-16
Pesticides/Herbicides 4-17
Byproducts ...... 4-IS
Can Making/Coating ............................ -— 4-19
5. How to Complete Form R ...... 5-1
Appendix A - Alphabetical Listing of 313 Chemicals — A-l
Appendix B - Release Estimation for Ammonia, Chlorine, and Acids.... B-l
-------
SECTION 1
INTRODUCTION
In 1986 Congress passed the Superfund Amendments and Reauthorization Act (SARA).
Concern over the Bhopai tragedy of 1984 plus many state and community right-to-know laws
resulted in Title HI of this legislation. Title in of SARA is also known as the Emergency.
Planning and Community Right-to-Know Act (EPCRA). This act requires industry to report
detailed informadon concerning the use, generation, and release of hazardous and toxic
materials. EPCRA is unique from other environmental regulations. It does not establish release
limitations, standards of practice, or standards of operation. Instead, it requires industries to
provide the public with information on hazardous and toxic materials used at individual facilities.
The purpose of providing this information is to help in emergency planning and community
right-to-know.
Table 1-1 summarizes the principal reporting requirements that fall under various
sections of EPCRA. Under Section 313, facilities in SIC Codes 20 through 39 must report
annually any releases to the environment of over 300 chemicals and chemical categories. This
information must be reported to EPA and states on the Toxic Chemical Release Inventory
Reporting Form (Form R).
The purpose of this manual is to help facilities in the food processing industry (SIC Code
20) with the annual reporting requirements under Section 313 of EPCRA. This industry group
includes facilities that produce meat products, dairy products, preserved fruits and vegetables,
grain mill products, bakery products, sugar and confectionery products, fats and oils, beverages,
and miscellaneous other food products. The manual provides a working understanding of
Section 313 repairing requirements plus discussions of specific release estimating scenarios
encountered at many faoliaes in this induscy. Since each plant is unique, the recommendations
presented' may have to be modified for a particular facility.
The manual has several sections to provide quick reference. Section 2 presents an
overview of Section 313 reporting requirements. Section 3 covers general concepts of Section
313 release estimation and common reporting errors. Section 4 discusses Section 313 release
scenarios in the food processing industry. It covers development of chemical release estimates
for several types of operations commonly encountered in food processing. These include 1)
water treaeneat, 2) refrigerant uses, 3) food ingredients, 4) reactants, 5) catalysts, 6)
extraction/carrier solvents, 7) cleaning/disinfectant uses, 8) wastewater treatment, 9) fumigants,
10) pesticides/herbicides, 11) byproducts, and 12) can making/coating. Section 4 explains in
detail how to complete each section of Form R. Appendix A is an alphabetical listing of the
chemicals and chemical categories that are subject to Section 313 reporting. Appendix B
presents detailed discussions of release estimation for ammonia, chlorine, and acids; these
chemicals comprise the majority of the Form R's submitted by food processors.
You should first review each section of the manual briefly to get an overview of its
contents. Next, read in detail Sections 2 and 3 and the discussions of the pertinent operations for
your facility in Section 4. There is also considerable useful information in EPA's "Toxic
1-1
-------
Table 1-1. Summary of Reporting Requirements Under EPCRA.
Section 302
Presence of Extremely
Hazardous Substances
Section 304
Emergency Notification
If a facility has any of more than 400 "extremely hazardous substances" on
site in quantities greater than Threshold Planning Quantities established by
EPA, it must notify its State Emergency Response Commission (SERQ that it
is subject to the emergency planning requirements of this section. A facility
representative most participate in the local emergency planning process. The
facility also must provide any information to the Local Emergency Planning
Committee (LEPC) deemed necessary for development or implementation of a
local emergency plan.
A facility must notify the LEPC and SERC immediately of the release of any
"extremely hazardous substances" (as defined by Section 302), or any
substances subject to emergency nouficauon requirements under CERCLA, in
amounts above the Reportable Quantities that EPA has established for each
substance. The facility must follow up this initial notification with a written
statement providing details of the incident.
Section 311
Material Safety Data Sheet
(MSDS) Reporting
A facility must submit to the LEPC, SERC, and local fire department a list of
MSDS's. or copies of MSDS's. for any "hazardous chemicals" (as defined
under the OS HA Hazard Communication Standard) that are present on site in
quantities greater than 10.000 pounds. It also must report any "extremely
hazardous substances" (as defined under Section 302) thai are present on site
in quantities above the Threshold Planning Quantities at 500 pounds. This
reporting requirement must be met within 90 days for any new chemical
handled on site.
Section 312
Hazardous Chemical
Inventory
Section 313
Toxic Chemical
Release Estimation
A facility must submit to the LEPC, SERC. and local fire department certain
information for any "hazardous chemical" reported under Secuon 311. This
includes any type of nazara uie material may pose, uie quantities stored,
general storage locations, and type of storage. The reports for each calendar
year are due by March 1 of the following year.
A facility classified in SIC Codes 20 through 39 (manufacturing) and having
the equivalent of ten or more full-time employees must estimate annually all
environmental releases of "toxic chemicals" defined ia a Congrcssionally
mandated list that contains more than 300 sabstances. This applies to those
listed chemicals that it manufactures (including imported) or processes in
annual quantities exceeding 22,000 poinds, or otherwise uses in quanaues
exceeding 10,000 pounds. The facility must develop estimates for the
amounts of each substance released annually to air. land, and water, and the
amounts transferred to off-six facilities. It also must provide estimates of the
efficiencies of any waste treatment devices used. Repots for each calendar
year are due by July 1 of the following year. The method used to identify
these chemicals and to estimate their releases must be documented and kept on
file for three yean.
1-2
-------
Chemical Release Inventory Reporting Package for 1989" (EPA 560/4-90-001). Besides Form R
and reporting instructions, the EPA package contains a "Questions and Answers" section that
addresses many common reporting problems. The EPA has developed a general technical
guidance manual for Section 313, "Estimating Releases and Waste Treatment Efficiencies for the
Toxic Chemical Release Inventory Form" (EPA 560/4-88-002). Other useful EPA publications
are "Common Synonyms for Section 313 Chemicals" (EPA 560/4-90-005) and "Comprehensive
List of Chemicals Subject to Reporting Under the Act (Tide in List of Lists)" (EPA 560/4-90-
011). These reports, plus other EPA documents regarding EPCRA, are available from:
Emergency Planning and Community Right-to-Know
Document Distribution Center
P.O. Box 12505
Cincinnati, OH 45212
For specific questions, you also may call EPA's Emergency Planning and Community
Right-to-Know Hotline at (800) 535-0202 or (202) 479-2449 (in Washington, D.C. or Alaska).
1-3
-------
SECTION 2
SECTION 313 REPORTING REQUIREMENTS
This section presents an overview of the Section 313 reporting requirements. It includes
discussions of 1) who must report, 2) the threshold levels that trigger reporting for different types
of chemical activities, 3) specific exemptions to the reporting requirements, 4) an overview of the
chemicals subject to reporting, and 5) a summary of the information thar must be reported on
Form R.
WHO MTJST REPORT
A plant, factory, or other facility falls under the provisions of the Section 313 reporting
requirements if it meets all three of the following criteria:
• It is in Standard Industrial Gassification (SIC) codes 20 through 39 (i.e., it
conducts manufacturing operations);
• It has ten or more full-time equivalent employees; and
• It manufactures (including imports), processes, or in any other way uses any of
the listed toxic chemicals or chemical categories in amounts greater than
specified threshold quantities.
Table 2-1 lists the industry categories in SIC code 20.
The amount of the chemical released to the environment does not affect the reporting
requirements. Thus, even if there are no releases of a listed chemical, a facility must report if it
meets the requirements regarding SIC code, number of employees, and quantity of the listed •
chemical that was manufactured, processed, or otherwise used during the calendar year.
A "facility" is all buildings, equipment, structures, and other stationary items that are on a
single site or adjacent or contiguous sites owned or operated by the same person or entity. An
"establishment" is a single business unit at a location. Although many facilities are equivalent to
an establishment, a facility can include several establishments within a property boundary and
owned or operated by the same person or entity. A facility therefore can be a multi-
establishment complex. Such a facility may submit reports that cover all its establishments, or
the individual establishments may report separately.
A few facilities may have several separate establishments at one location, some of which
have primary SIC codes within the 20 through 39 range, and some of which have primary SIC
codes outside that range. The entire facility is subject to Section 313 reporting if it meets either
of the following conditions:
• The combined value of products from those establishments that are in SIC
codes 20 through 39 is more than 50 percent of the total value of products
shipped or produced by the whole facility; or
2-1
-------
2011
2013
2015
2021
2022
2023
2024
2026
2032
2033
2034
2035
2037
2038
2041
2043
2044
2045
2046
2047
2048
2051
2052
2053
2061
2062
2063
2064
2066
2067
2D6S
2074
2075
2076
2077
2079
2082
2083
2084
2085
2086
2087
2091
2092
2095
2096
2097
2098
2099
Tabic 2-1. Industry Categories in SIC Code 20.
Descrmtinn
Meat packing plants
Sausages and oiher prepared meat products
Poultry slaughtering and processing
Creamery buuer
Natural, processed, and imitation cheese
Dry. condensed, and evaporated dairy products
Ice cream and frozen desserts
Fluid milk
Canned specialties
Canned fruit, vegetables, preserves, jams, and jellies
Dried and dehydrated fruits, vegetables, and soup mixes
Pickled fruits and vegetables, vegetable sauces and seasonings, and salad dressings
Frozen fruits, fruit juices, and vegetables
Frozen specialities, not elsewhere classified
Flour and other grain mill products
Cereal breakfast foods
Rice milling.
Prepared flour mixes and dough
Wet com milling
Dog and cat food
Prepared feeds and feed ingredients for animals and fowls, except dogs and cats
Bread and other bakery products, except cookies and crackers
Cookies and crackers
Frozen bakery products, except bread
Cane sugar, except refining
Cane sugar refining
Beet sugar
Candy and other confectionery products
Chocolate and cocoa products
Chewing gum
Sailed and roasted nuts and seeds
Cottonseed oil mills
Soybean oQ mills
Vegetable oil mills, except corn, cottonseed, and soybean
Animal and marine fats and oils
Shortening, table oils, margarine, and other edible fats and oils, not elsewhere classified
Malt beverages
Malt
Wines, brandy, and brandy spirits
Distilled and blended liquors
Bouled and canned soft drinks and carbonated waters
Flavoring extracts and flavoring syrups, not elsewhere classified
Canned and cured fish and seafoods
Prepared fresh or frozen fish and seafoods
Roasted coffee
Potato chips, com chips, and similar snacks
Manufactured ice
Macaroni, spaghetti, vermicelli, and noodles
Food preparations, not elsewhere classified
2-2
-------
• One establishment in SIC codes 20' through 39 has a value of products shipped
or produced that is greater than any other establishment in the facility.
For example, a single facility may include a sugarcane farm (SIC 0133) and a processing plant
(SIC 2061). This facility would have to report for listed chemicals used in its agricultural
operations if the value of the products from its processing plant exceeded those from its fanning
operations. To calculate the contribution of the food processing establishment, the facility could
subtract the crop value from the total value of the product shipped from the processing
establishment
A facility that is not stationary and is not located on a single site would not have to report
even though it is in SIC codes 20 through 39. For example, a fish processing factory on a ship
that moves to various locations would not be subject to Section 313, though it may be in SIC
code 2091. A pilot plant within the appropriate SIC codes is a covered facility, provided it meets
the employee and threshold criteria. Warehouses on the same site as covered facilities are also
subject to reporting, but stand-alone warehouses that do not support a manufacturing operation
are not covered.
The owner of a covered facility is not subject to Section 313 reporting if the owner's only
interest in the facility is ownership of the real estate upon which the facility is operated. The
operator of the facility must report if the appropriate criteria are met.
The number of employees is based on the total number of hours worked by ail employees
at the facility during the year. A "full-time employee" is equivalent to 2,000 labor hours per
year. The criterion for number of employees is met if the total hours worked by all employees is
20,000 hours or more. Thus, a facility with eight full-time employees (2,000 hours each) and
four half-time employees (1,000 hours each) would meet the employee threshold. The employee
count must include all employees at a facility, despite their function or location within a building.
Such penonnel as sales staff and contractors therefore must be included with production staff in
the employee threshold determination.
A multi-establishment facility that includes agricultural operations should not tabulate the
hours worked by farm workers that it does not pay. If the facility employs or contracts directly
with these workers, then the hours they work on-site should be counted toward the employee
threshold.
THRESHOLDS
Section 313 requires a facility that meets the SIC code and employee criteria to submit
Form R reports for any listed chemicals that it manufactures or processes in annual quantities
exceeding 23,000 pounds, or otherwise uses in annual quantities exceeding 10,000 pounds.
Chemicals must be classified into the following categories when evaluating whether a reporting
threshold has been surpassed:
• Manufacture - To produce, prepare, import, or compound a listed chemical.
This includes the coincidental production of a chemical during-the processing,
use, or disposal of another chemical, either as a byproduct or an impurity in a
mixture of chemicals. Use of a broker does not negate facility "importation" of
a chemical. If your facility specified that a listed chemical or mixture be
obtained from a foreign source and you specified the amount, then you
"imported" the chemical.
2-3
-------
• Process - To make mixtures* repackage, or use a listed chemical as a feedstock,
raw material, or starting material for making another chemical. This applies to
chemicals that your facility manufactured or received and become pan of your
final product.
• Otherwise use - Any use of a listed chemical that does not fall under the
definidon of manufactured or processed. These usually are chemicals that are
not manufactured and that do not intentionally leave the facility as pan of your
final product
The three principal chemical activities have subcategories that further define each
acdvity. Tables 2-2,2-3, and 2-4 list these activities and their definitions for manufacture,
process, and otherwise use, respectively. Each also includes examples of chemical activities
encountered in the food processing industry.
The difference between processing and otherwise using is important because these
activities are subject to different reporting thresholds. Processing implies incorporation; the
chemical added is intended to become part of a product distributed in commerce. Otherwise
using implies nonincorporation; the chemical added is not intended to become pan of a product
(although some may unintentionally leave the facility in the product).
Thresholds are calculated separately for manufacture, process, or otherwise use of the
same chemical. If any single threshold is met or exceeded, the facility must submit a Form R
covering all activities. Materials in inventory at the end of the calendar year are not included in
the threshold determination. Only those quantities of a chemical actually manufactured,
processed, or used during the year are counted toward the thresholds.
EXEMPTIONS
Section 313 provides for the following processing or use activities that are exempt from
reporting. You do not have to consider amounts of listed chemicals involved in any of these
processing or use activities when determining if reporting thresholds have been exceeded or
when estimating environmental releases. The EPA's 'Toxic Chemical Release Inventor/
Questions and Answer, Revised 1989 Version" (EPA 560/4/90-003) contains more detailed
explanations of these exemptions.
• De minimis materials • Includes chemicals present in materials below a
concentration of 1 percent, or a concentration below 0.1 percent when the
Occupational Safety and Health Administration (OSHA) defines the chemical
as carcinogenic. The list of Section 313 chemicals in the appendix identifies
the appropriate de muiimis level for each listed chemical. This exemption
applies to products that a facility purchases, sells, or commercially uses, but it
does not apply to wastestreams and releases. Wastes and releases must be
reported regardless of their concentration.
• Materials that are processed or used as articles - Includes chemicals present
in solids that undergo no shape change and have no potential for chemical
release. An article is a manufactured item that 1) is formed into a specific
shape or design during manufacture, 2) has end-use functions dependent in
whole or in pan upon its shape or design during end-use, and 3) does not
release a toxic chemical under the normal conditions of the processing or use of
that item at the facility. Articles are thus exempt from threshold determinations
2-4
-------
Table 2-2. Definitions and Examples of Manufactured Chemicals.
Activity
Produced or imported for
on-site use/processing
Produced or imported for
saie/distnbuuon
Produced as a byproduct
Produced as an imparity
Definition
A chemical thai is produced or
imported and then further processed
or otherwise used at the same facility.
A chemical that is produced or
imported specifically for sale or
distribution outside the manufacturing
facility.
A chemical that is produced
coinciden tally during the production,
processing, otherwise use, or disposal
of another chemical substance or
mixture and, following its production,
is separated from that other chemical
substance or mature. This includes
chemicals produced and released
because of waste treatment or
disposal
A chemical chat is produced
coincidentally bwause of the
manufacture, processing, or otherwise
use of another chemical that is not
separated and remains primarily in
the mixture or product with that other
chemical.
Examples in Food Processing*
• Chlorine dioxide that is produced on-
site for water treatment (p. 4-3)
Ammonia that is produced through
breakdown of proteins in a
wastewater treatment system (p. 4-18)
Ammonium sulfas that is produced in
a wastewater treatment system
containing ammonia and sulfuric acid
(p. 4-18)
'More complete discussions of the examples can be found on the referenced pages in Section 4.
2-5
-------
Table 2-3. Definitions and Examples of Processed Chemicals.
Activity
Asareactant
Definition
A natural or synthetic chemical thai is
used in chemical reactions for the
manufacture of another chemical
substance or product. This includes
feedstocks, raw materials,
intermediates, and initiators.
Examples in Food Processing*
• Ammonia that is used as a sorter
component in the batch process
manufacture of cheese (p. 4-8)
• Propylene oxide that is reacted with
com starch to product hydroxyaJkyl
starches (p. 4-8)
As a formulation
component
As an article component
Repackaging only
A chemical that is added to a product
or product mixture before further
distribution of the product and acts as
a performance enhancer during use of
the product. This includes additives,
dyes, reaction diluents, initiators,
solvents, inhibitors, emulsifiers,
- surfactants, lubricants, flame
retardancs, and rheological modifiers.
A chemical that becomes an integral
component of an article distributed
for industrial, trade, or consumer use.
A chemical that is processed or
prepared for distribution in commerce
in a different form, state, or quantity;
for example, materials that are
transferred from a bulk container to
smaller cans or bottles
Zinc compounds that are used as
additives in dog food (p. 4-6)
Phosphoric acid that is used as an
ingredient in the preparation of baking
ingredients and soft drinks (p. 4-6)
Food dyes (p. 4-6)
Pigments that are contained in inks
and coaungs that are applied on-site
(p. 4-19)
'More complete discussions of the examples can be found on the referenced pages in Section 4.
2-6
-------
Table 2-4. Definitions and Examples of Otherwise Used Chemicals.
Activity
As a chemical processing
aid
As a manufacturing aid
Ancillary or other use
Definition
A chemical that is added to a reaction
mixture to aid in the manufacture or
synthesis or another chemical
substance that is not intended to
remain in or become pan of the
product or product mixture. This
includes process solvents, catalysts,
inhibitors, initiators, reacuon
terminators, and solution buffers.
A chemical that aids the
-manufacturing process that does not
become part of the resulting product
and is not added to the reacuon
mixture during the manufacture or
synthesis of another chemical
substance. This includes process
lubricants, metalwortang fluids,
coolants, refrigerants, and hydraulic
fluids.
A chemical that is used for purposes
other than as a chemical processing
aid or manufacturing aid. This
includes cleaners, degrsasers.
lubricants, fuels, and chemicals used
for treating wastes.
Fianroles in Food Processing*
• Nickel catalyst used in the
hydrogenauon'of vegetable oil (p. 4.
9)
• N-butyl alcohol used as a earner
solvent for spices (p. 4-10)
• Gilonne used as a bleaching agent for
flour (p. 4-3)
• Chlorine used for water treatment (p.
4-3)
• Solvents contained in inks and
coaungs ihat are applied on-site (p. 4-
19)
• Ammonia used as a refrigerant (p. 4-
5)
• Ethylene oxide used as a bactericide
during processing of spices (p. 4-16)
Nitric acid used to clean process
equipment (p. 4-12)
Sulfuric acid used for pH ccr.rsl in z
wastewater treatment system (p. 4-14)
'More complete discussions of the examples can be found on the referenced pages in Section 4.
2-7
-------
if, during their normal processing and use, no listed, chemical is released and no
substantial change in form occurs. The exemption does not apply to
manufacture of articles.
• Materials that are structural components of the facility - Includes chemicals
present in materials used to construct, repair, or maintain a plant building.
Examples include solvents and metals present in paint used to coat the
structural components of a building.
• Materials used for janitorial or facility grounds maintenance • Includes
chemicals present in materials used for routine or facility grounds maintenance.
Examples include bathroom cleaners, fertilizers, and garden pesticides in the
same form and concentration commonly distributed to consumers. Equipment
maintenance such as the use of oil or grease is not exempt
• Materials used with facility motor vehicles - Includes chemicals present in
materials used for operating and maintaining motor vehicles operated by the
facility. Examples include gasoline, radiator coolant, and windshield wiper
fluid used in equipment such as cars, trucks, forklifts, and tow motors.
• Personal items - Includes chemicals present in materials such as foods, drugs,
cosmetics, or other personal items. Examples include materials used in the
facility cafeteria and infirmary. Office supplies are also exempt from reporting.
• Laboratory materials - Includes materials used in laboratories that are under
the supervision of a technically qualified individual. This exemption does not
apply to the use or production of listed chemicals in pilot-plant operations and
laboratories for distribution in commerce (i.e., specialty chemicals), but it does
include quality assurance testing.
• Materials as they are drawn from the environment - Includes process water,
noncontac: coolir.g water, ar.d combustion air as drawn from the environment.
Thus, you do not have to consider Section 313 chemicals that are present in
materials drawn directly from the environment. If you add chemicals to
process or noncontact cooling water, this exemption ends at the point where the
chemical is added.
LISTED CHEMICALS
The appendix to this manual contains an alphabetical listing of the chemicals subject to
Section 313 reporting, including their de minimis concentrations. The EPA publications
"Common Synonyms for Section 313 Chemicals'* (EPA 560/4-90-005) and "Comprehensive List
of Chemicals Subject to Reporting Under the Act (Title III List of Lists)" (EPA 560/4-90-011)
are useful references when reviewing the chemicals at your facility for Section 313 eligibility.
The following chemicals subject to Section 313 reporting have activity qualifiers
included in their names. These chemicals are only reportable when the conditions specified in
the qualifiers are met. Chemicals that are listed without parenthetic qualifiers are subject to
reporting in all forms in which they are manufactured, processed, or otherwise used.
• Fume or dust - Three metals (aluminum, vanadium, and zinc) are qualified as
"fume or dust." This does not refer to "wet" forms such as solutions or
2-8
-------
slurries, but to powder, paniculate, or gaseous forms of these metals. The
threshold applies only to amounts manufactured, processed, or otherwise used
in this fonn. Use of zinc metal as a food ingredient is therefore not subject to
reporting unless the chemical is processed as a fume or dust in this applicadon.
• Manufacturing qualifiers - Two chemicals that are widely used in food
processing, saccharin and isopropyl alcohol, contain qualifiers relating to
manufacture. For saccharin, the qualifier means that only manufacturers of the
chemical are subject to the reporting requirement. For isopropyl alcohol, the
qualifier means that only facilities that manufacture the chemical by the strong
acid process are required to report. Facilities that only process or use these
chemicals are not required to report Thus, a facility that uses saccharin as a
food ingredient or that uses isopropyl alcohol as a solvent in inks or coatings
does not need to report for either chemical.
• Solutions - Two chemicals, ammonium nitrate and ammonium sulfate, are
qualified by the texm "solution." Solid, molten, and pelletized forms of these
chemicals are exempt from reporting. A facility that purchases one of these
chemicals in a solid form and creates a solution with it is subject to threshold
determination, since it would be manufacturing the solution form. The EPA
has recently proposed that ammonium sulfate (solution) be removed the list
Section 313 list of toxic chemicals (40 CFR Pan 372). Therefore, for the 1990
reporting year (i.e., Form R's due on July 1,1991) and beyond, ammonium
sulfate should be treated in the same manner as other ammonium salts.
Appendix 3 contains a discussion of estimating releases for these compounds.
• Phosphorus (yellow or white) - Only manufacturing, processing, or use of
pho.Tphorus in the yellow or white chemical forms require reporting. The
handling of black or red phosphorus is not subject to Section 313.
• Asbestos (friable) - Asbestos only need be considered when it is handled in the
friable fonn. This refers to the physical characteristic of being able to be
crumbled, pulverized, or reducible to a powder with hand pressure.
• Aluminum oxide (fibrous) - Beginning with reports for calendar year 1989,
aluminum oxide is only subject to threshold determination when it is handled in
fibrous forms. The EPA has characterized fibrous aluminum oxide for
purposes of Section 313 reporting as a man-made fiber that is commonly used
in high-temperature insulation applications such as furnace linings, filtration,
gaskets, joints, and seals.
The original list of chemicals subject to Section 313 reporting was a combination of
chemical lists from New Jersey and Maryland. Over the past three yean, refinements to the list
have been made and are anticipated to continue. The list can be modified by EPA or through
petitions from industry or the public. The EPA reviews these petitions and initiates a rulemaking
to add or delete the chemical from the list, or publishes an explanation why it denied the pennon.
When evaluating a chemical for addition or deletion from the list, EPA must consider potential
acute and chronic human health effects and adverse environmental effects.
Table 2-5 presents the changes to the Section 313 list of toxic chemicals. Each delisted
chemical need not be reported beginning in the calendar year noted next to the table entry.
Reporting for the new Section 313 chemicals will stan with calendar year 1990 (i.e., for the July
2-9
-------
31,1991 reporting deadline). The EPA's "Toxic Chemical Release Inventory Reporting Form R
and Instructions, Revised 1989 Version" (EPA 560/4-90-007) lists only the 302 chemicals that
are now subject to Section 313 reporting for calendar year 1989. The nine new chemicals, which
were added to the list after printing of the instructions, are identified in the appendix to this
report.
Table 2-5. Changes to the Section 3T3 List of Chemicals.
Delistings:
Additions:
Chemical
r AS Nn
Xsai
Aluminum oxide (nonfibrous)
1344-28-1
1989
C.L Arid Blue 9
2650-18-2
1988
Melaniine
108-78-1
1988
Sodium hydroxide (solution)
1310-73-2
1989
Sodium sulfate (solution)
7757-82-6
1988
Titanium dioxide
13463-67-7
1987
Allylalcataol
107-18-6
1990
Creosae
8001-58-9
1990
2J-Dichloi opropene
78-88-6
1990
m-Diniaobenzene
99-65-0
1990
o-Dinitrobenzenc
528-29-0
1990
p-Diniaobenzene
100-25-4
1990
Dinitro toluene (mixed isomers)
25321-14-6
1990
Isosafioie
120-58-1
1990
Toluene diisocyanate (mixed isomers)
26471-62-5
1990
The biggest change affecting the food processing industry is the delisting of sodium
hydroxide (solution), which is widely used in these facilities for many purposes. Form R's for
sodium hydroxide are not required for calendar year 1989 reporting. Also, aluminum oxide is no
longer reportable unless handled in fibrous forms.
WHAT MUST BE REPORTED
If your facility is included in SIC codes 20 through 39, has ten or more full-time
employees, and manufactures, processes, or otherwise uses one of the listed chemicals in
amounts greater than the appropriate thresholds, you must report the following information on
FormR:
• The name and location of your facility;
• The identity of the listed chemical (unless you claim its identity to be a trade
secret);
• Whether you manufacture, import, or process the chemical, or use it in any
other way;
• The maximum quantity of the chemical on-site at any time during the year,
• The total quantity of the chemical released during the year, including both
accidental spills and routine emissions;
2-10
-------
* Off-site locations to which you shipped wastes containing the chemical and the
quantities of the chemical sent to those locations; and
• Treatment or disposal methods used for wastes containing the chemical and
estimates of their efficiency for each chemical.
A release is any spilling, leaking, pumping, pouring, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or disposing into the environment of any listed chemical.
This includes the abandonment or discarding of barrelr, containers, and other closed receptacles.
Separate release estimates must be provided for releases to air, water, and land (e.g., deep well
injection, permitted landfill). Quantities sent off-site for purposes of recycle or reuse are not
reportable.
2-11
-------
SECTION 3
OVERVIEW OF SECTION 313 RELEASE ESTIMATION
This section presents general guidelines for preparing Section 313 release estimates. It
begins with a discussion of general ideas on estimating chemical releases. A summary of
common reporting errors thai often occur in Section 313 reporting follows.
GENERAL CONCEPTS
Release Estimation
A Form R must be completed for each Section 313 chemical that surpasses the applicable
reporting thresholds. The main components of Form R are environmental release estimates for
the chemical during the preceding calendar year. Environmental releases generally include all
sources of wastes that leave the facility boundary. Specifically, facility release estimates must be
made for the following vectors:
• Releases to air from fugitive or nonpoim sources
> Releases to air from stack or point sources
• Releases to water directly discharged to a receiving stream
• Releases in wastes that are injected underground
• Releases to land on-site
• Releases to water discharged to a publicly owned treatment works (POTW)
• Releases in other wastes transferred off-site for treatment or disposal
When beginning the release estimation process for a chemical, you must first identify
each material in which the chemical is present. For each of these materials, you should then
draw a process flow diagram that traces the material's path through the plant. The process flow
diagram should identify each major piece of equipment (including pollution control devices) the
material passes through at the plant from receipt to final disposition. It also should identify
potential release sources for the chemical.
After you have identified all the potential release sources for a chemical, you can estimate
releases for each source. The starting point for each estimate is chemical throughput data.
Knowing the amount of chemical used is essential for developing a reliable estimate.
Given the chemical throughput quantities for a process, you must apply other data and
assumptions to complete the estimates. This information includes process-specific data (e.g.,
coating transfer efficiency) and any data developed for other environmentally oriented purposes
(e.g.f air and wastewater monitoring data, RCRA manifest data, OSHA monitoring data, scrubber
efficiency). New monitoring may not be necessary; Section 313 allows use of existing data to
calculate release estimates. The accuracy of a release estimate is proportional to the quantity and
quality of the data used in its preparation. It should be noted that in many circumstances, not all
3-1
-------
the available data are required to complete a release estimate. Situations will arise where
estimates based on one piece of data contradict estimates based on another.
Release estimates are completed by combining all applicable data with assumptions
concerning the fate of the chemical in the process. There are four general methods for
completing a release estimate:
• Direct measurement - These are estimates based on monitoring the
concentration of a chemical in a waste stream. The chemical's concentration in
the waste scream multiplied by the flow rate or volume of the waste sore am
yields the mass of the chemical released. Direct measurement is typically used
to estimate releases via wastewater, solid waste, and hazardous waste.
Although this estimation method should yield the most accurate results, only
rarely are sufficient data available for it to be applied without also resorting to
other techniques such as mass balance.
• Mass balance - These are estimates based on a knowledge of the quantity of a
chemical entering and leaving a process. An imaginary boundary is first drawn
around the process, and all streams entering or leaving the boundary are
identified. If the amount of the chemical in the process input streams is known,
you can calculate-the quantity in waste streams by difference. You also must
account for any accumulation or depletion of the chemical within the boundary.
Mass balance estimates are usually combined with engineering calculations or
assumptions. Typically, the total amount of chemical lost as waste is
calculated by mass balance. The media (e.g., fugitive release to air, off-site
transfer to POTW) to which the chemical is released are determined by
engineering assumption. You will need engineering calculations and
assumptions to estimate the amount of chemical accumulated or depleted
within the mass balance boundary.
• Emission factors - Release information derived from facilities or processes
similar to yours can be used to estimate releases. Emission factors come in two
forms. The first expresses releases as a ratio of the amount of chemical
released to facility throughput or production (e.g., 0.5 pound of Chemical X
released per every pound of Material Y used). The second provides a typical
concentration of a chemical in a waste stream (e.g., 0.1 mg/L of Chemical Z in
wastewater from scrubbers). These factors combined with process throughput
or waste stream flow data are the basis for the release estimate.
The reliability of emission factors depends on the quality and quantity of data
used in their derivation, plus the similarity of the process to which they are
applied. You may be able to develop emission factors from in-house
monitoring data to provide reliable, easy-to-use estimates for future use.
• Engineering calculations and assumptions - Estimates that do not fall into
any of the above categories are considered engineering calculations or
assumptions. Typically these estimates are based on chemical engineering
calculations using properties of the chemicals involved or process operational
parameters. Example chemical properties include vapor pressure, solubility in
water, and density. Example process parameters include temperature, pressure,
and material flow rate.
3-2
-------
Documenting Reporting Efforts
Section 313 regulations require that each reporting facility maintain the following records
concerning the reporting methodology:
• Copies of each Form R submitted;
• Details of material usage and the methodology used to decide which chemicals
require reporting, including threshold comparisons and application of reporting
exemptions;
• Assumptions and calculations used to estimate release quantities and treatment
efficiencies; and
• Any backup data used to make release calculations (e.g.f RCRA manifests and
wastewater discharge monitoring data).
A documentation package should walk through the sequence of your reporting efforts. Ic
should follow a logical path in presenting how you determined which chemicals required a Form
R (and why others did not). It also should detail how you estimated releases for these chemicals*
It should include all data, assumptions, calculations, and results.
You are required to maintain these records at the facility for three years. Although EPA
does not require you to submit your documentation, it must be readily available for purposes of
inspection by EPA. Documentation of Section 313 may seem onerous, but it is required and will
help in reporting efforts in subsequent years. This is especially true when personnel changes
occur.
COMMON REPORTING PROBLEMS
You should keep in mind the following common reporting errors when performing
threshold evaluations and preparing release estimates:
• The reporting threshold for manufactured and processed chemicals dropped
from 50,(XX) pounds for calendar year 1988 to 22.000 pounds for calendar year
1989. Thus, you may need to submit Form R reports for additional chemicals
this year that were not reportable in previous years because they did not exceed
the 20,000-pound threshold.
• Sodium hydroxide (solution) has been delisted from the Section 313 list of
chemicals. A Form R is not required for this chemical for calendar year 1989.
• Certain chemicals have activity qualifiers in their names that may eliminate the
need for reponmg from your plant. These are aluminum (fume or dust),
vanadium (fume or dust), zinc (fume or dust), isopropyi alcohol (manufacturing
only-strong acid process), saccharin (manufaensing only), ammonium nitrate
(solution), ammonium juifate (solution), phosphorus (yellow or white),
asbestos (friable), and aluminum oxide (fibrous). Although saccharin and
isopropyi alcohol are widely used in food processing operations, neither is
reportable under Section 313 unless it is manufactured on-site.
• The chemical throughput to be used for threshold determination is the total
amount of the chemical entering or leaving the plant. That is, it is only the
3-3
-------
amount that is manufactured (including imported), processed, or otherwise
used during the calendar year. Unused surpluses of chemicals that are in
storage on-site, or amounts that are in closed containers, are not counted toward
the threshold. Thus, (he amount of ammonia to be used for threshold
determination is not the total amount contained in a refrigeration system.
Rather, it is the amount added during the year to charge a new system or
replace amounts lost through leaks and maintenance activities on an existing
system.
• The requirements for Section 313 reporting are not mitigated in any way by
exemptions for food products under other regulatory mechanisms such as those
of the Food and Drug Administration (FDA) and the Occupational Safety and
Health Administration (OSHA). Also, you should remember that there are
three separate chemical lists under EPCRA: the Section 302 "extremely
hazardous substances," the Section 311 "hazardous chemicals," and the Section
313 "toxic chemicals." These lists are independent of one another. For
example, OSHA excludes food products from its Matenal Safety Data Sheet
(MSDS) requirements. This exempts them from EPCRA Section 311
reporting, but it does not affect Secnon 313 requirements.
•
• Some "multi-establishment" food processing facilities may have to submit
Form R reports for chemicals used in agricultural operations. This can occur if
the value of the products from a processing plant exceeds those from a farming
operation that is operated on an adjacent or contiguous site owned by the same
person or entity.
• Most reportable chemicals in die food processing industry are otherwise used
by Section 313 definition. Such chemicals rarely leave the facility with the
product. All throughput is either lost during processing through releases to air,
water, or land, or shipped off-site in wastes. Thus, except amounts that are
transferred to off-site facilities for recycle, the entire throughput is often
reporuble on Form R as releases to various media. A mass balance is
generally the best starting point from which to estimate these releases.
• Some chemicals such as solvents are commonly transferred off-site for recycle,
treatment, or disposal Quantities sent off-site for purposes of recycle or reuse
are not reportable on Foxxs R. They must be considered when performing a
mass balance, but they should not be reported as off-site transfers on Form R.
• Secnon 313 reporting rules consider a waste stream with a pH between 6 and 9
to be fully neutralized. Thus, if listed acids or bases have been neutralized to
pH between 6 and 9 before discharge to water or POTW, zero releases should
be reported. Any excursions beyond the 6 to 9 xange potentially constitute
release of an acid or base.
• In most water treatment/disinfection processes, chlorine enters water and forms
HOG, G-, and H+, with a small amount of G2 remaining. Although this is an
equilibrium reaction, at a pH above 4, the equilibrium is shifted almost
completely to the right. Therefore, essentially zero releases of chlorine to
water will occur under normal water treatment circumstances. Although some
facilities may monitor the residual chlorine concentration in their water, this
3-4
-------
parameter does not represent Q2 concentration. Residual chlorine is the sum of
the Q2, HOQ, and OQ- concentrations. Because the G2 concentration will be
negligible under neutral pH conditions, this parameter grossly overestimates
G2 releases.
• Releases should not be inadvertently "double counted." A single wastewater
discharge should not be listed as both a release to water (on-site) and a
discharge to POTW (off-site). Similarly, a release to land should not be listed
as both a release to land (on-site) and a transfer to an off-site landfill.
• Waste treatment efficiencies refer only to the percent destruction, degradation,
conversion, or removal of the listed chemical from the wastestream. They do
not refer to the percent conversion or removal of other chemical constituents in
the wastestream. The efficiency also does not refer to the efficiency for
removing generalized pollutants (e.g., VOC's, BOD) from the wastestream.
• Vendor data on treatment efficiencies often represent ideal operating
conditions. Thus, you may want to adjust such data to account for downtime
and process upsets during the year that would result in lower efficiencies.
5-5
-------
SECTION 4
RELEASE ESTIMATION SCENARIOS IN FOOD PROCESSING
This section describes release estimation techniques for twelve common reporting
scenarios in the food processing industry: 1) water treatment, 2) refrigerant uses, 3) food
ingredients, 4) reactants, 5) catalysts, 6) extraction/carrier solvents, 7) cleaning/disinfectant uses,
8) wastewater treatment, 9) fumigants, 10) pesticides/herbicides, 11) byproducts, and 12) can
making/coating. Each subsection lists the commonly used Section 313 chemicals, gives an
overview of the process involved, identifies the appropriate chemical activities and reporting
thresholds, and discusses release estimation techniques and common reporting errors.
Table 4-1 identifies chemicals typically used in food processing operations and discussed
in the following subsections. This list may not include all the chemicals your facility uses that
are subject to reporting, and it may include many chemicals that you do not use. You also should
decide whether any of the listed chemicals are created during processing at your facility. The
most frequently reported chemicals in SIC code 20 for the 1988 reporting year were ammonia,
phosphoric acid, sulfuric acid, chlorine, hydrochloric acid, and nitric acid.
4-1
-------
Tabic 4-1. Section 313 Chemicals Commonly Encountered in Food Processing.
Ammonia • Byproducts, reactants; refrigerant uses, wastewater treatment
Ammonium sulfate - Byproducts
Benzoyl peroxide - Reactanis
Bromomethane - Fumigants
n-Butyl alcohol • Extraction/earner solvents
Chlorine • Geaning/disinfectant uses, reactanis, water treatment
Chlorine dioxide • Cleanin{^disinfectant uses, reactams, water treatment
Chloroform • Byproducts
Dichloromethane • Extraction/carrier solvents
Ethylene glycol • Refrigerant uses
Ethylene oxide - Fumigants, reactants
Formaldehyde - Geaning/disinfectant uses
Hydrochloric acid - Wastewater treatment
Methanol - Byproducts
Nicicei/nickel compounds - Catalysis
Nitric acid - Cleaning/disinfectant uses
Phosphoric acid - Geaning/disinfectant uses, extraction/earner solvents, food ingredients,
Reactanis
Propylene oxide - Fumigants, reactants
Sulfuric acid • Wastewater treatment
Various listed food dyes (e.g., CJ. Food Red 5, CL Food Red 12) • Food ingredients
Various listed ink and coating solvents (e.&, glycol ethers, isopropyl alcohol, MEK. toluene,
xylene) - Can malcing/coanng
Various listed metals (e.g., manganese, nickel, chromium) - Can making/coaung
Various listed metal/meuil compounds (e.g_ zinc, copper, manganese, selenium) • Food
ingredients
Various listed pesticides and herbicides (e.g_ aldrin, cap tan, 2,4-D, hydrazine, lindane, maneb,
panthicn, zateb) - Pesucides/herbicides
Various listed metal pigment compounds (e.g., copper, barium, chromium, zinc, lead) - Can
making/coating
4-2
-------
WATER TREATMENT
Commonly Used Section 31J Chemicals: Chlorine, chlorine dioxide
Process Description: Chlorine is used to treat process water at food processing facilities. It is
received as a compressed gas and added to process water as a disinfectant. The created water
becomes a component of a food product, is used to wash or convey food products or to control
odors in fish meal processing, oris used for clearing purposes. At a few plants, chlorine dioxide
that is produced by reacting liquid sodium chlorite, chlorine gas, and water may be used for
similar purposes.
Reporting Threshold: Depending upon the application, these chemicals may be manufactured,
processed, or otherwise used, and therefore subject to different reporting thresholds. The most
common situation is when chlonne is purchased and used to treat water that is used to wash or
convey fruits or vegetables or to clean equipment In this case, the chlorine is otherwise used (as
a chemical processing aid), "with a 10,000-pound reporting threshold. Production of chlonne
dioxide on-site is considered manufacturing (produced for on-site use/processing). This activity
also should be reported, but since the chemical is then otherwise used the lower 10,000-pound
reporting threshold prevails. In manufacture of chlorine dioxide, the chlorine must be reported as
processed (as a reactant), which has a 25,000-pound reporting threshold. If chlorine or chlorine
dioxide are only used to treat water that becomes pan of a food product (e.g., a soft drink), they
are considered processed (as a formulation component), which has a 25,000-pound reporting
threshold.
Release Estimation: The only release that would be expected in this application would
normally be small fugitive air release of chlorine and chlorine dioxide. These occur from such
sources as leaks in valves and finings and losses dunng cylinder changeovers. For the quantities
of chlorine typically used for water treatment purposes, engineering judgment can be used to
estimate fugitive releases (e.g., based on the volume of the connecting hose and the numser of
changeovers). If significant quantities of chlonne are handled (e.g., greater than 1G0,000 pounds
annually), these fugitive releases can be estimated using the SOCMI factors presented in die EPA
report, "Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form" (EPA 560/4-88-002).
There are no releases of either of these chemicals to water. Chlorine reacts with water to form
HOQ, Or, and H"\ Although this is an equilibrium reaction, at a pH above 4, the equilibrium is
shifted almost completely to the right. Therefore, essentially zero releases of chlorine to water
will occur under normal circumstances. Zero releases of chlorine dioxide to water are also likely
based on its strong oxidizing potential and the constant supply of organics to be oxidized in the
waste stream. Appendix B presents more detailed information on estimating releases of chlorine.
Common Reporting Errors: The most common reporting error in use of chlorine or chlorine
dioxide to treat water is the reporting of discharges to water or POTW. As indicated above, if the
discharge is maintained at a pH above 4, there will be no releases of these chemicals to water
streams. Although some facilities may monitor the residual chlorine concentration in their water,
this parameter does not represent CI2 concentration. Residual chlorine is the sum of the CI?,
4-3
-------
HOQ, and OCI" concentrations. Because the CI2 concentration will be negligible under neutral
pH conditions, release to water or POTW should be reported as zero.
A second error in reporting the use of these chemicals for water treatment can occur when they
are used only to treat water that becomes pan of a food product. This is not considered otherwise
use of the chemical by Section 313 definition, but processing, which has a higher reporting
threshold.
4-4
-------
REFRIGERANT USES
Commonly Used Section 313 Chemicals: Ammonia, ethylene glycol
Process Description: Ammonia and (to a much lesser extent) ethylene glycol are used as heat
exchange media in refrigeration processes. These chemicals are condnuously reused in closed-
loop units. The ammonia is handled as a gas, while the ethylene glycol is handled as a liquid.
Both chemicals must be added to refrigeration systems to replace amounts lost through leaks or
because of losses when purging a section of the system for maintenance.
Reporting Threshold: Refrigerants are otherwise used (as a manufacturing aid) and are
therefore subject to the 10,000-pound reporting threshold.
Release Estimation: Ammonia is a volatile chemical and will be released to air through system
filling, relief vents, and leaks in valves and fittings. All the ammonia lost through these means
should be reported as fugitive air releases. If the system is vented to the air dunng system
maintenance, this amount also should be reported as a fugitive air release. The lines may be bled
directly into water during system maintenance. In this situation, estimates must be made of
ammonia releases to POTW or water.
Ethylene glycol is used in liquid form in heat exchange applications. Releases will be the result
of leaks in the system piping or drainage of the system for maintenance purposes. Releases will
be limited to wastewater and non-aqeuous liquid waste streams.
Releases in refrigeration applications are best estimated by mass balance. Total releases are
equivalent to the amounts of the chemicals that have been added to the system to replace losses.
If ammonia is used, releases are usually to air, whereas ethylene glycol releases probably will be
to water. When ammonia is bled to water, an aqueous solution is formed that contains both non-
ionized ammonia. NHj, and ionized ammonia, NHt+. Discharges to water should be calculated
by adding the ionized and non-ionized forms; such estimates can be based on monitoring data for
ammonia-nitrogen. Estimates of ammonia releases obtained from calculations using mass
balance equations are sufficient for reporting requirements if monitoring data are not available.
The amount released to air can then be estimated as the difference between total usage and the
amount discharged to water. Appendix B presents more detailed information on estimating
releases of ammonia.
Common Reporting Errors: The most common error in refrigerant uses is basing the threshold
determination on the total amount of the chemicals in the system. According to Section 313
definition, the throughput to be used for threshold determination is only the amount of new
chemicals added to the system during the year (Le., to charge a new system or to replace amounts
lost through leaks and maintenance activities on an existing system). Thus, though a
refrigeration system may contain more than 10,000 pounds of ammonia, a Form R is not required
unless 10,000 pounds of new ammonia is added to the systematizing the year. The quantities of
the chemicals added during the year can best be determined from purchase and inventory
records.
4-5
-------
FOOD INGREDIENTS
Commonly Used Section 313 Chemicals: Phosphoric acid, saccharin, various listed food dyes
(e.g., CL Food Red 5, CL Food Red 15), various listed metal/metal compounds (e.g., zinc,
copper, manganese, selenium)
Process Description: Various Section 313 chemicals are present in food ingredients and
become pan of the final food product. Several reportable metal and metal compounds are usea
as formulation components in prepared feeds. For example, zinc compounds are used as an
additive in dog food. Phosphoric acid may be used as a food ingredient in the preparation of
baking ingredients and soft drinks. Several food dyes are also on the list of Section 313
chemicals. Food ingredients are handled as solids or liquids and may undergo various types of
physical processing at the food plants (e.g., blending).
Reporting Threshold: Food ingredients are processed (as a formulation component) and are
therefore subject to the 25,000-pound reporting threshold, regardless of whether they are
regulated by the FDA.
The use of saccharin as a food ingredient is not reportable under Section 313. Saccharin is a
listed chemical, but it is qualified so that a Form R is required only if the facility manufactures
saccharin on-site.
Release Estimation: Most chemicals used as food ingredients are not volatile, and since they
become part of the final product, only minor releases would be expected from their processing.
Engineering judgment can generally be used to estimate releases to air or water from handling or
mixing operations. The largest source of release may be equipment cleanup (e.g., tank cleaning,
clean-in-place systems). Factors for estimating such releases can be found in the EPA report,
"Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form" (EPA 560/4-88-002). For storage tank losses (including loading and unloading)
of chemicals handled as liquids, estimates of air releases can be made using methods described in
the EPA publication, "Compilation of Air Pollutant Emission Factors, AP-42" (these methods
are also summarized in Appendix C of EPA 560/4-88-002). These emissions are considered
point air releases for Section 313 reporting. Depending upon the volatility of the chemical and
how (or if) the cleaned-up material is disposed of, spills of such liquids could be reported as
fugitive air releases, discharges to wastewater, or off-site transfers.
Any releases of phosphoric acid to water (e.g., from washdowns or spills) are likely neutralized
before discharge and are therefore not reportable. If the pH is main tamed above 6, the acid is
considered completely neutralized wiih zero releases. Estimates of releases of phosphoric acid to
water that do occur can be based upon the pH of the wastewater effluent. Operating records
showing the periods during which the pH falls below 6 are therefore the basis for estimating
these discharges. Releases can be calculated using the effluent flow rate during the excursion
period, the duration of the excursion, and the average pH during the excursion period. Appendix
B presents more detailed information on estimating releases of acids.
Common Reporting Errors: One potential reporting error in food ingredient applications is
incorrectly submitting a Form R for saccharin. According to Section 313 definition, a Form H is
4-6
-------
only required for saccharin if the facility manufactures the chemical on-site. Processing of
saccharin as a food ingredient is therefore not subject to Section 313 reporting.
A second potential error in this application is failure to estimate releases of food ingredient
chemicals that occur during storage, transfer, and mixing operations. Total usage of the
chemicals can be determined from purchasing records. Engineering judgment can be used to
estimate the minor releases that may occur during these operations.
A third error is incorrectly submitting a Form R for zinc metal that may be used as a food
ingredient. Zinc metal is only reportable under Section 313 when handled as a fume or dust.
Thus, a Form R may not be required for its use as a food ingredient. Reporting of zinc
compounds processed as a food ingredient is required.
4-7
-------
REACTANTS
Commonly Used Section 313 Chemicals: Ammonia, chlorine, ethylene oxide, phosphoric acid,
propylene oxide
Process Description: Various chemicals may be processed as reactants in the food industry.
These chemicals are raw materials or starring materials for food products. For example, ethylene
oxide is used as a reactant in the production of starch to improve the viscosity of the product.
Chlorine, chlorine dioxide, and benzoyl peroxide are used as bleaching agents for flour, and
phosphoric acid is processed in the manufacture of certain food products such as pet foods.
Ammonia is used as a starter component in the batch process manufacture of cheese. Propylene
oxide is reacted with com starch to produce hydroxyaikyl starches. These chemicals may be
handled as gases under pressure, liquids, or aqueous soludons.
Reporting Threshold: Depending upon the nature of the process, these chemicals are either
processed (as a reactant) and therefore subject to the 25,000-pound reporting threshold, or
otherwise used (as a chemical processing aid) and subject to the 10,000-pound reporting
threshold. The key difference is whether the chemical intentionally leaves the facility with the
product. In the examples given above, ethylene oxide, phosphoric acid, and propylene oxide are
processed. Chlorine, chlorine dioxide, benzoyl peroxide, and ammonia arc otherwise used.
Release Estimation: Most of the throughput of these chemicals would be consumed during the
reaction. Minor fugitive air releases of volatile chemicals such as ethylene oxide, ammonia, and
chlorine will occur from leaks in valves and fittings and losses during cylinder changeovers. If
significant quantities of these chemicals are handled, these fugitive releases can be estimated
using the SOCMI factors presented in the EPA report. "Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemical Release Lv. enter/ Form" (EPA 560/--88-C02). If
orly small ciar.tiries handled. engineering judgment should be used to estimate fugitive
releases (e.g., based on the volume of the connecting hose and the number of changeovers). For
storage tank losses (including loading and unloading) of chemicals handled as liquids, estimates
of air releases be made using methods described in the EPA publication, "Compilation of Air
Pollutant Emission Factors, AP-42" (these methods are also summarized in Appendix C of EPA
560/4-88-002). These emissions are considered point air releases for Section 313 reporting.
Depending upon the volatility of the chemical and how (or if) the cleaned-up material is disposed
of, spills of such liquids could be reported as fugiuve air releases, discharges to wastewater, or
off-site transfers.
The only likely source of releases of liquid solutions of phosphoric acid or aqueous ammonia
would be spills. These are generally neutralized before discharge or disposal and are therefore
not reportable. Appendix B presents more detailed information on estimating releases cf
ammonia and acids.
Common Reporting Errors: The most common reporting error in this application is failure to
account for minor fugidve air releases during storage and transfer of volatile chemicals such as
ethylene oxide, chlorine, or ammonia before their use as reactants.
4-6
-------
CATALYSTS
Commonly Used Section 313 Chemicals: Nickel/nickel compounds
Process Description: Certain Section 313 metals may be used as catalysts to help promote a
desired reaction in food processing operations. For example, a nickel catalyst is used to aid in
the hydrogenarion of vegetable oil. Such chemicals are not consumed in the reaction and do not
become part of the product Because of this use, the catalyst may become spent or contaminated
and require disposal or regeneration.
Reporting Threshold: Catalysts are otherwise used (as a chemical processing aid) and are
therefore subject to the 10,000-pound reporting threshold.
Release Estimation: Catalysts are typically not volatile and do not become pan of the final
product. The total amount of chemicaJ added to the system during the year therefore is
ultimately released to the environment via wastewater or solid waste, or shipped off-site for
treatment, disposal, or regeneration. A small fraction of the catalyst will be lost through
handling and processing. Typically, the bulk of the spent catalyst is shipped off-site for
regeneration. This quantity should not be reported as an off-site transfer. Releases via
wastewater would likely only occur from plant wash downs and should be minor.
Common Reporting Errors: The most common reporting error in catalyst uses is basing the
threshold determination on the total amount of the chemical in the processing system. According
to Section 313 definition, the throughput to be used for threshold determination is only the
amounts of new chemical added to the system during die year. Thus, though the processing
system may contain more than 10,000 pounds of catalyst, a Form R is not required unless 10,000
pounds of new catalyst is added to the system during the year. The quantities of catalyst added
during the year can best be determined from purcnase and inventory records.
A second error regarding catalysts is to report amounts sent off-site for regeneration as CiT'Siw
transfers. According to Section 313 instructions, quantities of a chemical sent off-sue for
purposes of reuse or recycle should not be reported on Form R. Only the amounts of the
chemical transferred off-site for disposal or treatments that do not involve recycle should be
"reported.
Another possible error would be submitting a Form R for aluminum oxide, which is used as a
catalyst in manufacture of edible fats and oils. Beginning with calendar year 1989 reporting,
aluniuium ox:ce :s reponable only when handled in fibrous forms. Thus, its use as a catalyst m
food processing is not subject to threshold determination.
4-9
-------
EXTRACTION/CARRIER SOLVENTS
Commonly Used Section 313 Chemicals: N-butyl alcohol, dichloromethane, phosphoric acid
Process Description: Certain Section 313 chemicals may be used as extraction or carrier
solvents in the food processing industry. For example, n-butyl alcohol may be used as a earner
solvent for spices. Dichloromethane may be used as an extraction solvent for hops and
flavorings and to remove caffeine from coffee. Phosphoric acid may be used to remove
impurities from vegetable oil. Extraction and cairier solvents are normally handled as liquids
and do not become pan of the final food product.
Reporting Threshold: Extraction and carrier solvents are otherwise used (as a chemical
processing aid) and are therefore subject to the 10,000-pound reporting threshold.
Release Estimation: Releases of these chemicals may be to any media depending on the
physical state of the chemical and the process in which it is used. Releases are best estimated by
mass balance, and it is generally reasonable to assume that total releases will equal usage of the
chemicaL It is often possible to estimate releases to one medium by difference between total
usage and the amount known to be released to another medium from monitoring data.
If volatile solvents such as acetone or dichloromethane are used, the quantity released to air is
equal to total solvent usage for these purposes minus any amounts that are captured or destroyed
by control devices such as carbon adsorbers or thermal oxidizers (i.e., incinerators). A mass
balance is the best method for estimating these releases. If there are no controls, all the solvent
usage should be reported as fugitive or point air releases. If destructive controls are used (e.g.,
thermal oxidizers), the amount of solvent destroyed can be determined using engineering
assumptions of the quantity of solvent reaching the control device and us destruction efficiency.
If nondestructive controls are used (e.g., adsorbers), the amount of the captured solvent in wastes
sent off-site for recycle, treatment, or disposal can oe determined uirougn analysis of uiese
wastes. Air releases then are the difference between total usage and the amount captured in this
manner.
In aqueous extraction processes, the Section 313 chemical may be released to water. If this is the
only medium to which it is released, a mass balance is the best method for estimating the release
quantity. Waste solvents are often shipped off-site for disposal, treatment, or reuse. If releases
are to several media, wastewater monitoring data or permit requirements and waste manifests
from off-site transfers can be used with the mass balance.
Common Reporting Errors: A common reporting error in use of extraction or carrier solvents
is failure to account for all the usage of the chemical through some release or off-site transfer.
None of tne solvent snouid oe assumed to remain with uie food product. All usage snouia be
accounted for through air releases, amounts captured or destroyed in control devices, and
amounts sent off-site. Total usage is best determined from purchase records for the solvent.
A second common reporting error in these applications is to report amounts of solvents sent off-
site for recycle as off-site transfers. Spent solvents are commonly shipped to off-site facilities for
recovery of the solvent According to Section 313 instructions, quantities of the chemical sent
off-site for purposes of reuse or recycle should not be reported on Form R. Only the amounts of
4-10
-------
the solvent transferred off-site for disposal or/treatments that do not involve recycle should be
reported.
A third common reporting error is overestimation of the amount of solvent in waste sent off-site.
This quantity should be based on analysis of the waste. The waste is not 100 percent solvent,
and the total amount of waste shipped off-site must be adjusted for the solvent concentration.
Many facilities that receive waste solvents will provide information on the quantity of solvents
present in the waste sent to them. This information is a key component of a mass balance for
estimating solvent release.
4-11
-------
CLEANING/DISINFECTANT USES
Commonly Used Section 313 Chemicals: Chlorine, chlorine dioxide, formaldehyde, nitric
acid, phosphoric acid
Process Description: Nitric acid and phosphoric acid may be used to clean process equipment
in the food industry. These chemicals are handled as liquid solutions in this application.
Chlorine also be used for cleaning purposes by reacting it with sodium hydroxide to form a
sodium hypochlorite solution. Chlorine dioxide is used as a germicidal disinfectant or saniazer.
Formaldehyde is used as a sterilant to limit microbial action in beet sugar processing equipment.
Reporting Threshold: The acids are otherwise used (ancillary or other use) in this application
and are therefore subject to the 10,000-pound reporting threshold. Chlorine used to produce
sodium hypochlorite is processed (as a reactant), which has a 25,000-pound repornng threshold.
Release Estimation: Releases of nitric acid and phosphoric acid in cleaning applications are
usually to water. Estimating releases of acids to water is based upon the pH of the wastewater
effluent, If the pH is maintained above 6, the acids are considered completely neutralized with
zero releases. Operating records showing the periods during which the pH fails below 6 are
therefore the basis for estimating any discharges. Releases can be calculated using the effluent
flow rate during the excursion period, the duration of the excursion, and the average pH during
the excursion period.
The chlorine is consumed curing reaction with sodium hydroxide. Therefore, the only release
sources to be considered would normally be small fugitive air releases from such sources as leaks
in valves and fittings and losses during cylinder changeovers. If only small quantities of chlorine
are handled, engineering judgment should oe used to estimate fugitive releases (e.g.. based on the
volume of the connecting hose and the number of changeovers). If significant quantities of
cmonne are nanaiea (.e.g., greater uian iOQ,Caju pounas annuallyj, these fugitive can oe
estimated using the SOCM1 factors presented in the EPA report, "Estimating Releases ana Waste
Treatment Efficiencies for the Toxic Chemical Release Inventory Form" (EPA 560/4-88-002).
For storage tank losses (including loading and unloading) of chemicals handled as liquids,
estimates of air releases be made using methods described in the EPA publication, "Compilation
of Air Pollutant Emission Factors, AP-42" (these methods are also summarized in Appendix C of
EPA 560/4-88-002). These emissions are considered point air releases for Section 313 reporting.
Depending upon the volatility of the chemical and how (or if) the c'.ear.ed-up material is disposed
of, spills of such liquids could be reported as fugitive air releases, discharges to wastewater, or
off-site transfers. Appendix B presents more detailed information on estimating releases of
chlorine ar.d acids.
Common Reporting Errors: The most common reporting error for cleaning uses of acids is
overestimation of releases to water. If the pH of the wastewater discharge is maintained between
6 and 9, which is required by many permits, the acid is neutralized and no releases to water
should be reported.
Overestimation of discharges to water is also a common error for chlorine and chlorine dioxide.
When the chlorine is reacted with sodium hydroxide, it is consumed in the reaction and no
4-12
-------
further releases need be reported. Even if the chlorine were to enter a water stream before
reaction with another chemical, there would be no discharges of this chemical to water. Chlorine
gas reacts with water to form HOC1, G~ and H+. Although this is an equilibrium reaction, at a
pH above 4, the equilibrium is shifted almost completely to the right and essentially zero releases
of chlorine to water will occur. Although some facilities may monitor the residual chlorine
concentration in their water, this parameter does not represent Clj concentration. Residual
chlorine is the sum of the CI2, HOQ, and OG~ concentrations. Because the G2 concentration
will be negligible under neutral pH conditions, releases to water should be reported as zero. Zero
releases of chlorine dioxide to water are also likely based on its strong oxidizing potential.
Another type of reporting error in this application involves confusion of other cleaning chemicals
with chlorine. Giemicals called "chlorine bleach" are often used for cleaning purposes. These
cleaners normally contain chemicals such as sodium hypochlorite or calcium hypochlorite, and
very little chlorine. It is highly unlikely that the chlorine present in such cleaners would require
reporting under Section 313.
4-13
-------
WASTEWATER TREATMENT
Commonly Used Section 313 Chemicals: Ammonia, hydrochloric acid, sulfuric acid
Process Description: Various Section 313 chemicals are used in wastewater treatment
processes at some food processing plants. .Acids and bases are added for pH control. Sulfuric
acid is the most frequently used acidulation agent. The principal base used, sodium hydroxide, is.
no longer reportable under Section 313. Ammonia is occasionally used as a nitrogen source in
biological wastewater treatment systems. During such treatment, the proteins in the wastewater
may break down, forming additional ammonia as a byproduct. The acids and bases are handled
as liquids, while the ammonia may be purchased as a gas or an aqueous solution.
Reporting Threshold: These chemicals are otherwise used (ancillary or other use) when used
for wastewater treatment and are therefore subject to the 10$00-pound reporting threshold. If
additional ammonia is produced in the treatment system, it is considered manufactured (produced
as a byproduct). This activity also should be reported, but since the ammonia is also otherwise
used the lower 10,000-pound reporting threshold prevails.
Release Estimation: The total usage of these chemicals is released to water except small
quantities of ammonia that may be released to air from storage and transfer operations before its
introduction into the wastewater treatment system. If significant quantities of ammonia are
handled, these fugitive releases can be estimated using the SOCMI factors presented in the EPA
report, "Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release
Inventory Form" (EPA 560/4-88-002). If only small quannnes are handled, engineering
judgment should be used to estimate fugitive releases (e.g., based on the volume of the
connecting hose and the number of changeoven). For storage tank losses (including loading and
unloading) of chemicals handled as liquids, estimates of air releases be rr.idc using methods
described in the EPA publication. "Compilation of Air Pollutant Emission Factors, AP-42"
(these metnods are also summarized in Appends C of EPa 560/4-88-002). Tnese emissions
are2 considered point air releases for Section 313 reporting. Releases of sulfuric acid should be
minor because of its low vapor pressure. Depending upon the volatility of the chemical and how
(or if) the cleaned-up material is disposed of, spills of such liquids could be reported as fugitive
air releases, discharges to wastewater, or off-site transfers.
Section 313 reporting rules consider a waste stream with a pH between 6 and 9 to be fully
neutralized. Therefore, if the wastewater effluent is maintained above a pH of 6, it can be
assumed that there are no releases of acids to water. Operating records showing the per.c-is
during which the pH falls outside this range are therefore the basis for estimating these
discharges. Releases can be calculated using the effluent flow rate during the excursion period.
***** *•••• ¦••• ** •• V »«• T «« ^^ •••« *• V • • ^ ^ » »
presents more detailed information on estimating releases of acids.
An aqueous solution contains both non-ionized ammonia, NH3, and ionized ammonia, NH4*.
Discharges to water should be calculated by adding the ionized and non-ionized forms; such
estimates can be based on monitoring data for ammonia-nitrogen. Appendix B presents more
4-14
-------
detailed information on estimating releases of ammonia. Ammonium hydroxide (CAS 1336-21-
6) is a solution of ammonia in water, and is therefore reportable as ammonia.
Common Reporting Errors: The most common reporting error for wastewater treatment is
overestimation of releases of acids or bases to water. If the pH of the wastewater discharge is
maintained between 6 and 9, which is required by many permits, the acid or base is neutralized
and there are no releases to the environment.
Another common error in wastewater treatment is failure to report the ammonia that may be
manufactured as a byproduct of the treatment process. Other reportable chemicals also may be
manufactured as byproducts during such treatments depending upon the chemicals present. For
example, ammonium sulfate could be formed when ammonia and sulfuric acid are present
together in the water. The section on byproducts discusses release estimation for such chemicals.
4-15
-------
FUMIGANTS
Commonly Used Section 313 Chemicals: Bromomethane, ethylene oxide, propylene oxide
Process Description: Various Section 313 chemicals are used as fumigants, either alone or in a
mixture with other carrier gases, during certain types of food processing operations. For
example, ethylene oxide can be used as a bactericide during processing of spices.
Bromomethane (methyl bromide) can be used as an insecticide in grain mills. In such
applications, these chemicals are handled and used as gases. The fumigant is usually released to
air when fumigation is complete. If the process is conducted in a pressurized container, the
release may be vented to a treatment device such as a scrubber.
Reporting Threshold: Fumigants are otherwise used (as a manufacturing aid) and are therefore
subject to the 10,000-pound reporting threshold.
Release Estimation: If there are no control devices, the total usage of these volatile chemicals
should be assumed to be released to air. The sources include fugitive air releases from leaks in
valves and fittings and losses during cylinder changeovers, point source air releases from control
devices, and point source air releases when the chemical is used to fumigate an entire building
such as a grain mill. A mass balance is thus the best approach for estimating releases, with an
assumption of minor fugitive air releases and the remainder of usage considered a point source
air release. The point source total must be adjusted based on the effectiveness of any control
devices, with the amount captured in the device reported as a discharge to water or a transfer to
an off-site facility depending upon its disposition.
Common Reporting Errors: The threshold determination should be based upon the quantity of
the Secnon 313 chemical, not including any carrier gas. Tne Section 313 chemical may
sometimes represent only a small percent of the total gas volume.
4-16
-------
PESTICIDES/HERBICIDES
Commonly Used Section 313 Chemicals: Various listed pesticides and herbicides (e.g., aldrin,
captan, 2,4-D, hydrazine, lindane, maneb, parathion, zineb)
Process Description: Agricultural activities are normally exempt from Section 313 reporting
because they do not fall within the appropriate range of SIC codes. Some facilities have multiple
establishments according to Section 313 definition that have different primary SIC codes. For
example, a food processing establishment in a facility may process crops grown at the facility in
a separate establishment). If the total value of the products at establishments in SIC codes 20
through 39 exceeds 50 percent of the value of the entire facility's products or services, or if any
single establishment in this range of SIC codes produces or ships products whose value exceeds
those of any other establishment within the facility, the entire facility is subject to Section 313
reporting. Such a multi-establishment facility must perform chemical threshold determinations
and report releases for all listed chemicals, even from establishments that are not in SIC codes 20
through 39. In other words, some food processing facilities may be required to report for
pesticides and herbicides because of the use of these chemicals in related agricultural activities at
the same site. For example, a facility that processes sugarcane that is grown at a faim at the
same facility may have to report for 2,4-D. The agricultural activities would be classified in SIC
code 0133 (Sugarcane and sugar beets), while the processing operation would be classified in
SIC code 2061 (Cane sugar, except refining).
Pesticides and herbicides may be handled as solids or as solids mixed with a liquid to form a
sprayable solution. They are sprayed mechanically over the area being treated.
Reporting Threshold: Pesticides and herbicides are otherwise used (ancillary or other use) and
are therefore subject to the IC,C00.-pousd ::pcrtr.g threshold. Quantities of pesaciaes ana
herbicides used fcr facility grounds maintenance are not reportable.
Release Estimation: Unless there is evidence to the contrary, ail the pesticide and herbicide
used should be considered an on-site release to land. Minor amounts of these chemicals could be
released to air and water from aerial spraying, but this is difficult to quantify.
Common Reporting Errors: Hie most common reporting error in use of pesticides and
herbicides is failure to submit a Form R for these chemicals because they are only used for
agricultural purposes. As explained above, a Form R may be required depending on the primary
SIC cede of a multi-establishment facility.
The threshold detenriination for pesticides and herbicides should be based upon the quantity of
the Section 313 chemical alone. Such formulations often contain other chemicals that are not
reportable, and the Section 313 chemical may rrpresen: only a smail percent of the total quantity
of material used.
Some facilities also may fail to report any releases of these chemicals because they are broken
down by soil microorganisms and there should be no accumulation in the soil from normal
agricultural use. According to the Section 313 rules, the total amount used should be reported as
a release without consideration of its disposition after it is applied to the soil.
4-17
-------
BYPRODUCTS
Commonly Produced Section 313 Chemicals: Ammonia, ammonium sulfate, chloroform,
methanol
Process Description: Various Section 313 chemicals may be manufactured as byproducts at
food processing plants during processing operations or waste treatment. For example, ammonia
can be produced through breakdown of proteins in a wastewater treatment system. Ammonium
sulfate can be produced in a wastewater treatment system containing ammonia and sulfuric acid.
Chloroform can be produced in a water treatment systeiji employing chlorine.
Reporting Threshold: Chemicals produced under these circumstances are normally considered
manufactured (produced as a byproduct) and are therefore subject to the 25,000-pound reporting
threshold. Sometimes, the byproduct may be otherwise used (e.g., an ammonium sulfate
byproduct forms an aqueous solution of ammonia that is used for water treatment) and the lower
otherwise use threshold of 10,000 pounds applies.
It should be noted thai the de minimis exclusion does not apply to threshold determinations for
byproduct chemicals.
Release Estimation: The possibility forTelease of byproduct chemicals depends upon the
physical state of the chemical and the processes in which it is produced. The most likely release
medium is water. The specific amounts of byproducts released are best estimated using
monitoring data for the waste stream. Ammonia presents a special case since an aqueous
solution contains both non-ionized ammonia, NH3, and ionized ammonia, NrU*- Discharges to
water should be calculated by adding the ionized and non-ionized forms; such estimates can be
based on monitoring data for ammonia-nitrogen. Appendix 3 p
on estimating releases of ammonia.
Common Reporting Errors: The most common reporting error is failure to take tne
manufacture of these byproduct chemicals into consideration wheaperforming threshold
determinations or release estimates. If the only source of the chemical at a plant is through the
formation of a byproduct (e.g., chloroform), the 25,000-pound manufacturing threshold may not
be exceeded. On the other hand, if the chemical is already reportable at the plant for other
reasons (e.g., ammonia), the releases from its formation as a byproduct also must be reported.
4-18
-------
CAN MAKING/COATING
Commonly Used Section 313 Chemicals: Can metal components such as manganese, nickel,
and chromium; various listed ink and coating solvents (e.g., n-butyl alcohol, glycol ethers,
methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), toluene, 1,1,1-trichloroethane,
xy'.er.:); varices listed compounds used as pigments (e s.. cotroer compounds, barium
compounds, chromium compounds, zinc compounds, lead compounds)
Process Description: Some food processing plants fabricate cans using vanous stamping and
coanng operations. Strip metal is formed into can bodies and lids using stamping machines.
Reportable chemicals also may be used during the fabrication of cans in welding, cementing, or
soldering processes.
The largest reportable use of Section 313 chemicals in can making is use of solvents and
pigments in inks and coatings. Coatings may be applied to both the interior and exienor of the
can, generally using roll coating, printing, or spraying processes. In larger operations, uie
coaangs may be formulated on-site. Vanous solvents may be used in printing md zzzzr.g us:s,
both as pigment earners and to clean up equipment and spills.
Reporting Threshold: Section 313 chemicals in the strip metal and in solder and welding rods
are processed (as an article component) and are therefore subject to the 25,000-pound reporting
threshold. It is important that the de minimis and article exclusions be considered for the strip
metal. In general, can making cannot be exempted from threshold determination under the
article exemption. To decide if the exemption applies, careful consideration must be given to
whether the shape of the metal is changed or emissions result from operations such as welding.
The article exemption is explained more fully in EPA's "Section 313 Reporting Issue Paper
Clarification and Guidance for the Metal Fabrication Industry." Questions also can be directed
to the Section 313 EPA regional contacts; their telephone numbers are listed in Appendix H of
EPA's "Toxic Chemical Release Inventory Reporting Form R and Instructions, Revised 1989
Version" (EPA 560/4-90-007).
Ink and coating pigments are also processed (as an article component) and subject to the 25,000-
pound reporting threshold. Solvents used in inks and coatings and for equipment cleanup are
considered otherwise used (as a chemical processing aid) and are subject to the 10,000-pound
reporting threshold. Formulation of the inks or coatings for use on-site constitutes processing of
the solvents (as a formulation component). This activity also should be reported, but since the
solvents are then otherwise used the lower 10,000-pound reporting threshold prevails.
The use of isopropyl alcohol as a printing or coating solvent is not reportable under Section 313.
A Form R is only required if the facility manufactures isopropyl alcohol on-site using the strong
acid process.
Release Estimation: Releases from strip metal stamping operations are typically minor. Scrap
from the process is usually shipped off-site for recycling of the metal. The quantity of Section
313 metals in this waste thus need not be reported on Form R. Releases from large soldering or
welding operations may be subject to air permitting requirements. Releases to air in such
instances may therefore best be determined by the permit conditions or monitoring of the
4-19
-------
process. The EPA's "Section 313 Reporting Issue Paper: Clarification and Guidance for the
Metal Fabrication Industry" also contains information on estimating releases from these types of
operations.
Most ink and coating solvents are volatile chemicals and it can be assumed that all the amounts
used will evaporate during handling, blending, or drying of the ink or coating. The quantity
released to air is therefore equal to total solvent usage for these purposes except any amounts that
are captured or destroyed by control devices such as carbon adsorbers or thermal oxidizers (i.e.,
incinerators). A mass balance is the best method for estimating these releases. If there are no
controls, all the solvent usage for inks and coatings should be reported as fugitive or point air
releases. If destructive controls are used (e.g., thermal oxidizers), you should estimate the
amount of solvent destroyed using engineering assumptions of the quantity of solvent reaching
the control device and its destruction efficiency. If nondesirucuve controls are usea (.e.g.,
adsorbers), the amount of the captured solvent in wastes sent off-site for recycle, treatment, or
disposal can be estimated through analysis of these wastes. Water releases from control devices
can be estimated from monitoring data. Air releases then are the difference between total usage
and the amount captured in this manner.
The wastes shipped off-site also may contain pigments. The quantity of the Section 313
chemicals involved can be determined through analysis of the wastes or knowledge of the
coa^ng operation nr.sfer The totil quantity cf Se:::o- 71? ccitir.r rrr-e-t ured
times (1 - transfer efficiency) will yield the total quantity of chemical released. Engineering
assumptions can then be used to determine the media to which these releases are made.
A portion of the solvents used to clean ink rollers or spills also will evaporate and should be
reponed as a fugitive air release. The remaining portion is typically collected, drummed, and
shipped off-site for disposal, treatment, or reuse. The quantity of the Section 313 chemicals in
these wastes can be determined through analysis of these wastes. The amount of cleanup solvent
released to air can be estimated by mass balance, based on analysis of the waste solvent from this
application that is sent for recycle or disposal.
Additional information on estimating releases on printing and coating solvents can be found in
the EPA publications, "Estimating Chemical Releases from Printing Operations" (EPA 560/4-88-
004b) and "Estimating Chemical Releases from Roller, Knife, and Gravure Coating Operations"
(EPA 560/4-88-004j).
Common Reporting Errors: One possible error in can making would be to fail to report for the
metal content of the cans under the assumption that it is always subject to the article exemption
and therefore not reportable under Section 313.
A common reporting error in use of solvents in ink and coating applications is failure to account
for all the usage of an ink or coating solvent through some release or off-site transfer. None of
the solvent should be assumed to remain with the printed or coated product. All usage should be
accounted for through air releases, amounts captured or destroyed in control devices, releases to
water, and amounts sent off-site. Total usage is best determined from purchase records for the
coating or ink and the percentage of the solvent in these materials.
Another common reporting error in use of solvents in these applications is to report amounts sent
off-site for recycle as off-site transfers. Spent solvents are commonly shipped to off-site .
facilities for recovery of the solvent According to Section 313 instructions, quantities of the
chemical sent off-site for purposes of reuse or recycle should not be reported on Form R. Only
the amounts of the solvent transferred off-site for disposal or treatments that do not involve
recycle should be reponed.
4-20
-------
Overestimarion of the amount of solvent in waste sent off-site also can occur. This quantity
should be based on analysis of the waste. The waste is not 100 percent solvent, and the total
amount of waste shipped off-site must be adjusted for the solvent concentration. Many facilities
that receive waste solvents will provide information on the quantity of solvents present in the
waste sent to them. This information is a key component of a mass balance for estimating
solvent release.
Another potential error in this category is incorrectly classifying the chemical activity of the
coating pigments as otherwise used. Because these chemicals are processed, they are subject to
the nigner 2i,GOO-pound reporting threshold.
A final reporting error in these applications is incorrectly submitting a Form R for isopropyl
i^ohcl is cfte* used as an ink solvent. According to Section 313 definition, a Form R is
only required for isopropyl alcohol if the facility manufactures the cnemicai on-site using tne
strong acid process. Use of isopropyl alcohol as an ink or coating solvent is therefore not subject
to Section 313 reporting.
4-21
-------
SECTIONS
HOW TO COMPLETE FORM R
5-1
-------
f/w£2222il^!2L21£ll2IH£Si^22£l!22t^SiKlJS!£i£££!£^Si-^——
SEPA
TOXIC O
Sauuuw 11}
IM MM 1
EPA FORM
R
J.S. E/nronmanui ' Aganay
HEMICAL RELEASE INVENTORY REPORTING FORM
of fM Eivwroaner Wvmj *10 Oamwy WyM«l | 1.1 fmmm i«« im>
[ ] Mm 1 m —11 1 J; [ Jiaflialml]! [ ] 1. mu[ Iimmim
• nw nalinoiai 1 * 0- •> —™ I 1.I k ' 1 '
Part I, Section 1
• This section should be answered only after completing report
• Trade secret submissions require substantiation
• Two reports are required for trade secret submissions
- One complete "unsaniazed" version
- One "sanitized" version
• Repordr.g year is the year in which releases occur:
X. CSKTlflCATION |AMd «na nqn *A«r «
I MW i Nm jvmmm* *a IMi— «au
1!
I
1—
Om tra
Part I, Section 2
• An original signature is required
• Must be signed by plant manager
• Name must be legible (printed or typed)
• Title is required
• Date is required
5-2
-------
J. FfOLTTY IDSN7TWCAT10N
WHERE TO SEND COMPLETED FORMS:
' •"*"*
J.I
1. SPCRA WWT1NQ CSKTBB
P.O. 1CX 33779
r
WASHINGTON, DC 20025-J77?
ATTN: TOXJC CHEMICAL RELEASE INVENTORY
•us
J* COB
2. APPROPRIATE STATS OFFICE (Sm Instruction*
TW PtMtnr mjjtntmum
In Appeosta G)
f t
[ ]
- » [
] m m imM*.
j.a
T—-
J 4
*oa Qsnad
Part I, Sections 3.1 through 3.4
• All pans of facility name and address are required
• Include your company and plant names in the name if appropriate (e.g., XYZ
Company Middletown Plant)
• P.O. Box addresses are no: acceptable
• The 15-character TRI facility identification number should be on the reporting
package you received from EPA; it begins with your Zip Code (call the
EPCRA Hotline if you do not know your TRI identification number)
• You must specify (with a check in Section 3.2) whether the report covers all or
pan of die releases of one chemical from the facility
• Establishments within a facility may report emissions separately (but
thresholds apply to the facility as a whole)
• Names and phone numbers of the technical and public contacts are required
- Technical contact should be able to explain the data to EPA
- Public contact should be able to represent the facility-to the public
5-3
-------
3.1
rndLmrmm i
a. k. «.
4 ft »
3.1
UtIMI
IJWMI
On MIWM
0"r*" "1"" ®"™"™
3.7
Ow A feMMM ftMWta)
k
».
3.1
9A —1^111 'MMMIM <*C*A (.0.
ft.
t.
3.1
»*¦—1.|
•
Part I, Sections 3 J through 3.9
• SIC zodts — ust be 4 digits from 2000 to 3999 (enter it least c-e); T:b'e I:-
Toxic Chemical Release Inventory Repornng Form R and Instructions
(Revised 1989 Version) lists the SIC codes in this range
• EPA identification numbers are assigned mainly for RCRA-covered facilities
• Latitude for all reporting facilities is less than 90° ("NA" is not acceptable)
• Longitude for all reporting facilities is less than 180° ("NA" is not acceptable)
• D'jn & Bradstrstt numbers 2re 9 numbers Cor enter "NA'"*
• EPA idtnrifjcation numbers are 3 letters (usually the state abbreviation and
"D") followed by 9 numbers (or enter "NA")
• NPDES permit numbers are 2 letters (state abbreviation) followed by 7
numbers (or enter "NA")
3.10
I
l
1
I
!
I
>
•
t
i
4
k
4
f
3.11
a.
Part L Sections 3.10 through 3.11
• Name each receiving stream to which you discharge the reported toxic
chemical; make sure to address each receiving stream in Section 5.3
• Provide the underground injection well code identification numbers (or enter
"NA"); make sure the totals from all wells arc aggregated in Section 5.4
5^
-------
4. parcnt qompamv information
4 1
hm« mtmm
t.i |
Part I, Section 4
• Provide the name and Dun & Bradstreet number of your parent company (or
enter "NA")
• Dun & Bradstreet numbers are 9 numbers (or enter "NA")
(Important: Typt or print: rtad bvirucitonj btfgrt campUunt for** ) »»q» I aM
A enA EPA FORM R
O C. A ii. opt-site locations to which toxic
CHEMICALS AAE TRANSFERRED IM WASTES
\Trm moo far jqj ;¦* jm
t. AJBUGLY OWN CO T*tAfM«HT WOAKI <^CTW«)
1.1 POTW uim
•
1*J POTW nim*
IM
lorn motma
Cttt j'fwwi
«uw |£*
Zm
Part II, Section 1
• Provide complete information on a POTW receiving wastewater containing any
listed chemical
• All information must be filled out for each POTW
• P.O. Box addresses are not acceptable
• Check the box at the bottom of Pan II if you are reporting more than two
POTW's and attach additional Page 2's
5-5
-------
U OTH£M 0f*F-4rTC LOCATION* DO a0T fWT U»nc»« TO «Oi «u*TU **( OCT TOM WCTOM OR fttujfll.
2.1 Oft-iO* t—Mow n«m«
2.2 Off-tiM it—run aatw
MNffMNP mmw (ACAA O.
Mm -I'-
CAT
car
OM1VV
2*
• wiii *mm tmmm m iwaf\u% mo*«q m wmwm mi —i|l
( ]- [ 1-
[ U [ )-
2.1 Off*«it« ioo4i»«n
2.4 ^ciJoA r\««
&A mmmjtmil»wy fl *•.)
C»* mumiw* 1 Ml—
-------
(Important: Tjpt or print; ttad mnrueuomt btfon computing /arm.) P*o« ) ¦( I
* EPA
SPA FOAmR
PART m. CXEMICAL-SPEOflC INFORMATION
(Tfti *40*
tor yar ootmm um.)
1. CHEMICAL lOENTrmoe not eoffwma va wanaw r you oanvtet* s«cioi I |
1.1
(naaamdl
1.2
CA* Nutoar «
1.1
Cihiihj a O
mrwn CAitQorr urwitwmMwoMBf e* n aa.j
1.4
Oiot Chamc
MIXTURE COMPONENT IDENTITY |5o net oomo*« rrt* Motion » rou oerrcMt* Scotun I 1
1.
fmmm Owmm*
i wwi, mmm
m. )
Part HI, Sections 1 and 2
• Complete Section 1 (Chemical Identity) or Section 2 (Mixture Component
Identify), but not both
• For trade secret reports, provide only a generic chemical name in Section 1 4
(remember to check the box in Part I, Section 1.1)
• In Section 1.2, provide the chemical name and CAS number exactly as listed
by EPA in Table II in Toxic Chemical Release Inventory Reporting Form R
and Instructions (Revised 1989 Version)
• Do not provide a CAS number for chemical category reports (enter "NA")
• Complete Section 2 if you know only the genenc chemical name of a
component in a mixture or trade name product; you should only use this section
if a supplier provides a generic chemical name but claims a trade secret and
will not supply exact contents
You do not have to report if:
• The chemical is not on the list in Table II in Toxic Chemical Release Inventory
Reporting Form R and Instructions (Revised 1989 Version)
• The chemical does not belong in one of the Section 313 chemical categories at
the end of Table II
• During the calendar year, you manufactured (including imported) or processed
less than 25,000 pounds or otherwise used less than 10,000 pounds of the
chemical
5-7
-------
t. ACTIVITIES ANO USES OP TH6 CHEMICAL AT TH6 FACILITY ICn«ci t Out K»N )
».l
ManuUoiu/a MM
«l—<»«ii f %
>.l j
b. [ ] Import
» pti»«ii m Wipeni
f Ihr , f 1 for utoS
••I J mmurumiim a.l Joaarttuom
«.[ ] Aa « brarodwt l.[ ] Aa «n knuHly
i.:
r",,M r 1 . . k f 1 Aa • tarmiauan f 1 A« an troot
ohawilaah ••I ' ¦•¦¦¦¦¦ ».l Iwibvhm o.l Jaempmm
4. [ ] KwnfjUj artr
j.i
Oitwrwia* uia f 1 As • armcnaM 1 l ^ f 1
iheehwefeili *** J Aa • manufaetwfria *M o.l J Anc*Unr or oO* um
Part III, Section 3
• Check all activities and uses that apply at the facility
• If you manufacture or import the chemical, you must check 3. la or 3.1 b plus at
least one additional activity indicated in 3:1c through 3.If
• If you check 3. lc, you must indicate at least one activity in 3.2 or 3.3
• You must check at least one box
4. MAXIMUM AMOUNT OP THg CHgMICAL 0f<-4fTg AT AMY TIMt OUHINO THg CALgNOAW YCA»
1 1 I lanttr eod*|
Part HI, Section 4
* You must enter your estimate of the maximum amount of the chemical on-site
(do not enter "NA")
• Appendix B in Toxic Chemical Release Inventory Reporting Form R and
Instructions (Revised 1989 Version) lists the maximum amount codes
5-8
-------
1. ACLCAS6S OPTHG CHEMICAL TO THe ENVIMOMMCNT ON-aiTE
1,000 pstra* bv rharttn ranqaa iattar A.I.
(Oa not w boat A. 1 and A.2)
A. Total Aalaaaa
IpauWMyMr)
a. Sam
Ifttnua
fwnir oodai
C. •* from
Starrmnur
A.I
KaBawtut flanqaa
a t->aa lap i—
A.2
Emwr
1.1 FVqnlva « nm palm ttt emlsstene
1.1a
(](][]
1.16 LJ
S.2 (task ar palm air omloaMna
1.3a
[][][]
l.2> LJ
I.J OJaafurga* (a rtdiMnt 1 1
iinuii o trtia/ iMtot LJ
Ito — to mm f~~1
nap«S!r J. 10 M 1.1.2 1 1
J.J. la
[][](]
S.J.1ft ~
S.J. la t
1.1.2a
Mini
s.j.a CH
S.J.Jo *
*.*.!>
(nit]
I.J.Jk LJ
1.1.Ja *
3.4 Uv4argrawn4 InfMtlan
t.U
m ri m
1.4k LJ
t.l m«m« hm
•.«.! i
9M«M
I.J.la
m m m
S.S.Ib n
«.(.]>
[)(][]
0.5.Ml Q
I.«.J*
(](](]
S.S.Jb LJ
l.l.to
(][][]
s.i.4» LJ
Part III, Section 5
• General
- All releases to the environment must be listed in this section
- Discharges to water should be identified by the receiving stream (use the
alphabetical codes from Pan I, Section 3.10 to match the discharges with the
receiving streams)
- Do not leave any lines blank; if a line item docs not apply, enter "NA" in
column A.2 for that line or check the "0" box
- Do not report POTW releases or other off-site transfers in this section
- Check the box at the bottom if additional information on releases to the
environment on-site is in Part IV and attach additional Page 5's
• Column A
- Estimate releases separately by medium and type of release
- Enter either the actual estimate or enter an "X" in the appropriate range
column if the release is less than 1000 pounds (do not enter both)
• Column B
- You must enter "M", "C", "E", or "O" as the basis for each estimate
• Column C
- Estimate the percent contributions from stormwater for discharges to water
5-9
-------
(Important: Typ* or print; rtad uvtnutimg ktfor* compUiUif form.) tail
£ EP/\ ih tonmR
PART IU. CHEMICAL-8PEQF)C INFORMATION
(continued)
(THc me* for your ootional um. )
1. T7UNIFCM OF TUG CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You ma* noon tr anal an
•f h«i ma 1,000 oomi by
ra»9M mar A.», (Ba
not um tout A.I and A.]|
A* Tout Trvwtmrt
1. taw (sonata
Mr oodcl
C.Typ# of TrmimmU
OUowmM
eodil
A.!
A.J
fnw
EMmai*
[][][]
l.t.lk L)
IHHH
0mm 1 »«¦ Moaiton ,
•m cr^mjsrj., |_»j (_j
t l f l r i
(_]
I.J.J Um •«, i. tmmtm 1 1 '
n
i l ( if i
i.j.a 0
I.I.Jo |m| | |
1.2.s 11*
[ l r i [ i
».».» n
I.J.Jo | Mi II
[ ]|Qnmi V Morm«dM to «i Nn W-*ee*smeniel Manfwdan.1
Part III, Section 6
• Transfers of chemicals to off-site locations must be included in this section
• Enter the POTW and other off-site location identification numbers as they
appear in Pan II, Section 2 (i.e., 1,2,3, etc.)
• Differentiate between transfers to a POTW (Section 6.3.1) and transfers to
other off-site locations (Section 6.2)
• Enter either the actual estimate or enter an "X" in the appropriate range column
if the release is less than 1000 pounds (do not enter both)
• For other off-site transfers, you must enter a treatment code in Section 6.2.C;
Appendix B in Toxic Chemical Release Inventory Reporting Form R and
Instructions (Revised 1989 Version) lists these treatment/disposal codes, which
start with an "M"
• Check the box at the bottom if additional information on off-site transfers is in
Part IV
5-10
-------
7. WA1TC TMATMKMT MCTHOOl AMO EFFICIENCY
r 1 Nat ApptnnW |NA| - 0»
-------
i. waste tmatmint mkthoq* and wasMcr
I 1 a«teoary.
A.Oflnartf
WUtMVHfll
lamsr ooda)
1. TrMtmart
m«im
oodsk
C.Jtan^a«
Cvmncrwton
0, £*quamtd
(QMCI d
E.
tmeteney
(MMU
P. Swd an
Optfim
0«t«>
He
7.1« ®
7.15 iPtHH
7. to 0
7.1d [X]
7.1* NA %
7.1' [If]
7.J* [w]
7,» |qtO|l|
7.U [_}
7M ( x I
7.2» NA *
7.31 [ ] [ ]
7J« (w]
7.» IP 1 9) 91
7. J* ~
TM fx!
7.J. 100 *
7¦* [ * ] f 1
?.«• Q
II 1 1
7.4, Q
744 [ ]
7.4. %
7.4f fill
7 1. Q
'» 1 M f
T.ta Q
TU [1
7.5a %
7 y f ] [ 1
'»° o
7» II II
r.trn Q
7.M f 1
7 U 1
7.M f 1 [ 1
7 7. Q
"* MM
7.7« Q
114 [ 1
7.7» %
7.7f r ] r j
7.14 ~
'¦» MM
7,1. Q
7.14 [ ]
7.to %
1 u [If]
7 1. Q
MM
T.fci Q
7.M [ 1
7 A* %
7 m [ I [ 1
7.1ta ~
MO. | | | |
7.toa Q
7.1M [ ]
7.10. * 7. lOf [ 1 [ ]
[ ](Omi N mtfrWid MwmaOan 4 Pwr IV Tiwilnniri Vttormctton.)
Part m, Section 7 (sequential treatment)
• The first step in a sequential treatment shows the influent concentration and the
last step shows the overall efficiency for the entire sequence and whether the
efficiency is based on operating data
• For each set of sequential treatment steps, you must fill in:
- Columns A, B, and D for all steps
- Column C for the first step only
- Columns E and F for the last step only
• Do not enter influent concentration or treatment efficiency for intermediate
steps of the sequential treatment
• Enter "NA" for treatment efficiency for all but the last step of the sequence
5-12
-------
t. POLUSTION f
(Moat* aettani
Kant and ai
•HEVBNTlONl OPTIONAL INFORMATION ON WAtTl MINIMIZATION
takan to raouoa ma amouM at tna miu bang rtluM from am fasflcy. I« tha hacruedona (or oodad
D
-------
(Important: Typ* or print: ttad bwruetUuu b*(or* compliant form.)
* EPA
MA FORM R
PART IV. SUPPLEMENTAL INFORMATION
Um (Mi Modan W you r—4 OWund aoaoa tar mmn ta quaadana b Fin a.
• Inaa IM4 hiiu>iiii>> Iron toaa n prMr aaooana I.J.4. I I.J. 7.11)
(1>a MM lor yow M0an4 w I
AOOfTtONAi. INFORMATION ON R£LEA*EJ O* THE CHCMICAL TO TH( CNVIMONMCNT ON-»rre
(Put HI. Wallow i l\
»
Ym may man rniMM ot lax than
1 000 mm av awauung ranqa* inar A.I.
10* km uaa Mat A.I ana A.J|
A. Tm* Ailam
(pounaa/yaarl
S. Sam at
littmitt
(•mar eoda
n ms
C % from
SlonfM«lir
A.I
Whimmg Hawp«i
Stmut#
1.3 OtaoAargaa la
atraMia •/ 11
»«ur trtln
fe^jSTaSMliT ISfoT" | [_]
(][][]
1 3 w
4 3 —C %
1.1 •
(][][]
».». til 111—0 h
«.J •
[](](]
*.i. JZU! * ^ c %
A00IT1ONAL INFORMATION ON TIUMIPOU OF TVt« CHEMICAL IN WAITS TO arf-trrc LOCATION*
A.To«4 Trcmfart
tpaMa/y«tf|
B. Hi«a of
Ciaiwu
|«n« ooda
n boa
prondadl
C. Typ* oi Ifttrrmntt
Qtaeo**i
(•m*f eodo
h box
provtotd)
of *••• 9tan 1.000 powos by oheotinq
rw9MiiMrA,l. (Oo not tut
bocn A.I and A.JI
A.1
AipOfTt^ Aviqm
9 >-*«• 100 <08
A.2
Kmar
Eitlmata
».i. £sfiSrsSr,
[ 1 [ 1 [ 1
1 1. b [_J
«. aaaw j i LfJ | |
I 1 [ 1 [ ]
• J. h (_J
«.l._a|M| | |
•*_er ran
[][][)
«.j. * n
• 1. g|M| | |
,l—u-F„.. «ssn., 0 ~
mum
n
0
I
N
4»
«.i. olMi | |
Part IV (top half)
• Additional information on discharges to water and transfers to off-site locations
may be provided in these sections
• Number information sequentially from the previous pages; for example, if you
discharge the chemical to two POTW's, the first would be listed on Page 4 as
6.1.1 and the second would be listed here as 6.1.2
• Be sure that the appropriate box is checked at the bottom of the page in Pans I,
II, or HI to indicate that additional information is provided in Pan IV
5-14
-------
AOOmONAL INFORMATION ON WASTf
THEATMFNT MffTHOOS ANO EFFICIENCY (Pift III. UcilaA 71
WMMtnan
fc» ttos uiuwmll
1. Trtatmwi)
Mltftod
law ac*>
h bos wowdwil
C.fUng« ct
WfclW
0. IcoumkUI
Trtunwmt
Ionia* »
£. Treatment
((fldMCV
Csifviu*
P. 3AM4 «l
Ootrittr*
0«V*F
v«« Mo
7--—8 n
>•_» 1 1 1 1
7. t *
1 II J
>• -> 1 1 1 1
• ~
'• * [ J
7. 0 *
'• * [ J I J
7-—
1 1 1 1
r-—• ~
7« * I J
9 [ J I ]
T._. 1 1 1 1
'• • ~
^ I j
7 * [ J [ ]
r._» II 1 1
'• o ~
^ I J
7. 9 %
' i J [ j
f. » 1 \ 1 1
• ~
'* ^ I j
'• ' [ J I J
7-—• ~
7- b UN
T. o Q
^ [ J
'• ' I J I ]
—• ~
LLLI
'• • ~
^ ^ I J
7. • *
1 I ] I J
1 1 1 1
7 4 [ j
7'——' L J I 1
Part IV (bottom half)
• Additional information on waste treatment methods and efficiency may be
provided in these sections
• Number information sequentially from previous sections (i.e., the first line
would be 7.11.a, 7.1 l.b, 7.1 I.e. etc.)
• Be sure that the appropriate box is checked at the bottom of the page in Pans I,
II, or HI to indicate that additional information is provided in Pan IV
5-15
-------
APPENDIX A
ALPHABETICAL LISTING OF
SECTION 313 CHEMICALS
A-l
-------
CAS Number Chemical Name Ds MinimisJk
75-07-0 AcetaJdehyde 1.0
60-35-5 Acetamide 0.1
67-64-1 Accionc 1.0
75-05-8 Acetonitrile 0.1
53-96-3 2-Acctylaminofluorcnc 0.1
107-02-8 Acrolein 1.0
79-06-1 Acrylamide 0.1
79-10-7 Acrylic acid 1.0
107-13-1 Acrylonitrile 0.1
309-00-2 Aldrin {1,4:5,8-dimethanonaphthalene, 1.0
1,2,3,4,10,10-hexachloro-1,4,4a,5,8,8a-
hexahydro-(l .alpha.,4.alpha.,4a.be ta.,
5.alpha.,8.alpha.,8a. beta.)-)
*107-18-6 Allyl alcohol 1.0
107-05-1 Allyl chloride 1.0
7429-90-5 Aluminum (fume or dust) 1.0
1344-28-1 Aluminum oxide (fibrous) 1.0
82-28-0 l-Amino-2-methylanthraquinone 0.1
{Pentachloronitro-benzene}
117-79-2 2-Aminoanthraquinone 0.1
60-09-3 4-Aminoazobenzene 0.1
92-67-1 4-Aminobiphenyl 0.1
7664-41-7 Ammonia 1.0
6484-52-2 Ammonium nitrate (solution) 1.0
7783-20-2 Ammonium sulfate (solution) 1.0
62-53-3 Aniline 1.0
90-04-0 o-Anisidine 0.1
104-94-9 p-Anisidine 1.0
134-29-2 o-Anisidine hydrochoride 0.1
120-12-7 Anthracene 1.0
7440-36-0 Antimony 1.0
7440-38-2 Arsenic 0.1
1332-21-4 Asbestos (friable) 0.1
7440-39-3 Barium 1.0
98-87-3 Benzal chloride 1.0
55-21-0 Benzamide 1.0
71-43-2 Benzene 0.1
92-87-5 Benzidine 0.1
98-07-7 Benzoic trichloride (Benzotrichloride) 0.1
98-88-4 Benzoyl chloride 1.0
94-36-0 Benzoyl peroxide 1.0
100-44-7 Benzyl chloride 1.0
7440-41-7 Beryllium 0.1
92-52-4 Biphenyl 1.0
* Those chemicals marked with an asterisk have been added to the Section 313 list and will be
subject to reporring for the 1990 reporting year with the first reports becoming due by July-1,
1991.
A-2
-------
CAS Number
Chemical Name
108-60-i
Bis(2-chloro-l-methylethyl) ether
1.0
111-44-4
Bis(2-chloroethyl) ether
1.0
103-23-1
Bis(2-ethylhexyl) adipate
0.1
542-88-1
Bis(chloromethyl) ether
0.1
75-25-2
Bromoform (Tribromomethane}
1.0
74-83-9
Bromomethane (Methyl bromide}
1.0
106-99-0
1,3-Butadiene
0.1
141-32-2
Butyl acrylate
1.0
71-36-3
n-Butyl alcohol
1.0
78-92-2
sec-Butyl alcohol
1.0
75-65-0
ten-Butyl alcohol
1.0
85-68-7
Butyl benzyl phthalate
1.0
106-88-7
1,2-Butylene oxide
1.0
123-72-8
Butyraldehyde
1.0
4680-78-8
C.I. Acid Green 3
1.0
569-64-2
C.I. Basic Green 4
1.0
989-38-8
C.I. Basic Red 1
0.1
1937-37-7
C.l. Direct Black 38
0.1
2602-46-2
C.I. Direct Blue 6
0.1
16071-86-6
CL Direct Brown 95
0.1
2832-40-8
CI. Disperse Yellow 3
1.0
81-88-9
C.I. Food Red 15
0.1
3761-53-3
C.I. Food Red 5
0.1
3118-97-6
C.I. Solvent Orange 7
1.0
842-07-9
CL Solvent Yellow 14
0.1
97-56-3
CL Solvent Yellow 3
0.1
492-80-8
C.I. Solvent Yellow 34 (Auraminc)
0.1
128-66-5
CI. Vat Yellow 4
1.0
7440-43-9
Cadmium
0.1
156-62-7
Calcium cyan amide
1.0
133-06-2
Captan (lH-Isoindole-l,3(2H)-
-------
-------
CAS Numtar
Chemical Name L
120-83-2
2,4-Dichlorophenol
1.0
78-87-5
1,2-Dichloropropane
1.0
*78-88-6
2,3-Dichloropropene
1.0
542-75-6
1,3-Dichloropropyiene
0.1
62-73-7
Dichlorvos (Phosphoric acid, 2,2-dichloroethenyl
1.0
dimethyl ester)
1.0
115-32-2
Dicofol {Benzenemethanol, 4-chloro-.alpha.-
(4-chlorophenyl)-.alpha.-(trichloromethyl)-)
0.1
1464-53-5
Diepoxybutane
111-42-2
Diethanolamine
1.0
84-66-2
Diethyl phthalate
1.0
64-67-5
Diethyl sulfate
0.1
119-90-4
3,3' -Dimethoxybenzidine
0.1
57-14-7
1,1-Dimethyl hydrazine
0.1
131-11-3
Dimethyl phthalate
1.0
77-78-1
Dimethyl sulfate
0.1
*99-65-0
m-Dinitrobenzene
1.0
*528-29-0
o-Dinitrobenzene
1.0
*100-25-4
p-Dinitro benzene
1.0
60-11-7
4-Dimethylaminoazobenzene
0.1
119-93-7
3,3' -Dimethylbenzidine
0.1
79-44-7
Dimethyicarbamyl chloride
0.1
105-67-9
2,4-Dimethylphenol
1.0
534-52-1
4,6-Dinitro-o-oesol
1.0
51-28-5
2,4-Dinitrophenol
1.0
121-14-2
2,4-Dinitrotoluene
1.0
606-20-2
2,6-Dinitrotoluene
1.0
*25321-14-6
Dinitrotoluene (mixed isomers)
1.0
117-84-0
n-Dioctyl phthalate
1.0
123-91-1
1,4-Dioxane
0.1
122-66-7
1,2-Diphenylhydrazine {Hydrazobenzene}
0.1
106-89-8
Epichlorohydrin
0.1
110-80-5
2-Ethoxyethanol
1.0
140-88-5
Ethyl acrylate
0.1
541-41-3
Ethyl chloroformate
1.0
100-41-4
Ethylbenzene
1.0
74-85-1
Ethylene
1.0
107-21-1
Ethylene glycol
1.0
75-21-8
Ethylene oxide
0.1
96-45-7
Ethylene thiourea
0.1
151-56-4
Ethyleneimine {Aziridine}
0.1
2164-17-2
Fluometuron {Urea, N,N-dimethyl-N'-
1.0
[3-(trifluoromethyl)phenyl]-)
50-00-0
Formaldehyde
0.1
76-13-1
Freon 113 {Ethane, 1,1,2-trichlord-1,2,2-
1.0
trifluoro-)
76-44-8
Heptachlor {1,4^5,6,7,8,8-Heptachloro-3a,4,7,7a-
1.0
tetrahydro-4,7-methano-lH-indene)
AS
-------
CAS Number Chemical Name Os Minim
87-68-3 Hexachloro-l,3-butadiene LO
118-74-1 Hexachlorobenzene 0.1
77-47-4 Hexachlorocyclopentadiene 1.0
67-72-1 Hexachloroethane 1.0
1335-87-1 Hexachloronaphthalene 1.0
630-31-9 Hexamethylphosphoramide 0.1
302-01-2 Hydrazine 0.1
10034-93-2 Hydrazine sulfate 0.1
7647-01-0 Hydrochloric acid 1.0
74-90-8 Hydrogen cyanide 1.0
7664-39-3 Hydrogen fluoride 1.0
123-31-9 Hydroquinone 1.0
78-84-2 Isobutylraldehyde 1.0
67-63-0 Isopropyl alcohol (manufacturing-strong acid 0.1
process, no supplier notification)
80-05-7 4,4'-Isopropylidenediphenol 1.0
*120-58-1 Isosafrole 0.1
7439-92-1 Lead 0.1
58-89-9 Lindane {Cyclohexane, 1,2,3,4,5,6-hexachloro-, 0.1
(l.alpha.»2.alpha.,3.beta.,4.alpha.,5.alpha.,
6.beta.)-}
108-31-6 Maleic anhydride 1.0
12427-38-2 Maneb (Carbamodithioic acid, 1,2- 1.0
ethanediylbis-, manganese complex)
7439-96-5 Manganese 1.0
7439-97-6 Mercury 1.0
67-56-1 Methanol 1.0
72-43-5 Methoxychlor (Benzene, l,l'-(2,22- 1-0
trichloroethylidene)bis(4-methoxy-}
109-86-4 2-Methoxyethanol 1.0
96-33-3 Methyl acrylate 1.0
78-93-3 Methyl ethyl ketone 1.0
60-34-4 Methyl hydrazine 1.0
74-88-4 Methyl iodide 0.1
108-10-1 Methyl isobutyl ketone 1.0
624-83-9 Methyl isocyanate 1.0
80-62-6 Methyl methacrylate 1.0
1634-04-4 Methyl ten-butyi ether 1.0
74-95-3 Methylene bromide 1.0
101-14-4 4,4,-Methyienebis(2-chloroaniline) (MBOCA) 0.1
101-61-1 4,4,-Methyienebis(N,N-dimeihyl) benzenamine 0.1
101-68-8 Methylenebis(phenylisocyanate) {MBI) 1.0
101-77-9 4,4'-Methylenedianiiine 0.1
90-94-8 Michler's ketone 0.1
1313-27-5 Molybdenum trioxide 1.0
505-60-2 Mustard gas (Ethane,l,r-thiobis(2-chloro-) 0.1
121-69-7 N,N-Dimethylaniline 1.0
759-73-9 N-Nitroso-N-ethylurea 0.1
A-6
-------
CAS Number
Chemical Name £
684-93-5
N-Nitroso-N-methylurea
0.1
924-16-3
N-Nitrosodi-n-butylamine
0.1
621-64-7
N-Nitrosodi-n-propylamine
0.1
55-18-5
N-Nitrosodie thy lamine
0.1
62-75-9
N-Nitrosodimethylamine
0.1
86-30-6
N-Nitrosodiphenylamine
1.0
4549-40-0
N-Nitrosomcthylvinylamine
0.1
59-89-2
N-Nitrosomorpholinc
0.1
16543-55-8
N-Nitrosonomicotine
0.1
100-75-4
N - N itrosopi peridine
0.1
91-20-3
Naphthalene
1.0
134-32-7 1
alpha-Naphthylamine
0.1
7440-02-0
Nickel
0.1
7697-37-2
Nitric acid
1.0
139-13-9
Nitrilotriacetic acid
0.1
99-59-2
5-Nitro-o-anisidine
0.1
98-95-3
Nitrobenzene
1.0
92-93-3
4-Nicrobiphenyl
0.1
1836-75-5
Nitrofen {Benzene, 2,4-dichloro-l-
0.1
(4-nitrophenoxy)-}
0.1
51-75-2
Nitrogen mustard {2-Chloro-N-(2-chloroethyl)-N-
methy lan amine)
1.0
55-63-0
Nitroglycerin
88-75-5
2-Nitrophenol
1.0
100-02-7
4-Nitrophenol
1.0
79-46-9
2-Nitropropane
0.1
156-10-5
p-Nitrosodiphenylamine
0.1
2234-13-1
Octachloronaphthalene
1.0
20816-12-0
Osmium tetroxide
1.0
56-38-2
Parathion (Phosphorothioic acid, o,o-diethyl-o-
1.0
(4-nitrophenyl)ester)
1.0
87-86-5
Pentachlorophenol {PCP)
79-21-0
Peracetic acid
1.0
108-95-2
Phenol
1.0
106-50-3
p-Phenylenediaminc
1.0
90-43-7
2-Phenylphenol
1.0
75-44-5
Phosgene
1.0
7664-38-2
Phosphoric acid
1.0
7723-14-0
Phosphorus (yellow or white)
1.0
85-44-9
Phthalic anhydride
1.0
88-89-1
Picric acid
1.0
1336-36-3
Polychlorinated biphenyls (PCB's)
0.1
1120-71-4
Propane sultone
0.1
57-57-8
beta-Propiolactone
0.1
123-38-6
Propionaldehyde
1.0
114-26-1
Propoxur {Phenol, 2-(l-methylethoxy)-p
1.0
tnethylcarbamate]
1.0
115-07-1
Propylene (Propene)
A-7
-------
CAS Number Chemical Name flg Minim
75-56-9 Propylene oxide 0.1
75-55-8 Propyleneimine 0.1
110-86-1 Pyridine 1.0
91-22-5 Quinolinc 1.0
106-51-4 Quinone 1.0
82-68-8 Quintozene 1.0
81-07-2 Saccharin (manufacturing, no supplier 0.1
notification) (l,2-Benzisothiazol-3(2H)-one,
1,1-dioxide)
94-59-7 Safrole 0.1
7782-49-2 Selenium 1.0
7440-22-4 Silver 1.0
100-42-5 Styrene 0.1
96-09-3 Styrene oxide 0.1
7664-93-9 Sulfuric acid 1.0
100-21-0 Terephthalic acid 1.0
79-34-5 1,1,2,2-Tetrachloroethane 0.1
127-18-4 Tetrachloroethylene (Perchloroethylene) 0.1
961-11-5 Tetrachlorvinphos (Phosphoric acid, 2-chloro-l- 1.0
(2,3,5-trichlorophenyOethenyl dimethyl ester)
7440-28-0 Thallium 1.0
62-55-5 Thioacetamide 0.1
139-65-1 4,4'-Thiodianiline 0.1
62-56-6 Thiourea 0.1
1314-20-1 Thorium dioxide 1.0
7550-45-0 Titanium tetrachloride 1.0
108-88-3 Toluene 1.0
584-84-9 Toluene-2,4-diisocyanate 0.1
91-08-7 Toluene-2,6-diisocyanate 0.1
*26741-62-5 Toluene diisocyanate (mixed isomers) 1.0
636-21-5 o-Toluidine hydrochloride 0.1
95-53-4 o-Toluidine 0.1
8001-35-2 Toxaphene 0.1
68-76-8 Triaziquone {2^-Cyclohexadiene-l,4-dione, 0.1
2,3,5-tris( 1 -aziridinyl)-)
52-68-6 Trichlorfon {Phosphoric acid,(2,2,2-trichloro-l- 1.0
hydroxyethyl)-, dimethyl ester)
120-82-1 1,2,4-Trichlorobenzene 1.0
71-55-6 1,1,1-Trichloroethane (Methyl chloroform) 1.0
79-00-5 1,1,2-Trichloroethane 1.0
79-01-6 Trichloroethylene 1.0
95-95-4 2,4,5-Trichlorophenol 1.0
88-06-2 2,4,6-Trichlorpphenol 0.1
1582-09-8 TrifluraJin (Benzenaminc, 2,6-dinitro-N,N- 1.0
dipropyl-4-(trifluoromethyl)-)
95-63-6 1,2,4-Trimethylbenzene 1.0
126-72-7 Tris(2^3-dibromopropyl) phosphate 0.1
51-79-6 Urethane (Ethyl carbamate) 0.1
A~8
-------
CAS Number
Chemical Name
7440-62-2
Vanadium (fume or dust)
1.0
108-05-4
Vinyl acetate
1.0
593-60-2
Vinyl bromide
0.1
75-01-4
Vinyl chloride
0.1
75-35-4
Vinylidene chloride
1.0
108-38-3
m-Xylene
1.0
95-47-6
o-Xylene
1.0
106-42-3
p-Xylene
1.0
1330-20-7
Xylene (mixed isomers)
1.0
87-62-7
2,6-Xylidine
1.0
7440-66-6
Zinc (fume or dust)
1 0
12122-67-7
Zineb (Carbamodithioic acid, 1,2-ethanediylbis-,
1.0
zinc complex]
Section 313 also requires release reporting for the following chemical categories. Unless
otherwise specified, these metal compounds are defined as including any unique chemical
substance that includes the named metal as part of that chemical's structure. Full definitions of
the Section 313 chemical categories can be found in the EPA publication, "Toxic Chemical
Release Inventory Reporting Form R and Instructions, Revised 1989 Version" (EPA 560/4-90-
007), which is included in EPA's 1989 reporting package.
Antimony compounds
Arsenic compounds
Barium compounds
Beryllium compounds
Cadmium compounds
Chlorophenols
Chromium compounds
Cobalt compounds
Copper compounds
Cyanide compounds
Glycol ethers
Lead compounds
Manganese compounds
Mercury compounds
Nickel compounds
Polybrominated biphenyls
Selenium compounds
Silver compounds
Thallium compounds
Zinc compounds
A-9
-------
APPENDIX B
RELEASE ESTIMATION FOR AMMONIA, CHLORINE, AND ACIDS
Over 80 percent of the Form R's submitted in 1989 by the food processing industry (i.e.,
those for reporting year 1988) were for six chemicals: ammonia, phosphonc acid, sulfuric acid,
chlorine, hydrochloric acid, and nitnc acid. This appendix presents more detailed background
information on estimating environmental releases of ammonia, chlorine, and these acids
(including example calculations) than is presented in the process-specific discussions in Section
4.
AMMONIA AND AMMONIA COMPOUNDS
The Section 313 list of toxic chemicals for reporting year 1989 contains three ammonia-
based chemicals: ammonia, ammonium sulfate (solution), and ammonium nitrate (solution).
The following paragraphs discuss release estimation for these chemicals and other compounds
that may be reportable because they contain ammonia. It concludes with an example calculation
of releases of ammonia to air and water from a refrigeration system.
Ammonia
Ammonia is a listed Section 313 chemical and all gaseous and aqueous forms must be
considered for reporting. Aqueous solutions of ammonia contain both non-ionized ammonia,
NH3, and ionized ammonia, NIV. As the chemical equation below shows, an equilibrium exists
between the two forms of ammonia in the presence of water.
NH3 + 2H20 <—> NH4+ + OH- + H20
The term "total ammonia" refers to the sum of these species (i.e., NH3 + NH4*). The relative
amounts of NH3 and NHi* depend upon several factors (e.g., temperature, pH, ionic strength).
To account for all forms that are present, estimates of releases for Section 313 should be made
for total ammonia.
Ammonium hydroxide solutions also should be considered ammonia because ammonium
hydroxide is aqueous ammonia. The commercial products "aqua ammonia" or "ammonium
hydroxide" are approximately equivalent to 30 percent solutions of ammonia in water. These
products are mixtures of ammonia and water and therefore should be reported as ammonia.
Ammonium Sulfate and Ammonium Nitrate
Aqueous releases of ammonium salts that are individually listed on the Section 313 list of
toxic chemicals should be reported as releases of the specific ammonium salt and not as
ammonia. Specifically, ammonium sulfate (solution) (CAS Number 6484-52-2) and ammonium
nitrate (solution) (CAS Number 6484-52-2) are listed chemicals under Section 313. Facilities
which manufacture, process, or otherwise use aqueous solutions of ammonium sulfate or
ammonium nitrate should report their releases as these chemicals, and not as aqueous ammonia.
B-l
-------
It is anticipated that ammonium sulfate (solution) soon will be removed from the Section
313 list of toxic chemicals. On March 30,1990, EPA issued a proposed rule to delist ammonium
sulfate (soludon) because releases of this chemical can be more effectively covered by the
ammonia listing (55 FR 12144; March 30, 1990). Therefore, for the 1990 reporting year (i.e..
Form R's due on July 1, 1991) and beyond, ammonium sulfate (if delisted) should be treated in
the same manner as other ammonium salts.
Other Ammonium Salts
Ammonium salts dissociate in water and form NH4+ plus a carrier ion. For example,
NH4G dissociates into NH4+ and C1-. The NKt"1" ion sets up the ammonia equilibrium reaction
with water.
NH3 + 2H20 <—> NH<+ + OH- + H20
Therefore, dissociation of ammonium salts forms ammonia as a byproduct that must be
considered for Section 313 reporting. Manufacture of ammonia in this manner is subject to the
25,000-pound manufacturing threshold. The amount of ammonia formed from dissociation is a
function of the ammonium salt, pH, and temperature. For the 1989 reporting year (i.e., Form
R's due July 1,1990), only the quantity of non-ionized ammonia (NH3) that is formed need be
considered.
Starting with the 1990 reporting year, both the ionized (NR*"1") and non-ionized (NH3)
forms of ammonia must be considered for Section 313 reporting (55 FR 12144; March 30, 1990).
Aqueous solutions of ammonium salts that dissociate in water are environmentally equivalent to
aqueous solutions of ammonia. Thus, facilities that manufacture, process, or otherwise use an
aqueous solution of an ammonium salt that dissociates in water (other than ammonium nitrate)
will have to report these releases as ammonia if an activity threshold is met or exceeded. For
example, a facility that buys ammonium chloride in dry form and then makes a solution by
adding water will have to add all non-ionized ammonia and ionized ammonia in the solution
when making threshold determinations and release estimates.
Starting with reporting year 1990, facilities that manufacture, process, or otherwise use
more than one ammonium salt or ammonia source (again excluding ammonium nitrate) must
aggregate their data when making threshold determinations or release estimates. The quantity of
ammonia should only be based on the percentage by weight of ammonia in each ammonium salt,
not the entire weight of the ammonium salt. For example, a facility generates an aqueous
ammonia solution by dissolving 20,000 pounds of ammonia, 100,000 pounds of ammonium
carbonate, and 100,000 pounds of ammonium chloride in water. Ammonium carbonate and
ammonium chloride consist of 27 percent and 32 percent NH3 by weight, respectively. Thus,
59,000 pounds of ammonia (27,000 pounds from ammonium carbonate plus 32,000 pounds from
ammonium chloride) was manufactured, which exceeds the 25,000-pound manufacturing
threshold. Also, 20,000 pounds of ammonia was processed or otherwise used.
By adding an ammonium salt to water, the facility is manufacturing aqueous ammonia
and therefore is subject to the manufacturing threshold of 25,000 pounds. If the resulting
ammonium salt is also "otherwise used" at a facility, both activities, manufacture and otherwise
use, should be shown on the Form R. If an ammonia byproduct is not incorporated into a
product for commercial distribution, the lower "otherwise use" threshold of 10,000 pounds
applies.
B-2
-------
Example Release Estimate
Estimates of releases of ammonia can be illustrated by the following example. A facility
uses anhydrous ammonia in a process refrigeration system. Releases of ammonia to air occur
during system maintenance and through leaks in valves, flanges, and pumps. Ammonia is bled
into water during system maintenance and can leak into the cooling water system through heat
exchangers. Because of leaks and maintenance losses, the refrigeration system must be
recharged with ammonia periodically. All ammonia added to the system is ultimately released in
some fashion. A mass balance approach therefore can be used to estimate releases.
Monitoring data and flow rate can be used to esdmate the quantity of ammonia lost via
wastewater. Fugitive air releases can then be estimated by subtracting the quantity lost to the
wastewater system from the quantity charged to the system. During the year, 15,000 pounds of
ammonia was charged to the system.
Monitoring data for ammonia-nitrogen content in the wastewater discharge are presented
below. Ammonia-nitrogen represents the total NH3 and NH
-------
CHLORINE
Many- industrial facilities use chlorine gas (G2) as a disinfectant in water and wastewater
treatment processes to destroy pathogens and control nuisance microorganisms. Typically, liquid
chlorine is received in pressurized steel cylinders in sizes ranging from 100 pounds to 1 ton. A
side stream of water flowing through an injector is used to create a vacuum that draws chlorine
gas from the cylinders. The gas is mixed into this side stream to form a concentrated solution
that is then mixed with the entire water flow.
Potential chlorine releases from water and wastewater chlorination processes include air
releases from cylinder changeovers, process piping component leaks, and vaporization from
water. Only minor quantity of fugitive air releases would be expected. Chlorine has a low odor
threshold; an average person can detect concentrations of 3 to 5 ppm in air. Some fugitive air
releases from the chlorine gas introduction train are probable, but they are unlikely to be very
high. Chlorine is stored in pressunzed tanks, so losses to air during storage should be low.
Because of the low odor threshold, any process piping leaks can be quickly detected and
remedied.
Releases of chlorine to water or POTW would not occur from water or wastewater
chlorination processes because chlorine reacts with water. Once Ch is introduced into water or
wastewater, it is transformed to HOC1 or other compounds.
Cl2 + H20 <—> HOCl + H* + Cl-
This reaction occurs very quickly. Calculations are presented at the end of this section for a
hypothetical chlorination process in which 100,000 pounds of Ch gas is used during the year, the
applied dose is 10 mg/L (this is an extremely high value), and the facility chlorinates incoming
well water and discharges the water to a stream. The results for several pH levels are as follows:
pH
O2 usage, lb
CI? release, lb
8
100,000
0.0003
6
100,000
0.03
4
100,000
3
Thus, even with assumptions of 100,000 pounds of chlorine usage and a very high
applied dose level, reportable releases do not occur until the pH level is maintained at 4.
Chlorination or discharge of water at this pH level is highly unlikely. A pH between 6 and 9 is
normally used. Chlorine therefore can be assumed to be completely dissociated when used for
water and wastewater disinfection.
Often, a facility will monitor its wastewater for "residual chlorine," which is a parameter
composed of many compounds. Total residual chlorine can be divided into free residual chlonne
(Q2, HOCl, and OQ~) and combined residual chlorine (chloroamines and other chlorinated
organic nitrogen compounds). Because the CI2 concentration will be negligible under neutral pH
conditions* reportable releases to water or POTW will not occur.
B-4
-------
Example Release Estimate
Once CI2 is introduced into water or wastewater, it is transformed to HOC1 or other
compounds.
Cl2 + H20 <—> HOCl + H* + Cl-
The equilibrium constant, Keq, for the reaction is 4.5 x 10-4 at 25° C; therefore:
~ [H+l [Cl-J [HOCll „ . ,
Keq - 45xl(r - 1—' 1 ^j j L Equaaonl
The brackets in Equation 1 represent the concentration of the chemical species in terms of gram
moles/L. At a pH above 4, the reaction is essentially complete and little CI2 remains. In
addition, HOCl may further dissociate into 0C1~ and react with ammonia in water to form
chloroamines. CI2 also will react directly with other compounds in water.
Releases of chlonne as CI2 to water or POTW will therefore be very small. By applying
the CI2/HOCI equilibrium relationship, CI2 releases to water can be calculated. The following
example presents CI2 releases for a hypothedcal chlorination process in which 100,000 pounds of
CI2 gas is used during the year, the applied dose is 10 mg/L (this is an extremely high value), the
pH of the discharge is 8, and the facility chlorinates incoming well water and discharges the
water to a stream.
. .. , . 10 mg Ch/L
Applied dose - (71Q00 mg C12H mol Cl2)
= 1.41 xlO4 mol ChlL = [ChJ applied
The goal of this calculation is to find the equilibrium concentration of CI2 after its reaction with
water (i.e., the [Q2J equilibrium). From the stoichiometry of the CI2/H2O reaction:
[Cl~J = [HOCl] at equilibrium
Also from stoichiometry:
(CtJ = [CIJ applied - {CI2J equilibrium = 1.41 xlQ-4 - (CI2J equilibrium
The pH of the water is maintained at a level of 8; therefore:
(H+] = lxlfr*
Substituting into Equation 1:
Keq = 4Jxl(H = f * l**) [O4 - (Ckl equilibrium?
ICljj equilibrium
Solving for [Q2] equilibrium yields:
CI2 equilibrium = 4.42 x 10mol CtyL
Translating this into a mass-per-volume basis:
Ch equilibrium = 4.42 x 1Q-U mol ChlL x 71 g Clilmol x 1000 mglL
= 3.14 x 10* mg ChlL
B-5
-------
The applied CI? dose is 10 mg/L, and the remaining O2 after equilibrium is 3.14 x 10*8 mg/L.
The fraction of the applied CI2 dose remaining is therefore:
Fraction of CI2 remaining = ^ ^iq^~ - 3-14 x 10'9
CI2 releases to water = 100,000 lb x 3.14 x 10-9 = 0.0003 lb
Similar calculations can be performed for other pH levels:
pH
Ch usage, lb
[H+l
CI? equilibrium
concentranon, mg/L
Ch release, lb
8
100,000
1 x 10*8
3.14 x 10-8
0.0003
6
100,000
1 x 10-*
3.14 x 10-6
0.03
4
100,000
1 x 1(H
3.14 x 104
3
ACIDS
Mineral acids are used in a variety of processes in the food industry. Typically, these
acids are disposed of via wastewater. Section 313 reporting rules consider a waste stream with a
pH between 6 and 9 to be fully neutralized. Therefore, the concentration of any Section 313 acid
would be zero whenever the wastestream pH exceeds 6. For most wastewater discharges,
however, there are periods during the year when the pH dips below this level. If these pH
excursions can be attributed to a Section 313 acid, release estimates must be made using pH
monitoring data. The following equation can be applied to each excursion event.
Acid release, lb = [1 x 1Q(-ph) x Y] x (effluent flow rate, gallmin) x (duration of
excursion, min)
Where: Y = 0.82 lb HiSOjgal (sulfuric acid)
= 030 lb HCUgal (hydrochloric acid)
= 0J3 lb HNOjIgal (nitric acid)
= 0.32 lb HjPOdgal (phosphoric acid)
Total releases for the year are calculated by summing the releases from each event.
Calculation of releases using this equation can be illustrated with the following
assumptions for hydrochloric acid. Process wastewater and stormwater runoff are centrally
collected, neutralized, and discharged to city sewers. The wastewater discharge is continuously
monitored for pH. Four acidic pH excursions occurred during the year.
Average flow
Duration,
Event
PH
rate, ?pm
minutes
1
1.5
106
10
2
2.8
90
30
3
3.9
125
5
4
5.5
100
300
B-6
-------
The acid release equation is applied separately for each excursion event. For example, for Event
1:
Acid release, lb = [(] x 10'lJ) (030 lb HCUgal)] (106 gpm) (10 min) = lOlbHCl
The following results can be calculated in this manner for the four events:
Event
HQ release, lb
1
10
2
1.3
3
0.02
4
0.03
Total discharges of HC1 to POTW for the four events are thus 11.35 pounds, which can be
reported on Form R as 11 pounds.
B-7
------- |