ZumMOL r
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Metal Finishing Guidance Manual:
A Practical Guide to Environmental Compliance and
Continuous Improvement
U.S. Environmental Protection Agency
Metal Finishing Suppliers Association
National Association of Metal Finishers
American Electroplaters and Surface Finishers Society
December 1996
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Table of Contents
Introduction
Air Emissions
Wastewater Discharges
Stormwater Discharges and
Oil Spill Prevention
Toxic Chemical Reporting
Emergency Planning and
Notification
Toxic Substances Control
Pollution Prevention
Environmental Management
Systems
Environmental Cost
Accounting
Superfund and Contaminated
Properties Mgmt.
15
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Table of Contents
Page
Acknowledgments ix
Limitations x
Regulatory Compliance Calendar xi
Part I—Environmental Regulations and Compliance
Chapter 1. Introduction
1.1 Background 1 -1
1.2 The Metal Finishing Industry 1-1
1.3 Purpose of This Manual 1-2
1.4 How the Manual Is Organized 1-3
Chapter 2. Air Emissions
2.1 Federal Requirements 2-2
2.1.1 What Agency Regulates Air Quality in My Area? 2-3
2.1.2 What Are "Criteria Pollutants"? 2-4
2.1.3 What Are "Attainment" and "Nonattainment" Areas? 2-4
2.1.3.1 What Happens if My Firm Is Located in a Nonattainment Area? 2-5
2.1.4 Does My Facility Emit Hazardous Air Pollutants (Air Toxics)? 2-5
2.1.5 What Is a Construction Permit? 2-6
2.1.5.1 What Is a PSD Permit? 2-7
2.1.5.2 What Is a Nonattainment New Source Review Permit? 2-8
2.1.5.3 What Is a New Source Performance Standard? 2-10
2.1.5.4 How Do I Obtain a Construction Permit? 2-11
2.1.5.5 What Is a Minor Construction Permit? 2-11
2.1.6 What Is an Operating Permit? 2-11
2.1.6.1 Do I Need an Operating Permit? 2-12
2.1.6.2 When Must ! Apply for an Operating Permit? 2-14
2.1.6.3 How Do I Obtain an Operating Permit? 2-15
2.1.6.4 What Information Is Required in the Permit Application? 2-15
2.1.6.5 What Permit Fees Must I Pay? 2-17
2.1.6.6 What Is a Synthetic Minor and How Can it Help Me Avoid Title V? 2-17
2.1.6.7 If I Don't Need an Operating Permit, Are There Other Requirements I Must Meet? . . 2-18
2.1.7 What Requirements Must I Follow Regarding Accidental Releases? 2-18
2.1.8 How Do Requirements for Stratospheric Ozone Protection Affect My Facility? 2-21
2.1.8.1 What Substitutes Can I Use for Ozone-Depleting Substances? 2-21
2.1.8.2 What Are the Requirements for Using Ozone-Depleting Substances? 2-23
2.2 State Requirements 2-24
2.3 For Further Information 2-24
Append
Append
Append
Append
Append
Append
Append
x 2-A Compliance Calendar for Federal Clean Air Act Requirements
x 2-B Glossary
x 2-C State and Territorial Air Pollution Control Agencies
x 2-D Clean Air Requirements Worksheet and Air Emission's Worksheet
x 2-E List of 189 Hazardous Air Pollutants by CAS Number
x 2-F Summaries of Three NESHAP Standards
x 2-G List of Regulated Substances and Thresholds for Accidental Release Prevention
Chapter 3. Wastewater Discharges
3.1 Federal Requirements 3-3
3.1.1 What Is the Clean Water Act? 3-3
3.1.2 What Clean Water Act Programs Affect Metal Finishers? 3-3
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3.1.3 Which Wastewater Discharge Requirements Apply to My Operation? 3-4
3.1.4 What Are the Wastewater Discharge Requirements for Indirect Dischargers? 3-5
3.1.4.1 Pretreatment Standards 3-5
3.1.4.2 Monitoring and Reporting Requirements 3-8
3.1.4.3 Renewal of the Control Authority Permit 3-10
3.1.5 What Are the Wastewater Discharge Requirements for Direct Dischargers? 3-10
3.1.5.1 Obtaining a Permit To Discharge 3-10
3.1.5.2 Monitoring and Reporting Requirements 3-12
3.1.5.3 Renewal of the NPDES Permit 3-14
3.1.6 How Pollution Prevention Can Reduce the Regulatory Burden for Wastewater
Discharge 3-14
3.2 State Programs 3-16
3.3 Where To Go for Further Information 3-17
Appendix 3-A Compliance Calendar for Federal Wastewater Discharge Requirements
Appendix 3-B Contact Information for NPDES-Approved States
Appendix 3-C Contact Information for EPA Regional Pretreatment Coordinators
Appendix 3-D What Do Control Authorities Consider When They Set Limits for Indirect Dischargers?
Appendix 3-E Effluent Limits Established Under 40 CFR Part 433 (Metal Finishing)
Appendix 3-F Effluent Limits Established Under 40 CFR Part 413 (Electroplating)
Appendix 3-G Sample NPDES Permits
Chapter 4. Stormwater Discharges and Oil Spill Prevention
4.1 Federal Requirements 4-3
4.1.1 What Storm Water Management Requirements Apply to Metal Finishers? 4-4
4.1.1.1 Does My Metal Finishing Operation Need a Permit for Storm Water Discharge? 4-4
4.1.1.2 What Types of Discharges Will My Storm Water Permit Cover? 4-6
4.1.1.3 What Type of Permit Should I Apply For? 4-6
4.1.1.4 What Is the Deadline for Permit Application? 4-8
4.1.1.5 Who Issues Storm Water Permits? 4-8
4.1.1.6 How Can I Register for a General Permit? 4-10
4.1.2 What Basic Requirements May Be Included in a General Storm Water Permit? 4-11
4.1.3 General Permit Requirements for Monitoring 4-12
4.1.4 General Permit Requirements for Preparing and Implementing Storm Water
Pollution Prevention Plans 4-13
4.1.4.1 Phase 1: Establish a Pollution Prevention Team 4-14
4.1.4.2 Phase 2: Assess the Site 4-16
4.1.4.3 Phase 3: Select Best Management Practices and Design the Plan 4-20
4.1.4.4 Phase 4: Implement the Plan 4-23
4.1.4.5 Phase 5: Conduct an Annual Evaluation 4-24
4.1.4.6 Required Signatures and Reviews 4-24
4.1.4.7 Recordkeeping 4-25
4.1.4.8 Plan Revisions 4-25
4.1.4.9 Deadlines for Developing and Implementing the Plan 4-25
4.1.5 What Oil Spill Prevention Requirements Apply to Metal Finishers? 4-26
4.2 Where To Go for Further Information 4-30
4.2.1 Storm Water Discharge 4-30
4.2.2 Oil Spill Prevention 4-31
Appendix 4-A Compliance Calendar for Federal Storm Water Discharge and Oil Spill Prevention
Requirements
Appendix 4-B List of Storm Water Industrial Activity Categories
Appendix 4-C Federal and State Storm Water Contacts
Appendix 4-D Section 3 I 3 Water Priority Chemicals
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Chapter 5. Hazardous Waste
5.1 Federal Requirements (RCRA) 5-4
5.1.1 What Is RCRA? 5-4
5.1.2 How Do These Rules Apply To Me? 5-4
5.1.2.1 What Other Classifications Might Apply to Me? 5-5
5.1.2.2 What Other Exemptions Might Apply to Me? 5-6
5.1.3 How Do I Determine if My Waste Is Hazardous? 5-6
5.1.3.1 What Are "Listed" Wastes and Hazard Codes? 5-8
5.1.3.2 How Do I Manage Mixtures and Spills of Hazardous Waste? 5-9
5.1.3.3 What Must I Do if I Generate Hazardous Waste? 5-10
5.1.4 How Should I Store Hazardous Waste? 5-11
5.1.4.1 Note to CESQGs 5-11
5.1.4.2 Hazardous Waste Accumulation at a Point of Generation (Applicable to
SQGs and LQGs) 5-11
5.1.4.3 Onsite Container Storage of Hazardous Waste (Applicable to SQGs and LQGs) 5-12
5.1.4.4 Onsite Tank Storage of Hazardous Waste (Applicable to SQGs and LQGs) 5-13
5.1.4.5 Onsite Tank Storage of Hazardous Waste (Applicable to SQGs Only) 5-14
5.1.4.6 Onsite Tank Storage of Hazardous Waste (Applicable to LQGs Only) 5-15
5.1.5 How Should I Prevent and Respond to Hazardous Waste Emergencies? . 5-19
5.1.5.1 Note to CESQGs 5-19
5.1.5.2 Preparedness Regulations Applicable to Both SQGs and LQGs 5-19
5.1.5.3 Preparedness Regulations Applicable to SQGs Only 5-21
5.1.5.4 Preparedness Regulations Applicable to LQGs Only 5-22
5.1.6 How Should I Transport Hazardous Waste? 5-26
5.1.6.1 Note to CESQGs 5-26
5.1.6.2 Requirements Applicable to Both SQGs and LQGs 5-27
5.1.6.3 Requirements'Applicable to SQGs Only 5-31
5.1.7 What Records Do I Need To Keep? 5-32
5.1.7.1 Note to CESQGs 5-32
5.1.7.2 Requirements Applicable to Both LQGs and SQGs 5-32
5.1.7.3 Requnemenrs Applicable to SQGs Only 5-33
5.1.7.4 Requirements Applicable to LQGs Only 5-33
5.1.8 Closure Requirements (Applicable to LQGs Only) 5-34
5.2 State Requirements 5-35
5.3 Where To Go for More Information 5-36
Appendix 5-A Compliance Calendar for RCRA Hazardous Waste Requirements
Appendix 5-B Glossary of Terms
Appendix 5-C Hazardous Waste Identification Procedures
Appendix 5-D Listed Hazardous Wastes
Appendix 5-E Regulatory Levels for Toxicity Characteristic Leaching Procedure
Appendix 5-F Requirements Related to Wastes Containing Economically Recoverable Quantities of
Precious Metals
Appendix 5-G Criteria Used To Consider a Container Empty
Appendix 5-H Toxicity Characteristic Leaching Procedure
Chapter 6. Underground Storage Tanks
6.1 Federal Requirements (RCRA Subtitle I) 6-3
6.1.1 What Do the Federal UST Requirements Cover? 6-3
6.1.2 Who Is the Implementing Agency? 6-6
6.1.3 Do the Federal Regulations Apply to USTs at My Metal Finishing Operation? 6-7
6.1.4 What Are the Performance Requirements for New USTs? 6-9
6.1.4.1 Protecting Tanks and Piping From Corrosion 6-11
6.1.4.2 Installing UST Systems the Right Way 6-11
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6.1.4.3 Preventing Spills and Overfills 6-12
6.1.5 What Are the Performance Requirements for Existing USTs? 6-13
6.1.6 What Operating Requirements Apply to USTs at My Facility? 6-14
6.1.6.1 Preventing Spills and Overfills 6-14
6.1.6.2 Corrosion Protection 6-14
6.1.6.3 Compatibility 6-15
6.1.7 What Must I Do To Detect Leaks? 6-15
6.1.7.1 Detecting Leaks Frim New Tanks 6-15
6.1.7.2 Detecting Leaks From Piping in New USTs 6-17
6,1.7.2 Additional Requirements for New Chemical USTs 6-18
6.1.7.4 What About Existing USTs? 6-19
6.1.7.5 What Leak Detection Records Must I Keep? 6-20
6.1.8 What Should I Do if I Think My Tank Is Leaking? 6-20
6.1.8.1 Warnings From Equipment 6-21
6.1.8.2 Warnings in the Environment 6-21
6.1.8.3 Conducting a Site Check 6-22
6.1.9 What Should I Do if I Find a Leak or if a Spill or Overflow Occurs? 6-22
6.1.9.1 Initial Response 6-22
6.1.9.2 Initial Abatement 6-23
6.1.9.3 Corrective Action Plan 6-24
6.1.9.4 Long-Term Abatement 6-25
6.1.10 Can Leaking Tanks and Pipes Be Repaired? 6-25
6.1.10.1 Tanks 6-25
6.1.10.2 Pipes 6-26
6.1.11 How Do I Close an UST? 6-26
6.1.11.1 Temporary Closure 6-26
6.1.11.2 Permanent Closure 6-27
6.1.11.3 Changing From a Regulated Substance to a Nonregulated Substance 6-28
6.1.12 What Are My Financial Responsibilities if I Own or Operate a Petroleum UST? 6-28
6.2 State Requirements 6-29
6.3 Where To Go for More Information 6-29
Appendix 6-A Compliance Calendar for the Federal UST Requirements
Appendix 6-B CERCLA Hazardous Substances Typically Used by Metal Finishers
Appendix 6-C Guides to Compliance With Federal UST Regulations
Chapter 7. Toxic Chemical Reporting
7.1 Federal Requirements (EPCRA) 7-3
7.1.1 MSDS Chemical Reporting (EPCRA Section 311) 7-4
7.1.1.1 What Requirements Must I Follow? 7-4
7.1.1.2 To Whom Must 1 Report? 7-4
7.1.1.3 What Are the Reporting Thresholds? 7-5
7.1.1.4 Are There Exemptions From This Requirement? 7-5
7.1.1.5 How Do I Calculate the Total Quantity of a Substance Present at My Facility? 7-6
7.1.16 How Do I Meet the MSDS Reporting Requirement for a Mixture or Solution? 7-6
7.1.17 How Do I Report MSDS Chemicals? 7-8
7.1.18 When Should 1 Report MSDS Chemicals? 7-10
7.1.2 Annual Inventory Reporting (EPCRA Section 312) 7-10
7.1.2.1 What Must I Report? 7-10
7.1.2.2 What Should I Include on My Inventory? 7-10
7.1.2.3 How Do I Report These Chemicals? 7-11
7.1.3 Annual Release Reporting (EPCRA Section 3 1 3) 7-12
7.1.3.1 What Must I Report? 7-12
7.1.3.2 Which Chemicals Must I Report? 7-12
7.1.3.3 What Information Must I Include in TRI Reporting? 7-12
7.1.3.4 How Do I Submit TRI Information? 7-13
7.1.3.5 Do I Have To Keep Records? 7-15
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7.1.3.6 How Can I Obtain Protection for Trade Secrets? 7-16
7.2 State Requirements 7-16
7.3 Where To Go for More Information 7-17
7.4 References 7-17
Append
Append
Append
Append
Append
Append
Append
7-A Compliance Calendar for EPCRA Toxic Chemical Reporting Requirements
7-B Hazard Categories
7-C Example Tier Two Form
7-D TRI Chemicals Typically Used in the Metal Finishing Industry
7-E Worksheet for TRI Reporting
7-F Guidance on Estimating Releases From Electroplating Operations
7-G Complete List of TRI Chemicals
Chapter 8. Emergency Planning and Notification
8.1 Federal Requirements (EPCRA)
8.1.1 What Is EPCRA?
8.1.2 Requirements for Emergency Planning
8.1.2.1 What Agencies Are Responsible for Emergency Planning?
8.1.2.2 What Is an "Extremely Hazardous Substance?"
8.1.2.3 What Is a "Threshold Planning Quantity?"
8.1.2.4 What Actions Must I Take If My Facility Handles an Extremely Hazardous
Substance at or Above the TPQ?
8.1.3 Requirements for Emergency Notification
8.1.3.1
8.2
8.3
When Must I Report an Accidental Release (Leak or Spill) of a
Hazardous Substance?
What Is a Release?
What Is a Facility? 8
Which Chemicals Are Covered? 8
What Releases Do I Not Have to Report? 8
How Do I Report an Accidental Release? 8
State Requirements 8
Where To Go for More Information 8
8.1.3.2
8.1.3.3
8.1.3.4
8.1.3.5
8.1.3.6
8-3
8-3
8-4
8-4
8-5
8-5
8-6
8-9
8-9
8-9
-10
-10
-11
-11
12
13
Appendix 8-A Compliance Calendar for EPCRA Emergency Planning and Notification Reporting
Requirements
Appendix 8-B Worksheet for Emergency Planning and Notification
Appendix 8-C State Emergency Response Commissions
Appendix 8-D Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
Appendix 8-E Additional Chemicals Typically Used by Metal Finishers That Are Subject to Emergency
Notification Requirements
Appendix 8-F Sample Form for Recording Information To Be Reported in the Event of a Release of a
Hazardous Substance
Chapter 9. Toxic Substances Control
9.1 Federal Programs (TSCA) 9-3
9.1.1 What Is TSCA? 9-3
9.1.2 Information Gathering Requirements 9-3
9.1.3 Requirements Related to Regulatory Controls 9-3
9.1.3.1 What PCB Regulations Might Apply to Me? 9-5
9.1.3.1 What Asbestos Regulations Might Apply to Me? 9-9
9.1.3.1 What Lead Regulations Might Apply to Me? 9-10
9.1.3.1 What Metalworking Fluid Regulations Might Apply to Me? 9-10
9.2 Where To Go for More Information 9-1 I
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9.3 References 9-12
Appendix 9-A Compliance Calendar for Toxic Substances Control Requirements
Appendix 9-B EPA Regional Information Sources
Appendix 9-C PCB Disposal Companies Commercially Permitted
Part II—Pollution Prevention and Environmental Management
Chapter 10. Pollution Prevention
10.1 Why is Pollution Prevention Important? 10-2
10.1.1 Cost Savings 10-3
10.1.2 Meeting^Reducing Compliance Requirements 10-4
10.1.3 Productivity/Quality Improvements 10-4
10.1.4 Employee/Community Risk Reduction 10-4
10.1.5 Reduced Future Liabilities 10-5
10.2 What is Pollution Prevention? 10-5
10.3 How Can I Do Pollution Prevention? 10-6
10.3.1 Obtain Management Commitment 10-7
10.3.2 Establish Employee Involvement 10-9
10.3.3 Define and Communicate Goals and Objectives 10-10
10.3.4 Determine and Prioritize Waste Streams 10-10
10.3.5 Identify and Evaluate Options 10-14
10.3.6 Implement Selected Options 10-18
10.3.7 Measure and Communicate the Results 10-18
10.3.8 Keep the Efforts Going 10-19
10.4 Where Can I Get More Information? 10-20
10.4.1 State Pollution Prevention Programs 10-20
10.4.2 Information Clearinghouses and Centers 10-33
10.4.3 Internet World Wide Web Home Pages 10-34
10.4.4 Pollution Prevention Training Course 10-34
10.4.5 References 10-35
Appendix 10-A Best Management Practices for Pollution Prevention in the Metal Finishing Industry
Appendix 10-B State Pollution Prevention Contacts
Chapter 11. Environmental Management Systems
11.1 What Is an Environmental Management System? 11-3
11.2 How Does an EMS Differ From an Audit? 11-3
11.3 What's Involved in Developing an EMS? 11-4
11.4 Why Implement an EMS? 11-5
11.5 Getting Started 11-7
11.5.1 Conduct a Baseline Inventory 11-7
11.5.2 Develop a Policy 11-9
11.5.3 Define Your Goals: Where Do You Want to Go? 11-11
11.6 Top Management Support—A Key to Success 11-14
11.7 A New Way of Thinking About Environmental Management 11-15
11.8 Spreading the Word—A Strategy for Training and Communication 11-17
11.9 Tracking Progress 11-17
11.10 Striving for Continuous Improvement 11-19
11.11 Environmental Management Standards 11-21
1 I.I I.I What Is ISO 14000? 11-21
I 1.1 1.2 ISO I 4001 Specifications for EMSs II -22
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I 1.11.3 How Important Is ISO 14000 to Metal Finishers? I 1-24
11.12 Where to Go for Further Information About Environmental Management
Systems and ISO 14000 11-26
Appendix 1 I-A Sample EMS From the Metal Finishing Operations
Appendix 11-B Current Status of ISO 14000-Series Standards
Chapter 12. Environmental Cost Accounting
12.1 Limitations of Conventional Accounting 12-1
12.2 What is Environmental Cost Accounting? 12-2
12.3 How Can ECA Benefit Metal Finishing Operations? 12-3
12.4 What Are "Environmental Costs"? 12-4
12.5 What Can Metal Finishers Use ECA For? 12-9
12.6 What's Involved in ECA? 12-10
12.7 Who Should Be Involved? 12-10
12.8 Information Sources 12-11
12.9 Key Steps in ECA 12-11
12.9.1 Determining the Scale 12-12
12.9.2 Defining the Goals 12-12
12.9.3 Determining the Scope 12-12
12.9.4 Developing a Process Flow Diagram 12-13
12.9.5 Identifying the Environmental Costs 12r 14
12.9.6 Quantifying the Environmental Costs 12-17
12.9.6.1 How Do I Calculate the Costs? 12-18
12.9.6.2 What if One Activity Applies to Several Chemicals or Wastes? 12-18
12.9.6.3 What if I Can't Calculate the Costs Exactly? 12-19
12.9.6.4 Calculating Total Costs 12-20
12.9.7 Accounting for the Time Value of Money 12-20
12.10 Implementing the Results and Institutionalizing ECA 12-23
12.11 Where To Go for Further Information About ECA 12-24
12.11.1 Clearinghouse and Hotlines 12-24
12.11.2 Software Programs 12-25
12.11.3 ECA Guidance Document for the Metal Finishing Industry 12-26
12.12 References 12-26
Appendix 12-A Financial Analysis of Pollution Prevention Projects
Appendix 12-B Environmental Accounting Resource List
Chapter 13. Superfund and Contaminated Properties Management
13.1 Introduction 13-3
13.2 Liabilities and Requirements 13-4
13.2.1 Federal Laws 13-4
13.2.1.1 RCRA 13-4
13.2.1.2 Superfund 13-6
13.2.2 State Laws 13-8
13.3 Sources of Contamination: How Does a Property Get Polluted? 13-8
13.3.1 Historic Land Use and Disposal Practices 13-9
13.3.2 Accidental Spills 13-9
13.3.3 Releases 13-10
13.3.4 Underground Storage Tanks 13-10
13.4 Investigating Contamination 13-11
13.4.1 Conducting a Site Investigation 13-11
13.4.2 Factors Affecting the Extent of Contamination 13-12
13.4.2.1 Soil and Ground-Water Contamination 13-12
13.4.2.2 Surface Water Contamination 13-13
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13.5 Remediation Standards (How Clean Is Clean?) 13-13
13.5.1 Federal Standards and Guidelines 13-14
13.5.2 Cleanup Procedures 13-16
13.5.3 State Cleanup Criteria 13-17
13.6 Remediation Technologies (What Are Common Cleanup Options?) 13-19
13.6.1 Soil Remediation 13-19
13.6.2 Ground-Water Remediation 13-20
13.6.2.1 Petroleum Products and VOCs 13-21
13.6.2.2 Metals 13-22
13.7 Facility Process Line Decontamination and Decommissioning 13-23
13.7.1 Waste Management Issues 13-24
13.7.2 Wastewater Management Issues 13-24
13.7.3 Health and Safety Issues 13-25
13.7.3.1 Chemical Hazards 13-25
13.7.3.2 Physical Hazards 13-26
13.7.4 How Clean Should Decontaminated and Decommissioned Equipment
and Facilities Be? 13-27
13.8 Incentives and Mechanisms for Voluntary Cleanups 13-27
13.8.1 Federal Initiatives and Funding 13-28
13.8.1.1 Progress on Protecting Purchasers From Liability 13-28
13.8.1.2 RCRA Corrective Action 13-28
13.8.1.3 Brownfields Economic Redevelopment Initiative 13-29
13.8.2 State Initiatives 13-29
13.8.3 Private Sector Financing 13-30
13.9 Using Consultants and Attorneys 13-31
13.10 State Requirements 13-33
13.11 Where To Go for More Information About Contaminated Properties 13-34
Appendix 13-A Compliance Calendar for Federal Superfund Requirements
Appendix 13-B OSHA Consultation Project Directory
Appendix 13-C EPA RCRA Contacts
Appendix 13-D EPA Brownfields Coordinators
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Acknowledgments and Limitations
Acknowledgments
The Metal Finishing Guidance Manual is a product of the Common Sense Initiative,
Metal Finishing Sector. It grew from the belief that enhanced access to information
was needed to improve environmental performance. The Manual was prepared as
a result of the generous support and contributions of the U.S. Environmental
Protection Agency's Office of Policy, Planning and Evaluation; the Metal Finishing
Suppliers' Association (MFSA); the National Association of Metal Finishers
(NAMF); and the American Electroplaters and Surface Finishers Society (AESF).
The project was partially funded by grant moneys provided by EPA's Office of
Policy, Planning and Evaluation, and EPA-New England (Assistance ID No.
T991721-01-0). Financial support was also generously given by the following
companies:
Aldoa Co., Detroit, MI
Benchmark Products Inc., Indianapolis, IN
Enthone-OMI Inc., New Haven, CT
Electrochemical Products Inc., New Berlin, WI
Falconbridge Ltd., Toronto, Ont.
Heatbath Corp., Springfield, MA
Parkson Corp., Fort Lauderdale, FL
Serfilco Ltd., Northbrook, IL
Taskem Inc., Brooklyn Heights, OH
Technical, editorial, and administrative support was provided by the following
dedicated individuals:
Frank Altmayer, Scientific Control Labs
Robert Benson, U.S. EPA, OPPE
Andrew Comai, United Automobile Workers
John Cullen, Masco Corporation
Dan Maki, Marsh Plating Corp.
B. J. Mason, Mid-Atlantic Finishing
William Saas, Taskem, Inc.
Rebecca Spearot, Clayton Environmental
Jordan Spooner, U.S. EPA, OPPE
Brenda Whalen, Enthone-OMI Inc. (Project Coordinator)
The Manual was written and compiled by Eastern Research Group, Inc. (ERG); with
assistance by GZA GeoEnvironmental, Inc. and Kerr & Associates.
December 1996
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Acknowledgments and Limitations
The Manual was no small undertaking. The talents, time and financial support by
all these remarkable individuals and organizations are truly appreciated.
Limitations
The information and materials contained in this manual are provided as an
educational resource, and not as legal advice. We have made every effort to make
the materials current and accurate as of December 1996. However, environmental
regulations may vary form locale to locale, and are always evolving. Neither the
sponsors nor authors can make any warranty with respect to the accuracy,
completeness or utility of the manual's content. Users of this manual may desire
to consult with qualified professionals or appropriate regulatory authorities.
Mention of trade names, commercial products, professional firms, or organizations
does not constitute endorsement or recommendations for use by the sponsors or
authors of the manual.
December 1996
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Regulatory Compliance Calendar
Regulatory Compliance Calendar
The Regulatory Compliance Calendar that follows lists all of the action items
required by the federal government that are discussed in this Manual. Three types
of action items are included:
¦ Milestone Events. Items that must be completed on or by a specific date in
the calendar year.
¦ Regular or Periodic Events. These items are required to be performed on
a regular or periodic basis (e.g., once a week, twice a year), as described in
the calendar and the individual chapters of the Manual.
¦ Other Events. These items may have to be completed depending on your
circumstances. For the most part, they are requirements that are triggered
when specific things happen (e.g., you apply for a permit to expand your
facility).
For each action item, the Calendar specifies the due date, frequency, item required,
regulation requiring the action, and provides a brief description of the requirement.
It indicates who should receive a copy of any documents, reports, forms, plans, etc.
completed as part of the requirement, and identifies the page(s) in the Manual
where the requirements are discussed.
In addition to this master version of the Regulatory Compliance Calendar, each
Chapter of the Manual contains a chapter-specific version of the calendar. These
can be found at the end of each chapter.
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Milestone Events
January 1, 1996
Substitute
Significant
New
Alternatives
Program
Use only approved substitutes for ozone-
depleting substances (e.g., 1,1,1-TCE and CFCs)
2-21 to 2-22
March 1 (Annual)
Inventory of hazardous
chemicals (Tier I or II
form)
EPCRA 312
Submit inventory of hazardous materials present
at facility during previous year
LEPC, SERC, local
fire department
7-10
March 1 (Annual)
Submit export report
RCRA
Submit a hazardous waste export report
Regional EPA
office
5-30
By March 1 of every
even-numbered year
(if you are an LQG)
Submit biennial report
RCRA
Prepare report describing your hazardous waste
management program in detail.
Regional EPA
office
5-33 to 5-34
July 1 (Annual)
Toxics Release Inventory
(Form R) report
EPCRA 313
Calculate and report releases of toxic chemicals
from the facility for the previous calendar year.
SERC, EPCRA
Reporting Center
7-12
By December 22,
1998
Upgrade USTs
RCRA
Subtitle I
Fully upgrade all USTs to meet corrosion
protection and spill/overfill requirements.
Keep records on
file at facility
6-13 to 6-15
Upgrade USTs
RCRA
Subtitle I
Upgrade USTs containing regulated chemicals to
meet the special leak detection and containment
requirements for chemical USTs
Keep records on
file at facility
6-13 to 6-15
Close USTs
RCRA
Subtitle I
Permanently close any USTs that you don't
upgrade.
Keep records on
file at facility
6-13 to 6-15
To be determined
Risk management plan
CAA Risk
Management
Program
Rule
Prepare risk management plan to prevent
accidental releases of listed substances
Air quality agency
2-18 to 2-21
By year 2000
Initiate voluntary
stabilization
RCRA
Beginning in 2000, EPA will pursue enforcement
action against any facility on RCRA High
Priority Corrective Action List that has not
under voluntary stabilization
13-29
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Regular or Periodic Events
At least twice a year
(indirect discharger)
Report monitoring data
CWA
Record and report monitoring data for your
wastewater discharge
Control Authority
3-8 to 3-10
If your facility is
covered by the CWA
oil spill prevention
requirements
¦ At least once
every 3 years
SPCC plan
CWA 3110)
Review and evaluate the SPCC plan.
Maintain a copy at
the site
4-27
Before commencing
discharge:
CWA
Indirect discharger. Contact your Control
Authority to determine applicable requirements.
Comply with all applicable requirements.
Control Authority
3-2
CWA
Direct discharger: Contact your permitting
authority to obtain a permit. Comply with permit
conditions
Permitting
Authority
3-2
IT-your facility is
covered by the CWA
oil spill prevention
requirements
¦ Within 6 months
of commencing
operations
SPCC plan
CWA 3110)
Prepare an SPCC plan and have it reviewed by a
registered professional engineer
Maintain a copy at
the site
4-27 to 4-29
¦ Whenever there is
a change at your
facility that
affects the
potential for oil
discharge
SPCC plan
CWA 31 lQ)
Amend the SPCC plan
Maintain a copy at
the site
4-27 to 4-29
¦ On a regular basis
Inspection
CWA 3110)
Inspect condition of aboveground tanks
On file at the
facility
4-27 to 4-29
-------
Regulatory Compliance and Environmental Management Calendar
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Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
¦ On a regular basis
Test
CWA 311 (j)
Test liquid level sensing devices in tanks
On file at the
facility
4-27 to 4-29
¦ On a regular basis
Record
CWA 31 l(j)
Document employee training
On file at the
facility
4-27 to 4-29
¦ On a regular basis
Monitor status of proposed changes to the Oil
Pollution Act that will strengthen the SPCC
requirements (proposed October 22, 1991)
4-27
At least once a week
Inspection
Inspect all hazardous waste storage areas to
check for leaks or other problems.
On file at the
facility
5-13
Once a year
Training
RCRA
Each employee must review this training
Certification on file
at the facility
5-22
Every 60 days
Inspection
RCRA
Subtitle 1
Inspect impressed current cathodic protection
systems to ensure equipment is running properly.
Keep records of last
3 inspections on file
at facility
6-14
Of/ier Events
Prior to beginning
construction of new
facility or major
modification to
existing facility
Permit
CAAA/PSD
Obtain a construction permit (PSD,
Nonattainment New Source Review, or Minor
Construction Permit)
Air quality agency
2-6 to 2-7
2 to 12 months after
state permit program
is approved by EPA
Permit
CAAA/Title
V
Obtain Title V permit
Air quality agency
2-14 to 2-15
Within 1 year of
commencing
operations
SPCC plan
CWA 311 (j)
Fully implement the SPCC plan
Maintain a copy at
the site
4-27 to 4-29
-------
X
<
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Within 60 days of a
spill of more than
1,000 gallons or
more of oil onto
navigable waters or
adjoining shorelines,
or 2 discharges of oil
in harmful quantities
within a 12-month
period
Report
CWA 31 l(j)
Submit information about the spill, including
corrective actions of countermeasures taken.
Amend SPCC plan to prevent future spills.
EPA and the State
agency responsible
for water pollution.
4-27 to 4-29
Prior to discharging
accumulated
stormwater
Inspection
CWA 31 l(j)
Ensure water conforms to applicable water
quality standards
On file at the
facility
4-27 to 4-29
48 hours before
commencing storm
water discharge
Permit
1990 Storm
Water
Regulations
Contact your permitting authority to obtain a
permit
Permitting authority
4-26
Within 90 days of
generation (if you
are a LQG)
RCRA
Remove waste from site
5-5
Within 180 days of
generation (if you
are a SQG and your
waste is being
shipped fewer than
200 miles)
Within 270 days of
generation (if you
are a SQG and your
waste is being
shipped more than
200 miles)
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
As soon as possible
after your firm
begins generating
hazardous waste
Emergency response plan
RCRA
Develop a plan to respond effectively to
emergencies caused by your hazardous waste.
5-23 to 5-24
As soon as possible
after you facility
begins generating
hazardous waste
Information about
hazardous waste
generated at the facility
RCRA
Provide information about your hazardous waste.
Local emergency
response authorities
5-20
As soon as possible
following a
reportable hazardous
waste release
Notification
RCRA
Notify officials
National Response
Center (NRC) and
local emergency
response officials.
5-21
Within 15 days of
any emergency
(if you are an LQG)
Report
RCRA
Send a copy of all documentation relating to the
emergency
Regional office of
the EPA.
5-25 to 5-26
As soon as possible
following a
reportable hazardous
waste release
Gather information
RCRA
Investigate the extent and cause of the release.
5-24 to 5-26
As soon as possible
or within 24 hours of
discovering a leaking
underground storage
tank (if you are an
LQG)
Remove waste
RCRA
Remove all waste from the leaking tank or
container and transfer to a secure tank or
container.
5-17
Within 30 days of
discovering a leaking
underground storage
tank (if you are an
LQG)
Submit report
RCRA
Submit a report describing the leak.
Regional EPA
office
5-17 to 5-18
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Within 30 days of
bringing a new UST
into use
Notification letter
RCRA
Send notification letter certifying the UST meets
installation, corrosion protection, and leak
detection requirements
State Agency
6-11 to 6-12
Within 6 months of
installation and
every 3 years after
Testing
RCRA
Subtitle 1
Have any cathodic protection systems tested by a
qualified tester.
Keep records of last
2 tests on file at
facility
6-14
If there is a
suspected release:
¦ Immediately
Action
RCRA
Subtitle I
Take action to stop and contain a leak, spill, or
overflow
Keep records on
file at facility
6-22
¦ Within 24 hours
of discovering a
problem
Investigation
RCRA
Subtitle I
Investigate any warning signals from equipment.
Immediately repair or replace faulty equipment.
Keep records on
file at facility
6-23
¦ Within 24 hours
of discovering a
problem
Report
RCRA
Subtitle I
Report any unusual operating conditions not
caused by faulty equipment and any
environmental contamination
Implementing
agency
6-21
¦ Within 7 days of
discovering a
problem
Tightness test
RCRA
Subtitle I
Conduct a tightness test of your entire UST
system
Keep records on
file at facility
6-21
X
<
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg. 1
Requirement
Submit To
Page in
Manual
Immediately upon
discovery of a
release
Action
Notification
RCRA
Subtitle I
Take action to stop and contain the release
If the release is a CERCLA hazardous substance
Keep records on
file at facility
Immediately notify
the National
Response Center 1 -
800-424-8802 and
appropriate state
and local
authorities
6-22
6-23
Mitigation
Identify and mitigate fire, explosion, and vapor
hazards.
Keep records on
file at facility
6-23
Within 24 hours of
confirming a release
Report
Notification
RCRA
Subtitle I
RCRA
Subtitle I
Within 24 hours of confirming that a release has
occurred, report any damage found.
Notify your implementing agency about any
confirmed release except: petroleum
spills/overfills of 25 gallons or less;
spills/overfills of hazardous substances regulated
under CERCLA that are less than the reportable
quantity.
Implementing
agency.
Implementing
agency
6-23
6-23
As soon as
practicable after
discovery
RCRA
Subtitle 1
Investigate and clean up the site.
Remove free product to the maximum extent
practicable.
6-23
6-23 to 6-24
Assessment
Conduct a site assessment to determine
environmental impact.
6-24
Within 7 days of
discovering
contamination
Inspection
RCRA
Subtitle I
If you find environmental damage or if tightness
testing indicates a leak, investigate your UST site
for evidence of environmental damage.
6-21 to 6-22
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Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Within 20 days of
confirming a release
Report
RCRA
Subtitle I
Report your investigation and abatement progress
to your implementing agency.
6-24 to 6-25
Within 45 days of
confirming a release
Report
RCRA
Subtitle 1
Report your approach to and progress in free
product removal to your implementing agency.
6-24
Within 45 days of
confirming a release
Report
RCRA
Subtitle I
Report the site assessment results to your
implementing agency.
6-24
Within 30 days of
repairing a leaking
UST
Test
RCRA
Subtitle i
Verify UST repair success by conducting
tightness testing, having the tank internally
inspected, or monitoring the repaired portion of
the UST monthly.
6-25 to 6-26
Within 6 months of
repairing a leaking
UST
Test
RCRA
Subtitle I
If your UST system is cathodically protected, this
system must also be tested.
6-26
Within 12 months
Closure
RCRA
Subtitle I
Any UST that does not meet the requirements for
new or upgraded USTs must be closed within 12
months unless an extension is granted by the
implementing agcy.
1
6-26 to 6-27
At least 30 days
before beginning
closure
Notice
RCRA
Subtitle I
Notify your implementing agency about your
intent to permanently close your UST or convert
to storing a nonregulated substance.
~~ H
Implementing
agency
6-27 to 6-28
After notifying your
implementing
agency about your
intent to close and
before completing
closure
Assessment
RCRA
Subtitle 1
Conduct an excavation zone assessment to
determine if any releases from your tank
damaged the surrounding environment.
Keep records on
file at facility
6-27 to 6-28
X
X
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
If a listed chemical
becomes present at
the facility in an
amount that triggers
the reporting amount
within 3 months
MSDS or list ofMSDS
chemicals
EPCRA 311
Submit an MSDS or list ofMSDS chemicals
SERC, LEPC, and
local fire
department
7-10
If new information
becomes available
about chemicals...
within 3 months
Revised MSDS
EPCRA311
Submit revised MSDS
1
LEPC, SERC,
7-10
Within 60 days of
equaling or
exceeding the TPQ
for a listed chemical
Notification
EPCRA
If a listed "extremely hazardous" chemical
becomes present at or above the TPQ, notify the
SERC. Also notify the LEPC and provide the
LEPC with name of your facility coordinator.
You need only provide this notification for the
first chemical.
SERC, LEPC
8-8 to 8-9
Immediately after
release of a
hazardous substance
Notification
EPCRA
Notify the SERC, the LEPC (or local emergency
response), and the National Response Center 1-
800-424-8802. Use form in Appendix 11-F to
record information they will need.
SERC, LEPC, NRC
8-11 to 8-12
As soon as possible
after release of a
hazardous substance
Written report
EPCRA
Provide written report on the release.
SERC, LEPC
8-12
Following any
changes relevant to
emergency planning
Notification
EPCRA
Notify LEPC of any changes occurring at the
facility that may be relevant to emergency
planning
LEPC
8-9
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CHAPTER 1
Introduction
1.1 Background l-l
1.2 The Metal Finishing Industry I-I
1.3 Purpose of This Manual 1-2
1.4 How the Manual Is Organized I -3
1.1 Background
In 1994, the U.S. Environmental Protection Agency (U.S. EPA) created the
Common Sense Initiative (CSI) to review environmental regulations
affecting various industries, by industry sector. Work under the CSI
involves a collaboration of business, government, environmentalists, and
labor, all seeking opportunities to do things "Cleaner, Cheaper, Smarter."
EPA selected six industry sectors, including the metal finishing industry, for
participation in the first phase of the CSI. These six industries form a
sizable piece of the U.S. economy. They comprise over 11% of the U.S.
Gross Domestic Product (GDP) and employ nearly four million people.
They also accounted for 12.4% of the toxic releases reported by all U.S.
industry in 1992. This Manual is a product of the CSI for the Metal
Finishing Sector.
1.2 The Metal Finishing Industry
Without question, metal finishing is an integral part of the U.S.
manufacturing economy. Nearly all manufactured products undergo some
type of metal or surface finishing to impart either decorative or functional
qualities.
The metal finishing industry was selected to participate in CSI because it is
highly regulated and dominated by small- to medium-sized business. The
industry is comprised of some 3,000 U.S. job shops employing 61% of the
industry's 72,600 employees; more than 90% of all job shops employ fewer
than 50 persons. According to U.S. Commerce Department estimates, 1992
pollution abatement costs and expenditures for this industry total
approximately $134 million—over a fifth of their budget.
In recent years, ways have been sought to characterize the industry's
environmental performance. One such characterization, called "performance
tiers," appears apt at describing the job shop segment of the industry:
1 Job shops are independently owned businesses. Captive shops are metal finishing operations contained in larger
manufacturing facilities.
December 1996
1-1
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Introduction
Part I, Chapter 1
¦ Tier 1 firms are top performers. They are consistently in
compliance with regulatory requirements, and are the most
proactive in moving beyond baseline compliance.
¦ Tier 2 firms represent the largest industry segment. Their
primary environmental objective is to comply with existing
regulatory requirements. Some Tier 2 firms suffer occasional
performance lapses due to limited expertise or resources;
however, all desire to achieve routine compliance.
¦ Tier 3 firms typically include older, smaller metal finishing job
shops with limited resources to invest in new technology or
infrastructure improvements. The owner(s) of a Tier 3 firm may
desire to eventually sell or close the business, yet they are unable
to do so because of environmental and financial liabilities.
¦ Tier 4 firms include recalcitrant companies that are generally out
of compliance, yet escape regulatory agency attention.
1.3 Purpose of This Manual
The CSI process identified the need to provide alternative "tracks" for metal
finishing companies in the four environmental performance "tiers."
"Traditional track" companies seek to achieve and maintain 100%
compliance with all applicable federal, state, and local environmental
requirements. Typically Tier 2 companies, they are best served by
"customer-oriented" assistance in the form of tools, services, and programs
that meet critical industry needs and promote and enable compliance. When
this type of assistance is coupled with "flexible track" programs—which
inspire companies to go beyond compliance—for Tier 1 metal finishing
firms, the ultimate goal of improved overall environmental performance
within the industry can be achieved.
The Metal Finishing Guidance Manual is a comprehensive "customer-
oriented" assistance tool designed to meet this critical industry need. The
Manual provides a plain language tool for use by shop floor managers to
ensure continuing compliance with regulatory requirements. It encourages
continual improvement in environmental performance and promotes pollution
prevention and systematic approaches to environmental management.
The Manual is intended to be an evergreen document. It will be updated
through an effort coordinated by the National Metal Finishing Resource
Center (NMFRC). Its contents can also be enhanced by Internet-accessible
information from the NMFRC.
December 1996
1-2
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Introduction
Part I, Chapter 1
The Manual is not an "industry only" document. For example, the Manual's
concise summary of the regulatory issues impacting the metal finishing
industry in all media can help to broaden the perspective of experienced
public officials, who typically get locked into specific media disciplines (i.e.,
air, water, waste). The Manual also introduces regulators and technical
assistance providers to the "tiered" concept—specifically that all companies,
metal finishing or not, do not have equal ability to administer environmental
programs and, therefore, they perform at different levels. With this
understanding, enforcement, technical, and financial assistance programs can
be appropriately targeted.
Finally, the Manual was written so that the layperson can understand its
contents. Therefore members of local communities, employees, and
environmental groups can learn much about the industry and the
environmental regulations that affect it.
1.4 How the Manual Is Organized
The Manual is organized into three sections:
¦ Compliance Calendar
¦ Part I—Environmental Regulations and Compliance
® Part II—Pollution Prevention and Environmental Management
Compliance Management Calendar
This section provides a 12-month regulatory calendar listing the action items
required by a specific calendar date. These items are described in detail in
the body of the Manual. Additionally, a section of the calendar details items
that must be completed regularly but are not tied to a specific calendar date
or conditional items. The Calendar specifies the due date, frequency, item
required, regulation requiring the action, and provides a brief description of
the requirement, who gets a copy, and the page in the Manual detailing the
requirement.
Part I: Environmental Regulations and Compliance
This section of the manual provides a comprehensive review of federal and
state regulations affecting metal finishers. Regulations described in each
chapter are organized according to a mandated regulatory activity (e.g., water
discharges, emergency planning). Each chapter is introduced by a section on
December 1996
1-3
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Introduction
Part I, Chapter 1
"How to Use This Chapter," providing the reader with a glimpse of what will
be found on the pages that follow.
Federal regulations and requirements are described as concisely as possible.
To make for friendly reading, the chapter text includes bulleted listings,
tables, and boxes.
Following the explanation of federal regulations is a summary of the
regulatory requirements of the selected states where the largest amount of
metal finishing is done. This information is provided in tabular form, and
highlights areas in which state requirements may vary from federal law.
State regulatory contacts are also listed.
Each chapter concludes with a reference section and topic-specific appendix.
Part II: Pollution Prevention and Environmental Management
This section starts with a chapter on pollution prevention, which gives useful
definitions, outlines the incentives for pollution prevention, and provides a
framework to begin pollution prevention efforts. Next, the section discusses
environmental management systems and how systematic approaches yield
positive results. The chapter highlights the evolution of management
systems, including the developing international standard, ISO 14000.
The section concludes with a chapter on contaminated property, which
reviews the issue of liability and the icentives and opportunities for
voluntary cleanup.
As in Part I, each chapter concludes with a reference and topic- specific
appendix.
December 1996
1-4
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Notes
—
—
¦
———
-
¦
—
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CHAPTER 2
Air Emissions
2.1 Federal Requirements 2-3
2.1.1 What Agency Regulates Air Quality in My Area? 2-3
2.1.2 What Are "Criteria Pollutants"? 2-4
2.1.3 What Are "Attainment" and "Nonattainment" Areas? 2-4
2.1.4 Does My Facility Emit Hazardous Air Pollutants (Air Toxics)? 2-5
2.1.5 What Is a Construction Permit? 2-6
2.1.6 What Is an Operating Permit? 2-11
2.1.7 What Requirements Must I Follow Regarding Accidental Releases? 2-18
2.1.8 How Do Requirements for Stratospheric Ozone Protection Affect My Facility? 2-2 I
2.2 State Requirements 2-24
2.3 For Further Information 2-24
This chapter gives you an overview of the air pollution control requirements
that your facility may have to meet under federal and state laws. The
specific requirements affecting your company depend on your location in the
United States and the amount of air pollutants your facility emits. You will
need to find out these specific requirements by contacting the air quality
agency for your area. Reading this chapter will help you become more familiar
with current air pollution control programs under federal law, the regulations
that apply to certain metal finishers, and requirements you may have to meet
in the future.
December 1996
2-1
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Air Emissions
Part I, Chapter 2
Table of Contents
Page
2.1 Federal Requirements 2-2
2.1.1 What Agency Regulates Air Quality in My Area? 2-3
2.1.2 What Are "Criteria Pollutants"? 2-4
2.1.3 What Are "Attainment" and "Nonattainment" Areas? 2-4
2.1.3.1 What Happens if My Finn Is Located in a Nonattainment Area? 2-5
2.1.4 Does My Facility Emit Hazardous Air Pollutants (Air Toxics)? 2-5
2.1.5 What Is a Construction Permit? 2-6
2.1.5.1 What Is a PSD Permit? 2-7
2.1.5.2 What Is a Nonattainment New Source Review Permit? 2-8
2.1.5.3 What Is a New Source Performance Standard? 2-10
2.1.5.4 How Do I Obtain a Construction Permit? 2-11
2.1.5.5 What Is a Minor Construction Permit? 2-11
2.1.6 What Is an Operating Permit? 2-11
2.1.6.1 Do I Need an Operating Permit? 2-12
2.1.6.2 When Must I Apply for an Operating Permit? 2-14
2.1.6.3 How Do I Obtain an Operating Permit? 2-15
2.1.6.4 What Information Is Required in the Permit Application? 2-15
2.1.6.5 What Permit Fees Must I Pay? 2-17
2.1.6.6 What Is a Synthetic Minor and How Can it Help Me Avoid Tide V? 2-17
2.1.6.7 If I Don't Need an Operating Permit, Are There Other Requirements I Must Meet? .... 2-18
2.1.7 What Requirements Must I Follow Regarding Accidental Releases? 2-18
2.1.8 How Do Requirements for Stratospheric Ozone Protection Affect My Facility? 2-21
2.1.8.1 What Substitutes Can I Use for Ozone-Depleting Substances? 2-21
2.1.8.2 What Are the Requirements for Using Ozone-Depleting Substances? 2-23
2.2 State Requirements 2-24
2.3 For Further Information 2-24
Appendix 2-A Compliance Calendar for Federal Clean Air Act Requirements
Appendix 2-B Glossary
Appendix 2-C State and Territorial Air Pollution Control Agencies
Appendix 2-D Clean Air Requirements Worksheet and Air Emissions Worksheet
Appendix 2-E List of 189 Hazardous Air Pollutants by CAS Number
Appendix 2-F Summaries of Three NESHAP Standards
Appendix 2-G List of Regulated Substances and Thresholds for Accidental Release Prevention
December 1996
2-2
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Air Emissions
Part I, Chapter 2
2.1 Federal Requirements
Air pollution is one of the nation's principal health and
environmental concerns. Most air pollution comes either from
stationary sources such as industrial facilities, power plants, and
smelters, or from mobile sources such as cars, buses, planes, trucks,
and trains. Air pollution had already reached levels of concern in
many areas when the first major federal Clean Air Act became law
in 1970. Congress passed major amendments to strengthen the Act
in 1977 and again in 1990.
Under the Clean Air Act, EPA has the authority to set national
standards for protecting public health and the environment from
pollutants in the outside air. State governments manage most of the
specific programs for achieving these standards. The states develop
state implementation plans (SIPs) that identify sources of air pollution
and specify how the state will meet the federal air quality standards.
Metal finishing facilities must meet requirements specified in
construction permits and operating permits (Sections 2.1.5 and 2.1.6).
You also must meet requirements for stratospheric ozone protection and
new regulations on accidental releases (Sections 2.1.7. and 2.1.8). See
Appendix 2-A for a compliance schedule for federal air pollution control
requirements, and Appendix 2-B for a glossary of terms used
throughout this chapter.
2.1.1 What Agency Regulates Air Quality in My Area?
Check Appendix 2-C to find your state or territorial air quality
agency. Your state may delegate responsibility for air quality to
regional or local agencies (such as "air quality districts"). Check
with your state agency to find out what state or local agency has
direct authority for air quality in your area.
On the worksheet in Appendix 2-D, list the name, address, and
phone number of the air pollution control agency for your area.
December 1996
2-3
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Air Emissions
Part I, Chapter 2
2.1.2 What Are "Criteria Pollutants"?
EPA has identified six primary (so-called "criteria") pollutants.
These criteria pollutants are:
¦ Ground-level ozone ("smog")
¦ Carbon monoxide
¦ Small particulate matter (also known as PM-10)
¦ Nitrogen oxides (NOJ
¦ Sulfur dioxide
¦ Lead
EPA has set National Ambient Air Quality Standards (NAAQS) for
these six criteria pollutants. These are the maximum concentration
allowed for each pollutant in the background ("ambient") air in all
areas of the country. Primary standards protect public health, and
secondary standards protect plants, wildlife, building materials, and
cultural monuments.
2.1.3 What Are "Attainment" and "Nonattainment" Areas?
Under the Clean Air Act, every state is divided into "areas." Each
area is classified as an attainment, nonattainment, or unclassifiable
area for each of the six criteria pollutants, depending on whether it
meets the NAAQS.
Attainment areas are divided further into three different categories,
ranging from Class I (relatively pristine areas) to Class III (areas
that just meet the NAAQS levels). The areas with more severe air
pollution problems must apply more stringent controls, but they
have more time to attain the standards.
Nonattainment areas do not meet NAAQS levels for one or more
criteria pollutants. Nonattainment areas for ozone, carbon
monoxide, and PM-10 are further classified as marginal, moderate,
serious, severe, and extreme. Contact your air quality agency or
EPA for an up-to-date list of nonattainment areas; the status of
these areas changes frequently.
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2.1.3.1 What Happens if My Firm Is Located in a
Nonattainment Area?
If you are located in a nonattainment area for one of the six criteria
pollutants and your facility emits that pollutant, you may have to
meet stricter requirements for air pollution control than if you were
in an attainment area. If you are located in a nonattainment area,
then even if you are not required to have a permit (as described in
Sections 2.1.5 and 2.1.6), you should check with your air quality
agency to see if you need to show compliance with regulations that
address nonattainment air pollution issues in your area.
Metal finishers are most likely to be affected by requirements in the
nonattainment areas for ground-level ozone (smog). Ozone is a
pollutant that is not discharged to the atmosphere but is created by
the reaction of ozone precursors (volatile organic compounds, or
VOCs) and sunlight. VOC emissions affect ozone production.
Metal finishing processes such as vapor degreasing, paint spraying,
and fuel burning are likely to emit VOCs and nitrogen dioxide.
These pollutants participate in complex chemical reactions in the
presence of intense sunlight to form smog.
2.1.4 Does My Facility Emit Hazardous Air Pollutants (Air
Toxics)?
Under the National Emission Standards for Hazardous Air
Pollutants (NESHAP) program, EPA has set limits for the amount
of 189 hazardous air pollutants (also known as air toxics) that
stationary sources can emit. Appendix 2-E lists the hazardous air
pollutants that may be emitted by metal finishers. Check this list
and record any used at your facility on the worksheet in Appendix
2-D.
To reduce the levels of hazardous air pollutants, EPA issues
Maximum Achievable Control Technology (MACT) standards.
Each MACT standard controls emissions of one or more air toxics
from a specific air pollutant source (such as chromium electroplating
and anodizing operations). The MACT is the best control
technology already in use for a given type of industry.
Under the NESHAP program, "major" sources of air toxics must use
the MACT. Your operation is a major source if its potential
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emissions are 10 tons/year or more of a hazardous air pollutant or
25 tons or more of a combination of hazardous air pollutants.
Appendix 2-F presents summaries of three NESHAP standards,
along with compliance dates, that apply to the metal finishing
industry:
¦ Chromium Emissions from Hard and Decorative
Electroplating and Anodizing Operations
¦ Halogenated Solvent Cleaning Machines
¦ Aerospace Manufacturing and Rework
Box 2-1 below shows the facilities and pollutants covered and
compliance dates for each of these standards.
If your facility emits a hazardous air pollutant not covered by the
NESHAP standards listed in Box 2-1 and described in Appendix 2-F,
check with your air quality agency to find out if any other NESHAP
standards apply to you.
2.1.5 What Is a Construction Permit?
If you are constructing a new facility or substantially modifying an
existing facility, you must obtain a construction permit. A
construction permit contains the air pollution control requirements
for a newly built facility or a facility undergoing major
modifications. New sources of air pollution usually must have
stricter controls than existing facilities. Emissions controls and
pollution prevention can be added in the initial design and
construction phase of a project.
A construction permit does not cover the air pollution requirements
for an entire facility. Many facilities may have more than one
construction permit (one permit for each new modification they
have made to their facility over the years). Federal construction
permits do not have an expiration date. The conditions of a
construction permit remain effective indefinitely (or until the
conditions are modified or removed in another permit).
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While some states only require a construction permit for new
equipment, other require both a permit to construct and a permit to
operate new equipment (different from the Title V operating permit
described in Section 2.1.6). Check with your air quality agency to
find out what type of permit you need for new equipment.
Box 2-1 Overview of Three NESHAP Standards
NESHAP Standard
Facility Covered
Pollutants Covered
40 CFR Part 63
Subpart N
Facilities performing hard and
decorative chromium
electroplating and anodizing
operations.
Chromium.
40 CFR Part 63
Subpart T
Facilities with batch vapor and
in-line solvent cleaning
machines using halogenated
solvents.
Methylene chloride,
perchloroethylene,
trichloroethylene, 1,1,1-
trichloroethane, carbon
tetrachloride, and chloroform.
40 CFR Part 63
Subpart GG
Aerospace manufacturing and
rework facilities.
Chromium, cadmium,
methylene chloride, toluene,
xylene, methyl ethyl ketone,
ethylene glycol, glycol ethers.
Th =re are two types of construction permits under the Clean Air
Act: Prevention of Significant Deterioration (PSD) permits and
Nonattainment New Source Review permits. These are described
below. (Note that states may have different names for construction
permits. For example, an Ohio construction, permit is called a
"permit to install.")
2.1.5.1 What Is a PSD Permit?
The PSD program is designed to prevent degradation of air in
attainment areas (areas that meet EPA's national air quality
standards for the six criteria pollutants). PSD permits cover
facilities located in attainment areas. EPA sets limits on the amount
of additional air pollution allowed in attainment areas. These limits
differ for Class I, Class II, and Class III areas. In addition, new
sources of air pollution may be required to install Best Available
Control Technologies (BACT). Facilities proposing to locate near
Class I areas may have to meet additional requirements to protect
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visibility arid other air quality-related values (such as damage to
plants and animals).
When Must I Obtain a PSD Permit?
If you are located in an attainment area, you must obtain a
construction permit under the PSD program if you can answer "yes"
to either of the following questions:
¦ Does your newly constructed facility have the potential to emit
250 tons per year of any pollutant subject to regulation under
the Clean Air Act?
¦ Will the modifications to yourfacility result in a net emissions
increase of the following levels? (Net emissions increase =
New emissions minus reductions in emissions caused by the
modifications; see Box 2-2.)
2.1.5.2 What Is a Nonattainment New Source Review
Permit?
Nonattainment New Source Review permits cover sources located
in areas that do not meet the NAAQS (nonattainment areas).
In nonattainment areas a new source must, at a minimum, install
controls to meet the "lowest achievable emissions rate" (LAER).
States may also require a new facility to reduce emissions to the
PSD levels (the limits set in attainment areas). In addition, facility
owners could be required to "offset" the emissions caused by their
facility by installing emission controls at another facility (whether
they own it or not) in the same area.
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Box 2-2 Net Emission Increases That Trigger Requirements
for a PSD Permit
Pollutants
Tons Per Year
Asbestos
0.007
Beryllium
0.0004
Carbon monoxide
100
Fluorides
3
Hydrogen sulfide
10
Lead
0.6
Mercury
0.1
Ozone
40
Particulate matter
25
Reduced sulfur compounds
10
Sulfur dioxide
40
Sulfuric acid mist
7
Total reduced sulfur
10
When Must I Obtain a Nonattainment New Source Review
Permit?
If you are located in a nonattainment area, you must obtain a
nonattainment new source review permit if you can answer "yes" to
either of the following questions:
¦ Does your newly constructed facility have the potential to emit air
pollutant(s) in excess of the "major stationary source threshold"
on an annual basis? (This threshold is 100 tons per year for
most pollutants, but for some pollutants, such as VOCs and
nitrogen dioxide, the major stationary source threshold can be as
low as 50 or 25 tons per year, depending on where your facility
is located. Check with your air quality agency for more
information.)
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¦ Will the modifications to your facility result in a net emissions
increase by any of the following amounts (Box 2.3)?
Box 2-3 Net Emissions Increases That Trigger Requirements
for a Nonattainment New Source Review Permit
Pollutants
Amount
Carbon monoxide
100 tons per vear
Nitrogen oxides
40 tons per year
Sulfur dioxide
40 tons per year
Ozone
40 tons per year volatile
organic compounds
Particulates
25 tons per year
15 tons per year small
particulate (PM10)
emissions
Lead
0.6 tons per year
2.1.5.3 What Is a New Source Performance Standard?
Under the Clean Air Act, EPA establishes New Source Performance
Standards (NSPSs) that restrict emissions from new industrial
facilities or existing facilities undergoing major modifications or
reconstruction. EPA sets the NSPS control level to reflect BACT.
NSPSs are reflected in construction permits.
To date, EPA has issued NSPSs, found in 20 CFR 60, for specific
categories of industry. NSPS categories that may apply to metal
finishers include:
¦ Subpart Kb
¦ Subpart EE
¦ Subpart SS
¦ Subpart TT
¦ Subpart WW
Volatile Organic Liquid Storage Vessels
Surface Coating of Metal Furniture
Surface Coating of Large Appliances
Metal Coil Surface Coating
Beverage Can Surface Coating Industry
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Typically, a NSPS sets out the kind of process and equipment
covered, and requirements that must be observed by the new source
operator. For example, Subpart IT describes metal coil surface
coating facilities and sets forth requirements for volatile organic
compound emission limits, performance testing, monitoring of
emissions and operations, reporting and recordkeeping
requirements, and test methods and procedures.
2.1.5.4 How Do I Obtain a Construction Permit?
The information that you must submit to obtain a PSD or
Nonattainment New Source Review permit includes information
about the polluting process and types of pollutants emitted,
engineering data on pollution control techniques that may be used
for the facility, and modeling data to determine the effects of the
new pollutants on air quality. Check with your air quality agency
to find out how to obtain a permit for your new or modified facility.
2.1.5.5 What Is a Minor Construction Permit?
If your new or modified source will emit less than the threshold level
for emissions increases (i.e., if you answered "no" to the relevant
questions in 2.1.5.1 or 2.1.5.2 above), you must obtain a minor
construction permit. A minor construction permit is less complex
than a major construction permit. Therefore, it may be to your
advantage to design your new facility (including taking advantage
of pollution prevention opportunities) so that emissions are below
the PSD or New Source Review threshold levels. In this case, your
facility will qualify for a minor construction permit.
Your state or local air quality agency may be able to provide you
with guidance on how to avoid a PSD or Nonattainment New
Source Review Permit by qualifying for a minor construction permit.
2.1.6 What Is an Operating Permit?
Under Title V of the Clean Air Act, all of the air pollution control
obligations of a facility must be contained in a single 5-year
operating permit. This operating permit will contain previously
issued PSD, New Source Review, and minor construction permits,
and will cover other sources of air pollution at your facility.
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The states develop permit programs that meet minimum
requirements set by EPA. At a minimum, the permit sets
requirements for:
¦ Limits on air pollutant emissions.
¦ A compliance schedule.
¦ Progress reports (including air monitoring results) every 6
months.
¦ Immediate reports about any deviations from permit
conditions.
¦ Facility recordkeeping.
You must obtain a revised permit if your facility becomes subject to
new air pollution requirements or if you make changes to your
facility that require the permit to be updated (i.e., increases in
potential total emissions, an increase of the maximum rated capacity
of the source, increased emissions of certain federally - or state-
regulated air pollutants, an increase in maximum uncontrolled
emissions, or a change in fuel—check with your air quality agency
for specifics).
NOTE: Before the 1990 amendment to the Clean Air Act were
passed, EPA did not require states to issue operating permits to
sources. Many states had their own operating permit programs for
many years, however. The new operating permits issued by your
state under Title V will not replace PSD, New Source Review, or
minor construction permits, but will reference these permits and list
them as part of the operating permit. Check with your air quality
agency for more details.
2.1.6.1 Do I Need an Operating Permit?
If you answer "yes" to any of the following questions, you are
required to obtain a Title V operating permit:
¦ Does my facility potentially emit criteria air pollutant(s) in
excess of the "major stationary source threshold" on an
annual basis as defined in 40 CFR Part 70? (This threshold
is 100 tons per year for most pollutants, but for some
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pollutants, such as VOCs and nitrogen dioxide, the major
stationary source threshold can be as low as 50 or 25 tons per
year, depending on where your facility is located. Your air
quality agency can tell you what threshold applies in your
area.)
Major stationary sources of criteria pollutants in
Nonattainment Areas (NAA) are facilities with the potential
to emit pollutants in the amounts indicated in Box 2.4.
Box 2-4 Emission Thresholds That Define "Major" Stationary
Sources in Nonattainment Areas
Pollutants
NAA Cateeorv
Tons Per Year
Any one regulated
pollutant
All
100
VOCs and NOx
Serious
50
Severe
25
Extreme
10
Carbon monoxide
Serious
50
Particulates (PM10)
Serious
70
¦ Does my facility potentially emit 10 tons or more per year of
any individual hazardous air pollutant (air toxic)?
¦ Does my facility potentially emit 25 tons or more per year of
any combination of hazardous air pollutants?
¦ Is my facility subject to New Source Performance Standards
(see Section 2.1.5.3)?
¦ Is my facility required to have a Prevention of Significant
Deterioration (PSD) or Nonattainment New Source Review
permit (see Section 2.1.5.1 and 2.1.5.2)?
¦ Is my facility subject to a NESHAP standard (see Section
2.1.4)? The Clean Air Act requires that any facility.that is
subject to a MACT air standard under the NESHAP program
implement the MACT via a Title V permit. For chrome
platers coming under the new chrome standard (Appendix 2-
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C), however, EPA has chosen to use a notification program
rather than a permit program. This could change as more
states get their Title V programs under way.
Most job shop metal finishing facilities generate less than the
threshold amounts for air emissions that trigger Title V permitting
(e.g., 10, 25, or 100 tons per year). Captive shops in larger
manufacturing operations are the ones that need to take a hard look
at the air emissions inventory for the plant as a whole to see if the
thresholds are exceeded. Metal finishing operations that include
surface applications and painting are more likely to trigger Title V
because of the VOCs emitted.
Box 2-5 Calculating Air Emissions
The following steps are recommended to determine the potential
and actual emissions from your facility (see appendix 4-D for an
example Air Emissions Inventory Worksheet):
¦ Identify all emission sources.
¦ Calculate the potential emissions from each emission
source.
¦ Total the potential emissions fr • each pollutant from all
emissions sources.
¦ Compare the total potential emissions to the thresholds
described in Section 2.1.6.1.
If the potential emissions exceed the thresholds, then:
¦ Calculate the actual emissions from each emission source.
¦ Total the actual emissions for each pollutant from all
emission sources.
2.1.6.2 When Must I Apply for an Operating Permit?
If your facility is subject to the Title V regulations, you must submit
a complete permit application within 12 months after your state's
permit program is approved by EPA. New sources and major
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modifications will require permit approval before construction
begins. State or local agencies have 18 months to approve or reject
each permit application.
Check with your air quality agency and record on the worksheet
(Appendix 2-D) the date your application is due.
2.1.6.3 How Do I Obtain an Operating Permit?
To obtain an operating permit, follow the steps listed below:
¦ Identify why you need a permit (see Section 2.1.6).
¦ Identify your permitting agency (see Section 2.1.1).
¦ Obtain application forms.
¦ Determine when the application is due (see "When Must I
Apply for an Operating Permit?" above).
¦ Designate people at your facility to gather the information
needed for the application.
¦ Decide who will be the "responsible official" to sign the
permit and other certifications.
¦ Complete, sign, and submit the application.
2.1.6.4 What Information Is Required in the Permit
Application?
In general, the following information will be required in your permit
application (the information required may differ slightly depending
on your state)1:
¦ Company or plant name and address.
¦ Owner's name.
¦ Names and telephone numbers of plant managers and other
facility contacts.
¦ Description of pollutant source's processes, products, and SIC
code.
' Source: Business and Legal Reports, Inc.. Environmental Compliance in Connecticut. Madison, CT 1995
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¦ Description of:
— All emissions for which the facility is a major source.
— Regulated emissions for which the facility is not a major
source.
— All emissions points for regulated pollutants.
— Emissions rate in tons per year.
— Fuel, fuel use, raw materials, production rates, operating
schedule.
— Any air pollution control equipment and monitoring
devices.
— Work practice standards for limiting emissions.
— Calculations you used to determine emissions rates and
other data.
¦ All applicable air pollution control requirements, including
reference to any applicable test methods.
¦ Any regulated emissions for which the facility has been
exempted.
¦ Any "alternative operating scenarios" that you may
anticipate.
¦ Emissions requirements that you have already complied with.
¦ Emissions requirements taking effect during the permit term
that you will comply with "on a timely basis."
¦ How you will meet existing requirements that you are not yet
in compliance with.2
¦ A compliance schedule for meeting standards you have not
yet met.
¦ A statement committing your company to submitting
progress reports twice a year on complying with existing
requirements not yet complied with.
¦ Methods to be used to determine compliance (monitoring,
testing, inspections, etc.).
¦ Schedule for submitting "compliance certifications" at least
annually to the regulatory agency.
2For assistance, contact the National Metal Finishers Resource Center [number to be added].
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2.1.6.5 What Permit Fees Must I Pay?
Most air quality agencies assess annual permit fees to cover the costs
of operating the programs. Most fees are based on actual pollutant
emissions. Check with your air quality agency to find out your
permit fees.
2.1.6.6 What Is a Synthetic Minor and How Can it Help
Me Avoid Title V?
A synthetic minor (a minor air emitting source) is a designation that
you can apply for to avoid Title V permitting altogether, or reduce
its regulatory burden under an existing Tide V permit. A synthetic
minor is defined as any facility (or unit within a facility, such as a
captive metal finishing operation) that would otherwise qualify as
a major source under Title V except that the owner or operator
voluntarily does one or more of the following in order to reduce
actual emissions below the applicable thresholds for a Tide V major
source:
¦ Puts restrictions on the hours or methods of operation of
particular pieces of equipment.
¦ Restricts the type or amount of air-polluting material stored,
combusted, or processed.
¦ Accepts more stringent requirements on the facility's air
pollution control devices.
Many companies are doing pollution prevention, especially source
reduction, so they can qualify as a synthetic minor.
The three main advantages of being a synthetic minor are:
¦ There is no need to get a Title V permit, develop detailed
emissions inventories, do annual Title V reporting and
recordkeeping, etc.
¦ You may be exempt from Tide V fees.
¦ You may avoid Title V-related future regulations, such as
source-specific MACT triggers and future monitoring
requirements.
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Many states have developed permit programs that allow synthetic
minors to be appropriately permitted but exempt from Title V
responsibilities. These permits are sometimes called "general
permits to limit potential to emit," "omni permits," or "synthetic
minor permits."
2.1.6.7 If I Don't Need an Operating Permit, Are There
Other Requirements I Must Meet?
Even if you don't need an operating permit, you should check with
your air quality agency to see if any air quality rules apply to your
facility. You may have to meet requirements in such areas as
recordkeeping and reporting, labeling, or equipment and methods
to control emissions. For example, some states require particular
methods for coating applications in nonattainment areas.
2.1.7 What Requirements Must I Follow Regarding Accidental
Releases?
On June 20, 1996, EPA promulgated a final rule for risk
management planning (40 CFR Part 68), as required under Section
112(r) of the Clean Air Act. The rule requires facilities to develop
and implement risk management programs that incorporate three
elements: hazard assessment, a prevention program, and an
emergency response program. These programs are to be summarized
in a risk management plan (RPM) that will be made available to
state and local government agencies and the public.
Any source with more than a threshold quantity of a listed
"regulated substance" must comply with this regulation. See
Appendix 2-G for the list of regulated substances and their threshold
quantities. (Note: The threshold quantity refers to the maximum
amount of a substance in a process, not the maximum quantity on
site.)
Some metal finishers may be subject to this rule, if they use a listed
"regulated substance" in a process above the threshold quantity.
Listed substances that metal finishers may use include:
¦ Ammonia (anhydrous)
¦ Chlorine
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¦ Hydrochloric acid
¦ Nitric acid
¦ Propane
Most metal finishers are unlikely to use these substances in a process
in quantities greater than the threshold levels. For example, a metal
finisher is unlikely to use more than 15,000 pounds of hydrochloric
acid in a process. If you do become subject to the rule, however, the
requirements are significant, as described below. (Record any listed
substances that you use in a process above the threshold quantity on
the worksheet in Appendix 2-D.)
The rule classifies processes into three categories ("Programs")
according to their size and the risks they may pose:
¦ Program 1 requirements apply to processes for which a worst-
case release, as evaluated in the hazard assessment, would not
affect the public. These are sources or processes that have
not had an accidental release that caused serious offsite
consequences. The facilities eligible for this program are
primarily remotely located sources and processes using listed
flammables.
•1 Program 2 requirements apply to less complex operations
that do not involve chemical processing (such as retailers,
propane users, non-chemical manufacturers, and other
processes not regulated under the Occupational Safety and
Health Administration's (OSHA's) Process Safety
Management (PSM) standard (29 CFR 1910.119).
¦ Program 3 requirements apply to higher risk, complex
chemical processing operations and to processes already
subject to OSHA's PSM standard.
If a metal finishing facility is subject to this rule at all, it is most
likely to have processes subject to Program 1 requirements.
(Note: A facility could have processes in one or more of the three
Programs. If a process meets Program 1 criteria, the facility need
only satisfy Program 1 criteria for that process, even if other
processes are subject to Program 2 or Program 3.)
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Sources with processes in Program 2 and Program 3 must carry out
the following elements of risk management planning:
¦ An offsite consequence analysis that evaluates specific
potential release scenarios, including worst-case and
alternative scenarios.
¦ A 5-year history of accidental releases of regulated substances
from covered processes.
¦ An integrated prevention program to manage risk.
¦ An emergency response program.
¦ An overall management system to supervise the
implementation of these program elements.
¦ A risk management plan (RMP), revised at least once every
5 years, that summarizes and documents these activities for
all covered processes.
For Program 1 processes, facilities are not required to implement a
prevention program, an emergency response program, or a
management system.
Facilities covered by the rule will submit a registration form, along
with their risk management plai., to a central location to be
specified by EPA. Facilities with at least one covered process must
submit the registration forms and risk management plans by June 20,
1999, with updates required every 5 years. If EPA adds to the list
of regulated substances, the regulation will take effect for newly
covered facilities 3 years after the date on which the substance is
first listed.
To encourage electronic submission of RMPs, EPA has standardized
the RMP requirements. With the exception of an executive
summary, data elements a facility must submit will be primarily
check-off boxes, yes/no answers, and numerical entries.
Small and medium-sized businesses may receive information about
risk management planning through the Small Business Assistance
Program in each state, the Federal Small Business Assistance
Program, the Network of Small Business Development Centers, and
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the Emergency Planning and Community Right-To-ICnow (EPCRA)
Hotline (800-424-9346).
EPA is also working with industry groups to develop model risk
management programs, and will issue RMP Offsite Consequence
Analysis Guidance to eliminate the need for covered small
operations to invest in computer modeling program and to answer
complex technical questions. Contact the EPCRA Hotline for more
information.
Section 112 (r) of the Clean Air Act (Accident Prevention) is an
applicable requirement for Title V permits (see Section 2.1.6). Air
permitting agencies must ensure that a source is in compliance with
this and other applicable requirements to issue a permit.
2.1.8 How Do Requirements for Stratospheric Ozone
Protection Affect My Facility?
Ozone in the stratosphere, a layer of the atmosphere 9 to 3 i miles
above the Earth, serves as a protective shield filtering out harmful
sun rays. EPA has set a schedule for phasing out substances that
harm the ozone layer. Several of these substances, including 1,1,1-
trichloroethane (methyl chloroform) and chlorofluorocarbons
(CFCs) such as freon, are used in the metal finishing industry.
Since the phaseout of these chemicals began, users have seen
availability shrink and prices skyrocket. U.S. production of both
CFCs and 1,1,1 -trichloroethane was completely phased out as of
January 1, 1996.
2.1.8.1 What Substitutes Can I Use for Ozone-Depleting
Substances?
EPA has established a program to identify alternatives to ozone-
depleting substances, known as the Significant New Alternatives
Policy (SNAP) Program. Once EPA has issued a final rule
identifying acceptable and unacceptable substitutes, it is illegal to
replace a regulated ozone-depleting substance with any substance
EPA determines may harm human health or the environment if
other substitutes have been identified that reduce overall risk and
are currently or potentially available.
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EPA's acceptability lists for substitutes can be obtained by calling
the Stratospheric Protection Hotline at 1-800-296-1996, Monday
through Friday, 10:00 a.m. to 4:00 p.m. EST.
Metal finishers have found several substitutes for ozone-depleting
substances, particularly 1,1,1-trichloroethane (methyl chloroform).
However, you should be cautious when choosing new materials,
which might be subject to one or more regulatory requirements.
Box 2-6 shows examples of acceptable substitutes for ozone-
depleting substances used in the metal finishing industry.
Box 2-6 Acceptable Substitutes for Ozone-Depleting
Substances
Ozone Depleting
Substance
Acceptable Substitute(s)
Methyl chloroform
(in coatings)
¦ Petroleum hydrocarbons
¦ Oxygenated solvents (alcohols, ketones,
¦ Terpenes
¦ Water-based formulations
Metals cleaning
with CFC-113,
methyl chloroform
¦ Aqueous cleaners
¦ Semi-aqueous cleaners
¦ Straight organic solvent cleaning (with
terpenes, C20 petroleum hydrocarbons,
oxygenated solvents such as ketones,
ethers, and esters)
¦ Trichloroethylene, perchloroethylene,
methylene chloride
¦ Vanishing oils
¦ Supercritical fluids
¦ Volatile methyl siloxanes
¦ Trans-1,2-dichloroethvlene
Mechanical cleaning has also become more common.
December 1996
2-22
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Air Emissions
Part I, Chapter 2
2.1.8.2 What Are the Requirements for Using Ozone-
Depleting Substances?
EPA regulations control the use of ozone-depleting compounds such
as freons and halons through requirements for labeling, leaic
detection and repair, record retention, and certification for servicing
and disposal. These requirements may apply to halon fire
suppression systems and refrigeration units that contain freon.
These requirements are found in 40 CFR Part 82.
The labeling requirements apply to "Class I" ozone-depleting
substances (substances containing CFCs or methyl chloroform,
including solvents, refrigerants, and fire retardants) and "Class II"
substances (hydrochlorofluorocarbons, or HCFCs). All containers
that store or transport Class I or Class II substances, and all
products containing Class I or Class II substances, must contain a
clearly legible and conspicuous label that states:
Warning: Contains (name of substance), a substance which harms
public health and environment by destroying ozone in the upper
atmosphere.
All products manufactured with a process that uses a Class I
substance must carry a clearly legible and conspicuous label that
states:
Warning: Manufactured with (name of substance), a substance which
harms public health and environment by destroying ozone in the upper
atmosphere.
Products also must be labeled if they have components that are
labeled. This means that if any component of a product is cleaned
using an ozone-depleting substance, the completed product must
have a label that will be seen by the ultimate consumer of the
product.
December 1996
2-23
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Air Emissions
Part I, Chapter 2
2.2 State Requirements
Most states have a state air toxics program that is more stringent
than the federal requirements and/or regulates more air toxics. The
programs are similar in that each air toxic regulated has been
assigned a health-based concentration limit not to be exceeded in
ambient air. Various modeling programs or state-derived formulas
are used to estimate an acceptable air toxic concentration.
Most states have permitting programs which are more stringent that
the federal permitting requirements. The main differences between
state and federal programs are that state permitting thresholds are
often lower or encompass more equipment than federal regulations.
In addition, each state that has its own air toxics program requires
a state permitting program to enforce its air toxic regulations.
Table 2-1 summarizes some of the individual state requirements
regarding hazardous air pollutants and general features about each
state's permitting requirements. Please keep in mind that many
states are in the process of revising their state regulations; moreover,
some of the larger states have regulations that vary slightly by
region. Therefore, it is recommended that each state be contacted
to discuss specific regulations that may affect the equipment
considered for installation.
2.3 For Further Information
American Electroplaters and Surface Finishers (AESF). 1995.
Chromium emissions regulations and compliance information for decorative
chromium platers. AESF Chromium Summit Workshop, May 25-26,
Chicago, IL.
AESF. 1995. Chromium emissions regulations and compliance
information for hard chromium platers. AESF Chromium Summit
Workshop, May 25-26, Chicago, IL.
AESF. 1995. Regulatory compliance workshop manual: Air/Water.
February 8-9.
December 1996
2-24
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Air Emissions
Part I, Chapter 2
U.S. Environmental Protection Agency. 1992. The Clean Air Act
Amendments of 1990: A guide for small businesses. EPA 450-K-92-001.
Office of Air and Radiation, Washington, DC.
U.S. Environmental Protection Agency. 1993. The plain English
guide to the Clean Air Act. EPA 400-K-93-001. Office of Air and
Radiation, Washington, DC.
December 1996
2-25
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Table 2-1 Summary of Selected State Air Pollution Programs
State
State Laws
Hazardous Air Pollutants
Permitting Requirements
State Contact(s)
AZ
Arizona
Administrative Code
Title 18, Chapter 2
Arizona has a state air toxics
program. An EPA screen model is
used to estimate ambient impacts.
Toxics regulated include those
commonly emitted from metal
finishing equipment. Also
delegated federal NESHAP
program and Title 111 of CAA.
One permit system for new sources. Permitting
requirements for metal finishing equipment vary by
county where equipment is located in. No general
permits for metal finishing equipment. Permits are
to be renewed every five years. State program
basically incorporates Federal programs and does not
add significant additional requirements. Title V
program has not been approved yet.
Arizona Department of
Environmental Quality
3033 North Central Avenue
Phoenix, AZ 85012-2809
(602)207-2316
CT
Regulations of
Connecticut State
Agencies 22a-174
Connecticut has a state air toxics
program. Emissions commonly
associated with metal finishing are
regulated. Formulas in state
regulations used to determine
compliance. Also delegated Federal
NESHAP and Title 111 of CAA
when program is approved.
Two permit system, permit to construct and permit
to operate based on potential to emit. General
permit currently under development for spray
booths. State program is more stringent than Federal
program. Specific site regulations concerning surface
coating and surface preparation exist. Title V
program has not been approved yet.
Connecticut Department of
Environmental Protection
Bureau of Air Management
Engineering Enforcement
Division
79 Elm Street
Hartford, CT 06106-5127
(860) 424-3028
GA
Official Compilation
of Rules and
Regulations, State of
Georgia, Chapter
391-3-1
State does not have air toxics
program in addition to Federal
NESHAP Program. Maximum
acceptable levels based on OSHA,
NIOSH, and LD50 values. Case by
case determinations made as to
whether modeling is necessary.
Given delegation for federal
NESHAP and Title III of CAA.
There is a state permitting program. Dual permit
system; permits to construct and operate issued
simultaneously. No regulations specific to metal
finishing industry except for Federal control
techniques guidelines. Title V program has been
approved.
Georgia Department of Natural
Resources
Environmental Protection
Division
205 Butler Street
Atlanta, GA 30334
(404) 363-7000
lL
Title 35, Subtitle B
Chapter I of Illinois
Administrative Code
No state air toxics program. Given
delegation for Federal NESHAP
program and Title III of CAA.
There is a state permitting program. Dual permit
system; permits to construct and operate. No general
permits or permit-by-rule for metal finishing
equipment. There are state-specific regulations for
coating and degreasing operations. Title V program
has been approved.
Illinois Environmental
Protection Agency
2200 Churchill Road
Springfield, IL 62794
(217) 782-7326
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Table 2-1 Summary of Selected State Air Pollution Programs
Slate
State Laws
Hazardous Air Pollutants
Permitting Requirements
State Contact(s)
IN
Indiana
Administrative Code
Title 326
No state air toxics program.
Delegated Federal NESHAP and
Title 111 ofCAA.
State has own permitting program. Dual permit
system; permits to construct, operate, and
registrations for sources not requiring permits.
Potential emissions greater than 25 TPY require
construction permit. State regulations specific to
printing, degreasing, VOC storage tanks, plating tank
regulations all under development. No general
permits for metal finishing. Title V program has
been approved.
Indiana Department of
Environmental Management
150 West Market Street
Suite 703
Indianapolis, IN 46206-6015
(317) 233-0178
ICY
Kentucky
Administrative
Regulation Service
Title 401, Chapter
50-63
State has air toxics program.
Approximately 120 air toxics are
regulated for existing sources, over
700 for new sources. Toxics
commonly associated with metal
finishing equipment regulated.
Delegated Federal NESHAP and
Title 111 ofCAA.
State has own permitting program, more stringent
than federal program. State permits authorize both
construction and operation. Federally-enforceable
permits issued for major sources. No state
regulations specific to metal finishing operations
except for CTG sources. No general permits
available yet. Title V program has been approved.
Kentucky Department of
Environmental Protection
14 Ueilly Road
Frankfort, KY 40601
(502) 573-3382
MD
Code of Maryland
Regulations Title 26
Department of
Environment
Subtitle I 1
State does have air toxics program.
Based on PEL. Fence line
concentrations determined using
modeling programs. Delegated
authority for Federal NESHAP and
Title III once program is approved.
One permit system: Permit to Construct, which is
Federally enforceable. State has list of equipment
which is exempt from permit requirements. No state
regulations specific to metal finishing. No permit by
rule or general permit program established; however,
general permit for spraybooths is under development.
Title V program not yet approved.
Department of the
Environment
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3304
MA
Code of
Massachusetts
Regulations, 310
CMR6.00 to 310
CMR 8.00
No state regulatory air toxics
program. State delegated authority
for federal NESHAP program and
Title III ofCAA.
Two permit system. Limited plan approval for
sources with potential emissions < 5 TPY.
Comprehensive plan approval for sources with
potential emissions > 5 TPY. State program has
lower permitting threshold than federal requirements.
Degreasers are exempt from state recordkeeping
requirements if solvent consumption < 100
gal/month. No general permits for metal finishing
equipment. Title V program has been approved.
Massachusetts Department of
Environmental Protection
1 Winter street
Boston, MA 02108
(617) 292-5630
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Table 2-1 Summary of Selected State Air Pollution Programs
State
State Laws
Hazardous Air Pollutants
Permitting Requirements
State Contact(s)
Ml
Michigan
Administrative Code,
R336 Parts I
through 17
State does have air toxic* program.
No deminimus air level for toxics
evaluation. BACT for toxics is
required. If meet MACT, that is
sufficient for state requirements.
Delegated Federal NESHAP
program and Title III once program
is approved.
State does have permitting program. Applicability
based on equipment type, regardless of potential to
emit. More stringent than federal requirements.
Unless equipment is on categorically exempt list,
permit is required. One permit system: "permit to
install". General permits are under development for
metal finishing sources. Title V program has not
been approved.
Michigan Department of
Natural Resources
530 West Allegan Street
P.O. Box 30260
Lansing, MI 48909
(517) 373-7023
MN
Minnesota Pollution
Control Agency,
Chapter 7000-7028
No state air toxics program.
Federal NESHAP and Title III of
CAA
State program is more stringent than federal
program. Three types of permits: facility, general,
and registration. State is in attainment for ozone,
therefore VOC emissions may not be a significant
concern. No general permits for metal finishing
sources. State does have regulations pertaining to
blasting, grinding, plating, painting, solvent, and
cleaning. Title V program has been approved.
Minnesota Pollution Control
Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-7331
N)
New Jersey
Administrative Code,
Chapter 7:27
There is a state air toxics program
covering approximately 50 toxics,
some of which are commonly
emitted from metal finishing
sources. State has delegation for
Federal NESHAP and Title "'of
CAA when approved.
State program is more stringent than federal
program. Two permit system: permit to construct
and certificate to operate, issued simultaneously.
There are state-specific regulations covering surface
coating, surface cleaners, degreasing, etching,
pickling, plating, cold cleaners. No general permits
available yet. Title V program has not been fully
approved.
New Jersey Department of
Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 292-6710
NY
Official Compilation
of Codes, Rules and
Regulations of the
State of New York,
Title 6, Chapter 111
There is a state air toxics program
which regulates several hundred air
toxics including those typically
emitted from metal finishing
sources. State also has delegation
for Federal NESHAP program and
Title 111 of CAA when program is
approved.
There is state permitting program which has
undergone recent changes from dual permit system of
construction and operations permit to just Operating
Permit. State does have regulations pertaining to
surface coating, surface preparation. General permit
program available, but no general permits for metal
finishing equipment available yet. No permit by rule
available. Title V has not been approved.
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233-1750
(518) 457-7230
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Table 2-1 Summary of Selected State Air Pollution Programs 1
State
State Laws
Hazardous Air Pollutants
Permitting Requirements
State Contact(s)
NC
North Carolina
Administrative Code,
title 15, Chapter 2,
Sub-Chapter 2D
State has air toxics program,
pollutant specific. Common
emissions from metal finishing
operations are covered. State
administers Federal NESHAP and
Title 111 ofCAA.
There is a state permitting program, more stringent
than federal which varies from county to county.
Two types of permits, construction and operating
with five year expiration date. No permit by rule
available. No general permits for metal finishing
equipment. No state regulations specific to metal
finishing. Awaiting full Title V approval.
North Carolina Department of
Environment, Health &.
Natural Resources
3800 Barrett Drive
Raleigh, NC 27609
(919) 733-3340
OK
Oklahoma
Administrative Code,
Title 252, Chapter
100
There is a state program which
regulates approximately 600 air
toxics including those commonly
emitted from metal finishing
equipment. Program based on
occupational exposure limit for
which a screening program is used
to assess compliance. State
delegated Federal NESHAP and
Title 111 ofCAA.
The state permitting program is more stringent than
federal. Permit application required for sources with
potential emissions greater than 1 Ib/hr. No state
regulations specific to metal finishing equipment.
Dual permit system: construction permits and
operating permits. No general permits or permit by
rule. Title V program approved March 1996.
Oklahoma Department of
Environmental Quality
4545 North Licoln Blvd.
Suite 250
Oklahoma City, OK 73 105-
3483
(405) 271-5220
(405) 524-1348
III
Code of Rhode
Island Regulations,
Division of Air
Resources,
Regulation No. 1-20,
27-34
State has air toxics program
regulating approximately 40 toxics
including those commonly emitted
from metal finishing processes.
Also delegated Federal NESHAP
program and Title ill of CAA.
Two types of permits, construction permit for state
requirements and operating permit for Title V.
Metal finishing processes which emit more than 10
Ib/hr or 100 lb/day of any pollutant are required to
obtain a permit. No general permits for metal
finishing sources. Title V program lias been
approved by EPA.
State of Rhode Island
Department of Environmental
Management
291 Promenade Street
Providence, RI 02908-5767
(401) 277-2808
TX
Title 30 Texas
Administrative Code,
Chapters 101-122
State has air toxics program,
regulating many air contaminants.
A complete health effects review
including screening modeling is
necessary for emissions greater than
25 TPY. Delegated Federal
NESHAP and Title III when
program is approved.
There is a state permitting program. One permit
system: construction permits. Permitting
requirements vary by county equipment is located in.
There are state regulations governing degreasing,
spraybooths, and plating. No general permit for
metal finishing equipment. No permit by rule. Title
V program has not been approved.
Texas Natural Resource
Conservation Commission
12100 Park 35 Circle
Austin, TX 78711-3087
(512) 239-1000
-------
Table 2-1 Summary of Selected State Air Pollution Programs
Slate
State Laws
Hazardous Air Pollutants
Permitting Requirements
State Contact(s)
Wl
Wisconsin
Administrative Code,
Chapters NR 400-
493
State lias air toxics program which
regulates approximately 400
compounds. Standards based on
TLV. Emissions commonly
associated with metal finishing are
included. Delegate federal
NESHAP and Title 111 of CAA.
There is a state permitting program. Dual permit
system; permits to construct and operate. State
regulations list exempt equipment, all sources not
specifically exempt require permit application. There
are regulations that pertain to degreasers and
painting operations. No general permits program
established. Title V program has been approved.
Wisconsin Department of
Natural Resources
10I South Webster Street
P.O. Box 7921
Madison, Wl 53707
(608) 266-7718
-------
APPENDIX 2-A
COMPLIANCE CALENDAR FOR FEDERAL CLEAN AIR ACT
REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
CHAPTER 2-AIR El
MISSIONS
Milestone Events
January 1, 1996
Substitute
Significant
New
Alternatives
Program
Use only approved substitutes for ozone-depleting
substances (e.g., 1,1,1 -TCE and CFCs)
2-21 to 2-22
To be determined
Risk management plan
CAA Risk
Management
Program
Rule
Prepare risk management plan to prevent
accidental releases of listed substances
Air quality agency
2-18 to 2-21
Regular or Periodic Events
Other Events
|
Prior to beginning
construction of new
facility or major
modification to
existing facility
Permit
CAAA/PSD
Obtain a construction permit (PSD, Nonattainment
New Source Review, or Minor Construction
Permit)
Air quality agency
2-6 to 2-7
2 to 12 months after
state permit program
is approved by EPA
Permit
CAAA/Title
V
Obtain Title V permit
Air quality agency
2-14 to 2-15
-------
APPENDIX 2-B
GLOSSARY OF TERMS
-------
Air Emissions
Part I, Chapter 2
Emission—The release of pollutants into the air from a source.
Hazardous air pollutants (HAPs)—Chemicals that cause serious health and
environmental effects. Hazardous air pollutants are released by sources such as chemical
plants, dry cleaners, printing plants, and motor vehicles (cars, trucks, buses, etc.).
Major modification—Any physical change or method of operation change at an existing
major stationary source that results in a significant net emissions increase, as defined in
the regulations, of a regulated pollutant.
Major stationary source—A term used to determine the applicability of Prevention of
Significant Deterioration and new source regulations. In a nonattainment area, a major
source is one that has the potential to emit more than 100 tons per year. In PSD areas,
the cutoff level may be either 100 or 250 tons, depending on the type of source.
Maximum Achievable Control Technology (MACT)—Emissions limitations based on
the best demonstrated control technology or practices in similar sources to be applied to
major sources emitting one or more of a listed toxic pollutant.
Mobile sources—Moving objects that release pollution; mobile sources include cars,
trucks, buses, planes, trains, motorcycles, and gasoline-powered lawn mowers.
Monitoring (monitor)—Measurement of air pollution is referred to as monitoring. EPA,
state, and local agencies measure the types and amounts of pollutants in community air.
National Ambient Air Quality Standards (NAAQS)—Standards established by EPA
that apply for outside air throughout the country.
National Emissions Standards for Hazardous Air Pollutants (NESHAP)—Emissions
standards set by EPA for an air pollutant not covered by National Ambient Air Quality
Standards that may cause an increase in deaths or is serious, irreversible, or
incapacitating illness.
Net emissions increase—For an existing facility, the amount of any new emissions
minus reductions in emissions caused by modifications to the facility
New Source Performance Standards (NSPS)—National EPA air emission standards
that limit the amount of pollution allowed from new sources or from modified existing
sources.
Nitrogen oxides (NOx)—A criteria air pollutant. Nitrogen oxides are produced from
burning fuels, including gasoline and coal. Nitrogen oxides are smog-formers; they react
December 1996
2-B2
-------
Air Emissions
Part I, Chapter 2
with volatile organic compounds to form smog. Nitrogen oxides are also major
components of acid rain.
Nonattainment area—A geographic area in which the level of a criteria air pollutant
is higher than the level allowed by the federal standards. A single geographic area may
have acceptable levels of one criteria air pollutant but unacceptable levels of one or more
other criteria air pollutants; thus, an area can be both attainment and nonattainment at
the same time. It has been estimated that 60% of Americans live in nonattainment areas.
Offset—A method used in the 1990 Clean Air Act to give companies that own or
operate large (major) sources in nonattainment areas flexibility in meeting overall
pollution reduction requirements when changing production processes. If the owner or
operator of the source wishes to increase release of a criteria air pollutant, an offset
(reduction of a somewhat greater amount of the same pollutant) must be obtained either
at the same plant or by purchasing offsets from another company.
Operating permit—A permit covering the air pollution requirements for existing
facilities. These permits are typically more comprehensive than construction permits;
air pollution sources typically have only one operating permit for their entire facility.
Operating permits have an expiration date and must be renewed periodically (typically
every 5 years). Operating permits are revised when a source becomes subject to new air
pollution requirements or makes changes to the facility that require the permit to be
updated.
Ozone—A gas which is a variety of oxygen. The oxygen ga.1- found in the air consists of
two oxygeru atoms stuck together; this is molecular oxygen. Ozone consists of three
oxygen atoms stuck together into an ozone molecule. Ozone occurs in nature; it produces
the sharp smell you notice near a lightning strike. High concentrations of ozone gas are
found in a layer of the atmosphere—the stratosphere—high above the Earth.
Stratospheric ozone shields the Earth against harmful rays from the sun, particularly
ultraviolet B. Smog's main component is ozone; this ground-level ozone is a product of
reactions among chemicals produced by burning coal, gasoline, and other fuels, and
chemicals found in products including solvents, paints, hairsprays, etc.
Particulates; particulate matter (PM-10)—A criteria air pollutant. Particulate matter
includes dust, soot and other tiny bits of solid materials that are released into and move
around in the air. Particulates are produced by many sources, including burning of diesel
fuels by trucks and buses, incineration of garbage, mixing and application of fertilizers
and pesticides, road construction, industrial processes such as steelmaking, mining
operations, agricultural burning (field and slash burning), and operation of fireplaces and
woodstoves. Particulate pollution can cause eye, nose and throat irritation and other
health problems.
December 1996
2-B3
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Air Emissions
Part I, Chapter 2
Permit—A document that resembles a license, required by the Clean Air Act for big
(major) sources of air pollution, such as power plants, chemical factories and, in some
cases, smaller polluters. Usually permits will be given out by states, but if EPA has
disapproved part or all of a state permit program, EPA will give out the permits in that
state. The 1990 Clean Air Act specifies requirements for permit applications, including
provisions for members of the public to participate in state and EPA reviews of permit
applications. Permits will have, in one place, information on all the regulated pollutants
at a source. Permits include information on which pollutants are being released, how
much the source is allowed to release, and the program that will be used to meet
pollutant release requirements. Permits are required both for the operation of plants
(operating permits) and for the construction of new plants. The 1990 Clean Air Act
introduced a nationwide permit system for air pollution control.
Permit fees—Fees paid by businesses required to have a permit. Permit fees are like the
fees drivers pay to register their cars. The money from permit fees will help pay for state
air pollution control activities.
Pollutants (pollution)—Unwanted chemicals or other materials found in the air.
Pollutants can harm health, the environment and property. Many air pollutants occur
as gases or vapors, but some are very tiny solid particles: dust, smoke, or soot.
Prevention of Significant Deterioration (PSD)—EPA program in which state and/or
federal permits are required to restrict emissions from new or modified sources in places
where air quality already meets primary and secondary ambient air quality standards.
Primary standard—A pollution limit based on health effects. Primary standards are set
for criteria air pollutants.
Secondary standard—A pollution limit based on environmental effects such as damage
to property, plants, visibility, etc. Secondary standards are set for criteria air pollutants.
Smog—A criteria air pollutant. A mixture of pollutants, principally ground-level ozone,
produced by chemical reactions in the air involving smog-forming chemicals. A major
portion of smog-formers comes from burning petroleum-based fuels such as gasoline.
Other smog-formers, volatile organic compounds, are found in products such as paints
and solvents. Smog can harm health, damage the environment, and cause poor visibility.
Major smog occurrences are often linked to heavy motor vehicle traffic, sunshine, high
temperatures, and calm winds or temperature inversion (weather condition in which
warm air is trapped close to the ground instead of rising). Smog is often worse away from
the source of the smog-forming chemicals, since the chemical reactions that result in
smog occur in the sky while the reacting chemicals are being blown away from their
sources by winds.
December 1996
2-B4
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Air Emissions
Part I, Chapter 2
Source—Any place or object from which pollutants are released. A source can be a
power plant, factory, dry cleaning business, gas station, or farm. Cars, trucks, and other
motor vehicles are sources, and consumer products and machines used in industry can
be sources too.
State implementation plan (SIP)—A detailed description of the programs a state will
use to carry out its responsibilities under the Clean Air Act. State implementation plans
are collections of the regulations used by a state to reduce air pollution. The Clean Air
Act requires that EPA approve each state implementation plan. Members of the public
are given opportunities to participate in review and approval of state implementation
plans.
Stationary source—A place or object from which pollutants are released that does not
move around. Stationary sources include power plants, gas stations, incinerators, houses,
etc.
Stratosphere—Part of the atmosphere of gases that encircle the Earth. The stratosphere
is a layer of the atmosphere 9 to 31 miles above the Earth. Ozone in the stratosphere
filters out harmful sun rays, including a type of sunlight called ultraviolet B, which has
been linked to health and environmental damage.
Sulfur dioxide—A criteria air pollutant. Sulfur dioxide is a gas produced by burning coal,
most notably in power plants. Some industrial processes, such as production of paper and
smelting of metals, produce sulfur dioxide. Sulfur dioxide is closely related to sulfuric
acid, a strong acid. Sulfur dioxide plays an important role in the production of acid rain.
Volatile organic compounds (VOCs)—Organic chemicals all contain the element
carbon (C); organic chemicals are the basic chemicals found in living things and in
products derived from living things, such as coal, petroleum and refined petroleum
products. Many of the organic chemicals we use do not occur in nature, but were
synthesized by chemists in laboratories. Volatile chemicals produce vapors readily; at
room temperature and normal atmospheric pressure, vapors escape easily from volatile
liquid chemicals. Volatile organic chemicals include gasoline, industrial chemicals such
as benzene, solvents such as toluene and xylene, and tetrachloroethylene (perchlo-
roethylene, the principal dry cleaning solvent). Many volatile organic chemicals are also
hazardous air pollutants; for example, benzene causes cancer.
December 1996
2-B5
-------
APPENDIX 2-C
STATE AND TERRITORIAL AIR POLLUTION CONTROL AGENCIES
-------
Air Emissions
Part I, Chapter 2
STATE AND TERRITORIAL AIR POLLUTION CONTROL AGENCIES
Alabama Department of Environmental
Management
Air Division
1751 Dickinson Drive
Montgomery, AL 36130
(205) 271-7861
Alaska Department of Environmental
Conservation
Air Quality Division
410 Willoughby Avenue, Suite 105
Juneau, AK 99801
(907) 465-5260
American Samoa
Environmental Protection Agency
American Samoa Government
Pago Pago, AS 96799
011 (684) 633-2304
Arizona Department of Environmental
Quality
Office of Air Quality
3003 N. Central Avenue
Pho;nix, AZ 85012
(602) 207-2308
Arkansas Department of Pollution Control
and Ecology
Air Division
8001 National Drive
P.O. Box 8913
Little Rock, AR 72219
(501) 562-7444
Secretary of Environmental Affairs
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812
(916) 322-2990
Colorado Department of Health
Air Pollution Control Division
4300 Cherry Creek Drive South
Denver, CO 80222
(303) 692-3100
Connecticut Department of Environmental
Protection
Bureau of Air Management
79 Elm Street
Hartford, CT 06106
(203) 424-3026
Department of Natural Resources and
Environmental Control
Division of Air and Waste Management
89 Kings Highway, P.O. Box 1401
Dover, DE 19903
(302) 739-4764
District of Columbia
Air Resources Management Division
2100 Martin Luther King Ave., SE
Washington, DC 20020
(202) 645-6093
Florida Department of Environmental
Regulation
Air Resources Management
3900 Commonwealth Boulevard
Tallahassee, FL 32399
(904) 488-1344
Georgia Department of Natural Resources
Environmental Protection Division
205 Buder Street, SE
Adanta, GA 30334
(404) 363-7000
December 1996
2-C1
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Air Emissions
Part I, Chapter 2
Guam Environmental Protection Agency
P.O. Box 2999
Agana, Guam 96910
Oil (671) 646-8863
Hawaii State Department of Health
Environmental Management Division
Clean Air Bureau
919 Ala Moana Boulevard
Honolulu, HI 96814
(808) 586-4200
Idaho Health and Welfare Department
450 State Street
P.O. Box 83720
Boise, ID 83720
(208) 334-0520
Illinois Environmental Protection Agency
Division of Air Pollution Control
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794
(217) 782-7326
Indiana Department of Environmental
Management
Air Pollution Control Board
105 S. Meridian Street
P.O. Box 6015.
Indianapolis, IN 46206
(317) 232-5586
Iowa Department of Natural Resources
Air Quality Section
Henry A. Wallace Building
900 E. Grand St.
Des Moines, LA 50319
(515) 281-8852
Kansas Department of Health and
Environment
Air and Radiation
Forbes Field, Building 740
Topeka, ICS 60620
(913) 296-1593
Kentucky Department for Environmental
Protection
Division of Air Quality
Fort Boone Plaza
14 Reilly Road
Frankfort, ICY 40601
(502) 564-3382
Louisiana Department of Environmental
Quality
Office of Air Quality and Radiation Protection
P.O. Box 82231
Baton Rouge, LA 70884
(504) 765-0108
Maine Department of Environmental
Protection
Bureau of Air Quality Control
State House, Station 17
Augusta, ME 04333
(207) 289-2437
Maryland Department of the Environment
Air Management Administration
2500 Broening Highway
Baltimore, MD 21224
(302) 631-3255
Massachusetts Department of
Environmental Protection
Division of Air Quality Control
One Winter Street
Boston, MA 02108
(167) 292-5630
December 1996
2-C2
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Air Emissions
Part I, Chapter 2
Michigan Department of Environmental
Quality
Air Quality Division
Hollister Building
P.O. Box 30260
Lansing, MI 48909-7760
(517) 373-7023
Minnesota Pollution Control Agency
Air Quality Division
520 Lafavette Road North
St. Paul, MN 55155
(612) 296-7331
Mississippi Department of Environmental
Quality
Air Division, Office of Pollution Control
P.O. Box 10385
Jackson, MS 39289
(601) 961-5171
Missouri Department of Natural Resources
Division of Environmental Quality
Air Pollution Control
P.O. Box 176
Jefferson City, MO 65102
(314) 751-4817
Montana Department of Health and
Environmental Science
Air Quality Bureau
Cogswell Building, Room A116
Helena, MT 59620
(406) 444-3454
Nebraska Department of Environmental
Quality
Air Quality Division
Suite 400
1200 N. Street
P.O. Box 98922
Lincoln, NE 68509
(402) 471-0001
Nevada Division of Environmental
Protection
Bureau of Air Quality
123 West Nye Lane
Carson City, NV 89710
(702) 687-4670
New Hampshire Department of
Environmental Services
Air Resources Division
64 N. Main Street, Box 2033
Concord, NH 03302
(603) 271-1370
New Jersey Department of Environmental
Protection
Division of Environmental Quality
Air Program
401 East State Street
Trenton, NJ 08625
(609) 984-6721
New Mexico Environmental Protection
Division
Air Quality Bureau
P.O. Box 26110
Santa Fe, NM 87502
(505) 827-0047
New York Department of Environmental
Conservation
Division of Air Resources
50 Wolf Road
Albany, NY 12223
(518) 457-7230
North Carolina Division of Environmental
Management
Air Quality Section
P.O Box 27687
Raleigh, NC 27611
(919) 733-4984
December 1996
2-C3
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Air Emissions
Part I, Chapter 2
North Dakota State Department of Health
Environmental Health Section
L200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58506
(701) 328-5150
Ohio Environmental Protection Agency
Division of Air Pollution Control
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43215
(614) 644-2270
Oklahoma State Department of
Environmental Quality
Air Quality Division
1000 Northeast 10th Street
Oklahoma City, OIC 73 117
(405) 271-5220
Oregon Department of Environmental
Quality
Air Quality Control Division
811 SW 6th Avenue, 11th Floor
Portland, OR 97204
(503) 229-5397
Pennsylvania Department of Environmental
Protection
Bureau of Air Quality Control
P.O. Box 8766
Harrisburg, PA 17105
(717) 787-9702
Puerto Rico Environmental Quality Board
P.O. Box 11488
San Juan, PR 00910
(671) 767-8056
Rhode Island Department of Environmental
Management
Division of Air and Hazardous Materials
291 Promenade Street
Providence, RI 02908
(401) 277-2808
South Carolina Department of Health and
Environmental Control
Bureau of Air Quality Control
2600 Bull Street
Columbus, SC 29201
(803) 734-4730
South Dakota Department of
Environmental and Natural Resources
Air Program
523 East Capitol Avenue
Pierre, SD 57501
(605) 773-3153
Tennessee Department of Environment and
Conservation
Division of Air Pollution Control
Life and Casualty Tower
401 Church Street, 21st Floor
Nashville, TN 37243
(615) 532-0554
State of Texas
Air Quality Office
12124 Park 35 Circle
Austin, TX 78753
(512) 239-5440
Utah Department of Environmental Quality
Division of Air Quality
168 North 1950 West
Salt Lake City, UT 84116
(801) 536-4022
December 1996
2-C4
-------
Air Emissions
Part I, Chapter 2
Vermont Agency of Natural Resources
Air Pollution Control Division
103 S. Main Street, Building 3 South
Waterbury, VT 05671
(802) 241-3840
Washington State
Department of Ecology
P.O. Box 47600
Olympia, WA 98504
(360) 407-6880
Virgin Islands Department of Planning and
Natural Resources
21-22 Kongens Gade
St. Thomas, VI 00802
(671) 774-3320
State of West Virginia
Air Quality Board
1558 Washington Street East
Charleston, WV 25311
(304) 558-4002
State of Virginia
Environmental Quality Department
629 E. Main Street
P.O. Box 10009
Richmond, VA 23240
(804) 762-4311
Wisconsin Department of Natural
Resources
Bureau of Air Management
Box 7921
Madison, WI 53707
(608) 266-0603
Wyoming Department of Environmental
Quality
Air Quality Division
Hathaway Building, 3rd Floor
2300 Capitol Avenue
Cheyenne, WY 82002
(307) 777-7391
December 1996 2-C5
-------
APPENDIX 4-D
CLEAN AIR REQUIREMENTS WORKSHEET
AND
AIR EMISSIONS INVENTORY WORKSHEET
-------
Air Emissions
Part I, Chapter 2
CLEAN AIR REQUIREMENTS WORKSHEET
Name, address, and phone number of the air pollution control agency for your area:
Hazardous air pollutants used at your facility:
Date your Title V operating permit application is due:
Extremely hazardous substances used at your facility (for risk management planning):
December 1996
2-D1
-------
APPENDIX 2-E
LIST OF 189 HAZARDOUS AIR POLLUTANTS
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
0
Antimony Compounds
0
Arsenic Compounds (inorganic including arsine)
0
Beryllium Compounds
0
Cadmium Compounds
0
Chromium Compounds
0
Cobalt Compounds
0
Coke Oven Emissions
0
Cyanide Compounds
0
Fine mineral fibers
0
Glycol ethers
0
Lead Compounds
0
Manganese Compounds
0
Mercury Compounds
0
Nickel Compounds
0
Polvc. iic Organic Matter
0
Radionuclides (including radon)
0
Selenium Compounds
50-00-0
Formaldehyde
51-28-5
2,4-Dinitrophenol
51-79-6
Ethyl carbamate (Urethane)
53-96-3
2-Acetylaminofluorene
56-23-5
Carbon tetrachloride
56-38-2
Parathion
57-14-7
1,1-Dimethyl hydrazine
57-57-8
beta-Propiolactone
57-74-9
Chlordane
59-89-2
N-Nitrosomorpholine
58-89-9
Lindane (all isomers)
December 1996
2-E1
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
60-11-7
Dimethvl aminoazobenzene
60-34-4
Methyl hydrazine
60-35-5
Acetamide
62-53-3
Aniline
62-73-7
Dichlorvos
62-75-9
N-Nitrosodimethvlamine
63-25-2
Carbarvl
64-67-5
Diethyl sulfate
67-56-1
Methanol
67-66-3
Chloroform
67-72-1
Hexachloroethane
68-12-2
Dimethyl formamide
71-43-2
Benzene (including benzene from gasoline)
71 -55-6
Methyl chloroform (1,1,1 -Trichloroethane)
72-43-5
Methoxychlor
74-83-9
Methyl bromide (Bromomethane)
74-87-3
Methyl chloride (Chloromethane)
74-88-4
Methyl iodide
75-00-3
Ethyl chloride (Chloroethane)
75-01-4
Vinvl chloride
75-05-8
Acetonitrile
75-07-0
Acetaldehvde
75-09-2
Methylene chloride (Dichloromethane)
75-15-0
Carbon disulfide
75-21-8
Ethylene oxide
75-25-2
Bromoform
75-34-3
Ethvlidene dichloride (1,1 -Dichloroethane)
75-35-4
Vinvlidene chloride (1,1 -Dichloroethvlene)
December 1996
2-E2
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
75-44-5
Phosgene
75-55-8
1,2-Propylenimine (2-MethyI aziridine)
75-56-9
Propylene oxide
76-44-8
Heptachlor
77-47-4
Hexachlorocyclopentadiene
77-78-1
Dimethvl sulfate
78-59-1
Isophorone
78-87-5
Propylene dichloride (1,2-Dichloropropane)
78-93-3
Methyl ethyl ketone (2-Butanone)
79-00-5
1,1,2-Trichloroethane
79-01-6
T richloroethylene
79-06-1
Acrvlamide
79-10-7
Acrylic acid
79-11-8
Chloroacetic acid
79-34-5
1,1,2.2-Tetrachloroethane
79-44-7
Dimethyl carbamoyl chloride
79-46-9
2-Nitropropane
80-62-6
Methyl methaaylate
82-68-8
Pentachloronitrobenzene (Quintobenzene)
84-74-2
Dibutylphthalate
85-44-9
Phthalic anhydride
87-68-3
Hexachlorobutadiene
87-86-5
Pentachlorophenol
88-06-2
2,4,6-T richlorophenol
90-04-0
o-Anisidine
91-20-3
1
Naphthalene
91-22-5
Quinoline
91-94-1
3.3-Dichlorobenzidene
December 1996
2-E3
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
92-52-4
Biphenvl
92-67-1
4-Aminobiphenvl
92-87-5
Benzidine
92-93-3
4-Nitrobiphenvl
94-75-7
2,4-D, salts and esters
95-47-6
o-Xylenes
95-48-7
o-Cresol
95-53-4
o-Toluidine
95-80-7
2,4-ToIuene diamine
95-95-4
2,4,5-TrichIorophenol
96-09-3
Stvrene oxide
96-12-8
1,2-Dibromo-3-chloropropane
96-45-7
Ethylene thiourea
98-07-7
Benzotrichloride
58-82-8
Cumene
98-86-2
Acetophenone
98-95-3
Nitrobenzene
100-02-7
4-Nitrophenol
100-41-4
Ethyl benzene
100-42-5
Styrene
100-44-7
Benzyl chloride
101-14-4
4,4-Methylene bis(2-chloroaniline)
101-68-8
Methylene diphenyl diisocyanate (MDI)
101-77-9
4,4'/-i-Methylenedianiline
105-60-2
Caprolactam
106-42-3
p-Xvlenes
106-44-5
p-Cresol
106-46-7
1,4-Dichlorobenzene(p)
December 1996
2-E4
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Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number0
CAS No.
Chemical name
106-50-3
p-Phenvlenediamine
106-51-4
Quinone
106-88-7
1,2-Epoxybutane
106-89-8
Epichlorohvdrin (I-Chloro-2,3-epoxypropane)
106-93-4
Ethylene dibromide (Dibromoethane)
106-99-0
1,3-Butadiene
107-02-8
Acrolein
107-05-1
Allvl chloride
107-06-2
Ethvlene dichloride (1,2-Dichloroethane)
107-13-1
Acrylonitrile
L07-21-I
Ethylene glycol
107-30-2
Chloromethyl methyl ether
108-05-4
Vinyl acetate
108-10-1
Methvl isobutyl ketone (Hexone)
108 31-6
M.ileic anhydride
108-38-3
m-Xvlenes
108-39-4
m-Cresol
108-88-3
Toluene
108-90-7
Chlorobenzene
108-95-2
Phenol
1 10-54-3
Hexane
1 11-42-2
Diethanolamine
111-44-4
Dichloroethyl ether (Bis(2-chloroethyl)ether)
114-26-1
Propoxur(Bavgon)
117-81-7
Bis(2-ethvlhexvl)phthalate (DEHP)
118-74-1
Hexachlorobenzene
1 [9-90-4
3.3-Dimethoxvbenzidine
119-93-7
3.3'A-Dimethvl benzidine
i :
December 1996
2-E5
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
120-80-9
Catechol
120-82-1
1,2,4-Trichlorobenzene
121-14-2
2,4-Dinitrotoluene
121-44-8
Triethylamine
121-69-7
N,N-Diethvl aniline (N,N-Dimethylaniline)
122-66-7
1,2-Diphenylhydrazine
123-31-9
Hydroquinone
123-38-6
Propionaldehyde
123-91-1
1,4-Dioxane (1,4-Diethyleneoxide)
126-99-8
Chloroprene
127-18-4
TetracKloroethylene (Perchloroethylene)
131-11-3
Dimethyl phthalate
132-64-9
Dibenzofurans
133-06-2
Captan
133-90-4
Chloramben
140-88-5
Ethyl acrylate
151-56-4
Ethylene imine (Aziridine)
156-62-7
Calcium cyanamide
302-01-2
Hydrazine
334-88-3
Diazomethane
463-58-1
Carbonyl sulfide
510-15-6
Chlorobenzilate
532-27-4
2-Chloroacetophenone
534-52-1
4,6-Dinitro-o-cresol, and salts
540-84-1
2,2,4-T rimethylpentane
542-75-6
1,3-Dichloropropene
542-88-1
Bis(chloromethvl)ether
584-84-9
2,4-Toluene diisocvanate
December 1996
2-E6
-------
Air Emissions
Part I, Chapter 2
Table 2-E1 List of 189 Hazardous Air Pollutants by CAS Number3
CAS No.
Chemical name
593-60-2
Vinyl bromide
624-83-9
Methyl isocyanate
680-31-9
Hexamethylphosphoramide
684-93-5
N-Nitroso-N-methvlurea
822-06-0
Hexamethylene-1,6-diisocyanate
1 120-71-4
1,3-Propane sultone
1319-77-3
Cresols/Cresylic acid (isomers and mixture)
1330-20-7
Xylenes (isomers and mixture)
1332-21-4
Asbestos
1336-36-3
Polvchlorinated biphenvls (Aroclors)
1582-09-8
Trifluralin
1634-04-4
Methyl tert butyl ether
1746-01-6
2,3.7,8-Tetrachlorodibenzo-p-dioxin
3547-04-4
DDE
7550-45-0
Titanium tetrachloride
7647-01-0
Hydrochloric acid
7664-39-3
Hydrogen fluoride (Hydrofluoric acid)
7723-14-0
Phosphorus
7782-50-5
Chlorine
7803-51-2
Phosphine
8001-35-2
Toxaphene (chlorinated camphene)
'Those substances typically used in the metal finishing industry are highlighted.
December 1996
2-E7
-------
Air Emissions
Part I, Chapter 2
Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
75-07-0
Acetaldehyde
60-35-5
Acetamide
75-05-8
Acetonitrile
98-86-2
Acetophenone
53-96-3
2-Acetylaminofluorene
107-02-8
Acrolein
79-06-1
Acrvlamide
79-10-7
Acrylic acid
107-13-1
Acrvlonitrile
107-05-1
Allyl chloride
92-67-1
Aminobiphenvl
62-53-3
Aniline
90-04-0
o-Anisidfne
0
Antimony Compounds
0
Arsenic Compounds (inorganic including arjine)
1332-21-4
Asbestos
71-43-2
Benzene (including benzene from gasoline)
92-87-5
Benzidine
98-07-7
Benzotrichloride
100-44-7
Benzyl chloride
0
Beryllium Compounds
92-52-4
Biphenyl
117-81-7
Bis(2-ethylhexyl)phtlialate (DEHP)
542-88-1
Bis(chloromethvl)ether
75-25-2
Bromoform
106-99-0
1,3-Butadiene
0
Cadmium compounds
156-62-7
Calcium cyanamide
December 1996
2-E8
-------
Air Emissions
Part I, Chapter 2
Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
105-60-2
Caprolactam
133-06-2
Captan
63-25-2
Carbaryl
56-23-5
Carbon tetrachloride
75-15-0
Carbon disulfide
463-58-1
Carbonvl sulfide
120-80-9
Catechol
133-90-4
Chloramben
57-74-9
Chlordane
7782-50-5
Chlorine
79-11-8
Chloroacetic acid
532-27-4
2 -Chloroacetophenone
108-90-7
Chlorobenzene
510-15-6
Chlorobenzilate
67-66-3
Chloroform
107-30-2
Chloromethyl methyl ether
126-99-8
Chloroprene
0
Chromium Compounds
0
Cobalt Compounds
0
Coke Oven Emissions
108-39-4
m-Cresol
95-48-7
o-Cresol
106-44-5
p-Cresol
1319-77-3
Cresols/Cresylic acid (isomers and mixture)
98-82-8
Cumene
0
Cyanide Compounds
94-75-7
2,4-D, salts and esters
3547-04-4
DDE
December 1996
2-E9
-------
Air Emissions
Part I, Chapter 2
I Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
334-88-3
Diazomethane
132-64-9
Dibenzofurans
96-12-8
1,2-Dibromo-3-chloropropane
84-74-2
Dibutylphthalate
106-46-7
1,4-Dichlorobenzene(p)
91-94-1
3,3-Dichlorobenzidene
111-44-4
Dichloroethyl ether (Bis(2-chloroethyl)ether)
542-75-6
1,3-Dichloropropene
62-73-7
Dichlorvos
111-42-2
Diethanolamine
121-69-7
N.N-Diethyl aniline (N,N-Dimethylaniline)
64-67-5
Diethyl sulfate
119-90-4
3,3-Dimethoxybenzidine
60-11-7
Dimethyl aminoazobenzene
11C-93-7
3,3'/4-Dimethyl benzidine
79-44-7
Dimethyl carbamoyl chloride
68-12-2
Dimethyl formamide
57-14-7
1,1-Dimethyl hydrazine
534-52-1
4,6-Dinitro-o-cresol, and salts
51-28-5
2,4-Dinitrophenol
121-14-2
2,4-Dinitrotoluene
123-91-1
1,4-Dioxane (1,4-Diethyleneoxide)
122-66-7
1,2-Diphenylhvdrazine
106-89-8
Epichlorohydrin (l-Chloro-2,3-epoxypropane)
106-88-7
1,2-Epoxybutane
140-88-5
Ethyl acrvlate
100-41-4
Ethvl benzene
51-79-6
Ethvl carbamate (L'rethane)
December 1996
2-E10
-------
Air Emissions
Part I, Chapter 2
Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants0
CAS No.
Chemical name
75-00-3
Ethyl chloride (Chloroethane)
106-93-4
Ethylene dibromide (Dibromoethane)
107-06-2
Ethylene dichloride (1,2-Dichloroethane)
107-21-L
Ethylene glycol
151-56-4
Ethylene imine (Aziridine)
75-21-8
Ethylene oxide
96-45-7
Ethylene thiourea
75-34-3
Ethvlidene dichloride (1,1 -Dichloroethane)
0
Fine mineral fibers
50-00-0
Formaldehyde
0
Glycol ethers
76-44-8
Heptachior
118-74-1
H exachlorobenzene
87-68-3
Hexachlorobutadiene
77-47-4
Hexachlorocyclopentadiene
67-72-1
Hexachloroethane
822-06-0
Hexamethylene-1,6-diisocyanate
680-31-9
Hexamethylphosphoramide
110-54-3
Hexane
302-01-2
Hydrazine
7647-01-0
Hydrochloric acid
7664-39-3
Hydrogen fluoride (Hydrofluoric acid)
123-31-9
Hydroquinone
78-59-1
Isophorone
0
Lead Compounds
58-89-9
Lindane (all isomers)
108-31-6
Maleic anhydride
0
Manganese Compounds
December 1996
2-E11
-------
Air Emissions
Part I, Chapter 2
Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
0
Mercury Compounds
67-56-1
Methanol
72-43-5
Methoxvchlor
74-83-9
Methyl bromide (Bromomethane)
74-87-3
Methyl chloride (Chloromethane)
71-55-6
Methyl chloroform (1,1,1 -Trichloroethane)
78-93-3
Methyl ethyl ketone (2-Butanone)
60-34-4
Methyl hydrazine
74-88-4
Methyl iodide
108-10-1
Methyl isobutvl ketone (Hexone)
624-83-9
Methyl isocyanate
80-62-6
Methyl methacrylate
1634-04-4
Methyl tert butyl ether
101-14-4
4,4-Methylene bis(2-chloroaniline)
75-09-2
Methylene chloride (Dichloromethane)
101-68-8
Methylene diphenyl diisocyanate (MDI)
101-77-9
4,4'/4-Methylenedianiline
91-20-3
Naphthalene
0
Nickel Compounds
98-95-3
Nitrobenzene
92-93-3
4-Nitrobiphenvl
100-02-7
4-Nitrophenol
79-46-9
2-Nitropropane
62-75-9
N-Nitrosodimethylamine
684-93-5
N-Nitroso-N-methvlurea
59-89-2
N-Nitrosomorpholine
56-38-2
Parathion
82-68-8
Pentachloronitrobenzene (Quintobenzene)
December 1996
2-E12
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Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
87-86-5
Pentachlorophenol
108-95-2
Phenol
106-50-3
p-Phenylenediamine
75-44-5
Phosgene
7803-51-2
Phosphine
7723-14-0
Phosphorus
85-44-9
Phthalic anhydride
1336-36-3
Polvchlorinated biphenyls (Aroclors)
0
Polycylic Organic Matter
1120-71-4
1,3-Propane sultone
57-57-8
beta-Propiolactone
123-38-6
Propionaldehyde
114-26-1
Propoxur(Baygon)
78-87-5
Propylene dichloride (1,2-Dichioropropane)
75-56-9
Propylene oxide
75-55-8
1,2-Propylenimine (2-Methyl aziridine)
91-22-5
Quinoline
106-51-4
Quinone
0
Radionuclides (including radon)
0
Selenium Compounds
100-42-5
Stvrene
96-09-3
Styrene oxide
1746-01-6
2,3,7,8-T etrachlorodibenzo-p-dioxin
79-34-5
1,1,2,2-Tetrachloroethane
127-18-4
Tetrachloroethylene (Perchloroethylene)
7550-45-0
Titanium tetrachloride
95-80-7
2,4-Toluene diamine
584-84-9
2,4-Toluene diisocvanate
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Part I, Chapter 2
Table 2-E2 Alphabetical List of 189 Hazardous Air Pollutants3
CAS No.
Chemical name
108-88-3
Toluene
95-53-4
o-Toluidine
8001-35-2
Toxaphene (chlorinated camphene)
120-82-1
1,2,4-Trichlorobenzene
79-00-5
1,1,2-Trichloroethane
79-01-6
T richloroethylene
95-95-4
2,4,5 -T richlorophenol
88-06-2
2,4,6-Trichlorophenol
121-44-8
Triethylamine
1582-09-8
Trifluralin
540-84-1
2,2,4-T rimethvlpentane
108-05-4
Vinyl acetate
593-60-2
Vinyl bromide
75-01-4
Vinyl chloride
75-35-4
Vinylidene chloride (1,1 -Dichloroethylene)
1330-20-7
Xylenes (isomers and mixture)
108-38-3
m-Xylenes
95-47-6
o-Xvlenes
106-42-3
p-Xylenes
'Those substances typically used in the metal finishing industry are highlighted.
December 1996
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APPENDIX 2-F
SUMMARIES OF THREE NESHAP STANDARDS:
Chromium Emissions From Hard and Decorative
Electroplating and Anodizing Operations
Halogenated Solvent Cleaning Machines
Aerospace Manufacturing and Rework Facilities
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Air Emissions
Part I, Chapter 2
NESHAP Standard for Chromium Emissions From Hard and Decorative
Electroplating and Anodizing Operations1
On January 25, 1995, EPA issued a final rule to reduce air toxics emissions from
chromium electroplating and anodizing operations. All existing sources performing hard
chromium electroplating and chromium anodizing must comply with the emission
limitations in the rule by January 25, 1997. All existing sources performing decorative
chromium electroplating must comply with the emission limitations by January 25,
1996. All new and reconstructed sources must comply immediately upon startup.
The final rule will reduce emissions of chromium, an air toxic, by 173 tons annually,
representing a 99% reduction. There is strong evidence that hexavalent chromium
causes lung cancer in humans.
An estimated 1,500 hard chromium electroplating facilities, 2,800 decorative chromium
electroplating facilities, and 700 chromium anodizing facilities nationwide will be
affected by this regulation. Hard chromium electroplated parts include large cylinders
and industrial rolls used in construction equipment and in printing presses; decorative
chromium plated parts include appliances such as toasters, various hand tools, and
automotive parts; anodized parts include miscellaneous aircraft parts, including wings
and landing gears. The vast majority of the facilities covered by this rule electroplate
parts for other industry manufacturers.
A major source is any chror.iium electroplating or anodizing operation that emits more
than 9.1 megagrams ot chromium compounds per year (Mg/yr) [10 tons per year
(ton/yr)]. Sources that emit less than this cutoff value are considered area sources. The
majority of all chromium electroplating and anodizing sources are considered to be area
sources.
What Does the Final Standard Require?
¦ Owners or operators of new hard chromium electroplating tanks must meet an
emission limit of 0.015 milligrams of total chromium per dry standard cubic
meter (mg'dscm) (6.6 x 10"6 grain per dry standard cubic foot [gr/dscf]) of
ventilation air. This standard is based on the application of the composite
mesh-pad system.
¦ Owners or operators of existing hard chromium electroplating tanks at facilities
with maximum cumulative potential rectifier capacities less than 60 million
'This standard (40 CFR Part 63, Subpart N) was published Ln the Federal Register on January 25, 1995 (60 FR 4963), with
corrections on June 27, 1995 (6C FR 33122).
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ampere-hours per year (Ah/yr) are required to meet an emission limit of 0.03
mg/dscm (1.3 x 10° gr/dscf), which is based on the application of packed-bed
scrubbers.
¦ Owners or operators of existing hard chromium electroplating tanks at facilities
with maximum cumulative potential rectifier capacities greater than or equal to
60 million Ah/yr are required to meet an emission limit of 0.015 mg/dscm (6.6 x
10'6 gr/dscf), which is based on the use of the composite mesh-pad system.
¦ All new and existing decorative chromium electroplating tanks that use a chromic
acid plating process are required to 1) meet a total chromium emission limit of
0.01 mg/dscm (4.4 x 10"6 gr/dscf) or 2) use a wetting agent type fume suppressant
in the plating bath and maintain a bath surface tension no greater than 45 dynes
per centimeter (dynes/cm) (3.1 x 10"3 pound force per foot [lbf/ft]).
¦ All new and existing decorative chromium electroplating operations that use a
trivalent chromium plating process that incorporates a wetting agent are required
to notify EPA that the trivalent chromium process is being used, and must provide
the bath components that comprise the trivalent chromium bath. Subsequent
notification is required if a change is made to the bath such that a different
standard applies to the tank.
¦ All new and existing chromium anodizing operations are required to 1) meet an
emission limit of 0.01 mg'dscm (4.4 x 10"6 gr/dscf) or 2) use a wetting agent type
fume suppressant in the plating bath and maintain a surface tension of no greater
than 45 dynes/cm (3.1 x 103 lbf7ft).
Monitoring Requirements
¦ All owners or operators must conduct an initial performance test to demonstrate
compliance with the emission limit unless the affected source is a decorative
chromium electroplating or chromium anodizing tank that uses a wetting agent
type fume suppressant and maintains a surface tension of no greater than 45
dynes/cm (3.1 x 10'3 Ibf/ft). During a performance test, the owner or operator
must establish values for an operating parameter (e.g., pressure drop) that is
subsequently monitored on a daily basis to ensure continued compliance. In the
case of packed-bed scrubbers, pressure drop across the unit and the velocity
pressure at the inlet to the control device must be monitored on a daily basis. In
the case of composite mesh-pad and fiber-bed mist eliminator systems, pressure
drop across the unit must be monitored on a daily basis. Operation of a control
device outside of the operating parameter value ranges established in accordance
with the rule is a violation of the standard.
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¦ All owners or operators that choose to comply with the emission limit by using a
foam blanket must conduct an initial performance test to demonstrate compliance
with the standard. Ongoing compliance must be demonstrated by maintaining
a foam blanket thickness of 2.5 centimeters (Uinch), or alternate thickness as
established during the performance test. Foam blanket thickness is initially to be
measured and recorded at least once every hour during tank operation.
Monitoring frequency can decrease to once every 8 hours of tank operation, as
allowed by the rule. Operation of the electroplating or anodizing tank below the
acceptable foam blanket thickness constitutes noncompliance with the standard.
¦ All owners or operators that choose to comply with the surface tension
requirements must either establish system-specific surface tension limits through
a performance test or adhere to the limits established by the standards. Surface
tension must initially be measured and recorded at least once every 4 hours during
tank operation. Monitoring frequency can decrease to once every 40 hours of
tank operation, as allowed by the rule. Operation of the electroplating or
anodizing tank above the acceptable surface tension constitutes noncompliance
with the standards.
¦ Work practice standards require all owners or operators of affected tanks to
prepare and follow an operation and maintenance plan to ensure that equipment
or process malfunctions due to poor maintenance or other performance conditions
do not occur.
¦ Operation and maintenance plans require the following: a standardized checklist
to document the inspection and maintenance of the equipment, a systematic
procedure for identifying malfunctions, and procedures to be followed to ensure
that equipment or process malfunctions due to poor maintenance or other
preventable conditions do not occur. Owners/operators must perform quarterly
inspections of the add-on air pollution control devices and monitoring equipment
expected to be used to comply with the standards.
Recordkeeping/Reporting
¦ The owner/operator of a tank that uses an add-on air pollution control device to
meet an emission standard is required to maintain records of inspections and
maintenance, daily velocity pressure and/or pressure drop readings, and any
emission tests at the facility. All records should be maintained for a minimum of
5 years. Each inspection record would identify the device inspected and include
the following: the date and approximate time of inspection, a brief description of
the working condition of the device during the inspection, and any actions taken
to correct deficiencies found during the inspection.
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¦ The owner/operator of a tank that uses a fume suppressant to comply with the
standard is required to maintain the following records at the facility for at least
5 years: the date and time of fume suppressant maintenance additions; the
surface tension of the bath or measurements of foam blanket thickness, as
applicable; and any emission tests to assure compliance with the standard. Each
record of a surface tension measurement should identify the tank and include the
date, approximate time, and measured surface tension. Each record of a foam
blanket thickness measurement should identify the tank and include the date,
approximate time, and measured thickness.
¦ The owner/operator of a tank that uses a trivalent chromium plating process that
incorporates a wetting agent is required to maintain records of the bath chemicals
purchased, with the wetting agent clearly identified as a bath component, for at
least 5 years.
¦ All owners or operators of affected tanks are required to submit an initial
notification that the source is subject to the standards no later than 180 davs after
the effective date (January 25, 1995). A notification of compliance status,
including the results of performance tests, must be submitted by all owners and
operators no later than 90 days after the completion of the performance
demonstration, or no later than 30 days after the compliance date if no
performance test is required by the rule.
¦ All owners or operators of any affected source, other than a decorative chromium
electroplating tank that uses a trivalent chromium plating process, that is located
at a major source site must submit semiannual reports of the ongoing compliance
status. If the affected source is located at an area source site, an ongoing
compliance status report must be prepared annually and maintained onsite.
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NESHAP Standard for Halogenated Solvent Cleaning Machines2
EPA has issued a NESHAP standard for degreasers (batch vapor and in-line solvent
cleaning machines using halogenated solvents). This standard went into effect on
December 2, 1994. Existing equipment must conform to this standard by December 2,
1997, and equipment whose construction or reconstruction was started after November
29, 1993, must conform when brought into operation.
The standard limits emissions from affected sources of the following halogenated
hazardous air pollutant (HAP) solvents: methylene chloride, perchloroethylene,
trichloroethylene, 1,1,1,-trichloroethane, carbon tetrachloride, and chloroform.
The standards for halogenated HAP solvent cleaning machines apply to each individual
solvent cleaning machine that uses any solvent containing methylene chloride,
perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or
chloroform, or any combination of these halogenated HAP solvents, in a total
concentration that is greater than 5 percent by weight.
What Does the Final Standard Require?
The rule requires that a facility comply with either equipment standards or emissions
limitations. A summary of the equipment standards option is presented in Box 2-F1.
Each owner or operator electing to comply with the equipment standard can either install
one of the control combinations listed in Box 2-F1 or demonstrate that the cleaning
machine can meet the indicated idling mode emission limits. No idling standard is
proposed for batch cold cleaning machines.
As an alternative to complying with the equipment standards option, each owner or
operator of batch vapor or in-line cleaning machines may elect to comply by
demonstrating that each solvent cleaning machine emits less than the overall solvent
emissions limit specified in the standards. No alternative emission standards are
proposed for batch cold cleaning machines.
The overall solvent emissions limits are as follows:
¦ For batch vapor solvent cleaning machines, 150 kg/square meter-month
¦ For existing in-line solvent cleaning machines, 153 kg/square meter-month
¦ For new in-line solvent cleaning machines, 99 kg^square meter-month
JThis standard (40 CFR Part 63, Subpart T) was published in the Federal Register on December 2, 1994 (59 FR 61801).
December 1996 2-F5
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Compliance Determinations
¦ Continuous compliance: Continuous compliance is determined through periodic
monitoring of process parameters. For batch vapor and in-line cleaning machines
complying with the equipment standard, monitoring of individual controls is
required. In the case where the owner or operator of a batch vapor or in-line
cleaning machine elects to comply with the alternative standards, compliance is
determined by solvent consumption records and materials balance calculations of
overall solvent emissions. Monitoring is not required for owners or operators of
batch cold cleaning machines.
¦ Performance tests: Performance tests are required only if the idling emission limit
standards are being used to comply with the rule and no vendor-supplied test is
available for the specific model cleaning machine. The initial performance test
demonstrates compliance with the idling standard and establishes monitoring
parameters to demonstrate continued compliance.
¦ Work practice standards: If required by the EPA Administrator during an
inspection, owners or operators of batch vapor and in-line cleaning machines must
demonstrate knowledge of work practices and proper solvent cleaning machine
operation by taking and passing an operator test. An operator test is not required
for owners or operators of batch cold cleaning machines.
Monitoring
¦ For owners or operators of batch vapor or in-line cleaning machines electing to
comply with the equipment-based standards, periodic monitoring of each control
device is required. Weekly monitoring is required for the freeboard refrigeration
device and super heated vapor system. When reducing room draft by controlling
room parameters, the parameters must be monitored weekly, while the actual
measurement of the windspeed must be done quarterly. Monthly monitoring is
required for controls less likely to vary in effective operation; such as a cover, hoist
speed, or reducing room draft by using an enclosure. The frequency of hoist
monitoring reduces to quarterly after a year of operation without an exceedance,
or if an owner or operator can demonstrate that the hoist speed cannot exceed the
specified limit. Monitoring is not required for owners or operators of batch cold
cleaning machines.
¦ For owners or operators of batch vapor or in-line cleaning machines electing to
comply with the alternative standards, dates and amounts of solvent that is added
to the solvent tank must be monitored, as well as the solvent composition of
wastes removed from the cleaning machines. (An equation is provided for
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facilities that do not routinely monitor solvent content of wastes.) This
information is used to determine the overall solvent emissions.
Reporting and Recordkeeping
¦ One-time—All owners and operators of solvent cleaning machines are required to
submit an initial notification report. The initial notification report must include
information on each solvent cleaning machine and control equipment, and the
yearly estimated consumption of each halogenated HAP solvent used. For
existing solvent cleaning machines, the initial notification report was due 270
days after this rule's promulgation date of December 2, 1994. New sources for
which construction or reconstruction had commenced and initial startup had not
occurred before the date of promulgation of this standard must submit the initial
report as soon as practicable before startup but no later than 60 days after the
date of promulgation of the standard. New sources for which the construction or
reconstruction began after the date of promulgation of this standard were required
to submit the initial notification as soon as practicable before the construction or
reconstruction is planned to commence.
¦ All owners or operators of solvent cleaning machines are also required to submit
a compliance report. The compliance report must show that the provisions of the
regulation are being met, including identifying which standards are being used to
comply with this regulation. For existing solvent cleaning machines, the
compliance report must be submitted 150 days after the compliance date for
existing solvent cleaning machines. For new solvent cleaning machines, the
compliance report must be submitted 150 days after startup. If the owner or
operator of a batch vapor or in-line cleaning machine elects to comply with the
idling emission limit standards, a test report is required as part of the initial
compliance report.
¦ Annually—Owners or operators of batch vapor or in-line cleaning machines are
required to submit a yearly compliance report. Owners or operators who choose
to comply with the equipment standards are required to maintain records of
control device monitoring on-site. These records are to include a list of control
equipment used, the parameters that were monitored, and the results of the
control equipment monitoring. Those owners or operators that choose to comply
with the alternative standards are required to submit annual reports that include
the average monthly solvent consumption and the overall solvent emissions
estimates calculated each month. Batch cold cleaning machines are not required
to submit an annual compliance report. Batch cold cleaning machines located at
nonmajor sources are exempt from Title V permitting requirements.
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¦ Periodic—Owners or operators of batch vapor or in-line solvent cleaning machines
are required to submit a biannual exceedance report. If an exceedance occurs this
report must be submitted quarterly. This includes exceeding equipment
parameter requirements and the overall solvent emissions limit. An exceedance
of some equipment parameter requirements occurs if, within 15 days from an
exceedance of a monitored parameter, the monitored equipment parameter
requirement is not met. Exceedance of other equipment parameters occurs at the
moment the parameter is exceeded. An exceedance in the overall solvent
emissions limit occurs at the moment the limit is exceeded.
Permitting Requirements
¦ All cleaning machines located at a major source need to apply for a permit within
12 months after the approval of a Tide V operating permit program for that state.
Cleaning machines (except cold batch) located at area sources need to apply for
a permit 42 months (3'/2 years) after the approval of a Title V operating permit
program and obtain a permit within 5 years of the approval of a Title V operating
permit program. All cold batch cleaning machines located at nonmajor sources
are exempt from Title V permitting requirements.
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Box 2-F1 Control Combinations or Idling Limit Alternatives for Solvent
Cleaning Machines[allbI
Cleaning Machine
Idling Limits
Type/Size
(kg/hr per m2
(m2 Solvent/Air
Solvent/Air
Interface Area)
Control Combination Options
Interface Area)
Batch vapor cleaning
Working-mode cover, freeboard ratio of 1.0,
0.22
machines (<.1.21 m2)
super heated vapor.
Freeboard refrigeration device, super heated
vapor.
Working-mode cover, freeboard refrigeration
device.
Reduced room draft, freeboard ratio of 1.0, super
heated vapor.
Freeboard refrigeration device, reduced room
draft.
Freeboard refrigeration device, freeboard ratio of
1.0.
Freeboard refrigeration device, dwell.
Reduced room draft, dwell, freeboard ratio of
; 0.
Freeboard refrigeration device, carbon adsorber.
Freeboard ratio of 1.0, super heated vapor,
carbon adsorber.
Batch vapor cleaning
Working-mode cover, freeboard refrigeration
0.22
machines (> 1.2 m2)
device, super heated vapor.
Freeboard refrigeration device, reduced room
draft, super heated vapor.
Freeboard refrigeration device, freeboard ratio of
1.0, super heated vapor.
Reduced room draft, freeboard ratio of 1.0, super
heated vapor.
Freeboard refrigeration device, reduced room
draft, freeboard ratio of 1.0.
Freeboard refrigeration device, reduced room
draft, dwell.
Freeboard refrigeration device, superheated
vapor, carbon adsorber.
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Box 2-F1 Control Combinations or Idling Limit Alternatives for Solvent
Cleaning Machines[aI[bl
Cleaning Machine
Type/Size
(m2 Solvent/Air
Interface Area)
Control Combination Options
Idling Limits
(kg/T»r per m2
Solvent/Air
Interface Area)
All batch cold cleaning
machines
Cover, water laver.
Cover, freeboard ratio of 0.75.
Cover, remote reservoir.
N/A
All existing in-line cleaning
machines
Superheated vapor, freeboard ratio of 1.0.
Freeboard refrigeration device, freeboard ratio of
1.0.
Dwell, freeboard refrigeration device.
Dwell, carbon adsorber.
0.10
All new in-line cleaning
machines
Superheated vapor, freeboard refrigeration
device.
Freeboard refrigeration device, carbon adsorber.
Superheated vapor, carbon adsorber.
0.10
Eajn owner or operator of a solvent cleaning machine would adopt one of the control
combinations listed in Table 1 or demonstrate that their solvent cleaning machine can achieve and
maintain specified idling emissions limits (kj^hr per m2 of solvent/air interface area).
[b| In addition to the listed control equipment in Table 1, all batch vapor and in-line cleaning
machines are required to have an automated hoist and an idling-mode cover.
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Aerospace Manufacturing and Rework NESHAP
EPA has promulgated a NESHAP standard for aerospace manufacturing and rework
facilities. This standard went into effect on September 1, 1995. Owners or operators
of all commercial, civil, or military aerospace original equipment manufacturing (OEM)
and rework operations with an initial startup date before September 1, 1998 that are
subject to the emission standard are required to comply with the control requirements
of the standard within 3 years from September 1, 1995. Owners or operators of new
commercial, civil, or military aerospace OEM and rework operations with initial startup
after September 1, 1998 must comply with all requirements upon startup.
The hazardous air pollutants (HAPs) covered by the rule include chromium, cadmium,
methylene chloride, toluene, xylene, methyl ethyl ketone, ethylene glycol, and glycol
ethers. The rule will reduce HAP emissions from at least 2,869 major source aerospace
manufacturing and rework facilities by approximately 112,600 megagrams (123,700
tons).
A major source is any aerospace manufacturing or rework facility that emits or has the
potential to emit (considering controls) 9.1 megagrams per year (10 tons per year) or
more of any hazardous air pollutant or 22.7 megagrams per year (25 tons per year) of
any combination of hazardous air pollutants.
All aerospace manufacturing and rework facilities classified as a major source must meet
the following control requirements for each of the processes noted below.
Cleaning
Several types of operations are used to clean aerospace vehicles or vehicle parts.
¦ Hand-wipe and flush cleaning operations must use cleaning solvents with a
vapor pressure of less than 45 mm mercury or cleaning agents included on the
list of approved solvents identified in the final rule. Incentives, such as reduced
recordkeeping requirements, serve to encourage the use of cleaning agents
included on the approved list.
¦ Facilities are required to use closed containers for storing cleaning agents.
Solvent-laden rags must be placed in bags or other closed containers immediately
after use. The bags or containers must contain the vapors of the cleaning agent.
This standard (40 CFR Part 63, Subpart GG) was published in the Federal Register on September 1, 1995 (60 FR 45947).
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¦ Owners or operators must implement handling and transfer procedures to
minimize spills during filling and transferring of the cleaning agent to or from
enclosed systems, vats, waste containers, and other cleaning operations equipment
that hold or store fresh or used cleaning agents.
¦ In addition to these general cleaning requirements, the regulation requires specific
work practices during the cleaning of spray guns and coating lines and during the
flush cleaning of parts and components.
Primers and Topcoats
Primers are coatings applied to aerospace vehicles or parts to protect the surface.
Topcoats are also coatings, but are applied on top of the primers for functional or
decorative purposes.
¦ Emissions from primers are limited to 2.9 pounds of hazardous air pollutants per
gallon of primer (not including water) during application; and emissions from
topcoats are limited to 3.5 pounds of hazardous air pollutants per gallon of
topcoat (not including water) during application. VOC emissions are limited to
the same levels (not including water and exempt solvents). These emission
reductions can be achieved by using low solvent coatings, abatement equipment
or emissions averaging between like categories of coating (i.e., high HAP topcoats
with low HAP topcoats).
¦ An equipment standard for the application of primers and topcoats requires the
use of one of the following application techniques, except for certain specified
limited exceptions: flow coat, roll coat, brush coat, dip coat, electrostatic
attraction, or high-volume low-pressure (HVLP) spray guns. All application
techniques must operate properly and be maintained at all times.
¦ To reduce emissions of inorganic hazardous air pollutants (mainly chromium and
cadmium), the final rule requires that topcoats and primers be applied in a booth
or hangar in which the airflow is directed across the part or assembly being
coated. Airflow must then be exhausted through one or more outlets equipped
with either dry particulate filters or a waterwash system to remove the hexavalent
chromium, cadmium, and selenium particulates before airflow is finally released
into the atmosphere.
Depainting
Large volumes of methvlene chloride have traditionally been used to remove paint from
the exterior of aerospace vehicles, including the fuselage, wings, horizontal and vertical
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stabilizers of the aircraft or the outer casing and stabilizers of missiles and rockets. Under
EPA's final rule:
¦ Depainting processes must have zero hazardous air pollutant emissions. This can
be achieved through either 1) media blasting equipment, high intensity-
ultra-violet light blasting, or any other nonchemical depainting technique, or 2)
chemical strippers that do not contain hazardous air pollutants.
¦ The use of 26 to 50 gallons (depending on the type of the aircraft) of chemical
stripper containing hazardous air pollutants per aircraft is allowed, however, for
spot stripping and decal removal.
Chemical Milling Maskant Operations
Chemical milling maskant operations use spray equipment or dip tanks to apply
protective coatings to surface areas of aerospace vehicles or parts.
¦ Emissions from chemical milling maskant operations are limited to 1.3 pounds of
hazardous air pollutants per gallon of maskant (not including water) during
application. VOC emissions are limited to the same levels (not including water
and exempt solvents).
¦ Options for complying with the standard include 1) using only maskants that
individually comply with the hazardous air pollutant limit; 2) using only maskants
for which the weighted average hazardous air pollutant content of all the
maskants used in the chemical milling maskant operation complies with the
hazardous air pollutant limit; 3) using a control device to reduce hazardous air
pollutant emissions such that the overall emissions from a chemical milling
maskant operation are equivalent to the emissions that would be achieved by
using compliant maskants.
Handling and Storage of Waste
¦ EPA's final rule requires that the handling and transfer of waste to or from
containers, tanks, vats, vessels, or piping systems be conducted in such a manner
that minimizes spills. In addition, all waste that contains hazardous air pollutants
must be stored in closed containers.
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Monitoring
¦ Cleaning operations: Enclosed spray gun cleaners must be visually inspected at
least once per month for leaks. Any leak must be repaired within 14 days.
¦ Primer, topcoat, and chemical milling maskant application operations controlled
with incinerators: The temperature of incinerators must be monitored using a
continuous recorder.
¦ Depainting operations and the application of coatings with inorganic HAPs: For
inorganic hazardous air pollutant emissions (e.g., metals such as chromium and
cadmium), the pressure drop across the filter must be monitored continuously.
Reporting
¦ Required reports include an initial notification of pertinent information about the
emission sources and a report or notification of compliance status, which provides
a detailed description of how the facility is complying with the regulation.
¦ Semiannual reports must document all noncompliance situations and/or
exceedances, as well as process changes. Annual reports must document periods
of compliance with all applicable standards. Other reports are identical to the
requirements outlined in the EPA's air toxics General Provisions rule, which was
promulgated in February 1994.
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APPENDIX 2-G
LIST OF REGULATED SUBSTANCES AND THRESHOLDS FOR
ACCIDENTAL RELEASE PREVENTION
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NOTE: On January 31, 1994, EPA published a final list of 139 regulated substances for
accidental release prevention: 77 acutely toxic substances, 63 flammable gases and
volatile liquids, and Division 1.1 high explosives as listed by the U.S. Department of
Transportation. On April 15, 1996, EPA proposed modifications to this list. If these
modifications are promulgated in a final rule, they will exclude facilities handling
explosives, exploration/production facilities for oil and gas, and gasoline.
The regulated toxic and flammable substances are listed in this Appendix, both in
alphabetical order and CAS number.
Table 2-G1 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [Alphabetical Order - 77 Substances]
Chemical Name
CAS No.
Threshold
Quantity
(lbs)
Basis
for
Listing
Acrolein [2-Propenal]
107-02-8
5,000
b
Acrvlonitrile [2-Propenenitrile]
107-13-1
20,000
b
Acrylvl chloride [2-Propenovl chloride]
814-68-6
5,000
b
Allvl alcohol [2-Propen-l-ol]
107-18-6
15,000
b
Allvlamine [2-Propen-1-amine]
107-1 1-9
10,000
b
Ammonia (anhvdrous)
7664-41-7
10,000
a,b
Ammonia (cone 20% or greater)
7664-41-7
20,000
a,b
Arsenous trichloride
7784-34-1
15,000
b
Arsine
7784-42-1
1,000
b
Boron trichloride [Borane, trichloro-]
10294-34-5
5,000
b
Boron trifluoride [Borane, trifluoro-]
7637-07-2
5,000
b
Boron trifluoride compound witJh methyl ether (1:1)
[Boron, trifluoro[oxvbis[metane]]-, T-4-
353-42-4
15,000
b
Bromine
7726-95-6
10,000
a,b
Carbon disulfide
75-15-0
20,000
b
Chlorine
7782-50-5
2,500
a,b
Chlorine dioxide [Chlorine oxide (CIO,)]
10049-04-4
1,000
c
Chloroform [Methane, trichloro-]
67-66-3
20,000
b
Chloromethvl ether [Methane, oxvbis[chloro-]
542-88-1
1,000
b
December 1996
2-G1
-------
Air Emissions
Part I, Chapter 2
Table 2-G1 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [Alphabetical Order - 77 Substances]
Chemical Name
CAS No.
Threshold
Quantity
(lbs)
Basis
for
Listing
Chloromethyl methyl ether [Methane,
chloromethoxv-]
107-30-2
5,000
b
Crotonaldehvde [2-Butenal]
4170-30-3
20,000
b
Crotonaldehvde, (E)- [2-Butenal, (E)-]
123-73-9
20,000
b
Cvanogen chloride
506-77-4
10,000
c
Cvclohexvlamine [Cyclohexanamine]
108-91-8
15,000
b
Diborane
19287-45-7
2,500
b
Dimethvldichiorosilane [Silane, dichlorodimethyl-]
75-78-5
5,000
b
1,1 -Dimethvlhydrazine [Hydrazine, 1,1-dimethyl-]
57-14-7
15,000
b
Epichlorohvdrin [Oxirane, (chloromethvl)-]
106-89-8
20,000
b
Ethvlenediamine [ 1,2-Ethanediamine]
107-15-3
20,000
b
Ethvleneimine [Aziridine]
151-56-4
10,000
b
Ethylene oxide [Oxirane]
75-21-8
10,000
a,b
Fk orine
7782-41-4
1,000
b
Formaldehyde (solution)
50-00-0
15,000
b
Furan
110-00-9
5,000
b
Hydrazine
302-01-2
15,000
b
Hydrochloric acid (cone 30% or greater)
7647-01-0
15,000
d
Hydrocyanic acid
74-90-8
2,500
a,b
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
5,000
a
Hydrogen fluoride/Hydrofluoric acid (cone 50% or
greater) [Hydrofluoric acid]
7664-39-3
1,000
a.b
Hydrogen selenide
7783-07-5
500
b
Hydrogen sulfide
7783-06-4
10,000
a.b
Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)5),
(TB-5-1 L)-]
13463-40-6
2,500
b
Isobutvronitrile [Propanenitrile, 2-methvl-]
78-82-0
20,000
b
December 1996
2-G2
-------
Air Emissions
Part I, Chapter 2
Table 2-G1 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [Alphabetical Order - 77 Substances]
Chemical Name
CAS No.
Threshold
Quantity
(lbs)
Basis
for
Listing
Isopropyl chloroformate [Carbonochloridic acid,
1 -methvlethvl ester]
108-23-6
15,000
b
Methacrvlonitrile [2-Propenenitrile, 2-methvl-]
126-98-7
10,000
b
Methvl chloride [Methane, chloro-]
74-87-3
10,000
a
Methyl chloroformate [Carbonochloridic acid,
methvlester]
79-22-1
5,000
b
Methvl hydrazine [Hydrazine, methvl-]
60-34-4
15,000
b
Methvl isocvanate [Methane, isocvanato-]
624-83-9
10,000
a.b
Methvl mercaptan [Methanethiol]
74-93-1
10,000
b
MetJhvl thiocvanate [Thiocvanic acid, methvl ester]
556-64-9
20,000
b
Methvltrichlorosilane [Silane, trichloromethvl-]
75-79-6
5,000
b
Nickel carbonvl
13463-39-3
1,000
b
Nitric acid (cone 80% or greater)
7697-37-2
15,000
b
Nitric oxide [Nitrogen oxide (NO)]
10102-43-9
10,000
b
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture
with sulfur trioxide] 1
8014-95-7
10,000
e
Peracetic acid [Ethaneperoxoic acid]
79-21-0
10,000
b
Perchloromethylmercaptan [Methanesulfenyl
chloride, trichloro-]
594-42-3
10,000
b
Phosgene [Carbonic dichloride]
75-44-5
500
a.b
Phosphine
7803-51-2
5,000
b
Phosphorus oxychloride [Phosphorvl chloride]
10025-87-3
5,000
b
Phosphorus trichloride [Phosphorous trichloride]
7719-12-2
15,000
b
Piperidine
110-89-4
15,000
b
Propionitrile [Propanenitrile]
107-12-0
10,000
b
Propvl chloroformate [Carbonochloridic acid,
propvlester]
109-61-5
15,000
b
Propvleneimine [Aziridine. 2-methvl-]
75-55-8
10,000
b
December 1996
2-G3
-------
Air Emissions
Part I, Chapter 2
Table 2-G1 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [Alphabetical Order - 77 Substances]
Chemical Name
CAS No.
Threshold
Quantity
(lbs)
Basis
for
Listing
Propylene oxide [Oxirane, methvl-]
75-56-9
10,000
b
Sulfur dioxide (anhvdrous)
7446-09-5
5,000
a,b
Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-]
7783-60-0
2,500
b
Sulfur trioxide
7446-11-9
10,000
a,b
Tetramethvllead [Plumbane, tetramethvl-]
75-74-1
10,000
b
Tetranitromethane [Methane, tetranitro-]
509-14-8
10,000
b
Titanium tetrachloride [Titanium chloride (TiCl4)
(T-4)-]
7550-45-0
2,500
b
Toluene 2,4-diisocyanate [Benzene,
2,4-diisocyanato-1 -methvl-]1
584-84-9
10,000
a
Toluene 2,6-diisocyanate [Benzene,
1,3-diisocvanato-2-methvl-]1
91-08-7
10,000
a
Toluene diisocyanate (unspecified isomer) [Benzene,
1,3-diisocvanatomethvl-]1
26471-62-5
10,000
a
Trimethvlchlorosilane [Silane, chlorotrimethvl-]
75-77-4
10,000
b
Vinvl acetate monomer [Acetic acid ethenyl ester]
108-05-4
15,000
b
'The mixture exemption in 68.115(b)(1) does not apply to the substance.
Basis for Listing:
1 Mandated for listing by Congress.
bOn EHS list, vapor pressure 10 mmHg or greater.
c Toxic gas.
d Toxicity of hydrogen chloride, potential to release hydrogen chloride, and history of accidents.
c Toxicity of sulfur trioxide and sulfuric acid, potential to release sulfur trioxide, and history of accidents.
December 1996
2-G4
-------
Air Emissions
Part I, Chapter 2
Table 2-G2 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [CAS Number Order - 77 Substances]
CAS No.
Chemical Name
Threshold
Quantity (lbs)
Basis
for
Listing
50-00-0
Formaldehyde (solution)
15,000
b
57-14-7
1,1-Dimethvlhvdrazine [Hydrazine, 1,1-dimethvl-]
15,000
b
60-34-4
Methvl hydrazine [Hydrazine, methvl-]
15,000
b
67-66-3
Chloroform [Methane, trichloro-]
20,000
b
74-87-3
Methvl chloride [Methane, chloro-]
10,000
a
74-90-8
Hydrocyanic acid
2,500
a.b
74-93-1
Methvl mercaptan [Methanethiol]
10,000
b
75-15-0
Carbon disulfide
20,000
b
75-21-8
Ethylene oxide [Oxirane]
10.000
a.b
75-44-5
Phosgene [Carbonic dichloride]
500
a.b
75-55-8
Propvleneimine [Aziridine, 2-methyl-]
10,000
b
75-56-9
Propylene oxide [Oxirane, methyl-]
10,000
b
75-74-1
Tetramethvllead [Plumbane, tetramethyl-]
10,000
b
75-77-4
Trimcthvlchlorosilane [Silane, chlorotrimethvl-]
: o.ooo
b
75-78-5
Dimethyldichlorosilane [Silane, dichlorodimethyl-]
5,000
b
75-79-6
Methvltrichlorosilane [Silane, trichloromethyl-]
5,000
b
78-82-0
Isobutvronitrile [Propanenitrile, 2-methyl-]
20,000
b
79-21-0
Peracetic acid [Ethaneperoxoic acid]
10,000
b
79-22-1
Methvl chloroformate
5,000
b
[Carbonochloridic acid, methvlester] |
91-08-7
Toluene 2,6-diisocyanate [Benzene,
1,3-diisocvanato-2-methvl-]'
10,000
a
106-89-8
Epichlorohvdrin [Oxirane, (chloromethvl)-]
20,000
b
107-02-8
Acrolein [2-Propenal]
5,000
b
107-11-9
Allvlamine [2-Propen-1-amine]
10,000
b
107-12-0
Propionitrile [Propanenitrile]
10,000
b
107-13-1
Acrvlonitrile [2-Propenenitrile]
20.000
b
December 1996 2-G5
-------
Air Emissions
Part I, Chapter 2
Table 2-G2 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [CAS Number Order - 77 Substances]
CAS No.
Chemical Name
Threshold
Quantity (lbs)
Basis
for
Listing
107-15-3
Ethvlenediamine [ 1,2-Eihanediamine]
20,000
b
107-18-6
Allvl alcohol [2-Propen-l-ol]
15,000
b
107-30-2
Chloromethyl methyl ether [Methane,
chloromethoxv-]
5,000
b
108-05-4
Vinvl acetate monomer [Acetic acid ethenyl ester]
15,000
b
108-23-6
Isopropyl chloroformate [Carbonochloridic acid,
1 -methvlethvl ester]
15,000
b
108-91-8
Cvclohexvlamine [Cvclohexanamine]
15,000
b
109-61-5
Propyl chloroformate [Carbonochloridic acid,
propvlester]
15,000
b
1 10-00-9
Furan
5,000
b
110-89-4
Piperidine
15,000
b
123-73-9
Crotonaldehvde, (E)- [2-Butenal, (E)-]
20,000
b
126-98-7
Methacrylonitrile [2-Propenenitrile, 2-methyl-]
10,000
b
151-56-4
Ethvleneimine [Aziridine]
10,000
b
302-01-2
Hydrazine
15,000
b
353-42-4
Boron trifluoride compound with methyl ether
(1:1) [Boron, trifluoro[oxvbis[metane]]-, T-4-
15,000
b
506-77-4
Cvanogen chloride
10,000
c
509-14-8
Tetranitromethane [Methane, tetranitro-]
10,000
b
542-88-1
Chloromethyl ether [Methane, oxybis[chloro-]
1,000
b
556-64-9
Methvl thiocvanate [Thiocvanic acid, methyl ester]
20,000
b
584-84-9
Toluene 2,4-diisocyanate [Benzene,
2,4-diisocvanato-1-methyl-] 1
10,000
a
594-42-3
Perchloromethvlmercaptan [Methanesulfenyl
chloride, trichloro-]
10,000
b
624-83-9
Methvl isocvanate [Methane, isocvanato-]
10,000
a,b
814-68-6
Acrvlvl chloride [2-Propenovl chloride]
5,000
b
4170-30-3
Crotonaldehvde [2-Butenal]
20,000
b
December 1996
2-G6
-------
Air Emissions
Part I, Chapter 2
Table 2-G2 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [CAS Number Order - 77 Substances]
CAS No.
Chemical Name
Threshold
Quantity (lbs)
Basis
for
Listing
7446-09-5
Sulfur dioxide (anhydrous)
5,000
a,b
7446-11-9
Sulfur trioxide
10,000
a,b
7550-45-0
Titanium tetrachloride [Titanium chloride (TiCl4)
(T-4)-]
2,500
b
7637-07-2
Boron trifluoride [Borane, trifluoro-]
5,000
b
7647-01-0
Hydrochloric acid (cone 30% or greater)
15,000
d
7647-01-0
Hvdrogen chloride (anhydrous) [Hydrochloric acid]
5,000
a
7664-39-3
Hydrogen fluoride/Hydrofluoric acid (cone 50% or
.greater) [Hydrofluoric acid]
1.000
a,b
7664-41-7
Ammonia (anhydrous)
10,000
a,b
7664-41-7
Ammonia (cone 20% or greater)
20,000
a,b
7697-37-2
Nitric acid (cone 80% or greater)
15,000
b
7719-12-2
Phosphorus trichloride [Phosphorous trichloride]
15,000
b
7726-95-6
Bromine
10,000
a,b
7782-41-4
Fluorine
1,000
b
7782-50-5
Chlorine
2,500
a,b
7783-06-4
Hydrogen sulfide
10,000
a,b
7783-07-5
Hydrogen selenide
500
b
7783-60-0
Sulfur tetrafluoride [Sulfur fluoride (SF4), (T-4)-]
2,500
b
7784-34-1
Arsenous trichloride
15,000
b
7784-42-1
Arsine
1,000
b
7803-51-2
Phosphine
5,000
b
8014-95-7
Oleum (Fuming Sulfuric acid) [Sulfuric acid,
mixture with sulfur trioxide]1
10,000
e
10025-87-3
Phosphorus oxvchloride [Phosphoryl chloride]
5,000
b
10049-04-4
Chlorine dioxide [Chlorine oxide (CIO,)]
1,000
c
10102-43-9
Nitric oxide [Nitrogen oxide (NO)]
10,000
b
10294-34-5
Boron trichloride [Borane. trichloro-]
5,000
b
December 1996 2-G7
-------
Air Emissions
Part i, Chapter 2
Table 2-G2 List of Regulated Toxic Substances and Threshold Quantities for
Accidental Release Prevention [CAS Number Order - 77 Substances]
CAS No.
Chemical Name
Threshold
Quantity (lbs)
Basis
for
Listing
13463-39-3
Nickel carbonvl
1,000
b
13463-40-6
Iron, pentacarbonyl- [Iron carbonyl (Fe(CO)s),
(TB-5-11)-]
2,500
b
19287-45-7
Diborane
2,500
b
26471-62-5
Toluene diisocyanate (unspecified isomer)
[Benzene, 1,3-diisocyanatomethvl-]'
10,000
a
'The mixture exemption in 68.115(b)(1) does not apply to the substance.
Basis for Listing:
1 Mandated for listing by Congress:
bOn EHS list, vapor pressure 10 mmHg or greater.
cToxic gas.
d Toxicity of hydrogen chloride, potential to release hydrogen chloride, and history of accidents.
'Toxicity of sulfur trioxide and sulfuric acid, potential to release sulfur trioxide, and history of accidents.
December 1996
2-G8
-------
Air Emissions
Part I, Chapter 2
Table 2-G3 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [Alphabetical Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Ouantitv fibs)
Basis for
Listine
Acetaldehvde
75-07-0
10,000
R
Acetvlene [Ethvne]
74-86-2
10,000
f
Bromotrifluorethvlene [Ethene, bromotrifluoro-]
598-73-2
10,000
f
1,3-Butadiene
106-99-0
10,000
f
Butane
106-97-8
10,000
f
1-Butene
106-98-9
10,000
2-Butene
107-01-7
10,000
f
Butene
25167-67-3
10,000
f
2-Butene-cis
590-18-1
10,000
f
2-Butene-trans [2-Butene, (E)]
624-64-6
10,000
f
Carbon oxysulfide [Carbon oxide sulfide (COS)]
463-58-1
10,000
f
Chlorine monoxide [Chlorine oxide]
7791-21-1
10,000
f
2-Chloropropvlene [1-Propene, 2-chloro-]
557-98-2
10,000
R
1-Chloropropvlene [1-Prcoene, 1-chloro-]
590-21-6
10,000
R
Cyanogen [Ethanedinitrile]
460-19-5
10,000
f
Cvclopropane
75-19-4
10,000
f
Dichlorosilane [Silane, dichloro-]
4109-96-0
10,000
f
Difluoroethane [Ethane, 1,1-difluoro-]
75-37-6
10,000
f
Dimethvlamine [Methanamine, N-methvl-]
124-40-3
10,000
f
2,2-Dimethvlpropane [Propane, 2,2-dimethvl-]
463-82-1
10,000
f
Ethane
74-84-0
10,000
f
Ethvl acetvlene [ 1-Butvne]
107-00-6
10,000
f
Ethvlamine [Ethanamine]
75-04-7
10,000
f
Ethvl chloride [Ethane, chloro-]
75-00-3
10,000
f
Ethvlene [Ethene]
74-85-1
10,000
f
Ethvl ether [Ethane, I.l'-o.wbis-]
60-29-7
10,000
R
Ethvl mercaptan [Ethanethioll
75-08-1
10.000
R
December 1996 2-G9
-------
Air Emissions
Part I, Chapter 2
Table 2-G3 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [Alphabetical Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Ouantitv (lbs)
Basis for
Listine
Ethvl nitrite [Nitrous acid, ethyl ester]
109-95-5
10,000
f
Hvdrogen
1333-74-0
10,000
f
Isobutane [Propane, 2-methvl]
75-28-5
10,000
f
Isopentane [Butane, 2-methvl-]
78-78-4
10,000
R
Isoprene [1,3-Butadiene, 2-methvl-]
78-79-5
10,000
R
Isopropvlamine [2-Propanamine]
75-31-0
10,000
R
Isopropvl chloride [Propane, 2-chloro-]
75-29-6
10,000
R
Methane
74-82-8
10,000
f
Methvlamine [Methanamine]
74-89-5
10,000
f
3-Methyl-1 -butene
563-45-1
10,000
f
2-Methvl-1 -butene
563-46-2
10,000
R
Methyl ether [Methane, oxvbis-]
115-10-6
10,000
f
Methvl formate [Formic acid, methvl ester]
107-31-3
10,000
R
"1 Methvlpropene [1-Propene, 2-methvl-]
115-1 1-7
10,000
f
1,3-Pentadiene
504-60-9
10,000
f
Pentane
109-66-0
10,000
R
l-Pentene
109-67-1
10,000
R
2-Pentene, (E)-
646-04-8
10,000
R
2-Pentene, (Z)-
627-20-3
10,000
R
Propadiene [1,2-Propadiene]
463-49-0
10,000
f
Propane
74-98-6
10,000
f
Propylene [1-Propene]
115-07-1
10,000
f
Propvne [1-Propvne]
74-99-7
10,000
f
Silane
7803-62-5
10,000
f
Tetrafluoroethvlene [Ethene, tetrafluoro-]
116-14-3
10,000
f
Tetramethvlsilane [Silane, tetramethvl-]
75-76-3
10,000
R
Trichlorosilane [Silane. trichloro-1
10025-78-2
10,000
R
December 1996 2-G10
-------
Air Emissions
Part I, Chapter 2
Table 2-G3 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [Alphabetical Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Ouantitv (lbs)
Basis for
Listine
Trifluorochloroethylene [Ethene, chlorotrifluoro-]
79-38-9
10,000
f
Trimethylamine [Methanamine, N,N-dimethvl-]
75-50-3
10,000
f
Vinvl acetylene [1-Buten-3-vne]
689-97-4
10,000
f
Vinvl chloride [Ethene, chloro-]
75-01-4
10,000
a, f
Vinvl ethyl ether [Ethene. ethoxy-]
109-92-2
10,000
R
Vinyl fluoride [Ethene, fluoro-]
75-02-5
10,000
f
Vinylidene chloride [Ethene, 1,1-dichloro-]
75-35-4
10,000
Z
Vinvlidene fluoride [Ethene, 1,1-difluoro-]
75-38-7
10,000
f
Vinyl methyl ether [Ethene, methoxy-J
107-25-5
10,000
f
Basis for Listing:
1 Mandated for listing by Congress.
' Flammable gas.
g Volatile flammable liquid.
December 1996
2-G11
-------
Air Emissions
Part I, Chapter 2
Table 2-G4 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [CAS Number Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Ouantitv (lbs)
Basis for
Listing
Ethvl ether [Ethane, I.l'-oxvbis-]
60-29-7
10,000
R
Methane
74-82-8
10,000
f
Ethane
74-84-0
10,000
f
Ethylene [Ethene]
74-85-1
10,000
f
Acetvlene [Ethvne]
74-86-2
10,000
f
Methvlamine [Methanamine]
74-89-5
10,000
f
Propane
74-98-6
10,000
f
Propvne [1-Propvne]
74-99-7
10,000
f
Ethvl chloride [Ethane, chloro-]
75-00-3
10,000
f
Vinvl chloride [Ethene, chloro-]
75-01-4
10,000
a, f
Vinyl fluoride [Ethene, fluoro-J
75-02-5
10,000
f
Ethvlamine [Ethanamine]
75-04-7
10.000
f
Acetaidehvde
75-07-0
10,000
R
Ethyl mercaptan [Ethanethiol]
"5-08-1
10,000
R
Cyclopropane
75-19-4
10.000
f
Isobutane [Propane, 2-methvl]
75-28-5
10,000
f
Isopropvl chloride [Propane, 2-chloro-]
75-29-6
10,000
R
Isopropvlamine [2-Propanamine]
75-31-0
10,000
R
Vinvlidene chloride [Ethene, 1,1 -dichloro-]
75-35-4
10,000
R
Difluoroethane [Ethane, 1,1 -difluoro-]
75-37-6
10,000
f
Vinvlidene fluoride [Ethene, 1,1-difluoro-]
75-38-7
10,000
f
Trimethvlamine [Methanamine, N,N-dimethyl-]
75-50-3
10,000
f
Tetramethvlsilane [Silane, tetramethvl-]
75-76-3
10,000
R
Isopentane [Butane, 2-methvl-]
78-78-4
10,000
R
Isoprene [ 1,3-Butadiene, 2-methvl-]
78-79-5
10,000
R
Trifluorochloroethvlene [Ethene, chlorotrifluoro-]
79-38-9
10,000
f
Butane
106-97-8
10.000
f
December 1996
2-G12
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Air Emissions
Part I, Chapter 2
Table 2-G4 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [CAS Number Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Quantity (lbs)
Basis for
Listine
1 -Butene
106-98-9
10,000
f
1,3-Butadiene
106-99-0
10,000
f
Ethvl acetylene [1-Butvne]
107-00-6
10,000
f
2-Butene
107-01-7
10,000
f
Vinvl methvl ether [Ethene, methoxv-]
107-25-5
10,000
f
Methvl formate [Formic acid, methvl ester]
107-31-3
10,000
K
Pentane
109-66-0
10,000
K
1-Pentene
109-67-1
10,000
K
Vinvl ethvl ether [Ethene, ethoxv-]
109-92-2
10,000
£
Ethvl nitrite [Nitrous acid, ethvl ester]
109-95-5
10,000
f
Propylene [ 1 -Propene]
115-07-1
10,000
f
Methvl ether [Methane, oxvbis-]
115-10-6
10,000
f
2-Methylpropene [1-Propene, 2-methvl-]
115-11-7
10,000
f
Tetrafluoroethvlene [Ethene, tetrafluoro-]
116-14-3
10,000
f
Dimethylamine [Methanamine, N-methvl-]
124-40-3
10,000
f
Cyanogen [Ethanedinitrile]
460-19-5
10,000
f
Propadiene [ 1,2-Propadiene]
463-49-0
10,000
f
Carbon oxvsulfide [Carbon oxide sulfide (COS)]
463-58-1
10,000
f
2,2-Dimethvlpropane [Propane, 2,2-dimethvl-]
463-82-1
10,000
f
1,3-Pentadiene
504-60-9
10,000
f
2-Chloropropvlene [1-Propene, 2-chloro-]
557-98-2
10,000
3-Methvl-1 -butene
563-45-1
10,000
f
2-Methyl-1-butene
563-46-2
10,000
2-Butene-cis
590-18-1
10,000
f
1-Chloropropvlene [I-Propene. 1-chloro-]
590-21-6
10,000
Bromotrifluorethvlene [Ethene, bromotrifluoro-]
598-73-2
10,000
f
2-Butene-trans [2-Butene, CEI]
624-64-6
10.000
f
December 1996
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Air Emissions
Part I, Chapter 2
Table 2-G4 List of Regulated Flammable Substances and Threshold Quantities
for Accidental Release Prevention [CAS Number Order - 63
Substances]
Chemical Name
CAS No.
Threshold
Ouantitv (lbs)
Basis for
Listine
2-Pentene, (Z)-
627-20-3
10,000
K
2-Pentene, (E)-
646-04-8
10,000
R
Vinvl acetylene [l-Buten-3-yne]
689-97-4
10,000
f
Hvdrogen
1333-74-0
10,000
f
Dichlorosilane [Silane, dichloro-]
4109-96-0
10,000
f
Chlorine monoxide [Chlorine oxide]
7791-21-1
10,000
f
Silane
7803-62-5
10,000
f
Trichlorosilane [Silane, trichloro-]
10025-78-2
10,000
R
Butene
25167-67-3
10,000
f
Basis for Listing:
1 Mandated for listing by Congress.
' Flammable gas.
8 Volatile flammable liquid.
December 1996
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Notes
3
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CHAPTER 3
Wastewater Discharges
3.1 Federal Requirements 3-3
3.1.1 What Is the Clean Water Act? 3-3
3.1.2 What Clean Water Act Programs Affect Metal Finishers? 3-3
3.1.3 Which Wastewater Discharge Requirements Apply to My Operation? 3-4
3.1.4 What Are the Wastewater Discharge Requirements for Indirect Dischargers? 3-5
3.1.5 What Are the Wastewater Discharge Requirements for Direct Dischargers? 3-10
3.1.6 How Pollution Prevention Can Reduce the Regulatory Burden for Wastewater Discharge 3-14
3.2 State Programs 3-16
3.3 Where To Co for Further Information 3-17
Under the federal Clean Water Act, all metal finishers must meet
requirements to control their wastewater discharges.
Deadlines for compliance with these requirements are long past. If your
facility is not yet in compliance, is under construction, or is expanding its
operation, read this chapter to find out how to comply. If you are already in
compliance, you can review this chapter to verify that you are complying with
all the requirements. Appendix 3-A provides a summary of the key
requirements and deadlines.
All states have their own laws to protect surface wa :er. Key state requirements
are summarized towards the end of this chapter. Be sure to check with state
authorities to determine what state requirements apply to your facility.
December 1996
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Wastewater Discharges
Part I, Chapter 3
Table of Contents Page
3.1 Federal Requirements 3-3
3.1.1 What Is the Clean Water Act? 3-3
3.1.2 What Clean Water Act Programs Affect Metal Finishers? 3-3
3.1.3 Which Wastewater Discharge Requirements Apply to My Operation? 3-4
3.1.4 What Are the Wastewater Discharge Requirements for Indirect Dischargers? 3-5
3.1.4.1 Pretreatment Standards 3-5
3.1.4.2 Monitoring and Reporting Requirements 3-8
3.1.4.3 Renewal of the Control Authority Permit 3-10
3.1.5 What Are the Wastewater Discharge Requirements for Direct Dischargers? 3-10
3.1.5.1 Obtaining a Permit To Discharge 3-10
3.1.5.2 Monitoring and Reporting Requirements 3-12
3.1.5.3 Renewal of the NPDES Permit 3-14
3.1.6 How Pollution Prevention Can Reduce the Regulatory Burden for Wastewater
Discharge 3-14
3.2 State Programs 3-16
3.3 Where To Go for Further Information 3-17
Compliance Calendar for Federal Wastewater Discharge Requirements
Contact Information for NPDES-Approved States
Contact Information for EPA Regional Pretreatment Coordinators
What Do Control Authorities Consider When They Set Limits for Indirect Dischargers?
Effluent Limits Established Under 40 CFR Part 433 (Metal Finishing)
Effluent Limits Established Under 40 CFR Part 413 (Electroplating)
Sample NPDES Permits.
Appendix 3-A
Appendix 3-B
Appendix 3-C
Appendix 3-D
Appendix 3-E
Appendix 3-F
Appendix 3-G
F^deraj Wastewater Discharge Regulations: How To Comply
~ Determine whether you are a direct or indirect discharger (Section
3.1.3).
~ Contact your Control Authority to find out what effluent standards
and permit requirements you must meet. To meet discharge
requirements, you will need to install pretreatment equipment and
conduct periodic monitoring and reporting. You may be able to
substantially lessen these requirements by implementing measures to
reduce the volume and toxicity of your facility's wastewater
discharge.
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Wastewater Discharges
Part I, Chapter 3
3.1 Federal Requirements
3.1.1 What Is the Clean Water Act?
The Clean Water Act (CWA) is the principal federal law protecting
surface water quality1 in the United States. Originally passed in 1972
as the Water Pollution Control Act, the CWA has been amended
several times, most notably in 1978 and 1982. The two principal
goals of CWA are:
¦ To restore and maintain the chemical, physical, and
biological integrity of the nation's waters.
¦ Where attainable, to achieve water quality that promotes
protection and propagation of fish, shellfish, and wildlife, and
provides for recreation in and on the water.
3.1.2 What Clean Water Act Programs Affect Metal Finishers?
Many programs have been developed to achieve the federal Clean
Water Act goals. Three of these programs affect metal finishers:
¦ Control of wastewater discharges, which affects all metal
finishers.
¦ Permitting of storm water discharges, which affects some
metal finishers.
¦ Preparation of oil spill control and countermeasure plans,
which affects a select few metal finishers.
The wastewater discharge program is described in this chapter.
Storm water and oil spill prevention requirements are discussed in
Chapter 4.
' Surface water is different from ground water. Surface water includes rivers, lakes, streams, ponds, estuaries, and
other natural bodies of water above the ground surface. Ground water refers to underground reservoirs or aquifers,
manv of which are used as sources for drinking water. Ground water is protected by the Safe Drinking Water Act and
other laws.
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Wastewater Discharges
Part I, Chapter 3
Deadlines for compliance with aJl these requirements are long past.
If your facility is in operation, you should already be in compliance
or should come into compliance as soon as possible.
In addition to the federal requirements, every state now has its own
clean water act with equivalent goals to the federal CWA. Section
3.2 reviews some of the key state requirements for wastewater
discharge. Contact your state authorities for details on the
particular requirements in your state.
3.1.3 Which Wastewater Discharge Requirements Apply to
My Operation?
Under the federal Clean Water Act regulations, a "metal finisher"
is any facility that performs any of the following operations:
¦ Electroplating
¦ Anodizing
¦ Chemical etching and milling
¦ Electroless plating
¦ Coating (chromating, phosphating, and coloring)
¦ Printed circuit board manufacturing
All facilities performing any of these operations must meet limits on
their wastewater discharges. There are no exclusions based on size
or any other criteria.
Wastewater from metal finishing operations (as from other
industrial operations) is controlled by two types of requirements.
Which type applies to your operation depends on where your
wastewater goes:
¦ If your facility discharges its process and/or nonprocess wastewater
directly to a surface water body (including rivers, streams, lakes,
and oceans), you are a direct discharger. Direct discharges are
controlled under the National Pollutant Discharge
Elimination Svstem (NPDES) program, established under the
December 1996
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Wastewater Discharges
Part I, Chapter 3
Clean Water Act. Direct dischargers must obtain an NPDES
permit to discharge wastewater.
¦ If your facility discharges its process wastewater to a sewer that
flows to a publicly owned treatment works (POTW), you are an
indirect discharger. Indirect dischargers must meet
pretreatment standards. (Nonprocess wastewaters from metal
finishing [e.g., boiler blowdown, noncontact cooling water,
and air compressor condensate] discharged to sewers are not
regulated under the CWA. However, if discharged directly to
a POTW, nonprocess wastewaters are subject to the local
POTW's permitting or sewer use ordinance requirements and
to state requirements.)
Figure 3-1 illustrates direct and indirect dischargers. You can be
both a direct and indirect discharger if some of your wastewater goes
directly to a water body and some into a sewer. Most metal
finishers are indirect dischargers.
Both direct and indirect dischargers must meet effluent limits and
conduct periodic monitoring and reporting. Both direct and indirect
dischargers will need to pretreat their wastewaters and/or implement
pollution prevention measures to successfully meet the applicable
effluent limits. Section 3.1.6 discusses opportunities for pollution
prevention.
3.1.4 What Are the Wastewater Discharge Requirements for
Indirect Dischargers?
3.1.4.1 Pretreatment Standards
As an indirect discharger, your wastewater must meet specific
pretreatment standards that control its quality. Standards for
indirect discharges are established by the "Control Authority" for
your area and are usually specified in a document issued by the
Control Authority. This document may be referred to by a number
of names, including "permit" and "agreement." Hereafter- in this
manual, this document is referred to as the "Control Authority
permit.
December 1996
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Wastewater Discharges
Part I, Chapter 3
» >
" Direct'
Industrial
Discharger
" Indirect"
Industrial
Discharger
1 1
1 '
' i
/
W
Figure 3-1. Diagram showing direct and indirect dischargers, plus federal regulatory mechanisms for
establishing discharge limits.
Adapted from The National Pretreatment Program, U.S. EPA, 1986. (EPA/625/10-86/005).
December 1996
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Wastewater Discharges
Part I, Chapter 3
Depending on your location, your Control Authority may be the
POTW, a state agencv, or the regional EPA office. Review Box 3-1
to determine the Control Authority for your area.
Box 3-1 Determining the Control Authority for Your
Area
1. Does vour local POTW have an approved pretreatment plan
in place? (Call your POTW as necessary to answer this
question.) Ifyes, your POTW is the Control Authority. If no,
go to 2.
2. Does your state have an approved NPDES program? (Review
Box 3-4 in Section 3.1.5 to answer this question.)
¦ If yes, a state agency (e.g., a state environmental
agency) is your Control Authority. Appendix 3-B
provides contact information for NPDES states.
¦ If no, the regional EPA Administrator is your Control
Authority. Appendix 3-C provides contact
information for EPA regional offices.
Each Control Authority detennines what effluent limits to set for
metal finishers within its jurisdiction based on federal guidelines and
on local needs and conditions.
If you are an indirect discharger, you should already know and be in
compliance with your effluent limits. If you are not in compliance
or if you are expanding your operation or constructing a new
facility, contact your Control Authority to find out:
¦ What discharge limits apply to your facility.
¦ What type of monitoring and reporting you must do to
ensure that you meet these limits.
For your information, Appendix 3-D provides background on federal
effluent guidelines that the Control Authorities consider when they
set limits. This appendix does not provide specific guidance on how
to comply but it may be helpful in understanding the types of limits
December 1996
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Wastewater Discharges
Part I, Chapter 3
vour Control Authority will require of you. Read Appendix 3-D if
vou are interested in how the limits for indirect dischargers are
developed. Remember, the limits established by a state or local
Control Authority may be more stringent than the federal guidelines
described in Appendix 3-D, but they may not be less stringent.
3.1.4.2 Monitoring and Reporting Requirements
Under the National Pretreatment Program (40 CFR Part 403),
indirect dischargers must monitor their compliance with the
pretreatment standards that apply to their facility. Two types of
monitoring and reporting are required:
¦ A one-time baseline Monitoring Report
¦ Semi-annual Continued Compliance Reports
These are described below. Your Control Authority may have
differing monitoring and reporting requirements. Be sure to check
with your Control Authority about what requirements apply to your
facility.
Baseline Monitoring Report
This report is required only when a new facility is coming on line.
It must be filed with the Control Authority at least 90 days before
beginning discharge. If your facility is in operation, you should
already have filed this type of report with your Control Authority.
(Facilities in existence when the 40 CFR Part 403 regulations were
promulgated had to file an Initial Compliance Report, which was
very similar to the Baseline Monitoring Report described here.)
In a Baseline Monitoring Report, you must provide basic
information about your facility, its processes, waste treatment
system, and discharge characteristics. You must estimate the
characteristics for all regulated metals and for toxic organics that
would reasonably be expected to be in your facility's wastewater.
Box 3-2 tells you what information must be in your Baseline
Monitoring Report. You can get additional information about filing
a Baseline Monitoring Report from your Control Authority or from
the EPA Regional Pretreatment Coordinator (see Appendix 3-C).
December 1996
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Wastewater Discharges
Part I, Chapter 3
Box 3-2 Required Contents of Baseline Monitoring Report
1.
Name and address of the facility, including name(s) of operator(s) and owrier(s).
2.
List of all environmental control permits held by or for the facility.
3.
Brief description of the nature, average production rate, and Standard Industrial
Classification (SIC) code for each operation(s) conducted, including a schematic
process diagram that indicates points of discharge from the regulated process to the
POTW.
4.
Flow measurement information for regulated process streams discharged to the
municipal system. Flow measurements of other waste streams will be necessary if
application of the combined waste stream formula is necessary.
5.
Identification of the pretreatment standards applicable to each regulated process
and results of measurements of pollutant concentrations and/or mass. All samples
must be representative of daily operations. Results reported must include values for
daily maximum and average concentration (or mass, where required). Where the
flow of the regulated stream being sampled is less than or equal to 250,000 gallons
per day, the industrial user must take three samples within a 2-week period. Where
the flow of the stream is greater than 250,000 gallons per day, the industrial user
must take six samples within a 2-week period. If samples cannot be taken
immediately downstream from the regulated process and other wastewaters are
mixed with the regulated process, the industrial user should measure flows and
concentrations of the other waste streams sufficient t j allow use of the combined
wastestream formula.
Continued Compliance Reports
If you are an indirect discharger, you must file a Continued
Compliance Report (CCR) with your Control Authority twice a
year, in June and December. CCRs should include:
¦ Data taken by your facility on flow and pollutant
concentration measurements.
¦ The methods used to sample and analyze the data.
¦ A certification that the sampling methods conform to the
methods outlined in the regulations.
Sometimes, the POTW may perform CCR sampling. When this
happens, vou may not have to file the CCR report. If the POTW
performs sampling, however, it is highly recommended to take split
December 1996
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Wastewater Discharges
Part I, Chapter 3
samples and have them analyzed independently. Also, it is
important not to rely on a POTW to sample or report on time,
correctly, or regularly.
If your discharge is free of toxic organics, the Control Authority may
waive the requirement for monitoring toxic organics if you file a
statement certifying that no dumping of toxic organics to the
vvastestream has occurred during the CCR reporting period.
You can request a waiver from sampling for toxic organics if you
submit a Toxic Organics Management Plan (sometimes referred to
as a Solvent Management Plan). The plan should identify the toxic
organics used at your facility, the method of disposal used, and
procedures in place for ensuring that toxic organics do not routinely
spill or leak into wastewater discharged to the POTW.
3.1.4.3 Renewal of the Control Authority Permit
The renewal period for Control Authority permits is normally
established by statute, regulation, or ordinance at the state or local
level. Most agreements are valid for a period of between 3 and 10
years, with 5 years being typical.
Mecal finishers should be aware that renewal of these permits
normally incorporate changes in water quality standards,
requirements for best management practices, and other conditions
adopted by the Control Authority since the permit was last issued.
Typically, renewal applications must be filed 180 days before the
permit expiration date. You should check with your Control
Authority well in advance of permit renewal to identify new limits
or other conditions that may be attached to your renewed permit.
3.1.5 What Are the Wastewater Discharge Requirements for
Direct Dischargers?
3.1.5.1 Obtaining a Permit To Discharge
If you are a direct discharger, you must obtain a permit to discharge.
This permit is often referred to as an NPDES permit because it is
drawn up under the auspices of the National Pollutant Discharge
Elimination System program, which was established under the Clean
Water Act to control direct discharges from industrial sources and
December 1996
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Wastewater Discharges
Part I, Chapter 3
POTWs. NPDES permits for metal finishers and other industrial
dischargers limit the quantity, discharge rate, pollutant
concentrations (and, possibly, whole effluent aquatic toxicity levels)
of discharges. These permits require compliance with all federal
standards and may also require additional controls based on state
and local conditions (see Box 3-3). Appendix 3-G contains sample
NPDES permits.
NPDES permits are issued either by EPA or by a state agency
approved by EPA to administer the NPDES program. Check Box
3-4 to find out whether your state has an approved NPDES
program. The state approval status changes constantly, so be sure
to double-check with your state agency to find out whether your
state's program is authorized. Contact information for state
agencies can be found in Appendix 3-B.
If you are a direct discharger, you should already have an NPDES
permit. If you will be a direct discharger (e.g., you are expanding
your current facility or constructing a new facility), contact the
appropriate authority to obtain a permit.
Box 3-3 Basis for NPDES Permit Pollutant Concentration Limits
NPDES permit limits are based on:
The Part 433 effluent guidelines.
These guidelines apply to most metal finishing operations that are indirect
dischargers and to all metal finishing operations that are direct dischargers. The Part
433 effluent guidelines are described in Section D.3.1 in Appendix 3-D. The actual
guidelines can be found in Appendix 3-E.
Water quality standards.
The Part 433 effluent guidelines establish the minimum levels of treatment required
for direct dischargers. You may face more stringent limits for certain pollutants as
necessary to meet state water quality standards. State water quality standards are
established for each water body to preserve the designated use (e.g.,
"fishable/swimmable") for the water body. States set their water quality standards
based on ambient water quality criteria developed by EPA, and by taking into account
how polluted (or clean) the water body already is. Also factored in are any upstream
contributors to the water's overall toxicity. For example, the existence of another
metal finishing firm or chemical company located upstream from you may mean that
vour limits are cut in half, that is made twice as stringent.
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Wastewater Discharges
Part I, Chapter 3
3.1.5.2 Monitoring and Reporting Requirements
As a condition of your NPDES permit, you may be required to
sample your treated effluent and report pollutant concentration and
flow data. Such sampling requirements are established by state
regulations and/or at the discretion of the permit writer.
Generally, the monitoring requirements for direct dischargers are
not comparable to those required from indirect dischargers. For
example, an NPDES permit may require a metal finisher to sample
weekly to determine concentrations of metals and certain
conventional pollutants, such as biological oxygen demand, chemical
oxygen demand, and oil and grease. Whole effluent toxicity testing
may also be required (i.e., you may be asked to conduct specific
tests to determine whether your effluent is toxic to certain aquatic
organisms).
If your permit requires you to monitor pollutant concentrations in
your treated effluents, you will need to submit Discharge
Monitoring Reports based on your monitoring results. These
reports must include information about when and where you
sampled your effluents, who performed the sampling, when and how
you (or a laboratory) analyzed the samples, and what the results
we-e. You may also need to report on your compliance with permit
limits. Specific reporting requirements and due dates are specified
in your permit.
Other reporting requirements have to do with specific events; you
need to submit the reports only if the events occur. For example,
you may be required to submit:
¦ A Transfer Report if you transfer your permit to another
person.
¦ A Planned Changes Report if you plan to alter or expand
your facility in a way that creates a new source of wastewater,
increases the amount of pollutants discharged, or changes
your sludge disposal procedures.
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Wastewater Discharges
Part I, Chapter 3
Box 3-4 States Approved To Issue NPDES Permits
Alabama
Nevada
Arkansas
New Jersey
California
New York
Colorado
North Carolina
Connecticut
North Dakota
Delaware
Ohio
Florida
Oregon
Georgia
Pennsylvania
Hawaii
Rhode Island
Illinois
South Carolina
Indiana
South Dakota
Iowa
Tennessee
ICansas
Utah
Kentucky
Vermont
Maryland
Virgin Islands
Michigan
Virginia
Minnesota
Washington
Mississippi
West Virginia
Missouri
Wisconsin
Montana
Wyoming
Nebraska
As of May 8, 1995. To get the most current information on the status of state NPDES permit
programs, contact U S. EPA, Office of Water, Permits Division
, NPDES Program Branch, 202-
260-8486
¦ An Anticipated Noncompliance Report if you plan any
facility changes that might result in noncompliance with the
requirements in your permit.
¦ A 24-Hour Noncompliance Report if a noncompliance could
endanger human health or the environment (e.g., an
unanticipated bypass or upset condition causes effluent
limitations to be exceeded).
¦ Additional reports if some other type of noncompliance
occurs or if you subsequently become aware that you failed
to submit relevant information (or submitted incorrect
information) in your permit application.
As with monitoring and compliance reports, specific requirements
and due dates for these reports will be specified in your permit.
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Wastewater Discharges
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3.1.5.3 Renewal of the NPDES Permit
NPDES permits are normally effective for a period of 5 years (40
CFR 122.46). States have the authority to establish a more
frequent renewal cycle at their discretion. Check with your
permitting authority to find out how often your permit must be
renewed. Metal finishers should be aware that renewal of NPDES
permits normally incorporates changes in water quality standards,
requirements for best management practices, and other conditions
adopted by the permitting authority since the permit was last issued.
You should check with your permitting authority well in advance of
permit renewal to identify new limits or other conditions that may
be attached to your permit.
3.1.6 How Pollution Prevention Can Reduce the Regulatory
Burden for Wastewater Discharge
Most wastewater from metal finishing operations contains potential
toxins. For this reason, both indirect and direct discharging metal
finishers incur a substantial regulatory burden for wastewater
discharge. In particular, many direct discharging metal finishers
have to comply with very stringent limits for metals and perform
toxicity testing of their treated effluent. Companies that explore
pollution prevention as the first line of defense against these
stringent requirements may find they can avoid expensive add-on
controls, decrease their operating costs, and minimize the chemicals
needed for wastewater treatment.
Pollution prevention alternatives include source reduction, water
conservation, recycling, reuse, and metal recovery before final
effluent treatment. Chapter 10 provides more information about
pollution prevention generally.
In many cases, zero discharge systems (also known as closed loop
systems) can be devised to entirely recycle, recover, and reuse
plating solutions and water in a metal finishing operation. This
eliminates the need to discharge any effluent at all. Box 3-5 defines
zero discharge systems and describes an important regulatory issue
that both direct and indirect discharge metal finishers who seek to
achieve zero discharge should be aware of.
December 1996
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Wastewater Discharges
Part I, Chapter 3
Box 3-5 Zero Discharge Systems and an Important Regulatory Issue for
Direct and Indirect Dischargers
What is a zero discharge system?
Zero discharge systems (also called closed-loop plating) use a combination of rinsing
modifications, drag-out recovery, and wastewater treatment that allows a plating shop to
reuse nearlv 100 percent of all the water in a plating process line. In these systems, all
wastewater is reclaimed and internally reused, so there is no discharge of wastewater.
Are there really zero discharges?
No, the "zero" refers onlv to the fact that no water is discharged. Often, there are air
emissions (mostlv water vapor) and solid wastes (spent filters, ion exchange resins,
cathodes, etc). Metals in the solid wastes may be reclaimed.
Can metal finishers with zero discharge systems retire their Control Authority or NPDES
permits?
Although, technically, you may have no discharge, you run a "regulatory risk" if you don't
have a wastewater discharge permit or agreement. Here's why.
As a metal finisher, you are treating plating wastes and wastewaters that are considered
to be listed and characteristic hazardous wastes. As a discharger with an NPDES permit
or a Control Authority permit under the Clean Water Act, however, you are exempt from
many of the hazardous waste treatment, storage, and disposal facility requirements under
the Resource Conservation and Recovery Act (RCRA), notably the requirement to obtain
a RCRA Part B permit (see Chapter 7 for a description of the RCRA requirements).
Simply put, the EPA and your state environmental agency let you avoid parts of the
RCRA program as long as you maintain some connection to a permitting authority or a
Control Authority authorized under the Clean Water Act. It's a matter of jurisdictional
control. If you throw out your discharge permit, there's no guarantee a RCRA inspector
won't come knocking on your door!
What can be done?
If you are considering installing a zero discharge system, discuss this with your Control
Authority or permitting authority. Some Control Authorities and permitting authorities
are issuing what they call "zero discharge permits." Essentially, these recognize the fact
that, with your current zero discharge configuration, you have no effluent discharges to
either a POTW or to receiving waters; however, for oversight purposes only, the permit
extends the CWA's RCRA exemption to your facility.
Zero discharge permits may have reduced fees and few reporting or recordkeeping
requirements. But thev may require that your system be certified by a registered
professional engineer, and this can cost several thousand dollars.
December 1996
3-15
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Wastewater Discharges
Part I, Chapter 3
3.2 State Programs
Table 3-1 summarizes the general regulatory requirements
associated with the discharge of metal finishing wastewaters for
selected states. Wastewater discharges from metal finishing facilities
are generally directed to POTWs, surface waters, or infrequently to
subsurface or land application. The regulatory summary presented
in Table 3-1 provides a basis for comparing the varying levels of
wastewater quality control and regulatory involvement associated
with each of these alternatives. In the event that specific decisions
must be reached for an individual discharger, your state contact
(identified in Table 3-1) or local Control Agency should be
consulted for further information.
Discharge to a POTW is the most common wastewater disposal
alternative utilized by metal finishers. Since the federal Industrial
Pretreatment Program (IPP) regulations specif/ a significant level of
regulatory control that must be exercised at most POTWs,
implementation of IPPs within the various states follows a fairly
consistent pattern. The state role in administering an IPP is largely
dependent on the state's status with respect to NPDES delegation.
When the authority to administer NPDES programs has been
delegated to a state, then ths state's laws and regulations define and
enforce the administration of IPPs. NPDES-delegated states may
then assume the responsibility for directly permitting and regulating
industrial discharges to POTWs, or alternatively, require that the
POTWs develop and administer their own IPPs. In most states,
whether NPDES-delegated are not, IPPs are administered by the
municipalities, sewerage districts, or counties that operate the
POTWs.
NPDES delegation also determines whether the state or the EPA
will issue permits to direct dischargers under the NPDES program.
Even without NPDES delegation, individual states often will be
involved in the NPDES permitting process, or in certain cases,
operate their own permitting program in parallel to the NPDES
program.
Metal finishers are no longer likely to select land application or
subsurface disposal as alternatives for process wastewater disposal.
December 1996
3-16
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Wastewater Discharges
Part I, Chapter 3
Although the regulatory framework exists in many states that allows
for consideration of these types of discharges, this discharge option
is generally unfavorable in comparison to direct discharge or
discharge to a POTW. Table 3-1 provides limited information on
these programs. The appropriate state agency should be contacted
for additional details if land application or subsurface disposal
appear to be the only viable wastewater disposal options.
3.3 Where To Go for Further Information
For more information on meeting wastewater pollutant limitations,
contact:
¦ Your Control Authority (if you are an indirect discharger).
¦ Your permitting authority (if you are a direct discharger).
You can also obtain the Code of Federal Regulations (CFR)
to read the original regulatory language:
— Pretreatment regulations are found at 40 CFR Part 403
— Effluent guidelines are found in 40 CFR Parts 413
(Electroplating) and 433 (Metal Finishing).
The Code of Federal Regulations a n be found in many libraries, or
may be obtained by calling the Government Printing Office Order
Desk at 202-783-3238 or by writing:
Superintendent of Documents
Attn.: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
December 1996
3-17
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Table 3-1 Summary of Selected State Wastewater Programs
State
AZ
Laws and Regulations
Non EPA-Authorized NPDES
Program State Arizona RSA, Title
49 - Arizona Environmental
Quality Act
AZ Administrative Code Title 18,
Chapter 1 I, Article I - Water
Quality Standards for Surface
Waters
AZ Administrative Code Title 18,
Chapter 9, Article I - Aquifer
Protection Permit Program (there
are no State rules that directly
relate to I Pi's or dischargers to
POTWs)
Permits and Reporting
Permitting is required for discharge
to POTWs with EPA-approved
IPPs. The specific permitting
requirements for other POTWs
may vary, as no umbrella
permitting is mandated by the
State. Reporting requirements are
at the discretion of the POTW, but
must at a minimum satisfy federal
requirements (semiannual).
NPDES Permits for direct
dischargers are drafted by the
State and issued by EPA. NPDES
holders also must obtain an
Aquifer Protection Permit from the
State. Direct discharging metal
finishers should anticipate
monthly monitoring initially, with
a reduced frequency possible after
a compliance history has been
established. General Permits are
available for storm water and for
non-contact cooling water flows
that are less than 1,000 gpd.
Aquifer Protection Permits are also
applicable for discharges to surface
impoundments, injection wells or
land application; however, no
metal finishers are currently
identified that use this disposal
option. Relatively significant
Aquifer Protection Permit
application fees are assessed for
both direct and subsurface
dischargers.
Discharge Effluent Limitations
Metal finishers discharging to
POTWs arc subject to the more
restrictive of local limits or federal
standards. The IPPs of certain
POTWs arc subject to federal
oversight and would control
metals, organics, and any other
identified pollutants of concern.
Direct dischargers will have permit
limits based on the federal effluent
guidelines, or the State's Surface
Water Quality Standards,
whichever is more restrictive.
For discharges to surface
impoundments, injection wells or
land application, the Aquifer
Water Quality Standards apply at
the point of compliance.
State Contact(s)
State of Arizona
Department of Environmental
Quality
Water Quality Division
3033 North Central Avenue
Phoenix, AZ 85012-2809
(602) 207-2303
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Table 3-1 Summary of Selected State Wastewater Programs
Slate
CP
Laws and Regulations
CPA-Authorized NPDES Permit
Program
CP General Statutes 22a-4l6, 22a-
430
Regulations of CP State Agencies
22a-430-3, 4
Permits and Reporting
The discharge of any wastewater to
surface water, groundwater, or
sewer requires authorization from
the State agency. Process water
discharges to surface water requires
NPDES permit. Discharges to
sewer requires a State discharge
permit. Minor discharges
(stormwater, non-contact cooling
water, boiler blow-down) are
eligible for coverage under
conditions of General Permit.
Permits are for 5 years and require
timely renewal. Treatment
systems require State approval.
Metal finishing discharges greater
than 10,000 gpd require weekly
monitoring with monthly
reporting. Permit application and
annual fees required.
Discharge Effluent Limitations
More stringent than Federal
limitations. NPDES permits
include BAT-based or numeric
water quality-based limits
(whichever is most stringent) for
metals, cyanide, TSS, 1TO and
many priority pollutants. Whole
effluent aquatic toxicity testing is
also required. Discharges to sewers
must meet treatment standards
more stringent than Federal
requirements for metals, cyanide,
pH, TSS and ITOs.
State Contact(s)
Connecticut Department of
Environmental Protection
Bureau of Water Management
Permitting, Enforcement and
Remediation Division
79 Elm Street
Hartford, CP 06106-5127
(860)424-3705
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Table 3-1 Summary of Selected State Wastewater Programs
State
Laws and Regulations
Permits and Reporting
Discharge Effluent Limitations
State Contact(s)
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MA
Non EPA-Authorized NPDES
Program State
Massachusetts Clean Water Act
Massachusetts General Laws
(Chapters 21 -26
Division of Water Pollution
Control Regulations:
i 1 4 Code of MA Regulations 1.00
- 15.00
360 Code of MA Regulations 1.00
- 12.00
Metal finishers discharging to
POTWs are subject to the more
restrictive of local limits or federal
categorical standards. The IPPs of
larger POTWs are subject to
federal oversight and would
control mctnls, organics, and any
other identified pollutants of
concern. Local limits are
developed by the State on an as-
required basis for POTWs that are
not required to implement EPA-
approved IPPs.
Direct dischargers will have permit
limits based on the federal effluent
guidelines, or the State's Surface
Water Quality Standards,
whichever is more restrictive.
For subsurface discharges,
Groundwater Quality Standards
would be considered in
development of permit limitations.
A 5-year State Sewer Connection
permit is required for all industrial
user discharges to POTWs and
requires an application fee and
annual compliance fee. Permitting
from both the POTW and the
State is required for discharge lo
PO TWs with EPA-approved IPPs.
Monitoring and reporting
requirements in permits are at the
discretion of the POTW (or the
Slate if only a Sewer Connection
permit is issued), but are generally
consistent with federal
requirements (minimum of
semiannual). The State is
developing a Certification Process
that is intended to replace the
existing Sewer Connection permit
program.
NPDES permits for direct
dischargers are certified by the
State and issued by EPA, requiring
submittal of both EPA and State
application forms. Application
fees and annual compliance fees
are assessed by the State. Metal
finishers should anticipate
monitoring for metals, organics,
and WET. General Permits are
available for storm water and non-
contact cooling water.
Groundwater Discharge Permits
ate issued; however, no metal
finishers are currently identified
that use this disposal option.
Massachusetts Department of
Environmental Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108
(617) 292-5500
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Table 3-1 Summary of Selected State Wastewater Programs
Slate
Laws and Regulations
Permits and Reporting
Discharge Effluent Limitations
State Contact(s)
Ml
EPA-Authorized NPDES Permit
Program State
Michigan Environmental Act No.
45 I of the Public Acts of 1994,
Parts 31 and 41
Executive Orders Nos. 199 1 -31,
1995-4, 1995-18 of the Michigan
Compiled Laws
Michigan Administrative Code
Rules 323.1001 through 323.2317
Water Resources Commission
General Rules (Internet available)
All POTWs in the State receiving
industrial wastewater are required
to implement State-approved IPPs
that require permitting. Multi-
jurisdictional IPPs are the rule.
Any fees are locally administered.
Permit writing and monitoring
activities are managed by the
approved IPPs without the need
for State review. The IPPs
generally mirror the federal
requirements, except the IPPs
administered by small POTWs
(i.e., those not required by EPA to
develop IPPs) may be less
comprehensive.
Direct dischargers are required to
obtain a NPDES permit from the
State with a maximum duration of
5 years. Reporting frequencies and
analytes are based on the permit
writer's best judgment considering
the pollutants present and
associated flows, as well as the
federal effluent guideline
pollutants. Permit application and
annual fees are assessed only for
stormwater permits. General
permits are available for storm
water, non-contact cooling water,
and treated groundwater from
petroleum product release
remediation sites.
Groundwater discharge permitting
is required. The 5-year permits
require hydrogeological study, and
Development of local limits for
metals is consistent with EPA-
recommended procedures. The
State requires POTWs to evaluate
a minimum of 10 metals for local
limits, and to identify other
pollutants of concern. There are
no State-wide numerical pollutant
limits.
Effluent limits for direct
dischargers are based on the
federal effluent guidelines and
water quality standards. The State
also considers background loadings
and develops waste load
allocations in establishing permit
limits as part of its watershed
basin approach to permit issuance.
Groundwater discharge limits
would be developed for metals and
organic compounds based on the
Groundwater Permitting Rules
non-degradation policy, and
generally would be established at
concentrations equivalent to 20
percent of the clean-up standards.
Michigan Department of
Environmental Quality
Surface Water Quality Division
P.O. Box 30273
Lansing, Mi 48909-7773
(517)373-1949
Environmental Assistance Division
1-800-662-9278
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Table 3-1 Summary of Selected State Wastewater Programs
State
Laws and Regulations
Permits and Reporting
Discharge Effluent Limitations
State Contact(s)
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lil'A-Aiithorized NPDES Permit
Program State
Minnesota Statutes I03A through
I6l (Internet accessible)
Minnesota Rules:
7001 - State Permitting Rules
7050 - Standards for Protection of
Water Quality and Purity
7060 - Protection of Groundwater
(there are no State rules that
directly relate to lPPs or
lischargcrs to POTWs)
Indirect dischargers are subject to
the federal prohibited discharge
standards, categorical discharge
standards, and local limits.
Development of local limits for
metals is consistent with EPA-
recommended procedures.
Numerical Tl'O local limits are
generally absent. A few POTWs
discharge to lakes and may have
relatively restrictive limits.
Effluent limits for direct
dischargers are based on the
federal effluent guidelines and the
State's Surface Water Quality
Limits. Pollutant parameters
limited include federal effluent
guideline listed pollutants plus any
other identified constituents
present at concentrations that
represent a reasonable potential to
exceed water quality standards.
WET limits are generally imposed
only when unresolved toxicity
issues are identified.
Dischargers to POTWs are
required to obtain permits from
the POTWs. In addition, metal
finishers at POTWs without
Minnesota Pollution Control
Agency- (MPCA-) approved lPPs
must also obtain a State Disposal
System permit from the MPCA.
The MPCA anticipates that a
General Permit for Metal Finishers
will be available for these POTW
dischargers. Multi-jurisdictional
I Pi's are present in the
Minneapolis/St. Paul and Duluth
areas. Permit writing anil
monitoring activities are managed
by the MPCA-approved lPPs
without the need for State review,
and generally are consistent with
EPA guidance.
Direct dischargers are required to
obtain a "NPDES and State
Disposal System Permit" from the
MPCA using State and standard
EPA application forms. Permit
application and annual fees are
assessed. Reporting frequencies
and analytes are based on the
permit writer's judgment
considering the pollutants present
and associated flows. WET testing
is required. General permits are
available for storm water, non-
contact cooling water, and treated
groundwater from petroleum
remediation sites.
Minnesota Pollution Control
Agency
Water Quality Division
520 Lafayette lload North
St. Paul, MN 55155-4194
(612) 296-6300
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Table 3-1 Summary of Selected State Wastewater Programs
State
Laws and Regulations
Permits and Reporting
Discharge Effluent Limitations
State Contact(s)
N|
F.PA-Authorized NPDES Permit
Program State
New |ersey Statutes Annotated 58
New Jersey Administrative Code
Title 7:
Chapter 14A - New Jersey
Pollutant Discharge Elimination
System
Chapter 9R - Surface Water
Quality Standards
Permitting for discharge to
POTWs with State-approved IPPs
is required and is coordinated
through the POTWs. Several
multi-jurisdictioiial IPPs may
involve regulatory control at both
the municipal and POTW levels.
For other POTWs without state-
approved IPPs, the State requires
and issues NJPDES Significant
Industrial User permits to metal
finishers and assesses annual fees
based on discharge characteristics.
Reporting frequency and analytcs
are at the discretion of the permit
issuer, but must at a minimum
satisfy federal requirements
(semiannual).
NJPDES Permits for direct
dischargers are issued by the State
for durations up to 5 years, and
require submittal of the standard
EPA application and State-specific
forms. There is no application fee,
but an annual fee based on
discharge toxicity factor is
assessed. Monitoring and
reporting requirements are at the
discretion of the permit writer, but
generally are monthly for initial
permits and include WET testing
and federal effluent guideline
liited pollutants. General Permits
are available for storm water, non-
contact cooling water and
petroleum product clcan-up
discharges.
Metal finishers discharging to
POTWs are subject to the more
restrictive of local limits or federal
categorical standards. Local limits
are subject to State approval and
are developed consistent with EPA
guidance for identified pollutants
of concern. The State calculates
local limits on an as-needed basis
for POTWs that are not required
to implement State-approved IPPs.
Direct dischargers will have permit
limits based on the federal effluent
guidelines, State Effluent
Standards, best available
technology, or whole effluent
toxicity, whichever is more
restrictive. WET limits are
incorporated into permits as an
alternative to water quality-based
limits.
Groundwater discharge limits for
pollutants expected to be present
in the discharge would be based on
the State Groundwater Quality
Standards with consideration of
site-specific hydrogeological
conditions.
New Jersey Department of
Environmental Protection
Division of Water Quality
401 East State Street
cyo2y
Trenton, NJ 08625-0029
((>09) 292-4543
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Table 3-1 Summary of Selected State Wastewater Programs
Slate
NY
Laws and Regulations
El'A-Authorized NPDES Permit
Program Slate
(Iwt not IPP-Authorized)
New York Environmental
Conservation Laws Article 17,
Titles 7 8
Uniform Procedures Act, Article 70
New York Environmental Quality
Review Act, Article 8
New York Code of Rules and
Regulations Title 6, Parts 485,
617, 621, 700-705, and 750-757
Permits and Reporting
POTW pollutant discharge limits
are locally developed. Limits are
based on the site-specific
characteristics associated with each
POTW, and are approved by the
State.
Effluent limitations for direct
dischargers are based on the.
State's Surface Water Quality
Standards and the federal
categorical effluent guidelines.
Groundwater effluent standards
for metals and organics provide the
basis for subsurface discharge
limitations.
Discharge Effluent Limitations
Permitting is required at all POTWs that
are required by federal regulations to
administer IPPs. All other POTWs in
the State receiving industrial wastewater
from Significant Industrial Users arc
required by the State to implement
abbreviated IPPs that require permitting.
Any fees are locally administered.
Permit writing and monitoring activities
are managed by the IPPs without the
need for Slate review and comply with
the minimum federal requirements.
As an NPDES-dclegated state,
direct dischargers must obtain
State Pollutant Discharge
Elimination System (SPDES)
permits using the standard EPA
application forms. Metal finisher
must also submit the Application
Supplements for Metal Finishers.
Annual fees are based on the
discharge characteristics and
maximum permit duration is five
years. Minimum monitoring
frequency is monthly for all
federally regulated pollutants.
WET testing may be required.
Stormwater general permits are
available, but non-contact cooling
water and boiler blowdown require
SPDES permits.
Groundwater discharge permitting
is also required and administered
by the SPDES permit program.
State Contact(s)
New York State Department of
Environmental Conservation
Division of Compliance Services
50 Wolf Road
Albany, New York 12233-1750
(518)457-2224
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Table 3-1 Summary of Selected State Wastewater Programs
State
Laws and Regulations
Permits and Reporting
Discharge Effluent Limitations
Slate Contact(s)
El'A-Authorized NPDES Permit
Program State
North Carolina General Statute
130A- Wastewater Systems
North Carolina Administrative
Code (NCAC) Chapter I5A,
2 HO 101 - Wastewater Discharges
to Surface Waters
I5A NCAC 2H.0900-Pretreatinent
Programs
Limits for discharges to POTWs
are developed on a site-specific
basis following the EPA-established
model and are promulgated in
local SUOs.
Direct discharger:, have permit
limits based on federal effluent
guidelines and surface water
quality standards, whichever is
more restrictive. Limits include
WET chronic pass/fail based on
the dilution factor available for the
receiving stream.
Groundwater quality standards are
considered in development of
limits for proposed industrial
subsurface disposal systems.
Permits for discharges to POTWs
are required and are issued by the
POTWs, after DENHR review and
approval. There are no fees
assessed at the state level. Several
POTW programs are county-wide
or nutlli-jurisdictional. Minimum
reporting frequency for metal
finishers is usually 4 days every 6
months.
NPDES permits are required for
surface water discharges and are
issued by the DEHNR. Permit
duration is usually five years, with
issuance scheduled on a watershed
basis.. General Permits are issued
for stormwater, non-contact
cooling water, and boiler
blowdown. In addition to self-
monitoring, DENHR annually
monitors NPDES permit-holders
and assesses monitoring fees.
DENHR and local health
department approval is required
for on-site wastewater disposal
systems; however, this option is
restrictive and no on-site metal
finishing discharges are currently
approved in the State.
North Carolina Department of
Environment, Health Natural
Resources
Division of Water Quality
512 Salisbury Street
Raleigh, NC 27601
(919) 733-5083
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Table 3-1 Summary of Selected State Wastewater Programs
Stale
III
Laws and Regulations
EPA-Authorized NPDES Permit
Program State
Rhode Island General Laws 42-
l 7.1, 42-35.
46-12. and 46-13.1
Rhode Island Water Quality
Regulations for Water Pollution
Control
Rhode Island Pretreatment
Regulations
Rhode Island PDES Regulations
Rhode Island Discharge Fee
Regulations
Underground Injection Control
Program Rules and Regulations
Permits and Reporting
POTW pollutant discharge limits
are locally developed, are based on
the site-specific characteristics
associated with each POTW. and
are approved hy the State.
Effluent limitations for direct
dischargers are based on the most
stringent of three criteria: receiving
stream waste load allocations,
antidegradation policy and the
federal categorical effluent
guidelines.
Groundwater quality standards
would provide the basis for
subsurface discharges.
Discharge Effluent Limitations
POTWs require and issue permits,
without the requirement for
concurrent State review and
approval. Reporting requirements
are established by each POTW and
comply with federal requirements.
The Narragansett Bay Commission
administers an IPP with multi-
jurisdictional authority. As an
NPDES delegated state, direct
dischargers must submit Rhode
Island Pollutant Discharge
Elimination System (RIPDES)
applications 6-months prior to
initiation of discharge and obtain
permits from the State.
Application fees are based on the
permitting status (major/minor)
and permit duration is five years.
Minimum monitoring frequency is
monthly. Parameters include
WET testing. Stormwater general
permits are available, but non-
contact cooling water and boiler
blowdown require R1PDES
permits. Groundwatc • discharges
are authorized by Orders of
Approval, but are typically
intended for stormwater
infiltration basins and groundwater
remediation projects.
State Contact(s)
Department of Environmental
Management
Division of Water Resources
235 Promenade Street
Providence, R1 02908-5767
(401) 277-3961
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Table 3-1 Summary of Selected State Wastewater Programs
State
Laws and Regulations
Non-EPA-authorized NPDES
program.
Authorization to administer
NPDES permits and regulate IPPs
is anticipated in 1997.
Texas Codes Annotated; Chapter
26 - Texas Water Code
Texas Administrative Code Title
30, Chapters 305, 307, 309, 317,
319, 331 (Internet available)
Permits and Reporting
POTW pollutant discharge limits
are locally developed, are based on
the site-specific characteristics
associated with each POTW, and
are approved by EPA.
Direct discharger permit limits are
based on the most restrictive of:
federal effluent guidelines, surface
water quality considerations, and
State-wide hazardous metals
quality levels (30 TAC 319.22,
319.23).
Dischargers to POTWs with EPA-
approved IPPs must obtain
ndustrial wastewater discharge
permits from the POTWs.
Reporting requirements are
established by each POTW and
comply with federal requirements.
POTWs that are not required to
have EPA-approved IPPs may also
require permitting. Texas is not
currently NPDES-authorized and
imposes no IPP requirements on
lUs or IPPs.
Discharge Effluent Limitations
Slate Contact(s)
Texas Natural Resource
Conservation Commission
Agriculture and Watershed
Management Division
Wastewater Permit Section-
MC148
12100 Park 35 Circle
P.O. Box 13087
Austin, TX 78711-3087
(512) 239-4433
Direct dischargers must obtain
applications and permits from
both the TNRCC and EPA.
TNRCC Wastewater Discharge
Permit applications require
comprehensive facility and site-
related information. 5-year permits
are issued on a watershed basis.
TNRCC permit monitoring
requirements vary according to the
nature of the discharge, range from
i weekly to annually, and include
WET testing. Permittees must
also satisfy all EPA NPDES permit
monitoring. TNRCC permit
application fees are assessed.
TNRCC Stormwater permits are
required based on site evaluations.
Non-contact cooling water
discharges require TNRCC
Wastewater Discharge Permits.
The State administers an
underground injection control
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Table 3-1 Summary of Selected State Wastewater Programs
State
Wl
Laws and Regulations
EPA-Authorized NPDES Permit
Program State
Wisconsin Statutes Annotated,
Chapter 147 - Pollution Discharge
Elimination
Wl Administrative Code:
Chapter NRMO - Groundwater
Quality
Wastewater Management
(NR200-NR299)
Chapter NR 200 - Application for
Discharge Permits
Chapter NR21 I - General
Pretreatment Requirements
Chapters NR221 through NR 297
- Categorical Pretreatment
Standards
Chapter NR2I4 - Land
Application and Disposal of Liquid
Industrial Wastes and By-Products
Permits and Reporting
Metal finishers discharging to
POTWs are subject to the more
restrictive of local limits or federal
standards. The IPPs are subject to
State oversight ;;nd typically
control metals, organics, and any
other identified pollutants of
concern.
Direct dischargers will have permit
limits based on the federal effluent
guidelines, or the Stale's Water
Quality Standards, whichever is
more restrictive. WET limits are
not generally incorporated into
new permits, but are added if
persistent toxicity problems are
identified.
Land application disposal
restrictions are based on the
Preventive Action Limits in the
Groundwater Quality Code.
Discharge Effluent Limitations
Permitting for discharge to
POTWs with State-approved IPPs
is required and is coordinated
through the POTWs. For other
POTWs, the State issues
Pretreatment Contiol Documents
to metal finishers. Reporting
frequency and analytes are at the
discretion of the permit issuer, but
must at a minimum satisfy federal
requirements (semiannual).
WPDES Permits for direct
dischargers are issued by the State
for durations up to 5 years, and
require submittal of the standard
EPA application forms. There is
no application fee, but an annual
fee based on permit limitations
and actual discharges is assessed.
Monitoring and reporting
requirements are at the discretion
of the permit writer, but would
likely include WET testing.
General Permits are available for
storm water (requires application
fee and annual fee payment) and
for non-contact cooling water and
boiler blowdown discharges.
A land disposal permitting
program is in place, but is
primarily geared to industrial
discharges that contain
conventional pollutants only.
State Contact(s)
Wisconsin Department of Natural
Resources
Water Division
I0I South Webster Street
P.O. Box 7921
Madison, Wl 53707
(608) 266-1099
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APPENDIX 3-A
COMPLIANCE CALENDAR FOR FEDERAL
WASTEWATER DISCHARGE REQUIREMENTS
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o
ft
o
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APPENDIX 3-B
CONTACT INFORMATION FOR NPDES-APPROVED STATES
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Wastewater Discharges
Part I, Chapter 3
Alabama
Mr. Charles Horn. Chief
VVater Division
AL Dept. of Environmental Mgmt.
I 751 Congressman Dickenson Dr.
Montgomery, AL 36130
(205) 271-7950
Alaska
Ms. Deena Henkins, Chief
Water &. Wastewater Treatment Section
AK Dept. of Environmental Conservation
410 Willoughbv Ave.
Juneau, AK 99801
(907) 465-5300
Arizona
Mr. Brian Munson, Assistant Director
Water Quality
AZ Dept. of Environmental Quality
3033 N. Central Ave.
Phoenix, AZ 85012-2810
(602) 207-2384
Arkansas
Mr. Chuck Bennet, Chief
Water Division
AR Dept. of Pollution Control &. Ecology
8X)1 National Drive
Little Rock, AR 722 19-8913
(501) 570-2114
California
Mr. John Youngerman, Director
Division of Water Quality
CA State Water Resources Quality Control
Board
P.O. Box 100
901 P Street
Sacramento, CA95814
(916) 657-1013
Colorado
Mr David Holm, Director
Water Qualitv Control Div.
CO Dept. of Public Health St Environment
WQCD-DO-B2
4300 Cherrv Creek Drive South
Denver, CO 80222-1530
(303) 692-3508
Connecticut
Mr. Robert Smith, Chief
Water Mgmt. Bureau
CT Dept. of Environmental Protection
79 Elm Street
Hartford. CT 06106-5127
(203) 424-3017
Delaware
Ms. Sarah Cooksev, Administrator
Delaware Coastal Mgmt.
DE Dept. of Natural Resources
Div. of Environmental Control
89 Kings Hwy, PO Box 1401
Dover, DE 19903
(302) 739-3451
Florida
Mr. Richard Drew, Chief
Division of Water Facilities
Bureau of Water Facilities
Planning and Regulation
FL Dept. of Environmental Protection
2600 Blairstone Rd.
Tallahassee, FL 32399-2400
(904) 487-0563
Georgia
Mr. Alan Hallum, Chief
Water Protection Branch
GA Dept. of Natural Resources
205 Butler Street, Suite 1058
Atlanta, GA 30334
(404) 656-4708
Hawaii
Mr. Dennis Lau, Chief
Clean Water Branch
HA Dept. of Health
919 Ala Moana Blvd., Rm. 301
Honolulu, HI 96814
(808) 586-4309
Idaho
Mr. Orville Green, Asst. Administrator
Permits and Enforcement
ID Div. of Environmental Quality
1 4 10 N. Hilton - State House Mall
Boise. ID 83706
(208) 334-5898
December 1996
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Wastewater Discharges
Part I, Chapter 3
Illinois
Mr. Tom McSwiggin, Manager
Permits Section
Bureau of Water
IL Environmental Protection Agency
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217) 782-0610
Indiana
Mr. Lonnie Brumfield, Chief
Permits Section
IN Dept. of Environmental Mgmt.
105 S. Meridian St., Rm. 719
Indianapolis, IN 46206-6015
(317) 232-8705
Iowa
Mr. Wayne Farrande
Environmental Protection Division
IA Dept. of Natural Resources
Henry A. Wallace Bldg.
900 East Grand Ave.
Des Moines, IA 50319-0034
(515) 281-8877
Kansas
Mr. Karl Mueldener, Director
Bureau of Water
ICS Dept. of Health &. Environment
Bldg. 740, Forbes Field
Topeka, ICS 66620
(913) 296-5500
Kentucky
Mr. Jack Wilson, Director
Division of Water
ICY Dept. of Natural Resources and
Environmental Protection Cabinet
Fort Boone Plaza, 14 Reilly Rd.
Frankfort, ICY 40601
(502) 564-3410
Louisiana
Mr. Dale Givens, Asst. Secretary
Office of Water Resources
LA Dept. of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-22 1 5
(504) 765-0634
Maine
Mr. Stephen Groves, Director
Bureau of Water Quality Control
ME Dept. of Environmental Protection
State House, Station #17
Augusta, ME 04333
(207) 287-3901
Maryland
Mr. Jeff Rein, Administrator
Wastewater Discharge and Permit Program
Water Management Administration
MD Dept. of Environment
2500 Broening Hwy.
Baltimore, MD 21224
(410) 631-3752
Massachusetts
Mr. Brian Donahoe, Director
Division of Water Pollution Control
MA Dept. of Environmental Protection
One Winter St., 8th Floor
Boston, MA 02108
(617) 292-5635
Michigan
Mr. Robert Miller, Chief
Surface Water Quality Div.
MI Dept. of Natural Resources
P.O. Box 30273
300 South Washington St.
Lansing, MI 48933-7773
(517) 373-1949
Minnesota
Ms. Patricia Burke, Manager
Water Quality Division
MN Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-7202
Mississippi
Mr. Barry Royals, Chief
Surface Water Division
MS Dept. of Environmental Quality
P.O. Box 10385-0389
Jackson. MS 39289-0385
(601) 961-5102
December 1996
3-B2
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Wastewater Discharges
PartI, Chapter 3
Missouri
Mr. Daniel Schuette. Chief
Permits Section
Water Pollution Coatrol Program
MO Dept. of Natural Resources
P.O. Box 176
205 Jefferson Street
Jefferson City. MO 65102
(314) 751-6825
Montana
Mr. Stephen Pilcher, Acting Administrator
Water Quality Division
MT Dept. of Health Sc. Environmental Sciences
P.O. Box 200901
Helena. MT 59620-0901
(406) 446-2406
Nebraska
Mr. (J. Gale Hutton. Asst. Director
Water Quality Division
NE Dept. of Environmental Control
Suite 400. The Atrium
P.O. Box 98922
Lincoln. NE 68509
(402) 471-2909
Nevada
Mr. Wendell McCurry; Bureau Chief
Water Qualicv.Planaing
NV Div. of Environmental Protection
333 W. Nve Lane. Capital Complex
Carson City. NV 89710
(702) 687-4670
New Hampshire
Mr. Raymond Carter
Administrator for Water Quality
Water Supply &. Pollution Control Div.
NH Dept. of Environmental Services
6 Hazen Drive
Concord. NH 03301
(603) 271-3503
New Jersey
Mr. Dennis Hart. Administrator
Environmental Regulations
Division of Water Quality
NJ Dept. of Environmental Protection Sc.
Energy
CN029, 401 E. State St.
Trenton. NJ 08625-0029
(609) 292-4543
New Mexico
Ms. Kathleen Sisneros. Director
Water Sc. Waste Mgmt. Division
NM Environment Dept.
P.O. Box 26110
Sante Fe. NM 87502
(505) 827-2855
New York
Mr. N.G. (Caul. Director
Division of Water
NY Dept. of Environmental Conservation
50 Wolf Rd.. Rm. 306
Albany. NY 12233-3500
(518) 457-6674
North Carolina
Mr. Steve Tedder. Chief
Water Quality Section
Division of Environmental Mgmt.
NC Dept. of Environment, Health &. Natural
Resources
P.O. Box 29535
Raleigh. NC 27626-0535
(919) 733-5083
North Dakota
Mr. Francis J. Schwindt. Chief
Environmental Health Section
N'D Dept. of Health
P.O. Box 5520
Bismarck. ND 58502-5520
(701) 221-5150
Oecember 1996
3-83
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Wastewater Discharges
Part I, Chapter 3
Ohio
Mr. Paul Novack, Manager
Permits Section
Division of Surface Water
OH Environmental Protection Agency
1800 Watermark Drive
Columbus, OH 43216-3669
(614) 644-2035
Oklahoma
Mr. John Craig, Director
Water Quality Division
OK Dept. of Environmental Quality
1000 N.E. 10th Street
Oklahoma City. OK 73117-1212
(405) 271-5205
Oregon
Mr. Michael Downs, Administrator
Water Quality Division
OR Dept. of Environmental Quality
811 SW 6th Ave.
Portland. OR 97204- 1390
(503) 229-5324
Pennsylvania
Mr. Stuart Gansell
Div. of Permits &. Compliance
Bureau of Water Quality Mgmt.
PA Dept. of Environmental Resources
P.O. Box 8465
400 Market Street
Hanisburg, PA 17105-8465
(717) 787-2666
Rhode Island
Mr. Edward S. Svmanski, Associate Director
Water Quality Management
RI Dept. of Environmental Mgmt.
291 Promenade St.
Providence. RI 02908-5767
(401) 277-3961
South Carolina
Mr. Russell Sherer, Chief
Bureau of Water Pollution Control
SC Dept. of Health and Environmental Control
2600 Bull Street
Columbia. SC 29201
(803) 734-5296
South Dakota
Mr. Kent Woodmansey
Point Source Program
SD Dept. of Environment &. Natural Resources
Joe Foss Bldg., 523 E. Capitol
Pierre. SD 57501-3181
(605) 773-3151
Tennessee
Mr. Paul Davis, Director
Div. of Water Pollution Control
TN Dept. of Environment &. Conservation
401 Church St.
LC Annex, 6th Floor
Nashville, TN 37243-1534
(615) 532-0625
Texas
Mr. Warren Davis, Director
Watershed Mgmt. Division
TX Natural Resource Conservation Commission
PO Box 13087
Austin, TX 78711-3087
(512) 239-4400
Utah
Mr. Don Osder, Director
Division of Water Quality
UT Dept. of Environmental Quality
PO Box 144870
288 North, 1460 West
Salt Lake City, UT 84116-4870
(801) 538-6146
Vermont
Mr. Gary Schultz, Director
Wastewater Mgmt. Division
VT Dept. of Environmental Conservation
103 S. Maine St.. Annex Office Bldg.
Waterbury, VT 05671
(802) 241-3822
Virginia
Mr. Robert Bumley, Director
Water Division
VA Department of Environmental Quality
P.O. Box 10009
Richmond. VA 23240-0009
(804) 786-8750
December 1996
3-B4
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Wastewater Discharges
Part I, Chapter 3
Washington
Mr. Mike Llewelvn, Manager
Water Quality Program
VVA Dept. of Ecology
P.O. Box 47600
Olvmpia, WA 98504-7600
(206) 407-6405
West Virginia
Mr. Lvle Bennett. Chief
Division of Water Resources
WV Dept. of Natural Resources
1201 Greenbrier St.
Charleston, WV 253 1 1
(304) 558-2108
Wisconsin
Ms. Mary Jo Kopecky, Director
Wastewater Management Bureau
WI Dept. of Natural Resources
PO Box 7921
Madison.WI 53707
(608) 266-3910
Wyoming
Mr. William Garland, Administrator
Water Quality Division
WY Dept of Environmental Quality
122 West 25th Street
Herschler Bldg., 4th Floor West
Cheyenne, WY 82002
(307) 777-7781
District of Columbia
James A. Collier, Program Manager
Water-Resources Management
Div. Housing and Environmental
Regulations Administration
Water Hygiene Branch, Suite 203
2100 Martin Luther King, Jr. Ave., SE
Washington,D C. 20020
(202) 404-1120
Guam
Fred M. Castro, Administrator
Environmental Protection Agency
IT&E Harmon Plaza, Complex Unit D-107
130 Rojas Street
Harmon, GUAM 96911
011-671-646-8863
Puerto Rico
Pedro A. Maldonado-Ojeda, Esq.
Chairman
PR Environmental Quality Board
P.O. Box 1 1488
San Juan, PR 00910
(809) 767-8056
U.S. Virgin Islands
Marc Pacifico
Territorial Pollution Division
Div. of Environmental Protection
VI Dept. of Planning and Natural Resources
1118 Watergut Homes
Christiansted, St. Croix, VI 00820-5065
(809) 773-0565
December 1996
3-B5
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APPENDIX 3-C
CONTACT INFORMATION FOR
EPA REGIONAL PRETREATMENT COORDINATORS
Source: Provided by Pat Bradley, U.S. EPA Office of Wastewater Management. Pretreatment and Multimedia
Branch, Pretieatment Team (202) 260-6963. Current as of September 1996.
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Wastewater Discharges
Part I, Chapter 3
U.S. EPA Pretreatment Contacts
EPA Region
Name
Telephone No.
Fax
Headquarters
OW/OWM (4203)
401 M Street SW
Washington, DC 20460
Pat Bradley
Louis Ebv
Lisa Hammond
John Hopkins
Jeff Smith
(202) 260-6963
(202) 260-6814
(202) 260-3094
(202) 260-9527
(202) 260-5586
(202) 260-1460
(202) 260-9544
Region I
Municipal Assistance Unit
(CMU)
JFK Federal Building
Boston, MA 02203
Mark SpinaJe
(617) 565-3554
(617) 565-4940
Region II
20th Floor (2DCEA-WCB)
290 Broadway
New York, NY 10007-1866
Virginia Wong
Phil Sweeney
(212) 637-4241
(212) 637-3873
(212) 637-3901
Region III
(3WP24)
841 Chestnut Street
Philadelphia, PA 19107
John Lovell
Steve Copeland
Martin Madin
(215) 566-5790
(215) 566-5792
(215) 566-5789
(215) 566-2302
(215) 566-2301
Region IV
Water Division
100 Alabama Street, SW
Adanta, GA 30303-3104
A1 Hemdon
(404) 347-4793
ext. 4236
(404) 347-1797
Region V
(WN-16-J)
77 W. Jackson Blvd.
Chicago. IL 60604-3507
Matt Gluckman
Carol Staniec (WN-
15-J)
(312) 886-6089
(312) 886-1436
(312) 886-7804
(312) 886-0168
Region VI
(6-WQ-PM)
1445 Ross Avenue
Dallas. TX 75202
Lee Bohme
Mike Tillman
A1 Hernandez
(214) 665-7532
(214) 665-7531
(214) 665-7522
(214) 665-2191
(214) 665-6490
Region VII
726 Minnesota Avenue
Kansas City. KS 66101
Paul Marshall
Mike Turvey
(913) 551-7419
(913) 551-7424
(913) 551-7765
Region VIII
(8WM-C)
999 18th Street. Suite 500
Denver. CO 80202-2466
Curt McCormick
Debra Thomas
(303) 312-6377
(303) 312-6373
(303) 312-6067
December 1996
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Wastewater Discharges
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U.S. EPA Pretreatment Contacts
EPA Region
Name
Telephone No.
Fax
Region IX
Keith Silva
(415) 744-1907
(415) 744-1235
(W-5-2)
75 Hawthorne Street
San Francisco, CA 94105
Region X
(OW-130)
1200 6th Avenue
Seattle. WA 98101-1128
Sharon Wilson
(206) 553-0325
(206) 553-0165
(206) 553-1280
December 1996
3-C2
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APPENDIX 3-D
WHAT DO CONTROL AUTHORITIES CONSIDER WHEN
THEY SET LIMITS FOR INDIRECT DISCHARGERS?
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Wastewater Discharges
Part I, Chapter 3
What Do Control Authorities Consider When They Set Limits for
Indirect Dischargers?
3D. 1 What Do Control Authorities Consider When Setting Pollutant Limits?
When setting pollutant limits for its area of jurisdiction, a Control Authority considers:
¦ Federal effluent guidelines. These are described below in Section D.2.
¦ Prohibited discharge standards developed under the CWA's National Pretreatment
Regulations (40 CFR Part 403). These standards are designed to prevent:
— Discharges that interfere with or disrupt a publicly owned treatment works' (POTW's)
treatment processes, operation, or sludge use or disposal. For example, the sudden
discharge of a slug of highly acidic plating solution may kill the microbes necessary for
proper functioning of the POTW.
— Discharges that pass through the POTW, causing it to exceed its NPDES permit limits
(POTWs that discharge directly to surface waters must obtain their own NDPES
discharge permit). For example, high concentrations of copper, which is not treated by
the POTWs may cause the POTW to violate its permit conditions.
¦ State standards, where applicable. Some states have their own effluent standards that are
at least as stringent as the federal effluent guidelines. (You can find a summary of state
water discharge programs in Section 3.2.)
¦ Any focal limits needed to allow the POTW to meet its NPDES permit. Local limits
consider factors unique to the POTW and local receiving waters. For example, local limits
may be more stringent than federal or state limits to provide additional protection to local
water bodies that are particularly sensitive or threatened. They may also provide additional
protection to the POTW from pass-through or interference.
¦ Total Maximum Daily Load (TMDL) limitations . A TMDL is an estimate, made by the state
or EPA, of the total loading of a pollutant that can be allowed within a particular receiving
water. When a TMDL is calculated, each point source discharging the particular pollutant
to the particular receiving water is assigned a specific wasteload allocation that limits how
much of that pollutant the point source can discharge. The more industries that discharge
a particular pollutant into a receiving water, the lower will be each facility's wasteload
allocation.
3D.2 What Are the Federal Effluent Guidelines?
Under the CWA, EPA developed categorical effluent guidelines (sometimes also referred to as
effluent standards) for industrial facilities in each of over 50 industrial categories, including
"electroplating" and "metal finishing." These effluent guidelines establish maximum allowable
December 1996
3-D1
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Wastewater Discharges
Part I, Chapter 3
levels of pollutants in wastewater discharges. In other words, the Control Authority limits must
be at least as stringent as these guidelines and they can be more stringent.
The federal effluent guidelines cover three categories of pollutants:
¦ Conventional pollutants. These include biological oxygen demand, suspended solids, fecal
coliform, and oil and grease.
¦ Toxic pollutants (also known as priority pollutants). These consist of 126 toxic compounds,
listed in Section 307(a)(1) of the CWA.
¦ Nonconventional pollutants. These include other pollutants known to have adverse effects
and for which accurate measurement techniques have been developed.
EPA established effluent guidelines in each industry category based on data from industrial
pretreatment operations showing what degree of pollutant reductions are possible. Four levels of
effluent guidelines were established depending on the type of pollutant and when the facility began
operations (see Box 3-D1 for more detail).
December 1996
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Wastewater Discharges
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Box 3-D1 Types of Federal Effluent Guidelines3
New Industrial Facilities'5
¦ New Source Performance Standards (NSPS)—New facilities must achieve
effluent levels for toxic and conventional pollutants equivalent to those
achievable bv the best available demonstrated technology.
Existing Industrial Facilities6
¦ Best Available Technology Economically Achievable (BAT)—Existing
facilities must implement controls for toxic and nonconventional pollutants that
are equivalent to the best existing performance in their industry.
¦ Best Conventional Technology (BCT)—Existing facilities must control
conventional pollutants to a degree that is reasonable in light of the cost of
removing the same pollutants in sewage treatment plants.
¦ Best Practicable Control Technology Currently Available
(BPT)—Existing facilities must implement control technologies equivalent
to the average performance of well-operated plants in the industry,c
• EPA used actual pretfeatment data to establish specific limits for each categorical industry within each of these four broad
categories of effluent guidelines.
b In the case of metal finishers, new facilities are facilities that began operating after August 31,1982. Existing facilities
are facilities that were operating on or before that date.
c BPT regulations were ti e first regulations developed for most industries. For some pollutants, the BAT and BCT
regulations "tsblish more stringent limits than the BPT regulations. In th;ie cases, the BAT or BCT regulations supersede
the less stringent BPT regulations.
3D.3 Which Federal Effluent Guidelines Apply to Metal Finishers?
Using pretreatment data from the metal finishing industry, EPA established specific
effluent limits for the "metal finishing" and "electroplating" industry categories. The
"metal finishing" guidelines are referred to as the Part 433 guidelines. The
"electroplating" guidelines are referred to as the Part 413 guidelines. The Part 433
guidelines are considerably more stringent (i.e., lower limits) than the Part 413
guidelines.
Most metal finishers are covered by Part 433 guidelines. If your facility was established
before August 8, 1981, the Part 413 guidelines may apply to you. Review Box 3-D2 to
find out which guidelines apply to your facility.
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3-D3
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Wastewater Discharges
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Box 3-D2 Which Effluent Guideline Applies to My Facility?
(I)
Do you perform any of the following:
¦ Electroplating ¦ Electroless plating
¦ Anodizing ¦ Coating (Cr04, P04)
¦ Chemical etching and milling ¦ Printed circuit board manufacturing
If you answered "no," then your facility is not covered by either of the effluent guidelines.
(2)
If you answered "yes" to (1), were you in business prior to August 8, 1981?
If not, your facility is covered by 40 CFR Part 433 (Metal Finishing Category).
(3)
If you answered "yes" to (2), are you a job shop (i.e., more than 50 percent of the parts you
process are owned by customers), or are you an independent printed circuit board
manufacturer?
If not, your facility is covered by 40 CFR Part 433 (Metal Finishing Category).
(4)
If you answered "yes" to (3), has your facility moved or installed new processes since August
8, 1981?
If so, your facility is covered by 40 CFR Part 433 (Metal Finishing Category).
If not, your facility is covered by 40 CFR Part 413 (Electroplating Category).
3D.4
What Are the 40 CFR Part 433 (Metal Finishing) Effluent Guidelines?
The Part 433 guidelines apply to indirect dischargers that maintain any of the following
primary metal finishing operations (and who are not already covered by the Part 413
guidelines):
¦ Electroplating
¦ Electroless plating
¦ Anodizing
¦ Coating (chromating, phosphating, and coloring)
¦ Chemical etching and milling
¦ Printed circuit board manufacturing
If your facility performs any of these operations, then wastewater from these operations,
as well as from any of 40 additional process operations you conduct (e.g., cleaning and
December 1996 3-D4
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Wastewater Discharges
Part I, Chapter 3
machining) must meet the numeric limits established in the guidelines. Box 3-D3 lists
the processes covered.
Box 3-D3 Metal finishing facilities that maintain any of the following processes
must meet numeric pollutant discharge limits:
electroplating
electroless plating
anodizing
coating (chromating, phophating,
and coloring)
chemical etching and milling
printed circuit board
manufacture
For metal finishing facilities that maintain any of the above processes, the
following additional processes are also subject to numeric pollutant limitations:
cleaning
machining
grinding
polishing
tumbling
burnishing
impact deformation
pressure deformation
shearing
heat treating
thermal cutting
welding
brazing
soldering
flame spraying
sand blasting
other abrasive jet machining
electric discharge machining
electrochemical machining
electron beam machining
laser beam machining
plasma arc machining
ultrasonic machining
sintering
laminating
hot dip coating
sputtering
vapor plating
thermal infusion
salt bath descaling
solvent degreasing
paint stripping
painting
electrostatic painting
electropainting
vacuum metalizing
assembly
calibration
mechanical plating
testing
The numeric limits established under Part 433 for metal finishers are provided in
Appendix 3-E. For cadmium, two limits are provided. The less stringent limit applies
to facilities in existence on or before August 31, 1982. The more stringent limit applies
to facilities that began operating after this date.
Appendix 3-E also lists long-term concentration averages for the regulated pollutants.
EPA has presented these averages as guidance to dischargers and Control Authorities,
with the suggestion that plants intending to consistendv comply with the Part 433 limits
for metal finishers use the long-term concentration average as the basis for design and
December 1996
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Wastewater Discharges
Part I, Chapter 3
operation. These averages were found to be attainable by the control technology that
EPA assessed to develop the Part 433 limits.
Remember, the limits listed in Appendix 3-E are guidelines. You can only find out what
limits actually apply to your facility bv contacting your Control Authority.
3D-5 What Are the 40 CFR Part 413 (Electroplating) Effluent Guidelines?
Under Part 413, EPA divided the metal finishing industry into seven subcategories. Box
3-D4 lists the subcategories and indicates which part of the regulation applies to each.
Within each subcategory, EPA established separate discharge limits for facilities
discharging less than 10,000 gallons per day of regulated wastewater and facilities
discharging 10,000 or more gallons per day.
The Part 413 discharge limits are concentration-based (they are calculated in mg^liter).
The concentration-based limits are the same for each subcategory except for silver.
Alternative mass-based limits calculated in milligrams per square meter of operation
(mg/mb) are also provided. These alternative limits vary somewhat depending on the
subcategory.
Box 3-D4 Subcategories for the 40 CFR Part 413 (Electroplating) Effluent
Guidelines
Subcategory
Applicable Regulation
Electroplating of common metals
Subpart A
Electroplating of precious metals
Subpart B
Electroplating of specialty metals
Subpart C [Reserved]
Anodizing
Subpart D
Coating
Subpart E
Chemical etching and milling
Subpart F
Electroless plating
Subpart G
Printed circuit board manufacturing
Subpart H
Appendix 3-F lists both the concentration-based and mass-based limits established under
Part 413. Remember, these are just guidelines to help the Control Authority establish
limits. Contact vour Control Authority to find out what actual limits apply to your
facility.
December 1996
3-D6
-------
Wastewater Discharges
Part I, Chapter 3
3D.6 Could Metal Finishers Be Covered by Other CWA Effluent Guidelines
as Well?
Some finishing operations may be covered by effluent guidelines for other industry
categories. For example, if your facility performs one of the six metal finishing
operations listed above in Section D.3.1 and also performs porcelain enameling, you are
covered by the Part 433 or Part 413 Metal Finishing effluent guidelines and you may
also be covered by the Porcelain Enameling effluent guidelines (Part 466).
When a waste stream appears to be covered by more than one effluent guideline, the
more specific effluent guidelines apply. For example, consider a shop that performs a
cleaning and phosphate coating operation in preparation for painting, and also performs
cleaning, pickling, immersion coating, and chemical coating as part of a porcelain
enameling process. The metal finishing effluent guidelines would apply to the discharge
from cleaning and phosphate coating, while the porcelain enameling guidelines would
apply to the application of porcelain and also the cleaning, pickling, immersion plating,
and chemical coating operations. The metal finishing guidelines normally apply to
cleaning, pickling, immersion plating, and chemical coating operations, but because these
operations are performed immediately prior to porcelain enameling, they are covered by
the porcelain enameling effluent guidelines.
December 1996
3-07
-------
APPENDIX 3-E
EFFLUENT LIMITS ESTABLISHED UNDER
40 CFR PART 433 (METAL FINISHING) AND
EPA GUIDANCE ON LONG-TERM CONCENTRATION AVERAGES
-------
Wastewater Discharges
Part I, Chapter 3
Effluent Limits Established Under 40 CFR Part 433 (Metal Finishing)3
Pollutant'
Daily Maximum (mg/L)
Maximum Monthly Average
(m#L)
Cadmium (T)
0.69c
0.1 ld
0.26c
0.07d
Chromium (T)
2.77
1.71
Copper(T)
3.38
2.07
Lead (T)
0.69
0.43
Nickel (T)
3.98
2.38
Silver (T)
0.43
0.24
Zinc (T)
2.61
1.48
Cyanide (T)
1.20
0.65
Cyanide, Ac
(Alternative to total cyanide)
0.86
0.32
Total toxic organics'
2.13
--
'Refer to Section D.3 in Appendix D for 1) an explanation of the "Metal Finishing" category, and 2)
to determine whether your operation falls within this category.
b(T) = Total.
'Applies to facilities in existence on or before August 31,1982.
dApplies to facilities that began operating after August 31, 19S2.
'Cyanide, A = Cyanide, amenable to chlorination.
'There is no monthly average for total toxic organics.
Source: U.S. Environmental Protection Agency. 1984. Guidance manual Jar electroplating and metal
finishing pretreatmatt standards. Effluent Guidelines Division, Office of Water Regulations and
Standards. Washington, DC. February.
December 1996
3-E1
-------
Wastewater Discharges
Part I, Chapter 3
Recommended Long-Term Concentration Averages3
Pollutant or Pollutant Property"
Long-Term Concentration Average (mg/L)
Cadmium (T)
0.13C
0.058d
Chromium (T)
0.572
Copper(T)
0.815
Lead (T)
0.2
Nickel (T)
0.942
Silver (T)
0.096
Zinc (T)
0.549
Cyanide (T)
0.18
Cyanide, Ae
0.06
Total toxic organics (raw water)
1.08
Total toxic organics (effluent)
0.434
'These averages are presented by EPA as guidance to metal finishers and Control Authorities. EPA
recommends, but does not require, that plants intending to consistently comply with the regulatory
limits use these long-term concentration averages as the basis for design and operation.
b(T) = Total
^Applies to facilities in existence on or before August 31, 198!:.
"Applies to facilities that began operating after August 31, 1982.
"Cyanide, A = Cyanide, amenable to chlorination.
Source: U.S. Environmental Protection Agency. 1984. Guidance manual for electroplating and metal
finishing pretreatment standards. Effluent Guidelines Division, Office of Water Regulations and
Standards. Washington, DC. February.
December 1996
3-E2
-------
APPENDIX 3-F
EFFLUENT LIMITS ESTABLISHED UNDER 40 CFR PART 413
(ELECTROPLATING)
-------
Wastewater Discharges
Part I, Chapter 3
Effluent Limits Established Under 40 CFR Part 413 (Electroplating)3
Facilities Discharging <38,000 Liters (10,000 Gallons) per Day of Regulated
Wastewater
Pollutantb
Daily Maximum (mg/L)
Maximum 4-Dav Average (mg/L)
Cadmium (T)
1.20
0.70
Lead (T)
0.60
0.40
Cyanide, Ac
5.00
2.70
Total toxic organicsd
4.57
-
Facilities Discharging 38,000 Liters (10,000 Gallons) per Day or ft/lore of Regulated
Wastewater
Pollutantb
Daily Maximum (mg/L)
Maximum 4-Dav Average (mg/L)
Cadmium (T)
1.20
0.70
Chromium (T)
7.00
4.00
Copper (T)
4.50
2.70
Lead (T)
0.60
0.40
Nickel (T)
4.10
2.60
Zinc (T)
4.20
2.60
Silver (T)e
1.20
0.70
Total Metals'
10.50
6.80
Cyanide (T)
1.90
1.00
Total Toxic Organicsd
2.13
1
-
'Refer to Section D.3 in Appendix D for 1) an explanation of the "Electroplating" category, and 2) to
determine whether your operation falls within this category.
b(T) = Total.
cCyanide, A = Cyanide, amenable to chlorination.
dThere is no maximum 4-day average for total toxic organics.
The silver pretreatment standard applies only to precious metals plating.
Total metals is defined as the sum of the concentrations of copper, nickel, total chromium, and lead.
Source: U.S. Environmental Protection Agency. 1984. Guidance manual for electroplating and metal
finishing pretreatment standards. Effluent Guidelines Division, Office of Water Regulations and
Standards. Washington, DC. February.
December 1996
3-F1
-------
Wastewater Discharges
Part I, Chapter 3
Alternate Mass-Based Limits for Electroplating Subcategpries Discharging 38,000
Liters (10,000 Gallons) per Day or More
Pollutant
Daily Maximum (m^m2 of
Operation)
Maximum 4-Day Average (mg'm2 of
Operation)
Electroplating,
Electroless
Plating,
Chemical
Etching and
Milling,
Coatings,
Anodizing
Printed Circuit
Board
Manufacturing
Electroplating,
Electroless
Plating,
Chemical
Etching and
Milling,
Coatings,
Anodizing
Printed Circuit
Board
Manufacturing
Cadmium (T)
47
107
29
65
Chromium (T)
273
623
156
357
Copper(T)
176
401
105
241
Lead (T)
23
53
16
36
Nickel (T)
160
365
100
229
Zinc (T)
64
374
102
232
Silver (T)'
47
--
29
-
Total metalsb
410
935
267
609
Cyanide, T
74
16*
39
89
Total toxic
organics'
"The silver pretreatment standard applies only to precious metals plating.
Total metals is defined as the sum of the concentrations of copper, nickel, total chromium, and lead.
There is no alternate mass-based limit for total toxic organics. The maximum for any one day is 2.13
mg/L.
Source: U.S. Environmental Protection Agency. 1984. Guidance manual for electroplating and metal
finishing pretreatment standards. Effluent Guidelines Division, Office of Water Regulations and
Standards. Washington, DC. February.
December 1996
3-F2
-------
APPENDIX 3-G
SAMPLE NPDES PERMITS
-------
Tpii.f.jiMM* (r»nn) /r>r» ipnn
Ch.n'rrnnn: S WnotfliMtv
c*»CI»."iffrnmt: (i. N^uy Uti'V
^Cfff.iry: C Wntih L.T"lrr<
Ettqitffr'DirTtnt'Trramtttr: A. Aifluc
DISCBARGK PERMIT
Permit Number:
Category: 40 CFR 413.14
COMPANY:
ADDRESS:
FACILITY NAME:
FACILITY ADDRESS:
TELEPHONE NUMBER:
NAME OF APPLICANT:
Authorization to discharge wastewater to the Upper
Blackstone Water Pollution Abatement District Wastewater
Facilities by . is hereby granted for the
period from NOVEMBER 15, 1993 to NOVEMBER 14, 1996 by the Upper
Blackstone Water Pollution Abatement District in accordance with
the attached limitations and conditions.
Unless the context clearly indicates otherwise, the meaning
of terms or abbreviations used in this discharge permit shall be
as defined in the District's Sewer and Pretreatment Regulations.
Article II. GENERAL CONDITIONS
A. All discharges authorized herein shall be consistent with
the Sewer and Pretreatment Regulations, and with the terms
and conditions of this permit. If there is a conflict
between the regulations and this permit, then the terms of
this permit shall govern. The discharge of any pollutant
Engineer-Director-Treasurer
Article I
DEFINITIONS
5G-1
-------
Page 4
more frequently than, or at a level in excess of, that
identified and authorized by this permit shall constitute a
violation of the terms and conditions of this permit. Any
violation of pretreatment standards or requirements may
result in the imposition of civil or criminal actions taken
by the District with penalties levied up to $10,000.00 per
day, for each violation as provided for in the District's
Sewer and Pretreatment Regulations. Modifications,
additions, and/or quantity of wastewater discharged to the
facilities must be reported to the Engineer-Director, in
writing, and this permit may then be modified or reissued to
reflect such changes. No change in the permittee's
discharge may be made unless reported to and approved by the
Board. In no case shall new connections, increased flows,
or significant change in effluent quantity and/or quality be
permitted if such will cause violation of the effluent
limitations specified herein. Neither this permit or any or
all of the allowable discharge of flows and pollutant
loadings provided for by the permit are transferable or
assignable in part or whole to any other company, facility
or process without the written consent of the chairman of
the Board.
B. This permit may be modified, suspended, or revoked in
whole or in part during its term for causes including
the following:
1. Violation of any term or condition of this permit.
2. Obtaining a permit by misrepresentation or failure
to disclose fully all relevant facts.
3. A change in conditions or the existence of a
condition which requires either a temporary or
permanent reduction or elimination of the
authorized discharge.
4. Promulgation of a more stringent pretreatment
standard by state or federal agencies having
jurisdiction over receiving waters. Permits
modified under this section may include
implementation schedules, self-monitoring
requirements, revised effluent limitations, and
other provisions necessary to assure compliance.
5G-2
-------
Page 3
5. A change in the facilities process or wastestream
characteristics.
C. The permittee shall allow authorized District personnel upon
the presentation of proper credentials:
1. To enter upon permittee's premise where an
effluent source is located or in which any records
are required to be kept under the terms and
conditions of this permit during business hours.
2. To have access to and copy records required to be
kept under the terms and conditions of this
permit.
3. To inspect any monitoring equipment or monitoring
method required in this permit.
4. To sample at any intake, wastewater facility, or
outfall.
5. To enter upon a permittee's premise where an
effluent source is located, during business and
non-business hours, when a condition of emergency
exists due to a process upset or discharge which
may cause harm to the District's wastewater
reatment facilities or process, or to the health
or welfare of the community.
D. All pretreatment facilities shall be operated in a manner
consistent with the Sewer and Pretreatment Regulations and
applicable federal and state regulations and guidelines.
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all facilities
or systems of control installed or utilized to achieve
compliance with the terms and conditions of this permit.
E. The provisions of this permit are severable, and the
invalidity of any condition or subdivision thereof shall not
make void any other condition or subdivision thereof.
F. Noncompliance - In the event the permittee is unable to
comply with any of the conditions of this permit due to a
breakdown of pretreatment facilities, process upset
emergency condition, of the occurrence of a spill, or the
5G-3
-------
Page 4
occurrence of a slug discharge, the permittee shall
immediately notify the Engineer-Director of su<-:h occurrence.
In addition, the permittee shall provide the Engineer-
Director with the following information in writing within
five calendar days after commencement of such occurrences:
1. Description of the discharge and the cause of non-
compliance .
2. Anticipated time the condition of noncompliance is
expected to continue, or if such conditions have
been corrected, and the duration of the period of
noncompliance.
3. Steps taken by the permittee to reduce and
eliminate the noncompliance.
4. Steps to be taken by the permittee to prevent
recurrence of the condition of noncompliance.
G. Revisions - The Board reserves the right to make appropriate
revisions to this permit to establish effluent limitations.
It may issue a schedule of compliance, or other provision
which may be authorized under federal, state, or District
acts to bring all such discharges into compliance with these
acts.
H. Reapplication - If the permittee desires to continue to
discharge after the scheduled expiration of this permit, the
permittee shall reapply on the application forms then in use
at least sixty (60) days before this permit expires. Under
no circumstances shall the permittee continue to discharge
after the expiration of the permit.
Article III SPECIAL CONDITIONS
Upon connection to the District's wastewater
facilities, the permittee is authorized to discharge
wastewater whose effluent characteristics shall not exceed
the values listed in the District's Sewer and Pretreatment
Regulations, or as further specified herein.
5GA
-------
Page 5
If a compliance schedule for installation of a
pretreatment system is required, the permittee is authorized
to discharge wastewater to the District's facilities which
are in conformance with prohibitions and limitations of the
Sewer and Pretreatment Regulations of the District, until
the completion date established in Article V.
Article IV REPORTING & MONITORING
A. At each connection to a public sewer, the permittee may
be required to install a flow meter(s), composite
sampler(s), sampling station, or other device(s) that
shall measure, sample, and record the quantity and
quality of wastewater flow from the industry. All
monitoring devices and sampling stations must be
approved by the Engineer-Director. The permittee shall
accept the estimates of quantities of wastewater flow
and pollutant loads, as established by the Engineer-
Director during all periods in which the meters fail to
measure the wastewater quantity or quality correctly.
The permittee shall maintain records of all information
resulting from any monitoring activities required
herein for a minimum of three years.
B. The permittee shall calibrate and perform maintenance
procedures on all monitoring and analytical instruments
at regular intervals to ensure accuracy of
measurements.
C. The permittee shall provide the above records and shall
demonstrate the accuracy of the monitoring devices upon
request of the Engineer-Director.
D. The permittee shall analyze any samples as may be
required by the monitoring schedule specified herein or
by the Engineer-Director to ensure effluent quality
control.
E. If the permittee monitors any wastewater
characteristics more frequently than is required by
this permit, the results of such monitoring shall be
made available to the Engineer-Director.
5G-5
-------
Page 6
Sampling and Analysis - The sampling, preservation,
handling, and analytical methods used must conform to
the methods specified by the District for its
laboratory involved in monitoring industrial flows.
24 Hour Notification - If sampling performed by the
permittee indicates a violation, the permittee shall
notify the District within 24 hours of becoming aware
of the violation. The permittee shall also repeat the
the sampling and analysis and submit the results of the
repeat analysis to the District within thirty days
after becoming aware of the violation.
All discharge limitations as provided foe in Article
III are conditional, and may be revised by the Board,
if the Engineer-Director determines that the
limitations are not sufficient to protect the
District's wastewater treatment and conveyance
facilities and/or that the limitations are not
sufficient to prevent the introduction of pollutants to
the District's facilities which may pass through the
treatment works or may otherwise be incompatible with
or prove detrimental to operation and maintenance of
said facilities. The permittee shall be responsible
upon notification to reduce or eliminate as required
and within the schedule established by the Engineer-
Director the discharge of the specified pollutants.
The permittee shall be responsible for all costs
incurred as a result of complying with theses
requirements.
In accordance with Title 40, Code of Federal
Regulations, Section 403.12, information and data
provided by the permittee which identifies the nature
and frequency of discharge shall be available to the
public without restriction. Requests for confidential
treatment of other information shall be governed by
procedures specified in the District's Sewer and
pretreatment Regulations.
Self-monitoring and reporting requirements set forth
under 40 CFR 403.12 shall be complied with by the
permittee.
5G -6
-------
Article V. IMPLEMENTATION SCHEDULE
Page 7
No later than 14 calendar days following each date
identified in a schedule of compliance, which will be issued by
the District, the permittee shall submit either a report of
progress or, in the case of specific actions being required by
identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the
cause of noncompliance, any remedial actions taken, and the
probability of meeting the next scheduled requirement.
The permittee shall achieve compliance with the final
effluent limitations as specified.
Article VI MONITORING REQUIREMENTS
The permittee shall collect and analyze representative
samples not less frequently than the following schedule:
5G-7
-------
Page 8
LIMITATIONS ON WASTEWATER STRENGTH (mg/L)
Sample Parameter
Daily
Max.
4-Day
Avg.
Sample Type
Prequency
Cadmium (T)
1.2
.70
composite
2x6 months
Chromium (T)
composite
1x6 months
Copper (T)
Cyanide (T)
Cyanide (amenable)
5.0
2.7
grab
2x6 months
Lead (T)
.60
.40
composite
2x6 months
Nickel (T)
composite
1x6 months
Phenols (T)
Silver (T)
Zinc (T)
Total Metals
(Cu, Cr, Ni, Zn)
ats, Oil, and Grease
Temperature-Max. Deg F.
pH-Maximum (SU)
10.0
grab
continuous
pH-Minimum (SU)
6.5
grab
continuous
Total Toxic Organics
4.57
grab
* 1x6 months
Flow GPD
10,000
2x6 months
1. Monitoring as required under 40 CFR part 403 General Pretreatment
Regulations.
2. Flow Must be recorded on the days samples are taken.
3. Flows and pH are to be monitored and recorded daily by the permittee.
Only violations of pretreatment standards outside the permitted range
must be reported to the District on the slug discharge report form.
4. * 1 x 6 months or certified statement.
5. Self-monitoring reports due May 1, and November 1 of each year.
6. Sample location i3 in sump after process prior to dilution and prior
to pH adjustment. pH is sampled after treatment prior to dilution.
7 . Discharge location is connected to pH neutralization system.
5G-8
-------
Page 9
Ar+.iclo VII REPORTING REQUIREMENTS
Monitoring results obtained shall be summarized and reported
on the District's industrial self-monitoring report form along
with all laboratory analyses and certification statements. The
self-monitoring report is due on May 1, and November 1, of each
year.
5G-9
-------
STATE OF CONNEC'llCUi-
rrr
DEPARTMENT OF ENVIRONMENTAL PROTECTION
KPDES PSTRMIT MODIFICATIOy
Re: Facility ID:
Watershed
Attention:
This permit is modified in accordance with Section 22a-430 of. Chapter 4455c,
Connecticut General Statutes, and regulations adopted thereunder, as amended,
pursuant to an approval dated September 26, 1973, by the Administrator of the
United States Environmental Protection Agency for the State of Connecticut tc
administer a N.P.D.E.S. permit program.
Your application for permit modification submitted by on
June 1, 1995 has been reviewed by the Connecticut Department of Environmental
Protection.
Your discharge toxicity evaluation (DTE), submitted by on
'ebruary 11, 1987, has been reviewed by the Connecticut Department of
Environmental Protection, has been found to be consistent with Section
22a-430-4 (c) (21) of the Regulations of Connecticut State Agencies and is hereby
approved in accordance with Section 22a-430 of Chapter 446k, Connecticut
General Statutes.
The Commissioner of Environmental Protection (hereinafter "the
Commissioner") has found that the system installed for the treatment of the
discharge will protect the waters of the state from pollution when all the
conditions of this permit have been met.
The Commissioner has determined that is in
full compliance with The
Commissioner, acting under Section 22a-430, hereby permits
to discharge non-contact cooling water and treated metal finishing
wastewater in accordance with the following conditions:
1. The wastewater shall be collected, pretreated and discharged in accordance
with the above referenced application and all approvals issued by the
Commissioner or his authorized agent for the discharges and/or activities
authorized by or associated with this permit.
( Printed on Recycled Paper )
79 Elm Street • Hartford, CT 06106 - 5127
An Equal Opportunity Employtr
5G-10
-------
2
2. The discharges shall not exceed and shall otherwise conform to specific
terms and conditions listed below. The discharges shall be monitored and
results reported to the Water Management Bureau (Attn: DMR Processing) by
the end of the month after the month in which samples are taken according
to the following schedule:
A. Discharge Serial No. 001-1
Monitoring Location: 1
Description: Non-Contact Cooling Water (Discharge Code 102000C)
Receiving Stream: Naucatuck River (Basin Code 6900)
Present/Future Water Quality Standard: C/B
Average Daily Flow: 200,000 gallons per day
Maximum Daily Flow: 317,400 gallons per day
Design Flow Rate: 221 gallons per minute
(1) The pH of the discharge shall not be less than 6.0 S.U. or
greater than 9.5. S.U. (Code 00400-012) at any time.
(2) The discharge shall not contain or cause in the receiving stream
a visible oil sheer, or floating solids.
(3) The discharge shall not cause visible discoloration or foaming in
the receiving waters.
(4) The temperature of the discharge shall not increase the
temperature of the receiving stream above 85 F or raise the
normal temperature of the receiving stream more than 4 F.
(5) The maximum daily limits specified below for all parameters other
than pH and acute and chronic aquatic toxicity shall not be
exceeded by more than 1.5 times the maximum daily concentration,
at any time, as measured by a grab sample. Compliance with acute
and chronic aquatic toxicity limitations shall be determined in
accordance with Sections 22a-430-3(j) (7) (A) and (B) of the
Regulations of Connecticut State Agencies, respectively.
(6) (a) During the period beginning on the date of issuance of this
permit and lasting through expiration, the permittee shall
comply with the following:
Parameter
Average
Monthly
Units Limits
Maximum
Daily
Limits
Minimum
Frequency
of Sampling
Sample
Tvoe
Aquatic Toxicity,
See paragraph 2.A.(8)
Quarterly Daily Composite
Acute
Aquatic Toxicity,
See paragraph 2.A.(8)
Quarterly Daily Composite
Chronic
Ammonia, N
Cadmium, Total
Chloride
mg/1
mg/1
mg/1
Quarterly Daily Composite
Quarterly Daily Composite
Quarterly Daily Composite
5G-11
-------
Chlorine, Total
mg/1
Quarterly
Grab Sample
Residual
Average
Chromium, Total
mg/1
Quarterly
Daily Composite
Copper, Total
mg/1
Quarterly
Daily Composite
D i chlorome thane
mg/1
Quarterly
Grab
Iron, Total
mg/1
Quarterly
Daily Composite
Lead, Total
mg/1
Quarterly
Daily Composite
Manganese, Total
mg/1
Quarterly
Daily Composite
Methylene
mg/1
Quarterly
Grab
Chloride
Nickel, Total
mg/1
Quarterly
Daily Composite
Nitrogen, Nitrate
mg/1
Quarterly
Daily Composite
Total (as N)
Oil and Grease,
mg/1
Quarterly
Grab Sample Average
Total
pH
S.U.
See paragraph 2.A.(1)
Quarterly
Range During
Comoosite
Surfactants,
mg/1
Quarterly
Daily Composite
Anionic (as MBAS)
Temperature
°F
See paragraph 2.A.(4)
Quarterly
Ranee During
Comoosite
Total Dissolved
rag/1
Quarterly
Daily Composite
Solids
Total Suspended
mg/1
Quarterly
Daily Composite
Solids
Zinc, Total
mg/1
Quarterly
Daily Composite
(b) During the period beginning 18 Months after the original issuance
date of this permit and lasting until expiration, the permittee
shall also comply with the following limitations:
Average
Maximum
Minimum
Monthly
Daily
Frequency
Sample
Parameter
Units
Limits
Limits
of Samolincr
Tvoe
Aquatic Toxicity,
• •» « —
See paragraph 2.A.(9)
Quarterly
Daily Composite
Acute
Aquatic Toxicity,
See paragraph 2.A.(9)
Quarterly
Daily Composite
Chronic
Ammonia, N
rng/1
3.0 mg/1
Quarterly
Daily Composite
Cadmium, Total
mg/1
0.006 mg/1
Quarterly
Daily Composite
Chlorine, Total
mg/1
0.087 mg/1
Quarterly
Grab Sample Average
Residual
Chromium," Total
mg/1
0.95 mg/1
Quarterly
Daily Composite
Copper, Total
mg/1
0.046 mg/1
Quarterly
Daily Composite
Lead, Total
mg/1
0.010 mg/1
Quarterly
Daily Composite
Nickel, Total
mg/1
0.6 98 mg/1
Quarterly
Daily Composite
Oil and Grease,
mg/1
5.0 mg/1
Quarterly
Grab Sample Avi
Total
Surfactants,
mg/1
0.5 mg/1
Quarterly
Daily Composite
Anionic (as MBAS)
5G-12
-------
4
Total Dissolved mg/1
Solids
Total Suspended mg/1
Solids
Zinc, Total rag/1
1500.0 mg/1
20.0 mc/l 3 0.0 mg/1
0.119 mg/1
Quarterly Daily Composite
Quarterly Daily Composite
Quarterly Daily Composite
(7) (a) The permittee shall monitor ar.d record the total flow (Code
74075-007) for each day of discharge, reccrd and report the total
flow (Code 74075-007) and the number of hours of discharge (Cede
81381-079) for each day of sample collection and the average daily
flow for the month (Code 000S6-007).
(b) The report shall include a detailed explanation of any violations
of the limitations specified above.
(c) "Grab Sample Average" means the mathematical average of test
results from grab samples taken over a full operating day at equal
intervals of no more than 120 minutes.
(d) The permittee shall immediately begin monitoring for acuatic
toxicity according to the frequency of sampling stated above.
Monitoring shall be conducted according to the protocol
established for determining compliance with aquatic toxicity
limits set forth below. if any monitoring result indicates that
the maximum daily acute toxicity limit has been exceeded
additional testing as required by paragraph 2.A.(10)(e) shall be
performed.
(8) A daily composite sample of tlie effluent shall be taken, for monitoring
of acute and chronic aquatic toxicity.
(a) Dilution equivalent to 72,437 gallons per hour (gph) is allocated
to a zone of influence for assimilation of toxicity. This
allocation shall be used to calculate the instream waste
concentration (IWC) according to the formula:
IWC - average dailv flow X 100
(average daily flow +• allocated zone of influence flow)
(b) In lieu of average daily flow, the mean effluent flow rate for the
previous 30 operating days may be used to calculate the instream
waste concentration provided the permittee maintains an accurate
record of the total flow and number of hours of discharge for each
operating day and provided that the flow rate for any one
operating day used in calculating the mean does not exceed the
mean flow by more than twenty-five percent (25%).
(c) Monitoring shall be performed fluarterly (January, April, July,
October) following the toxicity tests in "Methods for Measuring
the Acute Toxicity of Effluents to Freshwater and Marine
Organisms" (EPA 600/4-8S/013) with the following specifications:
5G-13
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s
(i) Neonatal Daphnia pulex (less than 24 hours old) and juveni
Pimeohales aromelas (30 +/- 5 days old) shall be used as
organisms.
(ii) Synthetic freshwater prepared as described in EPA
600/4-85/013 and adjusted to a hardness of 50 rr.g/1 as CaC03
shall be used as dilution water in the tests.
(iii) Test duration shall be 48 hours for Daphnia pulex and 96
hours for Pimeohales orcmelas.
(9) Effective 18 months after the original issuance date of the permit and
thereafter a daily composite sample of the effluent shall not exhibit
acute and/or chronic acuatic toxicity in the receiving waterbody.
(a) Dilution equivalent to 72,437 gallons per hour (gph) is allocated
to a zone of influence for assimilation of toxicity. This
allocation shall be used to calculate the instream waste
concentration (IWC) according to the formula:
IWC m average daily flow X 100
(average daily flow + allocated rone of influence flow)
(b) In lieu of average daily flow, the mean effluent flow rate for the
previous 30 operating days may be used to calculate the instream
waste concentration provided the permittee maintains an accurate
record of the total flow and number of hours of discharge for eac!
operating day and provided that the flow rate for any one
operating day used in calculating the mean does not exceed the
mean flow by more than twenty-five percent (25%) .
(c) Compliance with acute aquatic toxicity shall be achieved when the
LC value for the effluent is greater than three (3) times the
iwd:
(d) Compliance with chronic aquatic toxicity shall be achieved when
there is no significant mortality in a daily composite of the
effluent at a concentration equal to or greater than the
calculated NOAEL (NOAEL » IWC x 20/3 up to 100% for chronic
protection) as determined by the pass/fail methodology in Section
22a-430-3(j)(7)(A) of the Regulations of Connecticut State
Agencies.
(e) Monitoring to determine compliance with this limit shall be
performed Quarterly (January, April, July, October) following the
toxicity tests in "Methods for Measuring the Acute Toxicity of
Effluents to Freshwater and Marine Organisms" (EPA 600/4-85/013)
with the following specifications:
(i) Neonatal Daohnia pulex (less than 24 hours old) and juvenile
Pimcphales promelas (30 +/- 5 days old) shall be used as tes
organisms.
5G-14
-------
s
(ii) Synthetic freshwater prepared as described in EPA
600/4-85/0X3 and adjusted to a hardness of 50 mg/1 as CaC03
shall be used as dilution water in the tests.
(iii) Test duration shall be 43 hours for Daohnia pulex ar.d 36
hours for Piir.epl-.ales promelas.
(10) (a) In determining LC_0 values, five (S) test concentrations, in
duplicate, shall be utilized.
(b) The I«C__ value shall be determined by the computational method
5(1 "
(Binomial Distribution, Probit Analysis, Moving Average Angle,
Spearman-Karber) which yields the smallest 95V confidence interval
and value which is consistent with the dose-resconse cata.
50
(c) Any test in which the survival of test organisms is less thar.
ninety (90) percent in each replicate control test chamber or
failure to achieve test conditions as specified in Section
22a-430-3(j)(7)(A) of the Regulations of Connecticut State
Agencies, such as maintenance of appropriate environmental
controls, constitutes an invalid test and the permittee shall
immediately retest according to the requirements listed herein.
Failure to submit valid test results constitutes a permit
violation.
(d) Results of the toxicity tests required as part of this permit
condition shall be entered on1 Che Discharge Monitoring Report
(DM?.) for the month in which it was performed, using the
appropriate parameter code. Additionally, complete and accurate
test data, including all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as
dose/response data shall b<; entered on the Aquatic Toxicity
Monitoring Report form (ATMR) . The ATMR shall be sent to the
following address:
Aquatic Toxicity
Connecticut Department of Environmental Protection
Water Management Bureau
79 Elm Street
Hartford, CT 06106
(e) On or after 18 months from the original issuance date of this
permit, if any test result indicates that the maximum daily
toxicity limit for the effluent has been exceeded, a second sample
of the effluent shall be collected and tested as described above
and the results reported to the Commissioner within 30 days of the
receipt of the first set of test results.
5G-15
-------
(f) On or after IS months from the original issuance date of this
permit, if any two consecutive test results or any three -test
results in a single year indicate that the maximum daily toxicity
limit has been exceeded, the permittee shall immediately take all
reasonable steps to eliminate toxicity wherever possible and shall
submit a report for the review and approval of the Commissioner ir.
accordance with Section 22a-430-3 (j) (10) (c) of the Regulations of
Connecticut S":ate Agencies describing proposed steps to eliminate
the toxic impact of the discharge on the receiving waterbcdy.
Such a report shall include a proposed time schedule to accomplish
toxicity reduction.
Discharge Serial No. 002-1
Monitoring Location: 1
Description: Treated metal finishing wastewater (Discharge Code 10103SZ)
Receiving Stream: Naugatuck River (Basin Code 6900)
Present/Future Water Quality Standard: C/B
Average Daily Flow: 195,000 gallons per day
Maximum Daily Flow: 240,000 gallons per day
Design Flow Rate: 170 gallons per minute
(1) The pK of the discharge shall not be less than 6.0 S.U. or greater thar.
9.5. S.U. (Code 00400-012) at any time.
(2) The discharge shall not contain or cause in the receiving stream a
visible oil sheen or floating solids.
(3) The discharge shall not cause visible discoloration or foaming in the
receiving waters.
(4) The temperature of the discharge shall not increase the temperature of
the receiving stream above 85 F or raise the normal temperature of
the receiving stream more than 4 F.
(5) The maximum daily limits specified below for all parameters other than
pK and acute and chronic aquatic toxicity shall not be exceeded by more
than 1.5 times the maximum daily limit, at any time, as measured by a
grab sample. Compliance with acute and chronic aquatic toxicity
limitations shall be determined in accordance with Sections
22a-430-3 (j) (7) (A) and (B) of the Regulations of Connecticut State
Agencies, respectively.
(6) (a) During the period beginning on the date of issuance of this permit
and lasting through expiration, the permittee shall comply with
the following:
5G-16
-------
a
Average
Maximum
Minimum
Monthly
Daily
Frequency
Sample
Parameter
Units
Limits
Limits
of Samolincr TVoe
Aquatic Toxicity,
r • • • •
See paragraph 2.B.(9)
Quarterly
Daily Composite
Acute
Aquatic Toxicitv,
See paragraph 2.3.(9)
Quarterly
Daily Composite
Chronic
Ammonia, N
mg/1
89.0 ng/1
140.0 mg/1
Weekly
Daily Composite
Ammonia, N
kg/d
65.70 kg/d
103.34 kg/d
Weekly
Daily Composite
BOO 5
mg/1
Weekly
Daily Composite
BOO 5
kg/d
Weekly
Daily Composite
Cadmium, Total
mg/1
0.10 mg/1
0.20 mg/1
Weekly
Daily Composite
Cadmium, Total
kg/d
0.0204 kg/d
0.04 03 kg/d
Weekly
Daily Composite
Chlorine, Free
mg/1
Weekly
Grab Sample Aversr
Residual
Chlorine, Total
mg/1
0.46 mg/1
0.92 mg/1
Weekly
Grab Sample Averag
Residual
Chlorine, Total
kg/d
Weekly
Grab Sample Averar
Residual
Chromium,
mg/1
0.10 mg/1
0.20 mg/1
Weekly
Grab Sample Averar
Hexavalent
Chromium, Total
mg/1
1.0 mg/1
2.0 mg/1
Weekly
Daily Composite
Cobalt, Total
mg/1
2.0 mg/1
4.0 mg/1
Monthly
Daily Composite
Copper, Total
mg/1
1.0 mg/1
2.0 mg/1
Weekly
Daily Composite
Copper, Total
kg/d
0.1813 kg/d
0.3626 kg/d
Weekly
Daily Composite
Cyanide,Amenable
mg/1
0.098 mg/1
0.2 mg/1
Weekly
Grab Sample
See paragraph 2.B.(7)(g)
Average
Cyanide, Total
mg/1
0.65 mg/1
1.20 mg/1
Weekly
Grab Sample
Sea paragraph 2.;}. (7) (g)
Average
Cyanide, Total
kg/d
0.1607 kg/d
0.3214 kg/d
Weekly
Grab Sample
See paragraph 2.B.(7)(g)
Average
Fluoride, Free
mg/1
20.0 mg/1
30.0 mg/1
Weekly
Daily Composite
Fluoride, Total
mg/1
Weekly
Daily Composite
Iron, Total
mg/1
3.0 mg/1
S.0 mg/1
Weekly
Daily Composite
Lead, Total
mg/1
0.1 mg/1
0.5 mg/1
Weekly
Daily Composite
Lead, Total
kg/d
0.0402 kg/d
0.0804 kg/d
Weekly
Daily Composite
Nickel, Total
mg/1
1.0 mc/l
2.0 mg/1
Weekly
Daily Composite
pH
S.U.
See paragraph 2.B.(1)
Continuous
Instantaneous
See paragraph 2.B.(7)(f)
Silver, Total
mg/1
0.1 mg/1
0.43 mg/1
Weekly
Daily Composite
Silver, Total
kg/d
0.025 kg/d
0.050 kg/d
Weekly
Daily Composite
Solids, Total
mg/1
20.0 mg/1
30.0 mg/1
Weekly
Daily Composite
Suspended
Temperature (F)
°F
See paragraph 2.S.(4)
Quarterly
Range During
Composite
Tin, Total
mg/1
2.0 mg/1
4.0 mg/1
Weekly
Daily Composite
Total Toxic
mg/1
0.25 mg/1
Monthly
Grab Sample
Organics
Zinc, Total
mg/1
1.0 mg/1
2.0 mg/1
Weekly
Daily Composite
Zinc, Total
kg/d
0.4654 kg/d
0.9308 kg/d
Weekly
Daily Composite
5G-17
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9
(b) During the period begirmxng 18 months after original issuance date
of this permit and lasting until expiration, the permittee shall ¦
also comply with the following limitations:
Average Maximum Minimum
Monthly Daily Frequency Sample
Parameter Units Limits Limits of Sampling Tvoe
Ammonia, N mg/1 See paragraph 2.B.(8) Weekly Daily Composite
Ammonia, N kg/d See paragraph 2.B.(8) Weekly Daily Composite
(7) (a) The permittee shall monitor and record the total flow (Code
74076-007) for each day of discharge, record and report the total
flow (Code 7407S-007) and the number of hours of discharge (Code
81381-079) for each day of sample collection and the average daily
flow for the month (Code 000S6-007) .
(b) The report shall include a detailed explanation of any violations
of the limitations specified above.
(c) "Grab Sample Average" means the mathematical average of test
results from grab samples taken over a full operating day at equal
intervals of no more than 120 minutes.
(d) In lieu of analyzing for Total Toxic Organics at the frequency
required above, each monthly report may include a statement
certifying compliance with a Toxic Organic Management Plan
approved by the Commissioner in accordance with 40CFR433 (Metal
Finishing). Monitoring for Total Toxic Organics at the frequency
required above shall be done until such approval has been issued.
(e) The permittee shall immediately begin monitoring for aquatic
toxicity according to the frequency of sampling stated above.
Monitoring shall be conducted according to the protocol
established for determining compliance with acute toxicity limits
set forth below. If any monitoring result indicates that the
maximum daily acute toxicity limit has been exceeded additional
testing as required by paragraph (10) (e) shall be performed.
(f) The permittee shall report pH values, specifically maximum and
minimum, for each day of composite sample collection and in each
month. The pH range for each month is defined as the highest and
lowest single pH reading during all operating days of the month
including the periods when sampling is not performed.
(g) Monitoring for cyanide, both amenable and total, shall be
conducted only when the cyanide batch treatment system is
discharging.
(8) The following ammonia limits shall apply:
5G-18
-------
10
Average
Average
Maximum
Maximum
Monthly
Monthly
Daily
Daily
Limits
Limits
Limits
Limits
Month
(mg/1)
(kg/d)
(mg/1)
(kg/d)
January-June
89. 0
65.70
140.0
103.34
July-September
10 . 0
7.382
30.0
22.416
October
17 . 0
12.57
30.0
22.416
November-December
89.0
65.70
140 . 0
103.34
A daily composite sample of Che effluent shall not exhibit acute ar.d/o
chronic aquatic toxicity in the receiving waterbocy.
fa) Dilution equivalent to 412,267 gallons per hour (gph) is allocate
to a zone of influence for assimilation of toxicity. This
allocation shall be used to calculate the instream waste
concentration (IWC) according to the formula:
IWC » averace dailv flow X 100
(average daily flow + allocated zone of influence flow)
(b) In lieu of average daily flow, the mean effluent flow rate for the
previous 30 operating days may be used to calculate the instream
waste concentration provided the permittee maintains an accurate
record of the total flow and number of hours of discharge for each
operating day and provided that the flow rate for any one
operating day used in calculating the mean does not exceed the
mean flow by more than twenty-five percent (25%) .
(c) Compliance with acute aquatic toxicity shall be achieved when the
LC value for the effluent is creater than three (3) times the
iw8?
(d) Compliance with chronic aquatic toxicity shall be achieved when
the LC value for the effluent is greater than twenty (20)
times tne IWC.
(e) Monitoring to determine compliance with this limit shall be
performed Quarterly (January, April, July, October) following the
toxicity tests in "Methods for Measuring the Acute Toxicity of
Effluents to Freshwater and Marine Organisms" (EPA 600/4-85/013)
with the following specifications:
(i) Neonatal Daohr.ia oulex (less than 24 hours old) and juvenile
Pimeohales oromelas (30 +/- 5 days old) shall be used as test
organisms until such time that the most sensitive species has
been determined using data from three consecutive monitoring
events.
(ii) Synthetic freshwater prepared as described in EPA
600/4-85/013 ar.d adjusted to a hardness of 50 mg/1 as CaC03
shall be used as dilution water in the tests.
5G-19
-------
11
(iii) Test duration shall be 48 hours for Paohnia pulex and 96
hours for Pineohales promelas.
(10) (a) In determining LCS0 values, five (S) test concentrations, in
duplicate, shall be utilized.
(b) The LC value shall be determined by the computational method
(Binomi^ai Distribution, Probit Analysis, Moving Average Angle,
Speamtan-Karber) which yields the smallest 95% confidence interval
and LC value which is consistent with the dcse-response data.
50
(c) Any test in which the survival of test organisms is less than
ninety (90) percent in each replicate control test chamber or
failure to achieve test conditions as specified in Section
22a-430-3(j)(7) (A) of the Regulations of Connecticut State
Agencies, such as maintenance of appropriate environmental
controls, constitutes an invalid test and the permittee shall
immediately retest according to the requirements listed herein.
Failure to submit valid test results constitutes a permit
violation.
(d) Results of the toxicity tests required as part of this permit
condition shall be entered on the Discharge Monitoring Report
(DMR) for the month in which it was performed, using the
appropriate parameter code. Additionally, complete and accurate
test data, including all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as
dose/response data shall be entered on the Aquatic Toxicity
Monitoring Report form (ATMR) . The ATMR shall be sent to the
following address:
Aquatic Toxicity
Connecticut Department of Environmental Protection
Water Management Bureau
79 Elm Street
Hartford, CT 06106
(e) Any exceedance of a limitation on aquatic toxicity is a violation
this permit. If any test result indicates that the maximum daily
toxicity limit for the effluent has been exceeded, a second sample
of the effluent shall be collected and tested as described above
and the results reported to the Commissioner within 30 days of the
receipt of the first set of test results.
(f) If any two consecutive test results or any three test results in a
single year indicate that the maximum daily toxicity limit has
been exceeded, the permittee shall immediately eake all reasonable
steps to eliminate toxicity wherever possible and shall submit a
report for the review and approval of the Commissioner in
5G-20
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12
accordance with Section 22a-430-3 (j) (10) (c) of the Regulations of
Connecticut State Agencies describing proposed- steps to eliminate
the toxic impact of the discharge on the receiving waterbody.
Such a report shall include a proposed time schedule to accomplish
toxicity reduction.
3. The permittee shall achieve compliance with the effluent limitations in
paragraphs 2.A.(6)(b) and 2.3.(S)(b) including modified water quality based
effluent limits as soon as possible but in no ever.t later than 18 months after
the original date of issuance of this permit in accordance with the following:
A. On or before 30 days after the date of issuance of this permit, the
permittee shall retain one or more qualified consultants acceptable to the
Commissioner to prepare the documents and implement or oversee the actions
required by this permit and shall, by that date, notify the Commissioner in
writing of the identity of such consultants. The permittee shall retain one
or more qualified consultants acceptable to the Commissioner until the
actions required by this permit have been completed, and within ten days
after retaining any consultant other than the one originally identified
under this paragraph, the permittee shall notify the Commissioner in writing
of the identity of such other consultant. The consultant retained to
perform the studies and oversee any remedial measures required to achieve
compliance with paragraph 2.A. (6) (b) and 2.B.(6)(b) limitations shall be a
qualified professional engineer licensed to practice in Connecticut
acceptable to the Commissioner. The permittee shall submit to the
Commissioner a description of a consultant's education, experience ana
training which is relevant to the work required by this permit within ten
days after a request for such a description. Nothing in this paragraph
shall preclude the Commissioner from finding a previously acceptable
consultant unacceptable.
B On or before 180 days after the date of issuance of this permit, the
permittee shall submit for the Commissioner's review a comprehensive and
thorough report which describes and evaluates alternative actions which may
be taken by permittee to achieve compliance with the limitations in
paragraph 2.A.(6)(b) and 2.S.(6)(b) of this permit as soon as possible, but
in no event later than 18 months from the original date of issuance of this
permit. Such report shall:
a. evaluate alternative actions to achieve compliance including but not
limited to pollutant source reduction, process changes/innovations,
chemical substitutions, recycle and zero discharge systems, water
conservation measures, and application of new internal and/or
end-of-pipe treatment technologies;
b. state in detail the most expeditious schedule for performing each
alternative;
c. list all permits and approvals required for each alternative, including
but not limited to any permits required under sections 22a-32, 22a-42a,
22a-342, 22a-361, 22a-368 or 22a-430 of the Connecticut General
Statutes;
5G-21
-------
d. propose a preferred alternative or combination of alternatives with
supporting justification therefor; and
e. propose a detailed program and schedule to perform all actions required
by the preferred alternative including but not limited to a schedule
for submission of; engineering plans and specifications on any new
internal and/or end of pipe treatment facilities, start and completion
of any construction activities related to any internal anc/or end of
pipe treatment facilities, applying for and obtaining all permits and
approvals required for such actions.
The permittee shall submit to the Commissioner quarterly status reports
beginning sixtv days after the date that the report referenced in paragraph
B above was submitted. Status reports' shall include but not be limited to a
summary of all effluent monitoring data collected by the permittee curing
the previous six month period and a detailed description of progress made by
the permittee in performing actions required by this permit in accordance
with the approved schedule, including but not limited to development of
engineering plans and specifications, construction activity, contract
bidding, operational changes, preparation and submittal of permit
applications, and any other actions relevant to meeting the limitations in
paragraph 2.A.(6)(b) and 2.B.(6)(b).
The permittee shall perform all actions in accordance with the schedule
submitted with the report referenced in paragraph B above, but in no event
shall the actions be .completed later than 18 months of the original date of
issuance of this permit. Within fifteen days after completing such actions,
the permittee shall certify to the Commissioner in writing that the actions
have been completed as submitted.
The pemittee shall use best efforts to submit to the Commissioner all
documents required by this permit in a complete and approvable form. If the
Commissioner notified the permittee that any document or other action is
deficient, and does not approve it with conditions or modifications, it is
deemed disapproved, and the permittee shall correct the deficiencies and
resubmit it within the time specified by the Commissioner or, if no time is
specified by the Commissioner, within thirty days of the Commissioner's
notice of deficiencies. In approving any document or other action under
this order, the Commissioner may approve the document or other action as
submitted or performed or with such conditions or modifications as the
Commissioner deems necessary to carry out the purposes of this permit.
Nothing in this paragraph shall excuse noncompliance or delay.
Dates. The date of submission to the Commissioner of any document required
by this permit shall be the date such document is received by the
Commissioner. The date of any notice by the Commissioner under this permit,
including but not limited to notice of approval or disapproval of any
document or other action, shall be the date such notice is personally
delivered or the date three days after it is mailed by the Commissioner,
whichever is earlier. Except as otherwise specified in this permit, the
word "day" as used in this permit means calendar day. Any document or
action which is required by this permit to be submitted or performed by a
date which falls on a Saturday, Sunday or a Connecticut or federal holiday
5G-22
-------
14
shall be submitted or performed on or before the next day which is not a
Saturday, Sunday, or Connecticut or federal holiday.
Notification of noncompliance. In the event that the permittee becomes
at.wa.re that it did not or may not comply, or did not or may not comply on
time, with any requirement of this permit or of any document required
hereunder, the permittee shall immediately notify the Commissioner arid shall
take all reasonable steps to ensure that any noncompliance or delay is
avoided or, if unavoidable, is minimized to the greatest extent possible.
In so notifying the Commissioner, the permittee shall state in writing the
reasons for the noncompliance or delay and propose, for the review ar.c
written approval of the Commissioner, dates by which compliance will be
achieved, and the permittee shall comply with any dates which may be
approved in writing by the Commissioner. Notification by the permittee
shall, not excuse nonccmpliance or delay, and the Commissioner's approval of
any compliance dates proposed shall not excuse noncompliance or delay unless
specifically so stated by the Commissioner in writing.
Noncompliance. Failure to comply with this permit may subject the permittee
to an injunction and penalties under Chapters 439, and 44S or 446k of the
Connecticut General Statutes.
False statements. Any false statement in any information submitted pursuant
to this permit may be punishable as a criminal offense under Section 22a-438
or 22a-131a of the Connecticut General Statutes or, in accordance with
Section 22a-6, under Section 53a-l57 of the Connecticut General Statutes.
Permittee's obligations under law. Nothing in this permit shall relieve the
permittee of other obligations under applicable federal, state and local
law.
Notice to Commissioner of changes. Within fifteen days of the date the
permittee becomes aware of a change in any information submitted to the
Commissioner under this permit, or that any such information was inaccurate
or misleading or that any relevant information was omitted, the permittee
shall submit the correct or omitted information to the Commissioner.
Submission of documents. Any document, other than a discharge monitoring
report, required to be submitted to the Commissioner under this permit
shall, unless otherwise specified in writing by the Commissioner, be
directed to:
Stephen Edwards
Department of Environmental Protection
Water Management Bureau
Permitting, Enforcement & Remediation Division
79 Elm Street
Hartford, CT 06106
All sample analyses required by this permit shall be performed by a
laboratory certified for such analyses by the Connecticut Department of
Public Health and Addictive Services or approved in writing by the
Connecticut Department of Environment Protection.
5G-23
-------
15
Chemical analyses to determine compliance with effluent limits an
conditions established in this permit for the parameters identified below
shall be performed using the methods specified below unless an alternative
method has been specifically approved in writing by the Commissioner for
monitoring at this facility. Alternative analytical methods which have been
approved by the U.S. Environmental Protection Agency in accordance with 40
CFR 136 may be substituted for the methods identified provided the analysis
includes appropriate calibration points or check standards which demonstrate
that the method is capable of quantification of the parameter at the
concentration necessary to verify compliance with permit limits. Failure to
use analytical methods specified or approved by the Commissioner shall
constitute a permit violation.
Minimum
Parameter Method Leva!
Cadmium, Total EPA-213.2 0.5 ug/1
Chlorine, Total Residual EPA-330.4 50.0 ug/1
Copper, Total EPA-220.2 5.0 ug/1
Lead, Total EPA-239.2 5.0 ug/1
Silver, Total EPA-272.2 2.0 ug/1
Unless an alternative method is used pursuant to paragraph 4.8. above, the
Minimum Levels specified in paragraph 4.B. represent the concentration at
which quantification must be achieved and verified during the chemical
analyses for these parameters. Analyses for these parameters must include
check standards within ten percent of the specified Minimum Level or
calibration points equal to or less than the specified Minimum Level.
If any sample analysis indicates that quantification of a parameter at the
concentration necessary to verify compliai.ce with permit limits was not
demonstrated and that quantification can not be verified at or below the
specified Minimum Level for a particular parameter, a second effluent sample
shall be collected and analyzed for that parameter according to the above
specified methodology as soon as practicable. The results of the first and
subsequent sample analyses shall be submitted to the Commissioner no later
than 60 days following collection of the first sample for which
quantification was not achieved certifying that the appropriate methodology
was employed, quantification was verified at or below the Minimum Level for
quality-control samples and that failure to qualify the parameter at or
below the Minimum Level was a result of matrix effects which could not be
accounted for as part of sample analysis as allowed pursuant to 40 CFR 136.
If any three (3) samples analyzed in a twelve-month period indicate that the
specified Minimum Level was not achieved for a parameter when using the
specified test methodology, the permittee shall submit a report for the
review and approval of the Commissioner which justifies and defines the
matrix effect upon analyses for that parameter, identifies the lowest
concentration at which quantification can reliably be verified using the
specified method and presents recommendations regarding future monitoring at
the facility including alternative analytical methodologies, if available.
(i) The value of each parameter for which monitoring is required under this
permit shall be reported to the maximum level of accuracy and precision
possible consistent with the requirements of paragraph 4.
5G-24
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16
(ii) Effluent analyses which indicate that a parameter was not detected
using the method specified in paragraph 4.B. above shall be reported as
"less than x" where 'x' is the numerical value equivalent method
detection limit for that analysis.
B. Results of the effluent analyses which indicate that a parameter was not
present at a concentration greater than or ecrual to the Minimum Level
specified for that analysis shall be considered equivalent to zero (0.0} for
the purposes of determining compliance with effluent limitations or
conditions specified in this permit.
This permit shall expire on SEPTEMBER 29, 1999.
The permittee shall comply with the following sections of the Regulations of
Connecticut State Agencies which are hereby incorporated into this permit:
Section 22a-430-3 General Conditions
(a)Definitions
(b)General
(c)Inspection and Entry
(d)Effect of a Permit
(e)Duty
(f)Proper Operation and Maintenance
(g)Sludge Disposal
(h)Duty to Mitigate
(i)Facility Modifications; Notification
(j)Monitoring, Records and Reporting Requirements
(k)Bypass
(1)Conditions Applicable to POTWs
(m)Effluent Limitation Violations (Upsets)
(n)Enforcement
(0)Resource Conservation
(p)Spill Prevention and Control
(q)Instrumentation, Alarms, Flow Recorders
(r)Equalization
2a-43 0-4 Procedures and Criteria
(a)Duty to Apply
(b)Duty to Reapply
(c)Application Requirements
(d)Preliminary Review
(e)Tentative Determination
(f)Draft Permits, Fact Sheets
(g)Public Notice, Notice of Hearing
(h)Public Comments
(1)Final Determination
(j)Public Hearings
(k)Submission of Plans and Specifications. Approval.
(1)Establishing Effluent Limitations and Conditions
(m)Case by Case Determinations
5G-25
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17
(n)Permit issuance or renewal
(o)Permit Transfer
(p)Permit revocation, denial or modification
(q)Variances
(r)Secondary Treatment Requirements
(s)Treatment Requirements for Metals and Cyanide
(t)Discharges to POTWs - Prohibitions
\our attention is especially drawn to the notification requirements of subsection
(i) (2) , (i) (3) , (j)(6), (j) (9) (C) , (j)(ll)(C), (D), (E) , and (F) , (k):3) and (4) and
(1)(2} of Section 22a-430-3.
This Permit requires the payment of an annual fee as set forth in Section
22a-430-7 of the Regulations of Connecticut State Agencies:
The Commissioner reserves the right to make appropriate revisions to the permit
in order to establish any appropriate effluent limitations, schedules of compliance,
or other provisions which may be authorized under the Clean Water Act or the
Connecticut General Statutes or regulations adopted thereunder, as amended. The
permit as modified or renewed under this paragraph may also contain any other
requirements of the Clean Water Act or Connecticut General Statutes or regulations
adopted thereunder which are then applicable.
Entered as a Permit Modification of the Commissioner on the 16th day of November, 1
SidttSy J. Holbrook
Commissioner
APPLICATION NO. 9
5G-26
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Notes
1 =
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CHAPTER 4
Storm Water Discharges and
Oil Spill Prevention
4.1 Federal Requirements 4-3
4.1.1 What Storm Water Management Requirements Apply to Metal Finishers? 4-4
4.1.2 What Basic Requirements May Be Included in a General Storm Water Permit? 4-11
4.1.3 General Permit Requirements for Monitoring 4-12
4.1.4 General Permit Requirements for Preparing and Implementing Storm Water
Pollution Prevention Plans 4-13
4.1.5 What Oil Spill Prevention Requirements Apply to Metal Finishers? 4-26
4.2 Where To Go for Further Information 4-30
4.2.1 Storm Water Discharge 4-30
4.2.2 Oil Spill Prevention 4-31
What's in This Chapter
Three programs under the federal Clean Water Act are of concern to metal
finishers. One of these programs (covering wastewater discharges) is
described in Chapter 3. This chapter describes the other two programs of
concern, which cover storm water discharges and oil spill prevention:
¦ Some, but not all, metal finishers that discharge storm waters directly
into receiving waters or into a separate sewer system that discharges into
receiving waters will have to obtain permits for their storm water
discharges.
¦ A few metal finishers with certain types of oil storage facilities will have
to meet requirements to develop spill prevention and countermeasure
plans.
Deadlines for compliance with requirements under these programs are past. If
your facility is not yet in compliance, is under construction, or is expanding its
operation, read this chapter to find out how to comply. If you are already in
compliance, you can review this chapter to verify that you are complying with
all the requirements. Appendix 4-A provides a summary of the key
requirements and deadlines.
All states have their own laws to protect surface water. Key state requirements
are summarized towards the end of this chapter. Be sure to check with state
authorities to determine what state requirements apply to your facility.
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Table of Contents Page
4.1 Federal Requirements 4-3
4.1.1 What Storm Water Management Requirements Apply to Metal Finishers? 4-4
4.1.1.1 Does My Metal Finishing Operation Need a Permit for Storm Water Discharge? 4-4
4.1.1.2 What Types of Discharges Will My Storm Water Permit Cover? 4-6
4.1.1.3 What Type of Permit Should I Apply For? 4-6
4.1.1.4 What Is the Deadline for Permit Application? 4-8
4.1.1.5 Who Issues Storm Water Permits? 4-8
4.1.1.6 How Can I Register for a General Permit? 4-10
4.1.2 What Basic Requirements May Be Included in a General Storm Water Permit? 4-11
4.1.3 General Permit Requirements for Monitoring 4-12
4.1.4 General Permit Requirements for Preparing and Implementing Storm Water
Pollution Prevention Plans 4-13
4.1.4.1 Phase 1: Establish a Pollution Prevention Team 4-14
4.1.4.2 Phase 2: Assess the Site 4-16
4.1.4.3 Phase 3: Select Best Management Practices and Design the Plan 4-20
4.1.4.4 Phase 4: Implement the Plan 4-23
4.1.4.5 Phase 5: Conduct an Annual Evaluation 4-24
4.1.4.6 Required Signatures and Reviews 4-24
4.1.4.7 Recordkeeping 4-25
4.1.4.8 Plan Revisions 4-25
4.1.4.9 Deadlines for Developing and Implementing the Plan 4-25
4.1.5 What Oil Spill Prevention Requirements Apply to Metal Finishers? . . . 4-26
4.2 Where To Go for Further Information 4-30
4.2.1 Storm Water Discharge 4-30
4.2.2 Oil Spill Prevention: 4-31
Appendix 4-A Compliance Calendar for Federal Storm Water Discharge and Oil Spill
Prevention Requirements
Appendix 4-B List of Storn Water Industrial Activity Categories
Appendix 4-C Federal and State Storm Water Contacts
Appendix 4-D Section 313 Water Priority Chemicals
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Federal Storm Water Discharge and Oil Spill Prevention Requirements:
How To Comply
Federal Storm Water Discharge
~ Determine whether you are subject to the storm water discharge
requirements (Section 4.1.1).
~ If you are subject, apply for a storm water discharge permit. Comply
with permit requirements, which may include preparing and
implementing a storm water pollution prevention plan and
monitoring your storm water discharges.
Federal Oil Spill Prevention and Countermeasure Plans
~ Determine whether you are subject to these requirements (Section
4.1.5).
~ If you are subject, prepare a spill prevention and countermeasure
plan within 6 months of initiating operations. Fully implement your
plan within 1 year after beginning operations.
4.1 Federal Requirements
The Clean Water Act (CWA) is the principal federal law protecting
surface water quality in the United States. Chapter 3 provides more
information on this act and describes the CWA requirements for
wastewater discharge. Two other CWA programs, described in this
chapter, may affect metal finishers:
¦ Permitting of storm water discharges affects some metal
finishers.
¦ Preparation of oil spill control and countermeasure plans
affects a select few metal finishers.
With few exceptions, the deadlines for compliance with the storm
water and oil spill requirements have past. If your facility is in
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operation and is covered by either or both of these programs, you
should already be in compliance or should come into compliance as
soon as possible.
In addition, every state now has its own clean water act with
equivalent goals to the federal CWA. Section 4.2 reviews some of
the key state requirements for storm water discharge and oil spill
prevention. Contact your state authorities for details on the
particular requirements in your state.
4.1.1 What Storm Water Management Requirements Apply
to Metal Finishers?
Rain or snow that falls on industrial sites can pick up heavy metals,
oil and grease, nutrients, and other pollutants. This runoff often
flows undisturbed directly into receiving waters, contributing to
degraded water quality. This source of water contamination is a
major contributor to remaining water quality problems and is now
being addressed at the federal level. Beginning in 1990, EPA
initiated procedures to require permits for discharges of storm water
associated with industrial activity.
4.1.1.1 Does My Metal Finishing Operation Need a
Permit for Storm Water Discharge?
Some metal finishers will need an NPDES permit for storm water
discharge. Review Box 4-1 below to determine whether your facility
needs a storm water permit.
EPA has defined 11 industrial activity categories (numbered i - xi)
that are of varying levels of concern to storm water quality. All
metal finishers who are subject to the storm water regulations fall
into Category i because this category includes any facility (regardless
of size) that is subject to toxic pollutant effluent guidelines. All
metal finishers are subject to these guidelines, as described in Box 4-
1 and Appendix 3-E of Chapter 3; therefore, all metal finishers
subject to the storm water regulations need at least a Category I
permit.
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Box 4-1 Do the Storm Water Discharge Regulations Apply to My Facility?
1.
What happens to storm water at your facility?
• If your facility channels storm water into a conduit, pipe, or ditch that conveys it off
the premises as a point source discharge, go to 2.
• If storm water simply runs into the ground or off your facility without being collected
and channeled, your facility is not covered by the storm water regulations. You do
not need to read Sections 4.1.1 through 4.1.4 of this chapter. END
2.
Where does your facility's storm water discharge flow?
• If your facility's storm water discharge goes into a combined storm and sanitary sewer
system that conveys the storm water to a municipal treatment plant, then your
facility is not covered by the storm water regulations. You do not need to read
Sections 4.1.1 through 4.1.4 of this chapter. END
• If your facility's storm water discharge flows directly into a receiving water or into a
separate storm sewer system that discharges directly to a receiving water, go to 3.
3.
Are any of your processes, storage, or loading/unloading exposed to storm water?
Different permitting authorities make different judgments about what is considered to be
a process exposed to storm water. You likely will need to check with your storm water
permitting authority to definitively answer this question. Review Section 4.1.1.5 to
identify who your permitting authority is.
• Ifyes (i.e., one or more of your processes, storage, or loading/unloading is exposed to
storm water), go to 4.
• If no (i.e., none of your processes, storage, or loading'unloading is exposed to storm
water), your facility is not covered by the storm water regulations. You do not need to
read Sections 4.1.1 through 4.1.4 of this chapter. END
4.
Are you a job shop or captive metal finisher?
• If you are a captive metal finisher, go to 5.
• If you are a job shop metal finisher, your facility is covered by the storm water
regulations described in Sections 4.1.1 through 4.1.4 of this chapter. END
5.
Under the storm water regulations, each facility needs only one storm water
permit. Therefore, captive metal finishing operations will be covered by the permit for
the entire facility. In some cases, it is the captive metal finishing operations that trigger
the need for a facility-wide permit. A facility-wide permit will cover not only the captive
metal finishing operations but also any other relevant conditions at the facility.
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Metal finishers whose Standard Industrial Classification (SIC) code
is 3441 (Fabricated Structural Metal) are also covered by Category
ii. Category ii supersedes Category i because the permit
requirements are more stringent.
Appendix 4-B defines all 11 industrial activity categories for storm
water permits. If your operation is a captive shop, you can review
this appendix to determine which category applies to your facility
as a whole.
4.1.1.2 What Types of Discharges Will My Storm Water
Permit Cover?
Storm water permits cover discharges:
from any conveyance which is used for collecting and conveying storm
water and which is directly related to manufacturing, processing or raw
material storage areas at an industrial plant.
Conveyances include roads with drainage systems, catch basins, curbs,
gutters, ditches, man-made channels, or storm drains.
Box 4-2 lists the types of activities or areas normally covered in the
storm water permit. (For facilities in industrial Category xi [light
industry], the permits cover discharges from these areas only when
equipment or materials, product, or wastes are exposed to storm
water.)
4.1.1.3 What Type of Permit Should I Apply For?
EPA's 1990 storm water regulations established three permitting
options for industrial facilities:
¦ General permit—These permits (also referred to as Notices
of Intent, or NOIs) apply to a wide range of facility types and
their storm water discharges. This is the least expensive and
most straightforward option for most metal finishers.
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Box 4-2 Areas and Activities Covered by the Storm Water Permit
For facilities in industrial Categories i-x, the permits cover discharges from:
¦ Industrial plant yards.
¦ Immediate access roads and rail lines used or traveled by carriers of raw materials,
manufactured products, waste material, or by-products used or created by the
facility.
¦ Material handling sites.
¦ Refuse sites.
¦ Sites used for the application or disposal of process waste waters.
¦ Sites used for storing and maintaining material handling equipment.
¦ Sites used for residual treatment, storage, or disposal.
¦ Shipping and receiving areas.
¦ Manufacturing buildings.
¦ Storage areas (including tank farms) for raw materials and intermediate and
finished products.
¦ Areas where industrial activity has taken place in the past and significant materials
remain and are exposed to storm water.
¦ Individual permit. These permits consider specific aspects
of the facility and its storm water discharges. To apply for an
individual permit, you must create a site map and perform
sampling and analysis of a "representative" storm. Few metal
finishers are likely to require an individual permit. Applying
for an individual permit is much more complex and requires
substantial data collection and reporting compared to
applying for a general permit.
¦ Group permit. These permits allow facilities to group
together with other similar facilities. Group permits take into
account specific aspects of the group of facilities and their
storm water discharges. Note that most states discourage use
of group permits.
In the early stages of the permitting program, some metal finishers
applied for group permits. Over time, however, the group permit
option became impractical. It was complex and required substantial
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data collection and analysis. Many facilities that had applied for a
group permit either withdrew their applications or had their
applications rejected; these facilities reverted to general permit
status. EPA combined the remaining facilities that had applied for
a group permit and had not been rejected or had not withdrawn
their applications into 29 industrial sectors. EPA then crafted
specific permit language for each of the 29 sectors. This sector-
specific language was designed to be combined with the general
permit language to create a permit specific to the sector's operations.
With very few exceptions, facilities that become newly subject to the
storm water regulations cannot apply for a sector-specific permit.
Thus the group, or sector-specific, permit is not an option for metal
finishers.
EPA published final general permit language on September 9, 1992,
and final sector-specific (group) permit language on September 29,
1995.
4.1.1.4 What Is the Deadline for Permit Application?
For most existing facilities, the deadline for obtaining a permit has
past. If your facility is covered by the storm water regulations and
you are currently discharging storm water, you should have
registered for a general permit or hare an individual or group permit
in place. Facilities that were rejected or denied from the group
application process have a year from the date of the rejection or
denial before they have to start meeting the permit requirements for
planning. New facilities must register for a general permit or obtain
an individual permit and begin to meet the permit conditions before
commencing storm water discharge. Box 4-9 in Section 4.1.4.9
provides more detail on permitting deadlines.
4.1.1.5 Who Issues Storm Water Permits?
General Permits
Forty states have been given authority by EPA to manage general
storm water permits. These states are shown in Box 4-3. In all
other states and in the six territories, EPA manages the general
storm water permits.
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Box 4-3 States Approved To Issue NPDES Permits
Alabama
Nevada
Arkansas
New Jersey
California
New York
Colorado
North Carolina
Connecticut
North Dakota
Delaware
Ohio
Florida
Oregon
Georgia
Pennsylvania
Hawaii
Rhode Island
Illinois
South Carolina
Indiana
South Dakota
Iowa
Tennessee
Kansas
Utah
Kentucky
Vermont
Maryland
Virgin Islands
Michigan
Virginia
Minnesota
Washington
Mississippi
West Virginia
Missouri
Wisconsin
Montana
Wyoming
Nebrasl a
Current as of May, 1995. To get the most current information on the status of state general
storm water permit programs, contact U.S.
EPA, Office of Water, Permits Division, NPDES
Program Branch, 202-260-8486.
Individual Permits
Twenty-nine states have been given authority by EPA to issue
individual storm water permits. These states are shown in Box 4-4.
In all other states and in the six territories, EPA issues the individual
storm water permits.
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Box 4-4 States Approved To Issue Individual Storm Water Permits
Alabama
New Jersey
Arkansas
North Carolina
California
Ohio
Connecticut
Oregon
Florida
Rhode Island
Georgia
South Carolina
Hawaii
South Dakota
Iowa
Tennessee
Kentucky
Utah
Maryland
Vermont
Michigan
Virginia
Minnesota
Washington
Mississippi
West Virginia
Missouri
Wisconsin
Nebraska
Current as of May, 1995. To get the most current information on the status of state general
storm water permit programs, contact U.S. EPA, Office of Water, Permits Division, NPDES
Program Branch, 202-260-8486.
Contact Information
Appendix 4-C lists EPA and state storm water contacts.
4.1.1.6 How Can I Register for a General Permit?
To register for a general permit, you must first complete an NOI to
be covered by the permit. The NOI is a one-page document that:
¦ Identifies the facility operator.
¦ Describes the site and location.
¦ Describes site activity.
¦ States whether storm water is discharged to a municipal
separate storm sewer, and if so, provides the name of the
sewer authority.
¦ States whether storm water is discharged directly to receiving
waters, and if so, the name of such waters.
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¦ Indicates whether the facility is 1) not subject to monitoring,
2) subject to monitoring but not required to submit data, 3)
subject to monitoring and required to submit data, or 4)
subject to monitoring but submitting certification for
exclusion. Metal finishers fall into category 2 (subject to
monitoring but not required to submit data)—see Section
4.1.3.
¦ Gives the facility's primary and secondary SIC codes.
¦ States the existing NPDES permit number for the facility, if
one exists.
4.1.2 What Basic Requirements May Be Included in a
General Storm Water Permit?
Since a general permit is the most appropriate permitting option for
most metal finishers, the rest of this chapter focuses on the general
permit requirements. EPA has issued permit language that it uses
for general permits. States with authority to issue general permits
are free to develop their own permitting language. In practice,
however, most states incorporate a majority of the EPA general
permit language.
General storm water discharge permits that are based on EPA's
general permit language have two major requirement areas:
¦ Storm water monitoring.
¦ Preparation and implementation of a storm water pollution
prevention plan.
EPA has provided detailed guidance on fulfilling these requirements
in the following publications:
¦ Guidance for the preparation of discharge monitoring reports:
facilities required to report semi-annual monitoring results under
npdes storm water general permits (EPA Office of Water,
Washington, DC, EPA/833/B-93/002, April 1994, 20 pages).
¦ Storm water management for industrial activities: developing
pollution prevention plans and best management practices: summary
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guidance( EPA Office of Water, Enforcement and Compliance,
Washington, DC, EPA/833/R-92/002, 1994, 53 pages).
The key points of this guidance are summarized below, in Sections
4.1.3 through 4.1.4. This information is intended as an
introduction to fulfilling the requirements of general permits based
on EPA language. Be sure to consult with your permitting authority
and review the guidance documents to obtain complete information
on what is required by your permit.
4.1.3 General Permit Requirements for Monitoring
General permits may contain up to three types of monitoring
requirements, depending on the type of facility: analytical
monitoring, compliance monitoring, and visual monitoring. Most
metal finishers are subject only to the visual monitoring
requirements, as described below. Analytical monitoring may at
times be relevant for captive metal finishers. Compliance
monitoring is not required for any metal finishers.
Visual Monitoring
Visual monitoring of storm water quality is required of most
facilities covered under the storm water NPDES permits, including
metal finishers. The visual examination should cover all storm water
outfalls and include any observations of color, clarity, odor, floating
solids, foam, oil sheen, or other obvious indicators of storm water
pollution. The visual examination should take place in a well-lit
area. Monitoring is not required if there is insufficient rainfall or
snowmelt to generate runoff, or if hazardous conditions prevent
sampling. Inspectors should use grab samples to collect a sample of
the storm water runoff in a container for closer observation. In all
cases, observations should be recorded and attempts made to relate
the results of the observations (e.g., presence of contaminants) to
potential sources of contamination in the area. If a source is
identified, the facility operator should be informed immediately of
the source and actions taken to eliminate it.
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Analytical Monitoring
Analytical monitoring, or sampling of storm water discharges for
specific pollutants, is required for facilities that demonstrate a
potential to discharge pollutants at concentrations of concern. Job
shop metal finishing facilities are not on the list of facilities required
to perform analytical monitoring. Captive metal finishers that are
in industries covered by the analytical monitoring requirements will
generally not be involved in sampling and monitoring.
4.1.4 General Permit Requirements for Preparing and
Implementing Storm Water Pollution Prevention Plans
The purpose of a Storm Water Pollution Prevention Plan, often
abbreviated as SWP3, is to prevent industrial contaminants from
being picked up and washed into receiving waters. The plans
typically include common sense measures to reduce or eliminate the
potential for contact between storm water and materials, equipment,
or contaminated surfaces that can contribute pollutants to these
flows.
This section describes an approach you can use to develop and
implement an SWP3 for your facility. This approach consists of five
phases, as shown in Box 4-5 below.
Box 4-5
Five Phases of Developing the Storm Water
Pollution Prevention Plan
Phase 1:
Establish a pollution prevention team.
Phase 2:
Assess the site.
Phase 3:
Select best management practices and design
the plan
Phase 4:
Implement the plan
Phase 5:
Conduct an annual evaluation
Special requirements apply if you have certain chemicals on site (the
Section 313 water priority chemicals) in amounts large enough to
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make them subject to the Toxic Release Inventory (TRI) reporting
requirements (Section 313) of the Emergency Planning and
Community Right-to-Know Act (also known as SARA Title III).
Review Box 4-6 to determine whether you are subject to the special
requirements for facilities with water priority chemicals.
4.1.4.1 Phase 1: Establish a Pollution Prevention Team
The first step in preparing an SWP3 is to assemble a storm water
pollution prevention team. Your plan must identify and describe
the team members and their responsibilities under the SWP3. The
pollution prevention team will be responsible for:
¦ Defining and agreeing on an appropriate set of goals for the
facility's storm water management program.
¦ Implementing all general permit and pollution prevention
plan requirements.
¦ Presenting management with estimates of the level of
resources needed to implement the plan, including adoption
of best management practices (BMPs.)
¦ Being aware of any changes that are made in plant operations
to determine whether any changes must be made to the plan.
¦ Maintaining a clear line of communication with plant
management to ensure a cooperative partnership.
A small pollution prevention team at a metal finishing facility could,
for example, consist of a technical field person, an environmental
manager, and an operations manager. It could also include any
outside consultant you use to assist in plan preparation.
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Box 4-6 Am I Subject to the Special Requirements for Facilities With
Section 313 Water Priority Chemicals?
1. Does your facility employ fewer than 10 full-time workers?
If yes, you are automatically exempt from the Section 313 requirements and
therefore not subject to the special requirements for facilities with Section 313 water
priority chemicals. If no, go to 2.
2. Review the list of Section 313 water priority chemicals in Appendix 4-D.
Identify any chemicals present at your facility. If none of these chemicals is present
at your facility, you are not subject to the special requirements for facilities with
Section 313 water priority chemicals. If any of these chemicals is present, go to 3.
3. Read Section 8.1.3 of Chapter 8 to find out whether the water priority
chemicals at your facility are present in sufficient quantities to trigger the
Section 313 reporting requirements.
— If any of these chemicals triggcs the Section 313 reporting requirements, then
you are also subject to the special requirements, described below, for facilities
with Section 313 water priority chemicals.
— If none of these chemicals triggers the Section 313 reporting requirements, then
yrou are not subject to the special requirements for water priority chemicals. If
the quantities of any of these chemicals at your facility increase in the future,
however, you will need to recheck whether the larger quantities trigger the
Section* 313 requirements and thus, the special requirements for water priority
chemicals described below.
The pollution prevention team should examine other existing
environmental management plans and identify any plan elements
that can be incorporated into the SWP3. Examples of plans that
may provide useful information are:
¦ Spill Prevention Control and Countermeasures Requirements
(40 CFR Part 112) (see Section 4.1.5).
¦ NPDES Toxic Organic Management Plan (40 CFR Parts
413, 433, and 469) (see Section 3.1.4.2 of Chapter 3).
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¦ Occupational Safety and Health Administration (OSHA)
Emergency Action Plan (29 CFR Part 1910).
For facilities subject to reporting under EPCRA, Section 313 for
water priority chemicals, the team must include a person who will
be accountable for spill prevention related to these chemicals. This
individual must be identified in the plan, and must establish spill
emergency procedures and reporting requirements to isolate,
contain, and clean up spills and emergency releases of Section 313
water priority chemicals.
4.1.4.2 Phase 2: Assess the Site
The first step for the pollution prevention team is to examine the
facility and identify materials or activities that might contribute
contamination to storm water flows. To complete this phase, it is
recommended that the team complete the steps described below.
Develop a Map of the Site
The map should identify discharge points, drainage patterns, types
of pollutants likely to be discharged for each drainage area, direction
of flow, water bodies receiving discharges, structural control
measures, location of significant materials exposed to storm water,
and locations of relevant industrial activities (fueling stations,
loading and unloading areas, vehicle or equipment maintenance
areas, waste disposal areas, storage areas).
Develop an Inventory of "Significant Materials" That Are Handled,
Stored, or Processed Onsite
"Significant materials" are those that could potentially contribute to
contamination of storm water draining from the industrial site. A
list of such materials is shown in Box 4-7 below. The SWP3 also
must describe the methods and locations of:
¦ Onsite storage and disposal practices used to minimize
contact of the materials with storm water.
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¦ Structural and nonstructural controls used to reduce
pollutants in storm water runoff.
¦ Any storm water treatment methods.
Examples of structural controls include tanks, dikes, storm water
runoff control ditches, and sewer systems. The structural controls
should correspond to the site drainage map. Examples of
nonstructural controls include good housekeeping procedures, visual
checks for leaks or spills, and other manual procedures that the
facility has implemented to control material inventories or generally
keep the facility clean.
Box 4-7 Examples of "Significant Materials" To Include
in the Inventory
¦ Raw materials.
¦ Finished materials such as metallic products.
¦ Materials such as solvents, detergents, and plastic
pellets.
¦ Fuels.
¦ Fertilizers.
¦ Pesticides.
¦ Any chemical the facility is required to report
pursuant to EPCRA, Section 313 (see Chapter 8).
¦ Hazardous substances designated under Section
101(4) of CERCLA
¦ Waste products such as ashes, slag, and sludge that
have the potential to be released with storm water
discharges (40 CFR I2.16[b][12]).
Identify Past Spills and Leaks
All facilities are required to provide a list of significant spills or leaks
of toxic or hazardous materials that have occurred in the past 3
years. Significant spills are defined as releases that occur within a
24-hour period that exceed the reportable quantity (RQ) for that
December 1996
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
material under CERCLA or the Clean Water Act. Regulations
listing these quantities are contained at 40 CFR 302.4, 40 CFR
117.21, and 40 CFR 110.10. You must provide a description of the
cause of the spill or leak, response actions for cleanup, and measures
implemented to prevent future incidents.
Check for Unauthorized Water Discharges to Storm Water Sewers
One of the major sources of storm water contamination is the
unauthorized discharge of process waters to storm water sewers.
Examples of such discharges include water used directly in the
manufacturing process, air conditioner condensate, noncontact
cooling water, vehicle wash water, and sanitary wastes.
Aside from storm water, only the following discharges may be
discharged to storm water sewers:
¦ Air conditioner condensate.
¦ Springs or uncontaminated ground water.
¦ Uncontaminated foundation drains.
¦ Irrigation drainage.
¦ Discharges from firefighting activities and fire hydrant
flushing.
¦ Discharges from potable water sources including water line
flushing.
¦ Discharges from lawn watering.
¦ Discharges from routine exterior building wash-down
without detergents.
¦ Discharges from pavement washing where spills have not
occurred or where spills have been cleaned.
The SWP3 requires that all potential "cross-connections" that would
route process wastewater to storm water sewers be checked and
verified. Several methods exist for identification of piping flow,
such as in-pipe video cameras, dye tracing, flow tests, visual
inspections, and as-built diagrams. One simple way to verify there
December 1996
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
are no cross-connections is to check for an absence of flow from the
storm water outfalls during standard operations.
Certification of no cross-connections must be done by an authorized
person. If inspection is not possible, you must describe why
inspection is not possible in the SWP3 and notify EPA by October
I, 1993, for existing dischargers, or 180 days after submitting a
NO I for new dischargers. Any identified nonstorm water flows
that are not authorized under the general permit should either be
permitted by a nonprocess or process water NPDES permit or
prevented from combining with storm water discharges.
Submit Any Existing Analytical Data
Where existing storm water sampling data are available, you must
provide a summary of the existing data and describe the sample
collection procedures used. The general permit identifies certain
facilities that must perform additional sampling during storm events.
The storm water regulations specify requirements for this additional
sampling. The sampled storm event must:
¦ Result in at least 0.1 inch of rainfall accumulation.
¦ Occur a minimum of 72 hours after the previous rainfall of
at least 0.1 inch.
¦ Have an intensity within 50 percent of the average rain event
for the area.
The sampling requirements include:
¦ A grab sample obtained within the first 30 minutes from the
start of runoff.
¦ A flow-weighted composite sample of the first 3 hours of the
storm event.
The analysis must be performed by analytical methods approved by
40 CFR Part 136. EPA has issued a guidance document to assist
facility operators with storm water sampling (NPDES Storm Water
Sampling Guidance Document, EPA Office of the Assistant
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Storm Water Discharges and Oil Spill Prevention
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Administrator for Water, Washington, DC, EPA/833/B-92/001, July
1992, 177 pages). Sampling a storm event can be a significant tasle
Develop and Submit a Site Assessment Summary
The site assessment summary should describe activities with a high
potential for contaminating storm water discharges, and describe the
pollutants of concern associated with such activities. The
assessment must, at a minimum, consider the following activities:
¦ Loading and unloading
¦ Outdoor storage
¦ Outdoor processing and manufacturing
¦ Significant dust- and particulate-generating processes
¦ Onsite waste disposal
4.1.4.3 Phase 3: Select Best Management Practices and
Design the Plan
Once you have identified and characterized the areas and activities
with ootential for contributing contaminants to storm water
discharges, you should identify and implement appropriate storm
water pollution prevention and control measures (best management
practices or BMPs). To satisfy the requirements of this phase, you
must describe the BMPs and justify their selection.
For many facilities, this portion of the plan consists mainly of
documenting and describing current facility practices. If you don't
already have BMPs in place, however, establishing such procedures
can be time consuming, because it involves identifying which
procedures or controls are adequate for pollution prevention.
At a minimum, your SWP3 must incorporate the BMPs listed in
Box 4-8. Implementation of these BMPs should address most of the
concerns with respect to potential storm water contamination.
Additional BMPs may be appropriate for specific circumstances.
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Storm Water Discharges and Oil Spill Prevention
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Box 4-8 Mandatory BMPs To Include in Your SWP3
BMP
Description
Good housekeeping
Maintaining a clean and orderly work environment, proper
operation and maintenance of equipment, careful material
storage and management practices, employee training about
good housekeeping practices.
Preventive maintenance
Each plan must include a preventive maintenance program for
storm water runoff management devices and equipment. It
should also include inspections of facility operations to detect
faulty equipment that could contribute to storm water
contamination.
Visual inspections
Regular visual inspections of the facility's equipment and areas
are required. Inspectors should maintain written records of their
inspections, including areas inspected, problems found, steps
taken to correct problems. Records should be kept with the
SWP3 for at least 1 year.
Spill prevention and
response
Areas where spills may occur and their likely drainage points
should be identified in the SWP3. Appropriate material
handling, storage requirements, and cleanup procedures must
also be described.
Sediment and erosion
control
The SWP3 must identify areas that have a "high potential for
significant soil erosion" and identify measures to limit the
potential erosion. Erosion potential can be reduced using a
number of techniques, including soil stabilization methods and
runoff diversion or flow velocity dissipation structures. Several
erosion control methods are described in EPA guidance
documents on preparing SWP3s (see Section 4.1.2).
Management of runoff
The SWP3 must describe existing storm water controls and
identify any additional measures that can be implemented to
improve the prevention and control of contaminated storm
water. Examples include: vegetative swales, reuse of collected
storm water, infiltration trenches, and detention ponds.
Employee training
Permittees must develop employee training programs that cover
such topics as spill prevention and response, good housekeeping
practices, and proper material management. The goals of the
training are to teach all employees, at all levels of the
organization, the elements of the SWP3 and to create an overall
awareness of storm water pollution prevention concerns.
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Storm Water Discharges and Oil Spill Prevention
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Additional Requirements for Facilities With Water Priority
Chemicals
If your facility is subject to reporting under EPCRA Section 313 for
water priority chemicals, your plan must include regular inspections,
at appropriate intervals, of all areas of the facility for the following:
¦ Leaks or conditions that would lead to discharges of Section
313 water priority chemicals.
¦ Conditions that could lead to direct contact of storm water
with Section 313 water priority chemicals, intermediate
materials, waste materials, or products.
¦ Piping, plumbing, storage tanks and bins, pressure vessels,
process and material handling equipment, and material bulk
storage areas for leaks, wind blowing, corrosion, support or
foundation failure, or other deterioration or noncontainment.
In addition, if a spill or leak of a Section 313 water priority chemical
occurs, you must remove the contaminated soil, material, or debris
promptly and dispose of it in accordance with federal, state, and
local requirements, as described in your storm water pollution
prevention plan.
All facilities subject to reporting under EPCRA Section 313 for
water priority chemicals must also implement the following
additional controls:
¦ Provide containment, drainage control, and/or diversionary
structures. Prevent or minimize runon by installing curbing,
culverting, gutters, sewers, or other controls and/or prevent or
minimize exposure by covering storage piles.
¦ Prevent discharges from liquid storage areas. Store liquid
materials in compatible storage containers and/or provide
secondary containment designed to hold the volume of the
largest storage tank plus precipitation.
¦ Prevent discharges from material storage areas. Install
drainage and/or other control measures.
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Storm Water Discharges and Oil Spill Prevention
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¦ Prevent discharges from loading^unloading areas. Use drip
pans and/or implement a strong spill contingency and
integrity testing plan.
¦ Prevent discharges from handling/processing/transferring
areas. Use covers, guards, overhangs, door skirts and/or
conduct visual inspections or leak tests for overhead piping.
¦ Prevent discharges from all the above areas. Use manually
activated valves with drainage controls in all areas, and/or
equip the plant with a drainage system to return spilled
material to the facility.
¦ Introduce facility security programs to prevent spills. Use
fencing, lighting, traffic control and/or secure equipment and
buildings.
4.1.4.4 Phase 4: Implement the Plan
Under this phase, your facility's pollution prevention team should
establish a schedule for implementing BMPs and should train
employees to carry out the goals of the plan.
Developing a Schedule
The schedule should establish deadlines for completing each BMP
item. In establishing schedules, individuals responsible for
implementing various BMPs should be identified and consulted.
Management should be briefed on the implementation schedule and
strategy, and schedules should be established for providing
implementation progress reports.
Employee Training
Pollution prevention is most successful when all employees
understand and appreciate the prevention philosophy, are aware of
basic pollution prevention techniques, and understand the basic
elements of the pollution prevention plan. All employees, including
contract employees, should be trained in the basic elements of the
SWP3. The training must include, at minimum, spill prevention,
good housekeeping, and materials management practices.
December 1996
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
If your facility is subject to reporting under EPCRA Section 313 for
water priority chemicals, additional training requirements apply.
Employees and contractor personnel that work in areas where such
chemicals are used or stored must be trained in the following areas
at least once per year:
¦ Preventive measures, including spill prevention and response
and preventive maintenance.
¦ Pollution control laws and regulations.
¦ Your facility's Storm Water Pollution Prevention Plan.
¦ Features and operations of your facility that are designed to
minimize discharges of Section 313 water priority chemicals,
particularly spill prevention procedures.
4.1.4.5 Phase 5: Conduct an Annual Evaluation
Once your plan has been introduced, it is important to track and
monitor your facility's progress in implementing BMPs and
complying with the storm water regulations.
At least once per year, you must conduct an evaluation that includes
the following elements:
¦ Inspect storm water drainage areas for signs of pollutants
entering the drainage system.
¦ Evaluate the effectiveness of BMPs.
¦ Observe structural BMPs to ensure proper operation.
¦ Revise your plan as needed.
¦ Prepare an evaluation report.
Sign the report and file a copy with the plan.
4.1.4.6 Required Signatures and Reviews
Your facility's SWP3 must be signed by an "authorized
representative," who is a person at or near the top of your facility's
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Storm Water Discharges and Oil Spill Prevention
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management chain (the president, vice-president, or a production
manager).
If your facility is subject to reporting under EPCRA Section 313 for
water priority chemicals, a Certified Professional Engineer must
review your plan and certify that it was prepared in accordance with
good engineering practices. This certification does not relieve you
of the responsibility to implement the plan. You must have the plan
recertified every 3 years or after it is significantly altered.
4.1.4.7 Recordkeeping
You must maintain records of your annual evaluations (described
above) and of all spills, leaks, inspections, and maintenance
activities. You must maintain these records on site for at least 1
year after your permit expires.
In general, the storm water pollution prevention plan must be
maintained on site, although some permits may require the plans to
be submitted to the NPDES director for review. You must keep
your facility's plan and all related records for at least 1 year after
your facility's permit expires.
4.1.4.8 Plan Revisions
Any major changes in facility design, construction, layout, or
procedures that have the potential to impact storm water
management should be noted in the plan. Update your plan as
necessary to reflect these changes.
4.1.4.9 Deadlines for Developing and Implementing the
Plan
Box 4-9 shows the deadlines for developing and implementing your
SWP3.
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Storm Water Discharges and Oil Spill Prevention
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Box 4-9 Deadlines for Storm Water Pollution Prevention
Planning and Implementation
Type of facility
Deadline for plan
development
Deadline for plan
implementation
Facilities applying for
a general or
individual permit
48 hours before
commencing
discharge
48 hours before
commencing
I discharge
Industrial facilities
rejected or denied
from the group
application process
365 days after date of
rejection or denial
545 days after date of
rejection or denial
Note: The director may grant a written extension for plan preparation and
compliance for new dischargers after October 1, 1992, upon a showing of
good cause.
4.1.5 What Oil Spill Prevention Requirements Apply to
Metal Finishers? (40 CFR 112)
A few metal finishers may be subject to federal oil storage
requirements under the Clean Water Act. These requirements,
described below, should not be confused with federal, state, or local
planning requirements regarding prevention of and response to
chemical spills.
Section 311 (j) of the CWA requires spill control and prevention
plans of certain facilities that store oil. You are subject to these
requirements (described in 40 CFR 112) if your facility stores:
¦ More than 1,320 gallons of oil above ground (roughly
equivalent to 24 55-gallon drums), or
¦ Over 660 gallons in any single aboveground container, or
¦ Over 42,000 gallons below ground
AND
¦ The storage facility is located where it could reasonably be
expected to discharge oil in the navigable waters of the
United States or adjoining shorelines.
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
If your operation's oil storage facilities meet these criteria, you must
prepare a Spill Prevention Control and Countermeasure (SPCC)
Plan. Box 4-10 describes how to prepare and maintain the plan.
These plans must be in place within 6 months of when your facility
began operations. They must be fully implemented as soon as
possible, but no later than 1 year after operations begin.
Box 4-10 To Comply With SPCC Requirements You
Must:
/ Prepare an SPCC Plan within 6 months and implement the
plan within I year after your facility begins operation.
~ Have a Registered Professional Engineer review the SPCC
Plan, inspect the site, and certify that the plan complies
with good engineering practices.
/ Maintain a complete copy of the SPCC Plan at your
facility.
~ Amend the SPCC Plan whenever there is a change in
facility design, construction, operation, or maintenance that
materially affects your facility's potential for the discharge
of oil.
/ Review and evaluate the plan at least once every 3 years.
/ Submit reports and an amended SPCC Plan to EPA if there
is a single spill of 1,000 gallons or more of oil onto
navigable waters or adjoining shorelines or if there is a
discharge of oil in harmful quantities into navigable waters
or adjoining shorelines from two spills occurring within any
12-month period.
The requirements, described below, for SPCC Plans may change. In
1990, Congress amended the CWA through adoption of the Oil
Pollution Act (OPA). The OPA calls for EPA to revise and
strengthen the existing SPCC rules. EPA proposed revisions to the
SPCC rules on October 22, 1991. As of April 1996, these rules had
not been finalized. If and when they are finalized, you can call the
hotline numbers given in Box 4-11 to find out how these changes
affect you.
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Storm Water Discharges and Oil Spill Prevention
Parti, Chapter 4
Box 4-11 Further Information About Spill Prevention
For further information, call either of the following:
¦ ERNS/SPCC Information Line at 202-260-2342
¦ RCRA/Superfund Hotline at 800-424-9346
Your SPCC Plan must include the following elements:
¦ When there has been a spill within the past year, a
description of the spill detailing the corrective actions taken
and the plans for preventing a similar spill in the future.
¦ Where there is a reasonable potential for equipment failure,
such as a tank rupture or overflow, a prediction of the
direction, rate of flow, and total quantity of oil that could be
discharged as a result of such a failure.
¦ A discussion of the appropriate secondary containment
and/or diversionary structures or equipment to prevent
discharged oil from reaching navigable waters (see Box 4-12).
¦ Where installation of secondary containment or diversionary
structures is not practical, a demonstration of the
impracticability and presentation of a contingency plan for
remediating spills, including commitment of labor,
equipment, and materials.
¦ A discussion of conformance to spill prevention guidelines
detailed in the regulation for facility drainage systems, bulk
storage tanks, facility transfer operations (including pumping,
in-plant processes, and tank truck unloading), inspections
and recordkeeping, security, and personnel training in spill
prevention procedures.
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Box 4-12. Secondary Containment Systems
The regulations suggest, but don't require, that facilities use, at a
minimum, one of the following secondary containment systems:
¦ Dikes, berms, or retaining walls
¦ Curbing
¦ Culverts, gutters, or other drainage systems
¦ Weirs, booms, or other barriers
¦ Spill diversion ponds
¦ Retention ponds
¦ Sorbent materials
(These systems mav be required if EPA's October 22, 1991, proposed
rule is adopted.)
Having developed an SPCC Plan, you should then adhere to its
provisions and guidelines. In particular, you must:
¦ Inspect accumulated storm water before discharging it from
diked areas to ensure that it conforms to applicable water
quality standards.
¦ Inspect the condition of your aboveground tanks.
¦ Regularly test liquid level sensing devices in tank installations
(both new and old) to ensure that the devices operate
properly.
¦ Document employee training.
You should maintain records of these activities and retain the
records for at least 3 years.
If a single spill of more than 1,000 gallon occurs, or if two
reportable spills occur in a 12-month period, you must amend your
SPCC Plan to include provisions for preventing future spills. You
must report the spill(s) and submit your amended SPCC Plan within
60 days.
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
4.2 Where To Go for Further Information
4.2.1 Storm Water Discharge
For more information on storm water permitting, contact your
storm water permitting authority. Appendix 4-C provides EPA and
state storm water contact information.
The following guidance manuals contain valuable information that
may be helpful in complying with general permit conditions.
¦ Overview of the storm water program (EPA Office of Water,
Washington, DC, EPA 833-R-96-008, June 1996).
¦ Guidance for the preparation of discharge monitoring reports:
facilities required to report semi-annual monitoring results under
npdes storm water general permits (EPA Office of Water,
Washington, DC, EPA/833/B-93/002, April 1994, 20 pages).
¦ Storm water management for industrial activities: developing
pollution prevention plans and best management practices: summary
guidance(EPA Office of Water, Enforcement and Compliance,
Washington, DC, EPA/833/R-92/002, 1994, 53 pages).
¦ NPDES storm water sampling guidance document (EPA 833-B-92-
001, July 1992).
These manuals are available from:
The Office of Water Resources Center
USEPA - RC-4100
401 M Street, SW
Washington, DC 20460
Telephone: (202) 260-7786
The final national NPDES storm water multi-sector general permit
for industrial activities was published in the Federal Register on
September 29, 1995. This notice contains all of the requirements
for submitting Notices of Intent and complying with the pollution
prevention, monitoring, and reporting requirements of the general
permit. You can obtain a copy of the Federal Register from a library
December 1996
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
or by calling the Government Printing Office Order Desk at 202-
783-3238 or by writing:
Superintendent of Documents
Attn: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
4.2.2 Oil Spill Prevention
For further information about oil spill prevention requirements,
contact:
¦ ERNS/SPCC information line (202-260-2342)
¦ RCRA/Superfund hotline (800-424-9346)
December 1996
4-31
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APPENDIX 4-A
COMPLIANCE CALENDAR FOR FEDERAL STORM WATER
DISCHARGE AND OIL SPILL PREVENTION REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHAPTER 4 - STORMWATER DISCHARGES
Milestone Events
Regular or Periodic Events
At least once every 3
years
SPCC plan
CWA 31 l(j)
Review and evaluate the SPCC plan.
Maintain a copy at the
site
4-27
Within 6 months of
commencing
operations
SPCC plan
CWA 31 l(j)
Prepare an SPCC plan and have it reviewed by a
registered professional engineer
Maintain a copy at the
site
4-27 to 4-29
Whenever there is a
change at your facility
that affects the
potential for oil
discharge
SPCC plan
CWA 3110)
Amend the SPCC plan
Maintain a copy at the
site
4-27 to 4-29
On a regular basis
Inspection
CWA 3110)
Inspect condition of aboveground tanks
On file at the facility
4-27 to 4-29
On a regular basis
Test
CWA3U0)
Test liquid level sensing devices in tanks
On file at the facility
4-27 to 4-29
On a regular basis
Record
CWA 3110)
Document employee training
On file at the facility
4-27 to 4-29
On a regular basis
Monitor status of proposed changes to the Oil
Pollution Act that will strengthen the SPCC
requirements (proposed October 22, 1991)
4-27
Other Events
48 hours before
commencing storm
water discharge
Permit
1990 Storm
Water
Regulations
Contact your permitting authority to obtain a permit
Permitting authority
Within 1 year of
commencing
operations
SPCC plan
CWA 3110)
Fully implement the SPCC plan
Maintain a copy at the
site
4-27 to 4-29
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Regulatory Compliance and Environmental Management Calendar
Due Dale and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
Wiiliin 60 days of a
spill of more than
1,000 gallons or more
of oil onto navigable
waters or adjoining
shorelines, or 2
discharges of oil in
harmful quantities
within a 12-month
period
Report
CWA31IG)
Submit information about the spill, including
corrective actions of countermeasures taken.
Amend SPCC plan to prevent future spills.
EPA and the State
agency responsible for
water pollution.
4-27 to 4-29
Prior to discharging
accumulated
slornnvater
Inspection
CWA3U(j)
Ensure water conforms to applicable water quality
standards
On file at the facility
4-27 to 4-29
48 hours before
commencing storm
water discharge
Permit
1990 Storm
Water
Regulations
Contact your permitting authority to obtain a permit
Permitting authority
4-26
Within 60 days of a
spill of more than
1,000 gallons or more
of oil onto navigable
waters or adjoining
shorelines, or 2
discharges of oil in
harmful quantities
within a 12-month
period
Report
CWA 31 l(j)
Submit information about the spill, including
corrective actions of countermeasures taken.
Amend SPCC plan to prevent future spills.
EPA and the State
agency responsible for
water pollution.
4-27 to 4-29
Prior to discharging
accumulated
stormwater
Inspection
CWA 31 l(j)
Ensure water conforms to applicable water quality
standards
On file at the facility
4-27 to 4-29
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Regulatory Compliance and 'Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
48 hours before
commencing storm
water discharge
Permit
1990 Storm
Water
Regulations
Contact your permitting authority to obtain a permit
Permitting authority
4-26
-------
APPENDIX 4-B
LIST OF STORM WATER INDUSTRIAL ACTIVITY CATEGORIES
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Storm Water Industrial Activity Categories
Category
Facilities Covered
Category i
Facilities subject to:
¦ Storm water effluent limitations guidelines.
¦ New source performance standards.
¦ Toxic pollutant effluent standards under 40 CFR Chapter N
(except those exempt under category xi).
Category ii
Facilities with the following SIC Codes:
SIC Code Industry Description
24 (except 2434) Lumber and wood products except furniture
26 (except 265 &. 267) Paper and allied products
28 (except 283 &. 285) Chemicals and allied products
29 Petroleum refining and related industry
311 Leather tanning and finishing
32 (except 323) Stone, clay, and glass products
33 Primary metal industries
3441 Fabricated structural metal
373 Ship and boat building and repairing
Category iii
Mining facilities (active and inactive)
§IC Code Industry Description
10 Metal mining
12 Coal mining
13 Oil and gas extraction
14 Mining and quarrying of nonmetallic minerals, except
fuels
Category iv
Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs)
Category v
Landfills, land application sites, and open dumps that have received any industrial
waste as defined by these categories
Category vi
Recycling facilities
SIC Code Industry Description
5015 Motor vehicle parts, used
5093 Scrap and waste materials
Category vii
Steam electric power-generating facilities (co-generators) including coal handling
(required to have individual permit)
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Storm Water Discharges and Oil Spill Prevention
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Storm Water Industrial Activity Categories
Category
Facilities Covered
Category viii
Transportation facilities with vehicle maintenance shops
SIC Code
Industry Description
40
Railroad transportation
41
Local and interurban passenger transit
42
Trucking and warehousing
43
Postal service
44
Water transportation
45
Transportation by air
5171
Petroleum bulk stations and terminals
Category ix
Treatment works treating domestic sewage, including associated land used for
disposal, with design flow of 1.0 million gallons per day or more.
Category x
Construction activities, including clearing, grading and excavation, except: operations
that result in the disturbance of less than 5 acres of total land area that are not part
of a larger common
plan of development or sale.
Category xi
Low risk facilities
SIC Code
Industrv Description
20
Food and kindred products.
21
Tobacco products.
22
Textile mill products.
23
Apparel and other textile products.
2434
Wood kitchen cabinets.
25
Furniture and fixtures.
265
Paperboard containers and boxes.
267
Misc. converted paper products.
27
Printing and publishing.
283
Drugs.
285
Paints and allied products.
30
Rubber and miscellaneous plastics products.
31 (except 311)
Leather and leather products.
323
Products of purchased glass.
34 (except 3441)
Fabricated metal products.
35
Industrial machinery and equipment.
36
Electronic and other electronic equipment.
37 (except 373)
Transportation equipment.
38
Instruments and related products.
39
Miscellaneous manufacturing industries.
4221-25
Farm product warehousing and storage, refrigerated
warehousing and storage, general warehousing and
storage.
Source: Final National Pollutant Discharge Elimination System Storm Water Multi-Sector General
Permit for Industrial Facilities; Notice. Federal Register Vol. 60, No. 189. September 29, 1995, p.
50804.
December 1996
4-B2
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APPENDIX 4-C
FEDERAL AND STATE STORM WATER CONTACTS1
' Source: U.S. EPA. "Storm Water List of Contacts," March, 1995.
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Headquarters
Address
U.S. Environmental
Protection Agency
Office of Water Permits
Division, MC-4203
401 M Street, SW
Washington, DC 20460
Fax
(202) 260-9544
Name
I Address
I Telephone
1 Internet
Permits Division
Nancy Cunningham
Biologist
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
202-260-9535
Cunningham. Nancy
@ EPAMAIL.EPA.GOV
Kim Hankins
Environmental Specialist
Office of Water Permits Division, MC-4203
401 M Street. SW
Washington, DC 20460
202-260-8328
Hankins. Kim berly
® EPAMAIL.EPA.GOV
Bill Swietlik
Chief, Storm Water Section
Permits Division
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington. DC 20460
202-260-9529
Swietlik. William
@ EPAMAIL.EPA.GOV
Bill Tate
Environmental Engineer
Office of Water Permits Division, MC-4203
401 M'Street, SW
Washington, DC 20460
202-260-6963
Tate. William
@ EPAMAIL.EPA.GOV
Betty West
Program Analyst
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington. DC 20460
202-260-8486
West. Betty
@ EPAMAIL.EPA.GOV
Carmelita White
Program Analyst
Office of Water Permits Division, MC-4203
401 M Street. SW
Washington. DC 20460
202-260-6053
White.Carmelita
@ EPAMAIL.EPA.GOV
Office of General Counsel
Stephen Sweeney
Attorney
U.S. Environmental Protection Agency
Office of General Council, MC-2355
401 M Street, SW
Washington, DC 20460
202-260-8739
Sweeney.Steve
@ EPAMAIL.EPA.GOV
Municipal Support Division
Bob Lee
Chief, Municipal Technical Branch
U.S. Environmental Protection Agency
Office of Municipal Support, MC-7406
401 M Street. SW
Washington. DC 20460
202-260-9412
Jim Wheeler
Environmental Engineer
Municipal Technical Branch
U.S. Environmental Protection Agency
Office of Municipal Support, MC-4204
401 M Street. SW
Washington, DC 20460
202-260-7356
Joe Mauro
Environmental Engineer
Municipal Technical Branch
U.S. Environmental Protection Agency
Office of Municipal Support, MC-4204
401 M Street. SW
Washington. DC 20460
202-260-7356
December 1996
4-C1
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Office of Research and
Development
Richard Field
National Risk Management Research
Storm and Combined Sewer Program Laboratory
2890 Woodbridge Avenue
Edison, NJ 08837-3679
908-321-6674
Dan Murray
National Risk Management Research Laboratory
Center for Environmental Research Information
26 W. Martin Luther King Drive (G-75)
Cincinnati. OH 4S268
513-569-7522
FAX 513-569-7585
Murray. Dan
@ EPAMAIL.EPA.GOV
December 1996
4-C2
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region I
Address
U.S. EPA - Region I
JFK Federal Building
Boston, MA 02203
Fax
617-565-4940
Name
Title
Telephone
Mall Stop
Clyde Shufelt
Chief, Special Permits
617-565-3580
WMS
Jay Brolin
Environmental Engineer
617-565-3590
WMS
Shelly Puleo
Environmental Protection Specialist
617-565-3525
WCP
Olga Vergara
Environmental Protection Specialist
617-565-3525
WCP
State Offices
in EPA Region I
Name and Title
Address
Telephone
Chris Stone
Storm Water Coordinator
Connecticut Department of Environmental Protection
Water Management Bureau
79 Elm Street
Hartford, CT 06106-5127
860-424-3018
FAX 860-566-8650
Norm Marcotte
Nonpoint Program Coordinator
Maine Department of Environmental Protection
Division of Environmental Evaluation
State House, Station #17
Augusta, ME 04333
207-287-3901
FAX 207-287-7826
Paul Hogan
NPDES Coordinator
Massachusetts Department of Environmental Protection
Office of Watershed
40 Institute Road
P.O. Box 116
N. Grafton. MA 01536
508-792-7470
FAX 508-839-3469
Jeff Andrews
Supervisor, Industrial Permits Section
New Hampshire Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
603-271-2457
FAX 603-271-2867
Chris Feeney
Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277-6519
FAX 401-521-4230
Angelo Liberti
Supervising Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277-6519
FAX 401-521-4230
Kim Wiegand
Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277-6519 ext.
7233
FAX 401-521-4230
i
December 1996
4-C3
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Brian Koiker
j Chief Director, Permits Section
|
I
Environmental Conservation
Wastewater Management Division
Sewing Building
103 S. Main Street
Waterbury, VT 05671-0405
802-241-3822
FAX 802-244-5141
Gary Schultz
Director, Wastewater Management Division
Environmental Conservation
Wastewater Management Division
Sewing Building
103 S. Main Street
Waterbury, VT 05671-0405
802-241-3822
FAX 802-244-5141
December 1996
4-C4
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region II
Address U.S. EPA - Region II
Water Permits and
Compliance Branch
290 Broadway
New York, NY 10007-
1866
I Fax 212-264-9597
Name
Title
Telephone
Sergio Bosques
Storm Water Regional Coordinator
212-264-8681
Jose A. Rivera
Senior Environmental Engineer
Caribbean Field Office
Central Europa Building, Suite 417
1492 Ponce deLeon Avenue
Santurce. PR 00907
809-729-6951
FAX 809-729-7747
State Offices
in EPA Region II
Name and Title
Address
Telephone
Barry Chalofsky
Manager, Bureau of Storm Water Permitting
New Jersey Department of Environmental Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton. NJ 08625
609-633-7026
FAX 609-984-2147
Ed Frarkel
Section Chief
New Jersey Department of Environmeni :l Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton. NJ 08625
609-633-7026
FAX 609-984-2147
Janet Jessel
Brian McLendon
Supervisors
New Jersey Department of Environmental Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton. NJ 08625
609-633-7026
FAX 609-984-2147
General Information
New Jersey Department of Environmental Protection
(CN-243) Division of Water Quality
401 E. State Street
Trenton. NJ 08625
609-633-7026
FAX 609-984-2147
N.G. Kaul
Director, Division of Water
New York State Department of Environmental Conservation
50 Wolf Road
Albany. NY 12233-3505
518-457-6674
FAX 518-485-7786
Ken Stevens
Chief, Stormwater Management Section
New York State Department of Environmental Conservation
Bureau of Water Quality Management
50 Wolf Road
Albany. NY 12233-3508
518-457-3656
FAX 518-485-7786
Wanda Garcia-Hernandez
Chief. Permits and Engineering Division
Puerto Rico Environmental Quality Board
4? 1 Ponce de Leon Avenue
5th Floor, Office 527
P.O. Box 11488
Haw Rev. PR 00910
809-767-8731
FAX 809-767-1962
December 1996
4-C5
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Carlos Irizarry
Director, Water Quality Control Bureau
Puerto Rico Environmental Quality Board
431 Ponce de Leon Avenue
5th Floor. Office 527
P.O. Box 11488
Hato Rey, PR 00910
809-767-8731
FAX 809-767-1962
Jeff Miller
Environmental Specialist III
Virgin Islands Planning and Natural Resources
Division of Environmental Protection
1118 Watergut Homes, Christiansted
St. Croix. VI 00820-5065
809-773-0565
FAX 809-773-9310
December 1996
4-C6
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region III
Address
U.S. EPA - Region III
841 Chestnut Building
Philadelphia, PA 19107
Fax
215-597-8541/215-597-
8241/215-597-3359
Name
Title
Telephone
Mail Stop
Leo Essenthier
Storm Water Coordinator
215-597-0547
(3WM54)
Alexander Slinsky
Environmental Eneineer
215-597-6465
(3WM53)
State Offices
in EPA Region III
Name and Title
Address
Telephone
Chuck Schadel
Environmental Engineer ~
Delaware Department of Natural Resources and Environmental
Control
Division of Water Resources/Pollution Control Branch
89 Kings Highway
Dover. DE 19903
302-739-5731
FAX 302-739-3491
James Collier
Program Manager for Water Resource
Management Division
DC Department of Consumer and Regulatory Affairs
2100 Martin Luther King, Jr. Avenue S.E.
Washington. DC 20020
202-404-1120,
Ext. 3040
FAX 202-404-1141
Brian Clevenger
Chief, Program Review Division
Maryland Department of the Environment
2500 Broening Highway
Baltimore. MD 21224
410-631-3543
FAX 410-631-4883
Edward Gertier
Chief, Industrial Permits Division
Maryland Department of the Environment
2500 Broening Highway
Baltimore. MD 21224
410-631-3323
FAX 410-631-4883
Stu Gansell
Chief of Permits and Compliance
Pennsylvania Department of Environmental Resources
400 Market Street State Office Building, 10th Floor
Harrisbure. PA 17101-2702
717-787-3481
FAX 717-787-2802
R.B. Patel
Chief of Permits Section/
Sanitary Engineer IV
Pennsylvania Department of Environmental Resources - BWQM
Division of Permits and Compliance
400 Market Street State Office Building, 10th Floor
P.O. Box 8465
Harrisbure. PA 17105-8465
717-787-8184
FAX 717-772-5156
Mr. Vu
Sanitary Engineer
Pennsylvania Department of Environmental Resources - BWQM
Division of Permits and Compliance
400 Market Street State Office Building, 10th Floor
P.O. Box 8465
Harrisbure. PA 17105-8465
717-787-8184
FAX 717-772-5156
Burton Tuxford
Environmental Engineer
Virginia Department of Environmental Quality
4900 Cox Road
P.O. Box 11143
Glen Allen. VA 23060
804-527-5083
FAX 804-527-5293
December 1996
4-C7
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Cathy Boatwright
Storm Water Program Manager
Virginia Department of Environmental Quality
4900 Cox Road
P.O. Box 11143
Glen Allen, VA 23060
804-527-5316
FAX 804-527-5293
Jim Mason
Engineer, Storm Water Coordinator
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston, WV 25311
304-558-8855
FAX 304-348-5905
Jerry Ray
Assistant Chief, Permits
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston, WV 25311
304-558-0375
FAX 304-348-5905
Arthur A. Vickers
Engineer, Storm Water Coordinator
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston. WV 25311
304-558-8855
FAX 304-348-5905
December 1996
4-C8
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region IV
Address
U.S. EPA - Region IV
345 Courtland Street,
NE
Atlanta, GA 30365
Fax
404-347-1739
| Name
Title
Telephone
Roosevelt Childress
Chief, Permits Section
Water Management Division
404-347-3012. Ext. 2980
FAX 404-347-1739
Carolyn Ejimofor
Environmental Engineer
404-347-3012. Ext. 2978
FAX 404-347-1739
Cheryl Espy
Environmental Engineer
404-347-3012, Ext. 2977
FAX 404-347-1739
Mike Mitchell
Environmental Scientist
404-347-3012, Ext. 2951
FAX 404-347-1739
Bemita Richardson
Environmental Protection Specialist
404-347-3012, Ext. 2950
FAX 404-347-1739
State Offices
in EPA Region IV
Name and Title
Address
Telephone
Dennis Larrison
Chief, Permits/Compliance Section
Alabama Department of Environmental Management
Water Division
Municipal Branch
1751 Dickinson Drive
Montgomery, AL 36130
205-271-7801
FAX 205-270-5612
Tim Forester
Chief, Mining and Nonpoint Source Section
Alabama Department of Environmental Management
Water Division
1751 Dickinson Drive
Montgomery. AL 36130
205-271-7958
FAX 205-270-5612
John Poole
Chief, Industrial Branch
Alabama Department of Environmental Management
Water Division
Industrial Branch
1751 Dickinson Drive
Montgomery, AL 36130
205-271-7852
FAX 205-270-5612
Tyson Griswold
Engineer
Alabama Department of Environmental Management
Water Division
1751 Dickinson Drive
Montgomery. AL 36130
205-271-7811
FAX 205-270-5612
Eric Livingston
Environmental Administrator
Florida Department of Environmental Protection
Siormwater/NPS Management Section
2600 Blair Stone Road
Tallahassee. FL 32399-2400
904-488-0782
FAX 904-921-5217
December 1996
4-C9
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Jeff Larson
Program Manager
Georgia Department of Natural Resources
Environmental Protection Division - Municipal
4244 International Parkway, Suite 110
Atlanta. GA 30354
404-362-2680
FAX 404-362-2654
Lawrence W. Hedges
Program Manager
Georgia Department of Natural Resources
Environmental Protection Division - Industrial
205 Butler Street. SE, Suite 1070
Atlanta. GA 30334
404-656-4887
FAX 404-657-7379
Will Sailer
Environmental Specialist
Georgia Department of Natural Resources
Environmental Protection Division - Industrial
205 Butler Street, SE, Suite 1070
Atlanta. GA 30334
404-656-4887
FAX 404-657-7379
Douglas Allgeier
Industrial Section Supervisor
Department of Environmental Protection
Kentucky Division of Water
14 Reilly Road
Frankfort. KY 40601
502-564-3410
FAX 502-564-4245
Jeff Hippe
Permit Writer
Department of Environmental Protection
Kentucky Division of Water
14 Reilly Road
Frankfort. KY 40601
502-564-3410
FAX 502-564-4245
Herb Ray
Environmental Engineer (Municipalities)
Department of Environmental Protection
Kentucky Division of Water
14 Reilly Road
Frankfort. KY 40601
502-564-3410
FAX 502-564-4245
Jerry Cain
Chief, Industrial Wastewater Branch
Mississippi Department of Environmental Quality
Office of Pollution Control
Industrial Wastewater Branch
P.O. Box 10385
Jackson. MS 39289-0385
601-961-5073
FAX 601-961-5703
Louis Lavallee
Chief, Storm Water Section
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson. MS 39289-0385
601-961-5074
FAX 601-961-5703
Kenneth LaFIeur
Assistant, Storm Water Section
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson. MS 39289-0385
601-961-5192
FAX 601-961-5703
Hameh Salem
Environmental Engineer
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson. MS 39289-0385
601-961-5234
FAX 601-961-5703
Bradley Bennett
Environmental Engineer
North Carolina Division of Environmental Management
512 N. Salisbury Street
P.O. Box 29535
Raleieh. NC 27626-0535
919-733-5083,
Ext. 571
FAX 919-733-9919
Bill Mills
Environmental Engineer
North Carolina Department of Environment, Health and Natural
Resources
512 N. Salisbury Street
P.O. Box 29535
Raleiuh. NC 27626-0535
919-733-5083,
Ext. 548
FAX 919-733-9919
December 1996
4-C10
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Anuro Ovalles
Environmental Engineer Associate
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia. SC 29201
803-734-5300
FAX 803-734-5216
K. Flint Holbrook, PE
Storm Water Section Manager
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia. SC 29201
803-734-9251
FAX 803-734-5216
Harvey Daniel
Environmental Quality Manager
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia. SC 29201
803-734-9250
FAX 803-734-5216
Robert Haley HI
Environmental Engineer
Tennessee Water Pollution Control
L&C Annex. 6th Floor
401 Church Street
Nashville. TN 37243-1534
615-532-0625
FAX 615-532-0614
December 1996
4-C11
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Regioo V
Address
U.S. EPA - Region V
77 W. Jackson Blvd.
Mail Code WQP16J
Chicago, IL 60604
Fax
312-886-7804
Name
Title
Telephone
Mail Stop
Peter Swenson
Environmental Eneineer
312-886-0236
WQP-16J
Steve Jann
Environmental Scientist
312-886-2446
WQP-16J
State Offices
in EPA Region V
Name and Title
Address
Telephone
Ginger Wells
Storm Water Management
Illinois EPA
2200 Churchill Road
P.O. Box 19276
Springfield. IL 62794-9276
217-782-0610
FAX 217-782-9891
Laura Bieberich
Storm Water Coordinator
Indiana Department of Environmental Management
100 N. Senate Avenue
P.O. Box 6015
Indianapolis. IN 46206-6015
317-233-6725
FAX 317-232-8406
Gary Boersen
Chief, Storm Water Permits Unit
Michigan Department of Natural Resources
Surface Water Quality Division
P.O. Box 30273
Lansing. MI 48909
517-373-1982
FAX 517-373-9958
Dave Drullinger
Environmental Quality Analyst
Michigan Department of Natural Resources
Surface Water Quality Division
P.O. Box 30273
Lansing. MI 48909
517-335-4117
FAX 517-373-9958
Gene Soderbeck
Engineer/Supervisor
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul. MN 55155-3898
612-296-8280
FAX 612-297-8683
Dan Sullivan
Staff Engineer/Storm Water Coordinator
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul. MN 55155-3898
612-296-7219
FAX 612-297-8683
John Morrison
Supervisor, Storm Water Unit
Ohio EPA
1800 Watermark Drive
P.O. Box 1049
Columbus. OH 43216-1049
614-644-2259
FAX 614-644-2329
Robert Phelps
Storm Water Coordinator
Ohio EPA. Water Pollution Control
1800 Watermark Drive
P.O. Box 1049
Columbus. OH 43216-1049
614-644-2034
FAX 614-644-2329
December 1996
4-C12
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Storm Water Discharges and Oil Spill Prevention
Part l, Chapter 4
Name and Title
Address
Telephone
Jim Helm
Storm Water Administrative Assistant
Wisconsin Department of Natural Resources
101 S. Webster
P.O. Box 7921
Madison, WI 53707
608-266-2779
FAX 608-267-7664
EPA Region VI
Address U.S. EPA - Region VI
1445 Ross Avenue, Suite
1200
Dallas, TX 75202-2733
Fax 214-665-6490
Name
Title
Telephone
Mail Stop
Paulette Johnsey
Environmental Scientist
Municipal Permits Section
214-665-7521
(6W-PM)
Brent Larsen
Environmental Scientist
Municipal Permits Section
214-665-7523
(6W-PM)
Monica Burrell
Environmental Engineer
Municipal Permits Section
214-665-7530
(6W-PM)
Astrid Larsen
Enforcement Branch
214-665-6454
(6W-ET)
Dorothy Crawford
Environmental Engineer
Municipal Permits Section
214-665-7107
(6W-PM)
State Offices
in EPA Region VI
Name and Title
Address
Telephone
Mark Bradley
Permits Section Chief
Arkansas Department of Pollution Control and Ecology
8001 National Drive
P.O. Box 8913
Little Rock. AR 72219-8913
501-562-7444
FAX 501-562-4632
Tom Killeen
Program Manager
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
504-765-0525
504-765-0534
FAX 504-765-0635
Kilren Virdine
Environmental Coordinator - Municipal
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
504-765-0525
504-765-0534
FAX 504-765-0635
Anne Slater
Coordinator - General Permits
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge. LA 70884-2215
504-765-0525
FAX 504-765-0635
Darlene Bernard
Storm Water Coordinator
Louisiana Water Department of Environmental Quality
7290 Bluebonnet Boulevard
P.O. Box 82215
Baton Rouee. LA 70810
504-765-0525
FAX 504-765-0635
December 1996
4-C13
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Glen Saums
Health Program Manager, Surface Water
Section
New Mexico Health and Environment Department
Environmental Improvement Division
1190 St. Francis Drive
P.O. Box 26110
Santa Fe. NM 87502
505-827-2827
FAX 505-827-2836
Rich Powell
Environmental Scientist
New Mexico Environment Department
Surface Water Quality Bureau
1190 St. Francis Drive
P.O. Box 26110
Santa Fe, NM 87502
505-827-2798
FAX 505-827-2836
Brooks Kirlin
Environmental Engineer
Oklahoma Department of Environmental Quality
Customer Assistance Program
1000 N.E. 10th Street
Oklahoma Citv. OK 73117-1212
405-271-1400
FAX 405-271-7339
Dave Farrington
Storm Water Coordinator
Oklahoma Department of Environmental Quality
Water Quality Program
1000 N.E. 10th Street, WQS 0207
Oklahoma Citv. OK 73117-1212
405-271-7335
FAX 405-271-7339
Thomas W. Weber,
Manager, Permitting Section
Watershed Management Division
Texas Natural Resource Conservation Commission
1700 N. Congress Avenue
Steven F. Austin Building
P.O. Box 13087
Austin. TX 78711-3087
512-463-7748
FAX 512-463-6648
Arthur Talley
Team Leader
Texas Natural Resource Conservation Commission
P.O. Box 13087
Austin. TX 78711-3087
512-239-5767
FAX 512-239-4444
December 1996
4-C14
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region VII
Address
U.S. EPA - Region VII
726 Minnesota
Kansas City, KS 66101
Fax
913-551-7765
Name
Title
Telephone
Ralph Summers
NPDES Permits Coordinator
913-551-7418
State Offices
in EPA Region VII
Name and Title
Address
Telephone
Monica Wnuk
Storm Water Coordinator
Iowa Department of Natural Resources
Environmental Protection Division
900 E. Grand Avenue
Des Moines. LA 50319-0034
515-281-7017
FAX 515-281-8895
David Freise
Environmental Engineer
Kansas Department of Health and Environment
Building 283 - Forbes Field
J Street and 2 North
Topeka, KS 66620
913-296-5557
FAX 913-296-5509
Marian Massoth
Environmental Engineer
Kansas Department of Health and Environment
Building 283 - Forbes Field
J Street and 2 North
Topeka. KS 66620
913-296-5556
FAX 913-296-5509
Linda Vogt
Environmental Specialist
Missouri Department of Natural Resout :es
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
314-526-5630
FAX 314-751-9396
Richard Laux
Permits Unit Chief
Missouri Department of Natural Resources
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
314-751-6825
FAX 314-751-9396
Ron Asch
NPDES Permit Writer
Nebraska Department of Environmental Quality
Suite 400
1200 N Street, The Atrium
P.O. Box 98922
Lincoln. NE 68509-8922
402-471-4239
FAX 402-471-2909
David Ihrie
NPDES Permit Writer
Nebraska Department of Environmental Quality
Suite 400
1200 N Street, The Atrium
P.O. Box 98922
Lincoln. NE 68509-8922
402-47 M239
FAX 402-471-2909
Clark Smith
Supervisor. Permits and Compliance Section
Nebraska Department of Environmental Quality
Suite 400
1200 N Street. The Atrium
P.O. Bo* 98922
Lincoln. NE 68509-8922
402-471-4239
FAX 402-471 -2909
December 1996
4-C15
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Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region VIII
Address
U.S. EPA - Region VT11
999 18th Street, Suite
500
Denver, CO 80202-2466
Fax
303-294-1386
Name
Title
Telephone
Vernon Berry
Storm Water Coordinator (8WM-C)
U.S. EPA - Region 8
999 18th Street. Suite 500
Denver. CO 80202-2466
303-293-1630
Paul Montgomery
Environmental Engineer
U.S. EPA - Region 8
Montana Operations Office
Federal Building
301 South Park. Drawer 10096
Helena, MT 59626-0096
406-449-5486
Ext. 234
(Montana questions
only)
State Offices
in EPA Region VIII
Name and Title
Address
Telephone
Kathy Dolan
Environmental Scientist
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
Permits and Enforcement
4300 Cherry Creek Drive South
Denver. CO 80222-1530
303-692-3590
FAX 303-782-0390
Sarah Johnson
Storm Water Unit Leader
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
4300 Cherry Creek Drive South
Denver. CO 80222-1530
303-692-3590
FAX 303-782-0390
Dan Beley
Environmental Scientist
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
4300 Cherry Creek Drive South
Denver. CO 80222-1530
303-692-3590
FAX 303-782-0390
Fred Shewman
Supervisor of Permits
Montana Department of Health and Environmental Sciences
Water Quality Bureau
1400 Broadway
P.O.200901
Helena. MT 59620-0901
406-444-2406
FAX 406-444-1374
Roxann Lincoln
Storm Water Program Manager
Montana Department of Health and Environmental Sciences
Water Quality Bureau
1400 Broadway
P.O. Box 200901
Helena. MT 59620-0901
406-444-2406
FAX 406-444-1374
December 1996
4-C16
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Jim Collins
Environmental Scientist/Storm Water
Coordinator
North Dakota State Department of Health
Division of Water Quality
1200 Missouri Avenue
P.O. Box 5520
Bismarck. ND 58506-5520
701-328-5210
FAX 701-328-5200
Norma Job
Natural Resources Engineer
South Dakota Department of Environment and Natural Resources
Point Source Control Program
Joe Foss Building
523 E. Capitol
Pierre. SD 57501-3181
800-737-8676
FAX 605-773-6035
Harry Campbell
Environmental Engineer/Storm Water
Coordinator
Utah Department of Environmental Quality
Division of Water Quality
288 North 1460 West
P.O. Box 144870
Salt Lake City. UT 84114-4870
801-538-6146
FAX 801-538-6016
John Wagner
Technical Support Supervisor
Wyoming Department of Environmental Quality - Water
Herschler Building
122 West 25th Street
Cheyenne. WY 82002
307-777-7082
FAX 307-777-5973
Marisa Latady
Environmental Analyst
Wyoming Department of Environmental Quality - Water
Herschler Building
122 West 25th Street
Cheyenne. WY 82002
307-777-7588
FAX 307-777-5973
December 1996
4-C17
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region IX
Address
U.S. EPA - Region IX
75 Hawthorne Street
San Francisco, CA
94105
Fax
415-744-1235
Name
Title
Telephone
Mail Stop
Eugene Bromley (W-5-1)
Storm Water Coordinator
415-744-1906
(W-5-1)
State Offices
in EPA Region IX
Name and Title
Address
Telephone
Robert Wilson
Storm Water Coordinator
Arizona,Department of Environmental Quality
Water Permits Unit
3033 North1 Central Avenue
Phoenix, AZ 85012
602-207-4574
FAX 602-207-4674
Pavlova Vitale
Senior Water Resources Control Engineer
California State Water Resources Quality Control Board
Santa Ana Regional Board
2010 Iowa Avenue, Suite 100
Riverside. CA 92507-2409
714-782-4130
FAX 714-781-6288
John Short
Senior Engineer
California State Water Resources Quality Control Board
Lahontan Regional Board
2092 Lake Tahoe Boulevard
South Lake Tahoe, CA 96150
916-544-3481
FAX 916-544-2271
Adam White
Associate Water Resources Control
Engineer
California State Water Resources Quality Control Board
Central Coast Regional Board
81 Higuera Street. Suite 200
San Luis Obispo. CA 93401-5247
805-549-3147
FAX 805-543-0397
Deborah Jayne
Environmental Specialist IV
California Regional Water Quality Control Board
San Diego Regional Board
9771 Claremont Mason Boulevard, Suite B
San Diego. CA 92124-1331
619-467-2952
FAX 619-571-6972
Betsy Jennings
Senior Staff Counsel
California State Water Resources Quality Control Board
P.O. Box 100
Sacramento. CA 95812
916-657-2421
FAX 916-657-2388
Orlando Gonzalez
Associate Water Resources Control
Engineer
California State Water Resources Quality Control Board
Colorado River Basin Regional Board
73-720 Fred Waring Drive, Suite 100
Palm Desert. CA 92260
619-776-8962
FAX 619-341-6820
Archie Mathews
Supervising Engineer
California State Water Resources Quality Control Board
Central Valley Regional Board
P.O. Box 944213
Sacramento. CA 94244-2130
916-657-0523
FAX 916-657-2388
December 1996
4-C18
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Name and Title
Address
Telephone
Pamela Barksdale
Associate Water Resources Control
Engineer
California State Water Resources Quality Control Board
Central Valley Regional Board
3443 Routier Road
Sacramento. CA 95827-3098
916-255-3024
FAX 916-255-3015
Tom Mumley
Storm Water Coordinator
California State Water Resources Quality Control Board
San Francisco Bay Regional Board
2101 Webster Street, Suite 500
Oakland. CA 94612
510-286-0962
FAX 510-286-1380
Bruce Fujimoto
Chief of Stormwater Unit
California State Water Resources Quality Control Board
Division of Water Quality
P.O. Box 944213
Sacramento. CA 94244-2130
916-657-0908
FAX 916-657-1011
Xavier Swamikannu
Water Resources Control Engineer
California State Water Resources Quality Control Board
Los Angeles Regional Board
101 Centre Plaza Drive
Monterey Park. CA 91754-2156
213-266-7592
FAX 213-266-7600
John Hannum
Associate Water Resources Control
Engineer
California State Water Resources Quality Control Board
North Coast Regional Board
5550 Skyland Boulevard, Suite A
Santa Rosa. CA 95403
707-576-2220
FAX 707-523-0135
Ed Chan
Supervisor - Engineering Section
Hawaii Department of Health
Clean Water Branch
500 Ala Moana Boulevard
5 Waterfront Plaza, Suite 250A
Honolulu. HI 96813
808-586-4309
FAX 808-586-4370
Alec Wong
Hawaii Department of Health
Clean Water Branch
500 Ala Moana Boulevard
5 Waterfront Plaza, Suite 250A
Honolulu. HI 96813
808-586-4309
FAX 808-586-4370
Denis R. Lau
Chief
Hawaii Department of Health
Clean Water Branch
500 Ala Moana Boulevard
5 Waterfront Plaza, Suite 250A
Honolulu. HI 96813
808-586-4309
FAX 808-586-4370
Rob Saunders
Environmental Engineer, Division of
Conservation and Natural Resources
Division of Environmental Protection
Capital Complex
333 W. Nye Lane
Carson Citv, NV 89710
702-687-5870
FAX 702-885-0868
December 1996
4-C19
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
EPA Region X
Address
U.S. EPA - Region X
1200 6th Avenue
Seattle, WA 98101
Fax
206-553-0165
Name
Title
Telephone
Mail Stop
Joe Wallace
Storm Water Coordinator
206-553-8399
(WD 134)
State Offices
in EPA Region X
Name and Title
Address
Telephone
Kenwyn George
Manager, Industrial Wastewater Program
Alaska Department of Environmental Quality
410 Willoughby Avenue
Juneau. AK 99801
907-465-5313
FAX 907-465-5274
Milce AJIen
Chief
Idaho Department of Health and Welfare
Division of Environmental Quality
Permits and Enforcements
1410 North Hilton Street
Boise. ID 83706
208-334-5898.
FAX 208-334-0417
Paul Keiran
Oregon Department of Environmental Quality
2020 SW 4th Avenue
Suite 400
Portland. OR 97201-5884
503-229-6345
FAX 503-229-5359
Raghu Namburi
Oregon Department of Environmental Quality
1102 Lincoln Street
Suite 210
Eugene. OR 97401
503-686-7838
Ext. 230
FAX 503-686-7551
Andy Alrich
Oregon Department of Environmental Quality
201 W. Main Street
Suite 2-D
Medford. OR 97501
503-776-6010
FAX 503-776-6262
Walt West
Oregon Department of Environmental Quality
2146 NE Fourth, #104
Bend. OR 97701
503-388-6146
FAX 503-388-8283
Peter Birch
Supervisor of Urban Non-Point
Management Unit - Municipal
Washington Department of Ecology
Mail Stop PV-1I
P.O. Box 47600
Olympia. WA 98504-7600
206-438-7076
FAX 206-438-7490
December 1996
4-C20
-------
APPENDIX 4-D
SECTION 313 WATER PRIORITY CHEMICALS
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
75-07-0
Acetaldehvde
107-02-8
Acrolein
107-13-1
Acrylonitrile
309-00-2
Aldrin[l,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-I,4,4a,5,8,8a hexahydro-
(1 .alpha.,4.alpha.,4a. beta. ,5.alpha.,8.alpha.,8a.beta.)-]
107-05-1
Allyl Chloride
7429-90-5
Aluminum (fume or dust)
7664-41-7
Ammonia
62-53-3
Aniline
120-12-7
Anthracene
7440-36-0
Antimony
7647189
Antimony pentachloride
28300745
Antimony potassium tartrate
7789619
Antimony tribromide
10025919
Antimony trichloride
7783564
Antimony tri fluoride
1309644
Antimony trioxide
7440-38-2
Arsenic
1303328
Arsenic disulfide
1303282
Arsenic pentoxide
7784341
Arsenic trichloride
1327533
Arsenic trioxide
1303339
1
Arsenic trisulfide
1332-21-4
Asbestos (friable)
542621
Barium cyanide
71-43-2
Benzene
92-87-5
Benzidine
100470
Benzonitrile
218019
Benzo(a)phenanthrene
December 1996
4-D1
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
50328
Benzo(a)pvrene
205992
Benzo(b)fluoranthene
205823
Benzo(j)fluoranthene
207089
Benzo(k)fluoranthene
189559
Benzo(rst)pentaphene
56553
Benzo(a)anthracene
100-44-7
Benzyl chloride
7440-41-7
Beryllium
7787475
Beryllium chloride
7787497
Beryllium fluoride
7787555
Beryllium nitrate'
111-44-4
Bis(2-chloroethvl) ether
75-25-2
Bromoform
74-83-9
Bromomethane (Methyl bromide)
85-68-7
Butyl benzyl phthalate
7440-43-9
Cadmium
543908
Cadmium acetate
7789426
Cadmium bromide
10108642
Cadmium chloride
7778441
Calcium arsenate
52740166
Calcium arsenite
13765190
Calcium chromate
592018
Calcium cyanide
133-06-2
Captan [lH-Isoindole-l,3(2H)-dione,3a,4,7,7a-tetrahydro-2-[(trichloromethyl)thio]-]
63-25-2
Carbaryl [ l-Naphthalenol, methylcarbamate]
75-15-0
Carbon disulfide
1563662
Carboharan
56-23-5
Carbon tetrachloride
December 1996
4-D2
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
57-74-9
Chlordane [4,7-Methanoindan, 1,2,4,5,6,7,8,8- octachJoro-2,3,3a,4,7,7a-hexahydro-]
7782-50-5
Chlorine
59-50-7
4-Chloro 3-methvl phenol p-Chloro-rjl-cresol
108-90-7
Chlorobenzene
75-00-3
Chloroethane (Ethyl chloride)
67-66-3
Chloroform
74-87-3
Chloromethane (Methyl chloride)
95-57-8
2-Chlorophenol
106-48-9
4-Chlorophenol
75729
ChJorotrifluoromethane
1066304
Chromic acetate
11115745
Chromic acid
10101538
Chromic sulfate
7440-47-3
Chromium
1308-14-1
Chromium (Tri)
10049055
Chromous chloride
7789437
Cobaitous bromide
544183
Cobaltous formate
14017415
Cobaitous sulfamate
7440-50-8
Copper
106-39-4
m-Cresoi
9548-7
2-Cresol
106-44-5
p-Cresol
4170303
Crotonaldehvde
1319-77-3
Cresol (mixed isomers)
142712
Cupric acetate
12002038
Cupric acetoarsenite
7447394
Cupric chloride
December 1996
4-03
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
3251238
Cupric nitrate
5893663
Cupric oxalate
7758987
Cupric sulfate
10380297
Cupric sulfate, ammoniated
815827
Cupric tartrate
57-12-5
Cyanide
506774
Cyanogen chloride
333415
Diazinon
94-75-7
2,4-D [Acetic acid, (2,4-dichlorophenoxy)-]
226368
Dibenz(a,h)acridine
224420
Dibenz(a,j)acridene
538575
Dibenzo(a,e)fluoranthene
192654
Dibenzo(a,e)pyrene
53703
Dibenzo(a,h)anthracene
189640
Dibenzo(a,l)pvrene
191300
Dibenzo(a,h)p\Tene
194592
7, H"-Dibenzo(c,g)carbazole
106-93-4
1,2-Dibromoethane (Ethylene dibromide)
84-74-2
Dibutyl phthalate
1929733
2,4 D Butoxyethyl ester
94804
2,4 D Butyl ester
2971382
2,4 D Chlorocrotvl ester
1918009
Dicamba
95-50-1
1,2-Dichlorobenzene
541-73-1
1,3-Dichlorobenzene
¦
106-46-7
1,4-Dichlorobenzene
91-94-1
3,3'-Dichlorobenzidine
75-27-4
Dichlorobroniomethane
December 1996
4-04
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
107-06-2
1,2-Dichloroethane (Ethylene dichloride)
75434
Dichlorofluoromethane
540-59-0
1,2-Dichloroethvlene
120-83-2
2,4-Dichlorophenol
78-87-5
1,2-Dichloropropane
10061026
trans-1,3-Dichioropropene
542-75-6
1,3-Dichloropropvlene
62-73-7
Dichlorvos [Phosphoric acid, 2,2-dichioroethenyJ dimethyl ester]
115-32-2
Dicofol [Benzenemethanol, 4-chloro-.aJpha.-(4-chlorophenyl)-.alpha.-(trichloromethyl)-]
177-81-7
Di-(2-ethvlhexvl) phthalate (DEHP)
84-66-2
Diethyl phthalate
124403
Dimethvlamine
57976
7,12-Dimethylbenz(a)anthracene
105-67-9
2,4-Dimethylphenol
131-11-3
Dimethyl phthalate
534-52-1
4,6-Dinitro-Q-cresol
51-28-5
2,4-Dinitrophenol
121-14-2
2,4-Dinitrotoluene
606-20-2
2,6-Dinitrotolaene
117-84-0
n-Dioctyl phthalate
122-66-7
1,2-Diphenylhvdrazine (Hydrazobenzene)
94,111
2,4-D Isopropvl ester
106-89-8
Epichlorohydrin
1320189
2.4-D Propylene glycol butyl ether ester
330541
Diuron
100-41-4
Ethylbenzene
106934
Ethylene dibromide
50-00-0
Formaldehyde
December 1996
4-D5
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
76-44-8
Heptachlor [ 1,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-tetrahydro-4,7-methano-1 H-indene]
118-74-1
Hexachlorobenzene
319846
alpha-Hexachlorocyclohexane
87-68-3
Hexachloro-1,3-butadiene
77-47-4
Hexachlorocyclopentadiene
67-72-1
Hexachloroe thane
7647-01-0
Hydrochloric acid
74-90-8
Hydrogen cyanide
7664-39-3
Hydrogen fluoride
193395
Indeno[ 1,2,3-cd]pyrene
7439-92-1
Lead
301042
Lead acetate
7784409
Lead arsenate
7645252
U l»
10102484
a *»
7758954
Lead chloride
13814965
Lead fluoborate
7783462
Lead fluoride
10101630
Lead iodide
10099748
Lead nitrate
7428480
Lead stearate
1072351
-
52652592
-
7446142
Lead sulfate
1314870
Lead suJfide
592870
Lead thiocyanate
58-89-9
Lindane [Cyclohexane, 1,2,3,4,5,6-hexachloro-( 1.alpha.,3-beta.,4.alpha.,5.alpha.,6.beta.)-]
14307258
Lithium chromate
December 1996
4-06
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
121755
Malathion
108-31-6
Maleic anhydride
592041
Mercuric cyanide
10045940
Mercuric nitrate
7783359
Mercuric sulfate
592858
Mercuric thiocyanate
7782867
Mercurous nitrate
7439-97-6
Mercury
72-43-5
Methoxychlor [Benzene, l,r-(2,2,2-trichIoroethylidene)bis[4-methoxy-]
80-62-6
Methyl methacrylate
75865
2-Methyllactonitrile
3697243
5-Methylchrysene
298000
Methyl parathion
7786347
Mevinphos
300765
Naled
9! -20-3
Naphthalene
7440-02-0
Nickel
15699180
Nickel ammonium sulfate
37211055
Nickel chloride
7718549
» "
12054487
Nickel hydroxide
14216752
Nickel nitrate
7786814
Nickel sulfate
7697-37-2
Nitric acid
98-95-3
Nitrobenzene
88-75-5
2-Nitrophenol
100-02-7
4-Nitrophenol
5522430
1-Nitropvrene
December 1996
4-D7
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
62-75-9
N-Nitrosodimethvlamine
86-30-6
N-Nitrosodiphenvlamine
621-64-7
N-Nitrosodi-n-propylamine
56-38-2
Parathion [Phosphorothioic acid, 0,0-diethyl-0-(4-nitrophenyl) ester]
87-86-5
PentachJorophenol (PCP)
85018
Phenanthrene
108-95-2
Phenol
7664-38-2
Phosphoric acid
7723-14-0
Phosphorus (yellow or white)
1336-36-3
Polychlorinated biphenyls (PCBs)
7784410
Potassium arsenate
10124502
Potassium arsenite
7778509
Potassium bichromate
7789006
Potassium chromate
151508
Potassium cyanide
2312353
Propargite
75-56-9
Propylene oxide
91-22-5
Qui noli ne
7782-49-2
Selenium
7446084
Selenium oxide
7440-22-4
Silver
7761888
Silver nitrate
7631892
Sodium arsenate
7784465
Sodium arsenite
10588019
Sodium bichromate
7775113
Sodium chromate
143339
Sodium cvanide
7632000
Sodium nitrite
December 1996
4-08
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
10102188
Sodium selenite
7782823
7789062
Strontium chromate
NA
Strychnine &. salts
100-42-5
Styrene
7664-93-9
Sulfuric acid
79-34-5
1,1,2,2-TetrachIoroethane
127-18-4
Tetrachloroethylene (Perchloroethvlene)
935-95-5
2,3,5,6-Tetrachlorophenol
78002
Tetraethyl lead
7440-28-0
Thallium
10031591
Thallium sulfate
108-88-3
Toluene
8001-35-2
Toxaphene
52-68-6
Trichlorfon [Phosphonic acid, (2,2,2-trichJoro-l-hydroxyethyI)-dimethylester]
120-82-1
1,2,4-TrichJorobenzene
71-55-6
1,1,1 -Trichloroethane (Methyl chloroform)
79-00-5
1,1,2-Trichloroe thane
79-01-6
T richloroethylene
95-95-4
2,4,5-Trichlorophenol
88-06-2
2,4,6-Trichlorophenol
121448
Triethvlamine
7440-62-2
Vanadium (fume or dust)
108-05-4
Vinyl acetate
75-01-4
Vinyl chloride
75-35-4
Vinylidene chloride
108-38-3
m-Xvlene
95-47-6
Q-Xvlene
December 1996
4-09
-------
Storm Water Discharges and Oil Spill Prevention
Part I, Chapter 4
Section 313 Water Priority Chemicals (Alphabetically)
106-42-3
g-Xylene
1330-20-7
Xylene (mixed isomers)
7440-66-6
Zinc (fume or dust)
557346
Zinc acetate
14639975
Zinc ammonium chloride
14639986
m n u
52628258
una
1332076
Zinc borate
7699458
Zinc bromide
3486359
Zinc carbonate
7646857
Zinc chloride
557211
Zinc cyanide
7783495
Zinc fluoride
557415
Zinc formate
7779864
Zinc hydrosulfite
7779886
Zinc nitrate
127822
Zinc phenolsulfonate
1314847
Zinc phosphide
16871719
Zinc silicofluoride
7733020
Zinc sulfate
December 1996
4-D10
-------
December 1996 4-D11
-------
Notes
5
-------
CHAPTER 5
Hazardous Waste
5.1 Federal Requirements (RCRA) 5-4
5.1:1 What Is RCRA? 5-4
5.1.2 How Do These Rules Apply To Me? 5-4
5.1.3 How Do I Determine if My Waste Is Hazardous? 5-6
5.1.4 How Should I Store Hazardous Waste? 5-11
5.1.5 How Should I Prevent and Respond to Hazardous Waste Emergencies? 5-19
5.1.6 How Should I Transport Hazardous Waste? 5-26
5.1.7 What Records Do I Need To Keep? 5-32
5.1.8 Closure Requirements (Applicable to LQGs Only) 5-34
5.2 State Requirements 5-35
5.3 Where To Go for More Information 5-36
The generation, storage, treatment, and disposal of hazardous waste is strictly regulated
at the federal, regional, state, and local levels. Nearly all metal finishing facilities are
subject to this regulation because they typically use hazardous chemicals, which become
hazardous waste after use. Spent plating baths laden with heavy metals salts and cyanides,
for example, are considered hazardous waste.
The federal government regulates companies that generate hazardous waste under the
Resource Conservation and Recovery Act (RCRA). In general, RCRA's requirements for
hazardous waste can be divided into three categories:
¦ Recordkeeping and notification requirements. Many regulations require you to
maintain and furnish detailed records about your hazardous waste.
¦ Onsite storage standards. Other regulations require you to take specific actions to
minimize the chance of hazardous waste accidents and to minimize damage
should those accidents occur.
¦ Disposal standards. These standards specify how you may dispose of hazardous
waste.
Remember that federal regulations represent the minimum standards for environmental
compliance. Depending on where you are located, you might be subject to additional
regional, state, and local regulations. To make sure that your facility is fully compliant
with all environmental regulations, you will need to consult with state and local
authorities. (Refer to Section 5.2.). This chapter contains information and tools to help
you answer two important questions:
¦ Do I generate hazardous waste?
¦ What rules do I have to follow if I generate hazardous waste?
It is important to follow these rules because they constitute official standards for the
safe handling of hazardous waste. If you don't follow them, you may run unacceptable
accident risks and expose your company to severe fines.
December 1996
5-1
-------
Hazardous Waste
Part I, Chapter 5
Table of Contents Page
5.1 Federal Requirements (RCRA) 5-4
5.1.1 What Is RCRA? 5-4
5.1.2 How Do These Rules Apply To Me? 5-4
5.1.2.1 What Other Classifications Might Apply to Me? 5-5
5.1.2.2 What Other Exemptions Might Apply to Me? 5-6
5.1.3 How Do I Determine if My Waste Is Hazardous? 5-6
5.1.3.1 What Are "Listed" Wastes and Hazard Codes? 5-8
5.1.3.2 How Do I Manage Mixtures and Spills if Hazardous Waste? 5-9
5.1.3.3 What Must 1 Do if I Generate Hazardous Waste? 5-10
5.1.4 How Should I Store Hazardous Waste? 5-11
5.1.4.1 Note to CESQGs 5-11
5.1.4.2 Hazardous Waste Accumulation at a Point of Generation (Applicable to SQGs and LQGs)5-l 1
5.1.4.3 Onsite Container Storage of Hazardous Waste (Applicable to SQGs and LQGs) 5-12
5.1.4.4 Onsite Tank Storage of Hazardous Waste (Applicable to SQGs and LQGs) 5-13
5.1.4.5 Onsite Tank Storage of Hazardous Waste (Applicable to SQGs Only) 5-14
5.1.4.6 Onsite Tank Storage of Hazardous Waste (Applicable to LQGs Only) 5-15
5.1.5 How Should I Prevent and Respond to Hazardous Waste Emergencies? 5-19
5.1.5.1 Note to CESQGs 5-19
5.1.5.2 Preparedness Regulations Applicable to Both SQGs and LQGs 5-19
5.1.5.3 Preparedness Regulations Applicable to SQGs Only 5-21
5.1.5.4 Preparedness Regulations Applicable to LQGs Only 5-22
5.1.6 How Should I Transport Hazardous Waste? 5-26
5.1.6.1 Note to CESQGs 5-26
5.1.6.2 Requirements Applicable to Both SQGs and LQGs 5-27
5.1.6.3 Requirements Applicable to SQGs Only 5-31
5.1.7 What Records Do I Need To Keep? 5-32
5.1.7.1 Note to CESQGs 5-32
5.1.7.2 Requirements Applicable to Both LQGs and SQGs 5-32
5.1.7.3 Requirements Applicable to SQGs Only 5-33
5.1.7.4 Requirei :nts Applicable to LQGs Only 5-33
5.1.8 Closure Requirements (Applicable to LQGs Only) 5-34
5.2 State Requirements 5-35
5.3 Where To Go for More Information 5-36
Appendix 5-A Compliance Calendar for RCRA Hazardous Waste Requirements
Appendix 5-B Glossary of Terms
Appendix 5-C Hazardous Waste Identification Procedures
Appendix 5-D Listed Hazardous Wastes
Appendix 5-E Regulatory Levels for Toxicity Characteristic Leaching Procedure
Appendix 5-F Requirements Related to Wastes Containing Economically Recoverable
Quantities of Precious Metals
Appendix 5-G Criteria Used To Consider a Container Empty
Appendix 5-H Toxicity Characteristic Leaching Procedure
Appendix 5-1 Overview of the RCRA Permit Program
Appendix 5-J EPA RCRA Contact List
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Hazardous Waste: How To Comply
~ Determine whether you generate hazardous wastes:
— Determine which of your wastes are considered hazardous under the Resource
Conservation and Recovery Act (RCRA).
— Assign each hazardous waste one or more EPA hazardous waste codes.
— Classify your facility as a Conditionally Exempt Small Quantity Generator
(CESQG), Small Quantity Generator (SQG), Large Quantity Generator (LQG),
or Treatment, Storage, and Disposal (TSD) facility. This classification affects
the degree to which your facility will be subject to the requirements in this
chapter.
~ Avoid speculative accumulation (accumulating hazardous waste with no intent
to recycle or dispose of it).
~ Clearly label all hazardous waste containers.
~ Inspect hazardous waste containers regularly and keep them in good repair.
~ Ensure that the waste does not mix with incompatible substances.
~ Monitor all hazardous waste tanks frequently to check for leaks.
~ Prepare for unexpected waste releases and other waste-related emergencies:
— Develop a contingency plan to respond to emergencies.
— Keep local authorities informed about the nature of the waste you generate.
— Assign an employee to be an emergency coordinator.
— Maintain adequate safety equipment.
— Provide adequate safety training for all employees that work with hazardous
waste. Document this program carefully.
~ When you arrange to have your hazardous waste transported, use a hazardous
waste manifest and comply with all Department of Transportation requirements
for transporting hazardous materials.
~ Keep careful records of all activities related to your hazardous waste and report
to local environmental authorities as explained in this chapter.
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5.1 Federal Requirements (RCRA)
5.1.1 What Is RCRA?
In 1976, Congress passed the Resource Conservation and Recovery
Act (RCRA), which directed the U.S. Environmental Protection
Agency (EPA) to regulate the management of hazardous and
nonhazardous solid waste in the United States.
Subtitle C of RCRA contains requirements that apply to anyone
who generates hazardous waste. Because metal finishing processes
typically involve hazardous substances such as organic solvents,
acids, and heavy metals salts, you will need to follow these rules.
Under RCRA, you are required to determine which of your waste
products are considered hazardous. If you generate any hazardous
waste, you must classify the wastes according to RCRA
specifications, measure the rates at which they are generated, and
monitor their total onsite accumulation.
5.1.2 How Do These Rules Apply to Me?
The specific RCRA regulations that apply to you depend on how
much waste you generate, what kind of waste it is, and how long
you accumulate it onsite. Use Box 5-1 below to determine what
type of hazardous waste generator you are; you should classify
yourself in the first category that matches your waste
generation profile. Section 5.1.3 below explains how to determine
whether your waste is hazardous or acutely hazardous. If you
encounter unfamiliar terms, see Appendix 5-B for definitions.
Because classifications may change month-to-month, make sure you
consult the most recent version of the classification. As a general
rule, the less hazardous waste you generate, the fewer Subtitle C
regulations apply to you. This chapter assumes that you are a
CESQG, SQG, or LQG and describes what regulations apply to you.
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Box 5-1 RCRA Classification of Hazardous Waste Generators
If you generate...
And you
accumulate...
And you hold extra
waste for...
You are a....
Less than 100
kg/month of
hazardous waste and
less than 1 kg/month
of acutely hazardous
waste
Less than 1,000 kg of
hazardous waste and
less than 1 kg of
acutely hazardous
waste at any one
time
Any period
Conditionally
Exempt Small
Quantitv Generator
(CESQG)
Less than 1,000
kg/month of
hazardous waste and
less than 1 kg/month
of acutely hazardous
waste
Less than 6,000 kg of
hazardous waste and
less than 1 kg of
acutely hazardous
waste at any one
time
Less than 180 days
or less than 270 days
if waste is shipped
more than 200 miles
Small Quantity
Generator (SQG)
More than 1,000
kg/month of
hazardous waste or
more than 1
kg^month of acutely
hazardous waste
Any amount of
hazardous waste
Less than 90 days or
less than any
extended period
individually
authorized by EPA
Large Quantity
Generator (LQG)
5.1.2.1 What Other Classifications Might Apply to Me?
To avoid being additionally classified as a hazardous waste storage
facility:
¦ Do not accumulate hazardous waste for more than 90 days
without obtaining an EPA extension.
¦ If you are an SQG, do not exceed the 6,000-kg or the
180/270-day limit.
Storage facilities are subject to additional extensive RCRA
requirements that are not covered in this chapter. They are fully
subject to Title 40 of the Code of Federal Regulations (CFR), Part
264, once EPA permitted, and fully subject to 40 CFR Part 265 in
the interim.
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Your facility might also be classified as an onsite disposal facility if
it previously used wastewater settling ponds or sludge dewatering
lagoons. Like storage facilities, onsite disposal facilities are subject
to the full requirements of 40 CFR Part 264 or Part 265. Call the
RCRA Hotline (1-800-535-0202) if you have questions about how
to classify your facility or what requirements apply to you.
5.1.2.2 What Other Exemptions Might Apply to Me?
Wastewater treatment systems permitted to operate under the Clean
Water Act (CWA)—that is, those permitted by either the National
Pollutant Discharge Elimination System (NPDES) or the state or
local sewer authority—are exempt from RCRA requirements for
hazardous waste treatment, storage, and disposal (TSD) units (see
Appendix 5-1). (This exemption is commonly referred to as the
Permit By Rule.) The exemption generally applies to permanent
hard-piped portions of a permitted wastewater treatment system,
which includes tanks, sumps, trenches, pipes, metal recovery
systems, and sludge dewatering equipment that are included in the
initial wastewater permit applications or the final permit.
Wastewater collected in a container and immediately transferred to
a permitted wastewater treatment system for treatment is also
subject to exemption.
Although you are encouraged to adopt pollution prevention
strategies as much as possible, switching from your permitted
treatment system to a zero discharge system can void your
exemption from RCRA TSD requirements. Box 5-2 below explains
this issue in more detail.
5.1.3 How Do I Determine if My Waste Is Hazardous?
Subtitle C of RCRA specifies numerous definitions and rules for
classifying wastes. You can determine whether your waste is
considered hazardous under Subtitle C by:
¦ Determining whether the waste is a RCRA solid waste.
¦ If the waste is a RCRA solid waste, determining whether the
waste is exempt from classification as a hazardous waste.
¦ If the waste is not exempt, determining whether the waste is
an EPA listed waste.
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¦ If the waste is not exempt, determining whether the waste
exhibits hazardous characteristics.
Box 5-2 Zero Discharge Systems and RCRA
A zero discharge system is a pollution prevention method that uses rinsing modifications,
drag-out recovery, and wastewater treatment to allow a plating shop to recover valuable
metals and reuse nearly 100 percent of its water. Although they are called zero discharge
systems, only wastewater is totally recovered and reused; air emissions (mostly water vapor)
and solid wastes (e.g., spent filters, ion exchange resins, cathodes) are generated.
A plater who treats metal-containing wastewaters is normally exempt from all RCRA Subtitle
C requirements that apply to hazardous waste TSD facilities as long as you have a permit or
Control Authority agreement specifying the quality of wastewater you must achieve prior to
discharge (see Sections 3.1.1 and 3.1.6 for more information). A problem can arise when
you switch to zero discharge and then try to retire your permit or Control Authority
agreement because you have no wastewater discharge. Some state agencies interpret the
switch as voiding the CWA exemption, thus opening the door to considering your facility a
RCRA TSD facility. A TSD facility needs a Part B permit to operate, and such permits are
very expensive (see Appendix 5-1). Operating without either a Part B permit or a valid
discharge permit leaves you open to enforcement actions.
Some states and POTWs issue "zero discharge permits." Essentially, these recognize the fact
that no wastewater effluent is being discharged; for oversight purposes only, the permits
extend the CWA exemption to your zero discharge facility. Such permits may have reduced
fees and little reporting or recordkeeping requirements. They may require that your system
be certified by a registered professional engineer, however, which can cost several thousand
dollars. North Carolina is one state that offers engineer-certified zero discharge permits.
The Greater Lawrence Sanitary District in Lawrence, Massachusetts, is a POTW that offers
zero discharge permits to its users. Case studies of facilities with zero discharge systems can
be found in Appendix 3-1 of Chapter 3.
A series of flow charts and tables are presented in Appendices 5-C
and 5-D, respectively, that you can use to help determine whether
your waste is hazardous. Although they are simplified somewhat,
they can be used to make preliminary determinations. If this flow
chart directs you to assign even a single hazardous waste
number to your waste, the waste is hazardous.
For definitive determinations, you should consult a specialist or the
regulation itself (40 CFR Part 261). You can also contact the
RCRA Hotline (1-800-534-0202) for answers to specific questions.
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5.1.3.1 What Are "Listed" Wastes and Hazard Codes?
Part of RCRA (40 CFR 261.31) identifies a number of wastes as
"listed" wastes, so called because they are listed by name or category
in the regulation. For these wastes, EPA applies one or more of the
following hazard codes to identify the characteristic(s) that make
the waste hazardous:
¦ Ignitable Waste (I)
¦ Corrosive Waste (C )
¦ Reactive Waste (R)
¦ Toxicity Characteristic Waste (E)
¦ Acutely Hazardous Waste (H)
¦ Toxic Waste (T)
Several wastes from metal finishing processes are classified as listed
wastes and are considered hazardous. Use the hazardous waste
identification procedures provided in Appendix 5-C to determine
whether your wastes are listed and use the tables in Appendix 5-D
to determine what code(s) you should assign to them. Even if your
wastes are not listed, they might be considered hazardous. Be sure
to follow the full identification procedure to determine how to
classify your wastes. Four examples are shown in Box 5-3 below.
Box 5-3 Listed Hazardous Wastes Generated in Metal Finishing Operations
EPA Hazardous
Waste No.
Hazardous waste
Hazard
Code
F006
Wastewater treatment sludges from electroplating operations except from
the following processes: 1) Sulfuric acid anodizing of aluminum; 2) tin
plating on carbon steel; 3) zinc plating (segregated basis) on carbon steel;
4) aluminum or zinc-aluminum plating on carbon steel; 5)
cleaning/stripping associated with tin, zinc, and aluminum plating on
carbon steel; and 6) chemical etching and milling of aluminum.
(T)
F007
Spent cyanide plating bath solutions from electroplating operations.
(R, T)
F008
Plating bath residues from the bottom of plating baths from
electroplating operations involving cyanides.
(R, T)
F009
Spent stripping and cleaning bath solutions from electroplating
operations involving cyanides.
(R. T)
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Some Tips on Waste Identification
¦ F006 sludges are not produced by zinc plating on carbon
steel. Zinc cyanide processes, however, do generate F006
wastes.
¦ Sludges from pickling processes are not considered hazardous
waste.
¦ Containers used to store acutely hazardous wastes such as
sodium or potassium cyanide are themselves considered a
hazardous waste. These containers can only be made non-
hazardous by triple rinsing them to remove all residues.
Example: Classification of Metal Finishing Wastes
For purposes of illustration, Box 5-4 contains examples of how
several metal finishing wastes would be categorized under Subtitle
C.
5.1.3.2 How Do I Manage Mixtures and Spills of
Hazardous Waste?
¦ If you mix a hazardous waste with a nonhazardous waste, the
resultant mixture material must be identified as a hazardous
waste. This is called the mixture rule (40 CFR 261.3(a)(2)).
¦ If a hazardous waste is spilled into an environmental media,
the recovered chemical and contaminated media must be
managed and disposed of as a hazardous waste. This is called
the container-in policy, which has not been codified and not
referred to in the 40 CFR 261 regulations.
An exception to these rules is the mixtures of nonhazardous
materials with hazardous waste that are listed solely because they
exhibit the characteristics for which they were originally classified.
¦ If you generate waste from the treatment, storage, or disposal
of a hazardous waste, you must manage this material (e.g.,
sludge, spill residue, ash emission control dust, or leachate) as
a hazardous waste. This is known as the derived from rule
(40 CFR 261(c)).
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5.1.3.3 What Must I Do if I Generate Hazardous Wastes?
If you determine that you generate hazardous wastes, you must:
¦ Classify each waste by assigning it one or more EPA
hazardous waste codes (use the flow charts and tables in
Appendices 5-C and 5-D, respectively, and see the examples
in Box 5-4 above).
¦ Classify your facility as a CESQG, SQG, LQG, or Treatment,
Storage, and Disposal (TSD) facility (see Section 5.1.2
above).
¦ Avoid speculative accumulation (see below).
¦ Depending on what type of facility you have, comply with
RCRA's storage, emergency preparedness and response,
transportation, recordkeeping, and closure requirements (see
Sections 5.1.4 through 5.1.8 below).
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¦ If you generate wastes containing economically recoverable
quantities of precious metals (gold, silver, platinum,
palladium, iridium, osmium, rhodium, ruthenium, or any
combination of these), follow the notification and
recordkeeping requirements outlined in 40 CFR 266.70 (see
Appendix 5-D).
Speculative accumulation is accumulating hazardous waste with
either no intent to recycle it or holding it too long. To avoid
speculative accumulation of a waste, you must demonstrate that the
waste is potentially recyclable, a feasible means for recycling the
waste exists, and at least 75 percent of the material accumulated
over the calendar year has been recycled on- or offsite.
5.1.4 How Should I Store Hazardous Waste?
5.1.4.1 Note to CESQGs
You are not subject to RCRA regulations involving the storage of
hazardous wastes. Federal regulations may be helpful, however, as
guidelines for the responsible management of hazardous waste.
5.1.4.2 Hazardous Waste Accumulation at a Point of
Generation (Applicable to SQGs and LQGs)
You may accumulate as much as 55 gallons of hazardous waste or
1 quart of acutely hazardous waste in containers at or near any
point of generation (a work station), so long as the containers are:
¦ Compatible with their contents and incompatibles are
segregated.
¦ Kept in good repair.
¦ Kept closed, except when adding waste.
¦ Clearly marked with the words "hazardous waste" or with
other words identifying the contents of the containers.
For all other waste stored at your facility, you must comply with the
full regulations for onsite storage of hazardous waste (described
below).
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5.1.4.3 Onsite Container Storage of Hazardous Waste
(Applicable to SQGs and LQGs)
This section deals with hazardous waste that you store in a container,
defined as a portable device in which a material is stored. Examples
of containers are 55-gallon drums, roll-offs, and portable tanks or
totes. If you store hazardous waste in containers, you must comply
with the requirements described below regardless of whether you are
an LQG or SQG.
When storing hazardous wastes in containers, you must ensure that
the containers are:
¦ In good condition.
¦ Manufactured out of a compatible substance (i.e., one that
does not react with the waste).
¦ Stored in an area providing sufficient aisle space.
¦ Closed during storage, except when waste is added or
removed.
¦ Not handled in any way that might rupture them.
¦ Located at least 50 feet within your facility's property line (if
the containers are hold :ng ignitable or restrictive wastes and
you are an LQG).
¦ Palletized containers and stacked no more than two
containers high. (Higher is permitted for racked containers.)
¦ Stored in rows with sufficient aisle space for a person to walk
between (usually no less than 24").
¦ Clearly marked with visible labels containing the words
"hazardous waste" and the date on which the current period
of waste accumulation began. (This date is important for
determining how long particular wastes have been stored
onsite.)
¦ Free of incompatible mixtures of hazardous substances.
Regarding the last point, you must avoid placing hazardous waste in
a container holding other, incompatible substances or in unwashed
containers that previously contained incompatible substances. If
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you place a storage container holding hazardous waste close to an
incompatible substance, you must isolate it by means of a disk,
berm, wall, or other device.
An example of incompatible storage would be to place a container
of waste cyanide-bearing liquid or solid and a container of spent
acids in the same containment area. Combining these two materials
can produce hydrogen cyanide gas, which is very poisonous. Other
potentially incompatible wastes generated in the metal finishing
industry are acids (spent sulfuric or nitric) and bases (sodium
hydroxide).
At least once a week, you must inspect the areas where hazardous
wastes are stored. You must develop a written inspection schedule
detailing inspection frequency, method, and areas. Document your
inspections in a log that includes the date and time of the
inspection, the areas inspected, and any corrective actions taken. If
you find that a container has begun to leak, you must transfer the
contained hazardous wastes to an intact container, or otherwise
manage them in compliance with RCRA storage regulations and
note corrective actions in the log.
5.1.4.4 Onsite Tank Storage of Hazardous Waste
(Applicable to SQGs and LQGs)
This section deals with hazardous waste to be stored in tanks—
defined as devices designed to contain an accumulation of waste and
constructed primarily of nonearthen materials that provide
structural support. If you store an ignitable or reactive waste in a
tank, you must manage the waste so that it does not:
¦ Generate extreme heat or pressure.
¦ Explode or undergo violent reactions.
¦ Produce uncontrolled toxic mists, fumes, dusts, or gases in
sufficient quantities to threaten human health.
¦ Produce uncontrolled flammable fumes or gases in sufficient
quantities to pose a risk of fire or explosions.
¦ Damage the structural integrity of the tank.
¦ Endanger human health or the environment through any like
means.
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To meet these standards, you must take one or more of the
following approaches:
¦ Manage waste before or immediately after you placed it in a
tank so that the resultant mixture will no longer be
sufficiently ignitable or reactive to pose a hazard to human
health or the environment.
¦ Store or handle waste in such a way that it is protected from
any material or conditions that might cause it to ignite or
react.
¦ Designate the tanks as suitable only for use in emergencies.
You must also avoid mixing incompatible substances (see safety
guidelines discussed in Section 5.1.4.3).
Finally, if you store ignitable or reactive waste in covered tanks, you
must comply with the buffer zone requirements for tanks described
in the National Fire Protection Association's Flammable and.
Combustible Liquids Code (Item PC-30-93).
5.1.4.5 Onsite Tank Storage of Hazardous Waste
(Applicable to SQC s Only )
Leak and Overflow Protection
You may not store a hazardous waste in a tank if that waste could
cause the tank or its inner liner to rupture, leak, corrode, or
otherwise fail before the end of its intended life. If the tank is
uncovered, you must ensure that at least 2 feet of empty space
remains between the waste level and the top of the tank, unless the
tank is equipped with an external containment structure with a
volume capacity exceeding that of the top 2 feet of the tank. If
hazardous waste is continuously fed into a tank, the tank must be
equipped with a means of stopping this inflow, such as a waste feed
cutoff or a bypass system to a standby tank.
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Inspection Requirements
You must check the following (if present) at least daily:
¦ Discharge control equipment, such as waste feed cutoff
systems and bypass systems, to determine whether the
equipment is in good working order.
¦ Data gathered from monitoring equipment, such as
temperature and pressure gauges, to determine whether the
tank is being operated according to its design.
¦ The level of waste in the tank to determine whether the tank
is becoming too full.
You must also check the following at least once a week:
¦ The construction materials of the tank to determine whether
the tank is corroding or leaking at its fixtures or seams.
¦ The construction materials of and the area immediately
surrounding discharge confine structures (e.g., dikes) to
identify any erosion or obvious signs of leakage (e.g., wet
spots or dead vegetation).
Closure Requirements
Upon closure of your facility, you must remove all hazardous waste
from tanks, discharge control equipment, and discharge confinement
structures.
5.1.4.6 Onsite Tank Storage of Hazardous Waste
(Applicable to LQGs Only)
Assessment and Installation of Tank Systems
If you own or operate tank systems or components, you must ensure
that the foundation, structural support, seams, connections, and
pressure controls (if applicable) are adequately designed and that the
tank system has sufficient structural strength, compatibility with the
wastes to be stored, and corrosion protection so that it will not
collapse, rupture, or fail. You must obtain and keep on file a written
assessment, reviewed and certified by a qualified and independent
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engineer, that attests to the tank system's integrity and indicates
that it is acceptable for the storage of hazardous waste. As noted
earlier, these requirements do not apply to tanks that are part of a
permitted wastewater treatment system.
If you own or operate a new tank system, you must also ensure that
it is installed properly. Before covering, enclosing, or placing a new
tank system or component in use, a qualified independent engineer
must inspect the system for structural damage or inadequate
construction or installation. All problems must be remedied before
the tank system is covered, enclosed, or placed in use. You must
ensure that all tank fittings are sufficiently tight, that appropriate
corrosion resistance measures are in place, and that (for
underground tanks) the tank is buried with appropriate backfill.
These requirements are described in greater detail in 40 CFR
265.192.
Secondary Containment Systems
With some possible exceptions (see 40 CFR 265.193), all tanks
used to store hazardous wastes must have secondary containment
systems designed to prevent the migration of wastes out of the
system to the soil or ground water. These systems must be able to
detect and collect releases from the tank until the collected material
can be removed. Examples of secondary containment systems
include an external liner, a vault, and a double-walled tank. You can
find detailed specifications for such systems in 40 CFR 265.193
(c-g).
General Operating Requirements
Hazardous wastes must not be placed in a tank system if they could
cause the tank, its ancillary equipment, or the secondary
containment system to leak or otherwise fail. You must use
appropriate controls and practices to prevent spills and overflows
from tank systems. Such measures must at least include spill
prevention controls (e.g., check valves), overfill prevention controls
(e.g., high level alarms), and adequate maintenance.
You must inspect and document the following (where present) at
least once a day:
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¦ The tank's overfill/spill control equipment (e.g., waste-feed
cutoff and bypass systems).
¦ The aboveground portions of the tank system, if any, to
detect corrosion or releases of waste.
¦ Data gathered from monitoring equipment and leak-
detection equipment to ensure that the tank system is being
operated according to its design.
¦ Construction materials and the area immediately surrounding
the externally accessible portion of the tank system to detect
erosion or signs of release of hazardous waste (e.g., wet spots
or dead vegetation).
If the tank has cathodic protection systems, they must be inspected
annually, beginning 6 months after the tank's initial installation.
Response to Leaks, Spills, and Unfit Tanks
A tank system or secondary containment system from which
material has leaked or spilled, or which is unfit for use, must be
removed from service immediately. You must:
¦ Immediately stop the flow of hazardous waste into the tank
system or secondary containment system and inspect the
system to determine the cause of the release.
¦ Remove all hazardous waste from the tank or secondary
containment system within 24 hours or in as timely a manner
as possible if removal cannot be accomplished in 24 hours.
¦ Prevent visible contaminants from making any further
migration to soils or surface water, then remove and properly
dispose of these contaminants.
¦ Report to the EPA regional administrator any release of
hazardous waste to the environment that involves more than
a pound of material or is not immediately contained and
cleaned up. Your report must be submitted within 30 days
and must indicate:
— The likely route of migration of the release.
— The characteristics of the surrounding soil (e.g., soil
composition, geology, hydrogeology, climate).
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— The results of any monitoring or sampling conducted in
connection with the release. (If sampling or monitoring
data relating to the release are not available within 30
days, you must submit them to the regional administrator
as soon as possible.)
— The spill's proximity to downgradient drinking water,
surface water, and population areas.
— Response actions taken or planned.
Once you close a tank or secondary containment system, you may
not reopen it until all necessary repairs have been completed and (if
repairs were necessary) a qualified independent engineer recertifies
the tank or containment system. This certification must state that
the repaired system is capable of handling hazardous waste without
release for its intended life. Finally, if the source of the release was
an underground tank without secondary containment, you must
provide secondary containment before reopening the tank. This
requirement is waived if the source of the leak was an aboveground
portion of the underground storage tank.
Closure and Postclosure Care
On final closure of a tank system, you must remove or
decontaminate all waste residues, contaminated containment system
components, contaminated soils, and structures and equipment
contaminated with waste and manage them as hazardous waste, if
necessary.
If you can demonstrate that not all contaminated soils can be
practicably removed or decontaminated as required, you must close
the tank system and perform postclosure care in accordance with 40
CFR 265.310. Such postclosure care consists primarily of providing
a permanent cover for the landfill to prevent erosion and
contaminant leaching. If the tank does not have a secondary
containment system, you must provide a contingency plan to
provide the site with all appropriate postclosure care in the event
that the tank leaks in the future.
Scrap metals from tanks and tank system components are
considered a recyclable material. You should empty, clean of visible
residue, and send the metal components to a commercial scrap metal
facility for recycling. No other federal closure requirements apply.
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If your tank system.contains fiberglass components, you must test
them to determine that hazardous constituents are not present
before disposing of them.
5.1.5 How Should I Prevent and Respond to Hazardous
Waste Emergencies?
5.1.5.1 Note to CESQGs
You are not subject to RCRA regulations involving preparedness and
accident prevention. Federal regulations may be helpful, however,
as guidelines for the responsible management of hazardous waste.
5.1.5.2 Preparedness Regulations Applicable to Both
SQGs and LQGs
As a general principle, you must maintain and operate your facilities
to minimize the possibility of a fire, explosion, or any unplanned
release of hazardous waste into the environment. Specifically, you
must maintain:
¦ An internal communications or alarm system for providing
emergency instructions to facility personnel. All personnel
must have immediate access to this system whenever they
handle hazardous waste.
¦ An external communications system (such as a telephone or
two-way radio) capable of summoning emergency assistance
from state and local authorities. All personnel must have
immediate access to this system whenever they handle
hazardous waste and are alone at the facility.
¦ Portable fire extinguishers and other fire control equipment.
¦ Spill control and decontamination equipment.
¦ Water at adequate volume and pressure to supply hose
streams, foam-producing equipment, or water spray systems.
¦ Sufficient aisle space to allow the unobstructed movement of
personnel and required safety devices to any area in the event
of an emergency.
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If you store no wastes that could pose a hazard requiring access to
a particular piece of safety equipment, you need not obtain that
equipment.
You must test and maintain all required safety devices as necessary
to ensure proper operation in the event of an emergency. You must
document inspections of safety equipment monthly to ensure the
equipment's availability and proper function.
Finally, you must attempt to:
¦ Familiarize police, fire departments, and emergency response
teams with the layout of your facility, properties of the
hazardous waste handled at the facility (and associated
hazards), places where facility personnel would normally be
working, entrances to roads inside the facility, and possible
evacuation routes.
¦ Where more than one police and fire department might
respond to an emergency, establish agreements assigning
primary emergency authority to a specific police department
and a specific fire department, and agreements with any
others to provide support to the primary emergency
authorities.
¦ Establish agreements with state emergency response teams,
emergency response contractors, and equipment suppliers.
¦ Familiarize local hospitals with the properties of the
hazardous wastes handled at the facility and the types of
injuries or illnesses that could result from fires, explosions, or
releases at the facility.
You must maintain documentation of your attempts to make such
arrangements, including the refusal of any involved party to
participate as described above. A letter requesting this information
sent by certified mail should provide appropriate documentation.
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5.1.5.3 Preparedness Regulations Applicable to SQGs
Only
You must post the following information near your facility's
telephones:
¦ The name and telephone number of your facility's emergency
coordinator.
¦ The location of fire extinguishers, spill control material, and
(if present) fire alarms.
¦ The telephone number of the fire department, unless your
facility has an alarm that contacts the fire department
directly.
You must also take steps to ensure that all employees are thoroughly
familiar with proper waste handling and emergency procedures that
are relevant to their responsibilities (both daily work responsibilities
and responsibilities in the event of an emergency).
At all times, you must have at least one employee on the premises
or on call (i.e., available to reach the facility quickly in the event of
an emergency). This employee must be designated as the emergency
coordinator and must have the responsibility for coordinating all
emergency response measures.
In the event of a hazardous waste emergency (e.g., fire, explosion,
release of waste to ground water, or other release that could threaten
human health), you or someone from your facility must immediately
notify the National Response Center (using its 24-hour toll-free
number 1-800-424-8802) and report the following information:
¦ The name, address, and EPA Identification Number of the
facility.
¦ A description of the emergency incident, including the date
and time that it occurred.
¦ The quantity and type of hazardous waste involved in the
incident.
¦ The extent of any injuries related to the incident.
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¦ The disposition and estimated quantity of any recovered
hazardous waste.
5.1.5.4 Preparedness Regulations Applicable to LQGs
Only
Personnel Training
Facility personnel must successfully complete a program of
classroom instruction or on-the-job training that teaches them to
perform their duties in a way that ensures their compliance with the
facility's hazardous waste regulatory requirements. This program
must be directed by a person trained in hazardous waste
management procedures, and it must include instruction in
hazardous waste management procedures. At a minimum, the
program must teach:
¦ Procedures for using, inspecting, repairing, and replacing
facility emergency and monitoring equipment.
¦ Key parameters for automatic waste feed cutoff systems.
¦ Use of available communications and alarm systems.
¦ Appropriate responses to fres and explosions.
¦ Appropriate responses to ground water contamination
incidents.
¦ Procedures for shutting down plant operations.
Personnel must successfully complete this program within 6 months
of being assigned to work at your facility. Until they have
completed their training, personnel may not work unsupervised.
Once they have completed this training program, personnel must
participate in an annual review of the training material.
You must document your training procedures by keeping the
following records:
¦ The job title for each position at the facility related to
hazardous waste management, and the names of all
employees assigned to each position.
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¦ A written job description of each position at the facility,
detailing requisite skills, education, and duties.
¦ A summary of the introductory and continuing training
provided for each job description and whether the program
consisted of classroom or on-the-job training.
¦ Records documenting that facility personnel have completed
the required training. These records must be maintained for
all personnel currently employed or employed within the last
3 years.
The Emergency Contingency Plan
You must have a contingency plan designed to minimize hazards to
human health and the environment in the event of a fire, explosion,
or unplanned release of hazardous waste to the air, soil, or ground
water. In the event of such an emergency, facility personnel are
required to carry out the plan immediately. The plan should
contain the following:
¦ Instructions for personnel in the event of particular
emergencies.
¦ Information on arrangements made with police, fire
departments, hospital, contractors, and state and local
emergency response teams.
¦ An up-to-date list of the names, addresses, and telephone
numbers of all persons qualified to serve as emergency
coordinators. One individual should be indicated as the
primary emergency coordinator, and the others should be
listed in the order in which they will assume responsibility as
alternates.
¦ An up-to-date list of all emergency equipment in the facility,
including a physical description of each item, an outline of its
capabilities, and its location in the facility.
¦ An evacuation plan for facility personnel. This plan must
describe signals to be used to begin evacuation, primary
evacuation routes, and alternate routes for use in case the
primary route is blocked.
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You must keep copies of the plan at your facility and give copies to
all local police departments, fire departments, hospitals, and state
and local emergency response teams that might be called upon to
provide emergency services.
You must update and resubmit your continency plan whenever:
¦ Applicable regulations change.
¦ The plan fails in an emergency.
¦ The facility changes (e.g., in terms of design, construction,
operation, or maintenance).
¦ The list of potential emergency coordinators changes.
¦ The list of emergency equipment changes.
¦ Use certified mail to acknowledge receipt of plans.
Responsibilities of the Emergency Coordinator
Whenever there is an imminent or actual emergency situation (such
as a fire, explosion, or unplanned release of hazardous waste), the
individual designated as the emergency coordinator must
immediately activate all applicable facility and communications
systems to alert personnel. The coordinator should also notify any
state or local agencies whose help will be needed (e.g., hospitals).
The emergency coordinator must ascertain as much information as
possible about a hazardous waste emergency, including the identity
of wastes involved, the exact source of any releases, and the extent
of any releases. Based on this information, the coordinator must
assess possible hazards to human health or the environment that
might arise, either directly or indirectly, from the released waste. If
the facility's emergency threatens the environment or human health
outside the facility, the coordinator is required to:
¦ Determine whether evacuation of local areas is advisable. If
it is, the emergency coordinator must notify the appropriate
local authorities and assist them in making a final decision
about calling evacuations.
¦ Report the emergency to the government official designated
as the on-scene coordinator for that geographical area or the
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National Response Center (1-800-424-8802). In this report,
the coordinator must provide the following:
— His or her name and telephone number.
— The name and address of the facility.
— The type of incident (e.g., fire, explosion) and the time it
occurred.
— The names and quantities of the materials involved.
— The extent of any injuries.
— Possible hazards to the environment or human health
outside the facility.
¦ Take all reasonable measures necessary to ensure that fires,
explosions, and releases do not occur, recur, or spread to
other hazardous waste at the facility. These measure must
include, where applicable, stopping processes and operations,
collecting and containing released waste, and removing or
isolating containers.
¦ If the facility stops operations in response to an emergency,
monitor for leaks, pressure buildup, gas generation, or
ruptures in valves, pipes, or other equipment wherever
appropriate.
¦ Immediately after an emergency, provide for treating, stonng,
or disposing of recovered waste, contaminated soil or surface
water, or any other material that resulted from the
emergency.
¦ Ensure that, in the affected areas of the facility, no waste that
might be incompatible with the released material is treated,
stored, or disposed of until cleanup procedures are completed.
¦ Ensure that, in the affected areas of the facility, operations do
not resume until all emergency equipment listed in the
contingency plan is cleaned and fit for its intended use.
Documentation of Emergencies
Before operations can resume in an area of the facility affected by
an emergency, you must notify EPA's regional administrator and
appropriate state and local authorities that cleanup from the
emergency is complete and that all emergency equipment in that
area has been cleaned and is fit for use.
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In your operating record, you must note the time, date, and details
of any emergency situation that required the implementation of its
contingency plan. Within 15 days of the incident, you must submit
a written report on the incident to the EPA regional administrator.
The report must include:
¦ The name, address, and telephone number of the owner or
operator of the facility.
¦ The name, address, and telephone number of the facility.
¦ The date, time, and type of incident.
¦ The name and quantity of materials involved.
¦ The extent of any injuries.
¦ An assessment of actual or potential hazards to human health
or the environment, if applicable.
¦ The estimated quantity and disposition of recovered material
resulting from the incident.
Personnel Training
You must provide annual training for employees required to handle
or maintain compliance of the facility with respect to hazardous
waste regulations. The annual training must cover contingency plan
requirements, the types of hazardous wastes stored in the facility,
and the appropriate responses to be taken in the event of a release.
Your documentation of this training must include a written
description of the training, job title, job description, and name of
employee.
5.1.6 How Should I Transport Hazardous Waste?
5.1.6.1 Note to CESQGs
Except for being required to send your waste to only those sites that
are authorized by a state to manage hazardous waste, you are not
subject to RCRA regulations involving the transportation of
hazardous wastes. Federal regulations may be helpful, however, as
guidelines for the responsible management of hazardous waste.
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5.1.6.2 Requirements Applicable to Both SQGs and LQGs
EPA ID Numbers
Before you may arrange for the transport or disposal of hazardous
waste, you must obtain an EPA ID number. You can obtain an EPA
ID number by completing and submitting EPA Form 8700-12. If
you are in Alaska, California, Hawaii, Iowa, New Jersey, New York,
Puerto Rico, or Wyoming, contact your regional EPA office to
obtain this form. Otherwise, contact your state hazardous waste
office. Once you obtain an EPA ID number, you may arrange to
ship hazardous waste only with transporters that have EPA ID
numbers.
Hazardous Waste Manifests
When transporting hazardous waste for treatment, storage, or
disposal, you are required to use a form called a "hazardous waste
manifest." You must complete, sign, and retain a copy of the
manifest for every shipment of hazardous waste sent from your
facility. After the hazardous waste is generated, every firm or
individual that handles it (e.g., a storage facility or transporter) must
add a signature to the manifest, retain a copy of the manifest, and
pass on the original manifest along with the hazardous waste. The
facility operator at the waste's ultimate destination (i.e., the disposal
facility) will return the original manifest to you as a receipt of the
waste's final disposition.
If you are sending hazardous waste to a state (the consignment
state) that supplies hazardous waste manifests, you must obtain and
use the manifest from that state. If the consignment state does not
supply manifests but your state (the generator state) supplies
manifests, you must use your state's manifest. If neither the
generator state nor the consignment state supplies manifests, you
may obtain the manifest from any source. EPA provides a uniform
hazardous waste manifest that might be helpful in such cases. To
obtain a hazardous waste manifest, follow the same guidelines as for
obtaining an EPA ID number application (i.e., contact your state
hazardous waste office or regional EPA office).
Regardless of where it comes from, the manifest must consist of at
least enough copies for the generator, each transporter, and
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designated facilities to have one copy for their records, with one
additional copy returned to you. For example, if waste was
transported to a treatment facility by one company and then
transported to a disposal facility by another company, six copies of
the manifest would be needed: one copy retained by you, one copy
retained by each of the two transport companies, one copy retained
by the treatment facility, one copy retained by the disposal facility,
and a final copy returned to you.
You must designate on the manifest one facility that is permitted to
handle the waste described on the manifest. You may also designate
one alternate facility that is permitted to handle this waste in the
event that an emergency prevents delivery of the waste to the
primary designated facility. In the event that the transporter is
unable to deliver the hazardous waste to either facility, you must
designate another facility or instruct the transporter to return the
waste.
Packaging, Marking, and Placarding Requirements
Before transporting hazardous waste or offering hazardous waste for
transportation offsite, you must:
¦ Package the waste in accordance with the applicable U.S.
Department of Transportation (DOT) regulations on
packaging under 49 CFR Parts 173, 178, and 179.
¦ Mark and label the waste in accordance with the applicable
DOT regulations on hazardous materials under 49 CFR Part
172.
¦ Mark each container of 110 gallons or less with the words
and information shown in Box 5-5 (in accordance with 49
CFR 172.304).
¦ Ensure that the vehicles used to transport the hazardous
waste are placarded according to DOT regulations under 49
CFR Part 172, Subpart F.
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Box 5-5 Marking Requirements for Hazardous Waste
Containers
"HAZARDOUS WASTE—Federal Law Prohibits Improper
Disposal. If found, contact the nearest police or public
safety authority or the U.S. Environmental Protection
Agency."
Generator's Name and Address:
Manifest Document Number:
Export Requirements
If you export hazardous waste to another country, you must comply
with the same requirements that apply to domestic transportation,
with the following modifications:
¦ For every 12-month period during which you will export
hazardous waste, you must submit a Notification of Intent to
Export Report to EPA. Yo.u must submit this to EPA at least
60 days before the first shipment of the period. You must
keep a copy of this notification for three years after the last
shipment of the period. This report must include the
following information:
— Your company's name, address, and EPA ID.
— The name and address of each destination facility. If
there is more than one facility, you must organize all
waste information by the facility it pertains to.
— A description of the hazardous waste, including its EPA
hazardous waste number and its Department of
Transportation shipping name, hazard class, and ID
number.
— The frequency and quantity of all hazardous waste
shipments planned.
— The method by which the waste will be shipped and a list
of all the countries it will enter or pass through, including
points of entry and departure. If you are moving waste
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through a country, you must indicate how long it will be
in that country.
¦ You must obtain an EPA Acknowledgment of Consent before
you can ship your waste. This document shows the foreign
country's willingness to accept hazardous waste and must
accompany the hazardous waste manifest. EPA will issue this
document to you once it has been notified by the U.S.
Embassy in the foreign country that the country has
consented to accept the waste. If there is any deviation from
the waste shipping plan by which this document was
obtained (e.g., a change of disposal facilities), you must
notify EPA immediately. Finally, you must keep a copy of
this document for three years after the last date that waste
was transported with it.
¦ On the manifest:
— You need not supply an EPA ID number for the foreign
destination.
— Under "Special Handling Instructions" you must identify
the point of departure from the United States.
— The following statement must be added to the end of the
first sentence of the manifest certification: "and conforms
to the terms of the attached EPA Acknowledgment of
Consent."
¦ You must file an exception report with EPA if:
— You do not receive a copy of the manifest from your
transporter (within 45 days of beginning transport)
indicating that the waste has left the country.
— You do not receive a copy of the manifest from the
destination facility within 90 days of beginning transport.
— The waste is returned to the United States.
¦ You must submit an annual report to EPA by March 1 of
every year. This report must contain updated information for
all Notification Reports filed for the year. For LQGs, this
report must also describe efforts taken to reduce the quantity
and toxicity of the generated waste and demonstrate the
effect of these efforts. You must sign a certification at the
end of the report containing the language shown in Box 5-6.
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Box 5-6 Certification for LQG Annual Report
"I certify under penalty of law that I have personally
examined and am familiar with the information submitted
in this and all attached documents, and that based on my
inquiry of those individuals immediately responsible for
obtaining the information, I believe that the submitted
information is true, accurate, and complete. I am aware
that there are significant penalties for submitting false
information including the possibility of fine and
imprisonment."
Send reports to:
Office of International Activities (A-106)
Environmental Protection Agency
401 M Street SW.
Washington, DC 20460
5.1.6.3 Requirements Applicable to SQGs Only
If your hazardous waste is transported under a contractual
agreement that meets the following standards, you are released from
the obligation to complete a manifest for each shipment. The
contract must:
¦ Specify the type of waste and frequency of waste to be
shipped.
¦ Be made with a facility that not only reclaims hazardous
waste but owns and operates the vehicles used to transport
the hazardous waste.
¦ Be maintained in your records for at least 3 years after
termination of the agreement.
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5.1.7 What Records Do I Need To Keep?
5.1.7.1 Note to CESQGs
You are not subject to the following recordkeeping regulations.
They may be helpful, however, as guidelines for the responsible
management of hazardous waste.
5.1.7.2 Requirements Applicable to Both LQGs and SQGs
Manifest Records
You must keep a copy of each signed hazardous waste manifest for
3 years, or until receipt of a signed copy from the designated facility
that received the waste. You must retain the signed copy from the
designated facility for at least 3 years from the date that the waste
was accepted by the initial transporter.
Inspection Schedule and Logs
You must develop a written schedule for monitoring all operating
and structural equipment and all safety and emergency equipment
related to your hazardous waste. This schedule must list all the
significant potential problems that could happen with this
equipment and describe how to identify them. In general, you
should schedule equipment inspections at a frequency that is
appropriate to the rate of equipment deterioration. Specific
inspection frequency requirements are cited in 40 CFR 265.15.
You must keep a written log of all observations made during
inspections at your facility. These records must include the date
and time of the inspection, the name of the inspector, the nature of
any problems noted, and the date that any problems were resolved.
You must keep this record for at least three years after the date of
the inspection.
Arrangements With Local Authorities
You must document all attempts to provide local emergency
response authorities (e.g., fire departments, hospitals) with
information and to develop emergency response arrangements with
them.
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Annual Export Report
If you export hazardous waste to foreign countries, you must file an
annual export report. See Section 5.1.6.2 for details on this report.
Waste Analysis
You must keep records of any test results, waste analyses, or other
work done to determine which of your wastes are hazardous. The
principal purpose of these records is to support your claim to being
either a CESQG, SQG, or LQG.
5.1.7.3 Requirements Applicable to SQGs Only
Exception Reporting
If after signing a hazardous waste manifest, you do not receive a
copy of that manifest from the designated facility (e.g., the disposal
facility) within 60 days of the date the waste was accepted by the
initial transporter, you must submit a copy of your original manifest
to the EPA regional administrator. The copy should include some
indication that you have not received confirmation of delivery. It
is sufficient to include a short, handwritten note to this effect.
5.1.7.4 Requirements Applicable to LQGs Only
Biennial Reporting
You must prepare and submit a single copy of a biennial report to
the EPA regional administrator by March 1 of each even-numbered
year. The Biennial Report must be submitted on EPA Form 8700-
13A, must cover hazardous waste generator activities during the
previous year, and must include the following information:
¦ Your facility's EPA ID number, name, and address.
¦ The calendar year covered by the report.
¦ The EPA ID number of each transporter used during the
reporting year for shipping hazardous waste.
¦ Under the heading of each transporter, a listing of hazardous
wastes shipped during the reporting year. The listing should
provide a description, the EPA hazardous waste number,
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DOT hazard class, and quantity of each waste in each
shipment.
¦ A description of the efforts undertaken during the year to
reduce the volume and toxicity of waste generated.
¦ A description of the changes in volume and toxicity of waste
actually achieved during the year (in comparison with all
previous years for which information is available).
¦ A certification signed by you or an authorized representative.
If you treat, store, or dispose of hazardous waste onsite (i.e., if you
are a treatment, storage, and disposal facility as well as an SQG or
LQG—see Section 5.1.2.1), you must also submit a biennial report
covering those wastes in accordance with the provisions of 40 CFR
Parts 270, 264, 265, and 266. In addition, you must submit a
waste analysis plan [described in 40 CFR 268.7(a)4] to the EPA
regional director if you seek to achieve the treatment standards
specified in Subpart D of 40 CFR 268 (Land Disposal Restrictions).
Exception Reporting
If after signing a hazardous wiste manifest you do not receive a
copy of that manifest from the designated facility (e.g., the disposal
facility) within 35 days of the date the waste was accepted by the
initial transporter, you must contact the transporter and/or the
designated facility to determine the status of the hazardous waste.
If you do not receive a signed copy within 45 days, you must file an
exception report with the EPA regional administrator. The
exception report must include:
¦ A legible copy of the manifest for which you lack delivery
confirmation.
¦ A cover letter signed by you (or an authorized representative)
explaining the efforts you have taken to locate the hazardous
waste and the results of those efforts.
5.1.8 Closure Requirements (Applicable to LQGs Only)
If you close an LQG facility, you must do so in a way that
minimizes the need for further maintenance and that limits (to the
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extent necessary to protect human health and the environment)
postclosure escape of hazardous substances to ground or surface
waters or to the atmosphere. You must fully comply with the full
closure regulations of 40 CFR 265, including (but not limited to)
265.197, 265.228, 265.258, 265.280, 265.310, 265.351, 265.381,
and 265.404. All contaminated equipment, structures, and soil
must be properly disposed of or decontaminated unless specified
otherwise in 265.197, 265.228, 265.258, 265.280, or 265.310.
Generally, these regulations deal with minimizing the probability of
postclosure environmental problems and with ensuring that financial
resources are available to deal with any problems that occur.
5.2 State Requirements
The specific regulatory requirements of a state's hazardous waste
program will depend greatly on if the state is RCRA authorized and
for what individual hazardous waste programs the state has been
authorized. If a state is RCRA authorized, then EPA has authorized
the state to administer and enforce the state developed RCRA
program in lieu of federal authority. If a state is not RCRA
authorized, then EPA will implement and enforce the federal RCRA
program within the state. State RCRA programs must be as least as
stringent as the federal program and in many cases are more
stringent and encompassing than the federal program. As an
example, some states regulate all generators, regardless of the
amount or type of waste generated, under the same regulations. In
addition, most states regulate waste that is not regulated at the
federal level such as waste oil.
Most states are authorized for the base RCRA program. However,
EPA has promulgated additional regulatory programs under RCRA
and the Hazardous and Solid Waste Amendments (HSWA) for
which states may not be authorized. An example of this is the Land
Disposal Restrictions (LDR). This means the generator must
comply with both the state hazardous waste regulations and
additional federal regulations.
Manifest requirements also differ gready from state to state. Some
states use the uniform manifest form as supplied by the EPA. Other
states customize the form, require additional information on the
form, and require additional distribution of the completed form.
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Some states have 2-part, 4-part, and 8-part manifest forms. Other
states, such as the New England states, allow the use of either the
destination or generation states form.
Table 5-1 summarizes how the individual state requirements
regarding the generation, management, and disposal of hazardous
waste differ from the federal requirements, for selected states.
Hazardous waste regulations, at both the federal and state level, are
constantly evolving and changing. While some states are
promulgating more stringent and complex regulations, there is also
a trend in some states to actually simplify their regulations and to
rescind state regulations that are more stringent than the federal
regulations. Therefore, it is important to contact the states
periodically to track changes in the regulations.
5.3 Where To Go for More Information
To get more information about requirements for the treatment,
storage, and disposal of hazardous waste, contact:
¦ Your State Hazardous Waste Office
¦ Your EPA Regional Off :e
¦ EPA's RCRA Hotline (1 300-535-0202)
The federal regulations discussed in this chapter are found in the
Code of Federal Regulations (CFR). With the exception of the
Department of Transportation standards, these regulations can be
found in Title 40, Parts 260-281, of the CFR. The Department of
Transportation standards can be found in Tide 49, Part 172, of the
CFR. The CFR is found in many libraries or is available by writing:
Superintendent of Documents
Attn: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
or by calling:
Government Printing Office Order Desk at 202-783-3238.
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Connecticut Department of
Environmental Protection
Bureau of Waste Management
Waste Engineering &.
Enforcement Division
79 Elm Street
Hartford, CT 06106-5 127
(860) 424-3023
Manifest Contact:
Ms. Jane Brennan
Connecticut Department of
Environmental Protection
Manifest Department
79 Elm Street
Hartford, CT 06106
(860) 424-3375
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Table 5-1 Summary of Selected State Hazardous Waste Programs
State
GA
MA
Laws and
Regulations
Georgia Compliance
Rules &. Regulations
391-3-4.01
General Requirements
Georgia's hazardous waste regulations are essentially
identical to the federal regulations.
Massachusetts General
Laws Chapter 2lC
Department of
Environmental
Protection (DEP)
Hazardous Waste
Regulations
(310CMR 30.000)
Massachusetts is a RCRA authorized state.
Massachusetts has established three levels of
generators; very small quantity generators (VSQGs),
SQGs, and LQGs.
SQG considered by MA DEP a Very Small
Quantity Generator (VSQG) if generation is less
than 100 kg of hazardous waste per month or does
not generate any acutely hazardous waste. VSQG
are not "conditionally exempt". Accumulation limit
for VSQG must not exceed 600 kg. VSQG can self
transport small quantities of their own waste and can
conduct some on-site treatment and recycling
without a license. No annual compliance fee. SQG's
must submit $300.00 annual fee. LQG's biennial
report must be submitted to DEP by March 1 of even
years for the preceding year's hazardous waste
activity. Annual generator fee of $ 1,800.00.
Manifest Requirements
Georgia uses the federal uniform
manifest form.
Manifest Contact:
Georgia Department of Natural
Resources
Environmental Protection
Division
Hazardous Waste Management
Branch
Generator Compliance
205 Butler Street
Atlanta, GA 30334
(404) 657-8831
Massachusetts uses a customized
8-part, 4-part, and 2-part EPA
manifest form. VSQG's may use
4-part State form for interstate
transport of hazardous waste and
waste oil. The two-part manifest
form is used for waste being
shipped off-site for recycling. All
other waste shipments must use
the 8-part form.
Massachusetts has signed an
agreement between the six New
England states that allows
generators of hazardous waste to
use either the generators state
manifest form or the destination
state manifest form.
State Contact(s)
Georgia Department of Natural
Resources
Environmental Protection
Division
205 Butler Street
Atlanta, GA 30334
(404) 363-7000
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Massachusetts Department of
Environmental Protection
Division of Hazardous Waste
1 Winter street
Boston, MA 02108
(617) 292-5853
Manifest Contact:
Ms. Beth McDonough
Department of Environmental
Protection
Division of Hazardous Waste
Manifest Section
1 Winter Street
Boston, MA 02108
(617)574-6895
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Table 5-1 Summary of Selected State Hazardous Waste Programs
State
Laws and
Regulations
General Requirements
Manifest Requirements
State Contact(s)
Ml
Michigan
Administrative Code
299.9308
Michigan is a RCRA authorized state. LQG's must
submit biennial reports to DNR bv March 1.
Copy of manifest must be
submitted and postmarked no
later than the 10'1' day of the
month following the month of
the shipment'.
Manifest Contact:
Manifest "Department
Michigan Department of
Natural Resources
Waste Management Division
PO Box 30038
530 West Allegan Street
P.O. Box 30241
Lansing, MI 48909
(517) 373-2730
Michigan Department of
Natural Resources
530 West Allegan Street
P.O. Box 30241
Lansing, Ml 48909
(517)373-2730
MN
Minnesota
Regulations
7001.0520,
7045.0206
Minnesota is a RCRA authorized state. Minnesota
uses the federal generator categories of LQG, SQG,
and has reclassified CESQG as "Very Small Quantity
Generators" (VSQG's). VSQG's and SQG's are
excluded from contingency plans and personnel
training requirements. Alternate manifests are
allowed by State for generators of less than 100 kg
per month, and for generators of less than 1 kg of
acutely hazardous wastes. Annual fee required based
upon quantity or volume generated. State Permit
required for each LQG facility.
Minnesota uses a customized
manifest form. Copy must be
submitted to MPCA within 5
working days of shipment. Copv
must be signed by facility owner
or operator and submitted to
MPCA within 40 days of
acceptance of shipment.
Minnesota Pollution Control
Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
(800) 657-3864
Manifest Contact:
Mr. Ken Moon
Minnesota Pollution Control
Agency
Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612) 296-8333
-------
Table 5-1 Summary of Selected State Hazardous Waste Programs
State
Laws and
Regulations
General Requirements
Manifest Requirements
State Contact(s)
N|
New Jersey
Administrative Code
Title 7, 26-7.4
New Jersey is a RCRA authorized state. Currently
the state uses two generator categories; SQG, which
is comparable to the federal definition of a CESQG
and "Fully Regulated" which includes both federal
SQGs and LQGs. In October of 1995, the state will
change their regulations to follow the federal
regulations. Waste oil in New Jersey is currently
regulated as a hazardous waste. This will also
change in October when waste oil will be regulated
in accordance with the federal regulations.
New Jersey uses a customized 8-
part form.
Manifest Contact:
Mr. Ferd Scaccetti
New Jersey Department of
Environmental Protection
Division of Hazardous Waste
Management
Hazardous Waste Manifest
Section
401 East State Street
Trenton, NJ 08625
(609) 292-7081
New Jersey Department of
Environmental Protection
401 East State Street
Trenton, NJ 08625
(609) 292-8341
NY
New York Compliance
Codes Rules and
Regulations Title 6,
372
New York is a RCRA authorized state. New York
follows the federal requirements for CESQGs, SQGs
and LQGs. Annual reports must be submitted to
DEC by March l. Annual hazardous waste program
fee required.
New York State Department of
Environmental Conservation
Data Management Section
Hazardous Waste Manifest
50 Wolf Road
PO Box 12820
Albany, New York 12820
(518) 457-6858
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233-1750
(518) 457-6934
NC
North Carolina
Administrative Code
NCAC 15A,
RI3A.0007
North Carolina is a RCRA authorized state. North
Carolina has adopted the federal regulations with
few exceptions. Personnel training and contingency
plan requirements excluded for SQG's (less than
l ,000 kg per month, or less than l kg of acutely
hazardous waste). Reporting and recordkeeping
requirements apply. Annual SQG generator fee of
$25.00 required. Annual report must be submitted
to DEHNR by March l. Annual LQG fee of $500
required. Inspection records and results must be
maintained on-site for 3 years.
North Carolina uses the EPA
form with their state name and
seal printed on the form.
Manifest Contact:
Mr. Jim Edwards
Division of Waste Management
(919) 733-2178 x209
North Carolina Department of
Environment, Health &. Natural
Resources
Division of Waste Management
P.O. Box 27687
Raleigh, NC 27611
(919) 733-2178
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Table 5-1 Summary of Selected State Hazardous Waste Programs
State
Rl
Laws and
Regulations
Rhode Island General
Laws Chapter 23-19.1
Rhode Island
Hazardous Waste
Regulations
General Requirements
Rhode Island is a RCRA authorized state. Rhode
Island Hazardous Waste regulations differ from the
federal regulations in that they establish only one
category for all generators of hazardous waste. There
is no "de minimis" generation amount. All
generators are regulated by the same regulations
which are modeled on the federal requirements for a
LQG of hazardous waste.
Manifest Requirements
Rhode Island uses a customized
8-part EPA manifest form. Copy
B, signed by transporter, must be
submitted to DEM within 5
days.
Rhode Island has signed an
agreement between the six New
England states that allows
generators of hazardous waste to
use either the generators state
manifest form or the destination
state manifest form.
Manifest Contact:
Ms. Beverly Migliore
Department of Environmental
Management
Division of Waste Management
291 Promenade Street
Providence, Rl 02908
(401) 277-2797 Extension 7503
State Contact(s)
Department of Environmental
Management
Division of Waste Management
291 Promenade Street
Providence, Rl 02908
(401) 277-2797
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Table 5-1 Summary of Selected State Hazardous Waste Programs
State
Laws and
Regulations
General Requirements
Manifest Requirements
State Contact(s)
TX
30 Texas
Administrative Code
335.9, 335.61
Texas is a RCRA authorized state. Texas uses the
federal generator categories of LQG, SQG, and
CESQG. Training and contingency plan
requirements apply only to LQGs. Annual reports
and generator fees are required for LQGs and SQGs
and must be submitted to TNRCC by March 1.
Texas also regulates state-listed hazardous waste
refered to as Texas Class 1 waste.
Texas uses a customized 4-part
manifest form (document
number: TWC-0311). Non-
RCRA Texas Class I waste must
also be shipped using a manifest.
Manifest Contact:
Industrial and Hazardous Waste
Evaluation - MCI29
Texas Natural Resource
Conservation Commission
12100 Park 35 Circle
Austin, TX 78711
(512)239-6832
Texas Natural Resource
Conservation Commission
12100 Park 35 Circle
Austin, TX 787 1 1
(512) 239-2334
WI
Wisconsin
Administrative Code
NR 600.03(188)
Wisconsin is a RCRA authorized state. Federal
requirements apply to generators classified by the
State as "Very Small Quantity Generators".
Personnel training and contingent plan
requirements excluded for SQG's (less than 1,000 kg
per month, or less than 1 kg cf acutely hazardous
wastes). Annual reports required. LQG's must
submit annual report to DNR by March 1. A copy of
Federal biennial report must be submitted to DNR.
State form 4400-66 required.
Copy of form must be submitted
to DNR and consignment state
within 5 business days of
shipment. Submit copy of
consignment state's hazardous
waste manifest, if used, within 5
business days of receipt of form
copy from consignment state.
Manifest Contact:
Ms. ICathy Thompson
Wisconsin Department of
Natural Resources
Bureau of Solid and Hazardous
Waste Management
Manifest Section
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
(608) 266-7524
Wisconsin Department of
Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
(608) 266-2111
-------
APPENDIX 5-A
COMPLIANCE CALENDAR FOR RCRA HAZARDOUS WASTE
REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar |
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHAPTER 5 - HAZARDOUS WASTE
Milestone Events
By March 1 of every
year
Submit export report
RCRA
Submit a hazardous waste export report
Regional EPA office
5-30
By March 1 of every
even-numbered year
(if you are an LQG)
Submit biennial report
RCRA
Prepare report describing your hazardous waste
management program in detail.
Regional EPA office
5-33 to 5-34
Regular or Periodic Events |
Al least once a week
Inspection
Inspect all hazardous waste storage areas to check
for leaks or other problems.
On tile al the facility
5-13
Once a year
Training
RCRA
Each employee must review this training
Certification on file at
the facility
5-22
Other Events |
Within 90 days of
generation (if you are
a LQG)
Within 180 days of
generation (if you are
a SQG and your
waste is being
shipped fewer than
200 miles)
Within 270 days of
generation (if you are
a SQG and your
waste is being
shipped more than
200 miles)
RCRA
Remove waste from site
5-5
-------
Regulatory Compliance and Environmental Management Calendar 1
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
1 f you arc an LQG and
one of your shipments
of hazardous waste is
late in reaching its
final destination...
Within 35 days of
shipping
RCRA
Contact disposal site and/or the waste transporter
to find out what happened
5-34
If one of your
sltipments of
hazardous waste is
late in reaching its
final destination
Exception report
RCRA
File an exception report. Attach a copy of the
hazardous waste manifest.
Regional office of the
EPA
5-34
Within 45 days of
having the hazardous
waste shipped (if you
are an LQG)
Within 60 days of the
having the hazardous
waste shipped (if you
are an SQG)
Informal note
RCRA
File an informal note. Attach a copy of the
hazardous waste manifest.
Regional office of the
EPA
5-33
If you are an LQG...
within 6 months of
the date employees
start work involving
hazardous waste
Training
RCRA
If you are an LQG, ensure that all employees who
work with hazardous waste complete an
appropriate training course.
Certification on file at
the facility
5-22
As soon as possible
after your firm begins
generating hazardous
Emergency response plan
RCRA
Develop a plan to respond effectively to
emergencies caused by your hazardous waste.
5-23 to 5-24
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Regulatory Compliance and Environmental Management Calendar 1
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
As soon as possible
after you facility
begins generating
hazardous waste
Information about
hazardous waste generated
at the facility
RCRA
Provide information about your hazardous waste.
Local emergency
response authorities
5-20
As soon as possible
following a reportable
hazardous waste
release
Notification
RCRA
Notify officials
National Response
Center (NRC) and
local emergency
response officials.
5-21
Within 15 days of any
emergency
(if you are an LQG)
Report
RCRA
Send a copy of all documentation relating to the
emergency
Regional office of the
EPA.
5-25 to 5-26
As soon as possible
following a reportable
hazardous waste
release
Gather information
RCRA
Investigate the extent and cause of the release.
5-24 to 5-26
As soon as possible
or within 24 hours of
discovering a leaking
underground storage
tank (if you are an
LQG)
Remove waste
RCRA
Remove all waste from the leaking tank or
container and transfer to a secure tank or container.
5-17
Within 30 days of
discovering a leaking
underground storage
tank (if you are an
LQG)
Submit report
RCRA
Submit a report describing the leak.
Regional EPA office
5-17 to 5-18
70
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APPENDIX 5-B
GLOSSARY OF TERMS
-------
Hazardous Waste
Part I, Chapter 5
Acutely Hazardous Waste—Hazardous waste that carries immediate danger to human health or
the environment. Hazardous waste that is assigned a hazardous waste code beginning with "P" is
acutely hazardous. See Hazardous Waste, Hazardous Waste Code.
Certification—A statement of professional opinion based on knowledge and belief.
Conditionally Exempt Small Quantity Generator (CESQG)—See Section 5.1.2 for a
discussion.
Container—Any portable device in which a material is stored, transported, disposed of, or
otherwise handled.
Contingency Plan—A document setting out an organized, planned, and coordinated course of
action to be followed in case of a fire, explosion, or release of hazardous waste or hazardous waste
constituents which could threaten human health or the environment.
Designated Facility—The permitted hazardous waste treatment, storage, or disposal facility where
a shipment of waste is sent. See Treatment, Storage, and Disposal.
Discarded Material—Any substance that is abandoned, recycled, or is (in EPA's judgement)
inherently waste-like.
Discharge—The spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous
waste into or on any land or water.
Disposal—The application of hazardous waste into or on any land or water so that it mav enter
the environment (through either the air, water, or land).
Disposal Facility—A permitted facility for the disposal of hazardous waste. See Disposal.
EPA Hazardous Waste Number—See Hazardous Waste Number.
EPA ID Number—The ID number that EPA assigns to a hazardous waste generator or a
treatment, storage, or disposal facility. See Disposal, Hazardous Waste Generator, Storage,
and Treatment.
Hazardous Waste Number—The number or numbers assigned by to a solid waste on the basis
of its hazardous characteristics or listing as a hazardous substance. Any waste to which you assign
a hazardous waste number is hazardous waste. See Appendix 5-1 for information on assigning
hazardous waste numbers. See Hazardous Waste.
Hazardous Waste Generator—Any entity whose act or process produces hazardous waste.
Hazardous Waste—Any solid waste that has at least one Hazardous Waste Number assigned to
it. In general, Hazardous Waste is solid waste that is harmful to human health or the
environment. See Hazardous Waste Number and Solid Waste.
December 1996
5-B1
-------
Hazardous Waste
Part I, Chapter 5
Incompatible Waste—Any hazardous waste that is unsuitable for mixing with another waste
because the mixture might produce heat or pressure, fire or explosion, violent reaction, or
flammable or toxic dusts or gasses.
Large Quantity Generator (LQG)—See Section 5.1.2 for a discussion.
Leak Detection System—A system capable of detecting the failure of a containment structure or
the presence of the accumulation of liquid outside the containment structure.
Manifest—The shipping document (EPA form 8700-22) that accompanies a hazardous waste
shipment from the time it leaves the generating facility to the time it reaches its designated facilitv.
See Disposal Facility.
Resource Conservation and Recovery Act (RCRA)—The law from which federal hazardous
waste management regulations derive their authority.
Small Quantity Generator (SQG)—See Section 5.1.2 for a discussion.
Solid Waste—In general, any solid, liquid, semi-solid, or contained gaseous material that is
discarded. See Appendix 5-1 for more detailed criteria. See Discarded.
Storage—The holding of hazardous waste for a temporary period, at the end of which the
hazardous waste is treated, disposed of, or stored elsewhere. See Disposal and Treatment.
Tank—A stationary device, designed to contain an accumulation of hazardous waste. Typically
constructed out of wood, concrete, steel, or plastic.
Toxicity Characteristic Leachate Procedure (TCLP)—The laboratory procedure by which you
can evaluate whether or not a solid waste possesses the hazardous characteristic of toxicity.
Transporter—A person engaged in the offsite transportation of hazardous waste by air, rail
highway, or water.
Treatment—Any method, technique, or process designed to change the nature of hazardous waste
in such a way is to render it non-hazardous or less hazardous.
December 1996
5-B2
-------
APPENDIX 5-C
HAZARDOUS WASTE IDENTIFICATION PROCEDURES
-------
Hazardous Waste
Part I, Chapter 5
The following flow charts will help you determine whether your wastes are considered
hazardous under RCRA Subtitle C.
The flow charts are simplified somewhat, but will guide you through your preliminary
determinations. Applicable sections of the regulation are noted in the flow charts for
your reference.
December 1996
5-C1
-------
Hazardous Waste
Part I, Chapter 5
Step 1. Determine Whether the Waste Is a RCRA Solid Waste
1. Is the material a solid,
liquid, semisolid, or
contained gaseous
material?
I
Yes
~
2. Has the material
served its intended
purpose, been
produced as a
manufacturing or
mining byproduct, or
been discarded (see 40
CFR 261.2(a)(2)]?
Yes
~
No-
-No-
3. Is the material domestic sewage or
an industrial wastewater discharge
subject to regulation under the Clean
Water Act [see 40 CFR 261.4(a)(1)
and 261.4(a)(2)]?
[Note: The wastewater discharge
exemption applies only to wastes
directly discharged from an industrial
process to the sewer. Wastewater
that is stored, treated, or mixed with
solid waste is considered solid waste
and is subject to RCRA regulation.]
-Yes—'
No
4. Is the material
reclaimed and returned
to the original process
from which it was
generated [see 40 CFR
261.4(a)(8)]?
-Yes-
No
5. The material is a
RCRA solid waste. It
may or may not be
considered a hazardous
waste.
6. The material is not a
-~< RCRA solid waste and
therefore is not subject
to RCRA regulation.
T
END
No
7. Is the material
reclaimed through a
completely enclosed
system, using only tanks,
pipes, and comparable
means of conveyance
[see 40 CFR
261,4(a)(8)(i)]?
I
Yes
T
8. Does the reclamation method
used on the material involve fuel
production, material disposal, the
accumulation of more than 12
months' worth of material, or
controlled flame combustion [see
40 CFR 264.4(a)(8)(ii),
264.4(a)(8)(iii), 264.4(a)(8)(iv)]?
Yes
December 1996 ^ GO TO NEXT 5-02
PAGE
-------
Hazardous Waste
Part I, Chapter 5
Step 2. Determine Whether the Waste Is Exempt From Classification as a
Hazardous Waste
FROM
PREVIOUS
PAGE
9. Does the waste
contain chromium?
-No-
Yes
i
JL_
14. Does the waste
consist of petroleum-
contaminated media?
-No-
GO TO NEXT
PAGE
10. Is the chromium in
the waste exclusively (or
near exclusively)
trivalent?
-No-
Yes
Yes
11, Does the waste
come from a process
involving hexavalent
chromium?
-Yes-
No
12. Is the . uste
managed in a
nonoxidative
environment?
-No-
15. Is the waste
regulated under the rules
governing Underground
Storage Tanks (40 CFR
Part 280)?
Yes
Yes
13. The waste may be exempt from
classification as hazardous waste. If, after
finishing this identification procedure, the
waste would be considered hazardous
solely because of failing the toxicity
characteristic test for chromium, it is
exempted from classification as hazardous
[see 40 CFR 261.4(b)(6)],
16. The waste may be exempt from
classification as hazardous waste.
If, after finishing this identification
procedure, the waste would be
considered hazardous solely
because of being assigned one or
more hazardous waste codes
between 0018 and D043, it is
exempted from classification as
hazardous [see 40 CFR
261,4(b)(10)].
December 1996
GO TO NEXT
PAGE
-------
Hazardous Waste
Part I, Chapter 5
Step 3. Determine Whether the Waste Is an EPA Listed Waste
For the purposes of all following questions that ask if a waste is listed in a particular table, the following rules apply [see 40 CFR 261.3]:
If a listed hazardous waste is mixed (after generation) with any quantity of any other waste, the entire
mixture is listed as hazardous.
Any substance produced through the treatment, storage, or disposal of a listed hazardous waste is listed as the
j substance from which it was derived.
|
! - If the waste is an old container for hazardous waste, it is listed as the substance that it contained, unless it is
considered empty under the standards of 40 CFR 261.7. See Appendix 7-5 for a discussion of these standards.
I
j There are some exemptions to these three rules. Consult the regulation or a specialist to confirm your determinations.
I
FROM
PREVIOUS
PAGE
~ ~ GO TO NEXT
¦ 27. The waste is not an J ~ PAGE
j EPA listed waste. j
December 1996 5-C4
-------
Hazardous Waste
Part I, Chapter 5
Step 4. Determine Whether the Waste Exhibits Hazardous Characteristics
FROM
PREVIOUS
PAGE
• 1 28. Is the waste a liquid?
No I —T
Yes
No
36. Is the waste chemically unstable (e.g.,
does it readily undergo violent change or
does it react violently with water)?
-Yes, Go to 41
-No. Go to 37-
GO TO NEXT
PAGE
December 1996
5-C5
-------
Hazardous Waste
Part I, Chapter 5
Step 4. Determine Whether the Waste Exhibits Hazardous Characteristics
(Cont.)
FROM FROM
December 1996
5-C6
-------
APPENDIX 5-D
LISTED HAZARDOUS WASTES
-------
Hazardous Waste
Part I, Chapter 5
The following tables contain lists of EPA listed hazardous wastes. These tables will help
you assign hazard codes to any wastes considered hazardous:
Table 5D-1 F-Listed Wastes (Hazardous Wastes From Non-specific Sources)
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Table 5D-4 U-Listed Wastes (Hazardous Discarded Commercial Chemical Products)
December 1996
5-D1
-------
Hazardous Waste
Part I, Chapter 5
Table 50-1 F-Listed Wastes (Hazardous Wastes From Non-specific Sources)
Industry and
EPA
Hazardous
Waste No.
Hazardous Waste
Hazard
Code
Generic substances:
F001
The following spent halogenated solvents used in degreasing:
tetrachloroethvlene, trichloroethvlene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all
spent solvent mixtures/blends used in degreasing containing, before use,
a total of 10 percent or more (by volume) of one or more of the above
halogenated solvents or those solvents listed in F002, F004, and F005;
and still bottoms from the recovery of these spent solvents and spent
solvent mixtures.
(T)
F002
The following spent halogenated solvents: tetrachloroethylene,
methylene chloride, trichloroethvlene, 1,1,1-trichloroethane,
chloro benzene, l,l,2-trichloro-l,2,2-trifluoroethane,
orthodichlorobenzene, trichlorofluoromethane, and 1,1,2-
trichloroethane; all spent solvent mixtures/blends containing, before use,
a total of 10 percent or more (by volume) of one or more of the above
halogenated solvents or those listed in F00I, F004, or F005; and still
bottoms from the recovery of these spent solvents and spent solvent
mixtures.
(T)
F003
The following spent nonhalogenated solvents: xylene, acetone, ethyl
acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl
alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends
containing, before use, only the above spent nonhalogenated solvents; all
spent solvent mixtures/blends containing, before use, one or more of the
above nonhalogenated solvents and a total of 10 percent or more (by
volume) of one or more of those solvents listed in F001, F002, F004, and
F005; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures.
(I)*
F004
The following spent nonhalogenated solvents: cresols, cresylic acid, and
nitrobenzene; all spent solvent mixtures/blends containing, before use,
a total of 10 percent or more (by volume) of one or more of the above
nonhalogenated solvents or those solvents listed in F001, F002, and
F005; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures.
(T)
F005
The following spent nonhalogenated solvents: toluene, methyl ethyl
ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol,
and 2-nitropropane; all spent solvent mixtures/blends containing, before
use, a total of 10 percent or more (bv volume) of one or more of the
above nonhalogenated solvents or those solvents listed in F001, F002, or
F004; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures.
(I.T)
December 1996
5-D2
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-1 F-Listed Wastes (Hazardous Wastes From Non-specific Sources)
Industry and
EPA
Hazardous
Waste No.
Hazardous Waste
Hazard
Code
F006
Wastewater treatment sludges from electroplating operations except from
die following processes: sulfuric acid anodizing of aluminum; tin plating
on carbon steel; zinc plating (segregated basis) on carbon steel;
aluminum or zinc-aluminum plating on carbon steel; cleaning/stripping
associated with tin, zinc, and aluminum plating on carbon steel; and
chemical etching and milling of aluminum.
(T)
F 007
Spent cyanide plating bath solutions from electroplating operations.
(R. T)
F008
Plating bath residues from the bottom of plating baths from
electroplating operations where cyanides are used in the process.
(R, T)
F009
Spent stripping and cleaning bath solutions from electroplating
operations where cyanides are used in the process.
(R, T)
F010
Quenching bath residues from oil baths from metal heat treating
operations where cyanides are used in the process.
(R. T)
F011
Spent cyanide solutions from salt bath pot cleaning from metal heat
treating operations.
(R. T)
F012
Quenching wastewater treatment sludges from metal heat treating
operations where cvanides are used in the process.
(T)
F019
Wastewater treatment sludges from the chemical conversion coating of
aluminum except from zirconium phosphating in aluminum can washing
when such phosphating is an exclusive conversion coating process.
(T)
F028
Residues resulting from the incineration or thermal treatment of soil
contaminated with EPA Hazardous Waste Nos. F020, F021, F022, F023,
F026, and F027.
(T)
* Mixtures containing ignitible and toxic constituents.
December 1996
5-D3
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
Wood preservation:
KOOI
Bottom sediment sludge From the treatment of wastewaters from
wood preserving processes that use creosote and/or
pentachlorophenol.
(T)
Inorganic pigments:
IC002
Wastewater treatment sludge from the production of chrome
vellow and orange pigments.
(T)
IC003
Wastewater treatment sludge from the production of molvbdate
orange pigments.
(T)
K004
Wastewater treatment sludge from the production of zinc yellow
pigments.
(T)
IC005
Wastewater treatment sludge from the production of chrome
green pigments.
(T)
K006
Wastewater.treatment sludge from the production of chrome
oxide green pigments (anhydrous and hydrated).
(T)
IC007
Wastewater treatment sludge from the production of iron blue
pigments.
(T)
K0U8
Oven residue from the production of chrome oxide green
pigments.
(T)
Organic chemicals:
IC009
Distillation bottoms from the production of acetaldehyde from
ethylene.
(T)
ICO 10
Distillation side cuts from the production of acetaldehyde from
ethylene.
(T)
KOI 1
Bottom stream from the wastewater stripper in the production of
acrylonitrile.
(R, T)
ICO 13
Bottom stream from the acetonitrile column in the production of
acrvlonitrile.
(R, T)
KOI 4
Bottoms from the acetonitrile purification column in the
production of acrvlonitrile.
(T)
ICO 15
Still bottoms from the distillation of benzvl chloride.
(T)
ICO 16
Heaw ends or distillation residues from the production of carbon
tetrachloride.
(T)
December 1996
5-D4
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
KOI 7
Heavy ends (still bottoms) from the purification column in the
production of epichlorohvdrin.
(T)
ICO 18
Heaw ends from the fractionation column in ethyl chloride
production.
(T)
KOI 9
Heavv ends from the distillation of ethylene dichloride in
ethylene dichloride production.
(T)
K020
Heaw ends from the distillation of vinyl chloride in vinyl chloride
monomer production.
(T)
K021
Aqueous spent antimony catalyst waste from fluoromethanes
production.
(T)
IC022
Distillation bottom tars from the production of phenol/acetone
from cumene.
(T)
IC023
Distillation light ends from the production of phthalic anhydride
from naphthalene.
(T)
I<024
Distillation bottoms from the production of phthalic anhydride
from naphthalene.
(T)
K025
Distillation bottoms from the production of nitrobenzene by the
nitration of benzene.
(T)
IC026
Stripping still tails from the production of methy ethvl pyridines.
(T)
K027
Centrifuge and distillation residues from toluene diisocyanate
production.
(R. T)
K028
Spent catalvst from the hydrochlorinator reactor in the
production of 1,1,1-trichloroethane.
(T)
K029
Waste from the product steam stripper in the production of 1,1,1-
trichloroethane.
(T)
K030
Column bottoms or heavy ends from the combined production of
trichloroethvlene and perchloroethylene.
(T)
K083
Distillation bottoms from aniline production.
(T)
K085
Distillation or fractionation column bottoms from the production
of chlorobenzenes.
(T)
K093
Distillation light ends from the production of phthalic anhydride
from ortho-xvlene.
(T)
December 1996
5-D5
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
K094
Distillation bottoms from the production of phthalic anhydride
from ortho-xvlene.
(T)
K095
Distillation bottoms from the production of 1,1,1 -trichloroethane.
(T)
IC096
Heaw ends from the heaw ends column from the production of
1,1,1 -trichloroethane.
(T)
ICI03
Process residues from aniline extraction from the production of
aniline.
(T)
IC104
Combined wastewater streams generated from
nitrobenzene/aniline production.
(T)
K.105
Separated aqueous stream from the reactor product washing step
in the production of chlorobenzenes.
(T)
IC107
Column bottoms from product separation from the production of
dimethvl-hydrazine (UDMH) from carboxyiic acid hydrazines.
(C.T)
IC108
Condensed column overheads from product separation and
condensed reactor vent gases from the production of UDMH
from carboxyiic acid hvdrazides.
(IT)
K109
Spent filter cartridges from product purification from the
production of UDMH from carboxyiic acid hvdrazides.
(T)
Id 10
Condensed column overheads from intermediate separation from
the production of 1,1-dimethylhydrazine (UDMH) from
carboxyiic acid hvdrazides.
(T)
Kill
Product washwaters from the production of dinitrotoluene via
nitration of toluene.
(C.T)
IC112
Reaction byproduct water from the drying column in the
production of toluenediamine via hvdrogenation of
dinitrotoluene.
(T)
IC1I3
Condensed liquid light ends from the purification of
toluenediamine in the production of toluenediamine via
hvdrogenation of dinitrotoluene.
(T)
K114
Vicinals from the purification of toluenediamine in the
production of toluenediamine via hydrogenation of
dinitrotoluene.
(T)
IC115
Heaw ends from the purification of toluenediamine in the
production of toluenediamine via hydrogenation of
dinitrotoluene.
(T)
December 1996
5-D6
-------
Hazardous Waste
Part I, Chapter 5
Table 50-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
IC1 16
Organic condensate from the solvent recovery column in the
production of toluene diisocyanate via phosgenation of
toluenediamine.
(T)
KI17
Wastewater from the reactor vent gas scrubber in the production
of ethylene dibromide via bromination of ethene.
(T)
IC1 18
Spent adsorbent solids from purificauon of ethylene dibromide in
the production of ethylene dibromide via brominadon of ethene.
(T)
IC136
Still bottoms from the purificauon of ethylene dibromide in the
production of ethylene dibromide via brominadon of ethene.
(T)
K149
Distillation bottoms from the production of alpha- or methyl-
chlorinated toluenes, ring-chlorinated toluenes, benzoyl chlorides,
and compounds with mixtures of these functional groups. (This
waste does not include still bottoms from the distillation of
benzyl chloride.)
(T)
IC150
Organic residuals, excluding spent carbon adsorbent, from the
spent chlorine gas and hydrochloric acid recovery processes
associated with the producuon of alpha- or methyl-chlorinated
toluenes, ring-chlorinated toluenes, benzoyl chlorides, and
compounds with mixtures of these functional groups.
(T)
IC151
Waste -vater treatment sludges, excluding neutralization and
biological sludges, generated during the treatment of wastewaters
from the producuon of alpha- or methyl-chlorinated toluenes,
ring-chlorinated toluenes, benzoyl chlorides, and compounds with
mixtures of these functional groups.
(T)
IC156
Organic waste (including heavy ends, still bottoms, light ends,
spent solvents, filtrates, and decantates) from the producuon of
carbamates and carbamoyl oximes.
(T)
IC157
Wastewaters (including scrubber waters, condenser waters,
washwaters, and separation waters) from the producuon of
carbamates and carbamoyl oximes.
(T)
IC158
Bag house dusts and filter/separation solids from the producuon
of carbamates and carbamoyl oximes.
(T)
K159
Organics from the treatment of thiocarbamate wastes.
(T)
IC160
Solids (including filter wastes, separation solids, and spent
catalysts) from the production of thiocarbamates and solids from
the treatment of thiocarbamate wastes.
(T)
December 1996
5-D7
-------
Hazardous Waste
Part I, Chapter 5
Table 50-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
ICl 61
Purification solids (including filtration, evaporation, and
centrifugation solids), bag house dust, and floor sweepings from
the production of dithiocarbamate acids and their salts. (This
listing does not include IC125 or K126.)
(R.T)
Pesticides:
IC039
Filter cake from the filtration of diethyiphosphorodithioic acid in
the production of phorate.
(T)
IC040
Wastewater treatment sludge from the production of phorate.
(T)
IC041
Wastewater treatment sludge from the production of toxaphene.
(T)
IC042
Heavy ends or distillation residues from the distillation of
tetrachlorobenzene in the production of 2,4,5-T.
(T)
IC043
2,6-Dichlorophenol waste from the production of 2,4-D.
(T)
IC097
Vacuum stripper discharge from the chlordane chlorinator in the
production of chlordane.
(T)
IC098
Untreated process wastewater from the production of toxaphene.
(T)
KO 9 9
Untreated wastewater from the production of 2/-D.
(T)
ICl 23
Process wastewater (including supemates, filtrates, and
washwaters) from the production of ethylenebisdithiocarbamic
acid and its salts.
(T)
IC124
Reactor vent scrubber water from the production of
ethylenebisdithiocarbamic acid and its salts.
(C.T)
IC125
Filtration, evaporation, and centrifugation solids from the
production of ethvlenebisdithiocarbamic acid and its salts.
(T)
KI26
Baghouse dust and floor sweepings in milling and packaging
operations from the production or formulation of
ethylenebisdithiocarbamic acid and its salts.
(T)
ICl 31
Wastewater from the reactor and spent sulfuric acid from the acid
dryer from the production of methyl bromide.
(C.T)
KI32
Spent absorbent and wastewater separator solids from the
production of methvl bromide.
(T)
Explosives:
December 1996
5-D8
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
IC044
Wastewater treatment sludges from the manufacturing and
processing of explosives.
(R)
ICO 4 5
Spent carbon from the treatment of wastewater containing
explosives.
(R)
IC046
Wastewater treatment sludges from the manufacturing,
formulation, and loading of lead-based initiating compounds.
(T)
K047
Pink/red water from trinitrotoluene (TNT) operations.
(R)
Petroleum refining:
K048
Dissolved air flotation (DAF) float from the petroleum refining
industry.
(T)
IC049
Slop oil emulsion solids from the petroleum refining industry.
(T)
ICO 50
Heat exchanger bundle cleaning sludge from the petroleum
refining industry.
(T)
IC051
API separator sludge from the petroleum refining industry.
(T)
IC052
Tank bottoms (leaded) from the petroleum refining industry.
(T)
Veterinary pharmaceuticals:
ICO 8 4
Wastewater treatment sludges generated during the production
of veterinary pharmaceuticals from arsenic or organo-arsenic
compounds.
(T)
IC101
Distillation tar residues from the distillation of aniline-based
compounds in the production of veterinary pharmaceuticals from
arsenic or organo-arsenic compounds.
(T)
Coking:
IC060
Ammonia still lime sludge from coking operations.
(T)
ICO 8 7
Decanter tank tar sludge from coking operations.
(T)
IC14I
Process residues from the recovery of coal tar, including, but not
limited to, collecting sump residues from the production of coke
from coal or the recovery of coke byproducts produced from coal.
This listing does not include IC087 (decanter tank tar sludges
from coking operations).
(T)
ICl 47
Tar storage tank residues from coal tar refining.
(T)
December 1996
5-D9
-------
Hazardous Waste
Part 1, Chapter 5
Table 5D-2 K-Listed Wastes (Hazardous Wastes From Specific Sources)
Industry and
EPA Hazardous
Waste No.
Source and Hazardous Waste
Hazard Code
K148
Residues from coal tar distillation, including, but not limited to,
(T)
still bottoms.
December 1996
5-D10
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P023
107-20-0
Acetaldehvde, chloro-
P002
591-08-2
Acetamide, N-(aminothioxomethvl)-
P057
640-19-7
Acetamide, 2-fluoro-
P058
62-74-8
Acetic acid, fluoro-, sodium salt
P002
591-08-2
1 -Acetvl-2-thiourea
P003
107-02-8
Acrolein
P070
116-06-3
Aldicarb
P203
1646-88-4
Aldicarb suifone
P004
309-00-2
Aldrin
P005
107-18-6
Allvl alcohol
P006
20859-73-8
Aluminum phosphide (R,T)
P007
2763-96-4
5-(Aminomethyl)-3-isoxazolol
P008
504-24-5
4-Aminopvridine
P009
131-7-1-8
Ammonium picrate (R)
PI 19
7803-55-6
Ammonium vanadate
P099
506-61-6
Argentate( 1-), bis(cyano-C)-, potassium
P010
7778-39-4
Arsenic acid (HjAs04 )
P012
1327-53-3
Arsenic oxide (As203)
P011
1303-28-2
Arsenic oxide (As203)
P01I
1303-28-2
Arsenic pentoxide
P012
1327-53-3
Arsenic trioxide
P038
692-42-2
Arsine, diethvl-
P036
696-28-6
Arsonous dichloride, phenyl-
P054
151-56-4
Aziridine
P067
75-55-8
Aziridine, 2-methvl-
P013
542-62-1
Barium cvanide
P024
106-47-8
Benzenamine, 4-chIoro-
December 1996
5-D11
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P077
100-01-6
Benzenamine, 4-nitro-
P028
100-44-7
Benzene, (chloromethvl)-
P042
51-43-4
1,2-Benzenediol, 4-[l-hvdroxy-2-(methvlamino)ethvl]-, (R)-
P046
122-09-8
Benzeneethanamine, alpha, alpha-dimethyl-
POM
108-98-5
Benzenethiol
P127
1563-66-2
7-BenzofuranoI, 2,3-dihydro-2,2-dimethvl-, methyicarbamate
PI88
57-64-6
Benzoic acid, 2-hvdroxy-, compound with (3aS-cis)-1,2,3,3a,8,8a-
hexahvdro-1,3a,8-trimethvlpyrrolo[2,3-b]indol-5-yl
methyicarbamate ester (1:1)
POO I
81-81-2
2H-l-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-l-phenylbutyI)-, and
salts, when present at concentrations greater than 0.3%
P028
100-44-6
Benzyl chloride
P015
6440-41-6
Beryllium powder
P016
598-31-2
Bromoacetone
P018
356-57-3
Brucine
P045
39196-18-4
2-Butanone, 3,3-dimethyl-l-(methylthio)-, o-
[methvlamino)carbonyl] oxime
P021
592-01-8
Calcium cyanide
P021
592-01-8
Calcium cvanide[(Ca(CN)2]
PI 89
55285-14-8
Carbamic acid, [(dibutylamino)-thio]methyI-,2,3-dihydro-2,2-
dimethvl-7-benzofuranvl ester
P191
644-64-4
Carbamic acid, dimethyl-, 1-[(dimethyl-amino)carbonyl]-5-methyl-
lH-pvrazol-3-yl ester
PI 92
119-38-0
Carbamic acid, dimethyl-, 3-methyl-l-(l-methylethyl)-lH-pyrazol-
5-vl ester
I ~
PI 90
1129-41-5
Carbamic acid, methyl-, 3-methylphenyl ester
P127
1563-66-2
Carbofuran
P022
75-15-0
Carbon disulfide
P095
75-44-5
Carbonic dichloride
December 1996
5-012
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
PI 89
55285-14-8
Carbosulfan
P023
107-20-0
Chloroacetaldehvde
P024
106-47-8
p-Chloroaniline
P026
5344-82-1
1 -(o-Chlorophenvl)thiourea
P027
542-76-7
3-Chloropropionitrile
P029
544-92-3
Copper cyanide
P029
544-92-3
Copper cvanide [Cu(CN)]
P202
64-00-6
m-Cumenvl methylcarbamate
P030
--
Cyanides (soluble cyanide salts), not otherwise specified
P031
460-19-5
Cyanogen
P033
506-77-4
Cyanogen chloride
P033
506-77-4
Cyanogen chloride [(CN)C1]
P034
131-89-5
2-Cvclohexvl-4,6-dinitrophenol
P016
542-88-1
Dichloromethyl ether
P036
696-28-6
Dichlorophenylarsine
P037
60-57-1
Dieldrin
P038
692-42-2
Diethylarsine
P041
311-45-5
Diethvl-p-nitrophenyl phosphate
P040
297-97-2
o,o-Diethvl-o-pyrazinyl phosphorothioate
P043
55-91-4
Diisopropvlfiuorophosphate (DFP)
P004
309-00-2
1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa-chloro-
1,4,4a,5,8,8a-hexahydro-,
(1 alpha,4alpha,4abeta,5 alpha,8alpha,8abeta)-
P060
465-73-6
1,4,5,8-Diniethanonaphthalene, 1,2,3,4,10,10-hexa-chloro-
1,4,4a,5,8,8a-hexahvdro-,
(1 alpha,4alpha,4abeta,5beta,8beta,8abera)-
P037
60-57-1
2,7:3,6-Diniethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexachloro-
1 a,2,2a,3,6,6a,7,7a-octahvdro-,
(1 aalpha.2beta.2aalpha,3beta,6beta,6aalpha,7beta,7aalpha)-
December 1996
5-D13
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P051
72-20-8
2,7:3,6-Dimethanonaphth[2,3-b]oxirene, 3,4,5,6,9,9-hexachloro-
la,2,2a,3,6,6a,7,7a-octahydro-,
(laalpha,2beta,2abeta,3alpha,6alpha,6abeta,7beta, 7aalpha)-, and
metabolites
P044
60-51-5
Dimethoate
P046
122-09-8
alpha, alpha-Dimethvlphenethylamine
P191
644—64—4
Dimetilan
P047
'534-52-1
4,6-Dinitro-o-cresol and salts
P048
51-28-5
2,4-Dinitrophenol
P020
88-85-7
Dinoseb
P085
152-16-9
Diphosphoramide, octamethyl-
P1U
107-49-3
Diphosphoric acid, tetraethyl ester
P039
298-04-4
Disulfoton
P049
541-53-7
Dithiobiuret
P185
26419-73-8
1,3-Dithiolane-2-carboxalde:iyde, 2,4-dimethvl-, o-[(methylamino)-
carbonvl]oxime
P050
115-29-7
Endosulfan
P088
145-73-3
Endothall
P051
72-20-8
Endrin
P051
72-20-8
Endrin and metabolites
P042
51-43-4
Epinephrine
P031
460-19-5
Ethanedinitrile
PL94
23135-22-0
Ethanimidothioc acid, 2-(dimethylamino)-N-[[(methylamino)
carbonyl]oxv]-2-oxo-, methyl ester
P066
16752-77-5
Ethanimidothioic acid, N-[[(methylamino)carbonyl]oxy]-, methyl
ester
P101
107-12-0
Ethyl cvanide
P054
151-56-4
Ethvleneimine
P097
52-85-7
Famphur
December 1996
5-D14
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P056
7782-41-4
Fluorine
P057
640-19-7
Fluoroacetamide
P058
62-74-8
Fluoroacetic acid, sodium salt
P198
23422-53-9
Formetanate hydrochloride
P197
17702-57-7
Formparanate
P065
628-86-4
Fulminic acid, mercury(2 + ) salt (R,T)
P059
76-44-8
Heptachlor
P062
757-58-4
Hexaethvl tetraphosphate
PL 16
79-19-6
Hvdrazinecarbothioamide
P068
60-34-4
Hydrazine, methvl-
P063
74-90-8
Hvdrocvanic acid
P063
74-90-8
Hydrogen cyanide
P096
7803-51-2
Hydrogen phosphide
P050
465-73-6
Isodrin
P192
119-38-0
Isoian
P202
64—00—6
3-Isopropvlphenyl N-methylcarbamate
POO 7
2763-96-4
3(2H)-Isoxazolone, 5-(aminomethyl)-
P196
15339-36-3
Manganese, bis(dimethylcarbamodithioato-S,S')-
P196
15339-36-3
Manganese dimethyldithiocarbamate
P092
62-38-4
Mercurv, (acetato-o)phenyl-
P065
628-86-4
Mercurv fulminate (R,T)
P082
62-75-9
Methanamine, N-methyl-N-nitroso-
P064
624-83-9
Methane, isocvanato-
P016
542-88-1
Methane, oxybis[chloro-
PI 12
509-14-8
Methane, tetranitro- (R)
PI 18
75-70-7
Methanethiol, trichloro-
December 1996
5-D15
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
PI 98
23422-53-9
Methanimidamide, N,N-dimethvl-N'-[3-[[(methylamino)-
carbonvl]oxv]phenyl]-, monohydrochloride
P197
17702-57-7
Methanimidamide, N,N-dimethyl-N'-[2-methyl-4-
[[(methvlamino)carbonvl]oxv]phenvI]-
P050
115-29-7
6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9,10,10-hexachloro-
1,5,5a,6,9,9a-hexahydro-, 3-oxide
P059
76-44-8
4,7-Methano-1 H-indene, 1,4,5,6,7,8,8-heptachloro-3a,4,7,7a-
tetrahydro-
PI 99
2032-65-7
Methiocarb
P066
16752-77-5
Methomvl
P068
60-34-4
Methvl hydrazine
P064
624-83-9
Methyl isocvanate
P069
75-86-5
2-Methyllactonitrile
P071
298-00-0
Methyl parathion
PI 90
1129-41-5
Metolcarb
P128
315-8-4
Mexacarbate
P072
86-88-4
alpha-Naphthvlthiourea
P073
13463-39-3
Nickel carbonyl
P073
13463-39-3
Nickel carbonyl [Ni(CO)4], (T-4)-
P074
557-19-7
Nickel cyanide
P074
557-19-7
Nickel cyanide [Ni(CN)2]
P075
1 54-11-5
Nicotine and salts
P076
10102-43-9
Nitric oxide
P077
100-01-6
p-Nitroaniline
P078
10102-44-0
Nitrogen dioxide
P076
10102-43-9
Nitrogen oxide (NO)
P078
10102-44-0
Nitrogen oxide (N02)
P081
55-63-0
Nitroglycerine (R)
December 1996
5-D16
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P082
62-75-9
N-Nitrosodimethvlamine
P084
4549-40-0
N-Nitrosomethylvinylamine
P085
152-16-9
Octamethvlpvrophosphoramide
P087
20816-12-0
Osmium oxide [Os04], (T-4)-
P087
20816-12-0
Osmium tetroxide
P088
145-73-3
7-OxabicycIo[2.2. l]heptane-2,3-dicarboxylic acid
PI 94
23135-22-0
Oxamvl
P089
56-38-2
Parathion
P034
131-89-5
Phenol, 2-cvclohexvl-4,6-dinitro-
P048
51-28-5
Phenol, 2,4-dinitro-
P047
'534-52-1
Phenol, 2-methyl-4,6-dinitro-, and salts
P020
88-85-7
Phenol, 2-( l-methylpropyl)-4,6-dinitro-
P009
131-74-8
Phenol, 2,4,6-trinitro-, ammonium salt (R)
P128
315-18-4
Phenol, 4-(dimethylamino)-3,5-dimethyl-, methylcarbamate (ester)
PI 99
2032-65-7
Phenol, (3,5-dimethvl-4-(methylthio)-, methylcarbamate
P202
64-00-6
Phenol, 3-(l-methylethyl)-, methyl carbamate
P201
2631-37-0
Phenol, 3-methvl-5-(l-methylethyl)-, methyl carbamate
P092
62-38-4
Phenvlmercury acetate
P093
103-85-5
Phenylthiourea
P094
298-02-2
Phorate
P095
75_44_5
Phosgene
P096
7803-51-2
Phosphine
P041
311-45-5
Phosphoric acid, diethyl 4-nitrophenvl ester
P039
298-04-4
Phosphorodithioic acid, o,o-diethyl S-[2-(ethylthio)ethyl] ester
P094
298-02-2
Phosphorodithioic acid, o,o-diethvl S-((ethylthio)methyl] ester
P044
60-51-5
Phosphorodithioic acid. o,o-dimethvl S-[2-(methylamino)-2-
oxoethvl] ester
December 1996
5-D17
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P043
55-91-4
Phosphorofluoridic acid, bis( l-methylethyl) ester
P089
56-38-2
Phosphorothioic acid, o,o-diethvl o-(4-nitrophenyl) ester
P040
297-97-2
Phosphorothioic acid, o,o-diethyI o-pvrazinvl ester
P097
52-85-7
Phosphorothioic acid, o-(4-[(dimethylamino)suIfonyl]phenyl]-o,o-
dimethvl ester
P071
298-00-0
Phosphorothioic acid, o,o,-dimethvl o-(4-nitrophenyl) ester
P204
57_47_6
Phvsostigmine
P188
57-64-7
Physostigmine salicylate
PI 10
78-00-2
Plumbane, tetraethvl-
P098
151-50-8
Potassium cyanide
P098
151-50-8
Potassium cyanide [K(CN)]
P099
506-61-6
Potassium silver cyanide
P20I
2631-37-0
Promecarb
P070
116-06-3
Propanal, 2-methyl-2-(methylthio)-, o-
[(methvlamino)carbonyljoxime
P203
1646-88-4
Propanal, 2-methyl-2-(methyl-sulfonvl)-, o-
[(methylamino)carbonyl] oxime
P101
107-12-0
Propanenitrile
P027
542-76-7
Propanenitrile, 3-chloro-
P069
75-86-5
Propanenitrile, 2-hydroxy-2-methyl-
P081
55-63-0
1,2,3-Propanetriol, trinitrate (R)
P017
598-31-2
2-Propanone, 1-bromo-
PI 02
107-19-7
Propargyl alcohol
P003
107-02-8
2-Propenal
POOS
107-18-6
2-Propen-l-ol
P067
75-55-8
1,2-Propvlenimine
P102
107-19-7
2-Propvn-1 -ol
POO 8
504-24-5
4-Pvridinamine
December 1996
5-D18
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
P075
54-11-5
Pyridine, 3-( 1-methyI-2-pyrrolidinyl)-, (S)-, and salts
P204
57-47-6
Pvrrolo[2,3-b]indol-5-ol, 1,2,3,3a,8,8a-hexahydro-1,3a,8-trimethvi-
methvlcarbamate (ester), (3aS-cis)-
PI 14
12039-52-0
Selenious acid, dithallium (1 +) salt
PI 03
630-10-4
Selenourea
PI 04
506-64-9
Silver cvanide
PI 04
506-64-9
Silver cyanide [Ag(CN)]
P105
26628-22-8
Sodium azide
PI 06
143-33-9
Sodium cvanide
PI 06
143-33-9
Sodium cyanide [Na(CN)]
PI 08
'57-24-9
Strvchnidin-10-one and salts
P018
357-57-3
Strvchnidin-10-one, 2,3-dimethoxy-
PI 08
'57-24-9
Strychnine and salts
PI 15
7446-18-6
Sulfuric acid, dithallium (1 +) salt
PI 09
3689-24-5
Tetraethvldithiopyrophosphate
PI 10
78-00-2
Tetraethvl lead
PI 11
107-49-3
Tetraethvl pyrophosphate
PI 12
509-14-8
Tetranitromethane (R)
P062
757-58-4
Tetraphosphoric acid, hexaethyl ester
PI 13
1314-32-5
Thallic oxide
PI 13
1314-32-5
Thallium oxide (T1203)
PI 14
12039-52-0
Thallium (I) selenite
PI 15
7446-18-6
Thallium (I) sulfate
PI09
3689-24-5
Thiodiphosphoric acid, tetraethyl ester
P045
39196-18-4
Thiofanox
P049
541-53-7
Thioimidodicarbonic diamide ([(H2N)C(S)]2NH)
P014
108-98-5
Thiophenol
December 1996
5-D19
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-3 P-Listed Wastes (Acutely Hazardous Discarded Commercial Chemical
Products)
Hazardous
Waste No.
Chemical
Abstracts No.
Substance
PI 16
79-19-6
Thiosemicarbazide
P026
5344-82-1
Thiourea, (2-chlorophenvl)-
P072
86-88-4
Thiourea, I-naphthalenvl-
P093
103-85-5
Thiourea, phenvl-
P185
26419-73-8
Tirpate
PI23
8001-35-2
Toxaphene
PI 18
75-70-7
Trichloromethanethiol
PI 19
7803-55-6
Vanadic acid, ammonium salt
PL 20
13 14-62-1
Vanadium oxide (V205)
P120
1314-62-1
Vanadium pentoxide
P084
4549-40-0
Vinylamine, N-methvl-N-nitroso-
P001
'81-81-2
Warfarin and salts, when present at concentrations greater than
0.3%
P205
137-30-4
Zinc, bis(dimethylcarbamodii hioato-S,S')-
P121
557-21-1
Zinc cyanide
P121
557-21-1
Zinc cyanide [Zn(CN)2]
PI 22
1314-84-7
Zinc phosphide [Zn3P2], when present at concentrations greater
than 10% (R.T)
P205
137-30-4
Ziram
Chemical Abstracts number given for parent compound onlv.
December 1996
5-D20
-------
Hazardous Waste
Part I, Chapter 5
Table 50-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U394
30558-43-1
A2213
U001
75-07-0
Acetaldehvde (I)
U034
75-87-6
Acetaldehvde, trichloro
U187
62-44-2
Acetamide, N-(4-ethoxyphenvl)-
U005
53-96-3
Acetamide, N-9H-fluoren-2-yl-
U240
'94-75-7
Acetic acid, (2,4-dichlorophenoxv)-, salts, and esters
U1 12
141-78-6
Acetic,acid ethyl ester (I)
U144
301-04-2
Acetic acid, lead (2+) salt
U214
563-68-8
Acetic acid, thallium (1 +) salt
See F027
93-76-5
Acetic acid, (2,4,5-trichlorophenoxv)-
U002
67-64-1
Acetone (I)
U003
75-05-8
Acetonitrile (I,T)
U004
98-86-2
Acetophenone
U005
53-96-3
2-Acetylaminofluorene
U006
75-36-5
Acetyl chloride (C,R,T)
U007
79-06-1
Acrylamide
U008
79-10-7
Acrylic acid (I)
U009
107-13-1
Acrylonitrile
U011
61-82-5
Amitrole
UO12
62-53-3
Aniline (I,T)
U136
75-60-5
Arsinic acid, dimethvl-
UO 14
492-80-8
Auramine
U0I5
115-02-6
Azaserine
U365
2212-67-1
H-Azepine-l-carbothioic acid, hexahydro-, S-ethyl ester
U010
50-07-7
Azirino[2',3':3,4]pyrrolo[ 1,2-a]indole-4,7-dione, 6-amino-8-
[[(aminocarbonvl)oxv]methyl]-1,1 a,2,8,8a,8b-hexahydro-8a-
methoxv-5-methvl-, [laS-( laalpha, 8beta,8aalpha,8balpha)]-
U280
101-27-9
Barban
December 1996
5-D21
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U278
22781-23-3
Bendiocarb
U364
22961-82-6
Bendiocarb phenol
U271
17804-35-2
Benomvl
U157
56-49-5
Benz[j]aceanthrylene, 1,2-dihvdro-3-methvl-
U016
225-51-4
Benz[c]acridine
U017
98-87-3
Benzai chloride
U192
23950-58-5
Benzamide, 3,5-dichloro-N-( 1,1 -dimethvl-2-propynyl)-
U018
56-55-3
Benz[a]anthracene
U094
57-97-6
Benz[a]anthracene, 7,12-dimethvl-
U012
62-53-3
Benzenamine (I,T)
U014
492-80-8
Benzenamine, 4,4'-carbonimidoylbis[N,N-dimethyl-
U049
3165-93-3
Benzenamine, 4-chloro-2-methvl-, hydrochloride
U093
60-11-7
Benzenamine, N,N-dimethvl-4-(phenvlazo)-
U328
95-53-4
Benzenamine, 2-methvl-
' /
U353
106-49-0
Benzenamine, 4-methvi-
U158
101-14-4
Benzenamine, 4,4'-methvlenebis[2-chloro-
U222
636-21-5
Benzenamine, 2-methyl-, hydrochloride
U181
99-55-8
Benzenamine, 2-methyl-5-nitro-
U019
71-43-2
Benzene (I,T)
U038
510-15-6
Benzeneacetic acid, 4-chloro-alpha-(4-chlorophenyl)-alpha-
hydroxv-, ethyl ester
U030
101-55-3
Benzene, 1-bromo-4-phenoxy-
U035
305-03-3
Benzenebutanoic acid, 4-[bis(2-chloroethyl)amino]-
U037
108-90-7
Benzene, chloro-
U221
25376-45-8
Benzenediamine, ar-methvl-
U028
117-81-7
1,2-Benzenedicarboxvlic acid, bis(2-ethylhexyl) ester
L'069
84-74-2
1,2-Benzenedicar.boxvlic acid, dibutvl ester
U088
84-66-2
1,2-Benzenedicarboxvlic acid, diethyl ester
December 1996
5-D22
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
UI02
131—11-3
1,2-Benzenedicarboxylic acid, dimethyl ester
UI07
117-84-0
1,2-Benzenedicarboxvlic acid, dioctyl ester
U070
95-50-1
Benzene, 1,2-dichloro-
U071
541-73-1
Benzene, 1,3-dichloro-
L'072
106-46-7
Benzene, 1,4-dichloro-
U060
72-54-8
Benzene, 1, l'-(2,2-dichloroethylidene)bis[4-chloro-
U0I7
98-87-3
Benzene, (dichloromethvl)-
U223
26471-62-5
Benzene, 1,3-diisocvanatomethvl- (R,T)
U239
1330-20-7
Benzene, dimethyl- (I,T)
U201
108-46-3
1,3-Benzenediol
U127
118-74-1
Benzene, hexachloro-
U056
110-82-7
Benzene, hexahvdro- (1)
U220
108-88-3
Benzene, methvl-
U105
121-14-2
Benzene, l-methyl-2,4-dinitro-
U106
606-20-2
Benzene, 2-methyl-1,3-dinitro-
U055
98-82-8
Benzene, (1-methylethyl)- (I)
U169
98-95-3
Benzene, nitro-
U183
608-93-5
Benzene, pentachloro-
U185
82-68-8
Benzene, pentachloronitro-
U020
98-09-9
Benzenesulfonic acid chloride (C,R)
U020
98-09-9
Benzenesulfonyl chloride (C,R)
U207
95-94-3
Benzene, 1,2,4,5-tetrachloro-
U061
50-29-3
Benzene, 1 ,l'-(2,2,2-trichloroethylidene)bis[4-chloro-
U247
72-43-5
Benzene, 1, l'-(2,2,2-trichloroethylidene)bis[4-methoxy-
U023
98-07-7
Benzene, (trichloromethyl)-
U234
99-35^1
Benzene, 1,3,5-trinitro-
U021
92-87-5
Benzidine
December 1996
5-D23
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
ChemicaJ Abstracts
No.
Substance
U202
81-07-2
1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide, and salts
U2 78
22781-23-3
1,3-Benzodioxol-4-ol, 2,2-dimethyl-, methyl carbamate
U364
22961-82-6
1,3-Benzodioxol-4-ol, 2,2-dimethvl-
U203
94_59_7
1,3-Benzodioxole, 5-(2-propenvl)-
UI41
120-58-1
1,3-Benzodioxole, 5-( I-propenvl)-
U367
1563-38-8
7-BenzofuranoI, 2,3-dihydro-2,2-dimethyl-
U090
94-58-6
1,3-Benzodioxole, 5-propyl-
U064
189-55-9
Benzo[rst]pentaphene
U248
81-81-2
2H- l-Benzopvran-2-one, 4-hydroxv-3-(3-oxo-l-phenyl-butvl)-,
and salts, when present at concentrations of 0.3% or less
U022
50-32-8
Benzo[a]pvrene
U197
106-51—4
p-Benzoquinone
U023
98-07-7
Benzotrichloride (C,R,T)
U085
1464-53-5
2,2'-Bioxirane
U021
92-87-5
[1,1 '-Biphenyl]-4,4'-diamine
U073
91-94-1
[ 1, r-Biphenyl]-4,4'-diamine, 3,3'-dichloro-
U091
119-90-4
[1,1 '-Biphenyl]-4,4'-diamine, 3,3'-dimethoxy-
U095
119-93-7
[ 1,r-Biphenyl]-4,4'-diamine, 3,3'-dimethyl-
U401
97-74-5
Bis(dimethylthiocarbamoyl) sulfide
U400
120-54-7
Bis(pentamethvlene)thiuram tetrasulfide
U225
75-25-2
Bromoform
U030
101-55-3
4-Bromophenvl phenyl ether
U128
87-68-3
1,3-Butadiene, 1,1,2,3,4,4-hexachloro-
U172
924-16-3
1-Butanamine, N-butyl-N-nitroso-
U031
71-36-3
1 -Butanol (I)
U 159
78-93-3
2-Butanone (1,T)
U 160
1338-23-4
2-Butanone. peroxide (R,T)
U053
4170-30-3
2-Butenal
December 1996
5-D24
-------
Hazardous Waste
Part I, Chapter 5
Table 50-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U074
764-41-0
2-Butene, 1,4-dichloro- (I,T)
UI43
303-34-4
2-Butenoic acid, 2-methvl-, 7-[[2,3-dihydroxv-2-( I -
methoxvethvl)-3-methvI-1 -oxobutoxy]methvl]-2,3,5,7a-
tetrahvdro-IH-pvrrolizin-l-vl ester, [1S-
[Ialpha(Z).7(2S\3R*),7aa!pha]]-
U031
71-36-3
n-Butvl alcohol (I)
U392
2008-41-5
Butvlate
U136
75-60-5
Cacodvlic acid
U032
13765-19-0
Calcium chromate
U372
10605-21-7
Carbamic acid, 1 H-benzimidazol-2-vl, methyl ester
U271
17804-35-2
Carbamic acid, [l-[(butvlamino)carbonvi]-lH-benzimidazol-2^
yl]-, methyl ester
U375
55406-53-6
V
Carbamic acid, butyl-, 3-iodo-2-propynyl ester
U280
101-27-9
Carbamic acid, (3-chlorophenyi)-, 4-chloro-2-butvnyl ester
U238
51-79-6
Carbamic acid, ethyl ester
Ul 78
615-53-2
Carbamic acid, methylnitroso-, ethyl ester
U373
122-42-9
Carbamic acid, phenyl-, 1-methylethyl ester
U409
23564-05-8
Carbamic acid, [ 1,2-phenylenebis (iminocarbonothioyl)]bis-,
dimethvl ester
U097
79-44-7
Carbamic chloride, dimethyl-
U379
136-30-1
Carbamodithioic acid, dibutvl, sodium salt
U277
95-06-7
Carbamodithioic acid, diethyl-, 2-chloro-2-propenyl ester
U381
148-18-5
Carbamodithioic acid, diethyl-, sodium salt
U383
128-03-0
Carbamodithioic acid, dimethyl, potassium salt
U382
128-04-1
Carbamodithioic acid, dimethyl-, sodium salt
U376
144-34-3
Carbamodithioic acid, dimethyl-, tetraanhydrosulfide with
orthothioselenious acid
U378
51026-28-9
Carbamodithioic acid, (hydroxvmethyl)methyl-,
monopotassium salt
U384
137-42-8
Carbamodithioic acid, methvl-, monosodium salt
December 1996
5-025
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U377
137-41-7
Carbamodithioic acid, methyl-, monopotassium salt
U389
2303-17-5
Carbamothioic acid, bis(l-methvlethyl)-, S-(2,3,3-trichIoro-2-
propenvl) ester
U392
2008-41-5
Carbamothioic acid, bis(2-methvlpropyl)-, S-ethyl ester
U391
1114-71-2
Carbamothioic acid, butvlethyl-, S-propyl ester
U386
1134-23-2
Carbamothioic acid, cvclohexvlethyl-, S-ethyl ester
U390
759-94-4
Carbamothioic acid, dipropyl-, S-ethyl ester
U387
52888-80-9
Carbamothioic acid, dipropyl-, S-(phenylmethyl) ester
U385
1929-77-7
Carbamothioic acid, dipropyl-, S-propyl ester
Ul 14
'111-54-6
Carbamodithioic acid, 1,2-ethanediylbis-, salts, and esters
U062
2303-16-4
Carbamothioic acid, bis( 1 -methylethvl)-, S-(2,3-dichloro-2-
propenvl) ester
U279
63-25-2
Carbarvl
U372
10605-21-7
Carbendazim
U367
1563-38-8
Carbofuran phenol
U215
6533-73-9
Carbonic acid, dithallium (I +) salt
U033
353-50-4
Carbonic difluoride
U156
79-22-1
Carbonochloridic acid, methyl ester (I,T)
U033
353-50-4
Carbon oxyfluoride (R.T)
U211
56-23-5
Carbon tetrachloride
U034
75-87-6
Chloral
U035
305-03-3
Chlorambucil
U036
57-74-9
Chlordane, alpha and gamma isomers
U026
494-03-1
Chlornaphazin
U037
108-90-7
Chlorobenzene
U038
510-15-6
Chlorobenzilate
U039
59-50-7
p-Chloro-m-cresol
U042
110-75-8
2-Chloroethvl vinvl ether
December 1996
5-D26
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U044
67-66-3
Chloroform
U046
107-30-2
Chloromethvl methvl ether
U047
91-58-7
beta-Chloronaphthalene
U048
95-57-8
o-Chlorophenol
U049
3165-93-3
4-Chloro-o-toluidine, hydrochloride
U032
13765-19-0
Chromic acid (H2Cr04), calcium salt
U050
218-01-9
Chrvsene
U393
137-29-1
Copper, bis(dimethvlcarbamodithioato-S,S')-
U393
137-29-1
Copper dimethvldithiocarbamate
U051
--
Creosote
U052
1319-77-3
Cresol (cresylic acid)
U053
4170-30-3
Crotonaldehyde
U055
98-82-8
Cumene (I)
U246
506-68-3
Cyanogen bromide (CN)Br
U386
1134-23-2
Cvcloate
U197
106-51-4
2,5-Cvclohexadiene-l ,4-dione
U056
110-82-7
Cvclohexane (I)
U129
58-89-9
Cyclohexane, 1,2,3,4,5,6-hexachloro-,
(1 alpha,2aJpha,3beta,4alpha,5alpha,6beta)-
U057
108-94-1
Cvclohexanone (I)
U130
77_47_4
1,3-Cvclopentadiene, 1,2,3,4,5,5-hexachloro-
U058
50-18-0
Cvclophosphamide
U240
'94-75-7
2,4-D, salts, and esters
U059
20830-81-3
Daunomvcin
U366
533-74-4
Dazomet
U060
72-54-8
DDD
U061
50-29-3
DDT
L'062
2303-16-4
Diallate
December 1996
5-D27
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U063
53-70-3
Dibenz[a,h]anthracene
U064
l89-55-9
Dibenzo[a,i]pyrene
U066
96-12-8
1,2-Dibromo-3-chloropropane
U069
84-74-2
Dibutvl phthalate
U070
95-50-1
o-Dichlorobenzene
U071
541-73-1
m-Dichlorobenzene
U072
106-46-7
p-Dichlorobenzene
U073
91-94-1
3,3'-Dichlorobenzidine
U074
764-41-0
1,4-Dichloro-2-butene (I,T)
U075
75-71-8
Dichlorodifluoromethane
U078
75-35-4
1,1 -Dichloroethylene
U079
156-60-5
1,2-Dichloroethylene
U025
111-44-4
Dichloroethyl ether
U027
108-60-1
Dichloroisopropyl ether
U024
111-91-1
Dichloromethoxy ethane
U081
120-83-2
2,4-Dichlorophenol
U082
87-65-0
2,6-Dichlorophenol
U084
542-75-6
1,3-Dichloropropene
U085
1464-53-5
1,2:3,4-Diepoxvbutane (I,T)
U108
123-91-1
1,4-Diethvleneoxide
U028
117-81-7
Diethvlhexvl phthalate
U395
5952-26-1
Dietiwlene glycol, dicarbamate
U086
1615-80-1
N,N'-Diethvlhvdrazine
U087
3288-58-2
o,o-Diethvl S-methvl dithiophosphate
U088
84-66-2
Diethvl phthalate
U089
56-53-1
Diethvlstilbesterol
U090
94-58-6
Dihvdrosafrole
December 1996
5-D28
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U091
119-90-4
3,3'-Dimethoxvbenzidine
U092
124-40-3
Dimethvlamine (I)
U093
60-11-7
p-Dimethvlaminoazobenzene
U094
57-97-6
7,12-Dimethylbenz[a]anthracene
U095
119-93-7
3,3'-Dimethvlbenzidine
U096
80-15-9
alpha,alpha-Dimethylbenzvlhydroperoxide (R)
U097
79-44-7
Dimethvlcarbamoyl chloride
U098
57-14-7
1,1 -Dimethvihvdrazine
U099
540-73-8
1,2-Dimethvihvdrazine
U101
105-67-9
2,4-Dimethyiphenoi
U102
131-11-3
Dimethyl phthalate
U103
77-78-1
Dimethvl sulfate
UI05
121-14-2
2,4-Dinitrotoluene
U106
606-20-2
2,6-Dinitrotoluene
U107
117-84-0
Di-n-octvl phthalate
U108
123-91-1
1,4-Dioxane
U109
122-66-7
1,2-Diphenylhydrazine
U110
142-84-7
Dipropvlamine (I)
U111
621-64-7
Di-n-propylnitrosamine
U403
97-77-8
Disulfiram
U390
759-94-4
EPTC
U041
106-89-8
Epichlorohydrin
U001
75-07-0
Ethanal (I)
U404
121-44-8
Ethanamine, N,N-diethyl-
U 174
55-18-5
Ethanamine, N-ethvl-N-nitroso-
U155
91-80-5
1,2-Ethanediamine, N,N-dimethyl-N'-2-pyridinyl-N'-(2-
thienvlmethvl)-
U067
106-93-4
Ethane. 1,2-dibromo-
December 1996
5-D29
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U076
75-34-3
Ethane, 1,1-dichloro-
U077
107-06-2
Ethane, 1,2-dichIoro-
U131
67-72-1
Ethane, hexachloro-
U024
111-91-1
Ethane. 1, l'-[methvlenebis(oxy)]bis[2-chloro-
UI17
60-29-7
Ethane, I,l'-oxybis-(I)
U025
111-44-4
Ethane, l,l'-oxybis[2-chloro-
U184
76-01-7
Ethane, pentachloro-
U208
630-20-6
Ethane, 1,1,1,2-tetrachloro-
U209
79-34-5
Ethane, 1,1,2,2-tetrachloro-
U218
62-55-5
Ethanethioamide
U226
71-55-6
Ethane, 1,1,1-trichioro-
U227
79-00-5
Ethane, 1,1,2-trichloro-
U410
59669-26-0
Ethanimidothioic acid, N,N'-
[thiobis[(methylimino)carbonyloxv]]bis-, dimethyl ester
U394
30558-43-1
Ethanimidothioic acid 2-(dimethylamino)-N-hydroxy-2-oxo-,
methyl ester
U359
110-80-5
Ethanol, 2-ethoxy-
U173
1116-54-7
Ethanol, 2,2'-(nitrosoimino)bis-
U395
5952-26-1
Ethanol, 2,2'-oxybis-, dicarbamate
U004
98-86-2
Ethanone, 1-phenyl-
U043
75-01-4
Ethene, chlorq-
U042
110-75-8
Ethene, (2-chloroethoxy)-
U078
75-35-4
Ethene, 1,1 -dichloro-
U079
156-60-5
Ethene, 1,2-dichloro-, (E)-
U210
127-18-4
Ethene, tetrachloro-
U228
79-01-6
Ethene, trichloro-
Ul 12
141-78-6
Ethvl acetate (I)
Ul 13
140-88-5
Ethvl acrvlate (I)
December 1996
5-D30
-------
Hazardous Waste
Part I, Chapter 5
Table 50-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U238
51-79-6
Ethyl carbamate (urethane)
UU7
60-29-7
Ethvl ether (I)
U114
1 I 1-54-6
Ethvlenebisdithiocarbamic acid, salts, and esters
U067
106-93-4
Ethylene dibromide
U077
107-06-2
Ethylene dichloride
U359
110-80-5
Ethylene glycol monoethyl ether
UI15
75-21-8
Ethylene oxide (I,T)
U116
96-45-7
Ethvlenethiourea
U076
75-34-3
Ethvlidene dichloride
Ul 18
97-63-2
Ethvl methacrvlate
Ul 19
62-50-0
Ethyl methanesulfonate
U407
14324-55-1
Ethyl ziram
U396
14484-64-1
Ferbam
C
o
_
206-44-0
Fluoranthene
U122
50-00-0
Formaldehyde
U123
64-18-6
Formic acid (C,T)
U124
110-00-9
Furan (I)
U125
98-01-1
2-Furancarboxaldehyde (I)
U147
108-31-6
2,5-Furandione
U213
109-99-9
Furan, tetrahvdro- (I)
U125
98-01-1
Furfural (I)
U124
110-00-9
Furfuran (I)
U206
18883-66-4
Glucopvranose, 2-deoxy-2-(3-methyl-3-nitrosoureido)-, D-
U206
18883-66-4
D-Glucose, 2-deoxy-2-[[(methylnitrosoamino)-carbonyl]
amino]-
U 126
765-34-4
Glvcidvlaldehvde
|
U 163
70-25-7
Guanidine, N-methvl-N'-nitro-N-nitroso-
U127
118-74-1
He.xachlorobenzene
December 1996
5-D31
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U128
87-68-3
Hexachlorobutadiene
U130
77_47_4
Hexachlorocvclopentadiene
U131
67-72-1
Hexachloroe thane
U132
70-30-4
Hexachlorophene
U243
1888-71-7
Hexachloropropene
U133
302-01-2
Hydrazine (R,T)
U086
1615-80-1
Hydrazine, 1,2-diethyl-
U098
57-14-7
Hydrazine, 1,1-dimethvl-
U099
540-73-8
Hydrazine, 1,2-dimethvl-
U109
122-66-7
Hvdrazine, 1,2-diphenyI-
U134
7664-39-3
Hydrofluoric acid (C,T)
U134
7664-39-3
Hydrogen fluoride (C,T)
U135
7783-06-4
Hydrogen sulfide (H2S)
LT096
80-15-9
Hydroperoxide, 1-methyl-1-phenylethyl- (R)
U116
96-45-7
2-Imidazolidinethione
U137
193-39-5
Indeno[ 1,2,3-cd]pyrene
U375
55406-53-6
3-Iodo-2-propynvl n-butylcarbamate
U396
14484-64-1
Iron, tris(dimethylcarbamodithioato-S.S')-
U190
85-44-9
1,3-Isobenzofurandione
U140
78-83-1
Isobutvl alcohol (I,T)
U141
120-58-1
Isosafrole
U142
143-50-0
Kepone
U143
303-34-4
Lasiocarpine
U144
301-04-2
Lead acetate
U 146
1335-32-6
Lead, bis(acetato-o)tetrahydroxvtri-
U 145
7446-27-7
Lead phosphate
U146
1335-32-6
Lead subacetate
December 1996
5-D32
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U129
58-89-9
Lindane
UI63
70-25-7
MNNG
U147
108-31-6
Maleic anhvdride
UI48
123-33-1
Maleic hvdrazide
UI49
109-77-3
Malononitrile
U150
148-82-3
Melphalan
U151
7439-97-6
Mercurv
U384
137-42-8
Metam sodium
U152
126-98-7
Methacrvlonitrile (I,T)
U092
124-40-3
Methanamine, N-methyl- (I)
U029
74-83-9
Methane, bromo-
U045
74-87-3
Methane, chloro- (I,T)
U046
107-30-2
Methane, chloromethoxv-
U068
74-95-3
Methane, dibromo-
U080
75-09-2
Methane, dichloro-
U075
75-71-8
Methane, dichlorodifluoro-
U138
74-88-4
Methane, iodo-
U119
62-50-0
Methanesulfonic acid, ethyl ester
U21I
56-23-5
Methane, tetrachloro-
U153
74-93-1
Methanethiol (I,T)
U225
75-25-2
Methane, tribromo-
U044
67-66-3
Methane, trichloro-
U12 1
75-69-4
Methane, trichlorofluoro-
U036
57-74-9
4,7-Methano-l H-indene, 1,2,4,5,6,7,8,8-octachloro-
2,3,3a,4,7,7a-hexahvdro-
U154
67-56-1
Methanol (I)
U 155
91-80-5
Methapvrilene
December 1996
5-D33
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U142
143-50-0
1,3,4-Metheno-2H-cyclobuta[cd]pentaJen-2-one,
1 , Ia,3,3a,4,5,5,5a,5b,6-decachlorooctahvdro-
U247
72-43-5
Methoxvchlor
U154
67-56-1
Methyl alcohol (I)
U029
74-83-9
Methvl bromide
U186
504-60-9
1-Methvlbutadiene (1)
U045
74-87-3
Methvl chloride (I,T)
U156
79-22-1
Methvl chlorocarbonate (I,T)
U226
71-55-6
Methyl chloroform
U157
56-49-5
3-Methvlcholanthrene
U158
101-14-4
4,4'-Methvlenebis(2-chloroaniline)
U068
74-95-3
Methylene bromide
U080
75-09-2
Methylene chloride
U159
78-93-3
Methyl ethyl ketone (I,T)
U160
1338-23-4
Methyl ethyl ketone peroxi.le (R,T)
UI38
74-88-4
Methyl iodide
U161
108-10-1
Methyl isobutyl ketone (I)
U162
80-62-6
Methvl methacrylate (I,T)
U161
108-10-1
4-Methvl-2-pentanone (1)
U164
56-04-2
Methvlthiouracil
U010
50-07-7
Mitomycin C
U365
2212-67-1
Molinate
U059
20830-81-3
5,12-Naphthacenedione, 8-acetyl-10-[(3-amino-2,3,6-
trideoxy)-alpha-L-lyxo-hexopyranosyl)oxy]-7,8,9,10-
tetrahvdro-6,8,1 1 -trihydroxy-1 -methoxy-, (8S-cis)-
U167
134-32-7
1 -Naphthalenamine
U168
91-59-8
2-Naphthalenamine
U026
494-03-1
Naphthalenamine, N,N"-bis(2-chloroethvl)-
December 1996
5-D34
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U165
91-20-3
Naphthalene
U047
91-58-7
Naphthalene, 2-chloro-
U166
130-15-4
1,4-Naphthalenedione
U236
72-57-1
2,7-Naphthalenedisulfonic acid, 3,3'-[(3,3'-dimethvl[l, 1'-
biphenvl]-4,4'-diyl)bis(azo)bis[5-amino-4-hydroxy]-,
tetrasodium salt
U279
63-25-2
I-Naphthalenol, methvlcarbamate
U166
130-15-4
1,4-Naphthoquinone
U167
134-32-7
alpha-Naphthylamine
U168
91-59-8
beta-N'aphthvlamine
U217
10102-45-1
Nitric acid, thallium (1 +) salt
U169
98-95-3
Nitrobenzene (I,T)
U170
100-02-7
p-Nitrophenol
U171
79-46-9
2-Nitropropane (I,T)
U172
924-16-3
N-Nitrosodi-n-butylamine
1/173
1116-54-7
N-Nitrosodiethanolamine
1/174
55-18-5
N-Nitrosodiethylamine
U176
759-73-9
N - N i troso-N-e thy lurea
U177
684-93-5
N-Nitroso-N-methylurea
U178
615-53-2
N-Nitroso-N-methvlurethane
U179
100-75-4
N-Nitrosopiperidine
U180
930-55-2
N-Nitrosopvrrolidine
U181
99-55-8
5-Nitro-o-toluidine
U193
1120-71-4
1,2-Oxathiolane, 2,2-dioxide
U058
50-18-0
2H-1,3,2-Oxazaphosphorin-2-amine, N,N-bis(2-
chloroethvl)tetrahvdro-, 2-oxide
U115
75-21-8
Oxirane (I.T)
U 126
765-34-4
Oxiranecarboxvaidehvde
December 1996
5-D35
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U041
106-89-8
Oxirane, (chloromethyl)-
U182
123-63-7
Paraldehvde
U391
1114-71-2
Pebulate
UI83
608-93-5
Pentachlorobenzene
U184
76-01-7
Pentachloroethane
U185
82-68-8
Pentachloronitrobenzene (PCNB)
See F027
87-86-5
Pentachlorophenol
UI61
108-10-1
Pentanol, 4-methyl-
UI86
504-60-9
1,3-Pentadiene (I)
U187
62-44-2
Phenacetin
U188
108-95-2
Phenol
U048
95-57-8
Phenol, 2-chloro-
U039
59-50-7
Phenol, 4-chloro-3-methyl-
U081
120-83-2
Phenol, 2,4-dichloro-
Uu82
87-65-0
Phenol, 2,6-dichloro-
U089
56-53-1
Phenol, 4,4'-(l,2-diethyl-l,2-ethenediyl)bis-, (E)-
U101
105-67-9
Phenol, 2,4-dimethyl-
U052
1319-77-3
Phenol, methyl-
U132
70-30-4
Phenol, 2,2'-methylenebis[3,4,6-trichloro-
U4I1
114-26-1
Phenol, 2-( 1-methylethoxy)-, methylcarbamate
U170
100-02-7
Phenol, 4-nitro-
See F027
87-86-5
Phenol, pentachloro-
See F027
58-90-2
Phenol, 2,3,4,6-tetrachloro-
See F027
95-95-4
Phenol, 2,4,5-trichloro-
See F027
88-06-2
Phenol, 2,4,6-trichloro-
U150
148-82-3
L-Phenvlalanine, 4-[bis(2-chloroethyl)amino]-
U 145
7 446-27-7
Phosphoric acid, lead (2+) salt (2:3)
December 1996
5-D36
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U087
3288-58-2
Phosphorodithioic acid, o,o-diethyl S-methvl ester
U189
1314-80-3
Phosphorus sulfide (R)
U190
85-44-9
Phthalic anhydride
UI91
109-06-8
2-Picoline
U179
100-75-4
Piperidine, 1-nitroso-
U400
120-54-7
Piperidine, 1,1 '-(teurathiodicarbonothioyl)-bis-
U383
128-03-0
Potassium dimethvldithiocarbamate
U378
51026-28-9
Potassium n-hydroxymethyl-n-methyldithiocarbamate
U377
137-41-7
Potassium n-methvldithiocarbamate
U192
23950-58-5
Pronamide
UI94
107-10-8
1-Propanamine (I,T)
UI11
621-64-7
1 -Propanamine, N-nitroso-N-propyl-
UL10
142-84-7
1-Propanamine, N-propvl- (I)
U066
96-12-8
Propane, 1,2-dibromo-3-chloro-
U083
78-87-5
Propane, 1,2-dichloro-
U149
109-77-3
Propanedinitrile
U171
79-46-9
Propane, 2-nitro- (I,T)
U027
108-60-1
Propane, 2,2'-oxybis[2-chloro-
U193
1120-71-4
1,3-Propane sultone
See F027
93-72-1
Propanoic acid, 2-(2,4,5-trichlorophenoxy)-
U235
126-72-7
1-Propanol, 2,3-dibromo-, phosphate (3:1)
U140
78-83-1
1-Propanol, 2-methyl- (I,T)
U002
67-64-1
2-Propanone (1)
U007
79-06-1
2-Propenamide
U084
542-75-6
1-Propene, 1,3-dichloro-
U243
1888-71-7
1 -Propene, 1,1,2,3,3,3-hexachloro-
U009
107-13-1
2-Propenenitrile
December 1996
5-D37
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U152
126-98-7
2-Propenenitrile, 2-methyl- (I,T)
U008
79-10-7
2-Propenoic acid (I)
U113
140-88-5
2-Propenoic acid, ethyl ester (I)
U118
97-63-2
2-Propenoic acid, 2-methvl-, ethyl ester
U162
80-62-6
2-Propenoic acid, 2-methvl-, methyt ester (I,T)
U373
122-42-9
Propham
U411
114-26-1
Propoxur
U387
52888-80-9
Prosulfocarb
U194
107-10-8
n-Propvlamine (I,T)
U083
78-87-5
Propylene dichloride
U148
123-33-1
3,6-Pvridazinedione, 1,2-dihydro-
U196
110-86-1
Pyridine
U191
109-06-8
Pyridine, 2-methyl-
U237
66-75-1
2,4-( 1 H,3H)-Pyrimidinedione, 5-[bis(2-chloroethyl)amino]-
U164
56-04-2
4( 1 H)-Pyrimidinone, 2,3-dihydro-6-methyl-2-thioxo-
U180
930-55-2
Pyrrolidine, 1-nitroso-
U200
50-55-5
Reserpine
U201
108-46-3
Resorcinol
U202
'81-07-2
Saccharin and salts
U203
94-59-7
Safrole
U204
7783-00-8
Selenious acid
U204
7783-00-8
Selenium dioxide
U205
7488-56-4
Selenium sulfide (SeS2) (R,T)
U376
144-34-3
Selenium, tetrakis(dimethyldithiocarbamate)
U0L5
115-02-6
L-Serine, diazoacetate (ester)
See F027
93-72-1
Silvex (2,4,5-TP)
U379
136-30-1
Sodium dibutvldithiocarbamate
December 1996
5-038
-------
Hazardous Waste
Part I, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U381
148-18-5
Sodium diethvldithiocarbamate
U382
128-04-1
Sodium dimethyldithiocarbamate
U206
18883-66-4
Streptozotocin
U103
77-78-1
Sulfuric acid, dimethvl ester
U277
95-06-7
Sulfallate
UL89
1314-80-3
Sulfur phosphide (R)
See F027
93-76-5
2.4.5-T
U402
1634-02-2
Tetrabutvlthiuram disulfide
U207
95-94-3
1,2,4,5-Tetrachlorobenzene
U208
630-20-6
1,1,1,2-Tetrachloroethane
U209
79-34-5
1,1,2,2-Tetrachloroethane
U2I0
127-18-4
Tetrachloroethylene
See F027
58-90-2
2,3,4,6-Tetrachlorophenol
U213
109-99-9
Tetrahvdrofuran (I)
U401
97-74-5
Tetramethylthiuram monosulfide
U214
563-68-8
Thallium (I) acetate
U215
6533-73-9
Thallium (I) carbonate
U216
7791-12-0
Thallium (I) chloride
U21o
7791-12-0
Thallium chloride (T1C1)
U217
10102-45-1
Thallium (I) nitrate
U366
533-74-4
2H-1,3,5-Thiadiazine-2-thione, tetrahydro-3,5-dimethyl-
U218
62-55-5
Thioacetamide
U4I0
59669-26-0
Thiodicarb
U153
74-93-1
Thiomethanol (I,T)
U244
137-26-8
Thioperoxvdicarbonic diamide ([(H2N)C(S)]2S2), tetramethvl-
U402
1634-02-2
Thioperoxvdicarbonic diamide, tetrabutyl
U403
97-77-8
Thioperoxvdicarbonic diamide, tetraethvl
December 1996
5-D39
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Hazardous Waste
Part I, Chapter 5
Table 5D-4
U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U409
23564-05-8
Thiophanate-methyl
U2I9
62-56-6
Thiourea
U244
137-26-8
Thiram
U220
108-88-3
Toluene
U221
25376-45-8
Toluenediamine
U223
26471-62-5
Toluene diisocyanate (R,T)
U328
95-53-4
o-Toluidine
U353
106-49-0
p-Toluidine
U222
636-21-5
o-Toluidine hydrochloride
U389
2303-17-5
Triallate
U01 1
61-82-5
1H-1,2,4-Triazol-3-amine
U227
79-00-5
1,1,2-Trichloroethane
U228
79-01-6
Trichloroethylene
LM 2 I
75-69-4
Trichloromonofluoromethane
See F027
95-95-4
2,4,5-Trichlorophenol
See F027
88-06-2
2,4,6-Trichlorophenol
U404
121-44-8
Triethvlamine
U234
99-35-4
1,3,5-Trinitrobenzene (R,T)
U182
123-63-7
1,3,5-Trioxane, 2,4,6-trimethvl-
U235
126-72-7
Tris(2,3-dibromopropyl) phosphate
U236
72-57-1
Trypan blue
U237
66-75-1
Uracil mustard
U176
759-73-9
Urea, N-ethyl-N-nitroso-
U177
684-93-5
Urea, N-methvl-N-nitroso-
U385
1929-77-7
Vernolate
U043
75-01-4
Vinvl chloride
U248
'81-81-2
Warfarin and salts, when present at concentrations of 0.3% or
less
December 1996
5-D40
-------
Hazardous Waste
Part 1, Chapter 5
Table 5D-4 U-Listed Wastes (Hazardous Discarded Chemicals)
Hazardous
Waste No.
Chemical Abstracts
No.
Substance
U239
1330-20-7
Xylene (I)
U200
50-55-5
Yohimban-16-carboxylic acid, 11,17-dimethoxy-18-[(3,4,5-
trimethoxybenzoyl)oxy]-, methyl ester,
(3beta, 16beta, 17alpha, 18beta,20alpha)-
U407
14324-55-1
Zinc, bis(diethylcarbamodithioato-S,S')-
U249
1314-84-7
Zinc phosphide (Zn3P2), when present at concentrations of
10% or less
1 Chemical Abstracts number given for parent compound only.
December 1996
5-D41
-------
APPENDIX 5-E
REGULATORY LEVELS OF THE TOXICITY CHARACTERISTIC
LEACHATE PROCEDURE (TCLP)
-------
Hazardous Waste
Part I, Chapter 5
Table 5-E Regulatory Levels of the Toxicity Characteristic Leachate Procedure
(TCLP)
EPA Hazardous Waste
Number
Contaminant
Chemical
Abstracts No.
Regulatory Level
(mg/L)
D004
Arsenic
7440-38-2
5.0
D005
Barium
7440-39-3
100.0
DO 18
Benzene
71-43-2
0.5
D006
Cadmium
7440-43-9
1.0
DO 19
Carbon tetrachloride
56-23-5
0.5
D020
Chlordane
57-74-9
0.03
D021
Chlorobenzene
108-90-07
100.0
D022
Chloroform
67-66-3
6.0
D007
Chromium
7440-47-3
5.0
D023
o-Cresol
95-48-7
200.0
D024
m-Cresol
108-39-4
200.0
D025
p-Cresol
106-44-5
200.0
D026
Cresol
200.0
D016
2,4-D
94-75-7
10.0
D027
1,4-Dichlorobenzene
106-46-7
7.5
D028
1,2-Dichloroethane
107-06-02
0.5
D029
1,1 -Dichloroethylene
75-35-4
0.7
D030
2,4-Nitrotoluene
121-14-2
0.13
DO 12
Endrin
72-20-8
0.02
D031
Heptachlor (and its epoxide)
76-44-8
0.008
D032
Hexachlorobenzene
118-74-1
0.13
D033
Hexachlorobutadiene
87-68-3
0.5
D034
Hexachloroethane
67-72-1
3.0
D008
Lead
7439-92-1
5.0
DO 13
Lindane
58-89-9
0.4
D009
Mercury
7439-97-6
0.2
DOM
Methoxvchlor
72-43-5
10.0
December 1996
5-E1
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Hazardous Waste
Part I, Chapter 5
Table 5-E Regulatory Levels of the Toxicity Characteristic Leachate Procedure
(TCLP)
EPA Hazardous Waste
Number
Contaminant
Chemical
Abstracts No.
Regulatory Level
(mg^L)
D035
Methvl ethvl ketone
78-93-3
200.0
D036
Nitrobenzene
98-95-3
2.0
D037
Pentachlorophenol
87-86-5
100.
D038
Pyridine
1 10-86-1
5.0
D010
Selenium
7782-49-2
1.0
D011
Silver
7440-22-4
5.0
D039
Tetrachloroethvlene
127-18-4
0.7
DO 15
Toxaphene
8001-35-2
0.5
D040
T richloroethvlene
79-01-6
0.5
D041
2,4,5-Trichlorophenol
95-95-4
400.0
D042
2,4,6-Trichlorophenol
88-06-2
2.0
DO 17
2,4,5-TP (Silvex)
93-72-1
1.0
D043
Vinyl chloride
75-01-4
0.2
Note: If o-, m-, and p-Cresol concentrations cannot be differentiated, the total cresol (D026) concentration
is used. The regulatory level for total cresol is 200 mg'L.
December 1996
5-E2
-------
APPENDIX 5-F
REQUIREMENTS RELATED TO WASTES CONTAINING
ECONOMICALLY RECOVERABLE QUANTITIES
OF PRECIOUS METALS
-------
Hazardous Waste Part I, Chapter 5
40 CFR 266
RECYCLABLE MATERIALS UTILIZED FOR PRECIOUS METAL RECOVERY
Subpart F—General
§266.70 Applicability and requirements.
(a) The regulations of this subpart apply to
recyclable materials that are reclaimed to recover
economically significant amounts of gold, silver,
platinum, palladium, iridium, osmium, rhodium,
ruthenium, or any combination of these, (b)
Persons who generate, transport, or store
recyclable materials that are regulated under this
subpart are subject to the following requirements:
(1) Notification requirements under section 3010
of RCRA; (2) Subpart B of part 262 (for
generators), §§ 263.20 and 263.21 (for
transporters), and §§ 265.71 and 265.72 (for
persons who store) of this chapter; © Persons
who store recycled materials that are regulated
under this subpart must keep the following
records to document that they are not
accumulating these materials speculatively (as
defined in § 261.1© of this chapter); (1) Records
showing the volume of these materials stored at
the beginning of the calendar year' (2) The
amount of these materials generated or received
during the calendar year; and (3) The amount of
materials remaining at the end of the calendar
vear. (D) Recyclable materials that are regulated
under this subpart that are accumulated
speculatively (as defined in § 261.1© of this
chapter) are subject to all applicable provisions of
parts 262 through 265, 270 and 124 of this
chapter.
December 1996
5-F1
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Hazardous Waste
Part I, Chapter 5
40 CFR261
IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
Subpart A—General
261.2 Definition of solid waste.
(8) A material is "accumulated speculatively" if it
is accumulated before being recycled. A material
is not accumulated speculatively, however, if the
person accumulating it can show that the material
is potentially recyclable and has a feasible means
of being recycled; and that—during the calendar
year (commencing on January 1)—the amount of
material that is recycled, or transferred to a
different site for recycling, equals at least 75
percent by weight or volume of the amount of
that material accumulated at the beginning of the
period. In calculating the percentage of turnover,
the 75 percent requirement is to be applied to
each material of the same type {e.g., slags from a
single smelting process) that is recycled in the
same way (i.e., from which the same material is
recovered or that is used in the same way).
Materials accumulating in units that would be
exempt from regulation under § 261.4© are not
to be included in making the calculation.
(Materials that are already defined as solid wastes
also are not to be included in making the
calculation.) Materials are no longer in this
category once they are removed from
accumulation for recycling, however.
[45 FR 331 19. Mav 19. 1980, as amended at 48 FR 14293, Apr. I.
1983; 50 FR 663, Jan. 4. 1985; 51 FR 10174. Mar. 24. 1986; 5 1 FR
40636, Nov. 7, 1986]
December 1996
5-F2
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Hazardous Waste
Part I, Chapter 5
40 CFR261
IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
Subpart A—General
§ 261.24 Toxicity characteristic.
(a) A solid waste exhibits the characteristic of
toxicity if, using the Toxicity Characteristic
Leaching Procedure, test Method 1311 in "Test
Methods for Evaluating Solid Waste,
Phvsical/Chemical Methods," EPA Publication
SW-846, as incorporated by reference in §
260.11 of this chapter, the extract from a
representative sample of the waste contains any
of the contaminants listed in table 1 at the
concentration equal to or greater than the
respective value given in that table. Where the
waste contains less than 0.5 percent filterable
solids, the waste itself, after filtering using the
methodology oudined in Method 1311, is
considered to be the extract for the purpose of
this section.
(b) A solid waste that exhibits the
characteristic of toxicity has the EPA Hazardous
Waste Number specified in Table I which
corresponds to the toxic contaminant causing it to
be hazardous.
Table 1—maximum Concentration of
Contaminants for the Toxicity Characteristic
EPA
HW
No.'
Contaminant
CAS No.!
Regul-
atory
Level
(mtyT-)
D004
Arsenic
7440-38-2
5.0
D005
Barium
7440-39-3
100.0
DO 18
Benzene
71-43-2
0.5
D006
Cadmium
7440-43-9
1.0
DO 19
Carbon tetrachloride
56-23-5
0.5
D020
Chlordane
57-74-9
0.03
D021
Chlorobenzene
108-90-7
100.0
D022
Chloroform
67-66-3
6.0
D007
Chromium
7440-47-3
5.0
D023
o-Cresol
95-48-7
200.0
D024
m-Cresol
108-39-4
200.0
D025
p-Cresol
106-44-5
'200.0
D026
Cresol
-
'200.0
DO 16
2,4-D
94-75-7
10.0
D027
1,4-Dichlorobenzene
106-46-7
7.5
0028
1,2-Dichloroethane
107-06-2
0.5
D029
1,1 -Dichloroethvlene
75-35-4
0.7
D030
2,4-Dinitjotoluene
121-14-23
0.13
DO 12
Endrin
72-20-8
0.02
D031
Heptachlor (and its ep-
oxide)
76-44-8
0 008
D032
Hexachloro benzene
118-74-1 3
0 13
D033
Hexachlorobutadiene
87-68-3
0.5
D034
Hexachloroe thane
67-72-1
3.0
D008
Lead
7439-92-1
5.0
D013
Lindane
58-89-9
0.4
D009
Mercury
7439-97-6
0.2
DO 14
Methoxvchlor
72-43-5
10.0
D035
Methyl ethyl ketone
78-93-3
200.0
D036
Nitrobenzene
98-95-3
2.0
D037
Pentrachlorophenol
87-86-5
100.0
D038
Pyridine
110-86-1 3
35.0
D010
Selenium
7782-49-2
1.0
D011
Silver
7440-22-4
5.0
D039
T etrachloroethvlene
127-18-4
0.7
DO 15
Toxaphene
8001-35-2
0.5
D040
T richloroethylene
79-01-6
0.5
D041
2,4.5-Triehlorophenol
95-95-4
400.0
D042
2,4,6-T richlorophenol
88-06-2
2.0
DO 17
2.4,5-TP (Silvex)
93-72-1
1.0
D043
Vinvl chloride
75-01-4
0.2
' Hazardous waste number.
December 1996
5-F3
-------
Hazardous Waste
Part I, Chapter 5
2 Chemical abstracts service number.
' Quantitation limit is greater than the calculated regulatory
level. The quantitation limit therefore becomes the
regulatory level.
' If o-, m-, and p-Cresol concentrations cannot be
differentiated, the total cresol (D026) concentration is used.
The regulatory level of total cresol is 200 mg/1.
[55 FR 1 1862, Mar. 29, 1990, as amended at 55 PR 22684.
June I, 1990; 55 FR 26987, June 29, 1990, 58 FR 46049,
Aug. 31, 1993]
December 1996
5-F4
-------
Hazardous Waste
Part I, Chapter 5
40 CFR266
STANDARDS FOR THE MANAGEMENT OF SPECIFIC HAZARDOUS WASTES
AND SPECIFIC TYPES OF HAZARDOUS WASTE MANAGEMENT FACILITIES
Subpart F—Recyclable Materials Utilized for Precious Metal Recovery
§ 266.70 Applicability and requirements.
(a) The regulations of this subpart apply to
recyclable materials that are reclaimed to recover
economically significant amounts of gold, silver,
platinum, paladium, irridium, osmium, rhodium,
ruthenium, or any combination of these.
(b) Persons who generate, transport, or store
recyclable materials that are regulated under this
subpart are subject to the following requirements:
(1) Notification requirements under section
3010 of RCRA;
(2) Subpart B of part 262 (for generators), §§
263.20 and 263.21 (for transporters), and §§
265.71 and 265.72 (for persons who store) of this
chapter;
(c) Persons who store recycled materials that are
regulated under this subpart must keep the
following records to document that they are not
accumulating these materials speculatively (as
defined in § 261.1 (c) of this chapter);
(1) Records showing the volume of these
materials stored at the beginning of the calendar
year;
(2) The amount of these materials generated or
received during the calendar year; and
(3) The amount of materials remaining at the
end of the calendar year.
(d) Recyclable materials that are regulated under
this subpart that are accumulated speculatively
(as defined in § 261.1(c) of this chapter) are
subject to all applicable provisions of parts 262
through 265, 270 and 124 of this chapter.
December 1996
5-F5
-------
APPENDIX 5-G
CRITERIA USED TO CONSIDER A CONTAINER EMPTY
-------
Hazardous Waste
Part I, Chapter 5
CRITERIA USED TO CONSIDER A CONTAINER EMPTY
EPA's definition of "empty" is critical to the proper handling of waste containers and the
liners of waste containers. If a container is empty, neither the container nor the liner is
subject to any RCRA regulation. This means that you can throw the container and/or
the liner away without any problems.
It is possible, however, that a container might look empty to you but not meet EPA's
standards for emptiness. In this case, you would either have to meet EPA's emptiness
standards or treat the container or liner as hazardous waste. Furthermore, if the waste
was acutely hazardous, its non-empty container or the liner from its non-empty container
is considered acutely hazardous waste.
In short, you must check to see whether or not your containers are empty before you
dispose of them or dispose of liners from them.
To meet EPA standards for emptying a container that contained acutely hazardous waste
you must do one of the following:
¦ Triple rinse the container using a solvent capable of removing the appropriate
residues.
¦ Clean the container using a method that has been shown scientifically to be as
effective as triple rinsing
¦ Removing the liner and disposing of it as acutely hazardous waste.
To meet EPA standards for emptying a container that contained regular hazardous waste
you must do one of the following:
¦ Remove as much of the contents as possible by any practical method, making sure
that no more than 1 inch of residue remains at the bottom of the container.
¦ Remove as much of the contents as possible by any practical method, making sure
that no more than 0.3 percent of the weight of the total capacity of the container
remains in the container. If the container holds 110 gallons or less, this cutoff is
relaxed to 3 percent.
December 1996
5-G1
-------
Hazardous Waste
Part I, Chapter 5
When is a Container Empty?
Example 1: You fill a 50-gallon lined container with hydrocyanic acid, an acutely
hazardous waste. After dispensing the acid from the container until it is used up,
you remove the liner from the container. You must now dispose of the liner as
acutely hazardous waste and can reuse the container or dispose of it as
nonhazardous waste.
Example 2: You purchase a 50-gallon container which weighed 20 lbs. when you
bought it. You then fill it with concentrated hydrochloric acid and weigh it again.
The full container weighs 520 lbs., so the weight of the full capacity of the drum is
500 lbs. By EPA standards, an empty container can contain no more than 15 lbs.
(500 * 3%) of its original contents. You then dispense the acid from the container
until it is used up. After the acid is used up, you find that the container weighs 25
lbs. The container therefore contains 5 lbs. (25-20) of residue, which is within the
amount allowable. You can consider the container empty and can dispose of it as
nonhazardous waste.
December 1996
5-G2
-------
APPENDIX 5-H
TOXICITY CHARACTERISTIC LEACHING PROCEDURE
-------
START
-------
APPENDIX 5-1
OVERVIEW OF THE RCRA PERMIT PROGRAM
-------
Hazardous Waste
Part I, Chapter 5
Overview of the RCRA Permit Program
Permits are required under RCRA for all facilities that treat, store (for more
than the regulatory maximum number of days), or dispose of hazardous waste
(generally referred to as TSD facilities). Metal finishers who disposed of
waste on their property are often considered TSD facilities. The RCRA
permit application consists of two parts: a Part A permit application and a
Part B permit application:
¦ The Part A application consists of a fairly simple and straightforward
form requiring general facility information such as names, addresses,
telephone numbers, descriptions of regulated activities and waste
management processes, identification of other permits, and facility
maps. In general, existing facilities subject to RCRA permitting
probably filed a Part A permit years ago. Part A permits have been
required for most TSDs since 1980. For new facilities, Part A
applications are due prior to the start of physical construction. Part A
permits provide regulated facilities with authorization to operate on an
interim basis under RCRA. Final approval of facilities, however,
requires submission and approval of a Part B application.
¦ The Part B application is required prior to the start of construction for a
new facility; is required in 6 months when specifically "called" for by
the EPA or an EPA-authorized RCRA state; or can be voluntarily
submitted by an interim facility to hasten the issuing of a full operating
permit. Part B permit applications are far from simple and
straightforward. Typical Part B applications are several volumes long
and include waste analyses plans, contingency plans, closure plans,
post-closure plans, preparedness and prevention plans, design criteria,
insurance requirements, and financial assurance mechanisms, to name
but a few items. Not surprisingly, few Part B applications are
submitted voluntarily.
September 1996
5-11
-------
APPENDIX 5-J
EPA RCRA CONTACT LIST
-------
Hazardous Waste
Part I, Chapter 5
EPA RCRA Contact List
Region 1
One Congress Street
John F. Kennedv Federal Building
Boston, MA 02203-0001
Kevin McSweeney, Associate Director
Waste Policy Division
Office of Ecosystem Protection (CAA)
Telephone No. 617-565-3559
Fax No. 617-565-4940
Secretary: Virginia Ranauro-Walshe 617-565-
3478
Region 2
290 Broadwav
New York, NY 10007-1866
George C. Meyer
Hazardous Waste Compliance Branch
(2AWM/HWF)
Telephone 212-637-4144
Fax No. 212-637-4949
Secretary: Brenda Lawson, 212-637-4145
Andrew J. Bellina, Chief
Hazardous Waste Facilities Branch
Telephone No. 212-637-4109
Fax No. 212-637-4437
Region 3
841 Chestnut Street
Philadelphia, PA 19017
Maria Parisi Vickars
Office of RCRA Programs (3HW03)
Telephone No. 215-566-149
Fax No. 215-566-31 14
Secretary, Sondra Allen 215-566-3110
Region 4
345 Courtland Street, N.E.
Atlanta, GA 30365
Alan Farmer (Permits)
RCRA Branch
Waste Management Division
Telephone No. 404-347-3433
Fax No. 404-347-0076
Kent Williams, Acting Chief
RCRA Permitting Section
Waste Management Division (4WD-RCRA)
Telephone No. 404-347-3433
Fax No. 404-347-1918
Jeaneanne Williams, Acting Chief
RCRA Compliance Section
Waste Management Division
Telephone No. 404-347-7603
Fax No. 404-347-5202
Region 5
77 West Jackson Boulevard
Chicago, IL 60604
Karl Bremer (CA &. Permits)
Waste Management Branch
Waste, Pesticides St Toxics Division (DRP-8J)
Telephone No. 312-353-0398
Fax No. 312-353-4788
Gerald Phillips
Telephone No. 312-886-0977
Fax No. 312-353-6514
Region 6
First Interstate Bank Tower at Fountain Place
12th Floor, Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
Stephen A Gilrein (Permits)
RCRA, Multimedia Planning &. Permitting
Division (6PL)
Telephone No. 214-665-8179
Fax No. 214-665-2 164
Secretary, Janice Garland 214-665-7200
Region 7
726 Minnesota Avenue
Kansas City, ICS 66101
Larry Hacker (CA, Permits for Iowa and all SP)
Air, RCRA, &. Toxics Division
Telephone No. 913-551-7602
Fax No. 913-551-7521
Secretary, T.R. Lohmever 913-55 1-7676
September 1996
5-J1
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Hazardous Waste
Part 1, Chapter 5
JoAnn M. Heiman (CA &. Permits)
RCRA Permitting &. Compliance Branch
Air, RCRA, &. Toxics Division
Telephone No. 913-551-7323
Fax No. 913-551-7947
Region 8
999 18th Street
Suite 500
Denver, CO 80202-2466
Wanda Taunton, Director
Hazardous Waste Program (8P2-HW)
Telephone No. 303-312-7081
Fax No. 303-312-6064
Secretary, Judy Geise 303-312-6421
Paul Arell, Manager
Corrective Action Unit (8P2-SA)
Hazardous Waste Program
Telephone No. 303-312-6649
Fax No. 303-312-6064
Tom Bums, Team Leader
State Liaison—Assistance Team
(8P2-HW)
Telephone No. 303-312-6421
Fax No. 303-312-6064
Martin Hestmark, Director
Technical Enforcement
(8ENF-T)
Telephone No. 303-312-6778
Fax No. 303-312-6897
Jack Hidinger, Director
Pollution Prevention Program (Solid Waste)
(8P2-P2)
Telephone No. 303-312-6004
Fax No. 303-312-6363
Carol Rushin, Assistant RA
Office of Enforcement, Compliance and
Environmental Justice
(8-ENF)Telephone No. 303-312-
6406
Fax No. 303-312-6558 (or use 6191
[temporary])
Region 9
75 Hawthorne Street
San Francisco, CA94105
Richard Vaile
Waste Compliance Branch
Telephone No. 415-744-2090
Fax No. 415-744-1044
Secretary, Buu Quach 415-744-2108
Michael Feeley (Permits &. CA)
Facilities Branch (H-3)
Telephone No. 415-744-2138
Fax No. 415-744-1044
Secretary, Susan Chiu 415-744-2060
Region 10
1200 Sixth Avenue
Seattle, WA 94105
Michael Bu ;ell
Office of Waste and Chemicals Management
(WCM-127)
Telephone No. 206-553-4198
Fax No. 206-553-8509
Korina Layne-Jones
Resources Managment &. State Programs Unit
(WCM-122)
Telephone No. 206-553-6915
Fax No. 206-553-8509
Kerrigan G. Clough, Assistant RA
Office of P-2, State &. Tribal Programs
(8P-2)
Telephone No. 303-312-6241
Fax No. 303-312-6038
September 1996
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Notes
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CHAPTER 6
Underground Storage Tanks
6.1 Federal Requirements (RCRA Subtitle 1) 6-3
6.1.1 What Do the Federal UST Requirements Cover? 6-3
6.1.2 Who Is the Implementing Agency? 6-6
6.1.3 Do the Federal Regulations Apply to USTs at My Metal Finishing Operation? 6-7
6.1.4 What Are the Performance Requirements for New USTs? 6-9
6.1.5 What Are the Performance Requirements for Existing USTs? 6-13
6.1.6 What Operating Requirements Apply to USTs at My Facility?. 6-14
6.1.7 What Must I Do To Detect Leaks? 6-15
6.1.8 What Should I Do if I Think My Tank Is Leaking? 6-20
6.1.9 What Should I Do if I Find a Leak or if a Spill or Overflow Occurs? 6-22
6.1.10 Can Leaking Tanks and Pipes Be Repaired? 6-25
6.1.11 How Do I Close an UST? 6-26
6.1.12 What Are My Financial Responsibilities if I Own or Operate a Petroleum UST? 6-28
6.2 State Requirements 6-29
6.3 Where To Go for More Information 6-29
Underground storage tank systems (including tanks and attached piping)
can cause serious contamination and safety problems if their contents leak
into surrounding soil and ground water. The U.S. Environmental Protection
Agency has established regulations to prevent and mitigate contamination from
underground storage tank systems (often referred to as USTs) that contain
certain chemicals or petroleum products. Some, but not all, USTs typically
found at metal finishing operations are covered by these regulations. Many
states and some localities have more stringent requirements. This chapter
provides a detailed description of the federal UST rule. It also provides a brief
overview of state rules.
If you own or operate an underground storage tank system, be sure to read this
chapter. You will find out whether your UST is covered by the federal
regulations. You also will receive guidance about how to comply with these
regulations. Appendix 6-A provides a summary of the schedule for the various
activities required by the federal UST rule. In many cases, you will need to use
methods and equipment, that meet standard industry codes. Be sure to check
with your state and local authorities about any additional requirements for
USTs in your area.
December 1996
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Underground Storage Tanks Part I, Chapter 6
6.1 Federal Requirements (RCRA Subtitle I) 6-3
6.1.1 What Do the Federal UST Requirements Cover? 6-3
6.1.2 Who Is the Implementing Agency? 6-6
6.1.3 Do the Federal Regulations Apply to USTs at My Metal Finishing Operation? 6-7
6.1.4 What Are the Performance Requirements for New USTs? 6-9
6.1.4.1 Protecting Tanks and Piping From Corrosion 6-11
6.1.4.2 Installing UST Systems the Right Way 6-11
6.1.4.3 Preventing Spills and Overfills 6-12
6.1.5 What Are the Performance Requirements for Existing USTs? 6-13
6.1.6 What Operating Requirements Apply to USTs at My Facility? 6-14
6.1.6.1 Preventing Spills and Overfills 6-14
6.1.6.2 Corrosion Protection 6-14
6.1.6.3 Compatibility 6-15
6.1.7 What Must I Do To Detect Leaks? 6-15
6.1.7.1 Detecting Leaks From New Tanks 6-15
6.1.7.2 Detecting Leaks From Piping in New USTs 6-17
6.1.7.3 Additional Requirements for New Chemical USTs 6-18
6.1.7.4 What About Existing USTs? 6-19
6.1.7.5 What Leak Detection Records Must I Keep? 6-20
6.1.8 What Should I Do if I Think My Tank Is Leaking? 6-20
6.1.8.1 Warnings From Equipment 6-21
6.1.8.2 Warnings in the Environment 6-21
6.1.8.3 Conducting a Site Check 6-22
6.1.9 What Should I Do if I Find a Leak or if a Spill or Overflow Occurs? 6-22
6.1.9.1 Initial Response 6-22
6.1.9.2 Initial Abatement 6-23
6.1.9.3 Corrective Action Plan 6-24
6.1.9.4 Long-Term Abatement 6-25
6.1.10 Can Leaking Tanks and Pipes Be Repaired? 6-25
6.1.10.1 Tanks 6-25
6.1.10.2 Pipes 6-26
6.1.11 How Do I Close an UST? 6-26
6.1.11.1 Temporary Closure 6-26
6.1.11.2 Permanent Closure 6-27
6.1.11.3 Changing From a Regulated Substance to a Nonregulated Substance 6-28
6.1.12 What Are My Financial Responsibilities if I Own or Operate a Petroleum UST? 6-28
6.2 State Requirements 6-29
6.3 Where To Go for More Information 6-29
Appendix 6-A Compliance Calendar for the Federal UST Requirements
Appendix 6-B CERCLA Hazardous Substances Typically Used by Metal Finishers
Appendix 6-C Guides to Compliance With Federal UST Regulations
December 1996 6-2
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Underground Storage Tanks
Part I, Chapter 6
Underground Storage Tank Regulations: How To Comply
~ Identify all USTs at your facility and determine whether they are covered by the
UST regulations (Section 6.1.3).
~ Check to make sure that any USTs installed at your facility since December 22,
1988 meet the performance requirements for "new USTs" described in Section 6.1.4.
~ Make sure that any USTs installed at your facility in the future meet the
performance requirements for new USTs.
~ By December 22, 1998, upgrade or close any USTs installed at your facility on or
before December 22, 1988 (Section 6.1.5).
~ Make sure all active USTs at your facility meet the general operating requirements
described in Section 6.1.6.
~ Make sure you are using appropriate methods to detect leaks from all USTs at your
facility (Section 6.1.7).
~ Investigate and report any suspected leaks from your UST (Section 6.1.8).
~ Contain, report, and clean up any spills, overfills, or confirmed leaks. Investigate,
mitigate, and report any damage caused by releases (Section 6.1.9).
~ When vou repair an UST, be sure to follow the appropriate requirements (Section
6.1.10).
~ When you close an UST, either temporarily or permanently, make sure you follow
the requirements for closure (Section 6.1.11).
~ If your UST contains petroleum, you will need to demonstrate that you can pay for
site remediation, property damage, and third-party injury if your UST leaks (Section
6.1.12).
6.1 Federal Requirements (RCRA Subtitle I)
6.1.1 What Do the Federal UST Requirements Cover?
Federal UST regulations are contained in Subtitle I of the Resource
Conservation and Recoverv Act (RCRA). Thev are designed to
prevent and correct the problems that can be caused bv leaks and
spills from USTs. Box 6-1 describes some of the problems that may
December 1996
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Underground Storage Tanks
Part I, Chapter 6
be caused by USTs. EPA estimated that as many as 25 percent of
all underground storage tanks were leaking around 1988 when the
UST regulations were promulgated. Complying with UST
regulations reduces the chance that your tank will leak. It also helps
to ensure prompt discovery of the leak so that you can minimize the
cleanup costs and potential liability you may incur by
contaminating the local environment.
Box 6-1 Why Do USTs Cause Problems?
Corrosion
Many older UST systems are made of bare steel. Unprotected
steel that is buried in the ground can be eaten away by
corrosion. For this reason, the federal UST regulations require
corrosion protection for USTs.
Installation Errors
Tanks and piping can leak if they are not properlv installed. For
this reason, the federal regulations require you to make sure
your USTs are installed using standard industry procedures.
Overfills and Spills
Overfills and spills are the cause of many UST releases.
Overfills result when more liquid is delivered to a tank than it
can hold. Spills are caused when a delivery hose is incorrectly
disconnected. You are responsible for preventing spills and
overfills when your tank is being filled.
Pip ing Failures
Studies show that most leaks res Jts from piping failures. Piping
is more vulnerable to failure than tanks because it is smaller, less
sturdy, and often installed near the ground surface. For this
reason, the regulations applv to the entire UST system,
including tanks and piping.
Here are some of the key requirements you must meet if your UST
is covered by the regulations:
¦ Any USTs you have installed since December 22, 1988, or
install in the future must meet requirements for correct
installation, spill and overfill prevention, corrosion
protection, and leak detection.
¦ Bv December 22, 1998, you will have to upgrade older USTs
(installed on or before December 22, 1988) to meet the
requirements for leak detection, corrosion protection, and
spill and overfill prevention.
December 1996
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Underground Storage Tanks
Part I, Chapter 6
¦ All vour USTs must meet operating requirements designed to
prevent spills and overfills and minimize the chance of
corrosion.
¦ If an UST leaks or a spill occurs, you must report the release
and take corrective action.
¦ When you close an UST, either permanently or temporarily,
you must follow certain closure requirements.
¦ If your UST contains petroleum, you are financially
responsible for cleaning up a leak and for compensating others
for bodily injury or property damage caused by the leak.
¦ You must provide various reports and keep certain records of
your compliance.
For many activities, such as installing and repairing USTs and
protecting them from corrosion, you will need to make sure that
recognized industry codes of practice are followed. Any code of
practice developed by a nationally recognized association or
independent testing laboratory will fulfill this requirement.
Some of the federal UST requirements are very detailed. From time
to time, this chapter will suggest that you refer to the original
regulation to obtain complete information about the regulatory
requirement. The subpart of the regulation being discussed in each
section is indicated in parentheses in the section title. Reporting
and recordkeeping requirements are discussed throughout this
chapter and summarized in Appendix 6-A.
The UST regulations refer to "new USTs" and "existing USTs."
Definitions for these terms are provided in Box 6-2. A number of
USTs are exempt from the federal regulations. Exempted USTs are
listed in Box 6-3. Section 6.1.3 provides more information on
exemptions.
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Underground Storage Tanks
Part I, Chapter 6
Box 6-2 What Is An UST? A "New" UST? An "Existing" UST?
UST
An UST is any tank or combination of tanks and attached
piping that holds more than 110 gallons of a regulated
substance and has at least 10 percent of its volume
underground.
"New UST"
A "new UST" is any regulated UST installed after December
22, 1988, when the UST regulations went into effect.
"Existing UST"
An "existing UST" is any regulated UST installed on or before
December 22, 1988.
Box 6-3 Which USTs Are Exempt From the Regulations?
¦ Tanks containing any substance regulated as a hazardous waste under RCRA
Subtitle C.
¦ Tanks holding 110 gallons or less.
¦ Tanks containing only a trivial concentration of a regulated substance. (The term
"trivial" may be interpreted in different ways. Check with your implementing
agency for a working definition.)
¦ Tanks storing heating oil used on the premises where it is stored.
¦ Tanks on or above the floor of underground areas, such as basements and tunnels.
¦ Flow-through process tanks.
¦ Emergency spill and overfill tanks if emptied expeditiously.
¦ Septic tanks and systems for collecting storm water and wastewater.
¦ Other storage areas, such as surface impoundments and pits.
6.1.2 Who Is the Implementing Agency?
States can assume primary responsibility for implementing the
federal UST regulations. To do so, a state must demonstrate that
its program is at least as stringent as the federal UST program. As
of September 30, 1996, 22 states were authorized to implement the
federal UST regulations. Check Box 6-4 to see if vour state has
been given this authority. If not, you can call the RCRA Hotline at
1-800-535-0202 to get the most recent information on vour state's
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Underground Storage Tanks
Part I, Chapter 6
status. Table 6-1 in Section 6.2 provides contact information for
state programs.
Box 6-4 States With Approved UST Programs*
Arkansas
Maryland
Oklahoma
Connecticut
Massachusetts
Rhode Island
Delaware
Mississippi
South Dakota
Georgia
Montana
Texas
Iowa
Nevada
Utah
Kansas
New Hampshire
Vermont
Louisiana
New Mexico
Washington
Maine
North Dakota
* Current as of March 25, 1996. Call the RCRA Hotline at I -800-535-0202
to get the most current information on the status of state UST programs.
EPA is responsible for implementing the federal UST regulations in
states that do not have EPA-approved UST programs. The term
"implementing agency" in this chapter refers to the state agency if
it has implementation authority or to EPA if the state does not have
implementation authority.
State implementing agencies may modify some of the deadlines and
triggers for certain reporting requirements. Also, your state may
require you to do more than the federal regulations described here.
Be sure to check with the UST agency for your state to find out
about any differences between state and federal requirements.
6.1.3 Do the Federal Regulations Apply to USTs at My Metal
Finishing Operation?
Box 6-5 lists the types of USTs typically found at metal finishing
operations that are subject to federal UST regulations. Whether
your tank is covered by the federal rule depends on a few factors.
First, you'll need to find out whether your tank contains any
substance regulated as a hazardous waste under Subtitle C of
RCRA. If so, the tank is covered by Subtitle C but is exempt from
the Subtitle I rule described in this chapter. Appendix 5-D in
Chapter 5 provides a list of Subtitle C substances. If vour tank
contains anv of these listed substances, check with vour state UST
agencv and/or local fire marshal to find out if it is regulated under
December 1996 6-7
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Underground Storage Tanks
Part I, Chapter 6
state regulations. (Local fire marshals often are knowledgeable
about UST regulations because they approve UST removals.) Skip
the rest of this chapter and refer to Chapter 5 for the pertinent
regulations.
Box 6-5 Which USTs Typically Found at Metal Finishing Operations Are Subject
to Federal UST Regulations?
Type of UST
Subject to Federal UST Regulations?
USTs containing gasoline.
Probably. Review Section 6.1.3.
USTs containing heating oil.
Not if you use the heating oil on the premises.
USTs containing machining
fluids.
Fluids temporarily stored in small in-process holding
sumps are not subject. Petroleum-based lubricants
stored in bulk may be subject. Review Section 6.1.3.
USTs that are part of a
wastewater treatment system.
No.
USTs designed for emergency
correction and containment of
chemicals or wastewaters.
No.
USTs containing solvents or
othtr hazardous chemicals.
Probably. Review Section 6.1.3.
USTs containing hazardous
wastes.
No.
Assuming your tank does not contain a Subtitle C substance, here
are some of the key factors that determine whether your tank is
subject to Subtitle I regulations:
¦ How large is the tank? Subtitle I applies to tanks that are
greater than 110 gallons in size. Tanks that are 110 gallons
or smaller in size are exempt.
¦ What's in the tank? The Subtitle I rule applies to tanks
containing two tvpes of substances:
Chemicals listed as "hazardous" in the Comprehensive
Environmental Response, Compensation and Liabilitv
Act of 1980 (CERCLA).
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Underground Storage Tanks
Part I, Chapter 6
Petroleum and liquid petroleum distillates. This includes
such substances as motor fuels, residual fuel oils,
lubricants, petroleum solvents, and used oils.
Tanks containing any other substances are not covered by
Subtitle I.
¦ How much of the tank system is underground? Only tank systems
(tanks and piping) with at least 10 percent of their volume
underground are covered by the Subtide I rule. Tank systems
with less than 10 percent of their volume underground are
exempt.
Review Box 6-5 to make a preliminary determination of whether
your UST is subject to the federal regulations. Consult Box 6-6 to
make a definitive determination.
6.1.4 What Are the Performance Requirements for New USTs
(Installed After December 22, 1988) (Subpart B)?
The federal regulation has different requirements for USTs that were
installed before and after December 22, 1988—the date the
regulations went into effect. USTs installed after this date are called
"new USTs." USTs installed on or before this date are called
"existing USTs." This section discussej the performance
requirements for new USTs. Section 6.1.5 discusses the
performance requirements for existing USTs.
New USTs must meet three performance requirements:
¦ You must protect the tank and piping from corrosion.
¦ You must certify that the tank and piping are installed
properly according to industry codes.
¦ You must equip the UST with devices that prevent spills and
overfills.
These requirements (from Subpart B of the regulation) are discussed
below. Remember, they apply to any UST that you installed after
December 22, 1988 or that you install in the future.
December 1996
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Underground Storage Tanks
Part I, Chapter 6
Box 6-6 Are My USTs Regulated?
1.
Does your tank contain a substance that is considered a hazardous waste under RCRA
Subtitle C?
Review Appendix 5-C in Chapter 5 to answer this question. If no, go to 2. Ifyes, your tank is
regulated under RCRA Subtide C hazardous waste regulations described in Chapter 5, and your
tank is not regulated under anv of the federal UST regulauons described in this chapter. Check
with your state UST agency listed in Table 6-1 to find out if it is regulated under state UST
regulations. Skip the rest of this chapter and go to Chapter 5. END
2.
Is at least 10 percent of the tank volume (including the volume of attached underground
piping) below the ground surface?
If yes, go to 4. If no, go to 3.
3.
Your tank is not regulated under federal UST regulations.
You can skip the rest of this chapter, but be sure to check with your state UST agency listed in
Table 6-1 to find out if your UST is regulated under state UST regulauons. END
4.
Does your tank contain a substance designated as a hazardous substance under CERCLA?
You can find the complete list of CERCLA hazardous substances in 40 CFR Part 302.4.
Appendix 6-B lists the CERCLA hazardous substances typically used by metal finishers. If yes, go
to 6. If no, go to 5.
5.
Does your tank contain petroleum, crude oil, or any fraction of crude oil that is liquid at
standard conditions of temperature and pressure (60°F and 14.6 lbs/in2)?
Ifyes, go to 6. If no, go to 3.
6.
Review the following questions. If you answerj>es to any question, go to 3. If you answer no to all
questions, go to 7.
¦ Does your tank hold no more than 110 gallons?
¦ Does your tank contain only a trivial ("de minimis") concentration of a regulated
substance? (Check with vour implementing agency to determine what concentration is
considered to be trivial.)
¦ Does your tank store heating oil used at your facility?
¦ Is the tank on or above the floor of an underground area, such as a basement or
tunnel?
¦ Is your tank a flow-through process tank?
¦ Is your tank used to hold emergency spills or overfills?
¦ Is your tank a septic tank or part of a system for collecting storm water or
wastewater?
7.
Your tank is regulated under the federal UST regulations (RCRA Subtitle I) described in
this chapter. END
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Underground Storage Tanks
Part I, Chapter 6
6.1.4.1 Protecting Tanks and Piping From Corrosion
Both the tank and piping in a new UST must be properly designed,
constructed, and protected from corrosion in accordance with an
industry code of practice. (Some of the publications listed in
Appendix 6-C provide references for industry codes of practice.)
The regulations allow several approaches to corrosion protection:
¦ Steel tanks and piping can be coated with a corrosion-
resistant material and cathodically protected. (Cathodic
protection works by reversing the naturally occurring electric
current in the ground.)
¦ Tanks and piping can be made of a noncorrodible material,
such as fiberglass-reinforced plastic.
¦ Tanks, but not piping, can be made of a steel-fiberglass-
reinforced-plastic composite.
¦ Tanks and piping can be protected by another method
approved by the implementing agency.
You don't have to provide corrosion protection for metal tanks if a
corrosion expert determines there is no danger of corrosion at the
site and you maintain records of this determination for the lifetime
of the UST. Check 40 CFR 280.20(a) and (b) for more detail on
the corrosion protection requirements.
6.1.4.2 Installing UST Systems the Right Way
Installation includes excavation, tank system siting, burial depth,
tank system assembly, backfilling of the tank system, and surface
grading. Faulty installation is a significant cause of UST failures,
particularly piping failures. Therefore, the federal regulations
require that you make sure that standard industry codes are used
when new tanks are installed at your facility.
You'll also need to make sure that the lining of your UST system
will be compatible with whatever materials you plan to store in the
UST.
Within 30 days of bringing the new UST into use, you must notify
the state UST agency'. To do this, you'll have to complete either a
state or an EPA form. The form requires you to certify that your
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Underground Storage Tanks
Part I, Chapter 6
new tank meets the installation requirements (see Box 6-7), as well
as some of the corrosion protection requirements described above
and the leak detection requirements described in Section 6.1.7. If
your UST contains petroleum, you also have to certify that you are
financially able to pay for any damage caused by leaks from the
UST. Check with your implementing agency about which form to
use and where to send it.
Box 6-7 How Do 1 Certify Compliance With UST Installation
Requirements?
Demonstrate any of the following:
¦
The installer was certified bv the tank or piping manufacturer
or by the implementing agency.
¦
The installation was inspected and certified by a registered
professional engineer.
¦
The installation was inspected and approved by the
implementing agency.
¦
All work on the manufacturer's installation checklist(s) was
completed.
¦
You certified the installation using any other method approved
by the implementing agency.
6.1.4.3 Preventing Spills and Overfills
Most spills and overfills results from human error. Spills most often
occur at the fill pipe opening when the delivery truck's hose is
disconnected. Overfills result when a tank is filled with a volume
that exceeds its capacity.
UST regulations require anyone filling USTs to follow correct tank
filling procedures. These are discussed in Section 6.1.6.1. Also,
your new tank systems must contain the following spill and overfill
prevention equipment, unless you can demonstrate that you have
alternative measures in place that are equally protective of human
health and the environment:
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Underground Storage Tanks
Part I, Chapter 6
¦ Spill prevention equipment (e.g., a spill catchment basin)
that will prevent the release of product to the environment
when the transfer hose is detached from the fill pipe.
¦ Overfill prevention equipment that will:
— Alert the transfer operator when the tank is no more than
90 percent full by either restricting the flow into the tank
or sounding an alarm.
— Automatically shut off flow to the tank when it is no more
than 95 percent full.
There is one exception. If your UST system is filled only by
separate transfers of no more than 25 gallons, you do not have to
meet these spill/overfill requirements.
6.1.5 What Are the Performance Requirements for Existing
USTs (Installed Before December 22, 1988)? (Subpart
B)
You have until December 22, 1998, to upgrade any USTs installed
at your facility on or before December 22, 1988. To fully upgrade
your existing UST, you will need to meet the spill/overfill prevention
equipment requirements for new USTs described in Section 6.1.413
above. Also, you must either meet the corrosion protection
requirements for new USTs described in Section 6.1.4.1 or you can:
¦ Protect steel tanks from corrosion by installing an internal
lining and/or by providing cathodic protection.
¦ Provide cathodic protection for all metal piping in contact with
the ground that routinely contains regulated substances.
You can find more information on the specific upgrading
requirements for steel tanks and metal piping in 40 CFR 280.21.
EPA recommends making these changes as soon as possible to
reduce the chance that you will be liable for damages caused by
substandard USTs. If you cannot meet the deadline for upgrading
you will have to close your UST (see Section 6.1.11).
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Part I, Chapter 6
6.1.6 What Operating Requirements Apply to USTs at My
Facility? (Subpart C)
The following requirements apply to any active UST, regardless of
when it was installed.
6.1.6.1 Preventing Spills and Overfills
If you own or operate an UST, you are responsible for ensuring that
releases due to spilling and overfilling don't occur. For example,
before product is transferred to a tank, you must ensure that the
volume available in the tank is greater than the volume of product
to be transferred to the tank. Also, you must constantly monitor ail
transfer operations to prevent overfilling and spilling. The transfer
procedures described in the National Fire Protection Association
Publication 385 may be used to meet these requirements. If a spill
or overfill does occur, you must report it and clean it up. (Section
6.1.9 describes requirements for reporting and remediation.)
6.1.6.2 Corrosion Protection
If your UST is a steel system with corrosion protection, you are
responsible for ensuring that the system is operated and maintained
to provide continuous corrosion protection to those parts of the
system that are underground and routinely contain regulated
substances.
If your UST has cathodic protection, you must have it tested within 6
months of installation and every 3 years after that (or according to
another schedule established by the implementing agency).
Inspection must be done by a qualified cathodic protection tester in
accordance with a code of practice developed by a nationally
recognized association. You must maintain records of the results of
the last two of these inspections.
If your UST has impressed current cathodic protection, you must also
have it inspected every 60 days to ensure that the equipment is
running properly. You must maintain records of the last three of
these inspections.
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6.1.6.3 Compatibility
You are responsible for making sure that the material or lining of
your UST system is compatible with whatever you store in the UST.
6.1.7 What Must I Do To Detect Leaks? (Subpart D)
Both new and existing USTs must have some method for detecting
leaks. A variety of leak detection approaches may be used, as
described below. Whatever leak detection method you choose, it
must be able to detect a leak from any portion of the tank or its
piping that routinely contains a regulated substance. Also, it must
be installed, calibrated, operated, and maintained in accordance
with the manufacturer's instructions, including routine maintenance
and service checks for operability and running condition. Any
performance claims must be described in writing by the
manufacturer or installer. Any methods permanently installed after
December 22, 1990, must be at least 95 percent accurate in their
ability to detect leaks.
6.1.7.1 Detecting Leaks From New Tanks
You must check your tanks for leaks at least every 30 days using one
(or a combination) of the following methods (see Figure 6-1):
¦ Automatic tank gauging, which uses automated processes to
monitor product level and inventory control.
¦ Monitoring vapors in soil surrounding the UST
¦ Monitoring the ground water near the UST for product
releases.
¦ Interstitial monitoring (i.e,, monitoring the space between the
UST and a second barrier or wall).
¦ Other methods approved by the regulatory agency. To be
approved, alternative methods must work as effectively as the
four methods listed above.
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A couple of alternatives to 30-day monitoring can be used for
certain types of tanks:
¦ If your tank is less than 10 years old, you can check for leaks
by combining inventory control with tank tightness testing.
Inventory volume must be measured and recorded daily and
compiled monthly. Tank tightness must be tested every 5
years. Tightness testing requires taking the UST out of
service while changes in the level or volume over time are
measured. After 10 years, you must use one of the 30-day
monitoring methods listed above.
¦ For small tanks up to 1000 gallons, you can use weekly
manual tank gauging as the sole method of leak detection.
This method involves the following procedures. Each week,
keep the tank undisturbed for 36 hours and measure its
contents consecutively twice at the beginning and twice at
the end of this test period.
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Underground Storage Tanks
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¦ For tanks between 1000 and 2,000 gallons, you can use
weekly manual tank gauging in combination with tightness
testing every 5 years. This combined method can only be
used for the first 10 years after tank installation. After that,
you must use one of the 30-day monitoring methods
described above.
If your operation decides to use one of these three alternative
methods, it is important to have a system in place to ensure that
appropriate procedures are routinely conducted at the appropriate
frequency (daily, weekly, monthly, or every 5 years, as highlighted
above). Also, it is important to ensure that any new personnel who
come on board in the future and are made responsible for this
monitoring understand the schedule and the necessary procedures.
The regulatory calendar at the front of this document includes the
LIST monitoring timetable and may be useful when scheduling
monitoring activities.
The regulations describe a number of performance requirements
associated with each leak detection method. Be sure to review the
detailed specifications in 40 CFR 280.43
6.1.7.2 Detecting Leaks From Piping in New USTs
Because most leaks come from piping, any piping that routinely
conveys regulated substances must meet the following requirements
for leak detection.
Pressurized Piping
If your piping is pressurized, you must:
¦ Make sure it is equipped with an automatic line leak
detector. This can be either an alarm that will alert the
operator about a leak or a device that will automatically shut
off or restrict flow when a leak occurs. In either case, -the
equipment must be able to detect a leak of 3 gallons per hour
at 10 pounds per square inch line pressure within 1 hour.
¦ Either conduct an annual tightness test of the piping (if it can
detect a 0.1 gallon per hour leak rate at 1.5 times the
operating pressure) or use anv of the 30-dav monitoring
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Underground Storage Tanks
Part I, Chapter 6
methods, noted in Section 6.1.4.4 for tanks except automatic
tank gauging.
Suction Piping
If your UST has suction piping, your leak detection requirements
will depend on which type of suction piping you have:
¦ The most commonly used suction piping requires either 30-
day monitoring (using any of the 30-day methods noted in
Section 6.1.4.4 for tanks, except automatic tank gauging) or
tightness testing of the piping every 3 years (if it can detect
a 0.1 gallon per hour leak rate at 1.5 times the operating
pressure).
¦ Another kind of suction piping is safer and does not require
leak detection. This safer method has three main
characteristics:
O The below-grade piping operates at less than
atmospheric pressure.
© The below-grade piping is sloped so that the piping's
contents will drain back into the storage tank if the
suction is released.
© Only one check valve is included in each suction line
and is located directly below the suction pump.
This type of piping is exempt from leak detection requirements if
you can readily demonstrate that the piping meets the three
characteristics described above.
6.1.7.3 Additional Requirements for New Chemical USTs
The requirements discussed so far apply to USTs that contain
petroleum products and to USTs that contain regulated chemicals.
A few additional requirements apply only to USTs containing
regulated chemicals.
All new underground tanks and piping that contain regulated
chemicals must have "secondary containment." The wall of the
tank or piping itself provides the first or "primary" containment.
However, if the primarv wall fails, product will leak into the
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environment. By enclosing underground tanks and piping within a
second wall, leaks can be contained and detected quickly before
harming the environment. The secondary wall must be capable of
completely containing any leakage from the primary wall and
preventing it from entering the environment. Secondary
containment can be constructed in several ways:
¦ Place one tank inside another tank, or one pipe inside
another pipe.
¦ Place the UST svstem inside a concrete vault.
/
¦ Line the excavation zone around the UST system with a liner
that cannot be penetrated by the chemical.
Secondary containment systems must be checked for evidence of a
release at least every 30 days.
Your chemical UST must have a leak detection system that can
indicate the presence of a leak in the confined space between the
first and second wall. Several devices are available to monitor this
space. Underground piping that conveys regulated substances under
pressure must be equipped with an automatic line leak detector (as
described in Section 6.1.7.2 above for pressurized piping).
You can apply for an exception, called a variance, from the
requirement for secondary containment and interstitial monitoring.
This requires a lot of work. You have to convince your regulatory
authority that your alternative leak detection method will work
effectively by providing detailed studies of your site, proposed leak
detection method, and available methods for correction action.
Some states do not allow variances.
6.1.7.4 What About Existing USTs?
As of 1994, the leak detection requirements described above for
tanks and piping apply to all existing USTs. You can use any of the
leak detection methods described above for new tanks and piping,
with one exception. The option of combining inventory control
with tank tightness testing every 5 years applies only to USTs that
have been upgraded to meet the corrosion protection and
spill/overfill requirements described in Sections 6.1.4.1 arid 6.1.4.3
above:
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Underground Storage Tanks
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¦ If you have upgraded your UST, you can use this method for
the first 10 years after upgrading. Then you'll have to switch
to one of the 30-day monitoring methods described in
Section 6.1.7.1.
¦ If you haven't upgraded your UST, you can combine monthly
inventory control with annual tightness testing. However,
this method is allowed only until December 22, 1998, when
all existing tanks must be upgraded or closed.
If your existing UST contains regulated chemicals, it must meet the
leak detection and containment requirements for chemical USTs
(described in Section 6.1.7.3) by December 22, 1998.
6.1.7.5 What Leak Detection Records Must I Keep?
You must maintain records to demonstrate compliance with the leak
detection requirements. Specifically you must keep records of:
¦ All written manufacturer performance claims about any
release detection system you use for 5 years from the date of
installation.
¦ The results of tank tightness testing until the next tightness
test is performed.
¦ The results of all other sampling, testing, and monitoring for
at least 1 year.
¦ Records of required calibration and maintenance provided by
the release detection equipment manufacturer for 5 years
after the date of installation.
¦ All other calibration, repair, and maintenance records
relevant to the release detection system for at least 1 year
after servicing.
The implementing agency may establish other reasonable
timeframes for these recordkeeping requirements.
6.1.8 What Should I Do if I Think My Tank Is Leaking?
(Subpart E)
Various signals mav indicate that your UST is leaking. Prompt
reaction to these signals will help vou comply with the UST
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Underground Storage Tanks
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requirements and minimize the potential for expensive cleanup and
liability costs.
6.1.8.1 Warnings From Equipment
Your UST may be leaking when you discover either of these warning
signals from equipment:
¦ Unusual operating conditions (such as erratic behavior of the
dispensing pump, the sudden loss of product from an UST
system, or the unexplained presence of water in the tank).
¦ Results from leak detection monitoring and testing that
indicate a leak.
You need to confirm quickly whether these suspected leaks are real.
These signals could simply result from faulty equipment that needs
to be repaired or replaced. If so, you should immediately repair or
replace the equipment, but you do not need to notify anyone about
the problem.
If faulty equipment is not the cause of the problem, you must report
the unusual operating condition to the implementing agency within
24 hours of discovering the condition. Within 7 days, you must
also conduct tightness tests of the entire UST system (see Section
6.1.7 above). If these tests indicate a leak, you need to report it to
the implementing authority within 24 hours of confirming the leak.
You must also follow the actions for a confirmed leak, described in
Section 6.1.9 below.
If you are using the inventory control method to monitor for leaks,
you need only report unusual findings if they are confirmed by next
month's inventory control data.
6.1.8.2 Warnings in the Environment
The presence of free product or vapors in the environment (for
example, soil, basements, utility lines, sewer lines, and nearby
surface waters) at or near your UST's location may well indicate an
UST leak. If you discover evidence of environmental damage or if
someone brings this evidence to vour attention, you must:
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Underground Storage Tanks
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¦ Report this finding to your implementing agency within 24
hours.
¦ Conduct a tightness test of the entire UST system within 7
days to determine whether and in which part of the system
a leak exists.
6.1.8.3 Conducting a Site Check
If you find environmental contamination or if tightness testing
indicates a leak, investigate the UST site within 7 days for
additional information on the extent and nature of the
environmental damage. This includes measuring for the presence of
a release where contamination is most likely to be present. Report
any damage to the implementing agency within 24 hours of
confirming that a release has occurred.
Your implementing agency may request different procedures and
time frames.
The results of these system tests and site checks will help answer the
crucial question "Is my UST leaking?" If the answer is "yes,"
following the actions for responding to confirmed leaks described in
Section 6.1.9 below.
6.1.9 What Should I Do if I Find a Leak or if a Spill or
Overfill Occurs? (Subparts E and F)
Your response to confirmed leaks and to spills or overfills comes in
two stages: initial response and abatement and longer-term
abatement. Read the sections below to find out what you must do.
Also, be sure to check with your implementing agency for any
additional or modified requirements.
6.1.9.1 Initial Response
Your initial response to evidence of a leak, spill, or overfill should
include:
¦ Take immediate action to stop and contain the leak, spill, or
overfill.
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¦ Tell the implementing agency within 24 hours that there has
been a release. You don't have to report the following
releases if you contain and clean them up within 24 hours:
— Petroleum spills/overfills of no more than 25 gallons.
— Spills/overfills of hazardous substances regulated under
CERCLA that are less than the reportable quantity for the
substance. Appendix 6-B lists CERCLA hazardous
chemicals typically used by metal finishers and their
reportable quantities. The complete list of CERCLA
hazardous substances and reportable quantities can be
found in 40 CFR Part 302.4.
¦ If the release is a spill or overfill of a CERCLA hazardous
substance that meets or exceeds the reportable quantity, it is
also subject to requirements of the Emergency Planning and
Community Right-to-ICnow Act (EPCRA). Under these
requirements, you must immediately notify the National
Response Center at 1-800-424-8802 and the appropriate
state and local authorities that there has been a release. Read
Chapter 8 to find out more information about the EPCRA
requirements.
¦ Identify and mitigate any fire, explosion, and vapor hazards.
Petroleum spills and their vapors, in particular, may pose fire
and explosion hazards. Chemical spills and vapors may also
pose a health hazard. Safety measures may include, for
example, evacuating the area, extinguishing open flames and
cigarettes, and turning off electrical equipment in the area.
Your fire department can help or advise you about safety
measures.
6.1.9.2 Initial Abatement
Unless the implementing agency directs you to do otherwise, you
must:
¦ Remove as much of the regulated substance from the UST as
is necessary to prevent further release from the environment.
¦ Visuallv inspect anv exposed release areas and take steps to
prevent further migration of the released substance into
surrounding soils and ground water.
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Underground Storage Tanks
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¦ Continue to monitor and mitigate any additional fire and
safety hazards posed by vapors or free product that have
migrated from the UST excavation zone and entered into
subsurface structures (such as sewers or basements).
¦ Remedy any hazards that may be posed by contaminated
soils that are excavated or exposed as a result of your
investigations or corrective action.
¦ If you have not already determined the source of the release
during your site check, conduct further measurements to
determine the source.
¦ Within 20 days after you have confirmed a leak or spill,
report your progress and any information you have collected
and abatement actions you have taken to the implementing
agency.
¦ Remove free product to the maximum extent practicable.
When you do this, be sure to minimize the spread of
contamination by using recovery and disposal techniques that
are appropriate to the hydrogeologic conditions at the site.
Within 45 days of confirming a release, submit a report to
the implementing agency on your approach to and progress
in free product removal. You can find more details on what
should be in this report in ^0 CFR 280.64(d).
¦ Conduct a site assessment to investigate what impact the
release has had or may have on the surrounding environment,
including soils and ground water. You'll find more details on
what this assessment must cover in 40 CFR 280.63(a).
Within 45 days of confirming a release, submit a report to
the implementing agency describing the results of this
assessment. Check with your implementing agency for exact
requirements about the content, format, and schedule for this
report.
6.1.9.3 Corrective Action Plan
When soil and/or ground water are contaminated, the implementing
agency mav require you to develop and submit a corrective action
plan. The plan should demonstrate what actions you will take to
ensure adequate protection of human health and the environment
from the contamination.
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The implementing agency will review your plan for adequacy.
Agency representatives may modify the plan if they feel it does not
provide adequate protection. They will also notify the public about
the plan and provide opportunities for public review and comment.
Once the plan is approved, you must implement it. The
implementing agency will establish a schedule and format for
implementation and progress reporting. You can start cleanup of
soil and ground water before your plan is approved as long as you
notify the implementing agency that you are doing this and comply
with any conditions they may impose.
6.1.9.4 Long-Term Abatement
Some leaks and spills/overfills will require additional long-term
attention. Based on the information you have provided to this
point, the implementing agency will decide whether you need to
take further action at your site.
6.1.10 Can Leaking Tanks and Pipes Be Repaired? (Subpart
C)
Many types of repairs are possible as long as they meet requirements .
designed to prevent future releases from repaired USTs due to
structural failure or corrosion. You must keep records for each
repair as long as the UST is in service.
6.1.10.1 Tanks
You can repair a leaking or defective UST if the person who does
the repair follows standard industry codes that establish the correct
way to conduct repairs. Repairs to fiberglass-reinforced plastic tanks are
also acceptable if they are done by the manufacturer's authorized
representatives.
¦ Within 30 days of the repair, you must prove that the tank
repair has worked by doing one of the following:
¦ Testing the tanks for tightness using a test capable of
detecting a 0.1 gallon per hour leak rate from any portion of
the tank that routinelv contains product.
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¦ Having the tank internally inspected following a standard
industry code.
¦ Having the repaired portion of the UST system monitored
monthly for releases using one of the 30-day methods
described above in 6.1.7.1.
¦ Using another method approved by the implementing
agency.
If the UST system was cathodically protected, you must have it tested
within 6 months of completing the repair. Section 6.1.6.2 describes
the requirements for this testing.
6.1.10.2 Pipes
Damaged metal piping cannot be repaired and must be replaced.
Corroded or damaged fittings must also be replaced. Loose fittings can
simply be tightened if that solves the problem.
Fiberglass-reinforced plastic pipes and fittings may be repaired, but only
in accordance with the manufacturer's specifications.
Within 30 days of the repair, you must test the success of the repair
by doing one of the following:
¦ Testing the lines for tightness using a test that can detect a
0.1 gallon leak rate at 1.5 times the operating pressure.
¦ Having the line monitored monthly for releases using one of
the 30-day methods described above in 6.1.7.1.
¦ Using another method approved by the implementing
agency.
If the pipe system was cathodically protected, you must have it tested
within 6 months of completing the repair. Section 6.1.6.2 describes
the requirements for this testing.
6.1.11 How Do I Close an UST? (Subpart G)
6.1.11.1 Temporary Closure (3 to 12 Months or Longer)
If vou're not going to use your UST for 3 to 12 months, you must
follow these requirements for temporary closure:
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Underground Storage Tanks
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¦ Leave all vent lines that are attached to your UST open and
functioning. Cap and secure all other lines, pumps, manvvays,
and ancillary equipment.
¦ Continue meeting the requirements for corrosion protection
described above in Section 6.1.6.2.
¦ Continue meeting the requirements for release detection
described above in Sections 6.1.6.2 and 6.1.7 unless your
tank is empty ("empty" means either that your tank contains
no more than 1 inch of residue or that the remaining residue
constitutes no more than 0.3 percent by weight of the total
capacity of your UST system).
¦ If you find a leak, you will have to respond just as you would
for a leak from an active UST. Response requirements are
described in Section 6.1.9 above.
If your UST meets the requirements for a new or an upgraded UST
(except for the spill/overfill equipment requirements), you can keep
it "temporarily" closed indefinitely. USTs that do not meet the
requirements for new or upgraded USTs must be permanently closed
after 12 months of temporary closure unless you can get an
extension from your implementing agency. To request an extension,
you will have to conduct a site assessment to determine whether
leaks from the tank have damaged the surrounding environment.
6.1.11.2 Permanent Closure
Whenever you permanently close an UST, either because you
choose to do so or are required to do so, you must:
¦ Notify the implementing agency of your intent to close your
UST at least 30 days before beginning closure (unless you are
making this change in response to a corrective action).
¦ Empty and clean the tank by removing all liquid and
accumulated sludge.
¦ Either remove the tank from the ground or fill it with an
inert solid material such as sand.
¦ After you have notified the implementing agency and before
vou have completed closure, conduct an "excavation zone"
assessment to determine whether a leak from your tank has
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damaged the surrounding environment. This involves
measuring for the presence of a release where contamination
is most likelv to be present at the UST site. You are exempt
from this requirement if you have been using either 30-day
vapor monitoring or 30-day groundwater monitoring to
detect releases, and these methods have not detected any
releases. If product has been released, you will have to follow
the procedures for responding to a release described in
Section 6.1.9.
¦ Keep records that demonstrate you have complied with these
requirements. In particular, you must maintain records of
the excavation zone assessment for 3 years following closure.
If you are transferring your UST site to a new owner, the new
owner must maintain the records. If you are permanently
closing your operation, mail the assessment to the
implementing agency.
6.1.11.3 Changing From a Regulated Substance to a
Nonregulated Substance
If you've been Using your UST to store a regulated substance and
now want to use it to store an unregulated substance, this is
considered a "change in service." You must meet all the
requirements described above for tank closure, except you do not
have to remove the tank or fill it with an inert material.
6.1.12 What Are My Financial Responsibilities if I Own or
Operate a Petroleum UST? (Subpart H)
The federal regulations include detailed requirements designed to
make sure that owners and operators of petroleum USTs will be able
to pay for correcting any problems that may be created if their UST
leaks. You do not have to meet these requirements if your UST
contains regulated chemicals.
You will find a complete explanation of the financial requirements
for owners and operators of petroleum USTs in 40 CFR 280
Subpart H and in the EPA brochure "Dollars and Sense." In
general, owners and operators of petroleum USTs must demonstrate
their abilitv to pav for damage caused by a leaking UST by showing
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either that they are adequately insured or that they have sufficient
financial resources to seif-insure.
6.2 State Requirements
The requirements for managing USTs, including those regarding
notification, construction and maintenance, and financial assurance,
have been established nationally by the EPA. States have the
responsibility to implement UST programs and in doing so establish
their own criteria. All state programs must be at least as stringent
as EPA's rules, and most states opt to impose additional provisions
such as those requiring permits and more stringent monitoring.
Some states include in their bulk storage rules the regulation of
additional materials, such as hazardous waste, or the regulation of
aboveground storage tanks (ASTs).
EPA may bring enforcement action against facilities violating federal
requirements although enforcement authority is typically delegated
to the states. A state may in turn rely on local or regional agencies
to conduct inspections, and oversee tank removals and installations.
Increasingly, states are developing assistance programs that help
facilities comply with the financial re: ponsibility requirements of the
law, and provide loans and grants to pay for the cost of tank
removal or upgrade.
Table 6-1 provides a summary of state requirements. The agencies
listed are state authorities, although reliable information is typically
available from your local Fire Marshal's office.
6.3 Where To Go for More Information
For additional information about federal UST requirements, contact
the RCRA Hotline by calling 1-800-424-9346 or 1-202-382-3000
or your state UST program in states that have authority to
implement the federal regulations. These states are listed in Box 6-
4.
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Other sources of information include:
¦ Local agencies, such as your fire department, that regulate
USTs.
¦ Trade association and institute representatives (see Box 6-8).
¦ Contractors, jobbers, or equipment suppliers.
Government and private sector organizations have prepared a
number of guides to compliance with UST regulations. These are
listed in Appendix 6-C-
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Box 6-8 Organizations To Contact for Further Information
ACT—Association for Composite Tanks
1900 Frankfurst Ave.
Baltimore, MD 21226
(301) 235-6000
NFPA—National Fire Protection Association
1 Batterymarch Park
P.O. Box 9109
Quincy, MA 02269
(617) 770-3000
APT—American Petroleum Institute
1220 L Street, NW
Washington, DC 20005
(202) 682-8000
NLPA—National Leak Prevention
Association
7685 Fields Ertel Rd.
Cincinnati, OH 45241
(513) 489-9844
(800) 322-6572
Fiberglass Petroleum Tank and
Pipe Institute
One SeaGate, Suite 1001
Toledo, OH 43604-1560
(419) 247-5412
Fax: (419) 247-5421
PEI—Petroleum Equipment Institute
Box 2380
Tulsa, OK 74101
(918) 494-9696
NACE—National Association of Corrosion
Engineers
Box 218340
Houston, TX 77218
(713) 492-0535
Steel Tank Institute
570 Oakwood Rd.
Lake Zurich, IL 60047
(708) 438-TANK [8265]
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
Laws and Regulations
Recordkeeping, Reporting, Permits, and Enforcement
State Contact(s)
AZ
Federal Standards Apply
Arizona Revised Statutes
Annotated Title 49
Arizona Regulations Title
18, Chapter 12
Tax return due March^l and information specifying types and quantities of substances
deposited in each tank during the previous year must be included.
Arizona Department of
Environmental Quality
3033 North Central
Avenue
Phoenix, AZ 85012-2809
(602) 207-2300
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Table 6-1 Summary of Selected State Undergone! Storage Tank Programs
State
CT
Laws and Regulations
State Program has
Tentative EPA Approval
Regulations of State
Agency 22a-449(d)
Recordkeeping, Reporting, Permits, and Enforcement
State recordkeeping requirements more stringent. Notification addressed to State Agency
(CTDEP, Underground Storage Tank Enforcement Program) St to the Local Fire Marshal
within 30 days of installation. Excluded from Reporting, Leak Detection, Life Expectancy
Testing and Failure Determination Requirements are UST Systems: with a nominal
capacity of less than 2,100 gallons, fuel oil systems for on-site heating or stand-hy
electrical power generation, :;:id facilities not used for storing waste oils. Also excluded are
facilities used solely for the storage, transmission, or dispensing of viscous oils or
petroleum liquids that will not flow at temperatures below 60"F. Facilities used solely for
on-site heating, process steam generation; other on-site combustion- or manufacturing
process or waste oil storage are exempt from Leak Detection Requirements. Daily
recording of amount of product sold, used, received and the level of water and/or product
in the tank. Owners must reconcile the product gain or loss figures at least weekly to
determine whether an abnormal loss or gain has occurred. An abnormal loss or gain means
an apparent loss or gain in liquid exceeding 0.5% of the volume of product used or sold by
the owner during any 7-day consecutive period, or the volumetric capacity of the tank or
container; whichever is greater as determined by inventory reconciliation. Daily
measurements must be made by gauge or gauging stick, or by a automatic monitoring
device readout. New and existing tanks shall have all cathodic protection systems tested
annually. All new USTs and components must be: Constructed of listed fiberglass-
reinforced plastic, equipped with contact plates under all fill and gauge openings, and
chemically compatible with UST contents; a listed steel tank externally coated and
equipped with cathodic protection, permanent cathodic protection monitoring devices,
and contact plates under all fill and gauge openings; and life expectancy or failure
determination must be performed within 30 days of completion of new installations and
existing systems. All construction, monitoring installation activities, abandonment,
substantial modifications, and daily inventory records and.volume reconcilation figures
shall be kept on the tank system premises for at least five years. Owners/operators must
review and attest to the accuracy of all records by signing them within seven days
following completion of the recorded activity. Confirmed abnormal losses or gains
determined through reconcilation determinations must be reported immediately to the
Connecticut State Police and CTDEP must be notified immediately after a release: (860)
566-7350 CT State Police (860)424-3338 CTDEP. Owners/operators must notify
commissioner within 30 days of abandoning a facility. Facilities must be abandoned in
accordance with NFPA 30. State Leaking Underground Storage Tank (LUST) Fund meets
Federal requirements for Financial Responsibility.
State Contact(s)
Connecticut Department
of
Environmental Protection
Bureau of Waste
Management
Pesticide, I'Cli,
Underground Tank and
Terminal Division
79 Elm Street
Hartford, CT 06106-5127
(860) 424-3374
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
Laws and Regulations
Recordkeeping, Reporting, Permits, and Enforcement
State Contact(s)
c;a
Slate Program granted
Final Approval by EI'A
(leorgia Regulations 391 -
3-15.02
(leorgia Laws 12-13-13
Notification addressed.to Georgia Department of Natural Resources must be submitted
within 30 days of first use. Notification must specify: Age, Size. Type, Location and Use
of Tank
Annual Notification required for each tank. Notification required when any tank is taken
out of service. Tank seller is required to advise purchaser of tank of State Notification
requirements.
Georgia Department of
Natural Resources
Environmental Protection
Div.
205 Butler Street
Atlanta, CIA 30334
(404) 656-4713
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
Laws and Regulations
Recordkeeping, Reporting, Permits, and Enforcement
State Contact(s)
MA
State Program granted
Final Approval by EPA
527 (lode of
Massachusetts Regulations
y.()7(k)( I) Underground
Storage lank Regulations,
Tanks and Containers
UST installations require permits from local fire department. Hazardous waste tanks and
fuel oil tanks for consumptive use are exempt only from release detection requirements;
design requirements are also less stringent. Other UST systems must have one of the
following: mandatory inventory recordkeeping in addition to periodic tightness testing,
monthly reconciliation is required, and a loss is suspected if product loss/gain exceeds 0.5%
of the throughput; installation and maintenance of an approved in-tank monitoring system
which includes daily inventoiy control records and monthly monitoring records;
installation of an approved double-walled tank, an interstitial space monitoring system
and liquid removal port;manual tank gauging must be conducted on waste oil tanks on a
weekly basis. New or replacement USTs with acceptable forms of leak detection must
have tightness test on all new or replacement tanks and piping at installment, the system
must be tested by air pressure prior to installment ami piping must be tested 12 to 24
months after installment. USTs with acceptable spill containment, but no leak detection
system must be tested every fifth, ninth, and fifteenth year after installation. USTs
without acceptable spill containment or leak detection systems must be tested annually
until 1998. Existing suction piping systems are to be tested every three years. Existing
pressurized piping systems that are not monitored require annual testing, and secondary
piping containment systems. All new and replacement tanks must be constructed of the
following materials; UL listc double-walled steel with cathodic protection, UL listed
double-walled fiberglass, UL listed double-walled composite, double-walled composite or
UL listed double-walled jacketed steel tank; Dimensions and thickness are specified by
State. Daily inventory and monthly reconciliation is required, a release is unsuspected if
loss/gain exceeds 0.5% of throughput. All cathodic protection monitoring, leak detection
monitoring, and inventory records shall be kept at the UST facility for the entire operating
life of the UST system. Leaks shall be immediately reported to the local fire department
and MADEP Office of Incident Response - Springfield (413) 784-1 100, Worcester (508)
792-7653, Lakeville (508) 946-281 7 and Wobum (61 7) 935-2 160. For permanent
closure of tanks located under a building, which can not be removed, the local fire
department must verify that the tank can not be removed, and the owner/operator must
obtain a permit form the fire department, remove all tank products, secure all openings,
and remove tank from service. All other tanks can not be abandoned. The owner/operator
must obtain a permit from the fire department, remove all tank products, secure all
openings, and remove tank from ground.
Massachusetts Department
of Environmental
Protection
l Winter street
lkiston, MA 02108
(617) 292-5500
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
Laws and Regulations
Recordkeeping, Reporting, Permits, and Enforcement
State Contact(s)
Ml
Michigan Administrative
Code R29.21 13
Michigan Compliance
Laws Annotated 299.702
Notification required within 30 days of any change in registration information, or any
release, or the removal of any tank from service. Tank registration required at least 45
days prior to installation of any new tank. Tank registration required within 30 days of
acquiring an existing tank. Registrations must include: plot plan of site, location(s) of any
nearby drinking water or other wells, tank and piping system building materials, tank
dimensions and capacity, type of regulated substance to be stored, diagram of tank system,
and manufacturer and part number of tank components.
Michigan Department of
Natural Resources
530 West Allegan Street
P.O. Box 30260
Lansing, Ml 48909
(517) 373-2329
MN
9 Minnesota Statutes
Annotated I 16.48
Notification required at least 30 prior to tank installation or removal. Additional
notification required if date of installation or removal changes by more than 48 hours.
Notification to include: Name, address, telephone of site owner, location of site, date of
tank installation or removal, name of installer or remover. Notification required within 30
days of abandonment or change in tank status. Tank seller must inform buyer of
notification requirements.
Minnesota Pollution
Control Agency
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
N\
Laws and Regulations
The Underground Storage
of Hazardous Substances
Act NJAC 7:14li
Recordkeeping, Reporting, Permits, and Enforcement
Notification is required 30 days prior to use of the tank. Reccrtification required ever)' 3
years. Permits required for replacement, installation, expansion of UST system, or
substantial modifications. New Jersey DEI' does not exempt: tanks used to store heating
oil greater than 2,000 gallons, tanks under 110 gallons, US T emergency spill or overflow
containment systems. USTs that have a secondary containment system and can be
uncovered to allow visual inspections are exempt. Owners/Operators must have written
routine monitoring procedi' --s. Equipment operation and maintenance training required
for personnel responsible for checking and repairing UST monitoring systems. All
monitoring system access points located at grade level must be permanent marked or
tagged with the phrase "For Monitoring Only", the registration certficate's facility number,
and the well drilling permit number, if applicable. UST systems that contain heating oil
for on-site consumption are exempt from inventory control requirements. Manual tank
gauging may be used for waste oil tanks. UST spill basin must contain 5 gallons, I 5
gallons for USTs with remote fill ports.
New hazardous chemical UST systems must have secondary containment. All new US Ts
must he equipped with striker plates and product tight piping containment chambers
accessible to grade level. New hazardous chemical piping and piping for certain waste oil
and petroleum tanks must be either: double walled with leak detection system, suction
line piping, single wall or secondary contained piping with a pressurized shut down
monitoring device, secondarily contained utilizing a semigrid, dielectric, noncorrosive
material, or placed within a lined trench which terminates at the bottom of the dispenser
and the top of the tank and which has a leak detection monitoring system. All fill ports
must be permanently marked to identify product, in accordance to AIM. All UST system
records must be maintained for six years. Releases must be reported to the Environmental
Action Line (609) 292-7172. UST owners must prepare a release response plan. Closure
approval form must be submitted prior to UST closure.
An initial registration fee may be required.
Slate Contact(s)
New ]ersey Department of
Environmental Protection
401 East State Street
Trenton, N) 08625
(609) 292-3131
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Table 6-1 Summary of Selected State Underground Storage Tank Programs |
State
Laws and Regulations
Recordkeeping, Reporting, Permits, and Enforcement
State Contact(s)
NY
6 New York Code of Rules
ami Regulations, 1'art 612-
6 14 I'etroleum Bulk
Storage
Building permits as needed. NYDEC UST Registration form. Notification required 30
davs prior to substantial modification and 30 days after change in ownership of UST
system. Excludes USTs less than 1,100 gallons. New and replacement tanks must be
registered prior to being placed into service. Registration renewal required every 5 years.
All UST systems must have: shut-off valves to remote pumping units at motor fuel
dispensers, shut-off valves for gravity-fed motor fuel dispensers, check valves for pump
filled tanks, and operating valves for gravity-drained tanks. Unprotected tanks must have
initial test at age 10, retested every 5 years. Corrosion resistive tanks to be initially tested
at age 15, retest every 5 years until closure. Corrosion resistive tank and pipe with leak
monitoring system requires weekly monitored for traces of petroleum, and does not
require periodic testing. All new and replacement USTs must have: Overall prevention
and secondary containment systems, color coded fill ports, a leak monitoring system,
cathodically protected steel or fiberglass tank and piping construction. Daily inventory
records which indicate measurement of bottom water levels, sales, use, deliveries,
inventory on hand, and gains/losses. Reconciliation of records must be kept current.
Leaks are suspected if product gain or loss exceed 0.75% of the tank volume or 7.5 gallons
per 1,000 delivered gallons. UST owners must retain test results and daily inventory
records for 5 years. The application for registration certificate must be kept for the
lifetime of the UST. Monitoring records for leak detection system must be kept for 1 year
Inspection reports must be kept for 10 years. Leaks must be reported to NYDEC within 2
hours (518) 457-7362.
New York State
Department of
Environmental
Conservation
50 Wolf Roail
Albany, New York 12233-
1750
(518)457-5400
NC
North Carolina
Regulations, Title 1 5a
Notification required 30 days prior to installation of a tank or leak detection system.
Notification required 30 days prior to closure, change in tank status or ownership of tank.
Tank seller must inform buyer of notification requirements. UST registration and fee
required.
North Carolina
Department of
Environment, Health &.
Natural Resources
3800 Barrett Drive
Raleigh, NC 27609
(919) 733-4984
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Table 6-1 Summary of Selected State Underground Storage Tank Programs
State
HI
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Texas Natural Resource
Conservation Commission
12100 Park 35 Circle
Austin, TX 78711-3087
(512) 239-1000
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APPENDIX 6-A
COMPLIANCE CALENDAR FOR FEDERAL UST REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
1
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHAPTER 6-UNDE1
RGROIIND STORAGE TANKS
Milestone Events |
By December 22,
1998
Upgrade USTs
Upgrade USTs
Close USTs
RCRA
Subtitle I
RCRA
Subtitle I
RCRA
Subtitle I
Fully upgrade all USTs to meet corrosion
protection and spill/overfill requirements.
Upgrade USTs containing regulated chemicals to
meet the special leak detection and containment
requirements for chemical USTs
Permanently close any USTs that you don't
upgrade.
Keep records on file at
facility
Keep records on file at
facility
Keep records on file at
facility
6-13 to 6-15
6-13 to 6-15
6-13 to 6-15
Regular or Periodic Events
Lvery 60 days
Inspection
RCRA
Subtitle I
Inspect impressed current cathodic protection
systems to ensure equipment is running properly.
Keep records of last 3
inspections on file at
facility
6-14
Oilier Events |
Within 30 days of
bringing a new UST
into use
Notification letter
RCRA
Send notification letter certifying the UST meets
installation, corrosion protection, and leak
detection requirements
State Agency
6-11 to 6-12
Within 6 months of
installation and every
3 years after
Testing
RCRA
Subtitle I
Have any cathodic protection systems tested by a
qualified tester.
Keep records of last 2
tests on file at facility
6-14
If there is a suspected
release:
¦ Immediately
¦ Within 24
hours of
discovering a
problem
Action
Investigation
RCRA
Subtitle I
RCRA
Subtitle I
Take action to stop and contain a leak, spill, or
overflow
Investigate any warning signals from equipment.
Immediately repair or replace faulty equipment.
Keep records on file at
facility
Keep records on file at
facility
6-22
6-23
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Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
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¦ Within 24
hours of
discovering a
problem
Report
RCRA
Subtitle 1
Report any unusual operating conditions not caused
by faulty equipment and any environmental
contamination
Implementing agency
6-21
¦ Within 7 days
of discovering
a problem
Tightness test
RCRA
Subtitle I
Conduct a tightness test of your entire UST system
Keep records on file at
facility
6-21
Immediately upon
discovery of a release
Action
RCRA
Subtitle I
Take action to stop and contain the release
Keep records on file at
facility
6-22
Notification
If the release is a CERCLA hazardous substance
Immediately notify the
National Response
Center 1-800-424-
8802 and appropriate
state and local
authorities
6-23
Mitigation
Identify and mitigate fire, explosion, and vapor
hazards.
Keep records on file at
facility
6-23
Within 24 hours of
confirming a release
Report
RCRA
Subtitle 1
Within 24 hours of confirming that a release has
occurred, report any damage found.
Implementing agency.
6-23
Notification
RCRA
Subtitle 1
Notify your implementing agency about any
confirmed release except; petroleum spills/overfills
of 25 gallons or less; spills/overfills of hazardous
substances regulated under CERCLA that are less
than the reportable quantity.
Implementing agency
6-23
As soon as
practicable after
discovery
RCRA
Subtitle I
Investigate and clean up the site.
6-23
6-A2
Remove free product to the maximum extent
practicable
6-23 to 6-24
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
As soon as
practicable after
discovery
Conduct a site assessment to determine
environmental impact.
6-24
Within 7 days of
discovering
contamination
Inspection
RCRA
Subtitle 1
If you find environmental damage or if tightness
testing indicates a leak, investigate your UST site
for evidence of environmental damage.
6-21 to 6-22
Within 20 days of
confirming a release
RCRA
Subtitle !
Report your investigation and abatement progress
to your implementing agency.
6-24 to 6-25
Within 45 days of
confirming a release
RCRA
Subtitle 1
Report your approach to and progress in free
product removal to your implementing agency.
6-24
Within 45 days of
confirming a release
RCRA
Subtitle 1
Report the sire assessment results to your
implementing agency.
6-24
Within 30 days of
repairing a leaking
UST
Test
RCRA
Subtitle 1
Verify UST repair success by conducting tightness
testing, having the tank internally inspected, or
monitoring the repaired portion of the UST
.nonthly.
6-25 to 6-26
Within 6 months of
repairing a leaking
UST
Test
RCRA
Subtitle i
If your UST system is cathodically protected, this
system must also be tested.
6-26
Within 12 months
Closure
RCRA
Subtitle 1
Any UST that does not meet the requirements for
new or upgraded USTs must be closed within 12
months unless an extension is granted by the
implementing agcy.
6-26 to 6-27
At least 30 days
before beginning
closure
Notice
RCRA
Subtitle 1
Notify your implementing agency about your intent
to permanently close your UST or convert to
storing a nonregulated substance.
Implementing agency
6-27 to 6-28
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Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
After notifying your
implementing agency
about your intent to
close and before
completing closure
Assessment
RCRA
Subtitle I
Conduct an excavation zone assessment to
determine if any releases from your tank damaged
the surrounding environment.
Keep records on file at
facility
6-27 to 6-28
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APPENDIX 6-B
CERCLA HAZARDOUS SUBSTANCES TYPICALLY USED BY METAL
FINISHERS
-------
Underground Storage Tanks
Part I, Chapter 6
CERCLA Hazardous Substances Typically Used by Metal Finishers
CAS No.
Chemical
Reportable
Quantity
57125
Cyanides (soluble salts and complexes) not otherwise
specified
10
54197
Acetic acid
5,000
67641
Acetone
5,000
71432
Benzene
10
71556
Ethane, 1,1,1-trichloro-
(Methyl chloroform)
(1,1,1 -T richloropentane)
1,000
74873
Methane, chloro-
100
74908
Hydrocyanic acid
10
(Hydrogen cyanide)
75092
Methane, dichloro- (Methylene chloride)
1,000
78831
Isobutyl alcohol
(l-Propanol,2-methyl)
5,000
78933
Methyl ethyl ketone (MEIC, 2-Butanone)
5,000
143339
Sodium cyanide
10
151508
Potassium cyanide
10
506849
Silver cyanide
1
544923
Copper cyanide
10
557197
Nickel cyanide
10
557211
Zinc cyanide
10
557346
Zinc acetate
1,000
592018
Calcium cyanide
10
1310583
Potassium hydroxide
1,000
1310732
Sodium hydroxide
1,000
December 1996
6-B3
-------
Underground Storage Tanks
Part I, Chapter 6
CERCLA Hazardous Substances Typically Used by Metal Finishers
CAS No.
Chemical
Reportable
Quantity
1314870
Lead sulfide
10
7439921
Lead1
10
7440020
Nickel1
100
7440224
Silver1
1,000
7440235
Sodium
10
7440350
Antimony1
5,000
7440417
Beryllium1 (Beryllium dust)
10
7440439
Cadmium1
10
7440473
Chromium1
5,000
7440508
Copper1
5,000
7440606
Zinc1
1,000
7646957
Zinc chloride
1,000
7647910
Hydrochloric acid (Hydrogen chloride)
5,000
664393
Hydrofluoric acid (Hydrogen fluoride)
100
7664382
Phosphoric acid
5,000
7664417
Ammonia
100
7664939
Sulfuric acid
1,000
7661529
Sodium hypochlorite
100
7697372
Nitric acid
1,000
7718549
Nickel chloride
100
7723140
Phosphorus
1
7733020
Zinc sulfate
1,000
7738945
Chromic acid
10
7782505
Chlorine
10
December 1996
6-B4
-------
Underground Storage Tanks
Part I, Chapter 6
CERCLA Hazardous Substances Typically Used by Metal Finishers
CAS No.
Chemical
Reportable
Quantity
7783064
Hydrogen sulfide
100
7788814
Nickel sulfate
100
8014957
Sulfuric acid
100
10022705
Sodium hypochlorite
100
11115745
Chromic acid
10
11141185
Arochlor 1232 (Polychlorinated biphenyls—PCBs)
1
12054487
Nickel hydroxide
10
12872296
Arochlor 1248 (Polychlorinated biphenyls—PCBs)
1
13463393
Nickel carbonyl
10
37211056
Nickel chloride
100
53469219
Arochlor 1242 (Polychlorinated biphenyls—PCBs)
1
Reportable quantity applies only to particles with a diameter less than 100 micrometers. Other forms of
the chemical do not have to be reported.
Source: 40 CFR Part 302.4.
December 1996
6-B5
-------
APPENDIX 6-C
GUIDES TO COMPLIANCE WITH FEDERAL UST REGULATIONS
-------
Underground Storage Tanks
Part I, Chapter 6
Guides to Compliance With Federal UST Regulations
Topic
Tide
Order From
BROCHURES
Technical
Requirements
"Musts for USTs"—A Summary of the
Federal Regulations for Underground
Storage Tank Svstems
Stock No. 055-000-00294-1 S2.50
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 783-3238
"Normas v Procedimientos para
T.S.A."—Spanish Language Version of
"Musts for USTs"
Free
U.S. Environmental Protection
Agency
Office of Underground Storage
Tanks
P.O. Box 6044
Rockville, MD 20850
"Doing Inventory Control"—For
Underground Storage Tanks
"Manual Tank Gauging"—For Small
Underground Storage Tanks
NCEPI
Box 42419
Cincinnati, OH 45242
(513) 891-6685
"Don't Wait Until 1998"—Spill, Overfill,
and Corrosion Protection for Underground
Storage Tanks
Financial
Responsibility
"Dollars and Sense"—A Summary of the
Financial Responsibility Regulations for
Underground Storage Tank Systems
Stock No. 055-000-00293-2 '
$1.25
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 783-3238
"Controlling UST Cleanup Costs"
NCEPI
Box 42419
Cincinnati, OH 45242
(513) 891-6685
Leak
Detection
"Leak Lookout"—Using External Leak
Detectors to Prevent Petroleum
Contamination from Underground Storage
Tanks
Free
"Straight Talk on Tanks"—A Summary of
Leak Detection Methods for Petroleum
Underground Storage Tank Systems
Free
U.S. Environmental Protection
Agency
Office of Underground Storage
Tanks
P.O. Box 6044
Rockville, MD 20850
December 1996
6-C1
-------
Underground Storage Tanks
Part I, Chapter 6
Guides to Compliance With Federal UST Regulations
Topic
Title
Order From
Emergency
Response
"Oh No!"—Petroleum Leaks and Spills:
What Do You Do?
Free
U.S. Environmental Protection
Agency
Office of Underground Storage
Tanks
P.O. Box 6044
Rockvilie, MD 20850
"An Overview of Underground Storage
Tank Remediation Options'*
NCEPI
Box 42419
Cincinnati, OH 45242
(513) 891-6685
HANDBOOKS
Technology
"Detecting Leaks: Successful Methods Step-
bv-Step"
U.S. Environmental Protection
Agency
Office of Underground Storage
Tanks
P.O. Box 6044
Rockvilie, MD 20850
"Cleanup of Releases from Petroleum USTs:
Selected Technologies"
Stock No. 055-000-00272-0
$7.50
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 783-3238
"Petroleum Tank Releases Under Control:
A Compendium of Current Practices for
State UST Inspectors"
Stock No. 055-000-00295-9
S8.50
"Processes Affecting Subsurface Transport
of Leaking Underground Tank Fluids"
Stock No. 055-000-00269-0
S3.25
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 783-3238
I
"Survey of Vendors of External Petroleum
Leak Monitoring Devices for Use with
USTs"
Stock No. 055-000-00277-1
S4.25
December 1996
6-C2
-------
Underground Storage Tanks
Part I, Chapter 6
Guides to Compliance With Federal UST Regulations
Topic
Title
Order From
AUDIOVISUAL PROGRAMS
Installation
"Doing It Right"—Installation for the Crews
Who Do It
$25.00 prepaid
American Petroleum Institute
1220 L. Street. NW.
Washington, DC 20005
"Doing It Right II"—Installing Required
UST Equipment
S60.00
"Recommended Practices on Tank
Installation"—Companion Booklet
S 10.00 prepaid
or
Petroleum Equipment Institute
Box 2380
Tulsa, OK 74101
"A Question of When"—Tank Installation
for Inspectors"
S22.85 prepaid
"In Your Own Backyard"—Shorter Version
of Inspector Video for Tank Owners
$22.85 prepaid
National Fire Protection Association
Attn: Jim Smalley
Batterymarch Park
Quincy, MA 02269
Leak
Detection
"Straight Talk on Leak Detection"
$40.00
"Petroleum Leaks Underground"
$75.00
Environmental Media Center
Box 30212
Bethesda, MD 20814
(301) 654-7141
Closure
"Tank Closure Without Tears: An
Inspector's Safety Guide"
$20.00 prepaid
Companion booklet
$5.00 prepaid
New England Interstate Water
Pollution Control Commission
Attn: VIDEOS
85 Merrimac Street
Boston, MA 02114
To borrow video and booklet
($5.00):
New England Regional Wastewater
Institute
2 Fort Road
South Pordand, ME 04106
"What Do We Have Here?: A Guide to Site
Assessment at Closure"
$40.00 prepaid
Companion booklet
$5.00 prepaid
New England Interstate Water
Pollution Control Commission
Attn: VIDEOS
85 Merrimac Street
Boston, MA 02 I 14
December 1996
6-C3
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Underground Storage Tanks
Part I, Chapter 6
Guides to Compliance With Federal UST Regulations
Topic
Tide
Order From
Tank Program
"Managing Underground Storage
National Audiovisual Center
Management
Tanks"—185-Slide Presentation Action Plan
Customer Services Section/WD
Si20.00 prepaid
8700 Edgeworth Drive
Capitol Heights, MD 20743-3701
(301) 763-1891
System
"What Do We Have Here?"—An
New England Interstate
Inspection
Inspector's Guide to Site Assessment at
Environmental Training Center
Tank Closure
ATTN: VIDEOS
$45.00
2 Fort Road
South Portland, ME 04106
Companion booklet
(207) 767-2539
S5.00
"Searching for the Honest Tank"—A Guide
to UST Facility Compliance Inspection
$40.00
Companion booklet
$5.00
December 1996
6-C4
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Notes
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CHAPTER 7
Toxic Chemical Reporting
7.1 Federal Requirements (EPCRA) 7-3
7.1.1 MSDS Chemical Reporting (EPCRA Section 311) 7-4
7.1.2 Annual Inventory Reporting (EPCRA Section 3 12) 7-10
7.1.3 Annual Release Reporting (EPCRA Section 313) 7-12
7.2 State Requirements 7-16
7.2 Where To Go for More Information 7-17
7.3 References 7-17
Federal and state regulations require industries with hazardous chemicals on
their premises (such as metal finishers) to provide information on their
chemical inventories. They also require companies to periodically report their
releases of chemicals into the environment. This chapter describes the federal
requirements for toxic chemical reporting. It will help you determine what,
when, where, and how you have to report inventory and release information.
Appendix 7-A summarizes the key federal requirements and compliance
deadlines you must meet. Additional appendices will help you determine the
extent to which your facility is covered by the federal requirements and how
you can comply with them.
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
Table of Contents Page
7.1 Federal Requirements (EPCRA) 7-3
7.1.1 MSDS Chemical Reporting (EPCRA Section 3 11) 7-4
7.1.1.1 What Requirements Must I Follow? 7-4
7.1.1.2 To Whom Must I Report? 7-4
7.1.1.3 What Are the Reporting Thresholds? 7-5
7.1.1.4 Are There Exemptions From This Requirement? 7-5
7.1.1.5 How Do I Calculate the Total Quantity of a Substance Present at My Facility? 7-6
7.1.1.6 How Do I Meet the MSDS Reporting Requirement for a Mixture or Solution? 7-6
7.1.1.7 How Do I Report MSDS Chemicals? 7-8
7.1.1.8 When Should 1 Report MSDS Chemicals? 7-10
7.1.2 Annual Inventory Reporting (EPCRA Section 312) 7-10
7.1.2.1 What Must I Report? 7-10
7.1.2.2 What Should I Include on My Inventory? 7-10
7.1.2.3 How Do I Report These Chemicals? 7-11
7.1.3 Annual Release Reporting (EPCRA Section 313) 7-12
7.1.3.1 What Must I Report? 7-12
7.1.3.2 Which Chemicals Must I Report? 7-12
7.1.3.3 What Information Must I Include in TRI Reporting? 7-12
7.1.3.4 How Do I Submit TRI Information? 7-13
7.1.3.5 Do I Have To Keep Records? 7-15
7.1.3.6 How Can I Obtain Protection for Trade Secrets? 7-16
7.2 State Requirements 7-16
7.3 Where To Go for More Information 7-17
7.4 References 7-17
Appendix 7-A Compliance Calendar for EPCRA Toxic Chemical Reporting Requirements
Appendix 7-B Hazard Categories
Appendix 7-C Example Tier Two Form
Appendix 7-D TRI Chemicals Typically Used in the Metal Finishing Industry
Appendix 7-E Worksheet for TRI Reporting
Appendix 7-F Guidance on Estimating Releases From Electroplating Operations
Appendix 7-G Complete List of TRI Chemicals
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
TOXIC CHEMICAL REPORTING: HOW TO COMPLY
~ Determine whether you have "Material Safety Data Sheet" (MSDS)
chemicals at your facility at or above 10,000 pounds (for hazardous
chemicals) or 500 pounds or the threshold planning quantity (for
extremely hazardous substances). If so:
— Submit the MSDSs or a list of MSDS chemicals to the State
Emergency Response Commission (SERC), the Local Emergency
Response Committee (LEPC), and the local fire department.
— By March 1 of each year, submit an annual inventory report for MSDS
chemicals to the LEPC, SERC, and local fire department.
Determine whether you use hazardous chemicals in amounts that
trigger Toxic Release Inventory (TRI) reporting requirements. If so:
— By July I of each year, submit "Form R" for each chemical.
~ Determine and comply with any additional state, regional, and local
requirements.
7.1 Federal Requirements (EPCRA)
The Emergency Planning and Community Right-to-Know Act
(EPCRA)1 was passed in 1986 in response to concerns about
chemical accidents and emergencies. EPCRA regulations require
industries that have hazardous chemicals on their premises (such as
metal finishers) to provide information about the amount, type, and
location of these chemicals. Local planners and response personnel
use this information to prepare for and respond to chemical
emergencies. Also, the regulations require you to report information
about releases of toxic chemical from your facility. This information
is available to the public. The EPCRA inventory and release
requirements cover three broad areas, as shown in Box 7-1.
' Also known as Tille III of SARA (the Supert'und Amendments and Reauthorization Act).
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Toxic Chemical Reporting
Part I, Chapter 7
(Additional EPCRA requirements pertaining to emergency planning
and notification are covered in Chapter 8.)
Box 7-1
Toxic Chemical Reporting Requirements of EPCRA
Section 3 11
Requires you to report initial information on chemicals
for which vou keep material safety data sheets
(MSDSs) on file. This requirement is discussed in
Section 7.1.1.
Section 312
Requires vou, once a year, to provide an inventory of
MSDS chemicals at your facility. This requirement is
discussed in Section 7.1.2.
Section 3 13
Requires vou, once a year, to report information about
releases of hazardous chemicals from your facility.
This requirement is discussed in Section 7.1.3.
7.1.1 MSDS Chemical Reporting (EPCRA Section 311)
7.1.1.1 What Requirements Must I Follow?
If your facility handles hazardous chemicals, you are probably
required by the U.S. Occupational Safety and Health
Administration (OSHA) to keep material safety data sheets
MSDSs) on file for all hazardous chemicals in the workplace.
Under EPCRA, you are required to report these hazardous chemicals
when they are present at your facility in quantities that exceed
particular thresholds.
Some companies keep MSDSs for nonhazardous chemicals and may
choose to report these chemicals as well.
7.1.1.2 Whom Must I Report To?
You must provide information about MSDS chemicals to your Local
Emergency Planning Committee (LEPC), State Emergency Response
Commission (SERC), and local fire department, so that these
agencies can plan for unexpected emergencies. You'll find
information on LEPCs and SERCs in Section 8.1.2.1 of Chapter 8.
Appendix 8-C in Chapter S provides contact information for SERCs.
December 1996
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Toxic Chemical Riimdrting
Part I, Chapter 7
7.1.1.3 What Are the Reporting Thresholds?
The reporting requirement applies to chemicals present at your
facility in the following quantities:
¦ All extremely hazardous substances (EHSs) present at your
facility in an amount equal to or greater than 500 pounds or
the threshold planning quantity (TPQ), whichever is lower.
Appendix 8-D in Chapter 8 provides a complete list of
extremely hazardous substances and their TPQs. (When you
review this appendix, you'll find that two TPQs are provided
for EHSs that are solids. Box 8-3 tells you how to determine
which TPQ applies to your solid.)
¦ All other MSDS chemicals (i.e., chemicals for which OSHA
requires you to have an MSDS) that are present at your
facility at anv one time in amounts equal to or greater than
10,000 pounds.
This reporting requirement is broader than the reporting
requirement for emergency planning described in Chapter 8 (Section
8.1.2). The emergency planning requirement covers only extremely
hazardous substances, while the MSDS reporting requirement
discussed here covers nearlv every hazardous chemical at vour
~ ~ ~
facility.
7.1.1.4 Are There Exemptions From This Requirement?
Research laboratories and users of most household and agricultural
products are exempt.
Also, MSDS chemical reporting is not required if a hazardous
chemical is present as a solid in a manufactured item and exposure
does not occur under normal conditions of use. For example, steel
would be exempt until you weld it, grind it, or do anything else
resulting in a release that could cause exposure to the hazardous
constituents of steel (such as chromium and nickel).
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Toxic Chemical Reporting
Part I, Chapter 7
7.1.1.5 How Do I Calculate the Total Quantity of a
Substance Present at My Facility?
First, vou'll need to identify the various "containers" that hold the
~ »
substance or a mixture or solution containing that substance. Be
sure to consider both storage containers and process lines and tanks.
Then, you'll need to calculate the amount of the substance (by
weight) in each container or line. Finally, you'll need to add each of
those amounts to get a grand total which you can then compare to
the appropriate threshold (500 pounds or the TPQ for extremely
hazardous substances, and 10,000 pounds for all other MSDS
chemicals). Examples for chemicals I and II in Box 7-2 provide
sample calculations that illustrate this approach.
The total amount of any particular chemical at your facility may
vary over time. For EPCRA Section 311 requirements, it's
important to calculate the maximum total amount of the substance
present at your facility at any one time. This is referred to as the
maximum daily amount (MDA).
7.1.1.6 How Do I Meet MSDS Reporting Requirements
for a Mixture or Solution?
Commercial mixtures and solutions have their own MSDSs. They
also may contain one or more chemical constituents that have
MSDSs. You have two choices about how to determine whether
MSDS reporting applies to the mixture.
Whole Mixture Approach
You can compare the total quantity of the mixture at your facility
to the appropriate reporting threshold. If the total quantity exceeds
the reporting threshold, you'll need to report the mixture. The
example for Chemical III in Box 7-2 illustrates this approach.
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
Box 7-2 Example Calculations for a Hypothetical Metal Finishing Facility
A facility maintains several MSDSs. The manager considers which of these substances are an "Extremely
Hazardous Substance" fEHS) or simply "Hazardous Chemical" (HC), and whether it is a mixture. The
manager has identified at least four products that are or contain listed substances: sodium cvanide,
hydrochloric acid, "Nickel Brite," and "Solvent-C." The maximum daily storage amount of the listed
substances must be calculated to determine if reporting is required.
Chemical I: Sodium Cyanide
Sodium cvanide is an EHS stored at the facility in two 55-gallon drums that each weigh 500 lbs.
With two drums (1,000 lbs), the facility exceeds the substance's threshold planning quantity (TPQ)
of 100 lbs. This chemical must be reported.
Maximum Dailv Amount (MDA) = 2 drums x 500 lbs = 1,000 lbs
Chemical II: Hydrochloric Acid
Hydrochloric acid is an HC stored at the facility in 55-gallon drums and used in electroplating
process lines. Up to 30 drums, totallv 1,650 gallons, mav be stored at any one time. The process
lines hold 2,000 gallons. Each gallon weighs approximately 9 lbs. The total maximum amount stored,
on site is 32,850 lbs, which exceeds the TPQ for HC1 of 10,000 lbs. This chemical must be reported.
MDA = 14,850 lbs (30 drums x 55 gal x 9 lbs/gal) + 18,000 lbs (2,000 gal x 9 lbs) = 32,850 lbs
Chemical III: Nickel Brite
"Nickel Brite" is an electroless nickel plating bath mixture containing nickel sulfate. Nickel sulfate is
an HC because it is a nickel compound. The facility stores no more than two 55-gallon drums and a
00-gallon plating tank is usually full. Therefore, the facil'tv decs not store more than 610 gallons
(6,710 lbs) of "Nickel Brite." Instead of calculating the components of the mixture, including nickel
sulfate, individually, the manager chooses to consider "Nickel Brite" as a product. Its maximum
amount of 6,710 lbs does not exceed the HC threshold of 10,000 lbs. "Nickel Brite" does not need to
be reported.
MDA = 1,210 lbs (2 drums x 55 gal x 1 I lbs/gal) + 5,500 lbs (500 gal x 1 1 lbs/gal) = 6,710 lbs
Chemical IV: "Solvent-C"
"Solvent-C" is a mixture with 1.5% (bv weight) of glycol ether. Glycol ether is the only HC in this
product. "Solvent-C" is stored at the facility in a 1,000-gallon holding tank, and is used in the shop
in five 100-gallon containers. Therefore, the maximum amount of "Solvent-C" (8 lbs/gal) onsite is
12,000 lbs (1,500 gal x 8 lbs/gal). This exceeds the HC threshold of 10,000 lbs. The manager
decides to check whether the quantitv of the glycol ether constituent exceeds the reporting threshold.
Since glycol ether is onlv 1.5% of "Solvent-C," only 180 lbs of this HC is stored. This is well below
the 10,000-lb threshold, so neither the mixture as a whole or its glycol ether constituent needs to be
reported.
MDA = 0.0 1 5 x (1 2.000 lbs) = 1 SO lbs
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
The advantage of the whole mixture approach is that it reduces the
calculations you must perform. The disadvantage is that you are
more likelv to exceed the reporting thresholds than when you use
the individual constituent approach described below. This is because
constituents may make up only part of the mixture, and therefore
mav be less likely to exceed their reporting thresholds. Another
disadvantage is that fire departments and LEPCs may prefer to have
more specific information about the mixture components.
Individual Constituent Approach
You can calculate the individual quantity of each MSDS constituent
in the mixture and compare it to the appropriate reporting
threshold. You can do this by multiplying the concentration of the
hazardous constituent, in weight percent, by the mass (in pounds)
of the mixture or solution. Compare this total to the reporting
threshold for the compound. Report any constituents that exceed
their reporting threshold. This approach is illustrated in the
example for Chemical IV in Box 7-2. As the example illustrates,
even when the mixture as a whole triggers reporting requirements,
you can avoid reporting if the quantities of hazardous constituents
are below threshold amounts.
When you use the individual constituent approach, you don't have
to count very small quantities in mixtures or solutions. Specifically:
¦ For carcinogens (chemicals suspected to cause cancer), you
don't have to count quantities that constitute less than 0.1
percent of a mixture.
¦ For noncarcinogens, you don't have to count quantities that
constitute less than 1 percent of a mixture.
Check the MSDS to find out whether the chemical is a carcinogen.
7.1.1.7 How Do I Report MSDS Chemicals?
To report your MSDS chemicals, you may submit either actual
copies of the MSDSs or a list of the MSDS chemicals to your SERC,
LEPC, and local fire department. EPA recommends that you submit
a list rather than the actual MSDSs, because it is less burdensome
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
than copving the MSDSs and is easier for the SERC, LEPC, and fire
department to use.
If vou submit a list instead of the actual MSDSs, your list must
meet the following conditions:
¦ You must list the chemical name or common name of each
compound.
¦ For mixtures, you can list the mixture itself or itemize each
hazardous component of the mixture that is present at your
facility in a quantity above the reporting threshold.
¦ You must indicate which of five hazard categories apply to
each chemical: immediate (acute) health hazard, delayed
(chronic) health hazard, fire hazard, sudden release of
pressure, and reactive. You can find information on hazard
categories on the MSDS. Appendix 7-B provides information
that can help you select the appropriate EPA hazard
categories based on the MSDS information.
An example of a list of MSDS chemicals is shown in Box 7-3 below.
Box 7-3 E
xample List of MSDS Chemicals
Li-.
Hazardous
Chemical
Fire Hazard
Sudden
Release of
Pressure
Reactivity
Immediate
Health
Hazard
Delaved
Health
Hazard
Sodium
Cyanide
X
X
Hydrochloric
Acid
X
X
"Nickel Brite"
X
X
"Solvent-C"
X
If vou submit a list rather than copies of the MSDSs, the LEPC
could ask vou to also submit the MSDSs. If the LEPC makes this
request, vou must submit the MSDSs within 30 days.
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Toxic Chemical Reporting
Part I, Chapter 7
7.1.1.8 When Should I Report MSDS Chemicals?
The MSDS or listed information for a hazardous chemical must be
submitted within 3 months from the time the chemical is present at
your facility in an amount that triggers the reporting requirement.
You are onlv required to provide this notification once for each
chemical. However, if you discover significant new information (for
example, vou discover there was an important error in the MSDS
vou submitted), vou must submit a revised MSDS within 3 months
of this discovery.
7.1.2 Annual Inventory Reporting (EPCRA Section 312)
7.1.2.1 What Must I Report?
In addition to the one-time reporting requirement described above,
each year you must report your inventory of hazardous chemicals to
the LEPC, the SERC, and the fire department. You must submit
this inventory report, which covers the previous calendar year, by
March 1 of each year.
Note this date on your calendar—you are not likely to receive any
reminder notices from the reporting entities.
7.1.2.2 What Should I Include on My Inventory?
You are required to report hazardous chemicals that were present
during the previous calendar year at or above the minimum
reporting thresholds:
¦ 500 pounds or the TPQ, whichever is lower, for extremely
hazardous substances.
¦ 10,000 pounds for all other hazardous chemicals for which
you are required to have an MSDS.
Note that these are the same chemicals and reporting thresholds
covered bv the one-time reporting requirements described in Section
7.1.1 above. Refer back to Sections 7.1.1.5 and 7.1.1.6 for
guidance on calculating the total quantity of a chemical at your
tacilitv.
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Toxic Chemical Reporting
Part I, Chapter 7
7.1.2.3 How Do I Report These Chemicals?
You have two choices for annual inventory reporting, called "Tier I"
and "Tier II." Both approaches involve filling out a form, available
from the EPCRA Hotline (800-535-0202). Under Tier I, you must
report the amounts and general location of chemicals in each of the
five hazard categories (fire hazard, sudden release of pressure,
reactivity, immediate health hazard, delayed health hazard). For
example, a Tier I report might say that the facility stores 10,000
pounds of substances that cause delayed health effects.
A Tier II report contains basically the same information, but
includes specific details about each hazardous chemical present at
the facility. For example, it might report that the facility has 500
pounds of trichloroethylene, and it would indicate the physical and
health hazards associated with this substance, as well as its storage
location and conditions (such as a tank at elevated temperature and
ambient pressure). Check to see whether the Tier II report can be
filed electronically in your state. An example of a completed Tier II
Form is shown in Appendix 7-C.
You may choose whether to file Tier I or Tier II reports, unless the
SERC, LEPC, or local fire department requests Tier II. If you use
Tier I, you will divulge somewhat less information. You need to go
through the same process to cc r.plete both forms, however, and
EPA and many states encourage companies to submit Tier II reports,
because they provide emergency planners and communities with
more useful information.
You can obtain instructions for filling out the Tier I and Tier II
forms bv calling the EPCRA Hodine (800-535-0202). Make sure to
mail the form using certified mail so you have proof it was
submitted on time.
State and local requirements for annual inventory reporting may
differ from the federal requirements. Check with your SERC or
LEPC for more information.
December 1996
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Toxic Chemical Reporting
Part I, Chapter 7
7.1.3 Annual Release Reporting (EPCRA Section 313)
7.1.3.1 What Must I Report?
The requirements for Toxic Release Inventory (TRI) reporting (also
known as "Form R" reporting) apply to all facilities with SIC codes
of 20-39 that have 10 or more full-time employees (most metal
finishing facilities have an SIC code of 34). By July 1 of each year
vou must report the releases of toxic chemicals from your facility
that occurred during the previous calendar year.
A release is defined as "any spilling, leaking, pumping, pouring,
emitting, emptying, discharging, injecting, escaping, leaching,
dumping, or disposing into the environment of any toxic chemical."
Note that this definition includes both permitted and accidental
releases.
7.1.3.2 Which Chemicals Must I Report?
You must report annual releases for any of approximately 600
chemicals and chemical categories listed in the EPCRA regulations.
Reportable chemicals commonly found in the metal finishing
industry are listed in Appendix 7-D. Review this appendix to find
chemicals used at your facility. Then answer the three questions in
Fox 7-4 to see if you need to report the releases of any listed
chemicals. The information in Box 7-5 can help in answering these
questions.
Appendix 7-E provides a worksheet you can use to record the
calculations you make to determine whether or not chemicals at
your facility are subject to the TRI requirements.
7.1.3.3 What Information Must I Include in TRI
Reporting?
If your facility employs 10 or more full-time workers, you must
report the following information for any chemical that your facility
"manufactures, processes, or otherwise uses" in quantities greater
than the reporting thresholds:
¦ Whether the chemical is manufactured, processed, or used at
vour facility.
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Toxic Chemical Reporting
Part I, Chapter 7
¦ The maximum amount of the chemical present at your facility
during the year.
¦ For each waste stream, the waste treatment and disposal
methods typically used, and an estimate of the treatment
efficiency typically achieved by these methods for that waste
stream.
¦ The annual releases of the chemical to each environmental
medium (air, water, land). See Appendix 7-F for guidance in
estimating releases.
¦ Data on pollution prevention. This includes information on
quantities that are treated, used for energy recovery, or
recycled, both on and off site, and qualitative information
about source reduction efforts. This information helps EPA
evaluate the progress of national pollution prevention efforts.
7.1.3.4 How Do I Submit TRI Information?
You must submit a separate form, known as Form R, for each toxic
chemical that you report. EPA sends a TRI reporting package,
including Form R and instructions, to all facilities that submitted a
Form R in previous years.
If you do not receive the reporting package automatically, you can
obtain it by calling EPA's EPCRA Hotline at 1-800-535-0202.
Request EPA Publication 745-K-94-001, Toxic Chemical Release
Inventory Reporting Form R and Instructions. You can also request
a software package that EPA has developed to help facilities fill out
and submit Form R.
By July 1 of every calendar year, you must send vour
completed Toxic Release Inventory (TRI) reports to vour
State Environmental Response Commission (SERC), listed in
Appendix 8-C, and to EPA at:
EPCRA Reporting Center
P.O. Box 3348
Merrifield, VA 22116-33489
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Toxic Chemical Reporting
Part I, Chapter 7
Box 7-4 Determining Whether You Need To Report Releases of a Listed
Chemical
1. Do I manufacture or process 25,000 pounds of the listed chemical annually?
Manufacturing means to produce, prepare, import, or compound one of the toxic chemicals on the list. ;
Processing means incorporating the toxic chemical into a product. For example, a pigment coated onto j
a metal part would be considered "processed." However, the solvent carrier in the paint, which '
volatilizes during application, does not remain in the product and therefore would not be considered ;
"processed." j
See the example calculations in the box, "How To Calculate Amounts of Chemicals Processed or ;
Otherwise Used." !
It vou answered "ves" to question I, go to question 3. j
Ifvou answered "no. "go to question 2. ;
2. Do I otherwise use 10,000 pounds of the listed chemical annually?
Odierwise use means using a toxic chemical in a way that is not covered by the terms "manufacture"
or "process." Degreasing solvents, cleaning agents, wastewater treatment reagents, and other chemicals
that do not become part of the finished product are considered "otherwise used." See the example
calculations in the box, "How To Calculate Amounts of Chemicals Processed or Otherwise Used."
If you answered "ves" to question 2, go to question 3.
Ifvou answered "no, "you do not have to report any releases of this chemical.
3. Do I meet the "alternate threshold" for low-volume facilities?
To find out, calculate ie "reportable" amount of the chemical by adding the total quantities that are:
• Released at vour facility (see Appendix 7-F).
• Disposed of within vour facility.
• Treated at your facility.
• Recovered at your facility as a result of recvcle operations.
• Combusted for purposes of energy recovery at your facility.
• Transferred from your facility to off-site locations for the purpose of recycling, energy
recovery, treatment, and/or disposal.
3a. Is this reportable amount below 500 pounds? and
3b. Do I use less than 1 million pounds per year of the chemical?
If vou answered "i'es" to both questions 3a and 3b above, dien vou can file "Form A " instead of "Form
R. " Form A is a simplified form of reporting.
If i vu answered "no" to either question 3a or 3b. then vou must include releases for this chemical in
vour TRI report.
Note: You must submit Till information for each chemical for which a threshold is exceeded. The
thresholds applv separately; therefore, if vou both process and otherwise use a chemical and either
threshold is exceeded, vou must report for both activities. If neither threshold is exceeded, no report
is needed.
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Toxic Chemical Reporting
Part I, Chapter 7
Box 7-5 How to Calculate Amounts of Chemicals Processed or Otherwise Used
The amount of a chemical processed or otherwise used at your facility is the amount you purchased
during the vear, adjusted for beginning and ending inventories.
EXAMPLE: Calculating annual use of glycol ether through purchases and inventory changes
(including amounts in storage and in process)
Opening stock 5,000 lbs
Plus purchases during year 1 2.000 lbs
Subtotal 1 7,000 lbs
Less closing stock 6.000 lbs
Total use 1 1,000 lbs
How to Calculate the Amount of a Chemical in a Mixed Formulation
To calculate the amount of a chemical in mixed formulations, multiply the amount of the mixture (in
pounds) bv the concentration (weight percent).
EXAMPLE: Estimating usage of n-butyl alcohol (NBA) in coating formulations
In 1995, a plant used from inventory 5,000 gallons of a clear topcoat containing 15 percent NBA bv
volume. The plant also purchased and used 15,000 gallons of a color topcoat containing 7 percent NBA
bv volume. In addition, it purchased 300 gallons of a formulation containing 95 percent NBA by volume,
which was used for thinning and cleaning. Total annual usage of NBA was as follows:
Annual usage of NBA =
(5,000 gal x 0.15) + (15,000 gal x 0.07) + (300 gaJ x 0.95) = 2,085 gal
The densitv of NBA is 0.810 k^liter; therefore, the annual usage in gallons can be converted to pounds
r.s follows:
Annual usage of NBA =
2,085 gal x (3.785 liters/gal) x (0.810 kg/liter) x (2.205 ib/kg) = 14,095 lb
The "otherwise used" threshold of 10,000 pounds applies because the NBA is not incorporated into the
final product. The plant uses more than 10,000 pounds per year of NBA, so it must report its annual
releases for this substance.
7.1.3.5 Do I Have To Keep Records?
For each chemical report, you are required to keep a copy of Form
R and the documentation of how you made the compliance
determination. You must retain these records for 3 years after
submitting the Form R report. If you use the Appendix 7-E
worksheet to calculate maximum reportable chemicals, be sure to
retain this worksheet as part of these records. It may also be helpful
to retain copies of calculations for chemicals that you determine are
not subject to the requirements.
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Part I, Chapter 7
7.1.3.6 How Can I Obtain Protection for Trade Secrets?
Protection of trade secrets is mainlv a concern for manufacturers.
~
In the event that vou manufacture chemicals, you should be aware
that under limited conditions, a company reporting under EPCRA
can request that the identity of specific chemicals in its reports not
be disclosed to the public. To protect a chemical's identity from
disclosure, you must be able to prove that the information has not
been reported under any other environmental regulation, and that
it is a legitimate trade secret—in other words, that disclosure could
damage vour company's competitive position. You must answer a
series of questions to substantiate trade secret claims on the form
entitled "Substantiation to Accompany Claims of Trade Secrecy"
(available from the EPCRA Hotline).
If EPA upholds your claim of trade secrecy, you still must include
the chemical's identity in your reports to EPA. EPA will keep the
original reports in a confidential file, and "sanitized" versions of the
reports, with the chemical name deleted, will be available to the
public.
7.2 State Requirements
Some states have additional reporting requirements for facilities that
handle toxic chemicals. You need to be aware of the requirements
in your state as well as those specified in the federal law. Contact
your LEPC, SERC, or EPA Regional Office for additional
information about these requirements.
December 1996
7-16
-------
Toxic Chemical Reporting
Part I, Chapter 7
7.3 Where To Go for More Information
To get more information about requirements for toxic chemical
reporting, contact:
¦ Your State Emergency Response Commission (see Chapter 8,
Appendix 8-C).
¦ Your Local Emergency Planning Committee.
¦ Your EPA Regional Office.
¦ EPA's Emergency Planning and Community Right-To-Know
Hotline (1-800-535-0202).
The federal regulations discussed in this chapter are found in the
Code of Federal Regulations (CFR), Title 40, Parts 350 and 370.
The CFR is found in many libraries or is available by writing:
The Superintendent of Documents
Attn: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
or call the Government Printing Office order desk at 202-783-3238.
7.4 References
1. U.S. Environmental Protection Agency, 1987. Estimating releases
and waste treatment efficiencies for the toxic chemical release inventory
form, EPA 560/-88-002. Washington, DC,
2. U.S. Environmental. Protection Agency. 1991. Procedures for
establishing emissions for early reduction compliance extensions: Volume
1—Synthetic organic chemical manufacturing, ethylene oxide
sterilization, and chromium electroplating, EPA 450-91-012a,
Research Triangle Park, NC. July.
December 1996
7-17
-------
Toxic Chemical Reporting
Part I, Chapter 7
3. U.S. Environmental. Protection Agency. 1990. Section 313
reporting issue paper: clarification and guidance for the metal fabrication
industry. Washington, DC. January.
4. U.S. Environmental. Protection Agency. Toxic chemical release
inventory reporting Form R and instructions. EPA 745-IC94-001.
Latest version.
December 1996
7-18
-------
APPENDIX 7-A
COMPLIANCE CALENDAR FOR EPCRA TOXIC CHEMICAL
REPORTING REQUIREMENTS
-------
o
o
o
CD
3
CT
CO
CO
CD
Regulatory Compliance and Environmental Management Calendar
Due Dale and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHAPTER 7 - TOXIC CHEMICAL REPORTING
Miles lone Events
March 1 (Annual)
Inventory of hazardous
chemicals (Tier 1 or 11
form)
CPCRA
312
Submit inventory of hazardous materialspresent at
facility during previous year
Llil'C, SERC, local
fire department
7-10
July 1 (Annual)
Toxics Release Inventory
(Form R) report
EPCRA
313
Calculate and report releases of toxic chemicals
from the facility for the previous calendar year.
SERC, EPCRA
Reporting Center
7-12
Regular or Periodic Events
Other Events
If a listed chemical
becomes present at
the facility in an
amount that triggers
the reporting amount
. .within 3 months
MSDS or list of MSDS
chemicals
EPCRA
311
Submit an MSDS or list of MSDS chemicals
SERC, LEPC, and
local fire department
7-10
•nJ
>
-------
APPENDIX 7-B
HAZARD CATEGORIES
-------
Toxic Chemical Reporting
Part I, Chapter 7
Hazard Categories for Classifying Chemicals
EPA's Hazard Categories
Additional Hazard Categories That May Be
Found on MSDS Sheets
Fire Hazard
Flammable
Combustible liquid
Pvrophoric
Oxidizer
Sadden Release of Pressure
Explosive
Compressed gas
Reactive
Unstable reactive
Organic peroxide
Water reactive
Immediate (Acute) Health Hazard
Highly toxic
Toxic
Irritant
Sensitizer
Corrosive
Other hazardous chemicals with an adverse effect
on a targ " organ that generally occurs as a result
of short-term exposure and with a short duration
Delayed (Chronic) Health Hazard
Carcinogens
Other hazardous chemicals with an adverse effect
on a target organ that generally occurs as a result
of long-term exposure and with a long duration
December 1996
7-B1
-------
APPENDIX 7-C
EXAMPLE TIER II FORM
-------
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-------
APPENDIX 7-4D
TRI CHEMICALS TYPICALLY USED IN THE
METAL FINISHING INDUSTRY
-------
Toxic Chemical Reporting
Part 1, Chapter 7
TRI Chemicals Typically Used
in the Metal Finishing Industry2
Solvents:
1,1,1 -T richloroe thane
Methyl edivl ketone (MEK)
Acetone
O-Dichlorobenzene
Benzene
Tetrachloroethvlene
Butyl alcohol
Toluene
Carbon tetrachloride
T richloroethvlene
Chloroform
T richlorotrifluoroethane
Dichloroethane (methylene chloride)
Trichlorotrifluoromethane
Freon 113
White spirits
GIvcol ethers
Xylene
Kerosene
Acids/Alkalines:
Acetic acid
Nitric acid
Ammonium hvdroxide
Perchloric acid
Hydrazine
Phosphoric acid
Hvdrobromic acid
Potassium hydroxide
Hydrochloric acid
Sodium hydroxide (delisted in 1989)
Hydrofluoric acid
Sulfuric acid
Nitrates
Cyanide Compounds:
Cyanide compounds
Potassium cyanide
Potassium silver compounds
Sodium cyanide
Plating Solutions:
Ammonia
Lead
Cadmium oxide
Manganese
Chlorine
Nickel
Chromium compounds
Zinc
Copper
Source: U.S. Environmental Protection Agency. 1993. Sustainable industry project: metal finishing
industry sector, "Top 25 Chemicals" (Exhibit 3-B). Washington, DC.
2 Note: Remember that the chemicals listed are for illustration only. For a complete listing, see
Appendix 7-G or check the expanded Toxic Chemical List in 40 CFR Part 372.65. Also, be aware that EPA
frequently amends this list; call the EPCRA Hodine at (800) 535-0202 for updates.
December 1996 7-D1
-------
APPENDIX 7-E
WORKSHEET FOR TRI REPORTING
-------
Toxic Chemical Reporting
Part I, Chapter 7
WORKSHEET FOR CALCULATING TRI REPORTING THRESHOLDS
Chemical Name:
CAS No.:
Record the calculations you use to determine whether this chemical is reportable.
Make as many copies of this form as needed. For chemicals that are subject to TRI requirements, be sure
to retain copies of this form and the corresponding Form R. Keep these copies for 3 years after you submit
the Form R.
December 1996
7-E1
-------
APPENDIX 7-F
GUIDANCE ON ESTIMATING RELEASES FROM
ELECTROPLATING OPERATIONS
-------
United States
Environmental Protection Office of Pesticides EPA 560/4-88-004g
Agency and Toxic Substances January 1988
v>EPA Title III Section 313
Release Reporting
Guidance
Estimating Chemical Releases From
Electroplating Operations
-------
Estimating Chemical Releases From
Electroplating Operations
Facilities engaged in electroplating opera-
tions may be required to report annually any
releases to the environment of certain chemi-
cals regulated under Section 313. Title III, of
the Superfund Amendments and Reautho-
rization Act (SARA) of 1986. If your facility is
classified under SIC codes 20 through 39
(electroplating facilities generally fall under
SIC code 3471) and has 10 or more full-time
employees, for calendar year 1987 you must
report all environmental releases of any Sec-
tion 313-Iisted chemical or chemical category
manufactured or processed by your facility in
an amount exceeding 75.000 pounds per year
or otherwise used in an amount exceeding
10,000 pounds per year. For calendar years
1988 and 1989 (and beyond), the threshold
reporting quantity for manufactured or pro-
cessed chemicals drops to 50,000 and 25.000
pounds per year, respectively.
This document has been developed to
assist those who perform electroplating
operations in the completion of Part III
(Chemical Specific Information) of the Toxic
Chemical Release Inventory Reporting Form.
Included herein is general information on
toxic chemicals used and process wastes
generated, along with several examples to
demonstrate the types of data needed and
various methodologies available for esti-
mating releases. If your facility performs
other operations in addition to electroplating,
you must also include any releases of toxic
chemicals from these operations.
S \
Step One
Determine if your facility processes or
uses any of the chemicals subject to
reporting under Section 313.
A suggested approach for determination
of the chemicals your facility uses that could
be subject to reporting requirements is to
make a detailed review of the chemicals and
materials you have purchased. If you do not
know the specific ingredients of a chemical
formulation, consult your suppliers for this
information. If they will not provide this
information, you must follow the steps out-
lined to handle this eventuality in the in-
structions provided with the Toxic Chemical
Release Inventory Reporting Form.
The list presented here includes chemi-
cals typically used in electroplating opera-
tions that are subject to reporting under
Section lo. This list does not necessarily
include all of the chemicals your facility uses
that axe subject to reporting, and it may
include many chemicals that you do not use.
You should also determine whether any of the
listed chemicals are created during
processing at your facility.
Degreasing solvents: Perchloroethylene,
trichloroethylene. methylene chloride.
1.1.1-trichloroethane. and others
Alkaline cleaning agents: Sodium
hydroxide
Acid cleaning and pickling agents:
Sulfuric acid, hydrochloric acid, phos-
phoric acid, nitric acid, chromic acid
1
-------
Chelating agents: Thiourea, nitrilo-
triacetic acid (NTA). ethyleneimine
(aziridine)
Components of plating and other
process baths: Cadmium compounds,
chromium compounds, sodium
hydroxide, cobalt compounds, copper
compounds, lead compounds, nickel
compounds, silver compounds, zinc
compounds, cyanide compounds, sulfuric
acid, sodium sulfate, phosphoric acid,
ammonia, arsenic compounds, selenium
compounds, various aldehydes
Step Two
Determine if your facility surpassed the
threshold quantities established for
^reporting of listed chemicals last year. J
You must submit a separate Toxic Chemi-
cal Release Inventory Reporting Form for
each Listed chemical that is "manufactured."
"processed," or "otherwise used" at your
facility in excess of the threshold quantities
presented earlier. Manufacture includes
materials produced as byproducts or impu-
rities. Toxic compounds that are incorpo-
rated into your products (for example, metals
that are plated onto metal articles) would be
considered "processed" because they become
part of the marketed finished product. De-
greasing solvents, cleaning agents, and other
chemicals that do not become part of the
finished product would be considered
"otherwise used."
The amount of a chemical processed or
otherwise used at your facility represents the
amount purchased during the year, adjusted
for beginning and ending inventories. To
ascertain the amount of chemical in a mixed
formulation, multiply the amount of the
mixture (in pounds) by the concentration of
the chemical (weight percent) to obtain the
amount of chemical processed.
Example: Determining whether 1,1,1-
trichloroethcuxe was used in sufficient
quantity to require reporting under
Section 313.
An electroplater purchased 95 percent
1.1.1 -trichloroethane for use in a vapor
degreaser. In 1987. 3.000 pounds of this
material was in storage at the beginning of
the year. 18.000 pounds was purchased,
and 6.000 pounds was in storage at the
end of the year. The quantity of 1.1.1-
trichloroethane used by the facility equals:
(3.000 lb x 0.95) (beginning
inventory) +
(18,000 lb x 0.95) (purchased) -
(6.000 lb x 0.95) (ending inventory)
= 14.250 lb
A listed chemical may be a component of
several formulations you purchase, so you
may need to ask your supplier for informa-
tion on the concentration (percentage) of the
chemical in each. For chemical categories,
your reporting obligations are determined by
the total amounts of all chemicals in the
category. For example, in a copper plating
bath, three cyanide-containing compounds
are used: CuCN. NaCN, and KCN. The
quantity of cyanide compounds used equals
the sum of the quantities of CuCN, NaCN.
and KCN used. For a substance such as
CuCN, the amount used must be considered
in determining whether the threshold is met
for both copper- and cyanide-containing
compounds.
You must complete a report for each
chemical for which a threshold is exceeded.
The thresholds apply separately: therefore, if
you both process and use a chemical and
either threshold is exceeded, you must report
for both activities. If neither threshold is
exceeded, no report is needed.
2
-------
/ \
Step Three
Identify points of release for the
^ chemical(s) subject to reporting. J
An effective means of evaluating points of
release for listed toxic chemicals is to draw a
process flow diagram identifying the opera-
tions performed at your facility. The figure
on the right is an example flow diagram for
electroplating (chromium plating of zinc die
castings). Because each facility is unique,
you are strongly urged to develop a flow
diagram for your particular operations that
details the input of materials and chemicals
and the waste sources resulting from the
operation of each unit.
The largest source of toxic releases at
electroplating facilities will occur in the
wastewater. Wastewater is generated from a
variety of sources, including the rinsing of
parts between process baths during metal
cleaning, plating, and post-plating opera-
tions: the dumping of exhausted or spent
process baths: and the rinsing required
during auxiliary operations such as rack
stripping. Wastewater usually is centrally
collected and treated before discharge: thus,
all of these sources are aggregated into one
release point. Solid waste is generated
primarily from the treatment of wastewater.
Other sources include filter solids from
plating baths, anode wastes, spent degreaser
solvent and sludge, and precipitates from
electroless nickel bath regeneration. Two
notable air releases are solvents from metal-
degreasing operations and mists evolved from
electrolytic cleaning solutions and cyanide
and chromium plating solutions.
METAL PAflTS
Example Plow Diagram of Chromium
Plating of Decorative Zinc Die Castings
3
-------
Step Four
^ Estimate releases of toxic chemicals. J
After ail of the toxic chemicals and waste
sources have been identified, you can esti-
mate the releases of the individual chemicals.
Section 313 requires that releases to air.
water, and land and transfers to offsite facili-
ties be reported for each toxic chemical meet-
ing the threshold reporting values. The usual
approach entails first estimating releases
from waste sources at your facility (that is,
wastewater, air release points, and solid
waste) and then, based on the disposal
method used, determining whether releases
from a particular waste source are to air,
water, land, or an offsite disposal facility.
In general, there are four types of release
estimation techniques:
• Direct measurement
• Maas balance
• Engineering calculations
• Emission factors
Descriptions of these techniques are provided
in the EPA general Section 313 guidance
document. Estimating Releases and Waste-
Treatment Efficiencies for tne Toxic Chemical
t
Release Inventory Form.
Provisions of the Clean Air Act. Clean
Water Act, Resource Conservation and Re-
covery Act. and other regulations require
monitoring of certain waste streams. If
available, data gathered for these purposes
can be used to estimate releases. When only
a small amount of direct measurement data
is available, you must decide if another esti-
mation technique would give a more accurate
estimate. Mass balance techniques and
engineering assumptions and calculations
can be used in a variety of situations to
estimate toxic releases. These methods of
estimation rely heavily on process operating
parameters; thus, the techniques developed
are very site-specific. Emission factors are
available for some Industries in publications
referenced in the general Section 313 guid-
ance document. Also, emission factors for
your particular facility can be developed in-
house by performing detailed measurements
of wastes at different production levels.
Toxic Releases Via Wastewater
The U.S. Environmental Protection
Agency has set effluent limitations on electro-
plating wastewater discharges to publicly
owned treatment works (POTWs) and into
navigable waters. Your facility is therefore
probably required by a local pretreatment
permit or an NPDES permit to monitor dis-
charge wastewater for toxic metals, cyanide,
and various toxic organic compounds. The
data generated from this monitoring can be
used to estimate releases of these com-
pounds. The following example demonstrates
a wastewater release estimation based on
direct measurement.
Example: Using direct measurement
to estimate releases of cyanide via
wastewater.
An electroplating facility discharges its
pretreated wastewater to a POTW. The
municipality operating the POTW requires
the electroplater to monitor this discharge
once per month, for various parameters,
including total cyanide. The mass loading
(pounds per day) of cyanide in the dis-
charge is calculated for each sampling day
by multiplying the daily flow by the
measured cyanide concentration and unit
conuersion factors:
Amount of cyanide released to
wastewater =
cyanide concentration (mg/liter) x
wastewater flow (gal/day) x
3.78 liters /1 gal x
1 lb/453.000 mg
4
-------
Cyanide and flow data from the days
when cyanide was monitored during 1987
and the calculated mass loadings of
cyanide are presented below:
Wastewater
CN
CN mass
flow.
cone..
loading.
Day
gal/day
mg/liter
lb/day
Jan. 8
21.500
1.5
0.27
Feb. 12
20.500
0.8
0.14
Mar. 10
20,800
0.6
0.10
Apr. 15
22.000
0.5
0.09
May 9
23.500
0.7
0.14
June 13
21.300
1.9
0.34
July 11
25.900
2.1
0.44
Aug. 10
21,500
1.0
0.18
Sep. 8
24.600
0.9
0.18
Oct. 12
25,000
0.8
0.17
Nov. 10
20,100
0.6
0.10
Dec. 8
20,700
0.2
0.03
The average daily cyanide discharge
based on these monitoring data is 0.18
pound per day. Assuming the plant
operates 250 days per year, the total
quantity of cyanide released via waste-
water to the POTW equals:
0.18 lb/day x 250 days/year
= 45 lb
Monitoring data may not be available for
some of the toxic chemicals present in your
wastewater. In this case, you must use
another estimation method. The following
example demonstrates the use of a mass
balance combined with an engineering
calculation.
Elxample: Using a mass balance
combined with an engineering
calculation to estimate releases of
nitrilotriacetic acid (NTA) via
wastewater.
A facility used 12.970 pounds of NTA
in its electroless plating operation during
1987. Because it does not become part of
the product all of the NTA used becomes
part of the facility's waste and is either
destroyed during waste treatment or
released from the facility. To estimate
releases of NTA, one needs the answers to
two questions:
• How much NTA is destroyed during
treatment?
• In what formfs) is NTA released from
the facility (wastewater, solid waste,
air emissions)?
At this facility, NTA enters the waste-
water stream as a chelate-metal complex
during the rinsing of metal parts from the
plating bath. This wastewater stream
goes through a pH adjustment/clarification
system where lime is added to precipitate
metals. Typically, chelating agents will
not be destroyed in this process, nor will
they precipitate along with the metals. On
the contrary, the purpose of chelating
agents is to keep the metal ions in solution
in the plating bath. An engineering
assumption can therefore be made that all
of the NTA entering waste treatment leaves
in the wastewater discharge. Given that
the wastewater is discharged to a POTW,
the plant in this example could report.
wastewater releases of 13,000 pounds of
NTA.
If your facility uses a listed mineral acid
or base, but this acid or base is effectively
neutralized in use or during wastewater
treatment (to pH 6 to 9, as required by most
effluent standards), no release quantities
should be reported. If the acid or base is
transformed into a reportable substance,
however, you .must estimate the quantity of
this substance manufactured to determine If
the "manufactured" threshold value has been
reached. For example, sulfuric acid neutral-
ized by sodium hydroxide yields sodium
sulfate, which Is a listed chemical.
5
-------
Toxic Releases Via Solid Waste
Some soltd wastes at electroplating facili-
ties are listed as hazardous under RCRA
regulations. Others may be deemed hazard-
ous based on the extraction procedure tox-
icity characteristic (EP toxicity). Generation,
transportation, and disposal of certain solid
wastes from electroplating may therefore be
regulated under RCRA. The RCRA manifest-
ing procedure for hazardous waste shipped
ofTsite requires documentation of quantities
shipped. Detailed chemical and physical
analyses may be performed on the wastes bv
treatment, storage, and disposal facilities.
The electroplater also may perform analyses
on the waste. Release estimates for some
compounds can therefore be made by direct
measurement.
EZxample: Using direct measurement
to estimate releases of toxic metals
via solid waste.
Wastewater treatment sludge from an
electroplating operation is shipped to an
offsite secure chemical Landfill for disposed.
Shipping manifests for the past year con-
tain detailed information on the quantity of
sludge sent to the landfill. Shipments of
sludge were made on a monthly basis.
The landfill performed detailed chemical
analysis for nickel on repre sentative
portions of each shipment before final
disposal As shown in the following table,
the information from the manifests and
landfill can be combined to estimate
releases of toxic metals and cyanide in the
wastewater treatment sludge.
Sludge
Nickel
Nickel in
shipped.
conc..
sludge.
Month
lb
ppm
lb
Jan.
6.000
50.600
304
Feb.
5.400
51.900
280
Mar.
4.700
48.500
228
Apr.
5.500
37.000
204
May
6.100
30.000
183
June
6.800
75.000
510
July
7.200
84.000
605
Aug.
6.400
55.500
355
Sep.
5.900
50.000
295
Oct.
4.500
105.500
475
Nov.
5.200
69.000
359
Dec.
5.300
20.000
106
It should be noted that this example
only addresses nickel releases in waste-
water sludge. Nickel may also be present
in other wastes in the facility. Also, the
landfill probably would have analytical
data for other metals in this sludge that
could be used to calculate releases of
those compounds.
When direct measurement data are not
available, another method of estimating
releases is needed. The following example
demonstrates the use of an engineering
calculation to estimate toxic metal releases
via solid waste.
Example: Using an engineering
calculation to estimate toxic releases
of copper in wastewater treatment
sludge.
In an electroplating facility, rinse water
from a copper-plating unit is treated sep-
arately from other process wastewater.
The rinse water is first treated with
chlorine to oxidize cyanide. Sodium
hydroxide is then added to react with the
Cu in the wastewater. The precipitate
formed from this reaction is removed as
sludge from the facility's central clari-
fication unit.
6
-------
The reaction of NaOH and Cu~ in the rinse
water proceeds as follows:
Cu" + 2NaOH - Cu(OH)2 + 2Na~
For each mole of Cu present in the rinse
water, two moles of NaOH must be added
to precipitate the Cu. Purchasing and
inventory records indicate that 1.984
pounds of NaOH was used for precipi-
tating Cu last year. The quantity of Cu
precipitated (and thus the quantity of Cu
released from this source of solid waste)
can be estimated by performing the
following calculations:
Molecular weight of Cu = 63.5 Ib/lb-mole
Molecular weight of NaOH = 40 Ib/lb-moLe
Amount of Cu released in sludge =
1.984 lb NaOH x
1 lb-mole NaOH/40 lb NaOH x
1 lb-mole Cu/2 lb-mole NaOH x
63.5 lb Cu/1 lb-mole Cu
= 1.575 lb
The plant in this example could therefore
report the release of 1,600 pounds of Cu in
the wastewater treatment sludge.
It should be noted that the NaOH in this
example only reacted with the Cu present in
the v/s stewater. If other metal ions axe
present, they may also react with the NaOH,
which would make this estimation method
ineffective. In some instances, however, this
approach can result in a rough approxima-
tion of the quantity of releases.
Toxic Releases to Air
Typical emissions to air from electro-
plating facilities are fugitive in nature and are
not monitored. Alternative techniques must
therefore be used to estimate air releases.
Releases of toxic compounds contained in
mists evolved from plating and cleaning baths
can be estimated by mass balance (provided
sufficient information is available on the
quantity of chemical entering and leaving the
process) or engineering calculations. Sol-
vents emitted to air during metal cleaning
operations can usually be estimated by mass
balance or emission factors as shown in the
following example.
Example: Using a mass balance to
estimate air emissions of 1,1,1-
trichloroethane from a degreasing
operation.
In the example presented earlier in this
pamphlet, an electroplating facility op-
erating a uapor degreaser used 14.250
pounds of 1.1.1 -trichloroethane during the
past year. The uapor degreaser contains a
built-in local exhaust ventilation system to
reduce worker exposure to the solvent.
This system collects spray solvent fumes
and exhausts them to the atmosphere
through the roof of the facility. Spent
solvent and sludge that accumulate on the
bottom of the degreaser are collected in 55-
gallon drums for shipment to an offsite
solvent reclaimer. Last year. 13 drums of
spent solvent were sent to the reclaimer.
Because 1.1.1-trichloroethane is only
"used" in the process (Le.. it does not
become part of the product) and it is not
destroyed during the process or treatment
the enr'r? 14.250 pounds of the solvent is
releasea from the facility either as an air
emission or as solid waste. Thus, if the
quantity of spent solvent shipped to the
reclaimer is known, the quantity emitted to
air can be calculated by mass balance, as
shown in the following equations:
Volume of 1.1.1 -TCE to reclaimer =
13 drums x 55 gal/drum
= 715 gal
Mass of 1.1.1 -TCE to reclaimer =
715 gal x 11.05 lb/gal
= 7.900 lb
7
-------
Amount of 1.1.1 -TCE released to air =
14.250 lb (purchased) -
7,900 Lb (to reclaimer)
= 6.350 lb
The plant in this example could therefore
report the release of 6.400 pounds of
1.1.1 -TCE to air and 7.900 pounds
shipped offsite as solid waste.
Emission factors for estimating releases of
solvents from different types of degreasing
units are presented in the EPA publication.
Compilation of Air Pollutant Emission Factors
(AP-42). To apply these factors properly, you
should carefully read the text that
accompanies them.
Other Toxic Releases
Electroplating operations produce other
wastes from which toxic chemicals may be
released. These Include:
• Residues from pollution control
devices
• Wash water from equipment
cleaning
• Product rejects
• Used equipment
• Empty chemical containers
Releases from these sources may already
have been accounted for. depending on the
release estimation methods used. These
items (and any other of a similar nature)
should be included in your development of a
process flow diagram.
The contribution of sources of wastes
such as cleaning out vessels or discarding
containers should be small compared with
process losses. If you do not have data on
such sources (or any monitoring data on
overall water releases), assume up to 1 per-
cent of vessel content may be lost during
each cleaning occurrence. For example, if
you discard (to landfill) "empty" drums that
have not been cleaned, calculate the release
as 1 percent of normal drum content. If the
drums are washed before disposal, this may
contribute 1 percent of the content to your
wastewater loading.
Step Five
Complete the Toxic Chemical Release
i Inventory Reporting Form.
After estimating the quantity of each
chemical released via wastewater, solid
waste, and air emissions, you must deter-
mine the amount of each chemical released to
water, land, or air or transferred to an offsite
disposal facility. This determination will be
based on the disposal method you use for
each of your waste streams. Enter the re-
lease estimates for each chemical or chemical
category in Part III of the Toxic Chemical
Release Inventory Reporting Form. Also enter
the code for each treatment method used, the
weight percent by which the treatment
reduces the chemical in the treated waste
stream, and the concentration of the chemi-
cal in the influent to treatment (see instruc-
tions). Report treatment methods that do not
affect the chemical by entering "0" for re-
moval efficiency.
8
-------
For More Information
Emergency Planning
and Community
Right-to-Know
Hotline
(800) 535-0202
or
(202) 479-2449
(in Washington. D.C.
and Alaska)
Small Business
Ombudsman
Hotline
(800) 368-5888
or
(703) 557-1938
(in Washington, D.C.
and Virginia)
The EPA brochure. Title III Section 313
Release Reporting Requirements (EPA 560/4-
87-001) presents an overview of the new law.
It identifies the types of facilities that come
under the provisions of Section 313. the
threshold chemical volumes that trigger re-
porting requirements, and what must be
reported. It also contains a complete listing
of the chemicals and chemical categories
subject to Section 313 reporting. The EPA
publication. Estimating Releases and Waste-
Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (EPA 560/4-88-002).
presents more detailed information on gen-
eral release estimation techniques than is
included in this document.
Additional Sources of Information
on Releases From Electroplating
Operations
U.S. Environmental Protection Agency. Com-
pilation of Air Pollutant Emission Factors.
Fourth Edition. AP-42. Research Triangle
Park. North Carolina. September 1985.
U.S. Environmental Protection Agency.
Development Document for Existing Source
Pretreatment Standards for the Electroplating
Point Source Category. EPA 440/1 -79/003.
NTIS PB80-196488. Washington. D. C.
August 1979.
U.S. Environmental Protection Agency.
Assessment of Industrial Hazardous Waste
Practices - Electroplating and Metal Finishing
Industries - Job Shops. NTIS PB-264349
Washington, D. C. September 1976.
9
^U.S. Co»*nj««nt Printing Offlcs 1911 * S16*002/801*2
-------
APPENDIX 7-G
COMPLETE LIST OF TRI CHEMICALS
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Abamectin (Avermectin B l ]
71 751—41-2
01/01/95
Acephate (Acetvlphosphoramidothioic acid 0,S-dimethvl ester)
30560-19-1
01/01/95
AcetaJdehvde
75-07-0
01/01/87
Acetamide
60-35-5
01/01/87
Acet.onit.rile
75-05-8
01/01/87
Acetophenone
98-86-2
01/01/94
2-Acetvlaminofluorene
53-96-3
ObOl/87
Acifluorfen, sodium salt [5-(2-Chloro-4-(trifluoromethyl)phenoxy)-2-
nitrobenzoic acid, sodium salt)
62476-59-9
01/01/95
Acrolein
107-02-8
01/01/87
Acrvlamide
79-06-1
01/01/87
Acrvlic acid
79-10-7
01/01/87
Acrvlonitrile
107-13-1
01/01/87
Alachlor
15972-60-8
01,01/95
AJdicarb
116-06-3
01/01/95
Aldrin[ 1,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-
1,4,4a,5,8,8a-hexahvdro-(
1. alpha,4.alpha,4a. beta,5.alpha,8.alpha,8a. beta)-]
309-00-2
01/01/87
d-trans-Allethrin fd-trans-Chrvsanthemic acid of d-allethronej
28057-48-9
01/01/95
Allvl alcohol
107-18-6
01/01/90
Allvlamine
107-11-9
01/01/95
Allvl chloride
107-05-1
01/01/87
Aluminum (fume or dust)
7429-90-5
01/01/87
Aluminum oxide (fibrous forms)
1344-28-1
01/01/87
Aluminum phosphide
20859-73-8
01/01/95
Ametrvn (N-Ethvl-N'-( l-methylethyl)-6-(methylthio)-1,3,5,-triazine-2,4-
diamine)
834-12-8
01/01/95
2-Aminoanthraquinone
1 17-79-3
01/01/87
4-Aminoazobenzene
60-09-3
01/01/87
4-Aminobiphenvl
92-67-1
01/01/87
1 -Amino-2-methvlanthraquinone
82-28-0
01/01/87
Amitraz
33089-61-1
01/01/95
Amitrole
61-82-5
01/01/94
Ammonia (includes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources; 10 percent of total
aqueous ammonia is reportable under this listing)
7664—41-7
01/01/87
Anilazine [4,6-dichloro-N-(2-chlorophenvD-1,3,5-triazin-2-amine]
101-05-3
01/01/95
Aniline
62-53-3
01/01/87
o-Anisidine
90-04-0
01/01/87
D-Anisidine
104-94-9
01/01/87
o-Anisidine hydrochloride
134-29-2
ObOl/87
Anthracene
120-12-7
01.01/87
December 1996
7-G1
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Antimonv
7440-36-0
01/01/87
Arsenic
7440-38-2
01/01/87
Asbestos (friable)
1332-21-4
01/01/87
Atrazine (6-Chloro-N-ethvl-i\T-( I -methvlethvl)-1,3.5,-triazine-2,4-
diamine)
1912-24-9
01,01/95
Barium
7440-39-3
01,01/87
Bendiocarb [2,2-Dimethvl-1,3-benzodioxol-4-oI methvlcarbamate]
22781-23-3
01/01/95
Benfluralin (N-Butvl-N-ethvl-2,6-dinitro-4-(trifluoromethvl)benzenamine)
1861-40-1
01/01/95
Benomvl
17804-35-2
01/01/95
BenzaJ chloride
98-87-3
01/01/87
Benzamide
55-21-0
01,01/87
Benzene
71-43-2
01/01/87
Benzidine
92-87-5
01/01/87
Benzoic trichloride (Benzotrichloride)
98-07-7
01,01/87
Benzovl chloride
98-88-4
01/01/87
Benzovl peroxide
94-36-0
01/01/87
Benzvl chloride
100-44-7
01/01/87
Bervllium
7440-41-7
01/01/87
Bifenthrin
82657-04-3
01/01/95
Biphenvl
92-52-4
01/01/87
Bis(2-chIoroethoxv (methane
1 I 1-91-1
01/01/94
Bis(?.-chloroethvl) ether
111-44-4
01/01/87
Bisicnloromethvl) ether
542-88-1
01/01/87
Bis(2-chloro-l-methvlethvl) ether
108-60-1
01/01/87
Bis(2-ethvlhexvl) adipate
103-23-1
01/01/87
Bis(tributvlin) oxide
56-35-9
01/01/95
Boron trichloride
10294-34-5
01/01/95
Boron trifluoride
7637-07-2
01/01/95
Bromacil (5-Bromo-6-methvl-3-( 1 -methvlpropvl)-2,4-( 1 H,3H)-
pvrimidinedione)
314-40-9
01/01/95
Bromacil, lithium salt [2,4-( 1 H,3H)-Pvrimidinedione, 5-bromo-6-methvI-
3-( 1-methvlpropvl), lithium salt]
53404-19-6
0 1/01/95
Bromine
7726-95-6
01/01/95
1 -Bromo-1 -(bromomethvH-1,3-propanedicarbonitrile
35691-65-7
01/01/95
Bromochlorodifluoromethane (Halon 1211)
353-59-3
07/08/90
Bromoform (Tribromomethane)
75-25-2
01/01/87
Bromomethane (Methvl bromide)
74-83-9
01/01/87
2-Bromo-2-nitropropane-1,3-diol (Bronopol)
52-51-7
01/01/95
Bromotrifluoromethane (Halon 1301)
75-63-8
07/08/90
Bromoxvnil (3.5-Dibromo-4-hvdroxvbenzonitrile)
1689-84-5
01,01/95
Bromoxvnil octanoate (Octanoic acid. 2.6-dibromo-4-cvanophenvl ester)
|689-99-2
0101 '95
December 1996
7-G2
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Brucine
357-57-3
01/01/95
1,3-Butadiene
106-99-0
01/01/87
Butvl acrvlate
141-32-2
01/01/87
n-Butvl alcohol
71-36-3
01/01/87
sec-Butvl alcohol
78-92-2
01/01/87
tert-Butvl alcohol
75-65-0
01,01/87
1,2-Butvlene oxide
106-88-7
01/01/87
Butvraldehvde
123-72-8
01/01/87
C.I. Acid Green 3
4680-78-8
01/01/87
C.I. Basic Green 4
569-64-2
01/01/87
C.I. Acid Red 114
6459-94-5
01/01/95
C.I. Basic Red 1
989-38-8
01/01/87
C.I. Direct Black 38
1937-37-7
01/01/87
C.I. Direct Blue 6
2602-46-2
01/01/87
C.I. Direct Blue 218
28407-37-6
01/01/95
C.I. Direct Brown 95
16071-86-6
01/01/87
C.I. Disperse Yellow 3
2832-40-8
01/01/87
C.I. Food Red 5
3761-53-3
01/01/87
C.I. Food Red 15
81-88-9
01/01/87
C.I. Solvent Orange 7
3118-97-6
01/01/87
C.I. Solvent Yellow 3
97-56-3
01/01/87
C.I. Solvent Yellow 14
842-07-9
01/01/87
C.I. Solvent Yellow 34 (Aurimine)
492-80-8
01/01/87
C.I. Vat Yellow 4
128-66-5
01/01/87
Cadmium
7440-43-9
01/01/87
Calcium cvanamide
156-62-7
01/01/87
Captan( 1 H-Isoindole-1,3(2H)-dione,3a,4,7,7a-teLrahydro-2-
f (trichloromethvl) thiol-]
133-06-2
01/01/87
Carbarvl [ 1-Naphthalenol. methvlcarbamate]
63-25-2
01/01/87
Carbofuran
1563-66-2
01/01/95
Carbon disulfide
75-15-0
01/01/87
Carbon tetrachloride
56-23-5
01/01/87
Carbonvl sulfide
463-58-1
01/01/87
Carboxin (5,6-Dihvdro-2-methvl-N-phenvl-1,4-oxathiin-3-carboxamide)
5234-68—4
01/01/95
Catechol
120-80-9
01/01/87
Chinomethionat [6-Methvl-1,3-dithiolo[4.5-blquinoxalin-2-one]
2439-01-2
01/01/95
Chloramben [Benzoic acid.3-amino-2,5-dichloro-]
133-90-4
01/01/87
Chlordane [4,7-Methanoindan. 1.2,4,5,6,7,8,8-octachloro-2.3,3a.4,7,7a-
hexahvdro-]
57-74-9
01/01/87
Chlorendic acid
1I5-2S-6
01.01/95
December 1996
7-G3
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Chlorimuron ethyl [Ethyl-2-[[[(4-chloro-6-methoxyprimidin-2-vI)-
carbonvl]-amino|sulfonvl]benzoate]
90982-32-4
01/01/95
Chlorine
i i82—50—5
01/01/87
Chlorine dioxide
1 0049-04—i
01/01/87
Chloroacetic acid
79-11-8
01/01/87
2-Chloroacetophenone
532-27-4
01/01/87
1 -(3-Chloroallvl)-3.5,7-triaza-1 -azoniaadamantane chloride
4080-31-3
01/01/95
p-Chloroaniline
106-47-8
01/01/95
Chlorobenzene
108-90-7
01/01/87
Chlorobenzilate [Benzeneacetic acid, 4-chloro-.alpha.(4-.chlorophenyl)-
.alpha.hvdroxv-, ethvl ester]
510-15-6
01/01/87
1 -Chloro-1,1 -difluoroethane (HCFC- 142b)
75-68-3
01/01/94
Chlorodifluoromethane (HCFC-22)
75-45-6
01/01/94
Chloroethane (Ethvl chloride)
75-00-3
01/01/87
Chloroform
67-66-3
01/01/87
Chloromethane (Methvl chloride)
74-87-3
01/01/87
Chloromethvl methvl ether
107-30-2
01/01/87
3-Chloro-2-methvl-1 -propene
563-47-3
01/01/95
p-Chlorophenv! isocvanate
104-12-1
01/01/95
Chloropicrin
76-06-2
01/01/95
Chloroprene
126-99-8
01,01/87
3-Chloropropionitrile
542-76-7
01/01/95
v^hlorotetrafluoroethane
63938-10-3
01/01/94
1 -Chloro-1,1,2.2-tetrafluoroethane (HCFC-124a)
354-25-6
01/01/94
2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
2837-89-0
01/01/94
Chlorothalonil [ 1,3-Benzenedicarbonitrile,2,4,5,6-tetrachloro-]
1897-45-6
01/01/87
p-Chloro-o-toluidine
95-69-2
01/01/95
2-Chloro-1,1,1 -trifluoro-ethane (HCFC-133a)
75-88-7
01/01/95
Chlorotrifluoromethane (CFC-13)
75-72-9
01/01/95
3-Chloro-1,1,1 -trifluoro-propane (HCFC-253fb)
460-35-5
01,01/95
Chlorpvrifos methyl (0,0-dimethyl-0-(3,5,6-trichloro-2-
pvridvDphosphorothioate
5598-13-0
01/01/95
Chlorsulfuron (2-chloro-N-[[4-methoxy-6-methvl-1,3,5-triazin-2-
vl)amino]carbonvl]benzenesulfonamidel
64902-72-3
01/01/95
Chromium
7440-47-3
01/01/87
Cobalt
7440-48-4
01/01/87
Copper
7440-50-8
01/01/87
Creosote
8001-58-9
01/01/90
p-Cresidine
120-7 i-8
01/01/87
Cresol (mixed isomers I
1319-77-3
01/01/87
m-Cresol
108-39—4
01 01/87
December 1996
7-G4
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TR1) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
o-Cresol
95-48-7
01/01/87
p-Cresol
106-44-5
01/01/87
Crotonaldehvde
4170-30-3
01/01/95
Cumene
98-82-8
01/01/87
Cumene hydroperoxide
80-15-9
01/01/87
CuDferron[Benzeneamine. N-hvdroxv-N-nitroso, ammonium salt]
135-20-6
01/01/87
Cvanazine
21725-46-2
01/01/95
Cvcloate
1134-23-2
01/01/95
Cvclohexane
110-82-7
01/01/87
Cvclohexanol
108-93-0
01/01/95
Cvfluthrin [3-(2,2-Dichloroethenyl)-2,2-dimethylcvclopropanecarboxylic
acid, cvano(4-fluoro-3- phenoxvphenvHmethvl ester|
68359-37-5
01/01/95
Cvhalothrin [3-(2-Chloro-3,3,3-trifluoro-1 -propenvl)-2,2-
dimethvlcvclopropanecarboxvlic acid cvano(3- phenoxyphenyl)methvl
ester]
68085-85-8
01/01/95
2,4-D fAcetic acid, (2.4-dichlorophenoxv)-]
94-75-7
01/01/87
Dazomet(Tetrahvdro-3,5-dimethvl-2H-l ,3.5-thiadiazine-2-thione)
533-74-4
01/01/95
Dazomet, sodium salt [Tetrahydro-3,5-dimethyl-2H-l,3,5-thiadiazine-2-
thione. ion(l-), sodium]
53404-60-7
01/01/95
2,4.-DB
94-82-6
01/01/95
2,4-D butoxvethvl ester
1929-73-3
01/01/95
2,4-D butvl ester
94-80-4
01/01/95
2,4-D chlorocrotvi ester
2971-38-2
01/01/95
Decabromodiphenvl oxide
1163-19-5
01/01/87
Desmedipham
13684-56-5
01/01/95
2,4-D 2-ethvlhexvl ester
1928-43-4
01/01/95
2,4-D 2-ethvl-4-methvlpentvl ester
53404-37-8
01/01/95
Diallate [Carbamothioic acid, bis( 1 -methvlethyl)-, S-(2,3-dichloro-2-
propenvl) ester]
2303-16-4
01/01/87
2,4-Diaininoanisole
615-05-4
01/01/87
2,4-Diaminoanisole sulfate
39156-41-7
01/01/87
4,4'-Diaminodiphenvl ether
101-80-4
01/01/87
Diaminotoluene (mixed isomers)
25376-45-8
01/01/87
2.4-Diaminotoluene
95-80-7
01/01/87
Diazinon
333-41-5
01/01/95
Diazomethane
334-88-3
01/01/87
Dibenzofuran
132-64-9
01/01/87
1,2-Dibromo-3-chloroproDane (DBCP)
96-12-8
01/01/87
2.2-Dibromo-3-nitrilopr<, ai on amide
10222-01-2
01/01/95
1 ,2-Dibromoethane ( Ethylene dibromide)
106-93-4
01/01/87
Dibromotetrafluoroethane (Halon 2402)
124-73-2
07/08/90
Dibutvl ohthalate
84-74-2
0L0WS7
December 1996
7-G5
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Dicamba (3,6-Dichloro-2-methoxvbenzoic acid)
1918-00-9
01/01/95
Dichloran [2,6-Dichloro-4-nitroaniline]
99-30-9
01/01/95
Dichlorobenzene (mixed isomers)
25321-22-6
01/01/87
l ,2-Dichlorobenzene
95-50-1
0 1,01/87
1,3-Dichlorobenzene
541-73-1
01/01/87
1,4-Dichlorobenzene
(06-46-7
01/01/87
3,3 -Dichlorobenzidine
91-94-1
01/01/87
3.3'-Dichlorobenzidine dihydrochloride
612-83-9
01/01/95
3,3'-Dichlorobenzidine sulfate
64969-34-2
01/01/95
Dichlorobromomethane
75-27-4
01/01/87
1,4-Dichloro-2-butene
764-41-0
01/01/94
trans-1,4-Dichloro-2-butene
110-57-6
01/01/95
1,2-Dichloro-1.1 -difluoroethane (HCFC- 132b)
1649-08-7
01/01/95
Dichlorodifluoromethane (CFC-12)
75-71-8
07/08/90
Dichlorofluoromethane (HCFC-21)
75-43-4
01/01/95
1,2-Dichloroethane (Ethvlene dichloride)
107-06-2
01/01/87
1,2-Dichlorethvlene
540-59-0
01/01/87
1,1 -Dichloro-1 -fluoroethane (HCFC- 141b)
1717-00-6
01/01/94
Dichloromethane (Methylene chloride)
75-09-2
01/01/87
Dichloropentafluoropropane
127564-92-5
01/01/95
1,1 -dichloro-1,2,2.3,3-pentafluoropropane (HCFC-225cc)
13474-88-9
01/01/95
1 !.-dichloro-l,2,3,3.3-pentafluoropropane (HCFC-225eb)
111512-56-2
01/01/95
1,2-dichloro-1,1,2,3.3-pentafluoropropane (HCFC-225bb)
422-44-6
01/01/95
1,2-dichloro-1,1,3,3,3-pentafluoropropane (HCFC-225da)
431-86-7
01/01/95
1,3-dichloro-l, 1,2,2,3-pentafluoropropane (HCFC-225cb)
507-55-1
01/01/95
1,3-dichloro-1,1,2,3,3-pentafluoropropane (HCFC-225ea)
136013-79-1
01/01/95
2,2-dichloro-1,1,1,3,3-pentafluoropropane (HCFC-225aa)
128903-21-9
01/01/95
2,3-dichloro-1,1.1,2,3-pentafluoropropane (HCFC-225ba)
422-48-0
01/01/95
3,3-dichloro-1.1,1,2,2-pentafluoropropane (HCFC-225ca)
422-56-0
01/01/95
Dichlorophene [ 2.2'-Methvlene-bis(4-chlorophenol)]
97-23-4
01/01/95
2,4-Dichlorophenol
120-83-2
01/01/87
1,2-Dichloropropane
78-87-5
01/01/87
2,3-Dichloropropene
78-88-6
01/01/90
trans-1,3-Dichloropropene
10061-02-6
01/01/95
1,3-Dichloropropvlene
542-75-6
01/01/87
Dichlorotetrafluoroethane (CFC-1 14)
76-14-2
07/08/90
Dichlorotri fluoroethane
34077-87-7
01/01/94
Dichloro-1.1,2-tri fluoroethane
90454-18-5
01/01/94
1.1 -Dichloro-1,2.2-trifluoroethane (HCFC-1 23b)
812-04-4
01/01/94
1,2-Dichloro-1.1,2-rrifluoroethane (HCFC-1 23a)
354-23-4
01.01/94
2.2-Dichloro- i . 1 .1 -(rifluoroethane (HCFC-123) I
306-83-2
01 01/94
December 1996
7-G6
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Dichlorvos [Phosphoric acid. 2,2-dichloroethenvl dimethvl ester]
62-73-7
01/01/87
Diclofop methvl [2-[4-(2,4-Dichlorophenoxv)phenoxv]propanoic acid,
methvl ester]
51338-27-3
01/01/95
Dicofol [Benzenemethanol,4-chloro-.alpha. (4-chlorophenvl)-
. alpha, ftrichloromethv!)-]
115-32-2
01/01/87
Dicvclopentadiene
77-73-6
01/01/95
Diepoxvbutane
1464-53-5
01/01/87
Diethanolamine
I I 1-12-2
01/01/87
Diethatvl ethvl
38727-55-8
01/01/95
Di (^-ethvlhexvllphthalate
117-81-7
01/01/87
Diethvl phthalate
84-66-2
01/01/87
Diethvl sulfate
64-67-5
01/01/87
Diflubenzuron
35367-38-5
01/01/95
Die;lvcidvl resorcinol ether
101-90-6
01/01/95
Dimethipin [2,3.-Dihvdro-5.6-dimethvl-1,4-dithiin-1.1,4,4-tetraoxide]
55290-64-7
01/01/95
Dimethoate
60-51-5
01/01/95
Dihvdrosa/role
94-58-6
01/01/94
3.3'-Dimethoxvbenzidine
1i9-90-4
01/01/87
3.3'-Dimethoxvbenzidine dihvdrochloride (o-Dianisidine dihvdrochloride)
20325-40-0
01/01/95
3.3-Dimethoxvbenzidine hvdrochloride (o-Dianisidine hydrochloride)
I 11984-09-9
01/01/95
Dimethvlamine
124-40-3
01/01/95
Dimethvlamine dicamba
2300-66-5
01/01/95
4-Dimechvlaminoazobenzenc
6a-1 1-7
01/01/87
3.3'-Dimethvlbenzidine ( o-Tolidine)
1 19-93-7
01/01/87
3.3'-Dimethvlbenzidine dihvdrochloride (o-Tolidine dihvdrochloride)
612-82-8
01/01/95
3.3'-Dimethvlbenzidine dihvdrofluoride (o-Tolidine dihvdrofluoride)
41766-75-0
01/01/95
Dimethvlcarbamvl chloride
79-44-7
01/01/87
Dimethvl chlorothiophosphate
2524-03-0
01/01/95
Dimethvldichlorosilane
75-78-5
01/01/95
N.N-Dimethvlformamide
68-12-2
01/01/95
1.1 -Dimethvl hydrazine
57-14-7
01/01/87
2.4-Di methvl phenol
105-67-9
01/01/87
2.6-Dimethvlphenol
576-26-1
01/01/95
Dimethvl phthalate
131-11-3
01/01/87
Dimethvl sulfate
77-78-1
01/01/87
m-Di nitrobenzene
99-65-0
01/01/90
o-Dinitrobenzene
528-29-0
01/01/90
p-Dinitrobenzene
100-25-4
01/01/90
Dinitrobutvl phenol (Dinoseb)
88-85-7
01/01/95
Dinoeap
39300-45-3
01/01/95
4. -0i n11 ro- o-cri'sol
534-52-1
01 01/87
December 1996
7-G7
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
2.4-Dinitrophenol
51-28-5
01/01/87
2.4-Dinitrotoluene
121-14-2
01/01/87
2.6-Dinitrotoluene
606-20-2
01/01/87
Dinitrotoluene (mixed isomers)
25321-14-6
01.01/90
1,4-Dioxane
123-91-1
01,01/87
Diphenamid
957-51-7
01/01/95
Diphenvlamine
122-39-4
01/01/95
l .2-Diphenvlhvdrazine (Hvdrazobenzene)
122-66-7
01.01/87
Dipotassium endothalt [7-Oxabicvclo(2.2.1 )heptane-2,3-dicarboxvlic acid,
dipotassium salt]
2164-07-0
01/01/95
Dipropvl isocinchomeronate
136-45-8
01,01/95
Disodium cvanodithioimidocarbonate
138-93-2
01.01/95
2.4-D isopropvl ester
94-11-1
01.01/95
2.4-Dithiobiuret
541-53-7
01.01/95
Diuron
330-54-1
01.01/95
Dodine [Dodecvlguanidine monoacetate]
2439-10-3
01/01/95
2.4.-DP
120-36-5
01/0 1/95
2,4-D propylene glvcol butvl ether ester
1320-18-9
01/01/95
2.4-D sodium salt
2702-72-9
01/01/95
Epichlorohvdrin
106-89-8
01,01/87
Ethoprop [Phosphorodithioic acid O-ethvl S,S-dipropvl ester]
13194-48-4
01.01/95
2-Ethoxvethanol
110-80-5
01.01/87
Ethvl acrvlate
140-88-5
01/01/87
Ethvlbenzene
100-41—4
01/01/87
Ethvl chloroformate
541-41-3
01/01/87
Ethvl dipropvlthiocarbamate [EPTC]
759-94-4
01/01/95
Ethylene
74-85-1
01/01/87
Ethylene glycol
107-21-1
01/01/87
Ethvleneimine(Aziridine)
151-56-4
01/01/87
Ethylene oxide
75-21-8
01/01/87
Ethylene thiourea
96-45-7
01/01/87
Ethvlidene dichloride
75-34-3
01.01/94
Famphur
52-85-7
01/01/95
Fenarimol [.alpha.(2-Chlorophenvl)-.alpha.4-chlorophenvl)-5-
pvrimidinemethanoll
60168-88-9
01,01/95
Fenbutatin oxide (Hexakis(2-methvl-2-phenvl-propvl)distannoxane)
13356-08-6
01/01/95
Fenoxaprop ethvl [2-(4-( (6-Chloro-2-
benzoxazolvlen)oxv)phenoxv)propanoic acid,ethvl ester)
66441-23-4
01/01/95
Fenoxvcarb [2-(4-PhenoxvDhenoxv)ethvl]carbamic acid ethvl ester]
72490-01-8
01/01/95
Fenpropathrin [2,2.3.3-Tctramethylcyclopropane carboxylic acid cvano(3-
ohenoxv-Dhenvllmethvl ester 1
¦39515-41-8
01.-01/95
December 1996
7-G8
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Fenthion [O.O-Dimethvl 0-[3-methyl-4-(methylthio)phenyl]ester,
phosphorothioic acid]
55-38-9
01/01/95
Fenvalerate [4-Chloro-alpha-( 1 -methylethvl)benzeneacetic acid cvano(3-
phenoxvphenvDmethvl ester]
51630-58-1
01/01/95
Ferbam [Tris(dimethvlcarbamo-dithioato-S.S')ironl
14484-64-1
01/01/95
Fluazifop-butyl [2-[4-[[5-(Trifluoromethyl)-2-pyridinyl]oxy]-
phenoxv]propanoic acid, butvl ester]
69806-50-4
01/01/95
Fluorine
7782-41-4
01/01/95
Fluorouracil (5-Fluorouracil)
51-21-8
01/01/95
Fluvalinate [N-[2-Chloro-4-(trifluoromethvl)phenyl]-DL-valine( + )-cvano
(3-phenoxvphenvl)methvl ester]
69409-94-5
01/01/95
Folpet
133-07-3
01/01/95
Fomesafen [5-(2-Chloro-4-(trifluoromethvl)phenoxy)-N-methvlsulfonvl)-
2-nitrobenzamide]
72178-02-0
01/01/95
Fluometuron [Urea. N,N-dimethvl-N'-[3-(trifluoromethvl)phenvl]-]
2164-17-2
01/01/87
Formaldehyde
50-00-0
01/01/87
Formic acid
64-18-6
01/01/94
Freon 113 [Ethane, 1.1,2-trichloro-1,2,2-trifluoro-]
76-13-1
01/01/87
Heptachlor[ 1,4,5,6,7,8,8-Heptachloro-3a,4,7,7a-tetrahydro-4,7-methano-
1 H-indene]
76-44-8
01/01/87
Hexachlorobenzene
118-74-1
01/01/87
Hexachloro-1,3-butadiene
87-68-3
01/01/87
alpha-H ;xachlorocvclohexane
319-84-6
01/01/95
Hexachlorocvclopentadiene
77-47-4
01/01/87
Hexachloroethane
67-72-1
01/01/87
Hexachloronaphthalene
1335-87-1
01/01/87
Hexachlorophene
70-30-4
01/01/94
Hexamethvlphosphoramide
680-31-9
01/01/87
n-Hexane
110-54-3
01/01/95
Hexazinone
51235-04-2
01/01/95
Hvdramethvlnon [Tetrahydro-5.5-dimethvl-2( 1 H)-pvrimidinone[3-[4-
(trifluoromethyl)phenvl]-1 -[2-[4- (trifluoromethyl)phenyl]ethenyl]-2-
propenvlidene]hvdrazone]
67485-29-4
01/01/95
Hydrazine
302-01-2
01/01/87
Hydrazine sulfate
10034-93-2
01/01/87
Hydrochloric acid
7647-01-0
01/01/87
Hvdrogen cvanide
74-90-8
01/01/87
Hvdrogen fluoride
7664-39-3
01/01/87
Hvdro^en sulfide
7783-06-4
01/01/94
H vdroquinone
123-31-9
01/01/87
Imnzalil [ 1 -[2-i 2.4-Dichiorophenvl)-2-(2-propenv!ox\-lethvl] -1 H-
imulnzole!
35554-44-0
01/01/95
December 1996
7-G9
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
3-lodo-2-propvnvl Butvlcarbamate
55406-53-6
01/01/95
Iron pentacarbonvl
13463-40-6
01/01/95
Isobutvraldehvde
78-84-2
01/01/87
Isodrin
465-73-6
01/01/95
Isofenphos [2-[[Ethoxvl[( l-
methvlet_hvl)amino]phosphinothiovl]oxy]benzoic acid I -methvlethvl
ester]
2531 1-71-1
01/01/95
Isopropvl alcohol (Only persons who manufacture by the strong acid
process are subject, no supplier notifiction)
67-63-0
01/01/87
4,4'-lsopropvlidenediphenol
80-05-7
01/01/87
Isosafrole
120-58-1
01/01/90
Lactofen [5-(2-Chloro-4-(trifiuoromethyl)phenoxy)-2-nitro-2-ethoxy-1 -
methvl-2-oxoethvl ester]
77501-63-4
01/01/95
Lead
7439-92-1
01/01/8.7
Lindane [Cvclohexane, l ,2,3,4,5,6-hexachloro-
(I alpha.2.alpha,3.beta.4.alpha.5.alpha.6.beta)-]
58-89-9
01/01/87
Linuron
330-55-2
01/01/9,5
Lithium carbonate
554-13-2
01/01/95
Malathion
121-75-5
01/01/95
Maleic anhvdride
108-31-6
01/01/87
Malononitrile
109-77-3
01/01/94
Maneb [Carbamodithioic acid. 1,2-ethanedivlbis-. manganese complex]
12427-38-2
01/01/87
Man ^anese
7439-96-5
01/01/87
Mecoprop
93-65-2
01/01/95
2-Mercaptobenzothiazole (MBT)
149-30-4
01/01/95
Mercurv
7439_97_6
01/01/87
Merphos
150-50-5
01/01/95
Metham sodium (Sodium methvldithiocarbamate)
137-42-8
01/01/95
Methacrvlonitrile
126-98-7
01/01/94
Methanol
67-56-1
01/01/87
Methazole [2-(3.4-Dichlorophenyl)-4-methvl-1,2,4-oxadiazolidine-3,5-
dione]
20354-26-1
01/01/95
Methiocarb
2032-65-7
01/01/95
Methoxone (4-Chloro-2-methvlphenoxv) acetic acid (MCPA))
94-74-6
01/01/95
Methoxone-sodium salt ((4-chloro-2-methvlphenoxv) acetate sodium salt)
3653-48-3
01.-'01/9 5
Methoxvchlor [Benzene. 1,l'-(2.2.2-uichloroethvlidene)bis[4-methoxv-]
72-43-5
01/01/87
2-,Methoxvethanol
109-86-4
01/01/87
Methvl isothiocvanate [Isothiocvanatomethane]
556-61-6
01/01/95
2-Methvllactonitrile
75-S6-5
01/01/95
Methvl acrvlate
96-33-3
01/01/87
Methvl tert-butvl ether
1634-04-4
01 01/87
Methvl chlorocarbonate
70-22-1
0101 04
December 1996
7-G10
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
4.4'-Methvlenebis(2-chloroaniline) (MBOCA)
101-14-4
01/01/87
4.4'-Methvlenebis( N, N-dimethvl) benzenamine
101-61-1
01/01/87
Methvlenebis(phenvlisocvanate) (MDI)
101-68-8
01/01/87
Vlethvlene bromide
74-95-3
01/01/87
4.4'-Methvlenedianiline
101-77-9
01/01/87
Methvl ethvl ketone
78-93-3
01/01/87
Methvl hydrazine
60-34-4
01/01/87
Methvl iodide
74-88-4
01/01/87
Methvl isobutvl ketone
108-10-1
01/01/87
Methvl isocvanate
624-83-9
01/01/87
Methvl mercaptan
74-93-1
01/01/94
Methvl methacrvlate
80-62-6
01/01/87
N-Methvlolacrvlamide
924-42-5
01/01/95
Methvl parathion
298-00-0
01/01/95
N-Methvl-2-pvrrolidone
872-50-4
01/01/95
2-Methvlpvridine
109-06-8
01/01/94
Methvltrichlorosilane
75-79-6
01/01/95
Metiram
9006-42-2
01/01/95
Metribuzin
21087-64-9
01/01/95
Mevinphos
7786-34-7
01/01/95
Michler's ketone
90-94-8
01/01/87
Molinate (1 H-Azepine-1-carbot Hioic acid. hexahvdro-S-ethvl ester)
2212-67-1
01/01/95
Molvbdenum trioxide
1313-27-5
01/01/87
(Mono)chloropentafluoroethane (CFC-1 15)
76-15-3
07/08/90
Monuron
150-68-5
01/01/95
Mustard gas [Ethane, 1,l'-thiobis[2-chloro-]
505-60-2
01/01/87
Mvclobutanil [.alpha.Butyl-.alpha.(4-chlorophenvl)-1 H-1.2,4-triazole-l-
propanenitrile]
88671-89-0
01/01/95
Nab am
142-59-6
01/01/95
Naled
300-76-5
01/01/95
Naphthalene
91-20-3
01/01/87
alpha-Naphthvlamine
134-32-7
01/01/87
beta-Naphthvlamine
91-59-8
01/01/87
Nickel
7440-02-0
01/01/87
Nitrapvrin (2-Chloro-6-(trichloromethvl) pvridine)
1929-82-4
01/01/95
Nitric acid
7697-37-2
01/01/87
Nitrilotriacetic acid
139-13-9
01/01/87
5-Nitro-o-anisidine
99-59-2
01/01/87
5-Nitro-o-toluidine
99-55-8
01/01/94
p-Nirroaniline
100-01-6
01/01/95
Nitrobenzene
9S-9 5-3
01.01 '87
December 1996
7-G11
-------
Toxic Chemical Reporting
Part I, Chapter 7
1 Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
4-i\'itrobiphenvl
92-93-3
01/01/87
Nitrofen [Benzene. 2.4-dichloro-1-(4-nitrophenoxv)-]
1836-75-5
01/01/87
Nitrogen mustard r2-Chloro-N-(2-chloroethvl)-N-methvlethanamine|
51-75-2
01/01/87
Nitroglycerin
55-63-0
01/01/87
2-N'itroDhenol
88-75-5
01/01/87
4-Nitrophenol
100-02-7
01/01/87
2-Nitropropane
79-46-9
01/01/87
p-Nitrosodiphenvlamine
156-10-5
01/01/87
N, N-Dimethvlaniline
121-69-7
01/01/87
N-Nitjosodi- n-butvlamine
924-16-3
01/01/87
N-Nitrosodiethvlamine
55-18-5
01/01/87
N-Nitrosodimethvlamine
62-75-9
01/01/87
N-Nitrosodiphenvlamine
86-30-6
01,01/87
N-N'itrosodi- n-propvlamine
621-64-7
01/01/87
N-Nitrosomethvlvinvlamine
4549-40-0
01/01/87
N-Nitrosomorpholine
59-89-2
01/01/8.7.
N-Nitroso- N-ethvlurea
759-73-9
01/01/87
N-Nitroso- N-methvlurea
684-93-5
01/01/87
N-Nitrosonomicotine
16543-55-8
01/01/87
N-Nitrosopiperidine
100-75-4
01/01/87
Norflurazon [4-Chloro-5-(methylamino)-2-[3-(trifluoromethyl)phenyl]-
",''2H)-pvridazinone]
27314-13-2
01/01/95
Octachloronaphthalene
2234-13-1
01/01/8.7
Orvzalin [4-(Dipropvlamino)-3.5-dinitrobenzenesulfonamide]
19044-88-3
01/01/95
Osmium tetroxide
20816-12-0
01/01/87
Oxvdemeton methyl [S-(2-(ethvlsulfinyl)ethyl) o,o-dimethvl ester
phosphorothioic acid]
301-12-2
01/01/95
Oxvdiazon [3-[2,4-Dichloro-5-( 1 -methvletho>cy)phenyl]-5-( 1,1-
dimethvlethvl)-1,3,4-oxadiazol-2(3H)-one]
19666-30-9
01/01/95
Oxvfluorten
42874-03-3
01/01/95
Ozone
10028-15-6
01/01/95
Paraldehyde
123-63-7
01/01/94
Paraquat dichloride
1910-42-5
01/01/95
Parathion [Phosphorothioic acid, 0,0-diethvl-0-(4-nitrophenvl) ester]
56-38-2
01/01/87
Pebulate [Butvlethvlcarbamothioic acid S-propvl ester]
1114-71-2
01/01/95
Pendimethalin [N-( 1 -Ethvlpropvi)-3,4-dimethvl-2.6-dinitrobenzenamine]
40487-42-1
01/01/95
Pentachloroethane
76-01-7
01/01/94
Pentachlorophenol (PCP)
87-86-5
01/01/87
Pentobarbital sodium
57-33-0
01/01/95
Peracetic acid
79-21-0
01/01/87
Perchloromethvl mercaptan
504-42-3
01-01/95
December 1996
7-G12
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Permethrin [3-(2,2-Dichloroethenvl)-2,2-dimethylcyclopropanecarboxylic
acid. (3- phenoxvphenvDmethvl esier]
52645-53-1
01/01/95
Phenant_hrene
85-01-8
01/01/95
Phenol
108-95-2
01/01/87
Phenothrin [2,2-Dimethvl-3-(2-rriethyl-1 -propenyl)cyclopropanecarboxvlic
acid (3- phenoxvphenvDmethvl ester]
26002-80-2
01/01/95
p-Phenvlenediamine
106-50-3
01/01/87
1,2-Phenvlenediamine
95-54-5
01/01/95
1,3-Phenvlenediamine
108-45-2
01/01/95
1,2-Phenvlenediamine dihvdrochloride
615-28-1
01/01/95
1,4-Phenvlenediamine dihvdrochloride
624-18-0
01/01/95
2-Phenvlphenol
90-43-7
01/01/87
Phenvtoin
5 / —4 I —0
01/01/95
Phosgene
75-44-5
01/01/87
Phosphine
7803-51-2
01/01/95
Phosphoric acid
7664-38-2
01/01/87
Phosphorus (vellow or white)
7723-14-0
01/01/87
Phthalic anhvdride
85-44-9
01/01/87
Picloram
1918-02-1
01/01/95
Picric acid
88-89-1
01/01/87
Piperonvl butoxide
51-03-6
01/01/95
Pirirriphos melhvl [0-(2-(Diethylamino)-6-methyl-4-pvrimidinyl)-0,0-
ditiethvlphosphorothioate]
29232-93-7
01/01/95
Polvchlorinated biphenvls (PCBs)
1336-36-3
01/01/87
Potassium bromate
7758-01-2
01/01/95
Potassium dimethvldithiocarbamate
128-03-0
01/01/95
Potassium N-methvldithiocarbamate
137-41-7
01/01/95
Profenofos [0-(4-Bromo-2-chlorophenyl)-0-ethvl-S-propvI
phosphorothioate]
41198-08-7
01/01/95
Prometrvn [N,N'-Bis( l-methvlethvl)-6-methylthio-1,3,5-triazine-2,4-
diamine]
7287-19-6
01/01/95
Pronamide
23950-58-5
01/01/94
Propachlor [2-Chloro-N-( i -methvlethvl)-N-phenvlacetamide]
1918-16-7
01/01/95
Propane suitone
1120-71-4
01/01/87
Propanil [N-(3.4-Dichlorophenvl)propanamide]
709-98-8
01/01/95
Propargite
2312-35-8
01/01/95
Propargvl alcohol
107-19-7
01/01/95
Propetamphos [3-{[(Ethvlamino)methoxvphosphinothioyl]oxy]-2-
butenoic acid. 1 -methvlethvl ester]
31218-83-4
01/01/95
Propiconazole [ 1 -[2-(2,4-Dichlorophenvl)-4-propvl-1,3-dioxolan-2-vl]-
methvl-1 H-1,2,4,-tnazole]
60207-90-1
01/01/95
bcjt.vProoiolactone
57-57-8
01 01/87
December 1996
7-G13
-------
Toxic Chemical Reporting
PartI, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Propionaldehvde
123-38-6
01/01/87
Propoxur [Phenol, 2-( l-methvlethoxv)-, methvlcarbamate]
114-26-1
01/01/87
Propvlene (Propene)
115-07-1
01/01/87
Propvleneimine
75-55-8
01/01/87
Propvlene oxide
75-56-9
01/01/87
Pyridine
1 10-86-1
01/01/87
Quinoline
91-22-5
01/01/87
Quinone
106-51-4
01/01/87
Quintozene [Pentachloronitrobenzene]
82-68-8
01/01/87
Quizalofop-ethvl [2-[4-[(6-Chloro-2-quinoxaJinyl)oxy]phenoxy] propanoic
acid ethvl ester]
76578-14-8
01/01/95
Resmethrin [[5-(Phenvlmet_hvl)-3-furanyl]methyl 2,2-dimethvl-3-(2-
methvl- l-pro-penvl) cvcloDroDanecarboxvlate]]
10453-86-8
01/01/95
Saccharin (onlv persons who manufacture are subject, no supplier
notification) [ 1,2-Benzisothiazol-3(2H)-one, 1,1 -dioxide]
81-07-2
01,01/87
Safrole
94-59-7
01/01/87
Selenium
7782-49-2
01/01/87
Sethoxydim [2-[ 1 -(Ethoxyimino)butvl]-5-[2-(ethylthio)propvl]-3-hydroxy-
2-cvclohexen-1 -one]
74051-80-2
01/01/95
Silver
7440-22-4
01/01/87
Simazine
122-34-9
01/01/95
Sodium azide
26628-22-8
01/01/95
Solium dicamba [3.6-Dichloro-2-methoxvbenzoic acid, sodium salt]
1982-69-0
01/01/95
Sodium dimethvldithiocarbamate
128-04-1
01/01/95
Sodium fluoroacetate
62-74-8
01/01/95
Sodium nitrite
7632-00-0
01/01/95
Sodium pentachlorophenate
131-52-2
Sodium o-phenvlphenoxide
132-27-4
01/01/95
Stvrene
100-42-5
01/01/87
Stvrene oxide
96-09-3
01/01/87
Sulfuric acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of anv par-ticle size)
7664-93-9
01/01/87
Sulfurvl fluoride [Vikane]
2699-79-8
01/01/95
Sulprofos [O-Ethvl 0-[4-(methvlthio)phenvl]phosphorodithioic acid S-
propvl ester]
35400-43-2
01/01/95
Tebuthiuron [N-[5-( 1,1 -Dimethvlethyl)-I,3,4-ihiadiazol-2-yl)-N,N'-
dimethvlurea]
34014-18-1
01/01/95
Temephos
3383-96-8
01/01/95
Terbacil [5-Chloro-3-( 1,1 -dimethylethyl)-6-methvl-2.4( 1 H.3H)-
pvrimidinedione]
5902-51-2
01/01/95
l.l.l ,2-Tetrachloroethane
630-20-6
01/01/94
1.1,2.2-Tetrachloroethane
79-34-5
0I.0I.S7
December 1996
7-G14
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Tetrachloroethvlene (Perchloroethvlene)
127-18-4
01/01/87
I, I, i ,2-Tetrachloro-2-fluoroethane (HCFC-12 la)
354-11-0
01/01/95
1,1,2,2-Tetrachloro-1 -fluoroethane (HCFC-121)
354-14-3
01/01/95
Tetrachlorvinphos [Phosphoric acid, 2-chloro-1-(2.4,5-
trichlorophenvl)ethenvl dimethyl ester]
961-11-5
01/01/87
Tetracycline hydrochloride
64-75-5
01,01/95
Tetramethrin [2,2-Dimethyl-3-(2-methvl-l -
propenvl)cvciopropanecarboxvlic acid (1,3,4,5,6,7- hexahvdro-1,3-dioxo-
2H-isoindol-2-vl)methvl ester]
7696-12-0
01/01/95
Thallium
7440-28-0
01/01/87
Thiabendazole [2-(4-Thiazolvl)~ 1 H-benzimidazole]
148-79-8
01/01/95
Thioacetamide
62-55-5
01/01/87
Thiobencarb [Carbamic acid, diethvlthio-, s-(p-chlorobenzvl)]
2S249-77-6
01/01/95
4,4'-Thiodianiline
139-65-1
01/01/87
Thiodicarb
59669-26-0
01/01/95
Thiophanate ethyl [[ 1,2-Phenylenebis(iminocarbonothiovl)]biscarbamic
acid diethyl ester]
23564-06-9
01/01/95
Thiophanate-methvl
23564-05-8
01/01/95
Thiosemicarbazide
79-19-6
01/01/95
Thiourea
62-56-6
01/01/87
Thiram
137-26-8
01/01/94
Thorium dioxide
1314-20-1
01/01/87
Titanium tetrachloride
7550-45-0
01/01/87
Toluene
108-88-3
01/01/87
Toluene-2,4-diisocvanate
584-84-9
01/01/87
Toluene-2,6-diisocvanate
91-08-7
01/01/87
Toluenediisocvanate (mixed isomers)
26471-62-5
01/01/90
o-Toluidine
95-53-4
01/01/87
o-Toluidine hydrochloride
636-21-5
01/01/87
Toxaphene
8001-35-2
01/01/87
Triadimefon [ 1 -(4-Chlorophenoxv)-3.3-dimethvl-1 -(1 H-l ,2,4-triazol-l -
vH-2-butanone]
43121-43-3
01/01/95
Triallate
2303-17-5
01/01/95
Triaziquone [2,5-Cvclohexadiene-1,4-dione.2,3.5-tris( 1 -aziridinvl)-]
68-76-8
01/01/87
Tribenuron methvl (2-(((((4-Methoxy-6-methvl-1,3,5-triazin-2-vl)-
methvlamino) carbonvl)amino)sulfonvl)-. methvl ester]
101200-48-0
01/01/9 5
Tributvltin fluoride
1983-10-4
01/01/95
Tributvltin methacrvlate
2155-70-6
01/01/95
S.S.S-Tributvltrithiophosphate (DEF)
7S-48-8
01/01/95
Trichlorfon fPhosphonic acid, (2,'\2-trichloro-1 -hvdroxvethvl)-, dimethyl
ester]
52-68-6
01,01/37
Trichloroacetvl chloride
76-02-8
01 01/95
December 1996
7-G15
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
1,2.4-Trichlorobenzene
120-82-1
01/01/87
I, I. I -Trichloroethane (.Vlethvl chloroform)
71-55-6
01/01/87
1.1,2-Trichloroethane
79-00-5
01/01/87
Trichloroethvlene
79-01-6
01/01/87
Trichlorofluoromethane (CFC-1 1)
75-69-4
07/08/90
2.4.5-Trichlorophenol
95-95-4
01/01/87
2.4,6-Trichlorophenol
88-06-2
01,01/87
1.2,3-Trichloropropane
96-18-4
01,01/95
Triclopvr, triethvlammonium salt
57213-69-1
01,01/95
Triethvlamine
121-44-8
01/01/95
Triforine [N,N'-[ 1,4-Piperazinediyl-bis(2,2,2-trichloroethylidene)]
bisformamide]
26644-46-2
01,01/95
Trifluralin [Benzeneamine, 2,6-dinitro-N,N-dipropvl-4-(trifluoromethvl)-
1)
1582-09-8
01,01/87
1,2,4-Trimethvlbenzene
95-63-6
01/01/87
Trimethvlchlorosilane
75-77-4
01/01/9-5
2.3.5-Trimethvlphenvl methvlcarbamate
2655—15—4
01/01/95
Triphenvltin chloride
639-58-7
01/01/95
Triphenvltin hvdroxide
76-87-9
01/01/95
Tris(2,3-dibromopropvl) phosphate
126-72-7
01/01/87
Trypan blue
72-57-1
01,01/9.4
Ur?thane (Ethvl carbamate)
51-79-6
01/01/87
Vanadium (fume or dust)
7440-62-2
01/01/87
Vinclozolin [3-(3,5-Dichlorophenvl)-5-ethenvl-5-methyl-2,4-
oxazolidinedione]
50471-44-8
01/01/95
Vinvl acetate
108-05-t
01/01/87
Vinvl bromide
593-60-2
01/01/87
Vinvl chloride
75-01-4
01/01/87
Vinvlidene chloride
75-35-4
01/01/87
Xvlene (mixed isomers)
1330-20-7
01/01/87
m-Xvlene
108-38-3
01,01/87
o-Xvlene
95-47-6
01.-01/87
p-Xvlene
106-42-3
01/01/87
2,6-Xvlidine
87-62-7
01/01/87
Zinc (fume or dust)
7440-66-6
01/01/87
Zineb fCarbamodithioic acid. 1,2-ethanedivlbis-. zinc complexl
12122-67-7
01/01/87
December 1996
7-G16
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Section 3 13 reporting is required for the toxic chemical families listed below,
in addition to the specific toxic chemicaJs listed above.
Antimonv Compounds: Includes anv unique chemical substance that
contains antimonv as part of that chemical's infrastructure.
01/01/87
Arsenic Compounds: Includes any unique chemical substance that
contains arsenic as part of that chemical's infrastructure.
01/01/87
Barium Compounds: Includes any unique chemical substance that
contains barium as part of that chemical's infrastructure (except for
barium sulfate. CAS No. 7727-43-7).
01/01/87
Beryllium Compounds: Includes any unique chemical substance that
contains bervllium as part of that chemical's infrastructure.
01/01/87
Cadmium Compounds: Includes any unique chemical substance that
contains cadmium as part of chat chemical's infrastructure.
01/01/87
Chlorophenols.
01/01/87
Chromium Compounds: Includes any unique chemical substance that
contains chromium as part of that chemical's infrastructure.
01/01/87
Cobalt Compounds: Includes any unique chemical substance that contains
cobalt as part of that chemical's infrastructure.
01/01/87
Copper Compounds: Includes any unique chemical substance that
contains copper as part of that chemical's infrastructure. This category
does not include copper phthalocyanine compounds that are substituted
with onlv hvdrogen, and/or chlorine, and/or bromine.
01/01/87
Cvanide Compounds: X+CN- wl..re X = H+ or any other group where a
formal dissociation can be made. For example KCN or Ca(CN)-,.
01/01/87
Diisocvanates (this category includes only those chemicals listed below).
1.3-Bis(methvlisocyanate)cvclohexane
1.4-Bis(methvlisocyanate)cvclohexane
1.4-Cvclohe.xane diisocvanate
Diethvldiisocvanatobenzene
4,4'-Diisocvanatodiphenvl ether
2,4'-Diisocvanatodiphenvl sulfide
3.3'-Dimethoxvbenzidine-4,4'-diisocvanate
3.3'-Dimethvl-4,4'-diphenylene diisocvanate
3,3'-Dimethvldiphenvlmethane-4,4'-diisocyanate
He.xamethvlene-1,6-diisocvanate
Isophorone diisocvanate
4-Methvldiphenvlmethane-3,4-diisocyanate
1,1 -Methylene bis(4-isocvanatocvclohexane)
Methvlenebis(phenvlisocyanate) (MDI)
1.5-Naphthalene diisocvanate
1.3-Phenvlene diisocvanate
1.4-Phenvlene diisocvanate
Polvmeric diphenvlmethane diisocvanate
2,2.4-Trimethvlhexamethvlene diisocvanate
2.4.4-Trimethvlhexamethvlene diisocvanate
038661-72-2
010347-54-3
002556-36-7
134190-37-7
004128-73-8
075790-87-3
000091-93-0
000091-97-4
000139-25-3
000822-06-0
004098-71-9
075790-74-0
005124-30-1
000101-68-8
003173-72-6
000123-61-5
000104-49-4
009016-87-9
016938-22-0
015646-96-5
01/01/95
December 1996
7-G17
-------
Toxic Chemical Reporting
Part 1, Chapter 7
Complete Listing of Toxic Release Inventory (TRI) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Ethvlenebisdithiocarbamic acid, salts and esters: Includes any unique
chemical substance that contains an EDBC or an EDBC salt as part of
that chemical's infrastructure.
01/01/94
Certain Glvcol Ethers
R-(OCH,CH,)„-OR'
Where:
n = 1, 2, or 3;
R = alky 1 C7 or less: or
R = phenvl or alkvl substituted phenyl:
R' = H, or alkvl C7 or less; or
OR' consisting of carboxvlic acid ester, sulfate, phosphate, nitrate,
or sulfonate.
01/01/95
Lead Compounds: Includes any unique chemical substance that contains
lead as part of that chemical's infrastructure.
01/01/87
Manganese Compounds: Includes any unique chemical substance that
contains manganese as part of that chemical's infrastructure
01/01/87
Mercurv Compounds: Includes any unique chemical substance that
contains mercurv as pan of that chemical's infrastructure.
01/01/87
Nicotine and salts
01/01/95
Nitrate compounds (water dissociable; reportable only when in aqueous
solution).
01/01/95
Nickel Compounds: Includes any unique chemical substance that contains
nickel as part of that chemical's infrastructure.
01/01/87
Polvbrominated Biphenvls (PBBs).
0I/0I/S7
Polv-nlorinated alkanes (CIO to CI3): Includes those chemicals defi -jd
bv the following formula:
Where
x= 10 to 13;
y= 3 to 12; and
where the average chlorine content ranges from 40-70% with the
limiting molecular formulas C10HigC|3 and C^H^CI,;..
0.1/01/95
December 1996
7-G18
-------
Toxic Chemical Reporting
Part I, Chapter 7
Complete Listing of Toxic Release Inventory (TR1) Chemicals
Chemical Name
CAS No.
Effective
Date for
Reporting
Polvcvclic aromatic compounds (PACs): (This category includes only
those chemicals listed below)
Benz(a)anthracene
Benzo(a)phenanthrene
Benzo(a)pvrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
Benzo(k)fluoranthene
Benzo(rst)pentaphene
Dibenz(a,h)acridine
Dibenz(a,j)acridine
Dibenzo(a,h)anthracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pvrene
Dibenzo(a,h)pvrene
Dibenzo(a,l)pvrene
7H-Dibenzo(c.g)carbazole
7,12-Dimethvlbenz(a)anthracene
Indeno[ 1,2,3-cd]pvrene
5-Methvlchrysene
1 -Nitropvrene
00056-55-3
00218-01-9
00050-32-8
00205-99-2
00205-82-3
00207-08-9
00189-55-9
00226-36-8
00224-42-0
00053-70-3
05385-75-1
00192-65-4
00189-64-0
00191-30-0
00194-59-2
00057-97-6
00193-39-5
03697-24-3
05522-43-0
01/01/95
Selenium Compounds: Includes any unique chemical substance that
contains selenium as part of that chemical's infrastructure.
01/01/87
Silver Compounds: Includes any unique chemical substance that contains
silver as part of that chemical's infrastructure.
01/01/87
krvchnine and salts.
01/01/95
Thallium Compounds: Includes any unique chemical substance that
contains thallium as part of that chemical's infrastructure.
01/01/87
Warfarin and salts: Includes any unique chemical substance that contains
warfarin or a warfarin salt as part of that chemical's infrastructure.
01/01/94
Zinc Compounds: Includes any unique chemical substance that contains
zinc as part of that chemical's infrastructure.
01/01/87
December 1996
7-G19
-------
Notes
-------
CHAPTER 8
Emergency Planning and Notification
8.1 Federal Requirements (EPCRA) 8-3
8.1.1 What Is EPCRA? 8-3
8.1.2 Requirements for Emergency Planning 8-4
8.1.3 Requirements for Emergency Notification 8-9
8.2 State Requirements 8-12
8.3 Where To Go fof More Information 8-13
This chapter presents the federal requirements you need to follow to plan for
chemical emergencies (leaks or spills) at your facility, and to report any
accidental releases of hazardous substances. The chapter also provides a brief
overview of state requirements for emergency planning and notification.
Review this section to understand your responsibilities in the event of a
chemical emergency. You will learn whom to notify and what information you
must provide if such a situation arises.
responsibilities. This chapter will help you identify whether these additional
requirements apply to your facility.
This chapter provides a number of tools to assist you in complying with the
federal requirements. Appendix 8-A provides a handy summary of the actions
you must take and deadlines you must meet to comply with emergency
planning and notification requirements. In Appendix 8-B, you'll find a
worksheet where you can record important information about chemicals and
chemical releases that you can use to fulfill reporting requirements. Additional
appendices help you determine whom to report to and which chemicals trigger
reporting requirements.
December 1996
8-1
-------
Emergency Planning and Notification
Part I, Chapter 8
Table of Contents Page
8.1 Federal Requirements (EPCRA) 8-3
8.1.1 What Is EPCRA? 8-3
8.1.2 Requirements for Emergency Planning 8-4
8.1.2.1 What Agencies Are Responsible for Emergency Planning? 8-4
8.1.2.2 What Is an "Extremely Hazardous Substance?" 8-5
8.1.2.3 What Is a "Threshold Planning Quantity?" 8-5
8.1.2.4 What Actions Must I Take If My Facility Handles an Extremely Hazardous
Substance at or Above the TPQ? 8-6
8.1.3 Requirements for Emergency Notification 8-9
8.1.3.1 When Must I Report an Accidental Release (Leak or Spill) of a
Hazardous Substance? 8-9
8.1.3.2 What Is a Release? 8-9
8.1.3.3 What Is a Facility? 8-10
8.1.3.4 Which Chemicals Are Covered? 8-10
8.1.3.5 What Releases Do I Not Have to Report? 8-11
8.1.3.6 How Do I Report an Accidental Release? 8-11
8.2 State Requirements 8-12
8.3 Where To Go for More Information 8-13
Appendix 8-A Compliance Calendar for EPCRA Emergency Planning and Notification Reporting
Requirements
Appendix 8-B Worksheet for Emergency Planning and Notification
Appendix 8-C State Emergency Response Commissions
Appendix 8-D Complete List of Extremely Hazardous Substances and Their Threshold Planning Quantities
Appendix 8-E Additional Cheriiicals Typically Used by Metal Finishers That Are Subject to Emergency
Notification Requirements
Appendix 8-F Sample Form for Recording Information To Be Reported in the Event of a Release of a
Hazardous Substance
December 1996
8-2
-------
Emergency Planning and Notification
Part I, Chapter 8
Emergency Planning and Notification: How to Comply
~ Identify the State Emergency Response Commission (SERC) and the
Local Emergency Planning Committee (LEPC) for your area.
~ Determine whether you have any "extremely hazardous substance" at
or above the "threshold planning quantity." If so:
— Notify the SERC that you are subject to EPCRA's emergency planning
requirements.
— Name a facility coordinator and notify the LEPC who your coordinator
is.
— Inform the LEPC of any relevant changes at your facility.
~ If you have a leak or spill, determine whether it is a chemical for which
you must report accidental releases, and if the release is above the
"reportable quantity." If so:
— Immediately notify the LEPC and SERC.
— Immediately notify the National Response Center.
— Send a written followup report to the LEPC and SERC as soon as
possible.
— Determine and comply with any additional state, regional, or local
requirements.
8.1 Federal Requirements (EPCRA)
8.1.1 What Is EPCRA?
Federal emergency planning and notification requirements are
contained in the Emergency Planning and Community Right-To-
Know Act (EPCRA), also known as Title III of the Superfund
Amendments and Reauthorization Act of 1986 (SARA). This act
establishes emergency planning and reporting requirements for
businesses such as metal finishers that handle, store, or manufacture
certain hazardous materials. These requirements are designed to
prepare for and respond to emergencies involving hazardous
substances. (EPCRA also sets requirements for annual reporting of
December 1996
8-3
-------
Emergency Planning and Notification
Part I, Chapter 8
hazardous chemical inventories and toxic chemical releases. These
are discussed in Chapter 7.)
Box 8-1 Emergency Planning and Notification
Requirements of EPCRA
Sections 301-
Requires companies that handle,
303
store, or manufacture hazardous
chemicals to plan for chemical
emergencies.
Section 304
Specifies what companies need to
do in the event of a chemical
release.
8.1.2 Requirements for Emergency Planning (EPCRA
Sections 301-303)
Under EPCRA, every community in the United States must be part
of a comprehensive plan to prepare for and respond to chemical
emergencies. Your business does not have to prepare this plan, but
information that you report about hazardous materials at your
facility may be included in the plan.
8.1.2.1 What Agencies Are Responsible for Emergency
Planning?
The governor of each state must appoint a state emergency response
commission (SERC). The governor might name an existing state
agency as the SERC. The SERC might also include members of
trade associations, public interest organizations, and others with
experience in emergency planning. Appendix 8-C contains a list of
SERC contacts for all the states.
/ Record the contact name, address, and phone number for
your SERC on the worksheet in Appendix 8-B.
Each SERC divides its state into local emergency planning districts
and appoints a local emergency planning committee (LEPC) for
each district. Contact the SERC in your state to identify the LEPC
in your area.
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
/ Record the contact name, address, and phone number for
the LEPC in your area on the worksheet in Appendix 8-B.
The LEPC is responsible for developing the local emergency plan for
its district. The plan is based on information about "extremely
hazardous substances" reported to the LEPC by local industries and
other facilities with chemicals.
8.1.2.2 What Is an "Extremely Hazardous Substance"?
EPA has designated 366 substances as "extremely hazardous."
Those typically used in the metal finishing industry are listed in the
Box 8-2. Appendix 8-D contains the complete list of extremely
hazardous substances.
/ Review Appendix 8-D to see if you use any of these
substances at your facility.
Box 8-2 Extremely Hazardous Substances Typically Used
in Metal Finishing
Ammonia (aqueous ammonia) Potassium cyanide
Cadmium oxide Potassium silver cyanide
Nitric acid Sulfuric acid
8.1.2.3 What Is a "Threshold Planning Quantity"?
If you have an extremely hazardous substance at your facility/or any
length of time at or above a certain quantity, called a threshold
planning quantity (TPQ), you have to meet EPCRA's notification
requirements for emergency planning described in Section 8.1.3.
The list of extremely hazardous substances in Appendix 8-D
includes TPQs for each substance.
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
S Follow the procedure in Box 8-3 to see whether you handle
any extremely hazardous substances at or above the TPQ.
On the worksheet in Appendix 8-B, record any extremely
hazardous substances found at your facility at or above the
TPQ.
8.1.2.4 What Actions Must I Take if My Facility Handles
an Extremely Hazardous Substance at or Above
the TPQ?
If you have an extremely hazardous substance at or above the TPQ
at your facility, you must notify the SERC. An example notification
letter is shown further below in Figure 8-1. To use this letter, look
up the address of the State Emergency Planning Commission in
Appendix 8-C, and substitute the appropriate information for your
own facility. Make sure to call first to check whether the name of
the State Commissioner is current and the mailing address is still
the same.
You must provide this notification within 60 days of when your
facility met or exceeded the TPQ for any extremely hazardous
substance. You only need to provide this notification once (you do
not need to provide any further notification when other chemicals
exceed the TPQ).
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
Box 8-3 How To Calculate Whether Your Facility Stores "Threshold Planning
Quantities" of Extremely Hazardous Substances
EPCRA regulations require that you determine whether your facility stores extremely hazardous substances in
quantities equal to or greater than their TPQs. Follow the procedures below for solutions, mixtures, and solids.
When calculating the total quantity of a chemical on site, you must count and add together all individual quantities
of the chemical, regardless of use, volume, storage condition, or location. To demonstrate compliance, be sure to
keep on file the calculations you made to determine the total quantity of each extremely hazardous substance.
Mixtures and Solutions
Because the concentrations of chemical solutions and mixtures vary, you need to calculate the amount of each
extremely hazardous substance stored in all solutions and mixtures to see if the total weight of the substance stored
at your facility (in pounds) meets or exceeds the TPQ.
If a container or storage vessel holds a mixture or solution of an extremely hazardous substance, multiply the
concentration of the extremely hazardous substance, in weight percent by the mass (in pounds) in the vessel to
determine the actual quantity of the extremely hazardous substance. (If the concentration is less than 1 percent,
the mixture or solution is not subject to the emergency planning reporting requirements.)
EXAMPLE: A cyanide-cadmium plating solution contains 3% cadmium metal, 28% sodium cyanide, and 4% sodium
hydroxide. Imperial Plating, Inc. has two 55-gaIlon drums (500 pounds each) of this mixture onsite. The shop
foreman calculates the weight of the hazardous cadmium and sodium cyanide as follows: 0.003 x 2 drums x 500
pounds = 3 oz. cadmium, and 0.28 x 2 drums x 500 pounds = 280 oz. (17.5 lbs) sodium cyanide. The 3 oz.of
cadmium is below the TPQ of 1 lb, therefore it is not subject to the emergency planning requirements. The 17.5
lbs of sodium cyanide, however, is above the TPQ of 10 lbs so the company is required to follow emergency planning
requirements for this chemical. The sodium hydroxide is not listed as an extremely hazardous substance and is thus
not subject to emergency planning requirements.
Solids
Extremely hazardous substances that are solids are subject to either of two TPQs listed in Appendix 8-D. The lower
quantity applies only if you can answer "yes" to one of the three questio ,s below:
1. Does the solid exist in powdered form and have a particle size less than 100 microns? (Consult the Material
Safety Data Sheet (MSDS) or manufacturer for information about the chemical's particle size.)
2. Is the solid handled in solution?
3. Does the solid have a National Fire Protection Association (NFPA) rating of 2, 3, or 4 for reactivity? (Consult
the MSDS or manufacturer for information about the chemical's NFPA rating.)
If you answered "no" to all three questions, the higher TPQ applies.
To calculate the quantity of a solid with a particle size less than 100 microns, multiply the weight percent of the solid
in a particular container by the quantity of solid in the container. Add up the quantities for all containers that hold
this substance. Compare the total amount to the lower TPQ. If the amount meets or exceeds the TPQ, you must
follow the emergency planning reporting requirements for this chemical (described on the next two pages).
To calculate the quantity of a solid in solution, multiply the weight percent of the solid in solution in a particular
container by the quantity of solution in the container. Add up the quantities for all containers that hold that
substance. If the total amount meets or exceeds the lower TPQ you must follow the emergency planning reporting
requirements for this chemical.
December 1996
8-7
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Emergency Planning and Notification
Part I, Chapter 8
aria/ Q$ne.
123 Anywhere Street
Chicago, Illinois
April 28, 1996
Mr. John Mitchell, Chair
State Emergency Response Commission
Illinois Emergency Management Agency
110 East Adams Street
Springfield, IL 62701-9963
Dear Mr. Mitchell:
This letter serves as notification to the Illinois State Emergency Response Commission
that Imperial Plating, Inc. has an extremely hazardous substance on site in excess of the
threshold planning quantity, and therefore is subject to the emergency planning requirements
of Sections 301-303 of the federal Emergency Planning and Community Right-To-Know Act
(EPCRA).
Our facility coordinator, Mr. Bruce Glenn, can provide information about the chemical
identity, quantity, and storage needed for emergency planning. Please feel free to contact him
at any time at (312) 555-5555, ext. 123.
Sincerely,
Robert Bosek
President
Figure 8-1. Sample notification letter.
December 1996
8-8
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Emergency Planning and Notification
Part I, Chapter 8
In addition to notifying the SERC that you are subject to EPCRA's
emergency planning requirements, you must:
¦ Name an employee as the "facility coordinator." This facility
coordinator must participate in the district's emergency
response planning process. Record the name and phone
number of your facility coordinator on the worksheet in
Appendix 8-B.
¦ Notify the LEPC who your facility coordinator is within 60
days of first meeting or exceeding a TPQ for any extremely
hazardous substance. You can use the notification letter
mentioned above to fulfill this requirement.
¦ Inform the LEPC of any changes at your facility that might
be relevant to emergency planning.
¦ At the request of the LEPC, provide any information it needs
to develop or implement the local emergency plan.
8.1.3 Requirements for Emergency Notification (EPCRA
Section 304)
8.1.3.1 When Must I Report an Accidental Release (Leak
or Spill) of a Hazardous Substance?
Under EPCRA, you must immediately report the release from your
facility of more than a certain amount of any one of a large number
of hazardous substances. "Release" and "facility" are defined below.
Several other federal laws require reporting of spills and releases and
may define these terms differently. See Chapters 4 through 7 for
more information.
8.1.3.2 What Is a Release?
A release is essentially any loss of a hazardous substance that comes
in contact with water or land, or that evaporates into the
atmosphere. It includes material that is purposefully or accidentally
spilled, leaked, pumped, poured, emitted, emptied, discharged,
injected, dumped, disposed, or that escapes or leaches from a
container into the environment (including barrels, containers, and
other closed receptacles that are abandoned or discarded). Losses of
material that occur inside a facility and that never come into contact
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
with the environment (e.g., they are cleaned up before they reach
water, land, or evaporate into the air) are not considered releases.
8.1.3.3 What Is a Facility?
The term facility is defined as:
¦ Any building, structure, installation, equipment, pipe or
pipeline, well, pit, pond, lagoon, impoundment, ditch,
landfill, storage container, motor vehicle, rolling stock, or
aircraft; or
¦ Any site or area where a hazardous substance has been
deposited, stored, disposed of, placed, or is otherwise located.
8.1.3.4 Which Chemicals Are Covered?
The chemicals covered by this part of EPCRA include not only the
366 extremely hazardous substances discussed in Section 8.1.2.2
and listed in Appendix 8-D, but also more than 700 hazardous
substances subject to the emergency notification requirements of the
Superfund hazardous waste cleanup laws (some chemicals are on
both lists). Appendix 8-E shows the chemicals on the list of 700
substances that are typically used in the metal finishing industry.
For some of the most hazardous and toxic chemicals on these lists,
you must report releases of more than one pound. For others, the
reportable quantities range from 10 to 10,000 pounds. See
Appendix 8-D for the reportable quantities.
Box 8-4 If There Is a Release From Your Facility:
~ Check to see whether the chemical is an extremely
hazardous substance or one of the 700 additional
substances for which you must report a release.
~ If the chemical falls in either of these categories, look
up the reportable quantity for the substance. If your
release meets or exceeds that quantity, follow the
procedures under Section 8.1.3.6 "How Do I Report an
Accidental Release?" below.
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
8.1.3.5 What Releases Do I Not Have To Report?
Under the federal law, you do not have to report a release that:
¦ Is below the reportable quantity.
¦ Results in exposure only to people within the workplace
(even if it is above the reportable quantity).
¦ Is allowed under a federal permit (such as Clean Air Act or
Clean Water Act permits).
8.1.3.6 How Do I Report an Accidental Release?
Immediately after the release occurs, telephone the LEPC and the
SERC. If there is no LEPC for your area, contact emergency
response personnel (such as the fire department). If the release
results from a transportation accident, the transporter can dial 911
or the local telephone operator to report it.
In addition to notifying the LEPC and SERC, you must notify the
National Response Center (NRC), which alerts federal responders.
The number of the NRC is 1-800-424-8802.
Your emergency release notification must include the following
information:
¦ The name of the chemical.
¦ The location of the release.
¦ Whether the chemical is on the "extremely hazardous
substances" list.
¦ How much of the substance has been released.
¦ The time and duration of the incident.
¦ Whether the chemical was released into the air, water, or soil,
or some combination of the three.
¦ Known or anticipated health risks and necessary medical
attention. (You can obtain this information from the MSDS
for the chemical.)
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
¦ Proper precautions, such as evacuation. (This information
should also appear on the MSDS.)
¦ A contact person at the facility.
Information that would be reported in a hypothetical notification is
shown in the box on the Appendix 8-F.
As soon as possible, you must also submit a written follow-up report
to both the LEPC and the SERC. The follow-up report must
update the original notification and provide additional information
on:
¦ Response actions that were taken.
¦ The known or anticipated health risks.
¦ Any advice regarding any medical care needed by people who
were exposed to the released substance.
You must also submit additional followup reports as more
information about the release becomes available (such as more
information about additional response actions you took).
The worksheet in Appendix 8-B includes a table that can help you
keep track of notifications about accidental releases.
In addition to notifying the NRC, you may also call the Chemical
Transportation Emergency Center (CHEMTREC). CHEMTREC
is a Chemical Manufacturers Association hotline that provides
information about emergency response options for accidental
releases. The phone number for CHEMTREC is 1-800-424-9300.
8.2 State Requirements
Most states have Emergency Planning and Notification laws which
follow the federal requirements of SARA Title III. The state laws
may also extend coverage to additional chemical lists or require
additional notifications. The programs are similar in that each
facility that stores or uses hazardous chemicals must report the
inventory to state and local agencies. The purpose of the
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
notifications is to reduce the effects of chemical accidents, provide
information to the public, and to allow for the development of
emergency response plans by state and local public safety agencies.
Some states have notification programs which are more stringent
that the federal requirements. The main differences between the
states and federal program is that the state inventory thresholds
requiring notification are often lower or encompasses more lists of
chemicals or facility designations than the federal regulations.
Table 8-1 summarizes the individual state requirements regarding
hazardous chemical inventory notifications and general features
about each state's requirements that may be similar to the Federal
regulations or those that require more detailed submittals of
information. Please keep in mind that many states are in the
process of revising their state regulations. It is recommended that
each state be contacted to discuss specific regulations that may
affect the notification and planning process.
Contact your LEPC, SERC, or EPA Regional Office for additional
information about these requirements. The SERCs for each state
are listed in Appendix 8-C.
8.3 Where To Go for More Information
To get more information about emergency planning and notification
requirements, contact:
¦ Your State Emergency Response Commission.
¦ Your Local Emergency Planning Committee.
¦ Your EPA Regional Office.
¦ EPA's Emergency Planning and Community Right-To-ICnow
Hotline (1-800-535-0202).
December 1996
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Emergency Planning and Notification
Part I, Chapter 8
The federal regulations discussed in this chapter are found in The
Code of Federal Regulations (CFR) Title 40, Part 355. The CFR is
found in many libraries or is available by writing:
The Superintendent of Documents
Attn: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
or by calling the Government Printing Office order desk at 202-783-
3238.
December 1996
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Table 8-1
Summary of Selected State Emergency Planning and Notification Programs
State
Laws and Regulations
Notification, Planning and Reporting
State Contact(s)
Ml
Federal Requirements Apply
Michigan Administrative Code R29.5(p)
299.601, 408.10001
Michigan Compliance Laws Annotated
299.702
Same as Federal. Recordkeeping performed by Department of
Environmental Quality, Environmental Assistance, SARA Title 111
Unit. Michigan State Police coordinates activities as State Emergency
Response Commission. County governments are Local Emergency
Planning Commissions; Washtenaw County has an additional
ordinance.
Michigan Department of
Natural Resources
530 West Allegan Street
P.O. Box 30260
Lansing, Ml 48909
(517) 373-8481
MN
Federal Requirements Apply
Minnesota Statutes Annotated, Volume
9A, Chapter 299 K, 115D.03
Minnesota Regulations 7507
Filing fees for MSDSs submissions. Employers subject to Minnesota
State Occupational Safety and Health (MN-OSHA) Standards must
submit Tier I Chemical Inventory Forms. Filing fee for Form R
submissions, Form R filers are required to develop a Toxic Pollution
Prevention Plan. Each County has a designated library which holds
the County's Emergency Response Plan and a list of County facilities
subject to EPCRA requirements.
Minnesota Pollution
Control Agency
520 Lafayette Road
St. Paul, MN 55155
(800) 657-3864
(612) 649-5451
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Table 8-1 Summary of Selected State Emergency Planning and Notification Programs
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State
NJ
NY
Laws and Regulations
Federal Requirements Apply
Coverage extends to toxic chemicals
listed by EPA 40 CFR 372.65
Selected hazardous substances listed by
New Jersey Administrative Code (NJAC)
7:IF, Appendix A
Unusually hazardous substances defined
by NJAC 7:G-l.2
Hazardous substances subject to
pollution planning under NJAC 7:K-3.5
Hazardous substances listed by the New
Jersey Department of Health
Extraordinary hazardous substances
listed by NJAC 7:31 -2.3, Table 1
Environmental hazardous substances
listed at Table A are required to be
reported in the Annual Community
Right-To-Know (CRTK) Survey
Facilities with Standard Industrial
Classification codes listed in the NJ
Community Right-To-Know Survey
packet
New Jersey Statutes Annotated 34:5A-1,
7:31, 13-1D
NJAC 7:1G-1.1, 8:59-1.1. 13:1K-19
Federal Requirements Apply
Notification, Planning and Reporting
NJDEP must receive facility coverage notification. Notification of
facility coverage is due 90 prior to construction of a facility or the
placement of Extraordinary Hazardous Substances equipment into
service. Facilities must register with State and registration fee
required. Facilities required to develop Risk Management Program
and Summary Statement. Tier 1 Chemical Inventory submissions
must include CRTK Survey (DEQ-094 Form). NJDEP, LEPC, local
Police Department, lead County Right-To-Know Agencv must receive
Tier I Chemical Inventory Forms and Annual Survey from covered
facilities. Form R Forms must be submitted by July 1 of each year
and must include submission of a Release and Pollution Prevention
Report.
Federal Requirements Apply
State Contact(s)
New Jersey Department of
Environmental Protection
policy and Planning
Bureau of Hazardous
Substance Information
ATTN: 302 Notification
CN405
401 East State Street
Trenton, NJ 08625-0405
(609) 984-3219
New York State
Department of
Environmental
Conservation
50 Wolf Road
Albany, New York 12233-
1750'
(518)457-6934
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Table 8-1
Summary of Selected State Emergency Planning and Notification Programs
State
Laws and Regulations
Notification, Planning and Reporting
State Contact(s)
NC
Federal Requirements Apply
Coverage extends to certain fertilizers,
pesticides, and other agricultural
chemicals
Chemicals listed by the North Carolina
Hazardous Chemical Right-To-Know Act
(HCRTKA)
North Carolina General Statutes, 95-173
North Carolina Building Code, Volume
5, Chapter 22
The HCRTKA mandates that all facilities, which may store anv
chemical equal to or greater than 55 gallons or 500 pounds
(whichever is greater), must develop a list of the hazardous substances
and report the information to the State. Tier I Chemical Inventory
reporting requirements apply to hazardous chemicals equal to or
greater than 55 gallons or 500 pounds (whichever is greater). The
local ^re chief may request facilities to prepare an Emergency
Response Plan. The public may submit written requests for MSDSs,
hazardous chemical classification, or chemical list from a covered
facility. Annual updates of hazardous substances list required,
changes to the list should be updated within 30 days of a changes,
such as chemical classification changes.
North Carolina
Department of
Environment, Health &_
Natural Resources
3800 Barrett Drive
Raleigh, NC 27609
(919) 733-3865
III
Federal Requirements Apply
Rhode Island General Laws 23-24.4-1,
28-21-1
Rhode Island's Tier II Chemical Inventory Form is required to meet
both Tier I and Tier II Chemical Inventory reporting requirements.
Facilities must also submit Form R reports to Rhode Island
Department of Environmental Management.
State of Rhode Island
Department of
Environmental
Management
291 Promenade Street
Providence, RI 02908-
5767
(401) 277-3872
TX
Federal Requirements Apply
Coverage extends to all manufacturing
facilities with Standard Industrial
Classification codes 20-29, public
employers, and non-manufacturing
facilities
Texas Health and Safety Code 505.001,
506.001,
507.001
25 Texas Administrative Code 295.181
Facility notification, notices of change, MSDSs submissions, and Tier
1 &. 11 Reports must include Texas Tier II Chemical Description
Sheet. Federal Tier II Chemical Inventory Form is accepted as an
alternative to the Texas Tier II Chemical Description Sheet. Tier II
filing fee required. The Texas Department of Health, Hazard
Communication Branch is designated at the State Emergency
Response Commission. Facilities filing Form R reports must also send
reports to the Texas Natural Resource Conservation Commission's
Office of Pollution Prevention.
Texas Natural Resource
Conservation Commission
12100 Park 35 Circle
Austin, TX 78711-3087
(512) 239-3100
(512) 239-0028
00
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Table 8-1
Summary of Selected State Emergency Planning and Notification Programs
State
Laws and Regulations
Notification, Planning and Reporting
State Contact(s)
VV1
Federal Requirements Apply
Wisconsin Statutes 166.20
State Emergency Response Board 1.01
One-time notification fee for covered facilities. Tier 11 Chemical
Inventory Form filing fee. Wisconsin requires that the Tier 11
Chemical Inventory Form meet the reporting standards for Tier I
Forms. The State Emergency Response Board (SERB) is the
designated State Emergency Response Commission (SERC). The
SERB receives all reports and notifications. Form R reports must be
submitted to both the SERB and the Office of Technical Services of
the Wisconsin Department of Natural Resources. Wisconsin requires
employers to consider all employees in the State when determining
number of employees when completing Form R reports.
Wisconsin Department of
Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, WI 53707
(608) 266-0531
(608) 266-4235
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APPENDIX 8-A
COMPLIANCE CALENDAR FOR EPCRA EMERGENCY PLANNING AND
NOTIFICATION REPORTING REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHAPTER 8 - EMERGENCY PLANNING AND NOTIFICATION
Milestone Events
Regular or Periodic Events
Oilier Events
Within 60 days of
equaling or exceeding
the TPQ for a listed
chemical
Notification
EPCRA
If a listed "extremely hazardous" chemical
becomes present at or above the TPQ, notify the
SERC. Also notify the LEPC and provide the
LEPC with name of your facility coordinator. You
need only provide this notification for the first
chemical.
SERC, LEPC
8-8 to 8-9
Immediately after
release of a hazardous
substance
Notification
EPCRA
Notify the SERC, the LEPC (or local emergency
response), and the National Response Center 1-
800-424-8802. Use form in Appendix 1 l-F to
record information they will need.
SERC, LEPC, NRC
8-11 to 8-12
As soon as possible
after release of a
hazardous substance
Written report
EPCRA
Provide written report on the release.
SERC, LEPC
8-12
Following any
changes relevant to
emergency planning
Notification
EPCRA
Notify LEPC of any changes occurring at the
facility that may be relevant to emergency planning
LEPC
8-9
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APPENDIX 8-B
WORKSHEET FOR EMERGENCY PLANNING AND NOTIFICATION
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Emergency Planning and Notification
Part I, Chapter 8
Worksheet for Emergency Planning and Notification — Record Information Here
Contact Name, Address, and Phone Number of the SERC in Your State:
Contact Name, Address, and Phone Number of the LEPC in Your Area:
List of Extremely Hazardous Substances at Your Facility at or Above the TPQ:
Name and Telephone Number of Your Facility Coordinator:
December 1996
8-B1
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Emergency Planning and Notification
Part I, Chapter 8
The following table is not part of the requirements, but may help you track your
notifications for any accidental releases that occur at your facility.
Date/Time of Accidental
Release
Date/Time of Initial
Notification
Date of Follow-up
Report(s)
December 1996
8-B2
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APPENDIX 8-C
STATE EMERGENCY RESPONSE COMMISSIONS1
1 This list is current as of June, 1996. Updated copies of the list can be obtained, bv calling EPA's EPCRA Hotline
at 1-800-535-0202.
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Emergency Planning and Notification
Part I, Chapter 8
APPENDIX 8-C
STATE EMERGENCY
ALABAMA
Paulette Williams, Chair
Alabama Emergency Response Commission
Alabama Emergency Management Agency
520 South Court Street
Montgomery, AL 36130
Phone: (334) 280-204
Note: Contact Dave White
John Smith, Director
Alabama Energy Response Commission
Alabama Department of
Environmental Management
1751 Congressman W.L. Dickinson Drive
Montgomery, AL 36109
Phone: (334) 271-7706
FAX: (334) 270-5612
Edward Poolos
Alabama Emergency Response Commission
Alabama Department of
Environmental Management
1751 Congressman W.L Dickinson Drive
Montgomery, AL 36109
Phone: (334) 260-2717
FAX: (334) 272-8131
24 HOUR EMERGENCY NUMBER:
In State: (800) 843-0699
Out of State: (334) 242-4378
Note: CERTIFIED MAIL
Edward Poolos
Alabama Department of
Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
Note: REGULAR MAIL ONLY
•ONSE COMMISSIONS
ALASKA
Brigadier General Kenneth Taylor, Jr.,
Acting Chair
Department of Military and Veteran Affairs
Division of Emergency Services
P.O. Box 5750
Fort Richardson, AK 99505-5750
Phone: (907) 428-7039
FAX: (907) 428-7009
Ervin Martin, Director
Department of Military and Veteran Affairs
Division of Emergency Services
P.O. Box 5750
Fort Richardson, AK 99505-5750
Phone: (907) 428-7039
FAX: (907) 428-7709
AMERICAN SAMOA
Faamausili Pola
Territorial Emergency Mgmt.
Coordinatin ^ Officer
(TEMCO)
American Samoan Government
Department of Public Safety
P.O. Box 1086
Pago Pago, AS 96799
Phone: (684) 633-1111
FAX: (684) 633-2300
24 HOUR EMERGENCY NUMBER:
(684) 633-1111
Goipa Tausaga
American Samoa Environmental
Protection Agency
Office of the Governor
Pago Pago, AS 96799
Phone: (684) 633-2304
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Emergency Planning and Notification
Part I, Chapter 8
ARIZONA
William D. Lockwood, Chairman
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
Daniel Roe, Executive Director
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, AZ 85008
Phone: (602) 231-6346
FAX: (602) 231-6313
24 HOUR EMERGENCY NUMBER:
(602) 257-2330
Note: FORM RS SHOULD BE MAILED HERE
AND ADDRESS BELOW
Arizona Department of Environmental Quality
Pollution Prevention Unit
3033 North Central Avenue
Phoenix, AZ 85012
Phone: (602) 207-4205
ARKANSAS
Randall Mathis, Chairman
State Emergency Response Commission
c/o AR Dept. of Pollution Control and Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
John Ward
State Emergency Response Commission
c/o AR Dept. of Pollution Control and Ecology
P.O. Box 8913
8001 National Drive
Litde Rock, AR 722 19-8913
Phone: (501) 562-7444
FAX: (501) 562-0297
24 HOUR EMERGENCY NUMBER:
In State: (501) 374-1201
Out of State: (800) 322-4012
Note: ALL REPORTS SHOULD BE MAILED
HERE
CALIFORNIA
Dr. Richard Andrews, Director
Chemical Emergency Planning and
Response Commission
Office of Emergency Services
Hazardous Materials Division
2800 Meadowview Road
Sacramento, CA 95832
David Zocchetti
Chemical Emergency Planning and
Response Commission
Office of Emergency Services
Hazardous Materials Division
2800 Meadowview Road
Sacramento, CA 95832
Phone: (916) 262-1750
24 HOUR EMERGENCY NUMBER:
In State: (800) 852-7550
Out of State: (916) 262-1621
Note: DAVID ZOCCHETTI IS ALSO FOR
STATE PROGRAMS
Stephen Hanna
California Environmental Protection Agency
555 Capitol Mall Suite 235
Sacramento, CA 95814
Phone: (916) 324-9924
FAX: (916) 322-6005
COLORADO
Steve Gunderson
Colorado Emergency Planning Commission
Colorado Department of Health
Mail Code OE-EMU-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
Phone: (303) 692-3022
FAX: (303) 782-4969
24 HOUR EMERGENCY NUMBER:
(303) 756-4455
December 1996
8-G2
-------
Emergency Planning and Notification
Part I, Chapter 8
CONNECTICUT
Gerald P. Coudreau, Chairman
State Emergency Response Commission
do Ulbrich Stainless Steels
1 Dudley Ave.
P.O. Box 610
Wallingford, CT 06492
Phone: (203) 269-2507
David Jorsey, SARA Title III Coordinator
Department of Environmental Protection
c/o Waste Management
79 Elm Street
Hartford, CT 06106-5127
Phone: (203) 424-3373
FAX: (203) 566-5255
24 HOUR EMERGENCY NUMBER:
(203) 566-3338 or (203) 424-3338
DELAWARE
Karen Johnson, Chair/Secretary
Delaware Department of Public Safety
P.O. Box 818
Dover, DE 19901
Phone: (302) 739-4321
FAX: (302) 834-7495
Joe Wessels, SARA Title III Coordinator
Delaware Emergency Management Agency
P.O. Box 527
Delaware City, DE 19706
Phone: (302) 834-4531
FAX: (302) 834-7495
Robert Pritchett, Program Manager
Division of Air and Waste Management
Dept. of Natural Resources and Environmental
Control
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
Phone: (302) 739-4791
FAX: (302) 739-3106
24 HOUR EMERGENCY NUMBER:
(800) 662-8802 In State
(302) 739-5072 Out of State
DISTRICT OF COLUMBIA
Mr. Samuel Jordan, Acting Director
Office of Emergency Preparedness
2000 14th Street, NW
Washington, DC 20009
Leslie Nesbitt, Environmental Planning
Specialist
Emergency Response Commission for Title III
Office of Emergency Preparedness
2000 14th Street, NW
8th Floor
Washington, DC 20009
Phone: (202) 673-2102 EXT. 3161
FAX: (202) 673-2290
24 HOUR EMERGENCY NUMBER:
(202) 727-6161
FLORIDA
Linda Lomis Shelley, Chair
Florida Department of Community Affairs
Division of Emergency Management
State Emergency Response Commission
2740 Centerview Drive
Tallahassee, FL 32399-2100
Phone: (901) 413-9970
Eve Rainey, Compliance Planning
Florida Department of Community Affairs
Division of Emergency Management
State Emergency Response Commission
2740 Centerview Drive
Tallahassee, FL 32399-2149
Phone: (904) 413-9970 OUT OF FLORIDA
(800) 635-7179 IN FLORIDA ONLY
FAX: (904) 488-1739
24 HOUR EMERGENCY NUMBER:
(904) 413-9911
GEORGIA
Joe Tanner, Chairman/Commissioner
Georgia Emergency Response Commission
205 Buder Street, S.E.
Suite 1252
Atlanta, GA 30334-4910
Phone: (404) 656-3500
December 1996
8-G3
-------
Emergency Planning and Notification
Part I, Chapter 8
Burt Langley, Chief
Georgia Emergency Response Commission
205 Butler Street, S.E.
Suite 1252
Atlanta, GA 30334
Phone: (404) 656-6905
FAX: (404) 651-9425
24 HOUR EMERGENCY NUMBER:
In State: (800) 241-41 13
Out of State: (404) 656-4863
GUAM
Dr. George Boughton, Chairman
Guam Emergency Response Commission
Civil Defense - Guam Emergency Services
Office
Government of Guam
P.O. Box 2877
Auguana, GU 96910
Phone: (671) 472-7230
550-7230 FTS ONLY
Fred M. Castro
Guam Environmental Protection Agency
D-107 Harmon Plaza
130 Rojas Street
Harmon, GU 96911
Phone: (671) 646-8863 or 8864
HAWAII
Lawrence Miike
Hawaii State Emergency Response Commission
Hawaii State Department of Health
1250 Punchbowl Street
Honolulu, HI 96813
Note: CERTIFIED MAIL ONLY
Marsha Mealey
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Blvd.
Honolulu, HI 96814
Phone: (808) 586-4249
FAX: (808) 586-7537
24 HOUR EMERGENCY NUMBER:
(808) 586-4249 Business Hours Only
(808) 247-2191 After Hours
Leslie Au
Hawaii State Emergency Response Commission
Hawaii Department of Health
919 Ala Moana Boulevard
Honolulu, HI 96814
Phone: (808) 586-4249
FAX: (808) 586-7537
Lawrence Miike
Hawaii State Emergency Response Commission
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801
Phone: (808) 586-4410
Note: REGULAR MAIL ONLY
IDAHO
Jack Peterson, Chairman
Idaho Emergency Response Commission
1109 Main Street
Owyhee Plaza
P.O. Box 83720
Boise, ID 83720-3401
Phone: (208) 334-3263
Margaret Ballard, Chief of Staff
Idaho Emergency Response Commission
1109 Main Street
Owyhee Plaza
P.O. Box 82720
Boise, ID 83720-3401
Phone: (208) 334-3263
FAX: (208) 334-3267
24 HOUR EMERGENCY NUMBER:
In State: (800) 632-8000
Out of State: (208) 334-4570
December 1995
8-G4
-------
Emergency Planning and Notification
Part I, Chapter 8
ILLINOIS
John Mitchell, Chair
State Emergency Response Commission
Illinois Emergency Management Agency
110 East Adams Street
Springfield, IL 62701-9963
Phone: (217) 782-2700
FAX: (217) 782-2589
Oran Robinson
Hazardous Materials Compliance
and Enforcement
State Emergency Response Commission
cjo Illinois Emergency Management Agency
110 East Adams Street
Springfield, IL 62706
Phone: (217) 782-4694
FAX: (217) 782-2589
24 HOUR EMERGENCY NUMBER:
(217) 782-7860 Out of State
(800) 782-7810 In State
Joe Goodner
Office of Chemical Safety
Illinois Environmental Protection Agency
P.O. Box 19276
2200 Churchill
Springfield, IL 62794-9276
Phone: (217) 785-0830
FAX: (217) 782-1431
INDIANA
Melvin Carraway, Chair
State Emergency Response Commission
Indiana Government Center South
302 West Washington Street, Room E208
Indianapolis, IN 46204
Phone: (317) 232-3986
John Rose, Staff Director
Indiana Department of
Environmental Management
100 North Senate Avenue (N-1255)
P.O. Box 7024
Indianapolis, IN 46207
Phone: (317) 233-6371
FAX: (317) 233-6358
24 HOUR EMERGENCY NUMBER:
(317) 233-7745
Tom Neltner
Indiana Department of
Environmental Management
Office of Pollution Prevention
Technical Assistance
100 North Senate Avenue (N-1355)
Box 6015
Indianapolis, IN 46206
Phone(317)233-8172
FAX: (317) 233-5627
IOWA
Mr. William Zitterich, P.E.
Iowa Emergency Response Commission
Iowa Department of Transportation
Maintenance Services Engineer
800 Lincoln Way
Ames, LA 50010
Phone: (515) 239-1396
Paul Sadler
Disaster Services Division
Hoover State Office Building
Des Moines, IA 50319
Phone: (515) 242-5171
FAX: (515) 281-7539
Pete Hamlin, Chief
Air Quality Bureau
Iowa Department of Natural Resources
Wallace Office Building
Des Moines, LA 50319
Phone: (515) 281-8852
FAX: (515) 281-8895
24 HOUR EMERGENCY NUMBER:
(515) 281-3561
Don Peddy
Iowa Division of Labor
1000 East Grand Avenue
Des Moines, IA50319
Phone: (515) 281-8460
FAX: (515) 281-6301
December 1996
8-G5
-------
Emergency Planning and Notification
Part I, Chapter 8
Mr. Walter Johnson, Vice Chair
Iowa Emergency Response Commission
Iowa Division of Labor
1000 East Grand Avenue
Des Moines, LA 50319
Phone: (515) 281-8460
FAX: (515) 242-4831
KANSAS
Bob Barid
General Motors
3201 Fairfax Traffic Way
Kansas City, KS 66115
Phone: (913) 573-7303
FAX: (913) 573-7862
Jon Flint
Kansas Right-to-Know Program
J Street and 2 North
Forbes Field
Building 283
Topeka, KS 66620
Phone: (913) 296-1690
FAX: (913) 296-1545
Frank Moussa
Kansas Division of Emergency Preparedness
State Defense Building
2800 South Topeka Avenue
Topeka, ICS 66611-1287
Phone: (913) 274-1409
FAX: (913) 274-1426
24 HOUR EMERGENCY NUMBER:
(913) 296-3176
KENTUCKY
Ron Padgett, Acting Chair
Kentucky Emergency Response Commission
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort, ICY 40601 -6168
Phone: (502) 566-8681
Major General Robert L. DeCam
Kentucky Emergency Response Commission
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort, KY 40601-6168
Phone: (502) 564-8558
24 HOUR EMERGENCY NUMBER:
(502) 564-7815
LOUISIANA
Capt. Mark S. Oxley, Chair
Louisiana Emergency Response Commission
Office of State Police
TESS
Right-to-Know Unit
P.O. Box 66614
7901 Independence Boulevard
Baton Rouge, LA 70896
Phone: (504) 925-6113
Robert Hayes
Louisiana Emergency Response Commission
Office of State Police
TESS
Right-to-Know Unit
P.O. Box 66614
Baton !louge, LA 70896
Phone: (504) 925-6113
24 HOUR EMERGENCY NUMBER:
(504) 925-6595
Linda Brown
Department of Environmental Quality
7290 Bluebonnet Boulevard
Baton Rouge, LA 70810
Phone: (504) 765-0720
FAX: (504) 765-0742
Note: CERTIFIED MAIL ONLY
Linda Brown
Department of Environmental Quality
Office of the Secretary
P.O. Box 82263
Baton Rouge, LA 70884-2263
Note: REGULAR MAIL ONLY
December 1996
8-G6
-------
Emergency Planning and Notification
Part I, Chapter 8
MAINE
David D. Brown, Chairman
State Emergency Response Commission
Station Number 72
Augusta, ME 04333
Phone: (207) 289-4080 OUT OF MAINE
(800) 452-8735 IN MAINE ONLY
Ravna Leibowitz
j
State Emergency Response Commission
Station Number 72
Augusta, ME 04333
Phone: (207) 287-4080
FAX: (207) 289-4079
24 HOUR EMERGENCY NUMBER:
(800) 452-4664
MARYLAND
David McMillian, Chairman
Governor's Emergency Management Advisory
Council
c/o Maryland Emergency Management Agency
2 Sudbrook Lane, East
Pikesville, MD 21208
Phone: (410) 486-4422
\ 5te: Contact JUNE L. SWEN
Lee Marshall
Maryland Department of the Environment
Hazardous Waste Program
2500 Broening Highway
Baltimore, MD 2 1224
Phone: (410) 631-3800
24 HOUR EMERGENCY NUMBER:
(410) 486-4422
Patricia Williams
Maryland Department of the Environment
Toxics Information Center
2500 Broening Highway
Baltimore, MD 21224.
Phone: (410) 631-3800
FAX: (410) 631-3321
MASSACHUSETTS
Kathleen OToole, Chair
Secretary of Public Safety
Massachusetts Emergency Response
Commission
Executive Office of Public Safety
One Ashburton Place, Room 2 133
Boston, MA 02 108
Phone: (617) 727-7725
Douglas Forbes
Massachusetts Emergency Management Agency
P.O. Box 1496
400 Worcester Road
Framingham, MA 01701-0317
Phone: (508) 820-2040
24 HOUR EMERGENCY NUMBER:
(508) 820-2000
Walter Hope or Susi Peck
Massachusetts Dept. of Environmental
Protection
Bureau of Waste Prevention
Toxics Use Reduction Program
1 Winter Street
Boston, MA 02108
Phone- (617) 292-5982
FAX: (617) 556-1090
MICHIGAN
Captain Robert Tarrant, Chair
State Emergency Response Commission
Emergency Management Division
300 South Washington Square, Suite 300
Lansing, MI 48913
Phone: (517) 334-5101
Bonnie Fighter, Title III Coordinator
State Emergency Response Commission
Michigan Department of Natural Resources
Environmental Assistance Division
300 South Washington Square
5th Floor
Lansing, MI 48913
Phone: (517) 334-5110
FAX: (517) 482-7914
December 1996
8-G7
-------
Emergency Planning and Notification
Part I, Chapter 8
24 HOUR EMERGENCY NUMBER:
In State: (800) 292-4706
Out of State: (517) 373-7660
Note: CERTIFIED MAIL ONLY
Robert Jackson
State Emergency Response Commission
Michigan Department of Natural Resources
P.O. Box 30457
Lansing, MI 48909
Phone (517) 373-2731
FAX (517) 334-5110
Note: REGULAR MAIL ONLY
MINNESOTA
David Senjem, Chair
State Emergency Response Commission
Mayo Clinic
Rochester, MN 55905
Phone: (507) 284-8890
Paul Aasen
Minnesota Emergency Response Commission
Room B-5
State Capitol Building
75 Constitution Avenue
St. Paul, MN 55155
Phone: (612) 282-5391
FAX: (612) 296-0459
24 HOUR EMERGENCY NUMBER:
In State: (800) 422-0798
Out of State: (612) 649-5451
Note: TDD (612) 297-5353
Steve Tomlyanovich
Minnesota Emergency Response Commission
Room B-5
State Capitol Building
75 Constitution Avenue
St Paul, MN 55155
Phone: (612) 282-5396
MISSISSIPPI
J.E. Maher, Chairman
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson, MS 39296-4501
Phone: (601) 960-9000
Note: REGULAR MAIL ONLY
John David Bums
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
1410 Riverside Drive
Jackson, MS 39202
Phone: (601) 960-9000
FAX: (601) 352-8314
24 HOUR EMERGENCY NUMBER:
(800) 222-6362
Note: CERTIFIED MAIL ONLY
MISSOURI
Bob Krauss, Coordinator
Missouri Department of Public Safety
Division of Fire Safety
P.O. Box 3133
1715 Industrial Drive
Jefferson City, MO 65102
Phone: (314) 751-2930
FAX: (314) 751-1744
Gene Nickel
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
Phone: (314) 526-6627
FAX: (314) 526-5808
24 HOUR EMERGENCY NUMBER:
(314) 634-2436
December 1996
8-G8
-------
Emergency Planning and Notification
Part I, Chapter 8
MONTANA
Bob Robinson, Co-Chairman
Montana Emergency Response Commission
ESD/DHES
Cogswell Building A-107
Capitol Station
P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-2544
FAX: (406) 444-1804
24 HOUR EMERGENCY NUMBER:
(406) 444-6911
Tom Ellerhoff, Co-Chairman
Montana Emergency Response Commission
ESD/DHES
Cogswell Building CI08
Capitol Station
P.O. Box 200901
Helena, MT 59620-0901
NEBRASKA
Major General Stanley M. Heng, Chairman
Nebraska Emergency Response Commission
1300 Military Road
Lincoln, NE 68508-1090
Phone: (402) 473-1100
John Steinhauer, Coordinator
Nebraska Department of Environmental
Quality
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
Phone: (402) 471-4251
FAX: (402) 471-2909
24 HOUR EMERGENCY NUMBER:
(402) 471-2186 Business Hours Only
(402) 471-4545 After Business Hours Only
Note: CERTIFIED MAIL ONLY
John Steinhauer, Coordinator
Nebraska Department of Environmental
Quality
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
Phone: (402) 471-4251
FAX: (402) 471-2909
Note: REGULAR MAIL ONLY
John Tracy
Nebraska Civil Defense
1300 Military Road
Lincoln, NE 68509-1090
Phone: (402) 471-7415
FAX: (402) 471-7433
NEVADA
Bill Owen, Executive Director
State Emergency Response Commission
555 Wright Way
Carson City, NV 89711-0900
Phone: (702) 687-6973
FAX: (702) 687-8798
Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
Phone: (702) 687-4240
24 HOUR EMERGENCY NUMBER:
(702) 687-5300
Gene Williams
Fire Marshall's Office
107 Jacobsen Drive
Capitol Complex
Carson City, NV 89710
Phone: (702) 687-4290
Colleen Cripps
Division of Emergency Management
2525 South Carson Street
Carson City, NV 89710
Phone: (702) 787-4670
FAX: (702) 885-0868
December 1996
8-G9
-------
Emergency Planning and Notification
Part I, Chapter 8
NEW HAMPSHIRE
George L. Iverson, Director
New Hampshire Office of
Emergency Management
Tide III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
Phone: (603) 271-2231
Leland Kimball
New Hampshire Office of
Emergency Management
Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
Phone: (603) 271-2231
FAX: (603) 225-7341
24 HOUR EMERGENCY NUMBER:
In State: (800) 346-4009
Out of State: (603) 271-3636
NEW JERSEY
Shirlee Schiffman, Chief
New Jersey Department of
Environmental Protection and Energy
Bureau of Hazardous Substances Information,
DES
Health and Analytical Programs
401 East State Street, CN 405
Trenton, NJ 08625
Phone: (609) 282-6714
Stan Delikat
Director of Responsible Party Site Remediation
Bureau of Emergency Response
401 East State Street
CN-028
Trenton, NJ 08625
Phone: (609) 633-2168
24 HOUR EMERGENCY NUMBER:
(609) 292-7172
Alan Bookman
NJ Dept. of Environmental Protection and
Energy
Bureau of Hazardous Substances Information
Division of Environmental Safety
Health and Analytical Programs
401 East State Street CN-405
Trenton, NJ 08625
Phone: (609) 984-5338
Andrew Opperman
NJ Dept. of Environmental Protection and
Energy
Bureau of Hazardous Substances Information
Division of Environmental Safety
Health and Analytical Programs
401 East State Street CN-405
Trenton, NJ 08625
Phone: (609) 633-1154
FAX: (609) 633-7031
Irene Trujillo, Chairman
New Mexico Emergency Response Commission
New Mexico Department of Public Safety
P.O. Box 1628
Sante Fe, NM 87504-1628
Phone: (506) 827-9223
Max Johnson
New Mexico Emergency Response Commission
Chemical Safety Office
Emergency Management Bureau
P.O. Box 1628
Santa Fe, NM 87504-1628
Phone: (505) 827-9223
FAX: (505) 827-3456
24 HOUR EMERGENCY NUMBER:
(505) 827-9126
Note: REGULAR MAIL ONLY
Max Johnson
New Mexico Emergency Response Commission
Chemical Safety Office
Emergency Management Bureau
4491 Cerrillos Road
Sante Fe, NM 87504
Note: CERTIFIED MAIL ONLY
December 1996
8-G10
-------
Emergency Planning and Notification
Part I, Chapter 8
NEW YORK
Major General Michael Hall, Vice Chairman
New York Emergency Response Commission
State Emergency Management Office
Building 22/State Campus
Albany, NY 12226-5000
Phone: (518) 457-2222
William Miner
New York Emergency Response Commission
c/o State Department of
Environmental Conservation
Bureau of Spill Prevention and Response
50 Wolf Road
Room 340
Albany. NY 12233-3510
Phone: (518) 457-4107
FAX: (518) 457-4332
24 HOUR EMERGENCY NUMBER:
In State: (800) 457-7362
Out of State: (518) 457-7362
NORTH CAROLINA
Billy Camaron, Chairman
North Carolina Emergency Response
Commission
North Carolina Division of
Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
Phone: (919) 733-3825
Emily Kilpatrick
North Carolina Emergency Response
Commission
North Carolina Division of
Emergency Management
1 16 West Jones Street
Raleigh, NC 27603-1335
Phone: (919) 733-3865
FAX: (919) 733-6327
24 HOUR EMERGENCY NUMBER:
(919) 733-3867
NORTH DAKOTA
Lyle Gallagher, Director of Communications
State Radio Communications Department
P.O. Box 5511
Bismarck, ND 58502
Phone:(701) 224-2121
24 HOUR EMERGENCY NUMBER:
In State: (800) 472-2121
Out of State: (701) 224-2121
Douglas C. Friez, Chairman
North Dakota State Division of
Emergency Management
P.O. Box 55 II
Bismarck, ND 58502-55II
Phone: (701) 328-3300
FAX: (701) 224-21 19
OHIO
Jane Harf, Chairman
State Emergency Response Commission
Ohio Environmental Protection Agency
Office of Emergency Response
1800 Watermark Dr.
Columbus, OH 43215-1099
Phone: (614^ 644-2260
Ken Shultz or Jeff Beattie
Ohio Emergency Response Commission
Ohio Environmental Protection Agency
Office of Emergency Response
1800 Watermark Dr.
Columbus, OH 43215-1099
Phone: (614) 644-2081 Shultz or Beattie
24 HOUR EMERGENCY NUMBER:
In State: (800) 282-9378
Out of State: (614) 224-0946
Cindy Dewulf
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
Phone: (614) 644-3604
FAX: (614) 644-3681
December 1996
8-G11
-------
Emergency Planning and Notification
Part I, Chapter 8
OKLAHOMA
Lawrence Gales or Monty Elder
Department of Environmental Quality
Support Services
1000 North East Tenth Street
Oklahoma City, OK 731 17-1212
Phone: (405) 271-8062 LAWRENCE GALES
(405) 271-7353 MONTY ELDER
FAX: (405) 271-7339
Lynne Moss
Department of Environmental Quality
1000 N.E. 10th Street
Oklahoma City, OK 73117-1212
Phone: (405) 271-8056
24 HOUR EMERGENCY NUMBER:
In State: (800) 522-0206
Out of State: (405) 271-4468
OREGON
Martha Pagel, Chair
Oregon Emergency Response Commission
do State Fire Marshall
4760 Portland Road, N.E.
Salem, OR 97306-1760
Phone: (503) 378-3473 EXT 347
Bob Albers
Oregon Emergency Response Commission
do State Fire Marshall
4760 Portland Road, N.E.
Salem, OR 97305-1760
Phone: (503) 378-3473 EXT. 262
FAX: (503) 373-1825
24 HOUR EMERGENCY NUMBER:
In State: (800) 452-0311
Out of State: (503) 378-6377
PENNSYLVANIA
Lt. Governor Mark S. Schvveiker, Chairman
Pennsylvania Emergency Management Council
P.O. Box 3321
Harrisburg, PA 17105-3321
Phone: (717) 783-8150
Robert F. Broyles, Chief
Chemical Emergency Preparedness Division
Pennsylvania Emergency Management Agency
P.O. Box 3321
Harrisburg, PA 17105-3321
Phone: (717) 783-8150
FAX: (717) 783-7393
24 HOUR EMERGENCY NUMBER:
(800) 424-7362 Out of State
(717) 783-8150 In State
James Tinney or Lynn Snead
Bureau of Worker and Community Right-to-
Know
Pennsylvania Department of Labor and
Industry
Room 1503
Labor and Industry Building
7th and Forster Streets
Harrisburg, PA 17120
Phone: (717) 783-2071 Tinney or Snead
FAX: (717) 783-8363
PUERTO RICO
Hector Russe Martinez, Chairman
Puertc Rico Emergency Response Commission
Environmental Quality Board
P.O. Box 11, Santurce, PR 00910
Phone: (809) 767-8056
Genaro Torres
Puerto Rico Emergency Response Commission
Environmental Quality Board
P.O. Box I 1488
Santurce, PR 00910
Phone: (809) 766-2823
FAX: (809) 766-2483
24 HOUR EMERGENCY NUMBER:
(809) 724-0.124
Note: REGULAR MAIL ONLY
December 1996
8-G12
-------
Emergency Planning and Notification
Part I, Chapter 8
Genaro Torres
Puerto Rico Emergency Response Commission
Environmental Quality Board
Banco National Plaza
43 1 Ponce De Leon Avenue
Hatorey, PR 0091 7
Note: CERTIFIED MAIL ONLY
RHODE ISLAND
Joseph Carnevale Jr., Director
Rhode Island Emergency Response Commission
State House Room 27
Providence, RI 02903
Phone: (401) 277-3039
John Aucott
Rhode Island Emergency Response Commission
State House Room 27
Providence, RI 02903
Phone: (401) 421-7333
24 HOUR EMERGENCY NUMBER:
(401) 274-7745
Patrice Carvaretta
Rhode Island Department of Labor
Di\is:.on of Occupational Safety
610 Manton Avenue
Providence, RI 02909
Phone:(401) 457-1829
Martha Delaney Mulcahey
Department of Environmental Management
Attn. Toxic Release Inventory
291 Promenade Street
Providence, RI 02908-5767
Phone: (401) 277-2808
FAX: (401) 277-2017
SOUTH CAROLINA
Stan M. McICinney, Chairman
South Carolina Emergency Response
Commission
c/o Emergency Preparedness Division
1429 Senate Street
Columbia, SC 29201
Phone: (803) 734-8020
Michael Juras
South Carolina State Emergency
Response Commission
EPCRA Reporting Point
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: (803) 896-41 17
FAX: (803) 935-6322
24 HOUR EMERGENCY NUMBER:
(803) 253-6488
Peter Saussy
South Carolina State Emergency
Response Commission
South Carolina Department of Health
and Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: (803) 896-4116
SOUTH DAKOTA
Lee Ann Smith, Title III Coordinator
South Dakota Emergency Response
Commission
Department of Environment and
Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
Phone: (605) 773-3296
FAX (605) 773-6035
24 HOUR EMERGENCY NUMBER:
(605) 773-3231
TENNESSEE
John White, Chairman
Tennessee Emergency Response Commission
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
Phone: (615) 741-0001
December 1996
8-G13
-------
Emergency Planning and Notification
Part I, Chapter 8
Beatty Eaves
Tennessee Emergency Response Commission
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville, TN 37204
Phone: (615) 741-2986
FAX: (615) 242-9635
24 HOUR EMERGENCY NUMBER:
In State: (800) 262-3300
Out of State: (800) 258-3300
TEXAS
James Wilson, Director
Texas Emergency Response Commission
Texas Department of Public Safety
P.O. Box 4087
Austin, TX 78773-0001
Phone: (512) 465-2138
Paula McKinney
Texas Department of Health
Hazard Communication Branch
1100 West 49th Street
Austin, TX 78756
Phone: (800) 452-2791 IN TEXAS ONLY
(512) 834-6603 OUT OF TEXAS ONLY
David Barker
Emergency Response Team
Texas Natural Resource
Conservation Commission
Room 241
P.O. Box 13087
Austin, TX 78711
Phone: (512) 463-7727
24 HOUR EMERGENCY NUMBER:
(512) 463-7727
David James, TRI Coordinator
Office of Pollution Prevention and Recycling
Texas Natural Resources
Conservation Commission
P.O. Box 13087
Austin, TX 78711-3087
Phone: (512) 239-3184
FAX: (512) 475-4599
Note: REGULAR MAIL ONLY
David James, TRI Coordinator
Office of Pollution Prevention and Recycling
Texas Natural Resources
Conservation Commission
Stephen P. Austin Building
1700 North Congress Avenue
Austin, TX 78701
Phone: (512) 239-3184
FAX: (512) 475-4599
Note: CERTIFIED MAIL ONLY
Tom Millwee, Co-Chair
Texas Emergency Response Commission
Division of Emergency Management
P.O. Box 4087
Austin, TX 78773-0001
Phone: (512) 465-2138
UTAH
Lorayne Frank, Director
Comprehensive Emergency Management
State Office Building
Room 1110
Salt Lake City, UT 84114
Phone: (801) 538-3400
Neil Taylor
Comprehensive Emergency Management
State Office Building
Room 1110
Salt.Lake City, UT 84114
Phone: (801) 536-4400
24 HOUR EMERGENCY NUMBER:
(.801) 536-4100 During Business Hours Only
(801) 536-4123 After Business Hours Only
John Jones
Utah Hazardous Chemical Emergency
Response Commission
Utah Department of Environmental Quality
Division of Environmental Response
and Remediation
168 North 1950 West
Salt Lake City, UT 841 14-4840
Phone: (801) 536-4100
FAX: (801) 359-8853
December 1996
8-G14
-------
Emergency Planning and Notifjcation
Part I, Chapter 8
VERMONT
Captain Robert Yandow, Chairman
Vermont Emergency Response Commission
Essex Police Department
81 Main Street
Essex Junction, VT 05452
Phone: (802) 878-8331
George Lowe, Secretary of the SERC Board
Department of Public Safety
103 South Main Street
Waterbury, VT 05676
Phone: (802) 244-8721
24 HOUR EMERGENCY NUMBER:
(800) 347-0488 Northeast States Only
(8023 641-5005 All Other States
Ray McCandless
Vermont State Health Department
108 Cherry Street
P.O. Box 70
Burlington, VT 05402
Phone: (802) 865-7730
FAX: (802) 865-7745
VIRGIN ISLANDS
Roy E. Adams, Commissioner
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response
Commission Tide III
Nisky Center
Suite 231
Charlotte Amalie
St. Thomas, VI 00802
Phone (809) 774-3320 EXT. 101 OR EXT. 102
Ben Nazario
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response
Commission Tide III
1118 Watergut Homes
Christiansted
St. Croix, VI 00820-5065
Phone: (809) 773-0565 ST. CROIX
(809) 774-3320 ST. THOMAS
FAX: (809) 773-9310 ST. CROIX
(809) 774-54 16 ST. THOMAS
VIRGINIA
Addison Slayton, Jr., Chair
Virginia Emergency Response Commission
Virginia Department of Emergency Services
310 Turner Road
Richmond, VA 23225
Cathy Harris
Virginia Emergency Response Council
do Virginia Department of Environmental
Quality
P.O. Box 10009
Richmond VA 23240-0009
Phone: (806) 762-4480 or 4489
FAX: (804) 371-0193
24 HOUR EMERGENCY NUMBER:
In State: (800) 468-8892
Out of State: (804) 674-2400
Note: REGULAR MAIL ONLY
Cathy Harris
Virginia Emergency Response Council
c/o Virginia Department of Environmental
Quality
9th Floor Mezzanine
629 East Main Street
Richmond VA 23219
Note: CERTIFIED MAIL ONLY
WASHINGTON
Mike Fitzgerald, Chair
Washington Emergency Response Commission
Department of Community Development
906 Columbia Street SW
P.O. Box 48300
Olympia, WA 98504-8300
Phone: (206) 753-7426
Idell Hansen
Department of Ecology
Community Right-to-ICnovv Unit
PiO. Box 47659
Olympia, WA 98504-7659
Phone: (206) 407-6727
FAX: (206) 407-6715
December 1996
8-G15
-------
Emergency Planning and Notification
Part I, Chapter 8
Betty Lochner
Washington State Emergency
Management Agency
P.O. Box 48346
Olympia, WA 98504-8346
Phone: (206) 923-4973
24 HOUR EMERGENCY NUMBER:
(800)258-5990
WEST VIRGINIA
Carl L. Bradford, Director
West Virginia Emergency Response
Commission
West Virginia Office of Emergency Services
Main Capitol Building
Room EB-80
Charleston, WV 25305-0360
Phone:. (304) 558-5380
FAX (304) 344-4538
24 HOUR EMERGENCY NUMBER:
(304) 558-5380
Russ Durot
Department of Natural Resources
P.O. Box 7921
101 South Webster
Madison, WI 53707
Phone: (608) 266-9255
FAX: (608) 267-3579
WYOMING
Guy Cameron, Chair
Cheyenne Fire Department
1806 East 19th Street
Cheyenne, WY 82003
Mike Davis/Bob Beck
Department of Environmental Quality
P.O. Box I 709
Cheyenne, WY 82003
Phone: (307) 777-4900
FAX: (307) 635-6017
24 HOUR EMERGENCY NUMBER:
(307) 777-4321
(307) 777-4900 Business Hours Only
WISCONSIN
Note: REGULAR MAIL ONLY
Leroy Conner, Chair
Stite Emergency Response Board Mike Davis/Bob Beck
Division of Emergency Government Department of Environmental Quality
P.O. Box 7865 5500 Bishop Blvd.
2400 Wright Street Cheyenne, WY 82007
Madison, WI 53707-7865
Phone: (608) 242-3232 Note: CERTIFIED MAIL ONLY
William Clare
State Emergency Response Board
2400 Wright Street
Madison, WI 53707-7865
Phone: (608) 242-3232
FAX: (608) 242-3247
24 HOUR EMERGENCY NUMBER:
(800) 943-0003
December 1996
8-G16
-------
APPENDIX 8-D
COMPLETE LIST OF EXTREMELY HAZARDOUS SUBSTANCES AND
THEIR THRESHOLD PLANNING QUANTITIES2
2 This list was updated and published in the May 7, 1996 issue of the Federal Register (Voume 61, Number 89.
Pages 20473-20490).
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
75-86-5
Acetone Cvanohvdrin
10
1,000
l 752-30-3
Acetone Thiosemicarbazide
e
1
1,000/10,000
107-02-8
Acrolein
1
500
79-06-1
Acrvfamide
d,l
5,000
1,000/10,000
107-13-1
Acrvlonitrile
d .1
100
10,000
814-68-6
Acrvlvl Chloride
[e).h
1
100
111-69-3
Adiponitrile
e.l
1
1,000
116-06-3
Aldicarb
c
1
100/10,000
309-00-2
AJdrin
d
1
500/10,000
107-18-6
Allvl Alcohol
100
1,000
107-11-9
Allvlamine
e
I
500
20859-73-8
Aluminum Phosphide
b
100
500
54-62-6
Aminopterin
e
1
500/10,000
78-53-5
Amiton
e
1
500
3734-97-2
Amiton Oxalate
e
1
100/10,000
7664-41-7
Ammonia
1
100
500
300-62-9
Amphetamine
e
1
1,000
62-53-3
Aniline
d, 1
5,000
1,000
88-05-1
Aniline, 2,4,6-Trimethyl-
e
1
500
7783-70-2
Antimony Pentafluoride
e
1
500
1397-94-0
Antimycin A
>:,e
1
1,000/10,000
86-88-4
ANTU
100
500/10,000
1303-28-2
Arsenic pentoxide
d
1
100/10,000
1327-53-3
Arsenous oxide
d.h
1
100/10,000
7784-34-1
Arsenous trichloride
d
1
500
7784-42-1
Arsine
e
1
100
2642-71-9
Azinphos-Ethvl
e
1
100/10,000
86-50-0
Azinphos-Methvl
1
10/10,000
98-87-3
Benzal Chloride
d
5,000
500
98-16-8
Benzenamine, 3- (Trifluoromethvl)-
e
I
500
100-14-1
Benzene, 1-(Chloromethvl)- 4-Nitro-
e
1
500/10,000
98-05-5
Benzenearsonic Acid
e
1
10/10,000
3615-21-22
Benzimidazole, 4,5- Dichloro-2-
(Trifluoromethvl)-
e'§
1
500/10,000
98-07-7
Benzotrichloride
d
10
500
100-44-7
Benzvl Chloride
d
100
500
140-29-4
Benzvl Cvanide
e,h
1
500
15271-41-77
Bicvclo[221 ]Heptane-2-Carbonitrile,
5-Chloro-6-((((Methylamino)Carbonvl
)Oxv)lmino)-.( ls-( 1 -alpha, 2-beta, 4-aJpha,
5-alpha. 6E))-
e
1
500/10,000
December 1996
8-G1
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
534-07-6
Bis(Chloromethvl) Ketone
e
1
10/10.000
4044-65-9
Bitoscanate
e
I
500/10.000
10294-34-5
Boron Trichloride
e
1
500
7637-07-2
Boron Trifluoride
e
1
500
353-42-4
Boron Trifluoride Compound With Methyl Ether
(1:1)
e
1
1,000
28772-56-7
Bromadiolone
e
I
100/10.000
7726-95-6
Bromine
e,l
1
500
1306-19-0
Cadmium Oxide
e
100/10,000
2223-93-0
Cadmium Stearate
c.e
1
1,000/10,000
7778-44-1
Calcium arsenate
d
1
500/10,000
8001-35-2
Camphechlor
d
1
500/10,000
56-25-7
Cantharidin
e
1
100/10,000
51-83-2
Carbachol Chloride
e
1
500/10,000
26419-73-88
Carbamic Acid,
Methyl-,0-( ((2,4-Dimethyl-l,3-Dithiolan-2-yl)M
ethylene)Amino)-
e
1
100/10,000
1563-66-2
Carbofuran
10
10/10,000
75-15-0
Carbon Disulfide
1
100
10,000
786-19-6
Carbophenothion
e
1
500
57-74-9
Chlordane
d
1
1,000
470-90-6
Chlorfenvinfos
e
1
500
7782-50-5
Chlorine
10
100
24934-91-6
Chlormephos
e
1
500
999-81-5
Chlormequat Chloride
e.h
1
100/10,000
79-11-8
Chloroacetic Acid
e
1
100/10.000
107-07-3
Chloroethanol
e
1
500
627-11-2
Chloroethvl Chloroformate
e
I
1,000
67-66-3
Chloroform
d, 1
10
10,000
542-88-1
Chloromethyl ether
d.h
10
100
107-30-2
Chloromethyl methyl ether
e,d
10
100
3691-35-8
Chlorophacinone
e
1
100/10,000
1982-47-4
Chloroxuron
e
1
500/10,000
21923-23-9
Chlorthiophos
e,h
1
500
10025-73-7
Chromic Chloride
e
1
1/10,000
62207-76-55
Cobalt, ((2,2'-{ 1,2-e Ethanediylbis
(Nitrilomeihylidyne))Bis
(6-Fluorophenolato))(2-)- N.N'.O.O')-,
110
0/10,000
10210-68-1
Cobalt Carbonvl
e.h
1
10/10,000
64-86-8
Colchicine
e,h
1
10/10,000
56-72-4
Coumaphos
10
100/10.000
December 1996
8-G2
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
5836-29-3
Coumatetralvl
e
1
500/10,000
95-48-7
Cresol, o-
d
1,000
1,000/10,000
535-89-7
Crimidine
e
1
100/10.000
4170-30-3
Crotonaldehvde
100
1.000
123-73-9
Crotonaldehvde, (E)-
100
1.000
506-68-3
Cvanogen Bromide
1,000
500/10,000
506-78-5
Cvanogen Iodide
e
1
1,000/10,000
2636-26-2
Cvanophos
e
1
1,000
675-14-9
Cvanuric Fluoride
e
1
100
66-81-9
Cvcloheximide
e
100/10,000
108-91-8
Cvclohexvlamine
e,l
1
10.000
17702-41-9
Decaborane( 14)
e
1
500/10,000
8065-48-3
Demeton
e
1
500
919-86-8
Demeton-S-Methyl
e
1
500
10311-84-9
Dialifor
e
1100/10,000
19287-45-7
Diborane
e
1
100
111-44-4
Dichloroethyl ether
d
10
10,000
149-74-6
Dichloromethylphenylsilan e
e
1
1,000
62-73-7
Dichlorvos
10
1,000
141-66-2
Dicrotophos
e
1
100
1464-53-5
Diepoxvbutane
d
10
500
814-49-3
Diethyl Chlorophospate
e,h
1
500
1642-54-22
Diethvlcarbamazine Citrate
e
1
100/10,000
71-63-6
Digitoxin
c,e
1
100/10,000
2238-07-5
Diglvcidvl Ether
e
1
1,000
20830-75-5
Digoxin
e,h
1
10/10,000
115-26-4
Dimefox
e
1
500
60-51-5
Dimethoate
10
500/10,000
2524-03-00
Dimethyl Phosphorochloridothioa
e
1
500
77-78-1
Dimethvl sulfate
d
100
500
75-78-5
Dimethyldichlorosilane
e,h
1
500
57-14-7
Dimethvlhydrazine
d
10
1,000
99-98-9
Dimethvl-p- Phenylenediamine
e
1
10/10,000
644-64-4
Dimetilan
e
1
500/10,000
534-52-1
Dinitrocresol
10
10/10,000
88-85-7
Dinoseb
1,000
100/10,000
1420-07-1
Dinoterb
e
I
500/10,000
78-34-2
Dioxathion
e
1
500
82-66-6
Diphacinone
e
1
10/10,000
152-16-9
Diphosphoramide, Octamethvl-
100
100
December 1996
8-G3
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(ibs)
Threshold
Planning
Quantity (lbs)
298-04-4
Disulfoton
1
500
514-73-8
Dithiazanine Iodide
e
1
500/10.000
541-53-7
Dithiobiuret
100
100/10,000
316-42-7
Emetine, Dihvdrochloride
e.h
I
1/10.000
115-29-7
Endosulfan
1
10/10,000
2778-04-3
Endothion
e
I
500/10.000
72-20-8
Endrin
1
500/10.000
106-89-8
Epichiorohvdrin
d, 1
100
1,000
2104-64-5
EPN
e
1
100/10,000
50-14-6
ErgocaJciferol
c,e
1.000/10.000
379-79-3
Ergotamine Tartrate
e
1
500/10,000
1622-32-88
Ethanesulfonvl Chloride, 2-Chloro-
e
1
500
10140-87-11
Ethanol, 12-Dichloro-, Acetate
e
1
1,000
563-12-2
Ethion
10
1,000
13194-48-4
Ethoprophos
e
1
1,000
538-07-8
Ethvlbis(2- Chloroethyl)Amine
e,h
1
500
371-62-0
Ethylene Fluorohydrin
c,e,h
1
10
75-21-8
Ethylene oxide
d.I
10
1,000
107-15-3
Ethvlenediamine
5,000
10,000
151-56-4
Ethyleneimine
d
1
500
542-90-5
Ethylthiocv mate
e
1
10,000
22224-92-6
Fenamiphos
e
1
10/10,000
122-14-5
Fenitrothion
e
1
500
115-90-2
Fensulfothion
e,h
1
500
4301-50-2
Fluenetil
e
1
100/10.000
7782-41-4
Fluorine
k
10
500
640-19-7
Fluoroacetamide
i
100
100/10.000
144-49-0
Fluoroacetic Acid
e
1
10/10.000
359-06-8
Fluoroacetyi Chloride
c.e
1
10
51-21-8
Fluorouracil
e
1
500/10.000
944-22-9
Fonofos
e
1
500
50-00-0
Formaldehyde
d.I
100
500
107-16-4
Formaldehyde Cvanohvdrin
e.h
1
1,000
23422-53-9
Formetanate Hydrochloride
e,h
1
500/10,000
2540-82-1
Formothion
e
1
100
17702-57-7
Formparanate
e
1
100/10,000
21548-32-3
Fosthietan
e
1
500
3878-19-1
Fuberidazole
e
1
100/10,000
110-00-9
Furan
100
500
13450-90-3
Gallium Trichloride
e
I
500/10.000
December 1996
8-G4
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(ibs)
Threshold
Planning
Quantity (Ibs)
77-47-4
Hexachlorocvclopentadiene
d.h
10
100
4835-1 1-44
Hexamethvlenediamine, N.N'-Dibutvl-
e
1
500
302-01-2
Hvdrazine
d
I
1,000
74-90-8
Hvdrocvanic Acid
10
100
7647-01-00
Hvdrogen chloride (gas onlv)
e,l
5,000
500
7664-39-3
Hvdrogen Fluoride
100
100
7722-84-11
Hvdrogen Peroxide (Cone >52%)
e.l
1
1,000
7783-07-5
Hvdrogen Selenide
e
1
10
7783-06-4
Hvdrogen Sulfide
1
100
500
123-31-9
Hvdroquinone
1
1
500/10,000
13463-40-6
Iron, Pentacarbonvl-
e
1
100
297-78-9
Isobenzan
e
1
100/10,000
78-82-0
Isobutvronitrile
e,h
I
1,000
102-36-3
Isocvanic Acid, 3,4- Dichlorophenvl Ester
e
I
500/10,000
465-73-6
Isodrin
1
100/10,000
55-91-4
Isofluorphate
c
100
100
4098-71-9
Isophorone Diisocyanate
b.e
1
100
108-23-6
Isopropyl Chloroformate
e
1
1,000
119-38-0
Isoproplvmethvlpvrazolvl Dimethvlcarbamate
e
1
.500
78-97-7
Lactonitrile
e
1
1,000
21609-90-5
Leptopi js
e
1
500/10,000
541-25-3
Lewisite
c,e,h
1
10
58-89-9
Lindane
d
1
1,000/10,000
7580-67-8
Lithium Hydride
b,e
1
100
109-77-3
Malononitrile
1,000
500/10,000
12108-13-33
Manganese, Tricarbonyl Methylcvclopentadienvl
e,h
1
100
51-75-2
Mechloreth amine
c,e
1
10
950-10-7
Mephosfolan
e
1
500
1600-27-7
Mercuric Acetate
e
1
500/10,000
7487-94-7
Mercuric Chloride
e
1
500/10,000
21908-53-2
Mercuric Oxide
e
1
500/10,000
10476-95-6
Methacrolein Diacetate
e
1
1,000
760-93-0
Methacrvlic Anhvdride
e
1
500
126-98-7
Methacrvlonitrile
h
1,000
500
920-46-7
Methacrvlovl Chloride
e
1
100
30674-80-77
Methacrvlovloxvethvl Isocvanate
e,h
1
100
10265-92-6
Methamidophos
e
1
100/10,000
558-25-8
Methanesulfonvl Fluoride
e
1
1,000
950-37-8
Methidathion
e
1
500/10.000
2032-65-7
Methiocarb
10
500/10.000
December 1996
8-G5
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
16752-77-5
Methomvl
h
100
500/10,000
151-38-2
Methoxvethvlmercuric Acetate
e
I
500/10,000
80-63-7
Methvl 2-Chloroacrvlate
e
1
500
74-83-9
Methvl Bromide
1
1,000
1,000
79-22-1
Methvl Chloroformate
d,h
1,000
500
60-34-4
Methvl Hydrazine
10
500
624-83-9
Methyl Isocyanate
10
500
556-61-6
Methyl Isothiocvanate
b,e
1
500
74-93-1
Methyl Mercaptan
1
100
! 500
3735-23-7
Methyl Phenkapton
e
1
500
676-97-1
Methvl Phosphonic Dichloride
b,e
1
100
556-64-9
Methvl Thiocyanate
e
1
10,000
78-94-4
Methvl Vinvl Ketone
e
1
10
502-39-6
Methvfmercuric Dicv an amide
e
1
500/10,000
75-79-6
Methyluichlorosilane
e,h
1
500
1129-41-5
Metolcarb
e
1
100/10,000
7786-34-7
Mevinphos
10
500
315-18-4
Mexacarbate
1,000
500/10,000
50-07-7
Mitomycin C
d
10
500/10,000
6923-22-4
Monocrotophos
e
1
10/10,000
2763-94-4
Muscimol
1,000
500/10,000
505-60-2
Mustard Gas
e,h
1
500
13463-39-3
Nickel carbonyl
d
10
1
54-11-5
Nicotine
c
100
100
65-30-5
Nicotine sulfate
e
100
100/10,000
7697-37-2
Nitric Acid
1,000
1,000
10102-43-9
Nitric Oxide
c
10
100
98-95-3
Nitrobenzene
1
1,000
10,000
1122-60-7
Nitrocvclohexane
e
1
500
10102-44-0
Nitrogen Dioxide
10
100
62-75-9
Nitrosodimethvlamine
d,h
10
1,000
991-42-40
Norbormide Organorhodium Complex
(PMN-82-147)
e
1
100/10,000
630-60-4
Ouabain
c,e
1
100/10,000
23135-22-0
Oxamvl
e
1
100/10,000
78-71-7
Oxetane, 3,3-1
e
500
2497-07-6
Orvdisulfoton
e,h
1
500
10028-15-6
Ozone
e
1
100
1910-42-5
Paraquat
e
1
10/10,000
2074-50-2
Paraquat Methosulfate
e
1
10/10,000
December 1996
8*G6
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
56-38-2
Parathion
c.d
10
100
298-00-0
Parathion-Methvl
c
100
100/10,000
12002-03-8
Paris Green
d
1
500/10,000
19624-22-7
Pentaborane
e
1
500
2570-26-5
Pentadecvlamine
e
1
100/10,000
79-21-0
Peracetic Acid
e
1
500
594-42-3
Perchloromethvlmercaptan
100
500
108-95-2
Phenol
1,000
500/10,000
4418-66-00
Phenol, 2,2'- Thiobis(4-Chloro-6- Methyl)-
e
1
100/10,000
64-00-6
Phenol, 3-(l-Methylethyl)-, Methvlcarbamate
e
1 1
500/10,000
58-36-6
Phenoxarsine, 10, lO'-Oxydi-
e
1
500/10,000
696-28-6
Phenyl Dichloroarsine
d,h
1
500
59-88-1
Phenvlhydrazine Hydrochloride
e
I
1,000/10.000
62-38-4
Phenylmercury Acetate
100
500/10,00.0
2097-19-0
Phenylsiiatrane
e,h
1
100/10,000
103-85-5
Phenylthiourma
108
100/10,000
298-02-2
Phorate
10
10
4104-14-7
Phosacetim
e
1
100/10,000
947-02-4
Phosfolan
e
1
100/10,000
75-44-5
Phosgene
1
10
10
732-11-6
Phosmec
e
1
10/10,000
13171-21-6
Phosphamidon
e
1
100
7803-51-2
Phosphine
100
500
2703-13-11
Phosphonothioic Acid, Methyl-, O-Ethyl 0-(4-
(Methylthio)Phenyl) Ester
e
1
500
50782-69-99
Phosphonothioic Acid,
Methyl-,S-(2-(Bis( l-Methylethyl)Amino) Ethyl
O-Ethvl Ester
e
1
100
2665-30-77
Phosphonothioic Acid, Methyl-, 0-(4-
Nitrophenyl) O-Phenvl Ester
e
1
500
3254-63-55
Phosphoric Acid, Dimethyl 4-(Methylthio)
Phenvl Ester
e
1
500
2587-90-88
Phosphorothioic Acid, 0,0- Dimethyl-S-(2-
Methvlthio) Ethvl Ester
c.e.g
1
500
7723-14-0
Phosphorus
b.h
1
100
10025-87-3
Phosphorus Oxvchloride
d
1,000
500
10026-13-8
Phosphorus Pentachloride
b,e
1
500
1314-56-3
Phosphorus Pentoxide
b,e
1
10
7719-12-2
Phosphorus Trichloride
1,000
1,000
57-47-6
Phvsostigmine
e
1
100/10,000
57-64-7
Phvsostirmine. Salicylate (1:1)
e
1 [ 100/10.000 1
December 1996
8-G7
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
124-87-8
Picrotoxin
e
1
500/10,000
110-89-4
Piperidine
e
1
1,000
23505-41-1
Pirimifos-Ethvl
e
1
1,000
10124-50-2
Potassium arsenite
d
1
500/10,000
151-50-8
Potassium Cvanide
b
10
100
506-61-6
Potassium Silver Cyanide
b
1
500
2631-37-0
Promecarb
e,h
1
500/10,000
106-96-7
Propargyl Bromide
e
I
10
57-57-8
Propiolactone, Beta-
e
1
500
107-12-0
Propionitrile
10
500
542-76-7
Propionitrile, 3-Chloro-
1,000
1,000
70-69-9
Propiophenone, 4-Amino-
e.J?
1
100/10,000
109-61-5
Propvl Chloroformate
e
1
500
75-56-9
Propylene Oxide
1
100
10,000
75-55-8
Propyleneimine
d
1
10,000
2275-18-5
Prothoate
e
1
100/10,000
129-00-0
Pyrene
c
5,000
1,000/10,000
140-76-1
Pyridine, 2-Methyl-5- Vinvl-
e
1
500
504-24-5
Pvridine, 4-Amino-
h
1,000
500/10,000
1124-33-00
Pvridine. 4-Nitro-, 1- Oxide
e
1
500/10,000
53558-25-1
Pyriminil
e,h
1
100/10,000
14167-18-1
Salcomine
e
i
500/10,000
107-44-8
Sarin
e,h
1
10
7783-00-8
Selenious Acid
10
1,000/10,000
7791-23-3
Selenium Oxychloride
e
1
500
563-41-7
Semicarbazide Hydrochloride
e
1
1,000/10,000
3037-72-77
Silane, (4- Aminobutyl)Diethoxymethv 1-
e
1
1,000
7631-89-2
Sodium Arsenate
d
1,000
1,000/10,000
7784-46-5
Sodium arsenite
d
1
500/10,000
26628-22-8
Sodium Azide (Na(N3))
b
1,000
500
124-65-2
Sodium Cacodylate
e
1
100/10,000
143-33-9
Sodium Cyanide (Na(CN))
b
10
100
62-74-8
Sodium Fluoroacetate
10
10/10,000
13410-01-0
Sodium Selenate
e
1
100/10,000
10102-18-8
Sodium Selenite
h
100
100/10,000
10102-20-2
Sodium Tellurite
e
1
500/10,000
900-95-8
Stannane. Acetoxvtriphenvl-
e.K
1
500/10,000
57-24-9
Strvchnine
c
10
100/10,000
60-41-3
Strvchnine sulfate
e
10
100/10,000
3689-24-5
Sulfotep
100
500
December 1996
8-G8
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
3569-57-11
Sulfoxide, 3-Chloropropvl Octvl
e
1
500
7446-09-5
Sulfur Dioxide
e,l
1
500
7783-60-0
Sulfur Tetrafluoride
e
1
100
7446-11-9
Sulfur Trioxide
b,e
1
100
7664-93-9
Sulfuric Acid
1,000
1,000
77-81-6
Tabun
c.e.h
1
10
13494-80-9
Tellurium
e
1
500/10,000
7783-80-4
Tellurium Hexafluoride
e.k
1
100
107-49-3
TEPP
10
100
13071-79-9
Terbufos
e.h
1
100
78-00-2
Tetraethvllead
c,d
10
100
597-64-8
Tetraethvltin
c,e
1
100
75-74-1
Tetramethyllead
c,e,l
I
1,00
509-14-8
Tetranitromethane
10
500
10031-59-1
Thallium Sulfate
h
100
100/10,000
6533-73-9
Thallous Carbonate
c.h
100
100/10,000
7791-12-0
Thallous Chloride
c,h
100
100/10,000
2757-18-8
Thallous Malonate
c,e,h
1
100/10,000
7446-18-6
Thallous Sulfate
100
100/10,000
2231-57-4
Thiocarbazide
e
1
1,000/10,000
39196-18-4
Thiofanox
100
100/10,000
297-97-2
Thionazin
100
500
108-98-5
Thiophenol
100
500
79-19-6
Thiosemicarbazide
100
100/10,000
5344-82-11
Thiourea, (2- Chlorophenyl)-
100
100/10,000
614-78-8
Thiourea, (2- Methylphenyl)-
e
1
500/10,000
7550-45-0
Titanium Tetrachloride
e
1
100
584-84-9
Toluene 2,4-Diisocyanate
100
500
91-08-7
Toluene 2,6-Diisocvanate
100
100
1 10-57-6
Trans-1,4-Dichlorobutene
e
1
500
1031-47-6
Triamiphos
e
1
500/10,000
24017-47-8
Triazofos
e
1
500
76-02-8
Trichloroacety Chloride
e
1
500
115-21-9
Trichloroethylsilane
e,h
1
500
327-98-0
Trichloronate
e.k
1
500
98-13-5
T richlorophenvlsilane
e,h
1
500
1558-25-44
Trichloro(Chloromethyl)Si lane
e
I
100
27137-85-55
Trichloro(Dichlorophenyl) Silane
e
1
500
998-30-1
Triethoxvsilane
e
1
500
75-77-4
Trimethvlchlorosilane
e
1
1,000
December 1996
8-G9
-------
Emergency Planning and Notification
Part I, Chapter 8
Complete List of Extremely Hazardous Substances and Their Threshold Planning
Quantities
CAS No.
Chemical Name
Notes
Reportable
Quantity*
(lbs)
Threshold
Planning
Quantity (lbs)
824-1 1-3
Trimethvlolpropane Phosphite
e,h
1
100/10,000
1066-45-1
Trimethvltin Chloride
e
I
500/10,000
639-58-7
Triphenvltin Chloride
e
1
500/10,000
555-77-1
Tris(2-Chloroethvl) Amine
e,h
1
100
2001-95-8
Valinomvcin
c,e
1
1,000/10,000
1314-62-1
Vanadium Pentoxide
1,000
100/10,000
108-05-4
Vinvl Acetate Monomer
d,l
5,000
' 1,000
81-81-2
Warfarin
100
500/10,000
129-06-6
Warfarin sodium
e,h
100
100/10,000
28347-13-9
Xvlvlene Dichloride
e
I
100/10,000
58270-08-99
Zinc, DichIoro(4,4- Dimethyl-
5((((Methylamino) Carbonyl)Oxy)Imino)Penta
nenitrile)-,(T-4)-
e
1
100/10,000
1314-84-7
Zinc Phosphide
b
100
500
'Only the statutory or final RQ is shown. For more information, see 40 CFR Table 302.4.
Notes:
[a] This chemical does not meet acute toxicity criteria. Its TPQ is set at 10,000 lbs..
[b] This material is a reactive solid. The TPQ does not default to 10,000 lbs for nonpowder, nonmolten,
nonsolution form.
[c] The calculated TPQ changed after technical review as described in t' e technical support document.
[d] Indicates that the RQ is subject to change when the assessment of potential carcinogenicity and/or other
toxicity is completed.
[e] Statutory reportable quantity for purposes of notification under SARA sect 304(a)(2).
[f] [Reserved]
[g] New chemicals added that were not part of the original list of 402 substances.
[h] Revised TPQ based on new or re-evaluated toxicity data.
[j] TPQ is revised to its calculated value and does not change due to technical review as in proposed rule.
[k] The TPQ was revised after proposal due to calculation error.
[1] Chemicals on the original list that do not meet the toxicity criteria but because of their high production volume
and recognized toxicity are considered chemicals of concern ("Other chemicals").
December 1996
8-G10
-------
APPENDIX 8-E
ADDITIONAL CHEMICALS TYPICALLY USED
BY METAL FINISHERS THAT ARE SUBJECT TO EMERGENCY
NOTIFICATION REQUIREMENTS
-------
Emergency Planning and Notification
Part I, Chapter 8
Additional Chemicals Typically Used
Emergency Notification Requirements
CAS No.
Chemical
57125
Cyanides (soluble salts and
complexes) not otherwise
specified
54197
Acetic acid
67641
Acetone
71432
Benzene
71558
Ethane, 1,1,1-trichloro-
(Methyl chloroform)
(1,1,1 -T richloropentane)
74873
Methane, chloro-
74908
Hydrocyanic acid
75092
Methane, dichloro-
(Methylene chloride)
78831
Isobutyl alcohol
1-Propanol, 2-methyl
78933
Methyl ethyl ketone
(MEK)
2-Butanone
143339
Sodium cyanide
151508
Potassium cyanide
506849
Silver cyanide
544923
Copper cyanide
557211
Zinc cyar:de
1310583
Potassium hydroxide
1310732
Sodium hydroxide
1314870
Lead sulfide
7439921
Lead
7440020
Nickel
7440224
Silver
7440235
Sodium
7440350
Antimonv
Source: 40 CFR Part 302.4.
by Metal Finishers That Are Subject to
CAS No. Chemical
7440417
Beryllium
Beryllium dust
7440439
Cadmium
7440473
Chromium
7440508
Copper
7440606
Zinc
7646957
Zinc chloride
7647910
Hydrochloric acid
(Hydrogen chloride)
(Muriatic acid)
664393
Hydrofluoric acid
(Hydrogen fluoride)
7664382
Phosphoric acid
7664417
Ammonia
7664939
Sulfuric acid
7661529
Sodium hypochlorite
7697372
Nitric acid
7718549
Nickel chloride
7723140
Phosphorus
7733020
Zinc sulfate
7738945
Chromic acid
7782505
Chlorine
7783064
Hydrogen sulfide
7788814
Nickel sulfate
8014957
Sulfuric acid
10022705
Sodium hypochlorite
11115745
Chromic acid
12054487
Nickel hydroxide
13463393
Nickel carbonyl
37211056
Nickel chloride
December 1996
8-G1
-------
APPENDIX 8-F
SAMPLE FORM FOR RECORDING INFORMATION TO BE REPORTED
IN THE EVENT OF A RELEASE OF A HAZARDOUS SUBSTANCE
This Appendix contains a sample completed form for a hypothetical situation in which a hazardous chemical
is released, plus a blank form that can be used to record and report information in the event of a release at
your facility.
-------
Emergency Planning and Notification
Part I, Chapter 8
Sample Completed Form
Name of Chemical
Location of Release
Is Chemical an EHS?
Amount of Substance Released
Date, Time, Duration of Incident
Sodium cyanide
Imperial Plating, Inc.
123 Anywhere Street, Chicago IL
- release occured at loading dock at SE Pleasant St. entrance
Yes
approx. 10 gallons
April 4, 1996 at 3:17 p.m.
Release was stopped within 2 minutes.
Description of Release Truck was at loading dock unloading two 55-gallon drums
of sodium syanide solution. While transferring the second
drum, the transfer hose broke, causing approximately 15
gallons to spill onto the loading ramp underneath the truck.
Of this amount, approximately 10 gallons escaped to the
storm sewer, while the remainder was recovered using
sorbent.
Media Affected (air, water, soil)
Known or Anticipated Health Risks
Proper Precautions
Contact Person
Water
Mr. Bruce Glenn (312) 555-5555 ext. 123
December 1996
8-G1
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Emergency Planning and Notification
Part I, Chapter 8
Sample Blank Form
Name of Chemical
Location of Release
Is Chemical an EHS?
Amount of Substance Released
Date, Time, Duration of Incident
Description of Release
Media Affected (air, water, soil)
Known or Anticipated Health Risks
Proper Precautions
Contact Person
December 1996
8-G2
-------
Notes
9
-------
CHAPTER 9
Toxic Substances Control
9.1 Federal Programs (TSCA) 9-3
9.1.1 What Is TSCA? 9-3
9.1.2 Information Gathering Requirements 9-3
9.1.3 Regulatory Controls 9-3
9.2 Where To Go for More Information 9-1 I
9.3 References 9-12
Under the Toxic Substances Control Act (TSCA) EPA is authorized to
control risks from chemicals during their manufacture, processing,
distribution, use, or disposal. Many of EPA's TSCA-related requirements do
not apply directly to metal finishers, so this chapter focuses specifically on
those that may be applicable. It identifies TSCA-regulated chemicals and
products that you might have at your facility, and explains your obligations
under federal laws.
December 1996
9-1
-------
Toxic Substances Control Part I, Chapter 9
9.1 Federal Programs (TSCA) 9-3
9.1.1 What Is TSCA? 9-3
9.1.2 Information Gathering Requirements 9-3
9.1.3 Requirements Related to Regulatory Controls 9-3
9.1.3.1 What PCB Regulations Might Apply to Me? 9-5
9.1.3.2 What Asbestos Regulations Might Apply to Me? 9-9
9.1.3.3 What Lead Regulations Might Apply to Me? 9-10
9.1.3.4 What Metahvorking Fluid Regulations Might Apply to Me? 9-10
9.2 Where To Go for More Information 9-11
9.3 References 9-12
Appendix 9-A EPA Regional Information Sources
Appendix 9-8 PCB Disposal Companies Commercially Permitted
Appendix 9-C State Solid and Hazardous Waste Agencies
Toxic Substances Control: How To Comply
~ Review section 9.1.3.1 to identify any electrical equipment at your
facility that may contain polychlorinated biphenyls (PCBs).
~ Determine whether any TSCA-regulated metahvorking fluids are
used in ^our facility and follow proper procedures for their use.
~ Determine and comply with any additional state, regional, or local
requirements for PCBs, asbestos, lead, or other toxic substances that
you might have at your facility.
December 1996
9-2
-------
Toxic Substances Control
Part I, Chapter 9
9.1 Federal Programs (TSCA)
9.1.1 What Is TSCA?
The Toxic Substances Control Act of 1976 (TSCA) was enacted to
provide EPA with a mechanism for identifying and controlling
hazards related to toxic chemicals. Programs operating under TSCA
serve one of two basic functions:
¦ Information gathering. Under TSCA, EPA collects information
to help determine whether chemicals present hazards to
humans or the environment
¦ Regulations. If EPA determines that toxic chemicals might
pose risks, regulations may be developed to control those
risks. For example, EPA has regulated the manufacture, use,
and disposal of polychlorinated biphenyls (PCBs).
9.1.2 Information Gathering Requirements
Much of the regulation under TSCA applies to chemical
manufacturers or importers, who must submit basic information
about new chemicals (see Box 9.1) prior to introducing them to the
market. Manufacturers may also be required to test chemicals for
toxic effects and submit the results to EPA for review. These
requirements do not apply to you unless you are actually
manufacturing or importing chemicals.
9.1.3 Regulatory Controls
Under TSCA, EPA has wide-ranging powers to impose controls
when chemicals are found to pose an unreasonable risk of injury to
human health and the environment. EPA can issue regulations to
control risks at any stage of a chemical's lifecycle, including
manufacturing, processing, distribution in commerce, use, and
disposal.1
'Distinction between 7~SCA and the Resource Conserv ation and Recovery Act (RCR.-1): TSCA aulhoiizes EPA to regulate disposal
on a chemical-by-chemical basis. RCRA establishes regulations and programs to ensure safe waste treatment and disposal of any number
of chemicals: it generally deals with waste streams rather than individual chemicals.
December 1996
9-3
-------
Toxic Substances Control
Part I, Chapter 9
Box 9-1 New Versus "Existing" Chemicals
TSCA treats new chemicals (i.e., chemicals not yet on the market) differently than existing
chemicals already in commercial use. Requirements related to new chemicals do not apply
to you unless you manufacture chemicals commercially. Requirements related to existing
chemicals may be applicable depending on what chemicals you currently use.
New Chemicals
New chemicals are defined as any chemicals not listed on EPA's TSCA 8(b) Inventory. The
TSCA Inventory, first published in 1979, is a master list of chemicals commercially available
in the United States. Updated every four years, the list currently encompasses more than
72,000 chemicals, not including pesticides, foods, drugs, and cosmetics (which are regulated
by EPA under other statutes or by the Food and Drug Administration).
Many new chemicals are specialty chemicals developed for relatively limited use and
application. New chemicals introduced since 1979 accounted for only 0.03% of the United
States' total production volume in 1989, for example.
Manufacturers wishing to introduce new chemicals to the U.S. market must submit
Premanufacture Notifications (PMNs) to EPA, containing information about the chemical,
how it is expected to be used, and any data or studies pertaining to possible human health or
environmental effects. EPA receives between 1,000 and 2,000 PMNs each year. EPA
reviews these notices to determine whether there is reason for concern about risks associated
with the chemical. Once approved and made available on the market, the chemical is added
to the TSCA Inventory.
Existing Chemicals
Existing chemicals are those chemicals that appeared on the initial 1979 TSCA Inventory.
The initial inventory contained most high-volume commodity chemicals used in industry,
plus many thousands of specialty chemicals. EPA is empowered to regulate those chemicals
found to pose risks to human health and the environment, including some used in the metal
finishing industry.
Among the regulatory controls available under TSCA. are:
¦ Total prohibition of use of the chemical.
¦ Prohibitions of certain uses or applications.
¦ Recalls of chemicals already on the market.
December 1996
9-4
-------
Toxic Substances Control
Part I, Chapter 9
¦ Requirements that manufacturers provide warnings or other
information to users about safe use and/or disposal of the chemical.
Thus far, EPA has taken action to regulate risks from only a small
number of chemicals already in use (see Box 9-2).
Box 9-2 Some of the Chemicals Regulated by EPA
Under TSCA
¦ Hexavalent chromium.
¦ Certain metal-working fluids.
¦ Polvchlorinated biphenyls (PCBs).
¦ Asbestos.
¦ Lead and products that contain lead. *
* Regulations have been proposed but have not yet been finalized.
Of these chemicals, you are most likely to be concerned about
PCBs, asbestos, and lead. If you have metal machining operations,
vou mav also be. affected by regulations covering metal-working
fluids. Regulations covering hexavalent chromium refer specifically
to use in biocides in cooling towers, not to chrome plating.
9.1.3.1 What PCB Regulations Might Apply to Me?
PCBs are toxic to laboratory animals, they are persistent in the
environment, and they are bioaccumulative (they accumulate in the
fatty tissues of animals and move up the food chain). When
enacted in 1976, TSCA included provisions to phase out most
manufacturing, processing, distribution, and use of PCBs in the
United States. These regulations were passed in 1979.
December 1996
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Toxic Substances Control
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Box 9-3 PCB Regulations: How To Comply
Inventory all PCB-containing equipment for annual log
(note definitions below).
• Calculate the weight of PCBs contained in each.
• All PCB-containing equipment with more than 50 ppm
PCBs must be labeled according to 40 CFR 761.45.
• Bv Julv 1 of each year, complete annual PCB log for
previous calendar year.
• Notify fire department of any PCB-containing
equipment.
• Maintain records on anv PCB-containing equipment
that is out of service.
• Maintain records on PCB equipment destined for or
shipped for disposal.
• Inspect anv out-of-service PCB equipment quarterly.
• Report all leaks of PCB-containing < .juipment within 48
hours.
Important Definitions:
PCB transformers contain 500 ppm PCBs or greater.
PCB-containing transformers contain less than 500 ppm PCBs.
Prior to the ban on manufacturing, PCBs were used extensively in
industrial equipment such as electrical transformers, capacitors,
fluorescent light ballasts, and hydraulic systems, where they
functioned as electrical insulators and lubricants (see Box 9-4 ).
December 1996
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Toxic Substances Control
PartI, Chapters
Box 9-4 Examples of Equipment that May Contain PCBs
Electric motors
Circuit breakers
Transformers
Reclosers
Capacitors
Cables
Heat transfer svstems
Transport vehicles
Electromagnets
Microwave ovens
Hydraulic systems
Electronic equipment
Switches
Fluorescent light ballasts
Natural gas pipelines
Other electrical fixtures
Voltage Regulators
Manufacturing of PCB-containing equipment has been banned since
1979, but with the exception of equipment containing extremely
high concentrations of PCBs (500 ppm or greater), there are no
federal requirements to remove equipment already in place. Instead,
regulations are designed to ensure that PCB-containing equipment
is decommissioned and disposed of in a safe manner. Additional
:gulations cover the procedures that must be followed in the event
of a PCB spill.
How Do I Know if Equipment Contains PCBs?
Manufacturing of equipment containing PCBs was banned effective
Julv 1, 1979. Most equipment manufactured after this date will be
stamped with "No PCB" or other similar marking. Older
equipment, however, might contain PCBs.
To determine whether old equipment contains PCBs, you must
either:
¦ Ask the manufacturer (be sure to give the manufacturer
information such as the make, model, serial number, date
and location of manufacture of the equipment).
December 1996
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Toxic Substances Control
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Box 9-5 What Must I Do if Equipment Contains PCBs?
If vour equipment contains PCBs you need not do anything unless:
¦ State regulations require vou to take action (e.g., remove PCB equipment regardless
of condition).
¦ You repair or upgrade the equipment (i.e., open or replace the equipment in a wav
that could result in exposure to or release of PCBs).
¦ The equipment is leaking PCB-containing material or any other type of spill occurs.
When upgrading your facility, PCB-containing equipment must be drained and
decontaminated according to proper procedures. These are described at 40 CFR Part
761.60. Generally, the equipment must be drained of all free-flowing liquid and the liquid
disposed of in an approved incinerator, chemical landfill, or high-efficiency boiler. Once
properlv drained and cleaned, the equipment itself can be disposed of like anv other
equipment. All PCB-containing equipment with more than 50 ppm PCBs must be labeled
according to 40 CFR 761.45.
Under TSCA, any intentional or unintentional release (including leaks) of PCB-
containing material is considered a spill. If a spill occurs, you must use a qualified
contractor to control and clean up the spill and repair or dispose of the equipment. In
addition, vou must notify your EPA Regional Office (see Appendix 9-A) as soon as possible
(within 24 hours) if the spill involves:
¦ Materials with PCB concentrations of 50 ppm greater that contaminate surface
water, drinking water, sewers, animal grazing land, or vegetable gardens.
¦ A total of 10 pounds or more of PCBs.
Under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), vou must also notify the National Response Center (1-800-424-8802) if the
spill involves 1 pound or more of PCBs.
In general, vou will rely on authorized service and disposal companies to handle PCB-
containing equipment and spills. These companies can test your equipment for PCBs,
review the test results with you, recommend disposal/cleanup procedures, and implement
the procedures for a reasonable fee. Appendix 9-B provides a partial list of PCB disposal
companies permitted to operate in all 10 EPA regions.
What Records Must / Keep?
To track TSCA-regulated chemicals, EPA requires those disposing of PCBs to prepare a
Uniform Hazardous Waste Manifest. The disposal companv vou use can provide this form
and anv related documentation that, might be required.
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Toxic Substances Control
Part I, Chapter 9
¦ Ask a PCB disposal company or certified lab to test the
equipment (see Appendix 9-B for a partial list of companies).
¦ Assume the equipment contains PCBs and dispose of it
accordingly.
9.1.3.2 What Asbestos Regulations Might Apply to Me?
Asbestos insulation and building products were used extensively in
building construction until the mid-1970s. Asbestos-containing
products are still present in many buildings. Examples of materials
that might contain asbestos include electrical insulation, thermal
insulation, acoustical insulation, ceiling and floor tiles, packings,
gaskets, paper coverings, plastics, coatings, and asbestos-cement
pipes, sheets, and shingles.
A major effort by EPA to ban or restrict the use of asbestos-
containing building and transportation products was overturned in
1991. Increased recognition of the risks from asbestos, however, has
led manufacturers to voluntarily develop safer substitutes in many
of these applications. Nevertheless, a considerable amount of
asbestos-containing material remains.
Insulation and other asbestos-containing products may pose risks to
workers performing building maintenance, repair, and general
renovation work. EPA regulation of asbestos hazards applies to
maintenance and renovation work in schools and public buildings
only. Regulations covering privately-owned buildings have been
developed by the Occupational Safety and Health Administration
(OSHA) (see 29 CFR Part 1910.1101). Most metal finishing
operations are affected by these OSHA regulations, not the EPA
regulations.
In most states, under either the OSHA or EPA regulations, asbestos-
containing materials must be removed and disposed of by a licensed
asbestos removal contractor. These contractors will establish
protected areas where removal will take place and will communicate
information about hazards and protective requirements to other
employers whose employees may be working adjacent to the
controlled areas. In-place management, either through
December 1996
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Toxic Substances Control
Part I, Chapter 9
encapsulation or regular inspection to ensure that asbestos-
containing material is in good condition, is another option.
9.1.3.3 What Lead Regulations Might Apply to Me?
Lead poses considerable risk to human health, especially in children.
Childhood lead exposure through lead-based paint, lead-
contaminated drinking water, and other sources can cause
neurological damage, leading to learning and developmental
problems.
Under TSCA, EPA has initiated a number of investigations into lead
hazards and measures that can be taken to reduce lead consumption
and use. Currently, EPA is considering actions to restrict the use of
lead solder in drinking water systems, including water fountains. All
products containing lead, however, including those manufactured by
metal finishers, may be targets for future risk reduction initiatives.
Until EPA implements new rules, you should simply be aware of
concern over the hazards of lead in drinking water systems. You can
contact your drinking fountain manufacturer to determine whether
lead solder was used in manufacturing the fountains, and what, if
anything, you can do to mi: imize lead levels in the drinking water.
In addition, you may wish to consider avoiding the use of lead or
lead-tin products (such as lead-tin solder) in the products you
manufacture.
9.1.3.4 What Metalworking Fluids Regulations Might
Apply to Me?
Metalworking fluids are used to cool and lubricate working surfaces
in machining operations such as grinding, cutting, and shaping, and
to clear away filings or cuttings. Certain metalworking fluids
contain amines which, if combined with nitrosating agents, can form
cancer-causing substances (nitrosamines).
In 1984, EPA published regulations prohibiting manufacturers of
three types of metalworking fluids from adding nitrosating agents to
their products, and requiring them to label such products to warn
users against adding nitrosating agents.
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Toxic Substances Control
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Metal finishers that also perform metalworking operations should
review warning labels on all metalworking fluids to identify those
regulated under TSCA. Regulated fluids will feature a warning
statement that reads:
WARNING! Do Not Add Nitrites to This Metalworking Fluid
Under Penalty of Federal Law. Addition of nitrites leads to
formation of a substance known to cause cancer. This product
is designed to be used without nitrites.
Machinists and others that may use such fluids should be made
aware of these prohibitions, and the dangers associated with adding
nitrites.
9.2 Where To Go for More Information
To get more information about TSCA requirements, contact:
¦ Your EPA Regional Office (see Appendix 9-A).
¦ EPA's Toxic Substances Control Act Hotline (1-202-554-
1404).
¦ EPA's Green Lights Program (1-202-775-6650), which
encourages and provide assistance in upgrading to
environmentally safer lighting systems.
The federal regulations discussed in this chapter are found in the
Code of Federal Regulations (CFR):
PCB Management 40 CFR Part 761
Asbestos Worker Protection 29 CFR Part 1910.1101
Standards (OSHA)
Asbestos Worker Protection 40 CFR Part 763
Standards (EPA)
Metalworking Fluids 40 CFR Part 747
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Toxic Substances Control
Part I, Chapter 9
The CFR is found in many libraries or is available by writing:
The Superintendent of Documents
Attn: New Orders
P.O. Box 371954
Pittsburgh, PA 15250-7954
or by calling the Government Printing Office order desk at 1-202-
783-3238.
9.3 References
1. U.S. Environmental Protection Agency. 1995. Lighting upgrade
manual. EPA 430-B-95-003. Research Triangle Park, NC: Office
of Air and Radiation. January.
2. U.S. Environmental Protection Agency. 1994. PCB Q&A
manual. Office of Pollution Prevention and Toxics. Available
from the TSCA Hotline.
December 1996
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APPENDIX 9-A
EPA REGIONAL INFORMATION SOURCES
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Toxic Substances Control
Part I, Chapter 9
EPA Regional Offices
REGION I
(ME, VT, NH, MA, CT, RJ)
Environmental Protection Agencv
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3420
REGION VI
(NM.TX, OK, AR, LA)
Environmental Protection Agency
First Interstate Bank Tower at Fountain Place
12th Floor/Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-6444
REGION II
(NY, NJ, PUERTO RICO, VIRGIN ISLANDS)
Environmental Protection Agency
Jacob K. Javits Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657
REGION VII
(NE, KS, MO. IA)
Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7000
REGION III
(PA, VW, VA, MD, DE, WASHINGTON DC)
Environmental Protection Agency
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800
REGION VIII
(MT, WY, ND, SD, UT, CO)
Environmental Protection Agency
Suite 500
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
JIEGION IV
(TN, KY. NC, SC. GA, AL, MS, FL)
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
REGION IX
(CA, NV, AZ, HI, AMERICAN SAMOA, GUAM)
Environmental Protection Agency
75 Hawthorne Street
Sari Francisco, CA 94105
(415) 744-1305
REGION V
(IL, Wl. IN, Ml, MN, OH)
Environmental Protection Agency
77 West Jackson Boulevard
Chicago, IL 60604-3507
(312) 353-2000
REGION X
(WA. OR, ID, AK)
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
(206)553-4973
December 1996
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APPENDIX 9-B
PCB DISPOSAL COMPANIES COMMERCIALLY PERMITTED
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Toxic Substances Control
Part I, Chapter 9
PCB Disposal Companies Commercially Permitted in the U.S.
Company
Address
Phone Number
Incinerators J
Aptus, Inc.
P.O. Box 1328
Coffeyville, KS 67337
312-251 6380
P.O. 27448
Salt Lake City, UT
801-521-9009
1160 N. Aptus Road
Aragonite, UT
Chemical Waste Management
P.O. Box 2563
Port Arthur, TX 77643
409-736-2821
Rollins
P.O. Box 609
Deer Park, TX 77536
713-930-2300
WESTON
One Weston Way
West Chester, PA 19380
215-692-3030 *
| Alternate Thermal Technologies
General Electric
100 Woodlawn Avenue
Pittsfield, MA 01201
413-494-2700
Chemical Dechlorination
Chemical Waste Management
1550 Balmer Road
Model City NY 14107
716-754-8231
Exceltech, Inc. (ENSCO
Subsidiary)
41638 Christy Street
Fremont, CA 94538
415-659-0404
Aptus, Inc.
P.O. Box 1328
Coffeyville, KS 67337
316-251-6380
PPM, Inc. (USPCI Subsidiary)
1875 Forge Street
Tucker, GA 30084
404-934-0902 *
ENSR Operations (formerly
Sunohio)
1700 Gateway Blvd. S.E.
Canton, OH 44707
216-4S2-0837 *
Transformer Consultants, Div.
of S.D. Myers, Inc.
180 South Avenue
Tallmadge, OH 44278
800-444-9580 *
Trinity Chemical Co. Inc.
6405 Metcalf, Cloverleaf 3
Suite 313
Shawnee Mission, ICS 66202
913-831-2290
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PCB Disposal Companies Commercially Permitted in the U.S.
Company
| Address
| Phone Number
Physical Separation
CECOS International Process
Center
4879 Spring Grove Ave.
Cincinnati, OH 45232
513-681-5738
Aptus, Inc.
P.O. Box 1328
Coffeyville, ICS 67337
316-251-6380
Unison Transformer Services,
Inc.
5801 Riverport Road
Henderson, KY 43420
502-827-0541
General Electric
One River Road
Schenectady, NY 12345
518-385-2426 *
S. D. Myers, Inc.
180 South Avenue
Tallmadge, Ohio 44278
800-444-9580
Pipeline Removal
Alquonguin Gas
Transmission Company
1284 Soldiers Field Rd.
Boston, MA 02135
617-254-4050 *
CNG Transmission
Corporation
445 West Main Street
Clarksburg, WV 26302
304 623-8446
Columbia Gas
Transmission Corp.
P.O. Box 1273
Charleston, WV 25325-1273
304-359-2727 *
Columbia Gulf Transmission
Co.
P.O. Box 1273
Charleston, WV 25325-1273
304-359-2727 *
Natural Gas Pipeline Company
of America
701 East 22nd Street
Lombard, IL 60148
708 691-3808
Northern Natural Gas
Company
P.O. Box 251 I
Omaha. NB 68103
515-226-201 1 *
Tennessee Gas Pipeline
Company (Tenneco)
P.O. Box 251 1
Houston,TX 77252-251 1
713-757-5687 •
Texas Eastern Gas Pipeline
Company
P.O. Box 2521
Houston, TX 77252-2521
713-759-5472 *
Texas Gas Transmission
Corporation
3800 Frederica Street
Owenaboro, KY 42302
502-926-8686 '
Transcontinental Gas Pipeline
Corporation
2800 Post Oak Boulevard
Houston, TX 7725 1 -1396
713-439-2130 '
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PCB Disposal Companies Commercially Permitted in the U.S.
Company
Address
Phone Number
Transwestern Pipeline
Corporation
3800 Frederica Street
Owenaboro, ICY 42302
713-853-7237 *
Pipeline and Compressor Systems Decontamination
Burlington Environmental Inc.
2203 Airport Way South, Suite 400
Seattle, WA98I34
206-223-0500 *
Rucker Environmental
2908 Charles Avenue
Dunbar, WV 25064
Vector Group, Inc.
1118 Ferris Road
Cincinnati, OH 45 102
513-752-8988 *
PCB Transformer Decomissioning (Disassembly/Smelting)
Aptus, Inc.
P.O. Box 1328
Coffeyville, ICS 67337
316-251-6380
Transformer Consultants
Div. of S.D. Myers, Inc.
180 South Avenue
Tallmadge, OH 44278
800-444-9580
Trans End
1302 West 38th Street
Ashtabula, OH 44004
216-992-8665
3126 Brinkerhoff Road
Kansas City, ICS 66115
913-321-3155
Fluorescent Light Ballast Recycling
FuICircle Ballast Recyclers
186 Bratde Street
Cambridge, MA 02138
800-775-1516
S. D. Myers, Inc.
180 South Avenue
Tallmadge, Ohio 44278
800-444-9580
Salesco Systems USA, Inc.-AZ
5736 West Jefferson
Phoenix, AZ 85043
800 368-9095
Chemical Waste Management
Alabama Inc.
Box 55
Emelle, AL 35459
205-652-9721
Box 471
ICetdeman City, CA 93239
209-386-9711
Chem-Securitv Svstems
Incorporated
Star Route, Box 9
Arlington, OR 987 1 2
503-454-2643
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PCB Disposal Companies Commercially Permitted in the U.S.
Company
Address
Phone Number
Envirosafe Services Inc. of
Idaho
P.O. Box 16217
Boise, ID 83715-6217
800-274-1516
CWM Chemical Services
Control, Inc.
1550 Balmer Road
Model City, NY 14107
716-754-8231
U.S. Ecology, Inc.
Box 578
Beattv, NV 89003
702-553-2203
U.S. Pollution Control, Inc.
Grayback Mountain
8960N Hwy 40
Lake Point, UT 84074
801-595-3900
Biological
Detox Industries,. Inc..
12919 Dairy Ashford
Sugar Land, TX 77478
713-240-0892
* Permitted to operate in all ten EPA Regions.
December 1996
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APPENDIX 9-C
STATE SOLID AND HAZARDOUS WASTE AGENCIES
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Toxic Substances Control
Part I, Chapter 9
State Solid and Hazardous Waste Agencies
ALABAMA
Department of Environmental Management
Land Division ( Solid/Hazardous Waste
J 751 Federal Drive
Montgomery, AL 36130
(205) 271-7761/7735
ALASKA
Steve Willingham
Manager, Solid Waste Program
State of Alaska
Department of Environmental Conservation
410 Willoughby Avenue
Juneau, AK 99801-1 795
(907)465-5158
ARIZONA
Anthony Leverock
Arizona Department of Environmental Quality
Hazardous Waste Permits Unit
3033 North Central Avenue
Phoenix, AZ 85012
(602) 207-4160
ARKANSAS
Tom Ezell
Manager, Programs Branch
Department of Pollution Control and Ecology
Hazardous Waste Division
P.O. Box 8913
Little Rock, AR 72219-8913
(501) 562-7444
Fax (501) 562-6532
CALIFORNIA
Mardis Coers
Department of Toxic Substances Control
P.O. Box 806
Sacramento, CA 958 12-0806
(916) 322-0712
COLORADO
Scott KJarich
Environmental Compliance Officer
Monitoring and Enforcement Section
Hazardous Materials and Waste Management
Division
Colorado Department of Health and
Environment
Mail Code: HMWMD-HWC-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
(303) 692-3369
CONNECTICUT
Department of Environmental Protection
Waste Management Bureau
79 Elm Street
Hartford, CT 06106
(203) 566-8476
DELAWARE
Department of Natural Resources and
Environmental Control
Division of Environmental Control
Solid Waste/Hazardous Waste Section
Edward Tatnall Building
P.O. Box 1401
Dover, DE 19901
(302) 739-4403
Delaware Solid Waste Authority
P.O. Box 71
New Castle, DE 19901
(302) 736-5361
DISTRICT OF COLUMBIA
Department of Consumer and Regulatory
Affairs
Environmental Regulation Administration
Pesticides, Hazardous Waste and Underground
Storage Tank Division
Hazardous Waste Management Branch
(Hazardous Waste Disposal)
2 100 Martin Luther King, Jr. Ave. SE, Suite 203
Washington, DC 20020
(202) 404-1 167
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Department of Public Works
Public Space Maintenance Administration
Bureau of Sanitation Services (Solid Waste
Disposal/Recycling)
2750 South Capitol St., SE
(202) 767-8512
FLORIDA
Raoul Clarke, Environmental Administrator
Bureau of Solid and Hazardous Waste
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(904) 488-0300
GEORGIA
Vern George
Environmental Protection Agency
Toxics Branch
345 Courtland St., NW
Adanta, GA 30334
(404) 347-1033
Department of Natural Resources
Environmental Protection Division
Land Protection Branch
205 Butler Street, SE
Suite 1 154
Adanta, GA 30334
(404) 656-2833
HAWAII
State of Hawaii
Department of Health
Environmental Management Division
Clean Air Branch
Asbestos Abatement Office
P.O. Box 3378
Honolulu, HI 96801-3378
(808)586-8144
IDAHO
William Fritell
Department of Health and Welfare
Division of Environment
Bureau of Hazardous Materials
450 W. State Street
Boise, ID 83720
(208) 334-5879
ILLINOIS
Clarence L. Smith
State of Illinois
Environmental Protection Agency
2200 Churchill Road
Springfield, IL 62794-9276
(217)524-3300
INDIANA
Robert Snodgrass
Solid Waste Permit Section
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-5976
IOWA
Lavoy Haage
Department of Natural Resources
Solid Waste Section
Land Quality Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, LA 50319
(515) 281-4968
KANSAS
Ron Smith
Department of Health and Environment
Solid Waste Management Division
Forbes AFB Bldg. No. 740
Topeka, ICS 66620
(913) 296-1500
KENTUCKY
Abby ivtyer
Department for Environmental Protection
Division of Waste Management
Ft. Boone Plaza
14 Reilly Road
Frankfort, KY 40601
(502) 564-6716 x242
LOUISIANA
Department of Environmental Quality
Office of Solid and Hazardous Waste
Solid Waste Division
P.O. Box 44307
Baton Rouge, LA 70804
(504) 765-0355
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MAINE
Department of Environmental Protection
Bureau of Oil &. Hazardous Materials Control
State House Station 17
August, ME 04333
(207)287-2651
Waste Management Agency
State House Station 154
August, ME 04333
(207)287-5300
MARYLAND
Ed Hammerburg
Department of Environment
Toxic Operations Program
2500 Boening Highway
Baltimore, MD 21224
(410) 631-3345
MASSACHUSETTS
Victoria Phillips, Environmental Analyst
Office of Hazardous Waste
Enforcement Division
1 Winter Street
Boston, MA 02108
(617) 292-5812
MICHIGAN
Department of Natural Resources
Hazardous Waste Division
P.O. Box 30241
Lansing, MI 48909
(517) 373-2730
MINNESOTA
Nancy Ellefson
Minnesota Pollution Control Agency
Solid or Hazardous Waste Division
520 Lafayette Road North
St. Paul, MN 55155
(612) 296-6300
MISSISSIPPI
Russell Smith
Department of Environmental Quality
Office of Pollution Control
P.O. Box 10358
Jackson, MS 39209
(601) 961-5171
MISSOURI
Department of Natural Resources
Division of Environmental Quality
Waste Management Program
Jefferson State Office Building
205 Jefferson Street
P.O. Box 1 76
Missouri Boulevard
Jefferson City, MO 65102
(314) 751-3176
MONTANA
Don Vidrine
Department of Health and Environmental
Sciences
Environmental Sciences Division
Solid and Hazardous Waste Bureau
P.O. Box 200901
Helena, MT 59620-0901
(406) 444-1430
NEBRASKA
Department of Environmental Control
P.O. Box 94877
State Office Building
Lincoln, NE 68509
(402) 471-2186
NEVADA
Colleen Crips
Bureau of Hazardous Waste
333 West Nye Lane
Carson City, NV 89710
(702) 687-5872
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NEW HAMPSHIRE
Robert C. White, Chief
PCB Section
Department of Environmental Services
Air Resources Division/Toxics Management
Bureau
64 N. Main St., Caller Box 2033
Concord, NH 03302-2033
(603) 271-1370
Department of Environmental Services
Waste Management Division/Compliance
Bureau
6 Hazen Drive
Concord, NH 03301
(603) 271-2942
NEW JERSEY
Sandor Juhasz
NJ. Department of Environmental Protection
and Energy
Hazardous Waste Regulation Program
401 East State Street
CN 421
Trenton, NJ 08625
(609) 292-8341
NJ Department of Environmental. Protection:
and Energy
Solid Waste Management Division
840 Bear Tavern Road
CN 44
Trenton, NJ 08625
(609) 292-8341
NEW MEXICO
New Mexico Environmental Department
Harold Runnels Building
P.O. Box 26110
Santa Fe. NM 87502
Hazardous and Radioactive Materials Bureau
(505) 827-4308
Solid Waste Bureau
(505) 827-2775
NEW YORK
Sharon Rader
Division of Hazardous Substances Regulation
New York State Department of Environmental
Conservation
50 Wolf Road
Albanv, NY 12233
(518) 485-8988
NORTH CAROLINA
Department of Environment, Health, and
Natural Resources
Solid Waste Management/Hazardous Waste
Division,
P.O. Box 27687
Raleigh, NC 27611
(919) 733-2178
NORTH DAKOTA
Neil M. Knatterud, Director
Health Department
Division of Waste Management
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
(701)328-5166
OHIO
Environmental Protection Agency
Office of Solid and Hazardous Waste
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266-0149
(614) 644-2917
OKLAHOMA
Allen Bussert
Oklahoma Department of Environmental
Quality
Public Information and Education
1000 Northeast 10th Street
Oklahoma City, OK 73117-1212
(405) 271-7353
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Part I, Chapter 9
OREGON
Gary Galaba
Department of Environmental Quality
Waste Management Clean-up Division
81 I S.W. 6th Avenue
Portland, OR 97204
(503) 229-5630
PENNSYLVANIA
Department of Environmental Resources
Bureau of Waste Management
P.O. Box 8471
Harrisburg, PA 17105-8471
PUERTO RICO
Environmental Quality Board
Solid and Hazardous Waste Bureau
P.O. Box 1 1488
Santurce, PR 00910
(809) 725-5140
RHODE ISLAND
Robert Nero
Department of Environmental Management
Air and Hazardous Materials
291 Promenade Street
Providence, R1 02908
(401) 277-2797
SOUTH CAROLINA
Board of Health and Environmental Control
Bureau of Solid and Hazardous Waste
2600 Bull Street
Columbia, SC 29201
(803) 896-4174
SOUTH DAKOTA
Department of Water and Natural Resources
Environmental Health Division
Joe Foss Building
Pierre, SD 57501
(605) 773-3153
TENNESSEE
Wayne Gregory, Technical Coordinator
Department of Environment and Conservation
Division of Solid Waste Management
5 th Floor, C Tower
401 Church Street
Nashville. TN 37243-1535
(615)532-0780
TEXAS
Alice Hamilton Rogers, P.E., Technical
Consultant
Texas Water Commission
P.O. Box 13087
1700 North Congress Avenue
Austin, TX 78711-3087
(512) 463-7830
UTAH
Rusty Lundburg
Department of Environmental Qualitv
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, UT 841 14-4880
VERMONT
Stephen Simoes,
Hazardous Materials Coordinator
Department of Environmental Conservation
Hazardous Materials Management Division
103 South Main Street
Waterbury, VT 05671-0404
(802) 241-3888
VIRGINIA
Robert Lincoln, Waste Division
Virginia Department of Environmental Quality
Special Solid Waste Program
P.O. Box 10009
Richmond, VA 22240
(804) 527-5357
WASHINGTON
Vern Meinz, Environmental Engineer
Department of Ecology
Solid and Hazardous Waste Program
P.O. Box 47600
Olympia, WA 98504-7600
(206) 407-6753
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WEST VIRGINIA
WV Division of Environmental Protection
Office of Waste Management
1356 Hansford Street
Charleston, WV 25301
(304) 558-5929
WISCONSIN
Department of Natural Resources
Bureau of Solid Waste Management
101 South Webster Street
Madison, WI 53707
(608) 266-1327
WYOMING
Department of Environmental Qualitv
Solid Waste Management Program
122 West 25th Street
(307) 777-7752
December 1996
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Notes
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CHAPTER 10
Pollution Prevention
10.1 Why Is Pollution Prevention Important? 10-2
10.1.1 Cost Savings 10-3
10.1.2 Meeting/Reducing Compliance Requirements 10-4
10.1.3 Productivity/Quality Improvements 10-4
10.1.4 Emplovee/Community Risk Reduction 10-4
10.1.5 Reduced Future Liabilities 10-5
10.2 What Is Pollution Prevention? 10-5
10.3 How Can I Do Pollution Prevention? 10-6
10.3.1 Obtain Management Commitment 10-7
10.3.2 Establish Employee Involvement 10-9
10.3.3 Define and Communicate Goals and Objectives 10-10
10.3.4 Determine and Prioritize Waste Streams 10-10
10.3.5 Identify and Evaluate Options 10-14
10.3.6 Implement Selected Options 10-18
10.3.7 Measure and Communicate the Results 10-18
10.3.8 Keep the Efforts Going 10-19
10.4 Where Can I Get More Information? 10-20
10.4.1 State Pollution Prevention Programs 10-21
10.4.2 Information Clearinghouses and Centers 10-33
10.4.3 Internet World Wide Web Home Pages 10-34
10.4.4 Pollution Prevention Training Course 10-34
10.4.5 References 10-35
away from an "end-of-pipe" mentality, emphasizing instead the need to change
processes and work practices to avoid generating waste in the first place. All
waste streams in the metal finishing facility, including hazardous waste, air and
pollution prevention is important, and provides guidance on how to design and
Metal finishers are concerned about the increasing amount of regulation
they must comply with. They also have con :ems about the
environmental costs and impacts associated with waste generation, handling,
disposal, and liability. These concerns have raised awareness about the
importance of waste management and prevention practices.
Pollution prevention has become a common strategy used by companies in all
industries to achieve environmental compliance, reduce their environmental
costs, improve their image in their community, and work towards minimizing
their environmental impacts. With pollution prevention, companies move
away from an "end-of-pipe" mentality, emphasizing instead the need to chang
processes and work practices to avoid generating waste in the first place. All
waste streams in the metal finishing facility, including hazardous waste, air an
water pollution, and solid waste, can be addressed using pollution prevention.
This chapter introduces the concept of pollution prevention, describes why
pollution prevention is important, and provides guidance on how to design an
implement a pollution prevention program. In addition, this chapter identifie
resources available to help you pursue pollution prevention in your facility.
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Table of Contents Page
10.1 Why is Pollution Prevention Important? 10-2
10.1.1 Cost Savings 10-3
10.1.2 Meeting/Reducing Compliance Requirements 10-4
10.1.3 Productivity/Quality Improvements 10-4
10.1.4 Employee/Community Risk Reduction 10-4
10.1.5 Reduced Future Liabilities 10-5
10.2 What is Pollution Prevention? 10-5
10.3 How Can I Do Pollution Prevention? 10-6
10.3.1 Obtain Management Commitment 10-7
10.3.2 Establish Employee Involvement 10-9
10.3.3 Define and Communicate Goals and Objectives 10-10
10.3.4 Determine and Prioritize Waste Streams 10-10
10.3.5 Identify and Evaluate Options 10-14
10.3.6 Implement Selected Options 10-18
10.3.7 Measure and Communicate the Results 10-18
10.3.8 Keep the Efforts Going 10-19
10.4 Where Can I Get More Information? 10-20
10.4.1 State Pollution Prevention Programs 10-20
10.4.2 Information Clearinghouses and Centers 10-33
10.4.3 Internet World Wide Web Home Pages 10-34
10.4.4 Pollution Prevention Training Course 10-34
10.4.5 References 10-35
Appendix 10-A Best Management Practices for Pollution Prevention in the Metal Finishing Industry
Appendix 10-B State Pollution Prevention Contacts
10.1 Why Is Pollution Prevention Important?
Complying with existing environmental regulations can be extremely
daunting and costly to the average metal finishing firm. Because of
the substantial amount of materials used, all metal finishing
processes have pollution problems and generate wastes to varying
degrees. Even a firm that does a good job of managing these
materials and wastes can end up spending a large amount of money,
time, and other resources on environmental compliance. And in a
business climate of ever-increasing competition, these types of
expenditures are not very desirable to a firm.
Pollution prevention provides a means for meeting, and possibly
even reducing, a firm's environmental compliance requirements,
while also saving money and improving the firm's economic
competitiveness. It is a proactive, "common-sense" approach to
environmental management, whereby actions are taken to change
the conditions and circumstances that have the potential to generate
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pollution and require compliance efforts. By reducing the
generation of pollution in the first place, possibly even below the
various regulatory thresholds that trigger the need for compliance,
a firm can save itself valuable resources.
There is a general misconception that pollution prevention involves
expensive and "high-tech" process changes, but this is frequently not
the case. Many pollution prevention options for metal finishing and
other industries are simple and of minimal cost, and as a result
many firms have begun to practice pollution prevention, even
though the only pollution prevention mandate as specified under
some federal (see Chapters 4 and 5) and state regulations (see
Section 10.4.1) is the formation of a program or plan. The
popularity of pollution prevention is growing because of its many
benefits, which are described below.
10.1.1 Cost Savings
This is perhaps the most important benefit of practicing pollution
prevention to a firm. There are numerous ways to save money by
making production efficiency improvements and other changes that
reduce the generation of pollution. Some of these costs savings are
dirrct and are therefore intuitively obvious, while others are indirect
and as a result not so obvious. The following are environmental
costs that can be reduced or eliminated:
¦ Materials costs, by reducing plating bath solution purchases,
and reclaiming valuable metals in wastewater using an ion
exchange system.
¦ Water/energy and other utility costs, by reducing water usage
through flow control, and reducing electricity usage through
alternative metal cleaning systems.
¦ Waste treatment, storage, and disposal costs, by reducing
sewer/discharge permit fees, and reducing waste
transportation/shipping fees.
¦ Compliance labor costs, by reducing the man-hours needed
to prepare permits, keep records, conduct audits, and monitor
and report on emissions.
¦ Worker health and safety costs, by reducing workman's
compensation costs.
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10.1.2 Meeting/Reducing Compliance Requirements
By reducing or eliminating wastes, a firm can potentially reduce its
emissions below some of the various regulatory thresholds that
trigger compliance requirements. Compliance requirements that
may be avoided include obtaining permits, monitoring and
inspecting, recordkeeping and reporting, manifesting, and
emergency planning. For example, a firm that reduces hazardous
waste generation may be able to move from "Small Quantity
Generator" status to "Conditionally-Exempt Small Quantity
Generator" status (see Chapter 5), thereby escaping numerous
reporting requirements.
An added benefit is that the pollution prevention action usually
results in a "permanent" reduction or elimination of emissions, so
that meeting or reducing compliance requirements can be assured.
This contrasts with the lack of assurance of end-of-pipe controls,
which often require constant attention or maintenance to perform
properly.
10.1.3 Productivity/Quality Improvements
Pollution is essentially a loss from a process or operation that usually
represents an inefficient use of a material resource. Pollution
prevention therefore focuses on reducing losses from processes, so
that companies can use resources more efficiendy and increase
productivity. By practicing pollution prevention, companies also
typically find ways to improve product quality, and reduce energy
or water consumption. In metal finishing operations, pollution
prevention techniques often increase the quality of rinsing, and
reduce spotting and staining of the workpiece. Also, pollution
prevention often increases the process controls of the plating
operation, thereby improving the predictability and performance of
process solutions and decreasing reject rates (NEWMOA, 1996).
10.1.4 Employee/Community Risk Reduction
By reducing or eliminating the generation of hazardous pollutants,
a firm can reduce the risk of exposures due to releases, spills, and
leaks to its employees and the surrounding community. This can
have the added benefits of reduced workman's compensation or
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other insurance costs, improved relations with employees,
community groups, and customers, and increased employee
productivity and customer market share. These and the other
benefits of pollution prevention can even be enhanced by involving
employees, customers, and local community groups in pollution
prevention efforts. Input from employees is especially valuable
because they can provide some of the best information on reducing
waste and increasing efficiency.
10.1.5 Reduced Future Liabilities
Several future potential liabilities that can be quite expensive can be
minimized or avoided by reducing the generation of pollution.
These include site remediation costs, property damage, worker
health costs, noncompliance enforcement fines or penalties, reduced
customer market share, and legal expenses for citizen suits.
10.2 What is Pollution Prevention?
Many working definitions of pollution prevention exist, in addition
to the formal definitions developed by EPA and various states over
the years. Many other terms also are commonly used for pollution
prevention both inside and outside the environmental field,
including waste reduction, waste minimization, source reduction,
materials efficiency, and throughput efficiency.
Despite the wide variety of terms and definitions, they all more or
less refer to the principle of reducing or eliminating the generation
of pollutants or waste at the source. Some metal finishers have
already been following this principle for many years.
In the EPA's definition, which is based on the Pollution Prevention
Act of 1990 passed by Congress, pollution prevention is equated to
"source reduction" and is defined to mean any practice which: 1)
reduces the amount of any hazardous substance, pollutant, or
contaminant entering any waste stream or otherwise released into
the environment (including fugitive emissions) prior to recycling,
treatment, and disposal; and 2) reduces the hazards to public health
and the environment associated with the release of such substances,
pollutants, or contaminants. These reductions can be achieved
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through increased efficiency in the use of raw materials, energy,
water, or other resources, or protection of natural resources by
conservation. Source reduction techniques include: equipment or
technology modifications, process or procedure modifications,
reformulation or redesign of products, substitution of raw materials,
and improvements in housekeeping, maintenance, training, or
inventory control.
In the 1990 Pollution Prevention Act, Congress also established a
national policy that is commonly referred to as the "waste
management hierarchy." This policy states that:
¦ Pollution should be prevented or reduced at the source
whenever feasible
¦ Pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible
¦ Pollution that cannot be prevented or recycled should be
treated in an environmentally safe mariner whenever feasible
¦ Disposal or other release into the environment should be
employed only as a last resort and should be conducted in an
environmentally safe manner.
This waste management hierarchy makes clear that pollution
prevention is not the only strategy for reducing risk but is the
preferred one. The policy recognizes that environmentally-sound
recycling shares many advantages with prevention—it can reduce
the need for treatment and disposal, and conserve energy and
resources. Recycling, treatment, and disposal are all not considered
pollution prevention, however, although some practices commonly
described as "in-process recycling" may qualify.
10.3 How Can I Do Pollution Prevention?
It is not necessary to have a formal and bureaucratic program in
place in order to practice pollution prevention. What is needed in
order to maximize the success is commitment, participation,
planning, and analysis. Several important steps cover these four
areas:
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¦ Obtain management commitment and support
¦ Establish employee involvement
¦ Define and communicate quantitative goals and objectives
¦ Determine and prioritize all existing waste streams
¦ Identify and evaluate pollution prevention options
¦ Implement the selected options
¦ Measure and communicate the results
¦ Keep the pollution prevention efforts going.
This section provides an overview of the above steps. The
majority of this section is based on other documents (listed in the
references at the end of this chapter) that cover this information in
more depth, and the reader is encouraged to review these documents
if interested.
10.3.1 Obtain Management Commitment
For many firms, adopting a pollution prevention philosophy will
involve a major shift in thinking about products, production
methods, and work habits. Many of the activities that create
pollution are locked up in the traditional ways of doing things.
These old ways can often be difficult to change, especially when
they seem to have worked well for many years. And like other types
of change of this magnitude, there will be resistance and inertia to
overcome.
The commitment and support of company management, preferably
top executives, is essential for successful and lasting pollution
prevention efforts. If management places a strong emphasis on
pollution prevention, then most likely employees will as well. From
the start, management should endorse the goals and efforts, promote
employee education about pollution prevention, communicate the
importance of pollution prevention to the company's business
strategy, and encourage and reward employee participation in the
effort. Successful management initiatives that have promoted
pollution prevention include incorporating pollution prevention
success into employee performance evaluations, and offering
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financial incentives for finding pollution prevention opportunities
or meeting quantitative goals (NEWMOA, 1996).
Many companies also demonstrate their management commitment
by establishing and endorsing a written pollution prevention policy.
Once endorsed by management, the policy should be distributed to
all employees to raise their awareness about pollution prevention.
A sample corporate policy statement on pollution prevention is
shown in Box 10-1.
Box 10-1 Pollution Prevention Policy Statement
We [company name], are committed to excellence and leadership in protecting the
environment. In keeping with this policy, our objective is to reduce waste generation
and emissions. We strive to minimize adverse impacts on the air, water, and land
through excellence in pollution prevention. By successfully preventing pollution at its
source, we can achieve cost savings, increase operational efficiencies, improve the
quality of our products and services, and maintain a safe and healthy workplace for our
employees.
[Company name]'s environmental guidelines include the following:
¦ Environmental protection is everyone's responsibility. It is valued and displays
commitment to [company name],
¦ Preventing pollution by reducing and eliminating the generation of waste and
emissions at the source is a prime consideration in research, process design, and
plant operations. [Company name] is committed to identifying and implementing
pollution prevention opportunities through encouragement and involvement of
all employees.
¦ Technologies and techniques which substitute nonhazardous materials and
utilize other source reduction approaches will be given top priority in addressing
all environmental areas.
¦ [Company name] seeks to demonstrate its corporate citizenship by adhering to all
environmental regulations. We promote cooperation and coordination between
industry, government, and the public toward the shared goal of preventing
pollution at its source.
Source: Minnesota Office of Waste Management, 1991.
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10.3.2 Establish Employee Involvement
Begin this step by organizing a pollution prevention team, headed
by a coordinator or team leader, to champion and manage the
pollution prevention efforts. The team would be responsible for
planning, designing, implementing, and maintaining the pollution
prevention initiatives. Specific responsibilities or tasks of the team
should include:
¦ Working with upper management to set quantitative
preliminary and long-term goals
¦ Promoting pollution prevention to all employees and
educating them on how they can participate in the effort
¦ Gathering and analyzing necessary planning and design
information
¦ Monitoring and reporting to management on progress
(NEWMOA, 1996).
A team approach allows the above tasks to be distributed among
different employees, and enables staff from different parts of the
company to have input into the planning process. People who bring
different backgrounds and expertise to the table should be included,
as well as anyone else who expresses an interest—volunteers should
always be welcomed. In small companies, the team could consist of
one person who wears many hats, or the company manager and a
technical person. In larger companies, it might include
environmental managers, technical staff, building and maintenance
staff, marketing and purchasing staff, and other interested
employees.
In addition to establishing a core team, it is critical to promote the
pollution prevention initiatives to all employees, particularly the
plant/shop workers, and to encourage their input and participation.
All employees should be made aware of the potential benefits to
them and to the firm, and also of the importance of their
participation. Information that is essential to success of pollution
prevention efforts can come from a well-trained work force that sees
the benefits of reducing pollution and waste in the workplace, and
the substantial cost savings available to the company. Workers
appreciate pollution prevention that will protect the environment,
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as long as they are not asked to bear an additional health risk in the
workplace.
10.3.3 Define and Communicate Goals and Objectives
It is important to thoughtfully develop goals and objectives for the
pollution prevention efforts in order to establish a clear focus for the
work, and to help later in the prioritization of waste streams. Goals
might reflect a need or desire to comply with a specific regulation,
reduce costs, reduce the quantity or toxicity of certain wastes, or
reduce worker exposure. The team should develop these goals and
objectives with management assistance, but it is also important to
communicate what is developed to all employees, especially the
plant/shop workers, and receive some feedback. This will help to
obtain cooperation and support from the maximum number of
employees, and hopefully enhance participation and success.
Another important consideration is to make the goals and objectives
as specific and quantitative as possible. A quantitative goal sets a
numeric target (e.g., "reduce toxic substance emissions by 50%"),
while a qualitative goal does not (e.g., "achieve a significant
reduction of toxic substance emissions"). Quantitative goals will
help to clearly identify and maintain the focus, which is critical for
long-term pollution prevention efforts, and will also make it easier
to measure progress. Nonetheless, specific/quantitative goals and
objectives do not guarantee the ability to measure progress unless
the necessary data is available. Data availability, therefore, must
also be factored in when developing goals and objectives.
10.3.4 Determine and Prioritize Waste Streams
This step involves assessing the facility or operations of interest in
order to identify all existing waste streams that would be the
possible targets for pollution prevention actions, and then ranking
them according to the goals and objectives previously defined.
These potential target waste streams are commonly referred to as
"pollution prevention opportunities." In order to conduct a
thorough assessment, it is necessary to understand all of the material
flows through the facility or operations being examined (including
water flows). This is usually the most tedious and time-consuming
step in the pollution prevention process because it can involve
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gathering a large amount of information and data that is not readily
available.
In performing this assessment, it is important to realize that the
manufacturing or production processes are typically not the only
operations where pollution prevention opportunities exist. In an
entire facility, there are often many other operations, often referred
to as ancillary operations, that are inherently wasteful and that
should be examined (Pojasek, 1993). Some typical ancillary
operations in a metal finishing facility are machine shops, warehouse
and storage areas, shipping and receiving areas, maintenance
departments, chemical mixing areas, and laboratories.
Tour the Facility
The first thing to do is to familiarize all members of the pollution
prevention team with the physical layout and equipment of the
facility or operations, if they are not already familiar with it A
thorough tour of the facility or operation should be given for those
who need it. In addition, drawings of the process and storage area
layout should be located or prepared. These drawings should be to
scale, and should show the location of all relevant equipment, tanks,
and oiping lines, including:
¦ Plating and other process lines
¦ Gutters, sumps, and sewer lines
¦ Water lines, control valves, and flow regulators
¦ Utility connections.
Gather Baseline Information
After becoming familiar with the layout, it is necessary to collect
technical and financial information that will support the assessment.
This information is typically found by examining records or
conducting interviews in areas such as engineering, accounting,
purchasing, shipping, and receiving. Some suggested information to
collect is shown in Box 10-2, but a customized list should be
developed for each situation. Other information that may be
necessarv includes the utility usage and costs, and labor hours and
costs.
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Box 10-2 Information for a Pollution Prevention Assessment at a Metal Finishing
Facility
General Facility Information
Process Line Information
— Estimates of production units,
— Rack/barrel design and condition
such as square meters plated,
— Actual operating procedures
number of parts, barrels or racks
— Operating parameters
to pass through a line sequence.
— Production rates (i.e., square feet
— Types of parts plated
processed per hour)
— Chemical purchases
— Chemical inventory
Plating Bath Information
— Chemical usage rates (where is
— Batch dumps that result from the
each chemical used and how
process
much in each process)
— Drag-out rates from each process
— Quality of makeup water
tank
— Facility wide water use rates
— Bath evaporation rates
— Wastewater treatment operating
— Process solution composition
procedures
— Actual operating parameters for
— Wastewater content
each process tank
— Sludge management procedures
— Dump schedule for each process
— Sludge content analysis
tank
— Waste management costs
— Raw material costs
Rinsing Process Information
— Compliance problems
— Rising and draining times on
— Control processes
automatic lines or efficiency of
— Sampling and analysis
operator on manual lines
information
— Drag-out measurements
— General amount of drippage on
— Drag-in/contaminant loading rates
the floor
— Rinsewater quality requirements
— Flow control techniques
— Wastewater flow rate from each
rinse tank
— Drag-out reduction techniques
used
Source: NEWMOA, 1996.
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This is a lot of information to collect, and some may not be readily
available, so keep in mind that the overall purpose is to prevent
pollution and not to collect data. Data that is hard to collect may
be approximated using engineering estimates or "best professional
judgement." The extent of actual data collection should be
consistent with the overall goals and objectives, but the bottom line
is that the better the database, the better the results.
Develop a Process Flow Diagram
After the necessary data is collected, it will need to be organized and
analyzed in order to determine waste streams and opportunities for
reducing them. This involves preparing a process flow diagram, or
process map, for the operations of interest. A process map is an
analytical tool that is typically used in quality improvement
programs to understand the production process, by providing a way
to visualize the functional sequence of events or actions (Pojasek,
1996). It also provides a way to account for the flow, generation,
consumption, and accumulation of mass in a process, based on the
principle of the conservation of mass (Mass in = Mass out -
Generation +- Consumption + Accumulation). A good diagram will
reveal material quantities lost to waste or to accumulation in
equipment (EPA, 1992).
The process flow diagram should cover the main and ancillary
operations of the metal finishing facility, and should include each
substance entering and leaving each operation. The unit operations
are drawn in sequence, and then all materials entering and leaving
each operation are included. Material inputs include raw materials,
intermediate products, processing aids (e.g., catalysts, solvents), and
utilities (e.g., water, electricity); outputs include products and
wastes. It should be recognized that there are typical difficulties in
preparing process flow diagrams (e.g., lack of sufficient data to
characterize all streams), and that most require at least some
estimation (EPA, 1992). An example of a process flow diagram is
provided in Chapter 12 of this manual.
Prioritize the Waste Streams
Once all the waste streams have been identified, they should be
prioritized for pollution prevention action according to the goals
and objectives that were defined earlier. For cost reduction, it is
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crucial to understand the full costs of the wastes generated, as well
as the operations or processes that are the sources or drivers of these
costs. Unfortunately, most firms typically underestimate many of
their environmental management costs because they are "hidden" in
overhead accounts. Other firms do recognize their primary
environmental costs, but fail to fully explore and analyze the
"hidden" activities or reasons why these costs are so high.
Environmental cost accounting (ECA) is a collective set of methods
and tools that can be used by firms to identify and quantify many
of these "hidden" environmental costs, and to link them to the
operations or activities that generate them. While not yet
developed to a point where it is widely applied, ECA is being
increasingly explored as an alternative to conventional accounting
techniques to more fully assess environmental costs and the benefits
of pollution prevention investments. For metal finishing, a study by
the Waste Reduction Institute for Training and Applications
Research (WRITAR) found that firms may benefit substantially by
using ECA to assess 1) the costs due to excess water use, bath
dumps, disposal of tank bottoms, reworking rejected parts, and
decommissioning process lines and 2) the savings available from
pollution prevention options that minimize these activities
(WRITAR, 1996). Chapter 12 of this manual covers ECA in more
depth, and it is recommended that the reader review this chapter.
10.3.5 Identify and Evaluate Options
In this step, the team identifies pollution prevention options or
ideas to address the high priority waste steams, and then evaluates
them for technical and economic feasibility. All ideas should be
taken seriously, and none should be rejected automatically for
reasons such as "that's already been tried," or "it will never work,"
or "it's too expensive." Very often, the best pollution prevention
ideas represent new and sometimes unconventional ways of doing
things.
Identify Proven Options
Many proven and often cost-effective pollution prevention options
are available for metal finishing, ranging from simple (a.k.a. "low
hanging fruit") to complex. For instance, Best Management
Practices (BMPs) are simple and inexpensive steps that can reduce
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waste, save money, and eliminate worker exposure, and that should
be implemented first whenever possible. Well-known BMPs
applicable to metal finishing operations are shown in Box 10-3.
Many BMPs concern material handling issues, for which worker
training is an essential component. From the storage and shipping
of raw materials, the mixing of baths, to prompt response to small
spills, operators will be essential participants in reducing waste.
Beyond simple BMPs, a large number of more complex, yet often
inexpensive, pollution prevention options exist for metal finishing
operations. Appendix 10-A provides some information on many of
these options for specific waste streams.. In addition, there is a vast
amount of in-depth information available on pollution prevention
options for metal finishing from the various resources provided in
Section 10.4. The reader is encouraged to seek out some of these
information resources, particularly the pollution prevention program
in the firm's appropriate state and the National Metal Finishing
Resource Center, if access to the Internet is available.
Generate Innovative Options
In addition to identifying proven options, the team can attempt to
generate innovative ones using typical quality improvement tools
known as brainstorming, brainwiiting, and root cause analysis.
Brainstorming and brainwriting are two ways to generate ideas, with
the former done openly and the latter done anonymously. Root
cause analysis involves developing a cause and effect diagram that
helps dissect the problem down into its basic parts. In doing so, the
team can discuss the interrelationships between materials,
technology, methodology, measurement techniques, and people that
are contributing to the problem (Pojasek, 1996).
Screen and Rank the Options
After all options have been identified, the team should screen them
and then rank-order the remaining ones before doing a more
detailed feasibility analysis. Screening and ranking should be based
on the overall goals and objectives, and also on any other criteria
which are important. Possible criteria could be upfront (before
pavback) cost, impact on product quality, impact on cycle time or
December 1996
10-15
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Pollution Prevention
Part II, Chapter 10
Box 10-3 Best Management Practices for a Metal Finishing Facility
Materials Inventory and Handling
Housekeeping
— Inventory system for raw
— Prompt removal/cleanup of
materials
small spillage
— New container inspection
— Regular garbage pickup and
before acceptance
disposal
— First-in/first-out material
— Maintenance of clean and
utilization
dry floors
— Inventory protection from
— Demarcation of proper
exposure to weather
pathways with no
— Employee training: container
protrusions
handling, spill response
— Minimize inventory by
Waste Segregation
optimizing purchases
— Segregate hazardous from
— Minimize waste package by
nonhazardous wastes
returnable containers
— Look for reuse, recycle,
— Dispose of obsolete material
reclaim opportunities
that cannot be returned
— Segregate cyanide wastes
from noncyanide wastes
Spill Prevention and Control
— Segregate hexavalent chrome
— Incident reporting, record
streams
keeping, follow-up
— Segregate chelate-containing
prevention
ind non-chelate wastes
— Train employees in use of
— Segregate streams requiring
sorbents, neutralizing agents
only neutralization
— Motivation of employees
concerning spill prevention
Source Reduction—Miscellaneous
— Spill containment around
— Keep solvent tanks covered
high risk areas
when not in use
— Remove dropped parts from
Preventive Maintenance
tanks after every shift
— Schedule inspections of
— Install drain boards between
equipment, systems
tanks to return drippage
— Appropriate adjustment,
— Install flow regulators on
repair or replacement
rinse tanks
— Maintenance of records on
— Shut off fresh water feed
equipment, systems
when plating line is down
— Use warm water rinse after
alkaline cleaning
— Mix process baths bv
properlv trained personnel
Source: CLAMF IW)
December 1996
10-16
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Pollution Prevention
Part II, Chapter 10
throughput, and supplier/customer issues. Option screening should
consider the following questions (EPA, 1992):
¦ Will the option sufficiently reduce waste?
¦ What are the main benefits to be gained by implementing
this option?
¦ Is the option safe for our workers?
¦ Is the option technically feasible (e.g., space, system
compatibility, utilities)?
¦ How much does it cost? Does it appear to be cost-effective?
¦ Can the option be implemented without major disruptions in
production?
¦ Does the option have a good "track record"?
¦ What other areas might be affected by implementation?
Ranking options can be done using another quality improvement
tool known as bubble-up/bubble-down. It involves comparing each
option against all of the other ones, one at a time, using the
established criteria. For each comparison, the team discusses the
two options until one is deemed superior. The process continues,
each time comparing unique pairs that have not been compared
before. Eventually, the options become ordered from the most to
least preferable.
Analyze the Cost-Effectiveness
Most pollution prevention options, like other types of production
changes, require an initial investment of money to implement. And
tvpically, pollution prevention options have to compete with other
tvpes of business expenditures for a finite and often small pot of
available monev. This competition usually involves applying
conventional accounting techniques and financial tests, such as
requiring that projects demonstrate a payback period that is less
than a certain number of months or years. In this type of situation,
pollution prevention options that require a relativelv high initial
investment often suffer, because the full, long-term environmental
costs and benefits are not considered.
December 1996
10-17
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Pollution Prevention
Part II, Chapter 10
For most pollution prevention options to be found cost-effective, it
is very important to identify and quantify their full, long-term
benefits, and to present them in terms that financial decisionmakers
and upper management can understand. As suggested in Section
10.3.4 under prioritizing waste streams, Chapter 12
(Environmental Cost Accounting) should be read in order to learn
best how to do this. Using that information will provide the best
way to sell the merits of pollution prevention to upper management.
It is also worthwhile to point out that private and government sector
financing for pollution prevention is becoming more available due
to an increasing awareness of its sound business aspects. Check with
some of the resources listed in Section 10.4, particularly state
pollution prevention programs, for information on this type of
financing.
10.3.6 Implement Selected Options
Once an option has been selected, and any necessary funding or
equipment has been obtained, the option may have to be pilot
tested prior to full facility implementation. A pilot test can
highlight any installation or implementation issues, and may also
provide an opportunity for worker training. Also before full
implementation, all employees should be clearly informed of the
importance of the project, the benefits that they can expect to
receive, and the value of their long-term support and cooperation.
Employee support and cooperation is critical to successful
implementation.
One of the keys to employee cooperation in implementation is
worker training. Highly complex systems should be explained to
workers before installation, to gather worker concerns and feedback.
Workers will then know what to expect, and as a result be aware of
any new risks associated with a different process or new materials.
Early discussions will also help to avoid costly mistakes. Should
problems still arise with the changes, workers will then be more able
to adapt, and to mitigate the problems.
10.3.7 Measure and Communicate the Results
It is important to measure the pollution prevention progress against
the established goals and objectives, and to communicate these
results to management and all employees. Measuring the progress
December 1996
10-18
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Pollution Prevention
Part II, Chapter 10
provides a way to demonstrate the presumed benefits of pollution
prevention to all members of the firm, helps to identify the
implemented options that work well and the ones that do not, and
helps to guide future pollution prevention efforts. The data that is
collected should reflect the goals and objectives being measured
(e.g., mass or volume to measure reductions in waste quantity), and
as with gathering the baseline information, the more accurate the
data, the more accurate the results. Frequent communication of
these results can increase upper management's confidence and staff s
stake in the efforts.
Measuring pollution prevention progress can be difficult because
there is often the need to normalize, or correct, the results to
account for factors unrelated to the pollution prevention efforts,
such as the production level. A waste generation change could be
influenced by a change in the production level, and the
determination and use of a productivity or activity index (e.g.,
quantity of product output, or duration of process operation) that
is directly related to quantity of waste can significantly alter the
measurement results: Although it is not easy, failure to find and use
an accurate index can lead to meaningless results. A Research
Triangle Institute (RTI) study on this topic has produced a five-step
process for developing a production-adjusted measurement for
pollution prevention (RTI, 1996).
10.3.8 Keep the Efforts Going
As with many new initiatives that involve a major shift in thinking
and other more concrete changes, keeping the momentum for
pollution prevention efforts in a firm is often the most significant
challenge. And once again, employee support and involvement is
critical to long-term success. Some of the best ways to maintain
employee involvement are to provide ongoing staff education
programs on pollution prevention, continuously solicit input from
all employees on pollution prevention ideas, and reward personnel
for their participation, especially in successful projects (EPA, 1992).
These actions will help to maintain awareness on pollution
prevention.
It is also important to keep the pollution prevention team intact so
they can continue to champion and manage the efforts. On a
regular basis, team members can meet individually with small groups
December 1996
10-19
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Pollution Prevention
Part II, Chapter 10
of employees familiar with particular unit operations to brainstorm
about waste and pollution ideas and to develop ideas. A suggestion
box can aiso be used to solicit ideas outside of these sessions or
anonymously.
10.4 Where Can I Get More Information?
This section lists a wide variety of sources of information on
pollution prevention in metal finishing. There is no shortage of
good resources, and it is recommended that ones be selected to meet
a firm's specific need or situation. Resources include:
¦ State pollution prevention programs
¦ Information clearinghouses and centers
¦ Internet World Wide Web home pages
¦ A pollution prevention training course
The pollution prevention programs and information
clearinghouses/centers all have some metal finishing pollution
prevention expertise. They can locate and possibly provide
documents, and can provide information on other sources of
valuable technical assistance. The Internet Web home pages are for
online information systems on pollution prevention in metal
finishing. The training course will provide comprehensive pollution
prevention instruction for metal finishers.
10.4.1 State Pollution Prevention Programs
During the past several years, the number of state initiatives
designed to encourage pollution prevention in industry has grown
steadily. Like the federal pollution prevention programs, states are
relying on pollution prevention to address their concerns about
issues such as nonattainment of air quality standards, difficulties in
siting hazardous waste disposal facilities, and removal of toxic
substances from municipal treatment plant discharges.
State pollution prevention initiatives differ considerably in terms of
their objectives, methods, state of development, and organizational
December 1996
10-20
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Pollution Prevention
Part II, Chapter 10
structures. Most state programs include outreach and technical
assistance to provide information and assistance to companies
interested in pollution prevention. These programs include services
that help companies find technical information about pollution
prevention in their industry, provide experts to conduct confidential
onsite audits to help companies identify pollution prevention
opportunities, or provide help developing facility pollution
prevention plans. Some states provide financial assistance to
companies for pollution prevention planning or implementation.
These programs are often operated apart from the state's regulatory
programs, and may be linked to university-based centers or small
business assistance programs. A state-by-state list of technical
assistance contacts can be found in Appendix 10-B.
Some states have adopted regulatory approaches that require pollution
prevention facility planning or reporting. A recent review
(WRITAR, 1994) showed that 18 states now require certain
facilities to submit pollution prevention plans. Some of these require
plans from only large facilities (e.g., Arizona, Pennsylvania) while
others require them from all facilities that generate hazardous waste
(e.g., Tennessee, New Jersey, Georgia). Another regulatory
approach used by states is to levy fees on facilities that generate
hazardous waste or use toxic chemicals. These programs provide
economic incentives for reducing chemical use and hazardous waste
generation.
A recent trend in state pollution prevention programs involves
attempts to integrate pollution prevention into permits or other
regulations. These efforts, like those at the federal level, are
designed to ensure that the pollution prevention approach is
incorporated into all environmental activities involving the state.
Table 10-1 provides a summary of pollution prevention programs in
selected states.
December 1996
10-21
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Table 10-1 Summary of Selected State Pollution Prevention Programs
State
AZ
CA
Laws and Regulations
Arizona Revised Statutes
Annotated 49-961, 49-93!
1 lealth and Safety Code
2 524-4.12 ct so]., 22
California Code Regulations
67 100.1 ct seq., 66268 cf vrr/.
Permits, Planning and
Reporting Requirements
Generators of hazardous wastes over the
threshold quantities must submit a report
detailing the following: Pollution
prevention measures, performance goals,
and current activities. Annual progress
reports to be submitted. $l0/ton fee for
hazardous wastes shipped off-site for
generators. $40/ton fee for hazardous
wastes disposed of off-site by generators.
Fees reduced bv 50% for compliant
facilities.
Generators of hazardous wastes over
threshold quantities must submit four
separate reports describing certain details
of operations, waste streams,
opportunities for source reduction, and
implementation timetables every four
vears. Regular progress reports on the
effectiveness of current measures and
estimates of future reductions are to be
included in the generator's biennial
report.
Technical and
Financial Assistance
State-run technical assistance
program provides on-site
technical assistance, sponsors
conferences and workshops, and
helps companies create pollution
prevention plans.
State provides on-site
consultations, training, seminars,
and workshops, supports an
information clearinghouse, and
offers assistance in developing
pollution prevention plans.
UCLA's Pollution Prevention
Center offers on-site technical
assistance as well as cost-sharing
for innovative technologies.
Various regional, county, and
local programs also exist.
State Contact(s)
State of Arizona
Department of Environmental
Quality
Pollution Prevention
3033 North Central Avenue
Phoenix, AZ 8501 2-2809
(602) 207-4210
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California Environmental
Protection Agency
Office of Pollution Prevention and
'I ethnology Development
PO Box 806
Sacramento, CA 958 I 2-0806
322-3670
University of California-Los
Angeles
Pollution Prevention Education
and Research Center
UCLA
405 Hilgard Ave.
Los Angeles, CA 9002-1600
(310) 206-2098
pperc@ea.ucla.edu
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Table 10-1 Summary of Selected State Pollution Prevention Programs
State
CT
l:l.
CIA
Laws and Regulations
(lonnecticut General Statutes
22a-1 34oo, 32-23pp
Florida Statute 403.03 I (8),
403.072 ct seif.
Georgia Code Annotated 12-
8-62, 12-8-65.1
Permits, Planning and
Reporting Requirements
No State pollution prevention planning or
reporting requirements. Resource
conservation a condition of all industrial
wastewater discharge permits, although
no specificity. Generators required to
certify on state manifests that a waste
minimization program exists.
Voluntary Program. No State pollution
prevention planning or reporting
requirements.
Large quantity generators must submit
hazardous waste reduction plans to DNR.
Biennial progress reports required for
reduction plans. Out-of-state large
quantity generators who have wastes
treated, stored or disposed of in Georgia
are required to submit a hazardous waste
reduction plan and biennial progress
reports.
Technical and
Financial Assistance
Pollution prevention technical
assistance provided bv the
Connecticut Technical Assistance
Program (ConnTAP) including:
free on-site evaluations, resource
center, conferences &. workshops.
Financial assistance also available
through ConnTAP using
matching challenge grants and the
Environmental Assistance
Revolving Loan Fund. Assistance
also provided bv the CT DEP.
State DEP offers on-site technical
assistance, a resource library, and
training, seminars, and
workshops.
Various county programs exist.
Georgia Institute of Technology
provides technical assistance.
Services provided upon request
include: hazardous waste
reduction plans, biennial progress
reports
Some assistance is also available
through the state DNR.
State Contact(s)
Connecticut Technical Assistance
Program
50 Columbus Boulevard
Hartford, C: i' 06106
(860)24 I-0777
conntap(Waol.com
Connecticut Department of
Environmental Protection
Bureau of Waste Management
79 Elm Street, 4'1' Floor
Hartford, CT 06106-5127
(860) 424-3297
Florida Department of
Environmental Protection
Pollution Prevention Program
2600 Blair Stone Road
Tallahassee, FL 3299-2400
488-0300
Florida Department of
Environmental Protection
Small Business Assistance Program
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-1344
Georgia Department of Natural
Resources
Pollution Prevention Assistance
Division
7 Martin Luther King, Jr. Drive
Suite 450
Atlanta, GA 30334
651-5120
http://mvw.state.ga.us/Department
S/DNR/P2AD/
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Table 10-1 Summary of Selected State PollutiorrFrevention Programs 1
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Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
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IL
4 1 5 CS 85/1 et seq., Illinois
Administrative Code 181.101
et seq.
No State pollution prevention planning or
reporting requirements. Companies
applying for a state gTant must meet
guidelines.
Illinois Hazardous Waste
Research and Information Center
(HWRIC) provides on-site
technical assistance with
development (results must be
made public), runs an information
clearinghouse, and provides some
grant and loan assistance.
Illinois Environmental Protection
Agency.
Office of Pollution Prevention
2200 Churchill Road
PO Box 19276
Springfield, IL 62794-9276
(217) 782-8700
Illinois Hazardous Waste Research
and Information Center
One East Hazelwood Drive
Champaign, IL61820
(217) 333-8940
IN
Indiana Administrative Code
13-9-1 etseq., 13-7-27-1 et seq.
No State pollution prevention planning or
reporting requirements. Companies
applying for a state grant must meet
guidelines.
Information, training programs,
and grant money are available
through IDEM. A planning
manual is available from the
Pollution Prevention Institute.
Indiana Department of
Environmental Management
Office of Pollution Prevention and
Technical Assistance
100 North Senate Avenue
PO Box 6015
Indianapolis, IN 46206-6015
(317) 232-8172
Indiana Pollution Prevention and
Safe Materials Institute
1291 Cumberland Ave. Suite C1
West Lafayette, IN 47906
(317) 494-6450
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Kentucky Revised Statute
Annotated 224.46-305 et seq.
Voluntary program. No State pollution
prevention planning or reporting
requirements, although waste levels must
reported to state in annual reports. State
has reduction goals of 25% from 1987
levels by 1997 and 50% by 2002.
Technical assistance, conferences,
workshops, and waste audit
procedures are available through
Kentucky Center for Pollution
Prevention (formerly Kentucky
Partners). The center also runs
grant and loan programs.
Kentucky Pollution Prevention
Center
420 Academic Building
University of Louisville
Louisville. KY 40292
(502) 852-0965
http://\vww. louisville.edu/groupVkp
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Table 10-1 Summary of Selected State Pollution Prevention Programs
State
MD
MA
Laws and Regulations
No state law.
Massachusetts Regulations
Code 50.01
Permits, Planning and
Reporting Requirements
Voluntary program participation. No
State pollution prevention planning or
reporting requirements.
A Form S must be submitted annually by
large quantity toxic users (July 1). The
Form S must detail the amount of toxics
used, processed, or manufactured during
the preceding year. An annual fee based
upon the number of full-time employees
and the amount of toxins used, processed,
or manufactured is required with the Form
S submission. A toxic use reduction plan
and a plan summary must be submitted to
the DEP by large quantity toxic users.
Plan updates due to DEP biennially.
Facility employees must be allowed to
comment on initial plans six months
before final due date.
Technical and
Financial Assistance
Information on voluntary
programs available through the
Pollution Prevention Program at
the state Department of the
Environment.
Massachusetts Toxic Use
Reduction Institute provides toxic
use reduction courses, seminars,
and conferences. The Institute
prepares technical assistance
reports and guidelines on toxic
use reduction. Institute provides
training and sponsors pilot
programs demonstrating
innovative toxic reduction
technologies. Small business
focus for assistance programs.
The Massachusetts Executive
Office of Environmental Affairs
provides on-site technical
assistance, planning and
compliance workshops, and some
financial assistance.
State Contact(s)
Maryland Department of
Environment
Pollution Prevention Program
2500 Broening Highway
Baltimore, MD 21224
(410) 631-3165
Massachusetts Department of
Environmental Protection
Office of Program Integration and
Toxics Use Reduction
Implementation
75 Grove St.
Worcester, MA 01605
(508)792-7692, ext. 3775
Massachusetts Executive Office of
Environmental Affairs
Office of Technical Assistance for
Toxics Use Reduction
100 Cambridge Street, Suite 2 109
Boston. MA 02202
(617)727-3260
Toxics Use Reduction Institute
University of Massachusetts at
Lowell
1 University Ave
Lowell, MA 01854-2881
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Table 10-1 Summary of Selected State Pollution Prevention Programs
State
Ml
MN
Laws and Regulations
Michigan Administrative
Code of Regulations 14.528
Minnesota Statutes
Annotated 1 15D.01
Permits, Planning and
Reporting Requirements
Voluntary program participation. No
State pollution prevention planning or
reporting requirements.
Facilities required to file Federal SARA
Title III, Section 313 Form R Report must
prepare a Minnesota toxic pollution
prevention plan
plans must be updated every two years by
January 1. Progress reports on the plan's
effectiveness due each year on October 1
Pollution prevention fees based upon
amount of toxics released are due every
January 1. Fee assessments based on
amount of toxic releases.
Technical and
Financial Assistance
Michigan Environmental
Assistance Division is authorized
to have a waste reduction
information clearinghouse, waste
reduction workshops and on-site
consultations with generators
wanting to implement a pollution
prevention program.
Minnesota TAP conducts on-site
consultations, provides Pollution
Prevention information, training
programs and seminars
Pollution prevention grants are
available through MnTAP.
State Contact(s)
Michigan Department of Natural
Resources
Waste Management Division
530 West Allegan Street
P.O. Box 30241
Lansing, Ml 48909
373-2730
Michigan Department of
Environmental Quality
Environmental Assistance Division
PO Box 30457
Lansing, Ml 48909-7957
Minnesota Pollution Control
Agency
Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
296-8643
Minnesota Pollution Control
Agency
Small Business Assistance Program
520 Lafayette Road
St. Paul, MN 55155
(612)297-7709
Minnesota Technical Assistance
Program (MnTAP)
1315 5"'Street SE, #207
Minneapolis. MN 55414
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Table 10-1 Summary of Selected State PollutiorfePrevention Programs I
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State
Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
O
MO
No state law.
Voluntary program participation. No
State pollution prevention planning or
reporting requirements.
State runs a technical assistance
program and a Governor's Award
for Pollution Prevention.
Information is available through
the DNR.
Missouri Department of Natural
Resources
Technical Assistance Program,
Pollution Prevention Unit
PO Box 176
Jefferson Citv, MO 65102
526-6627
(800) 361-4827
NJ
New Jersey Statutes
Annotated 13:1 D-35
New Jersey Administrative
Code 7:IK-1.1
Facilities required to file Federal SARA
Title 111, Section 313 Form R Report must
prepare a 5-year pollution prevention
plan, pollution prevention summary and
pollution prevention progress report and
submit the information to the OPP.
Progress reports are due each July 1. The
OPP is authorized to designate other
facilities to be subject to the pollution
prevention requirements.
The Office of Pollution
Prevention (OPP) within the
NJDEP provides the Industrial
Pollution Prevention Planning
guidance document. The
document details industry-specific
pollution prevention
opportunities. The OPP will
provide, upon request plans,
summaries or progress reports
submitted to the DEP.
NJTAP offers on-site consultation,
assistance in development of
pollution prevention plans, and
training, seminars, and
workshops.
New Jersey Department of
Environmental Protection
Office of Pollution Prevention
CN423
401 East State Street
Trenton, NJ 08625
(609) 777-0518
New Jersey Technical Assistance
Program for Industrial Pollution
Prevention (NJTAP)
New Jersey Institute of Technology
CEES Building University Heights
Newark, NJ 07102-1982
(210) 596-5864
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Table 10-1 Summary of Selected State Pollutior^Prevention Programs 1
State
Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
NY
New York Compliance Codes
ECL 27-908
Hazardous waste generators must prepare
a Hazardous Waste Reduction Plan
(HWRP). The HWRP must be updated
every two years and submitted to the
DEC. Annual reports detailing the
generator's hazardous wa^tc activities
must include certification that a HWRP is
in place. The annual reports must also
detail the amount of waste and toxicity
reduction during the previous year. The
reports are to certify that hazardous waste
treatment, storage and disposal methods
utilized by the generator are the best
practical methods available. Biennial
updates are required including a re-
evaluation of planned measures, a
schedule revision and new options to
replace inadequate measures.
The New York Environmental
Facilities Corporation has
established a technical assistance
program for hazardous waste
reduction. NYDEC is required to
prepare and distribute a guidance
manual which will assist
generators to prepare their
Hazardous Waste Reduction
Plans (HWRP) and required
annual reports.
New York State Department of
Environmental Conservation
Pollution Prevention Unit
50 Wolf Road
Albany, New York 12233-8010
457-2480
New York State Department of
Economic Development
Environmental Ombudsman Unit
Division for Small Business
1515 Broadway 51" Floor
New York, NY 10036
(212)827-6157
(800) STATE-NY ext. 157
NC
North Carolina General
Statutes 113-8.01
Any facility required to hold a permit
under the Clean Air Act must prepare a
description of any pollution prevention
programs planned or in piace.
The State Industrial Pollution
Prevention Program encourages
voluntary waste and pollution
reduction through research and
technical assistance. Grants and
educational programs available to
all State businesses and
industries.
North Carolina Dept. of Env.,
Health & Natural Resources
Office of Waste Reduction
Industrial Pollution Prevention
Program
PO Box 29569
Raleigh, NC 27626-9569
Parker-Lincoln Building
2728 Capital Blvd.
Raleigh, NC 27604
(919)715-6500
763-0136
http://owr.ehnr.state.nc.us/
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Table 10-1 Summary of Selected State Pollution Prevention Programs
13
O
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State
Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
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OH
Ohio Revised Code Annotated
6111.045
Class 1 underground injection wells
receiving hazardous wastes for disposal
must prepare and implement a 3-year plan
for waste reduction. The plan must
include specific pollution prevention
measures to be taken. An executive
summary must be submitted to OPP every
three years.
Technical and financial assistance
is available through Ohio's Office
of Pollution Prevention.
Ohio Environmental Protection
Agency
Office of Pollution Prevention
PO Box 1049
Columbus, OH 43216-1049
644-3469
http://www.epa. ohio.gov/opp/oppm
ain.html
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27A Oklahoma Statutes 2-11-
201 et seq. 2-1 1-301 et seq.,
Oklahoma Administrative
Code 252:200-17-20 et seq.,
Oklahoma Administrative
Code 252:200-17-1 et seq.
Voluntary program. No State pollution
prevention planning or reporting
requirements. Incentives for participation
include reduction or refund of state in-
house hazardous waste treatment fee and
a one-time tax credit.
State DEQ sponsors an
information clearinghouse. Funds
are available for pilot projects
using innovative technologies.
Oklahoma Department of
Environmental Quality
Pollution Prevention Program
1000 NE 10,h Street
Oklahoma City, OK 731 17-1212
(405) 271-1400
PA
25 Pennsylvania Code 262.80,
25 Code Pennsylvania Code
287.1, 25 Pennsylvania Code
287.51 etseq.
Large quantity hazardous waste generators
and residual generators must prepare and
implement a source reduction strategy.
The strategy must be revised every five
years or in the event of a significant
ch.inge in type of waste generated.
Technical assistance and outreach
education are provided by the
state DEP. Funds are available
for waste minimization research
and hazardous waste recycling
equipment.
Pennsylvania Department of
Environmental Resources
Pollution Prevention Program
PO Box 8472
Harrisburg, PA 17105-8472
787-7382
http://www.dep.state.pa.us/dep/dep
utate/pollprev/pollution_preventio
n.html
Pennsylvania Technical Assistance
Program (PennTAP)
Penn State University
117 Tech Center
University Park, PA 16802
(814) 865-0427
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Table 10-1 Summary of Selected State PollutiofPPrevention Programs
O
r
r
State
Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
c
H
o
z
Rl
Rhode Island General Laws
37-1 5.1 -1
Voluntary program participation. No
State pollution prevention planning or
reporting requirements. Pollution
prevention grant or loan applicants must
meet State requirements for grants or
loans.
Grants and loans available for
pollution prevention from
RIDEM. The DEM coordinates
and encourages voluntary
recycling of hard-to-dispose
materials. The DEM also
coordinates disposal and recycling
organizations who specialize in
hard-to-dispose materials.
State of Rhode Island
Department of Environmental
Management
Pollution Prevention Program
83 Park Street
Providence, RI 02903-1037
277-3434
University of Rhode Island
Rhode Island Center for Pollution
Prevention
Crawford Hall Chemical
Engineering Department
Providence, RI 02908
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SC
No state law.
Voluntary program participation. No
State pollution prevention planning or
reporting requirements.
State offers training and on-site
assessments through the Center
for Waste Minimization.
South Carolina Department of
Health and Environmental Control
Center for Waste Management
2600 Bull St.
Columbia, SC 29201
(803) 734-4761
TN
Tennessee Compiled Rules
and Regulations 68-212-301
el seq.
Large quantity hazardous waste generators
and facilities must prepare a hazardous
waste reduction plan, an annual progress
report, and a summary. The summary
must be submitted to Tennessee DEC;
plan and progress report must be kept on-
site.
On-site technical assistance,
pollution prevention workshops,
an information clearinghouse, and
a guidance document for
preparing waste minimization
plans are provided by the state.
Tennessee Department of Health
and Environment
Division of Pollution Prevention
and Environmental Awareness
8'" Floor
LNC Annex
401 Church St.
Nashville, TN 37243-1551
Tennessee Valley Authority
Industrial Waste Reduction
400 West Summit Hill Drive
Knoxville, TN 37902-1499
(615) 632-8489
Part II, Chapter 1
-------
Table 10-1 Summary of Selected State PollutiorLPrevention Programs
State
Laws and Regulations
Permits, Planning and
Reporting Requirements
Technical and
Financial Assistance
State Contact(s)
TX
Texas Compliance Rules and
Regulations 68-212-301
Large quantity generators of hazardous
waste and facilities filing a Form R under
SARA Title III, Section 313 must prepare
a source reduction and waste
minimization plan (for a 5-year period)
with an executive summary of plan.
Annual progress reports required. Small
quantity generators can prepare an
executive summary of plan to serve as
complete plan. Summary and progress
reports are to be submitted to TNRCC.
Plans must be available on-site for
TNRCC Inspections.
State offers pollution prevention
workshops, on-site technical
assistance, information
clearinghouse. A guidance
document is available for the
preparation of a waste
minimization plan. Information
on waste minimization
technologies and procedures is
available. Some loan assistance is
available through the Small
Business Advocate.
Texas Natural Resource
Conservation Commission
Office of Pollution Prevention and
Recycling
PO Box 13087
Austin, TX 7871 1-3087
239-3100
http://www.tnrcc.state.tx. us/exec/op
pr/index.html
Texas Natural Resource
Conservation Commission
Small Business Technical
Assistance Program
PO Box 13087
Austin, TX 78711-3087
239-1 112
(800) 447-2827
WA
Washington Administrative
Code
173-307-0 \0ctscq.
Facilities required to file Form R under
SARA Title III, Section 313 (excluding
those distributing fertilir"»rs for
commercial agricultural use), and
generators of more than 2,640 lbs of
hazardous waste annually, must prepare a
reduction plan, an executive summary of
the plan and a progress report. The
summary must be submitted to WDOE.
The progress report shall be submitted
annually on September 1. Fees required.
Advice, consultation, information,
and workshops are provided by
WDOE's Hazardous Waste and
Toxics Reduction Program.
Washington State Department of
Ecology
Hazardous Waste and Toxics
Reduction Program
PO Box 47600
Olympia, WA 98504
(360) 407-6086
http://www.wa.gov/ecology/
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Table 10-1 Summary of Selected State PollutioirPrevention Programs
State
Wl
Laws and Regulations
Wisconsin Statutes 144.995,
560.19
Administrative Code NR
615.09, 630.32
Permits, Planning and
Reporting Requirements
Hazardous waste treatment, storage, and
disposal facilities (TSDFs) owners or
operators must sign a waste minimization
certification each year stating that a waste
minimization program is in place to
reduce the volume and toxicity of
hazardous waste. A review of waste
minimization efforts during the past year
and a year-to-year comparison of waste
reduction efforts must be included on the
TSDF's yearly hazardous waste activity
report.
Technical and
Financial Assistance
The Solid and Hazardous Waste
Education Centers of the
University of Wisconsin
Extension provide education and
technical assistance programs on
how to establish and maintain a
pollution prevention program in
collaboration with the DNR.
State Contact(s)
Wisconsin Department of Natural
Resources
Bureau of Pollution Prevention
101 South Webster Street
P.O. Box 7921 TS/6
Madison, WI 53707
267-9700
Solid and Hazardous Waste
Education Center (SHWEC)
University of
Wisconsin Extension
610 Langdon Street Rm 529
Madison, Wl 53703
(608)265-2360
(414)475-2845
U
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Pollution Prevention
Part II, Chapter 10
10.4.2 Information Clearinghouses and Centers
EPA Pollution Prevention Information Clearinghouse
401 M Street, SW (7409)
Washington, DC 20460
(202) 260-1023
Great Lakes Pollution Prevention Center
265 N. Front St., Suite 112
Samia, ON N7T 7X1
(800) 667-9790
Hazardous Waste Research and Information Center Library and
Clearinghouse
One East Hazelwood Drive
Champaign, Illinois 61820
(217) 333-8940
Northeast Waste Management Officials Association
Clearinghouse
129 Portland Street
Boston, MA 02114
(617) 367-8558
Pacific Northwest Pollution Prevention Resource Center
1326 Fifth Ave, Suite 650
Seattle, WA 98101
(206) 223-1151
Toxics Use Reduction Institute Clearinghouse
University of Massachusetts - Lowell
One University Avenue
Lowell, MA 01854-2881
(508) 934-3275
Waste Reduction Resource Center
3825 Barrett Drive, Suite 300
PO Box 27687
Raleigh, NC 27611-7687
(919) 715-6500
December 1996
10-33
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Pollution Prevention
Part II, Chapter 10
10.4.3 Internet World Wide Web Home Pages
National Metal Finishing Resource Center (NMFRC)
h ttp://cai. eclipse. netfhome2 .htm
This on-line system provides "one-stop," up-to-date information for
metal finishers and others about technical and compliance-related
issues that affect their operations. The goal is to give direct,
"customer-oriented" assistance to metal finishers to help them to
reduce pollution, promote manufacturing efficiency, and achieve full
compliance with all applicable environmental laws and regulations.
For more information, call Scott Throwe at the U.S. EPA, (202)
564-7013.
Pollution Prevention Information Resource for Industrial Sectors
(P2 IRIS)
http://wvm.p2 iris.com
This on-line system provides information on qualified, cost-effective,
industry- and process-specific technologies and business practices for
pollution prevention. The initial version contains information on
three industry sectors: electroplating, printing, and metal painting
and organic coatings. For more information, call Greg Hume at the
Institute of Advanced Manufacturing Sciences, Inc., (513) 948-
2017.
10.4.4 Pollution Prevention Training Course
This course will provide comprehensive pollution prevention
instruction for electroplaters and metal finishers through a series of
training modules designed for presentation over a four day period.
The target audience is primarily managers and operators of metal
finishing facilities, and the material will be available in English and
Spanish. Material topics include: plant assessment procedures;
process-specific pollution prevention options; economic evaluation;
and case studies of successful applications. The course is scheduled
to be available by September, 1997. For more information, call
AESF at (407) 281-6441.
December 1996
10-34
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Pollution Prevention
Part II, Chapter 10
10.4.5 References
Canadian Association of Metal Finishers, et al. 1995. Metal
finishing pollution prevention guide. Canada. September.
Northeast Waste Management Officials' Association. 1996.
Pollution prevention for the metal finishing industry. November.
Pojasek, R.B. 1993. "Looking beyond the manufacturing process
for opportunities to prevent pollution," Pollution Prevention Review,
Autumn, pps. 469-473.
Pojasek, R.B. 1996. Integrating pollution prevention into an existing
quality improvement program. Cambridge Environmental Inc.
February 12.
Research Triangle Institute. 1996. Developing and Using Production-
Adjusted Measurements of Pollution Prevention. July. Draft.
U.S. Environmental Protection Agency. 1992. Facility pollution
prevention guide. EPA/600/R-92/088. May.
Waste Reduction Institute for Training and Applications
Research. 1994. Summary of state pollution prevention legislation.
Waste Reduction Institute for Training and Applications
Research. 1996. Applying environmental cost accounting in the metal
finishing industry: an in-depth analysis. October. Draft.
December 1996
10-35
-------
APPENDIX 10-A
BEST MANAGEMENT PRACTICES FOR
POLLUTION PREVENTION IN THE
METAL FINISHING INDUSTRY
-------
Pollution Prevention
Part II, Chapter 10
The focus of this appendix is on specific waste streams and potential opportunities for
pollution prevention that are applicable to these waste streams. BMPs are grouped
under four different process areas:
¦ Box 10A-1 Spent Plating Solutions
¦ Box 10A-2 Drag-Out Reduction
¦ Box 10A-3 Drag-Out Recovery
¦ Box 10A-4 Rinse Water
December 1996
10-A1
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Pollution Prevention
Part II, Chapter 10
Box 10A-1 Spent Plating Solutions
General Bath Life Extension
Extending the useful life of a process bath is an effective means of source reduction of waste. Spent
baths must be treated either offsite or onsite by the waste treatment system. Several methods of
extending bath life are described below.
Filtration: The accumulation of solids reduces the efficiency of the process bath, and removal of these
contaminants can extend the life of the bath. Various types of equipment are used to remove
suspended solids from plating solutions, with the most common being cartridge filters and precoat
(diatomaceous earth) filters. Cartridge filters are available in either in-tank or external
configurations. Most cartridges are disposable, but washable and reusable filters are now available.
Carbon Treatment: Carbon treatment of plating baths can be used to remove organic contaminants,
either on a continuous or batch basis. The carbon adsorbs organic impurities and is periodically
changed and disposed of. The most common applications reported in one study were nickel
electroplating (mostly Watts nickel and nickel sulphamate), followed by copper electroplating
(mostly copper cyanide and copper sulphate), zinc plating, and cadmium cyanide plating,
respectively.
Replenishment: The effectiveness of a bath decreases with use, but control may be achieved by
disposing of only a portion of the bath and replenishing the remainder with fresh chemicals and
water. This practice can help to extend bath life, and there are various automated bath monitoring
and replenishing systems currently available for this purpose. Alternatively, baths can be adjusted
manually by the operator after monitoring keybath characteristics, such as pH or metal
concentration.
Purified Water: Natural contaminants found in tap water, such as calcium, iron, magnesium,
manganese, chlorine, carbonates, and phosphates have a deleterious effect on plating operations.
These substances reduce rinse water efficiency and decrease the potential for drag-out recovery. In
process baths, these contaminants decrease bath life and thereby increase the frequency of process
bath dumping. In addition, these contaminants increase the volume of sludge produced in a
conventional wastewater treatment system. It is therefore advantageous to utilize purified water for
process bath makeup and rinsing. Purification may be accomplished by deionization, distillation, or
reverse osmosis. In addition, purified water may permit reuse options that are not possible with tap
water. This in turn may reduce the size of the water purification system required as compared to
current water use.
Electrolytic Dummying: Some metal contaminants that enter the plating bath with the workpiece can
sometimes be selectively plated out by a process called "dummying." A trickle current is run through
the system, and the selected removal of the contaminant metal extends the bath life. The
contaminant metals that are most commonly plated out are copper, zinc, iron, and lead. Treatment
can be batch or continuous, with batch treatment usually performed in the process tank during down-
time.
December 1996
10-A2
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Pollution Prevention
Part II, Chapter 10
Box 10A-1 Spent Plating Solutions
Cyanide Bath Carbonate Freezing: Carbonates are formed in cyanide baths by the breakdown of
cyanide, excessive anode current densities, and the adsorption of carbon dioxide from the air.
Excessive carbonates increase the resistance in the bath, resulting in low plating current densities and
adversely affecting the smoothness of deposits, plating efficiency, and plating range. Carbonates can
be removed from sodium cyanide baths by lowering the bath temperature to approximately -30 °C,
where the low solubility of the carbonate salt results in crystallization, permitting subsequent removal
from the bath.
Precipitation: Some metal contaminants that enter the plating bath as impurities in anodes can be
removed from certain plating baths by chemical precipitation. The precipitate can then be removed
by bath filtration. Precipitation is an alternative method to carbonate freezing for cyanide baths and
is especially applicable to potassium cyanide baths. Chemicals used for this purpose include barium
cyanide, barium hydroxide, calcium hydroxide, caJcium sulphate, or calcium cyanide.
Monitoring: Continuous or frequent monitoring of bath parameters can permit the determination of
the need for chemical addition or contaminant removal. More frequent bath maintenance can
prolong bath life.
Housekeeping: The prevention of bath contamination by foreign material can significantly prolong
bath life. Prompt removal of dropped parts, good rack cleaning, and incoming air filtration are
examples of good housekeeping practices.
Drag-In Reduction: The liquid from the preceding bath that adheres to the workpiece and gets
dragged-in to the subsequent tank reduces bath life and effectiveness. Rinsing helps prevent cross-
contamination of process baths by removing drag-out into the rinse bath, so that the drag-in to the
next process bath is only rinse water.
Purer Anodes and Bags Impurities in anodes will contaminate a process banh. The anodes can be
immersed in cloth bags to prevent insoluble impurities from entering the bath, but the bags must be
compatible with the process solution and must be regularly maintained. Alternatively, more
expensive but more pure anodes may be used, which would decrease this source of bath
contamination.
Ventilation/Exhaust Systems: Ventilation and exhaust systems can generate waste and increase bath
losses. If segregated, some wastes from scrubbers can be filtered and returned to the process bath.
Process baths that generate mist should be in tanks with more freeboard in order to reduce the
amount of mist that reaches the ventilation system. Foam blankets and polypropylene balls can also
be used for this purpose.
Specific Practices to Extend Bath Life
Hexavalent Chrome Alternatives: Trivalent chromium plating solutions can be used for decorative
plating to replace hexavalent chromium. The use of trivalent chromium eliminates the reduction step
in the wastewater treatment process, and eliminates the problems associated with hexavalent
chromium bath misting. In addition, trivalent chromium baths operate with a lower viscosity and
lower concentration than do hexavalent baths, thus decreasing bath drag-out. Chrome conversion
coatings for paint pretreatments can sometimes be replaced by nonchrome conversion coatings or no-
rinse chrome chemistries.
December 1996
10-A3
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Pollution Prevention
Part II, Chapter 10
Box 10A-1 Spent Plating Solutions
Nonchelated Process Chemistries: Chelators are used in process baths in order to control the
concentration of free metal ions in the solution. Unfortunately, chelating compounds inhibit the
precipitation of metals so that additional chemicals must be used in wastewater treatment, which
consequently increases sludge volume. Also, some spent process baths contain chelators which mav
not be effectively treatable onsite, resulting in increased hazardous waste disposal costs. Nonchelated
process chemistries can be used for some cleaning processes in which it may not be necessary to keep
metals that have been removed from the workpiece surface in solution. These metals can be allowed
to precipitate but must then be removed by filtration. Continuous filtration of the nonchelated
process bath results in increased operating costs, but savings will be realized in reduced waste
treatment and handling costs.
Noncyanide Process Chemicals: Waste streams containing free cyanide are typically treated using sodium
hypochlorite or chlorine to accomplish oxidization, and complex cyanides are commonly precipitated
using ferrous sulphate. These chemicals contribute to sludge volume, so that using noncyanide
process chemistries may both eliminate a treatment step and reduce sludge volume. Many
noncyanide processes are difficult to treat, however, and produce more sludge than cyanide baths.
Therefore, users will have to determine the specific advantages and disadvantages of switching
processes in their facility.
Solvent Degreasing: Solvent degreasing of workpieces before processing may be replaced by hot
alkaline cleaning baths. Solvent use requires offsite recycling or disposal, or onsite recycling with
only solvent sludge disposal offsite, whereas alkaline baths can be treated onsite. The effectiveness of
alkaline cleaners can be enhanced by applying an electrocurrent or ultrasonics, and the benefits of
avoiding solvent vapors and sludges often outweigh an additional operating costs.
Alkaline Cleaners: Alkaline cleaners are typically discarded after the accumulation of oil, grease and
soils from use. reach a level u hich impairs the cleaning efficienc • of the bath. Several means are
available for removing these contaminants and thereby extending the life of the bath. Free-floating
oils can be removed by simple skimming devices. Particulates can be removed by settling and/or
cartridge filtration. Some emulsified oil (as well as free oil) can be removed by an oil-water coalescer.
However, the most effective means of alkaline cleaning bath filtration is to use microfiltration or
ultrafiltration. With these membrane technologies, the emulsified oils from the cleaning bath are
separated from the aqueous cleaning solution, resulting in a small residual of oily-water waste
(typically 10% of the original bath volume) and a recycled cleaner requiring only fortification. Cost
savings result from a decrease in new cleaner purchases and a reduction in spent cleaner requiring
treatment or offsite disposal.
Caustic Etch Solution Regeneration: Dissolved aluminum can be removed from a caustic etch bath by
precipitating the aluminum as a hydrate which can be reused in a number of applications.
Acid Purification: The bath life of sulfuric acid anodizing solutions can be extended indefinitely by
removing the dissolved aluminum using a specialized ion exchange process.
December 1996
10-A4
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Pollution Prevention
Part II, Chapter 10
Box 10A-2 Drag-Out Reduction
Reducing the volume of drag-out from process baths serves to reduce the amount of valuable process
chemicals that contaminate the rinse water, which in tum reduces the amount of sludge that is
generated by a conventional metal precipitation treatment system. Several methods of reducing drag-
out are discussed in general terms below.
Process Bath Operating Concentration: Drag-out can be reduced by keeping the chemical concentration
of the process bath at the lowest acceptable operating level, since the greater the concentration of
chemicals in solution, the greater the viscosity. Consequently, the film that adheres to the workpiece
as it is removed from the process bath is thicker and requires more time to drain back into the
process tank. In addition, the chemical concentration of the drag-out film is greater.
Process Bath Operating Temperature: The viscosity of the process solution can be reduced by increasing
the bath temperature, which in turn reduces drag-out since the film drains from the workpiece more
quickly. However, a limit on the operating temperature is usually imposed by the brighteners which
break down, and—in cyanide solutions—by the increased buildup of carbonates. Operating process
baths at higher temperatures increases the evaporation rate from the tank, and water from the
following rinse tank can be used to replenish the process bath.
Wetting Agents: Wetting agents can be added to a process bath in order to reduce the surface tension
of the solution and thereby reduce the drag-out loss. However, wetting agents can create foaming
problems in process baths, and bath chemistries should be evaluated for their compatibility with
wetting agents. Also, the effect of these agents on the wastewater treatment or rinse water recovery
system needs to be assessed:
Workpiece Positioning: Drag-out loss can be reduced by strategic positioning of the workpiece on the
rack. Workpieces should be oriented so that the adhering film drains freely and does not get trapped
in cTooves or cavities. Parts should be tilted so that drainage is consolidated, since fluid flowing
together in a preferred route will drain more quickly. Parts should not be positioned direcdy over one
another in order to avoid drainage onto the part below. Finally, the workpiece should be oriented so
that only a small surface area contacts the solution surface as the workpiece is removed from the
process bath.
Withdrawal and Drainage Time: The faster a workpiece is removed from the process bath, the thicker
the film on the workpiece surface and thus the greater the drag-out volume. The effect is so
significant that it is believed that most of the time allowed for drainage of a rack should instead be
used for withdrawal only.
Air IOiives: As the workpiece rack is raised above the process tank, air can be blown at the workpieces
to improve the drainage of the drag-out solution into the process bath. High humidity air can be
used in order to counteract workpiece drying.
Spray or Fog Rinses: Spray or fog rinse systems can be used above heated baths to recover drag-out on
the workpiece. Purified water should be used for these systems in order to reduce bath
contamination from the rinse water. The spray rinse flow rate should be adjusted to be equal to the
evaporation rate of the tank so that the spray rinse is used to replenish the process bath.
December 1996
10-A5
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Pollution Prevention
Part II, Chapter 10
Box 10A-2 Drag-Out Reduction
Plating Baths: Contaminated plating baths can increase drag-out by as much as 50 percent because of
the increase in solution viscosity (for example, a cyanide plating bath contaminated with carbonate).
Consider freezing out carbonates. Organic contaminants can be removed with activated carbon
filters. Quick removal of fallen workpieces helps to prevent contaminant accumulation. Avoid drag-
in of contaminants. See also Bath Life Extension.
Drainage Boards: Drain boards capture process solution that drips from the workpiece rack as it is
moved from the process bath to the rinse system, and return the solution to the process bath. Drain
boards should cover the space between the process tank and the rinse tank which also serves to
prevent drippage onto the floor. Removable drain boards have the advantage of still permitting
access to the space between the tanks.
Drag-Out Tanks: Drag-out tanks, also called dead or static rinse tanks, are essentially rinse tanks that
operate without a continuous flow of water and the workpiece is placed in the drag-out tank before
the standard rinsing operation. Thus, drag-out from the process bath is captured in the drag-out
tank, where the chemical concentration increases over time. Eventually, the chemical concentration
in the drag-out tank will increase to the point where it can be used to replenish the process tank. For
this reason, drag-out tanks are primarily used in conjunction with process baths that operate at an
elevated temperature where evaporation is significant. Purified water should be used in the drag-out
tank so that contaminants do not build up in the process bath where the drag-out solution is used for
replenishment.
December 1996
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Pollution Prevention
Part II, Chapter 10
Box 10A-3 Drag-Out Recovery
Recovering the drag-out from process baths offers the potential for significant savings due to the
reduction of bath replenishment costs and the reduction of wastewater treatment requirements.
Several methods of recovering drag-out are discussed in general terms below.
Evaporation: Evaporators can be used for recovery of chemicals in rinse water. The evaporator usually
operates off the plating bath, in order to enhance the rate of evaporation of water from the bath to
make room for the addition of the rinse overflow from the first rinse tank. The most common uses
are for chromium and nickel plating baths. Atmospheric evaporators are the most common, which
operate at atmospheric pressure and elevated temperatures. Vacuum evaporators are a more
expensive alternative, but they are more energy efficient and they recover the water vapor for use as
make-up water. In addition, vacuum evaporators can be used for solutions that are heat sensitive, or
for alkaline cyanide solutions where the buildup of carbonates is problematic due to the aeration used
in atmospheric evaporators.
Ion Exchange: Ion exchange is a chemical reaction wherein an ion from solution is exchanged for a
similarly charged ion attached to a resin bed. Ion exchange can be used for chemical recovery of rinse
water, or in select cases for plating bath maintenance. With rinse water recovery, both an anion and
cation exchange resins are used in order to"deionize" the water; the rinse water can be recirculated in
a closed loop. When the capacity of the unit is reached, the resin is "regenerated" and the ions are
concentrated into a manageable volume of solution. Ion exchange has been used for rinse water
recovery with nickel plating, chromium plating, noncyanide zinc plating, cadmium cyanide plating
and gold cyanide plating.
The major use of ion exchange in plating bath maintenance is for the removal of iron and trivalent
chromium from hexavalent chromium plating solutions. These cations reduce the performance of the
bath, but can be removed by ion exchange while the chromate anions remain in solution. Ion
exchange can also be user to remove metals dragged out of electrolytic baths for anodized aluminum.
Electrowinning: Electrowinning is an electrolytic process whereby the dissolved metals in the solution
are reduced and deposited on the cathode. The deposited metal is subsequently recovered either by
scraping or chemical means, for reuse as anode material or for offsite refining/reuse. Electrowinning
can thus be used to recover metal from a drag-out tank, allowing return of the "electrowinned"
solution to the rinse tank. However, because electrowinning does not remove all dissolved solids, the
drag-out solution must periodically be purged in order to control the accumulation of dissolved solids.
Electrowinning is used in a wide variety of plating applications, including gold, silver, copper,
cadmium, and zinc plating operations.
Electrodialysis: Electrodialysis utilizes ion-permeable membranes and applied current in order to
separate ionic species from an aqueous solution. It is primarily used for recovery of nickel from rinse
tanks, where it allows the return of concentrated nickel solution to the plating bath. The potential
advantage of electrodialysis is that the selectivity of the membrane can be chosen so as to permit the
recovery of desirable plating bath organic constituents (such as saccharin), while inhibiting the
recovery of some undesirable organic materials that would otherwise accumulate. Thus,
electrodialysis can be more effective than other recovery methods such as evaporation and reverse
osmosis.
December 1996
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Pollution Prevention
Part II, Chapter 10
Box 10A-3 Drag-Out Recovery
Reverse Osmosis: Reverse osmosis is a separation process that utilizes a semipermeable membrane to
produce purified water and a concentrated ionic solution from a feedstock of dilute solution. High
pressure is used to force the water through the membrane, while most dissolved salts are retained by
the membrane. The concentrated components can be recovered and then returned to the process
bath, and the treated water can be reused as a high quality source of rinse water. The most common
application of reverse osmosis in the metal finishing industry is in the recovery of drag-out from
nickel plating solutions. The advantages of this technology over competing processes (such as
evaporation) are that it is a low temperature, low energy process, which generates a recovered water
stream of acceptable quality for reuse as rinse water. The drawbacks are that the membranes can be
fouled by suspended solids and/or precipitation products, necessitating cleaning or replacement, and
that the membranes have a limited lifetime. Furthermore, reverse osmosis concentrates (and thus
returns to the process) both essential plating chemicals and unwanted impurities, unless some post-
treatment is performed, but this aspect is common to other recovery options as well.
Meshpad Mist Eliminators: Meshpad mist eliminators are used to recover plating chemicals that are
entrained in the exhaust gas from the plating tank. They are most commonly used with chromic acid
baths, but are also used with caustic, cyanide, hydrochloric acid, nitric acid, and sulphuric acid baths.
Mist eliminators are an alternative to scrubbers, and they are typically used in a dedicated manner,
with one mist eliminator installed within the exhaust system duct work of each plating tank. This
configuration makes return of the captured chemicals to the plating tank more feasible than with a
scrubber which may service multiple exhaust streams.
December 1996
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Pollution Prevention
Part II, Chapter 10
Box 10A-4 Rinse Water
Most of the hazardous waste produced in a metaJ finishing facility comes from wastewater generated
by the rinsing operations that follow cleaning and plating operations. By increasing rinse efficiency, a
facility can significantly reduce wastewater flow with savings resulting from the cost of water and
wastewater treatment. Treatment chemical use and sludge generation should be reduced, with the
amount dependent on rinse water hardness and the sludge precipitation chemicals used. Also,
clarification and filtration efficiency should be increased, as should the overall treatment plant spare
capacity.
Improved Rinsing Efficiency: There are three basic strategies which can be used to enhance the rinsing
process. First, turbulence can be generated between the workpiece and the rinse water. Second, the
contact time between the workpiece and the rinse water can be increased. Finally, the volume of
rinse water in contact with the workpiece can be increased. This third strategy, however, which
requires the use of more rinse water, runs counter to the objective of reduced water usage and thus
will not be pursued here.
¦ Spray Rinses and Rinse Water Agitation: Spray rinses and rinse water agitation can be used to
create turbulence at the workpiece surface. A spray rinse alone may not provide sufficient
cleaning for some workpieces, and therefore may be used in conjunction with an immersion
rinse as described above under spray or fog rinses. Alternatively, workpieces can be agitated
in the rinse water by moving the workpiece rack or creating turbulence in the water. Hand
rack lines permit rack movement by the operator, with movement into and out of the rinse,
tank being most effective. The rinse water itself can be agitated with forced air or water. Air
bubbles create the best turbulence for removing the process solution from the workpiece
surface, but misting caused by the air bubbles breaking at the liquid surface may result in air
pollution.
¦ Increased Contact Time: The feasibility of increasing the contact time between the workpiece
and the rinse water will be different for each facility. Rotation plating increases contact time
by allowing operators to leave workpiece racks in the rinse water while they handle other
racks. Multiple rinse tanks also permit an increase in contact time, as discussed below.
¦ Countercurrent Rinsing: Multiple rinse tanks can be set up in series in order to significantly
reduce the amount of rinse water used. In countercurrent rinsing, the workpiece flow moves
in the opposite direction to the rinse water flow. The rinse water overflow from the last tank
is used as the feed to the preceding tank, and so on for the number of tanks in the series with
only the overflow from the first tank going out of the system. The obvious limitation on the
applicability of this method of rinse water reduction is the availability of floor space for the
added tanks.
Ffow Controls: Rinse water control devices can increase the efficiency of a rinse water system by
eliminating excessive water use. Oversized piping permits the rinse water flow rate to be increased
beyond that necessary for effective rinsing, which wastes water and therefore should be deterred. In
addition, controls can be put in place to ensure that rinse water is not left running when the rinse
tanks are not being used.
¦ Flow Restrictors: Flow restrictors limit the volume of rinse water flowing through a rinse
system by maintaining a constant flow of fresh water through a rinse system once the optimal
flow rate has been determined. These restrictors can also be used upstream to ensure that
operators must turn off unused rinse systems in order to operate another rinse system.
December 1996
10-A9
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Pollution Prevention
Part II, Chapter 10
Box 10A-4 Rinse Water
¦ Conductivity-Actuated Flow Controllers: These devices control the fresh water flow through a
rinse system by means of a conductivity sensor that measures the level of ions in the rinse
water. When the ion level reaches a preset minimum, the sensor activates a valve that shuts
off the flow of fresh water to the rinse system. When the concentration builds up to the
preset maximum level, the sensor again activates a valve to resume the flow of fresh water.
Recycling/Recovery-. Recycling and recovery technologies either directly use waste from one process as
raw material for another process or recover valuable materials from a waste stream before they are
disposed. Segregating waste streams is essential for most recycling and recovery technologies, since
other wastes if mixed in can disrupt the reuse or recycling process. The chemical properties of a
waste stream must be understood in order to assess the potential for reuse/recycling or recovery.
¦ Rinse Water: After rinse baths become too contaminated for their original purpose, they may
be useful for other rinse processes. For example, the effluent from a rinse following an acid
cleaning bath may be reusable as an influent to a rinse system following an alkaline cleaning
bath (known as reactive rinsing). Reusing rinse water in this way can improve rinse efficiency
by accelerating the diffusion process and reducing the viscosity of the alkaline drag-out film;
Care must be exercised to ensure that tank materials and pipes are compatible with the rinse
solutions. The assessment team should evaluate the various rinse water requirements for
their process lines and determine how they can take advantage.of rinse,water reuse
opportunities that do not affect product quality.
¦ Spent Process Baths: Typically, spent acid or alkaline solutions are dumped, when
contaminants exceed an acceptable level. These solutions, if they remain sufficiently acidic or
alkaline, may be useful as pH adjusters in the treatment operations. However, it is important
to ensure that the process solutions are compatible before they are used in this manner.
Alternatively, chemical suppliers may have reclamation services, some of which permit certain
spent plating baths to be returned.
¦ Solvents: Solvents can be recycled offsite as part of a package solvent service, which may be
cost-effective for low volume users. High volume users of solvent cleaners can recycle solvent
waste onsite using distillation technologies. Clean solvent is obtained after boiling and
condensation, leaving only a still bottom or sludge that must be handled as a hazardous
waste.
December 1996
10-A10
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APPENDIX 10-B
STATE POLLUTION PREVENTION PROGRAMS
-------
State Pollution Prevention Programs'
EPA Region 1
Connecticut Technical Assistance Program
(ConnTAP)
50 Columbus Blvd. 4th floor
Hartford, CT 06106
Phone: 203/241-0777
Fax: 203/244-2017
Contact: Rita Lomasney
Maine Department of Environmental
Protection
State House Station #17
Augusta, ME 04333
Phone: 207/287-281 1
Fax: 207/287-7826
Contact: Ronald Dyer
Maine Waste Management Agency
160 Capitol Street, SHS# 154
Augusta, ME 04333-0154
Phone: 207/287-5300
Fax: 207/287-5425
Contact: Gayle Briggs
Massachusetts Department of Environmental
Protection
1 Winter Street
Boston MA 02108
Phone: 617/292-5870
Contact: Suzi Peck
Massachusetts Department of Environment
Office of Technical Assistance
100 Cambridge Street
Boston, MA 02202
Phone: 617/272-3260
Contact: Barbara ICelley
Toxics Use Reduction Institute
University of Massachusetts at Lowell
1 University Ave
Lowell, MA 01854
Phone: 508/934-3346
Fax: 508/934-3050
Contact: Janet Clark
Rhode Island Department of EnvironmentaJ
Management
Office of Environmental Coordination P2
Section
83 Park Street
Providence, RJ 02903
Phone: 401/277-3434
Fax: 401/277-2591
Contact: Richard Girasole, Jr.
Vermont Department of Environmental
Conservation
Pollution Prevention Division
Hazardous Materials Div West Office Building
103 South Main Street
Waterbury, VT 05676 Phone: 802/241-3888
Fax: 802/241-3296
Contact: Paul Van Holiebeke
EPA Region 2
New Jersey Department of Environmental
Protection
Office of Pollution Prevention
CN423; 401 East State Street
Trenton, NJ 08625
Phone: 609/777-0518
Fax: 609/777-1330
Contact: Jeanne Herb
New Jersey Technical Assistance Program for
Industrial Pollution Prevention
(NJTAP)
CEES Building University Heights
Newark, NJ 07102-1982
Phone: 201/596-5864
Fax: 201/596-6367
Contact: Kevin Gashlin
New York State Department of Environmental
Conservation
Pollution Prevention Unit
50 Wolf Rd
Albany, NY 12233-8010
Phone: 518/457-2480
Fax: 518/457-2570
Contact: William F. Eberle
1 Source: National Pollution Prevention Roundtable's Yellow Pages. Available on the World Wide Web at
http://es.Lnel.gov/program/regional/rndtable/Lndex.htnil. Last update: January 11, 1996.
December 1996
10-B1
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State Pollution Prevention Programs (cont.)
Pennsylvania Department of Environmental
Resources
Source Reduction Program
P.O. Box 8472
Harrisburg, PA 17105
Phone: 717/787-7382
Fax: 717/787-1904
Contact: Meredith Hill
Pennsylvania Technical Assistance Program
Penn State University
117 Tech Center
University Park, PA 16802
Phone: 814/865-0427
Fax: 814/865-5909
Contact: Jack Gido
EPA Region 3
Delaware Department of Natural Resources and
Environmental Conservation
Pollution Prevention Program
P.O. Box 1401
89 Kings Highway
Dover, DE 19903
Phone: 302/739-6242
Fax: 302/739-5060
Contact: Andrea Farrell
Virginia Department of Environmental Quality
Office of Pollution Prevention
P.O. Box 10009
Richmond, VA 23240-0009
Phone: 804/762-4344
Fax: 804/762-4346
Contact: Sharon K. Baxter
West Virginia Division of Environmental
Protection, Office of Water Resources
Pollution Prevention Services
2006 Robert C. Byrd Dr.
Beckley, WV 25801-8320
Phone: 304/256-6850
Fax: 304/256-6948
Contact: Barbara Taylor
EPA Region 4
Alabama Department of Environmental
Management
Special Projects
P.O. Box 301463
Montgomery, AL 36130-1463
Phone: 205/260-2777
Fax: 205/260-2795
Contact: Gary Ellis
Florida Department of Environmental Resource
Mgmt
Pollution Prevention Program
33 SW Second Ave., Suite 800
Miami, FL 33130
Phone: 305/372-6804
Fax: 305/372-6729
Contact: Lori Cunniff
Georgia Department of Natural Resources
Pollution Prevention Assistance Division
7 Martin Luther King, Jr. Drive Suite 450
Adanta, GA 30334
Phone: 404/651 -5120
Fax: 404/651-5130
Contact: G. Robert Ken-
Kentucky Partners
State V aste Reduction Center
Rm 312 Emst Hall, University of Louisville
Louisville, KY 40292
Phone: 502/852-7260
Fax: 502/852-0964
Contact: Joyce St. Clair
Mississippi Department of Environmental
Quality
Waste Reduction/Waste Minimization Program
P.O. Box 10385
Jackson, MS 39289-0385
Phone: 601/961-5171
Fax: 601/354-6612
Contact: Thomas E. Whitten
December 1996
10-B2
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State Pollution Prevention Programs (cont.)
North Carolina Department of Environment,
Health, and Natural Resources
Office of Waste Reduction
P.O. Box 27687
Raleigh, NC 2761 1-7687
Phone: 919/5 71 -4100
Fax: 919/571-4135
Contact: Gary Hunt
South Carolina Department of Health &.
Environmental Control
Center for Waste Minimization
2600 Bull St
Columbia, SC 29201
Phone: 803/734-4761
Fax: 803/734-5199
Contact: Robert E. Burgess
Univ of South Carolina Institute of Public
Affairs
Hazardous Waste Management Research Fund
937 Assembly Street
Columbia, SC 29208
Phone: 803/777-8157
Fax: 803/777-4575
Contact: Doug Dobson
EPA Region 5
Illinois Environmental Protection Agency
Office of Pollution Prevention
2200 Churchill Road P.O. Box 19276
Springfield, IL 62794-9276
Phone: 217/782-8700
Fax: 217/782-9142
Contact: Michael J. Hayes
Illinois Hazardous Waste Research and
Information Center
One East Hazelwood Drive
Champaign, IL 61820
Phone: 217/333-8940
Fax: 217/333-8944
Contact: David Thomas
Indiana P2 &_ Safe Materials Institute
1291 Cumberland Ave. Suite Cl
West Lafayette, IN 47906
Phone: 317/494-6450
Fax: 317/494-6422
Contact: Lvnn A. Corson or Jim Noonan
Indiana Department of Environmental
Management
Office of P2 and Technical Assistance
100 North Senate Avenue
P.O. Box 6015
Indianapolis, IN 46206-6015
Phone: 317/232-8172
Fax: 317/233-5627
Contact: Tom Neltner
Michigan Departments of Commerce &_ Natural
Resources Environmental Services
Division
Office of Waste Reduction Services
P.O. Box 30004
Lansing, MI 48909-7504
Phone: 517/335-1 178
Fax: 517/335-4729
Contact: Nan Merrill
Minnesota Office of Environmental Assistance
520 Lafayette Road North
Suite 200
St. Paul, MN 55155-4100
Phone: 612/296-3417
800/657-3843
Fax: 61 7/215-0246
Contact: Kevin McDonald
Minnesota Pollution Control Agency
Environmental Assessment Office
520 Lafayette Road
St. Paul, MN 55155
Phone: 612/296-8643
Contact: Eric Kilberg
Ohio Environmental Protection Agency
Pollution Prevention Section
1800 Watermark Dr.
P.O. Box 163669
Columbus, OH 43266-3669
Phone: 614/644-3469
Fax: 614/644-2329 or 614/728-1245
Contact: Michael W. Kelley
December 1996
10-B3
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State Pollution Prevention Programs (cont.)
Wisconsin Department of Natural Resources
Hazardous Waste Minimization Program
P.O. Box 7921
Madison, WI 53707
Phone: 608/267-3763
Fax: 608/267-2768
Contact: Lynn Persson
Wisconsin Department of Natural Resources
Pollution Prevention Program
P.O. Box 7921
Madison, WI 53707
Phone: 608/267-9700
Fax: 608/267-5231
Contact: Tom Eggert
EPA Region 6
Oklahoma Department of Environmental
Quality
Pollution Prevention Program
1000 NE 10th Street
Oklahoma City, OK 73117-1212
Phone: 405/271-1400
Fax: 405/271-1317
Contact: Dianne Wilkins
Texas Natural Resource Conservation
Commission
Office of Pollution Prevention and Recycling
P.O. Box 13087
Austin, TX 78711-3087
Phone: 512/239-3100
Fax: 512/239-3165
Contact: Andrew C. Neblett
University of Texas at Arlington
Environmental Institute for Technology
Transfer
P.O. Box 19050
Arlington, TX 75080
Phone: 817/273-2300
Fax: 817/794-5653
Contact: Gerald Nehman
EPA Region 7
Iowa Department of Natural Resources
Waste Reduction Assistance Program
Wallace State Office Bldg
Des Moines, LA 50319-0034
Phone: 515/281-8941
Fax: 515/281-8895
Contact: Larry Gibson
Iowa Waste Reduction Center
University of Northern Iowa
Cedar Falls, IA 50614-0185
Phone: 319/273-2079 Fax: 319/273-2926
Contact: John L. Konefes
Kansas Department of Health and Environment
Office of Pollution Prevention
Building 740, Forbes Field
Topeka, KS 66620
Phone: 913/296-6603
Fax: 913/296-6247
Contact: Theresa Hodges
Missouri Department of Natural Resources
Technical Assistance Program
Pollution Prevention Unit
P.O. Box 176
Jefferson City, MO 65102
Phone: 314/526-6627
Fax: 314/526-5808
Contact: Becky Shannon
F.PA Region 8
Colorado Department of Public Health Sl
Environment
Pollution Prevention Unit
4300 Cherry Creek Drive South
Denver, CO 80222
Phone: 303/692-3003
Fax: 303/782-4969
Contact: Parry Bumap
Montana Pollution Prevention Program
Montana State University Extension Service
Taylor Hall
Bozeman, MT 59717
Phone: 406/994-3451
Fax: 406/994-5417
Contact: Karen BuckJin Sanchez
December 1996
10-B4
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Notes
-------
CHAPTER 11
Environmental Management Systems
II. I What Is an Environmental Management System? I I-3
I l .2 How Does an EMS Differ From an Audit? I l -3
II.3 What's Involved in Developing an EMS? I I-4
I 1.4 Why Implement an EMS? 11-5
11.5 Getting Started 11-7
11.5.1 Conduct a Baseline Inventory 11-7
I 1.5.2 Develop a Policy 11-9
1 1.5.3 Define Your Goals: Where Do You Want To Go? 1 I -1 I
11.6 Top Management Support—A Key to Success 11-14
11.7 A New Way of Thinking About Environmental Management 11-15
I 1.8 Spreading the Word—A Strategy for Training and Communication 11-17
11.9 Tracking Progress 11-17
11.10 Striving for Continuous Improvement 11-19
11.11 Environmental Management Standards 11-21
I 1.1 1.1 What Is ISO 14000? 11-21
1 1.11.2 ISO 14001 Specifications for EMSs I 1-22
11.11.3 How Important Is ISO 14000 to Metal Finishers? 11 -24
11.12 Where To Go for Further Information About Environmental Management Systems and ISO 14000 1 I -26
This chapter provides a basic introduction to environmental management
systems, which are commonly referred to by the acronym EMS. In this
chapter, you will learn what an environmental management system is and
how it might benefit your metal finishing operation. You'll find out what's
involved in developing an EMS, so that you can evaluate whether this course
of action makes sense for your operation. You'll get ideas about how to start
developing an EMS, as well as guidance about where you can find more
detailed information.
Finally, you'll learn about current national and international activities that
have important implications for any metal finisher considering an EMS. This
includes discussion of the ISO 14000-series of international standards being
developed for EMSs.
December 1996
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Environmental Management Systems
Part II, Chapter 11
Table of Contents Page
11.1 What Is an Environmental Management System? 11-3
11.2 How Does an EMS Differ From an Audit? 11-3
11.3 What's Involved in Developing an EMS? 11-4
11.4 Why Implement an EMS? 11-5
11.5 Getting Started 11-7
11.5.1 Conduct a Baseline Inventory 11-7
11.5.2 Develop a Policy 11-9
11.5.3 Define Your Goals: Where'Do You Want to Go? 11-11
11.6 Top Management Support—A Key to Success 11-14
11.7 A New Way of Thinking About Environmental Management 11-15
11.8 Spreading the Word—A Strategy for Training and Communication 11-17
11.9 Tracking Progress 11-17
11.10 Striving for Continuous Improvement 11-19
11.11 Environmental Management Standards 11-21
11.11.1 What Is ISO 14000? 11-21
11.11.2 ISO 14001 Specifications for EMSs 11-22
11.11.3 How Important Is ISO 14000 to Metal Finishers? 11-24
11.12 Where to Go for Further Information About Environmental Management
Systems and ISO 14000 . . . 11-26
Appendix 1 1-A Sample EMS From the MetaJ Finishing Operations
Appendix 1 1-B Current Status of ISO 14000-Series Standards
December 1996
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Environmental Management Systems
Part II, Chapter 11
11.1 What Is an Environmental Management System?
An EMS is any systematic, integrated approach to managing
environmental activities within an organization. EMSs are based on
the belief that a coordinated, proactive approach to environmental
management will make your operations more efficient and benefit
the environment. Environmental management is a concept that can
help your company integrate all the guidance provided in this
manual in an efficient, systematic way.
Environmental management systems vary from one organization to
another in their scope and components. They may range from
modest, relatively informal systems (especially at smaller companies)
to larger, more comprehensive and formal systems. However, they
all seek to provide an efficient, effective mechanism for managing,
measuring, and continuously improving a company's environmental
performance. Improving environmental performance means
fulfilling regulatory requirements and taking steps to reduce or
eliminate resource use, waste, emissions, discharges, and accidental
releases.
Ideally, an EMS integrates all of an operation's environmental
activities—including regulatory compliance, waste reduction,
recycling, and pollution prevention—into a single unified system
that is an integral part of the overall operation. In this way,
environmental management becomes a company-wide function,
rather than the responsibility of a single manager or separate group.
This approach promotes a corporate culture of increased awareness
and personal responsibility for a company's environmental
performance. Ideally, all employees become involved in working to
continuously improve the company's environmental performance.
11.2 How Does an EMS Differ From an Audit?
An EMS is the mechanism to achieve ongoing success through
consistent, proactive, and documented management and
improvement of environmental performance. An audit is a tool for
measuring, evaluating, and verifying that success.
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Environmental Management Systems
Part II, Chapter 11
Audits vary in purpose and scope. For example, some audits focus
on a company's success in regulatory compliance or pollution
prevention or both. An audit of an environmental management
system focuses on how well your company's EMS system is
functioning. An EMS audit therefore is broader in scope than a
compliance or prevention audit. For example, an EMS audit might
spot check compliance, but would focus more on determining how
well your company's system to achieve compliance is functioning. An
EMS audit evaluates the success of the EMS in achieving its goals,
verifies that your company is doing what it claims to be doing in
environmental management, and may provide ideas for refining and
improving the EMS.
Environmental audits can be conducted internally be company
employees or externally by consultants. An external audit provides
an independent, third-party evaluation. You can use the results of
a third-party audit to provide a credible demonstration of your
environmental management success to outside parties, such as
suppliers, customers, and government agencies.
11.3 What's Involved in Developing an EMS?
In a nutshell, an EMS typically involves assessing your company's
current environmental activities, defining an environmental policy
and quantitative goals, developing and implementing a system to
measure and achieve those goals, monitoring results, and refining
the system over time.
There is no formula for developing an EMS. In fact, to be
successful, an EMS must be tailored to the particular circumstances
of each company. Experience so far indicates that EMSs will be
most effective if they are developed over time by gradually building
on and refining a company's current environmental management
activities.
This chapter provides guidance about the core elements, or building
blocks, of an EMS. You can use this information as a framework to
which you can apply common sense, basic management techniques,
and environmental tools to transform your operation's current
December 1996
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Environmental Management Systems
Part II, Chapter 11
environmental management activities into an EMS that will work
for your particular operation.
11.4 Why Implement an EMS?
Management "systems" are not a new concept, and many companies
have implemented systems to manage such aspects of their business
as finances, information, human resources, and even quality. The
idea of unified system for environmental management, however, is
relatively new, and has not been widely implemented as yet in the
metal finishing industry. Nevertheless, an increasing number of
companies in an ever-broadening variety of sectors are creating
EMSs to manage the environmental aspects of their business.
Many organizations also have developed standards that establish the
recognized principles, system elements, or auditing and reporting
practices for such management systems. Examples include the
Generally Accepted Accounting Practices (established by the
Securities and Exchange Commission and the Financial Accounting
Standards Board) that govern financial reporting for publicly-held
conipanies, and the ISO 9000-series standards that describe the
. isential elements of a quality management system. Similar
national and international voluntary standards for EMSs have been
developed or are currently under development.
Does an EMS make sense for a metal finishing operation? The
answer is yes—at least in some form. Larger operations likely will
need a more comprehensive, formal EMS. For smaller operations,
a more modest, relatively informal system often is most practical, at
least initially. Whatever its form and scope, an EMS can make good
business sense for several reasons:
¦ Improved Efficiency. By coordinating environmental
management activities, rather than conducting them
piecemeal, a company can realize many efficiencies. A
svstematic examination of your operation may illuminate
opportunities for reducing raw materials use, as well as
opportunities to minimize regulatory requirements through
pollution prevention and recycling. An EMS also provides a
mechanism for keeping your company's environmental
December 1996
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Environmental Management Systems
Part II, Chapter 11
management activities organized, focussed, and coordinated,
so that you can allocate resources in the most cost-effective
manner.
¦ Enhanced Opportunities for Market Development. Increasingly,
customers and consumers are placing more importance on
environmental protection. They specifically seek out and
bring their business to those companies that demonstrate a
commitment to environmental protection. An environmental
management system is one of the best ways your company
can demonstrate this commitment. How can you know
whether environmental stewardship matters to your
customers? Soliciting customer feedback is one of the best
ways. Also, you can monitor industry trends by reading trade
journals and attending conferences and you can keep an eye
on whether your competitors are becoming proactive about
environmental management.
¦ Demonstrate your commitment to the customer. Customers are not
only looking for firms that protect the environment but
provide assurance that they will be in business tomorrow.
This is frequently defined as firms that have implemented
systems to manage their business processes, be they financial,
quality, or environmental in nature.
¦ Regulatory Relief. The EPA and some state agencies are
looking to environmental management systems as a sensible
alternative to "command and control" regulations. The EPA,
for example, has some new pilot programs that reduce EPA
inspections, reduce reporting requirements, and expedite
permitting for companies that have demonstrated EMSs in
place. Also, the EPA may reduce or waive fines and provide
some immunity from prosecution for companies that
implement an EMS. Similarly, the U.S. Department of
Justice guidelines allow judges to take commitment to
environmental performance into account when sentencing.
¦ Reduced Exposure to Liability. Improved environmental
management may limit exposure to liability. With an EMS
in place, vour operation is more likely to reduce or prevent
the types of circumstances (accidental spills and releases, etc.)
that could provoke environmental-related litigation.
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Environmental Management Systems
Part II, Chapter 11
¦ Improved Public Relations. The commitment to environmental
protection demonstrated by an EMS can contribute to
improved public relations and good will with the local
community. Having an EMS in place could provide
reassurance to financial institutions and investors who
consider potential liabilities when making loan and
investment decisions.
11.5 Getting Started
Most companies—particularly small and medium-sized
companies—will find it easiest to implement an EMS incrementally.
The most important thing is to get started. You can build your
EMS in a step-wise fashion one change at a time. This not onlv
makes developing an EMS more feasible, it also ensures that the
system will be effectively integrated with other aspects of your
operation. With this approach, the EMS will stem from within
rather than being grafted onto your operation.
The metal finishing industry is highly regulated. Therefore, chances
are your metal finishing operation currently devotes at least some
time and resources to environmental management. Any regulatory
compliance activities are part of environmental management.
Similarly, any pollution prevention activities also are part of
environmental management. In implementing an EMS, you will
start to synthesize these and any other environmentally related
activities into an organized system designed to optimize your
operation's environmental effectiveness.
11.5.1 Conduct a Baseline Inventory
Before you design an EMS, you'll need to know what your operation
is currently doing in the environmental area. Therefore, the first
step toward an EMS is to take stock of your operation's
environmental activities. You'll need to find out:
¦ What are your current environmental obligations?
"Environmental obligations" means any regulatory
requirements your company must comply with and any
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Environmental Management Systems
Part II, Chapter 11
voluntary environmental improvement activities your
company has committed to.
¦ Which features of your operation have potential or actual
environmental impacts? (These features are sometimes
referred to as "environmental aspects.")
¦ What activities are currently in place to manage those
impacts? How successful are they?
This initial inventory will provide the foundation for deciding
whether and how to integrate and improve your company's current
environmental management activities.
The goal at this stage is to get as complete a picture of the current
situation as is practically feasible. Focus your efforts on those areas
and activities that appear to be of greatest environmental
significance—additional information can always be added over time.
Significant areas are areas that have the most serious environmental
consequences (such as high-volume, toxic waste production; existing
circumstances that could lead to accidental releases of toxic
materials, and so on) and areas that have the greatest potential for
improvement (for example, clear noncompliance with environmental
regulations). One way to identify and prioritize the environmental
aspects of your operations is to account for the materials that come
into or leave your operations (see Box 11-1).
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Environmental Management Systems
Part II, Chapter 11
Box 11-1 Using Materials Accounting To Quantify and Prioritize Wastes
Materials come in as raw materials or as process materials such as cleaning solvents.
They leave either as part of products or as wastes. One relatively easy way to identify
and quantify waste materials is to ask:
¦ How much material did you purchase and use last month?
¦ How much of that material was shipped out in your products?
The difference is what you wasted. Whether the material went to a treatment system
or was released directly to the environment, it is a waste. For example, most solvents do
not become part of a product. In such cases, the entire volume of solvent used becomes
a liquid or vapor waste. The materials accounting approach to quantifying wastes
frequently is simpler than measuring the waste at each point of release.
For each waste identified, you can then ask: How important is this waste? Is it toxic?
Can people be exposed to it? Can you reduce how much you use by recycling or reusing
it or changing the design of your process?
Also, you will probably want to focus initially on readily available
information. You don't need to do a sophisticated analysis or risk
assessment. The point is to develop an awareness of the major
environmental activities and consequences associated with your
metal finishing operation. Box 11-2 lists some useful questions to
ask when conducting the inventory.
11.5.2 Develop a Policy
Once you've conducted a baseline inventory, you'll have a good idea
of what your metal finishing operation is doing in environmental
management. But how can you start to transform these various
activities into a system?
One of the first steps is to work with senior management to develop
an environmental polity statement. This is important to provide a
unifying vision for vour company's environmental management
activities. Policv statements will be most effective if they honestly
reflect senior management vision and commitment to environmental
stewardship.
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Box 11-2 Conducting a Baseline Inventory: Where To Focus?
The following are suggested areas of focus for a baseline inventory of environmental
activities. Other areas may also be appropriate to your particular operation.
Remember, gather readily available information first—then decide how much
additional effort you want to put into further research.
¦ What aspects of your operation, products, and services use water or energy,
produce emissions or discharges, or generate waste?
¦ What materials go into your operation? What materials go out in products?
The remainder is waste (see Box 11-1).
¦ What regulatory requirements currently apply to your operation? How
thorough and up-to-date is your company's knowledge of these requirements?
¦ What does your operation currently do to comply with these requirements?
What is your company's track record in compliance? Have there been any
permit violations? Are there opportunities for improvement?
¦ What is your company currently doing to prevent pollution (see Chapter 10)?
¦ Have any environmental audits been conducted? What were the results?
¦ Does your company conduct any kind of environmental monitoring or
measurement? If so, what are the results?
¦ What procedures does your company currentl have in place for emergency
preparedness and response? Have any environmental emergencies (spills or
releases of toxic chemicals to the environment) resulted from your company's
operations? If so, what caused them? What were the consequences? What
steps were taken to prevent future emergencies?
¦ Has your company received environmentally related input or feedback from its
stakeholders, including regulatory agencies, customers, suppliers, or the
financial/insurance community?
Policy statements don't have to be lengthy or complicated. In fact,
many effective policy statements are relatively simple. Here are
some examples:
¦ It is our policv to be an environmental leader in the industry.
As such, we intend to go beyond compliance with applicable
environmental laws and regulations and to strive for zero
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waste generation to all media (land, air, water) to be achieved
by continually improving all our operations.
¦ Our environmental policy includes the elimination or
minimization of hazardous and nonhazardous waste and
emissions of toxic chemicals and provides for the safe disposal
of all waste material. We also strive to minimize the effect
on the environment of the products we manufacture.
¦ Environmental excellence is a core value of the our company.
We consider it our responsibility to conduct business in such
a manner as to ensure harmonious coexistence with the
environment through a guardianship policy base on
conservation and preservation of the environmental and its
natural resources.
Environmental policy can strive to go beyond compliance, as in the
first example, or strive to achieve compliance and, where
economically feasible, go beyond compliance. Remember, policy
serves as the cornerstone to build everything else you do. Be honest
and realistic about what you expect to achieve.
If you are seeking to implement an EMS based on the international
ISO 14000 standards, you should review the standards to identify
the required elements of the EMS and include these in your policy
statement. Box 11-4 summarizes the required elements of ISO
14000.
11.5.3 Define Your Goals—Where Do You Want To Go?
The next step in developing an EMS is to define the goals for the
EMS that are consistent with the policy. Clearly defined goals
provide an important focus, purpose, and direction for
environmental management at your company. They convey to all
employees what you want the EMS to accomplish over time. Goals
also are critical for accountability, because they provide targets you
can use to gauge and demonstrate the progress and success of the
EMS.
To lay the foundation for defining goals, you will probably want to
consider how ambitious the EMS should be at this point. Points to
consider include:
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¦ To what extent can your current environmental management
activities be consolidated and integrated? How might this be
done? What kind of time and resources are needed?
¦ To what extent does it make sense to expand beyond the
current activities? How might this be done? What kind of
time and resources are needed?
¦ What pace of change makes sense for your operation?
One way to address these questions is to use your inventory results
to list your operation's current environmental management
activities. Then, involve various members of your company to
create a wish list of the ways you could consolidate, expand, or add
to these activities. Discuss the challenges and merits of the ideas
and, where appropriate, estimate the resources required taking into
account as full a picture of the true costs and benefits as you
reasonably can (see Chapter 12 for guidance on how to do this).
Factors to consider when prioritizing ideas include:
¦ Which activities will yield the greatest improvement in one
or more of your environmental performance measures?
¦ Which activities are expecte:'. to yield the greatest benefits to
the company (e.g., in the form of improved compliance,
reduced operating costs, reduced fees and fines, improved
customer relations)?
¦ What resources will be needed to perform these activities?
¦ Which activities are the most feasible?
Once you have a list of priorities, you can decide which specific
priorities it makes sense for the EMS to address in the foreseeable
future. When you've identified an initial set of priorities, you can
define specific goals for each priority. This is where you consider
what you want to accomplish in environmental management over
specific periods of time—3 months, 6 months, or a year, for
example.
Some goals address environmental performance. These may include
goals that address improving regulatory compliance, reducing water
or energy use, or substituting less toxic raw materials. Others goals
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pertain to the program itself. These may include goals for raising
employee participation in the program, training employees, or
integrating different environmental management functions.
Where possible, goals should include a specific deadline for
achievement. Also, goals should be quantifiable so that you can
monitor and measure the success of your program. Examples of
goals that meet these two criteria include:
¦ Achieving 100% compliance with NPDES permit limits
within the next calendar year.
¦ Training 50% of employees in pollution prevention by July
30.
¦ Develop a just-in-time chemical purchase program and reduce
the chemical inventory by 25% by January 1.
¦ By July 1, install a hard pipe solvent still to restore spent
solvent and extract oil sludge.
Above all, goals should be realistic. They can be challenging, but
they should be feasible. Impossible goals can have a demoralizing
°fk::t on employees and lead to a loss of credibility with the public.
By contrast, success in achieving goals, however modest, provides
inspiration and momentum to continue developing an EMS. More
ambitious goals can be set once the earlier goals have been achieved.
Whatever goals you formulate, be sure to write them down. Box 11 -
3 illustrates one simple way to document a goal ("to minimize water
usage...") and the action plan to achieve that goal. This example
also shows how the action plan stems from the company's
environmental management policy.
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Box 11-3 Environmental Aspect, Policy, Goal, and Action: An Example
Significant Environmental Aspect:
We use a great deal of water.
Policv Commitment:
We will conserve resources.
Goal:
We will minimize water use where possible
economically and technically.
Specific Target:
We will reduce water use at site "x" bv 15
percent next vear.
Program Name:
Water Reuse.
Action To Be Taken:
Install equipment recycle rinse for Process A to
be reused in Process B.
Resources Needed:
$15,000 capital.
Timing:
Within 18 months.
Person Responsible:
John Smith, Operations Manager.
11.6 Top Management Support—A Key to Success
One of the factors most critical to the success of an environmental
management program is top management support. Numerous
studies have shown that this is the single most important element
of a successful environmental program. Why? Because everything
else flows from it. Any form of environmental
management—however modest—requires at least some investment
of employee time and corporate resources. Top management must
be willing and committed to making that investment. Also, many
EMSs cross organizational boundaries and seek to involve personnel
from different sections of the company in an integrated
management program. To be successful, this kind of change must
be sanctioned, or preferably championed, by top managers.
You'll be more likely to get senior management approval if you can
identifv opportunities for cost savings and risk reduction. These
may include, for example:
¦ Greater efficiencies in regulatory' compliance.
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¦ Identifying opportunities to reduce raw materials or energy
used.
¦ Turning waste materials into resources by finding ways to
reuse them within the company or recycle them externally.
¦ Reducing regulatory requirements, for example, by
substituting less toxic raw materials.
Chapter 20 provides some guidance on assessing the financial costs
and benefits of environmental management activities.
11.7 A New Way of Thinking About Environmental Manage-
ment
In many companies, environmental management activities are the
responsibility of a handful of employees. Other staff give little or no
thought to these aspects of the company's business. Yet each
employee has a unique perspective on the company's operation.
Therefore, each employee is in a unique position to identify
opportunities for change that can improve the efficiency and
effectiveness of a company's environmental management activities.
Many of the best suggestions for improving operations come from
those on the shop floor who are closest to the day-to-day operations.
Companies can harness this potential by encouraging all employees
to think creatively about opportunities for environmental
improvement and by integrating environmental considerations into
the day-to-day operations. This includes linking environmental
management considerations with business decisions throughout the
company. For example:
¦ The purchasing department may work with shop staff to
review and identify alternative supplies that can do the same
job but with fewer environmental consequences.
¦ The human resources office or training officer could develop
awareness training for shop workers to keep degreaser tanks
covered when they are not in use, thus reducing evaporation
of chlorofluorocarbor.s and trichloroethvlene.
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¦ A list of approved hazardous waste treatment and disposal
firms could be developed by purchasing and/or legal
department to reduce the potential that your waste will go to
a future Superfund site.
Once you've formulated EMS goals, you'll need to assign specific
roles and responsibilities for achieving them. What activities will be
necessary? Who will do them? Who will be the overall EMS
manager? Ideally, you will have the freedom to draw upon any
personnel and equipment within the organization that may be
needed to achieve the goals. The key to constructing the most
effective system may lie in crossing organizational boundaries.
For all these reasons, an EMS will generally be most effective in a
corporate culture where every employee understands and feel
responsibility for the environmental issues within his or her sphere
of operation, and where ideas for improvement can be explored and
implemented together, across organization boundaries and
supervisory categories. This culture change can be effected in a
number of ways:
¦ Make effective environmental management a clear corporate
goal.
¦ Incorporate the goal into written corporate policy.
¦ Clearly communicate this goal to all employees.
¦ Establish incentives and rewards to motivate employees to be
vigilant in identifying opportunities for improved
environmental management.
¦ Train employees in the basics of pollution prevention.
As with other aspects of an EMS, it's important to remember that
change takes time. Corporate culture won't change overnight, but
can be transformed gradually, particularly if management supports
and models the concept.
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11.8 Spreading the Word—A Strategy for Training and Com-
munication
Any type of change requires training and communication to raise
awareness, provide information, and build appropriate knowledge
and skills. In designing an EMS, it can be useful to think ahead and
plan what will be transmitted via training or communication, to
whom, how, and when. Training and communication can be written
(memos, e-mail, plans, newsletters, manuals, for example) and in
person (speeches, group meetings, one-to-one dialogues between
managers and staff members, training workshops, for example). A
variety of approaches often is most effective to communicate and
reinforce information. Some important topics for training and
communication include:
¦ The environmental management system, including its policy
and goals.
¦ Why it is important to conform with the system. What
might be the consequences of not conforming.
¦ The potential or actual environmental impacts of each
employee's work.
¦ Each employee's specific role (including regulatory
compliance and pollution prevention) in implementing the
system.
11.9 Tracking Progress
Tracking the progress and success of an EMS is important for several
reasons. In particular, it allows you to evaluate the system to decide
how and when to improve or expand it. Also, top management
likely will want assurance that the system is producing results.
Successful results can be used to motivate employees. They also
provide concrete evidence you can use to demonstrate your
operation's commitment to environmental stewardship to external
stakeholders. Finallv, data on your company's environmental
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performance will also be important if you request or are required to
have an audit.
How do you go about tracking EMS progress? Establishing goals
that can be quantified is an important starting point. You will then
need to consider:
¦ What types of data are necessary to track progress in meeting
each goal?
¦ Has this data already been collected? Often, useful data have
already been collected as part of operations. For example, as
mentioned in Box 11-1, the amount of solvent used typically
is tracked by materials accounting.
¦ How will this data be collected?
¦ Bv whom?
¦ How frequently?
¦ How will this data be documented?
¦ To whom will this data be provided? How will information
flow through the system?
For example, suppose your goal was to "reduce the generation of
metal-bearing hydroxide sludge by 50 percent by January 1." You
could measure the number of drums of sludge generated based on
manifest forms and the dollar cost of disposal. You could document
this data in the form of a monthly report or chart.
Mechanisms for tracking progress include tracking of environmental
emissions and wastes, periodic internal auditing, and periodic top
management review. In deciding how to track progress, it's
important not to burden the EMS with excessive monitoring and
recordkeeping requirements. You can build on what's already in
place, adding only the minimum additional tracking activities
necessary to keep the system functioning effectively.
Many metal finishers already have a number of mechanisms in place
to monitor environmental performance. These provide a ready-
made foundation for monitoring and measuring progress. The first
step mav be to make sure the existing systems are working
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effectively. You can supplement them as appropriate as your EMS
evolves over time.
It's also important to consider what uses will be made of the tracking
data. Data used for external purposes will likely require more
rigorous documentation than data used solely for internal purposes.
If you wish to have transparent accountability to external
stakeholders, for example, you may want to schedule periodic
independent, third-party audits of your system. If such
transparency is not important, internal audits often will suffice.
11.10 Striving for Continuous Improvement
The most effective EMSs are dynamic. They contain built-in
mechanisms for periodically evaluating success at achieving goals
and objectives, and then improving the system based on the results
of this evaluation. Managers often visualize this as a cycle of
continuous improvement. This cycle is illustrated in Figure 11-1.
Why is continuous improvement important? Because it's a
systematic way to learn from experience. With every cycle of
measurement and evaluation, you can review the system's success
and look for new opportunities for improvement. And, with every
review you can decide anew whether to expand the system by
establishing more ambitious goals as earlier goals are achieved.
Also, the social, political, and regulatory backdrop against which
EMSs operate is continually changing—especially in the metal
finishing industry. Existing regulations may be modified. New
regulations mav be added. Customer or local community interests
and concerns may grow. The most effective EMSs will be responsive
to these developments.
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Identify opportunfties to
improve environmental
performance.
• Set pnoritiei.
Evaluate what has been learned.
Based on what Has been
learned, make changes (e.g.,
train employees, change
processes or procedures) to
institutionalize success.
Use the knowledge
gained to start the
cyde again.
Improved
Environmental
Performance
• Observe and evaluate the
effects of the changes made.
Implement the action plan (preferably c
a pilot scale to minimize disruptions).
Track progress.
Source: Adapted from Deming, W.E. 1986. Out of Crisis. Center for Advanced Engineering Study,
Massachusetts Institute of Technology. Cambndne, Massachusetts.
Figure 11-1. A Cycle of Continuous Improvement.
How do you implement continuous improvement? Decide how you
are going to monitor the progress and success of your EMS. Then,
consider what will be done when system weaknesses, failures, or
opportunities are detected:
¦ How will the situation be investigated?
¦ What type of corrective actions will be taken? Within what
time frame?
¦ Who has the responsibility and authority to investigate
nonconformance and initiate corrective and preventive
action?
¦ How will the tracking information be used to identify
opportunities for improving the EMS?
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system weaknesses, and setting out corrective actions or preventive
measures. Goals would then be adjusted accordingly and new
assignments and schedules established.
11.11 Environmental Management Standards
The concept of environmental management has evolved in recent
years as the private sector has sought cost-effective ways to cope
with increasing social, market, and regulatory pressure for
environmentally accountability. More and more companies are
voluntarily creating EMSs. And, increasingly, nations, trading
partners, and industries are developing voluntary standards or
requirements for environmental management. In addition, several
industries have developed good management codes of practice for
their members to follow in developing environmental management
systems. The Chemical Manufacturer's Association's Responsible
Care program is one example.
This proliferation of separate and potentially incompatible standards
and initiatives poses particular challenges for companies doing
business internationally. Even voluntary standards can become a de
racto requirement by posing a trade barrier to companies that do
not comply with the standard.
11.11.1 What Is ISO 14000?
In response to this situation, an international standard-setting
organization (the International Organization for Standardization,
also known as the ISO, based in Geneva, Switzerland) has been
developing an international set of environmental management
standards, known as the ISO 14000 series. ISO 14000 series
standards distill the best international experience in environmental
management. They are intended to provide a common international
baseline for environmental management.
The ISO 14000 standards emphasize processes, not performance. In
other words, thev don't tell companies what level of environmental
performance to achieve. Instead, they specify- the core components
of a model management system that can be used to enhance your
companv's environmental performance. The underlying philosophy-
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is that an effective management system will produce good
performance. The first set of ISO 14000 standards was published
in final form in 1996. Appendix 11-B provides current information
on the status of the various ISO 14000-series standards.
Many metal finishers are familiar with ISO 9000, which is a
standard for quality management and quality assurance. Over
100,000 companies are now certified to ISO 9000. ISO 14000 is
similar to ISO 9000 in that both are management standards rather
than performance standards. Both sets of standards describe the
basic elements of a management system and provide guidance for
implementing the system. ISO 9000 describes a quality
management system and ISO 14000 describes an environmental
management system, however, both sets of standards share generic
management elements.
11.11.2 ISO 14001 Specification for EMSs
ISO 14000 consists of a series of standards covering six topics:
environmental management system, environmental auditing,
environmental performance evaluation, environmental labeling, life-
cycle assessment, and environmental aspects in product standards.
The first standard in the series—ISO 14001—is the specifications
standard for environmental management systems. ISO 14001
provides voluntary specifications for an environmental management
system. Box 11-4 provides an overview of some key specifications.
All the other standards in the ISO 14000 series provide general
guidance on implementing an environmental management system
or analyzing product characteristics.
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Box 11-4 What Does ISO 14001 Require?
An Environmental Policy—It does not have to be long or complicated, but it does have
to address the "significant environmental aspects of your activities, products, and
services," and it must include a commitment to preventing pollution and to complying
with legal requirements.
An Environmental Plan—Your plan shall set objectives and targets for improvement
related to your significant environmental aspects.
A Management Program—Your management program shall assign responsibility,
resources, and schedules for meeting your objectives and targets. Responsibility for
meeting environmental objectives and targets can be assigned to any appropriate level
or function in your organization.
A Training Program—Ultimately, all staff whose work may have a "significant
environmental impact" shall receive training. Start with those whose jobs may have the
greatest effort.
A System To Monitor Progress and Make Corrections—Develop a simple way to track
whether you are making progress toward your environmental objectives and to make
mid-course corrections if necessary.
Documentation—To receive certification you will also need documentation both to
demonstrate that you have procedures in place and to communicate effectively and
consistently to your managers and employees.
Recordkeeping—Record the results of your EMS: employee training, monitoring reports,
environmental performance measurements, audit outcomes.
Auditing—Internal audits check the "functioning" of the EMS. External audits (for
certification) evaluate the conformity of your EMS with the ISO 14001 standard.
ISO 14001 is not prescriptive. Rather, it provides flexibility for
each organization to design an EMS that makes the most sense in
the context of its particular culture, business niche, function, and
location. Also, it is designed to allow companies to build on their
current system or on useful models and to improve their EMSs over
time. All the guidance provided in this chapter is compatible with
the ISO 14001 requirements.
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Companies can use ISO 14001 in two basic ways. Most
importantly, the standard provides a framework for establishing an
EMS. The standard also serves as an internationally sanctioned
reference point a company can use to demonstrate to external
stakeholders its commitment to environmental stewardship.
One ISO 14001 specification is that a company establish and
maintain programs and procedures for periodic EMS audits. These
audits are both internal and external.1 They focus on whether the
EMS conforms to the ISO 14001 specifications and how well the
system is functioning—not on how well the system is performing.
Companies may use the results of successful internal audits to "self-
declare" conformity with ISO 14001. Alternatively, a company may
request an external audit to receive independent, third-party
verification of conformance to the standard. The American
National Standards Institute (ANSI) is currently working to help
develop a system for third-party verification in the United States.
This system will include criteria by which third parties can become
accredited to verify conformance to ISO 14001. Accredited entities
would then audit firms seeking third-party registration. However,
third-party registration can be expensive, so other options for
demonstrating conformance may also be developed.
11.11.3 How Important Is ISO 14000 to Metal Finishers?
The ISO 14000 is expected to have a significant impact both in the
United States and worldwide. ISO 14001 will likely become the
primary environmental management systems standard within and
outside the United States. ANSI is expected to adopt ISO 14001
as the national U.S. EMS standard. Other countries have already
adopted or are planning to adopt ISO 14001 as their national
standard.
What does this mean for metal finishers? Though ISO 14000 is a
voluntary standard, conformance with ISO 14001 is likely to
become a de facto requirement for doing business in many
international markets. In other words, companies doing business
internationally may find their business opportunities are restricted
' The external audit is for certification purposes. If certification is not required or desired it is not necessary,
although it may still be desireable.
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if they don't conform to the standard. Some major customers of
metal finishing that do business internationally (for example large
auto manufacturers) may require their service organizations to
conform to the standard.
Even metal finishers whose business lies entirely within U.S. borders
are likely to feel the impact. As national awareness about the ISO
14001 standard grows, you may increasingly find environmentally
oriented suppliers and customers asking whether your operation has
an EMS and, if so, whether it conforms to ISO 14001.
Also, the standard may impact regulatory and enforcement activities
by government agencies. The EPA, for example, has been a
significant player in the U.S. delegation to the international
committee developing ISO 14001. EPA is already exploring the use
of ISO 14001-like EMS as an alternative to the traditional
command-and-control approach to environmental management.
Among the possibilities are reducing the permit monitoring and
reporting requirements for facilities that demonstrate superior
environmental performance—for example, through a third-party
registered EMS.
Finally, an EMS provides evidence that a company is making good
faith efforts to comply with regulations, detect and correct
violations, and generally optimize environmental performance. In
this way, an EMS can be a mitigating factor in enforcement and
penalty decisions.
Is conformance to ISO 14001 important to your metal finishing
operation? That depends a couple of factors:
¦ First, does your operation want to be proactive regarding
environmental management?
¦ Second, do you currently experience or do you anticipate
pressure from your stakeholders or the marketplace to
demonstrate a commitment to environmental stewardship?
If you answered "yes" to either question, you will probably want to
start developing an EMS based on the ISO 14001 criteria. That
wav, you will embark on the path to conformance with ISO 14001,
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and you can move to full-fledged conformance over time or at any
point in time that makes sense.
Metal finishing operations that do not currently place a priority on
being environmentally proactive and do not feel external regulatory
or market pressures may choose to ignore ISO 14001 for the
moment. However, ISO 14000 will likely raise the level of
awareness and knowledge about environmental management and
may eventually impact your business. The good news is that any
steps you take to develop an EMS based on the guidance in this
chapter will better position you for ISO 14001 conformance in the
future, should that become important.
11.12 Where To Go for Further Information About Environ-
mental Management Systems and ISO 14000
Even if your company is not currently interested in conforming to
ISO 14001, the ISO 14000 series standards provide useful guidance
in establishing an EMS.
¦ You can obtain a copy rf the standard from the American
National Standards Institute, 11 West 42nd Street, New
York, NY 10036 (phone: 212-642-4900; fax: 212-398-0023;
internet: http://www.ansi.org).
¦ An introduction to the ISO 14000 standards can be found in
ISO 14000: A guide to the new environmental management
standards, by Tom Tibor and Ira Feldman, published in 1996
by the Times Mirror Higher Education Group. Development
of the ISO 14000 standards has continued since publication
of this book, therefore some information may be out of date.
¦ Perhaps the most authoritative, comprehensive, and reader-
friendly guide to ISO 14000 currently available is The ISO
14000 handbook, edited by Joseph Cascio, published in 1996
by CEEM Information Services, 10521 Braddock Road,
Fairfax, Virginia 22032. Phone: 800-745-5565. Fax: 703-
250-5313.
¦ 77/e ISO 14000 resource directoiy, also published by CEEM
Information Services (see above), provides a detailed
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directory of private sector organizations that provide services
(e.g., consulting, training) related to developing and
implementing an EMS.
¦ EPA currently is developing an ISO 14000 resource directory
that likely will be published in 1996 or 1997. This will focus
on government resources. When published, this directory
will be available from Office of Research and Development
publications, U.S. EPA, 26 West Martin Luther King Drive,
Cincinnati, Ohio. Phone: 513-569-7562.
¦ Some metal finishers invlved in an EPA-funded EMS project
are using the publication: Environmental Management Systems:
An Implementation Guide for Small and Medium-Sized
Organizations, by P. Stapleton, A. Cooney, and W. Hix.
Published in 1996 by NSF International, P.O. Box 130140,
Ann Arbor, MI 48113.
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APPENDIX 11-A
SAMPLE EMS FROM THE METAL FINISHING INDUSTRY
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NEW ENGLAND METAL FINISHING JOB SHOP
In late 1994, the owner of a 160-employee metal finishing job shop stated, "I want my
company to be the first metal finishing job shop in the country to receive ISO 14000
certification." At the time it was not yet clear what ISO 14000 really meant, and how
much effort would be required to become "certified." However, the owner was confident
that to remain an industry model for responsible environmental management, the
company needed to become more systematic in its approach.
The company was motivated by four factors:
¦ A desire to stand out in the market place as a progressive, innovative organization.
¦ A need to reduce costs associated with managing environmental affairs.
¦ An expectation to obtain regulatory relief.
¦ A commitment to reduce potential environmental impacts initiating from metal
finishing operations.
To achieve its goals, the company embarked on a variety of activities, including:
¦ Pollution Prevention Training. In 1994, the company retained a consultant to
provide awareness training to a newly-formed Pollution Prevention Team. The
initial team comprised a cross section of employees including the Chief Financial
Officer, shift supervisors, plating line operators, maintenance staff, and rackers.
The training included an overview of regulatory requirement affecting the
company, and instructions on how to identify prevention opportunities. The
training led to the development of a pollution prevention plan with a concise
environmental policy statement.
¦ Environmental Policy Statement. Company employees established a draft
Environmental Policy Statement, later endorsed by the company president.
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Environmental Polity Statement
We are committed to excellence and leadership in protecting the environment. In
keeping with this policy, our objective is to reduce waste and emissions. We strive to
minimize adverse impacts on the air, water, and land through pollution prevention
and energy conservation. By successfully preventing pollution at its source, we can
achieve cost savings, increase operation efficiencies, improve the quality of our
products and services, maintain a safe and healthy workplace for our employees, and
improve the environment. We will continue to strive for continuous improvement of
our environmental performance. Our environmental guidelines include the following:
— Environmental protection is everyone's responsibility. It is valued and displays
commitment to us. Preventing pollution at the source is a prime consideration
in research, process design, and plant operations. We are committed to
identifying and implementing pollution prevention opportunities by
encouraging and involving all employees. To that end, the company will train
its employees about how their actions affect the company's environmental
performance.
— We will commit to including pollution prevention in the design of our processe:
and products. Technologies and methods which substitute non-hazardous
materials and utilize other source reduction approaches will be given top
priority in addressing all environmental issues.
— We seek to demonstrate our responsible corporate citizenship by adhering to
all applicable environmental regulations. We promote cooperation and
coordination between industry, government, and the public toward the shared
goal of environmental protection. A copy of this document is available to any
interested party.
¦ Obtain Recognition for Environmental-Friendly Operations. A long history of
regulatory compliance was rewarded when the company received a Governor's
Environment 2000 Award for environmental excellence in 1994, the first such
award given to a state manufacturer.
In 1996, the companv was one of 20 New England businesses recognized for
superior environmental performance under EPA-New England's Environmental
Leadership.
December 1996
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Environmental Management Systems
Part II, Chapter 11
¦ Participate in Creating Government Initiatives. The company agreed to participate in
an EPA Common Sense Initiative's program referred to as Metal Finishing 2000.
The company will participate in a pilot project in which an EMS manual is
developed and its contents implemented. The ultimate goal is to establish an
EMS model.for the metal finishing industry.
In 1996 the company was selected by EPA-New England to be one of the first
participates in Star Track, in which they will pilot the Star Track third-party
certification initiative and receive relief from certain administrative regulatory
requirements.
According to the company's environmental manager, creating and nurturing an effective
systematic approach to environmental management is a long, constantly evolving
process. It requires support of top management, and well-educated employees. In
getting a program started, it also helps to have an established, formalized quality
assurance or health and safety program.
As evidence of this example, fully-implemented and successful EMS programs are not
simply created, nor easy to implement. However, efforts by a metal finisher to
demonstrate a commitment towards continuous improvement signals a new level of
environmental stewardship.
December 1996
11-A3
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APPENDIX 11-B
CURRENT STATUS OF ISO 14000-SERIES STANDARDS
-------
Environmental Management Systems
Part II, Chapter 11
Standards in the ISO 14000 Series—Status as of September 1996
Organizational Evaluation
ISO 14001
Environmental Management Systems—Specifications with Guidance
for Use
Published as final International
Standard September 1, 1996
ISO 14004
Environmental Management Systems—General Guidelines on
Principles, Systems, and Supporting Techniques
as above
ISO 14010
Guidelines for Environmental Auditing—General Principles on
Environmental Auditing
Final Draft International Standard
for ballot; publication expected
October 1996
ISO 14011/1
Guidelines for Environmental Auditing—Audit Procedures—Audit of
Environmental Management Systems
as above
ISO 14012
Guidelines for Environmental Auditing—Qualification Criteria for
Environmental Auditors
as above
ISO 14015
Environmental Site Assessments
New Work Item proposal
ISO 14031
Evaluation of Environmental Performance
5th Working Draft
Product Evaluation
ISO 14040
Environmental Management—Life Cycle Analysis—Principles and
Framework
Draft International Standard
ISO 14041
Environmental Management—Life Cycle Analysis—Life Cycle
Inventory Analysis
Committee Draft for ballot
ISO 14042
Environmental Management—Life Cycle Analysis—Impact
Assessn . :nt
Working Draft
ISO 14043
Environmental Management—Life Cycle Analysis—Interpretation
as above
ISO 14020
Goals and Principles of All Environmental Labeling
Committee Draft for Comment
ISO 14021
Environmental Labels and Declarations—Self Declaration
Environmental Claims—Terms and Definitions
Draft International Standard
ISO 14022
Environmental Labels and Declarations—Self Declaration
Environmental Claims—Symbols
Working Draft
ISO 14023
Environmental Labels and Declarations—Self Declaration
Environmental Claims—Testing and Verification
as above
ISO 14024
Environmental Labels and Declarations—Environmental Labeling Type
I—Guiding Principles and Procedures
Committee Draft for
ballot/comment
ISO 14025
Environmental Labels and Declarations—Environmental Information
Profiles—Type III Guiding Principles and Procedures
New Work Item
ISO Guide 64
Guide for Inclusion of Environmental Aspects in Product Standards
ISO Guide
Overall
ISO 14050
Terms and Definitions—Guide on the Principles for ISO/TC 207/SC6
Terminology Work
Draft International Standard
Source: International Environmental Systems Update, v.3, No. 9. CEEM Information Services. Fairlax. VA, September, 1996.
December 1396 11-B1
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Notes
12
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CHAPTER 12
Environmental Cost Accounting
12.1 Limitations of Conventional Accounting 12-1
12.2 What is Environmental Cost Accounting? 12-2
12.3 How Can ECA Benefit Metal Finishing Operations? 12-3
12.4 What Are "Environmental Costs"? 12-4
12.5 What Can Metal Finishers Use ECA For? 12-9
12.6 What's Involved in ECA? 12-10
12.7 Who Should Be Involved? 12-10
12.8 Information Sources 12-11
12.9 Key Steps in ECA 12-11
12.9.1 Determining the Scale 12-11
12.9.2 Defining the Goals 12-12
12.9.3 Determining the Scope 12-12
12.9.4 Developing a Process Flow Diagram 12-13
12.9.5 Identifying the Environmental Costs 12-14
12.9.6 Quantifying the Environmental Costs 12-17
12.9.7 Accounting for the Time Value of Money 12-20
12.10 Implementing the Results and Institutionalizing ECA 12-23
12.1 1 Where To Go for Further Information About ECA 12-24
12.11.1 Clearinghouse and Hotlines 12-24
12.11.2 Software Programs 12-25
12.11.3 ECA Guidance Document for the Metal Finishing Industry 12-26
12.12 References 12-26
As a member of the highly regulated metal finishing industry, you probably
know that regulatory compliance is a significant cost to your operation. But
exactly what is this cost? Where do the greatest opportunities for reducing costs
lie? Which pollution prevention investments will improve the bottom line?
This chapter will help you understand how to answer these questions. First,
you'll find out why conventional accounting techniques obscure the true costs
and benefits of environmental activities. Then, you'll learn about
environmental cost accounting (ECA)—an emerging approach you can use to
more fully assess the environmental costs and benefits of your company's
activities and potential investments. The chapter provides an introduction to
ECA and points you to sources of further information.
December 1996
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Environmental Cost Accounting Part II, Chapter 12
12.1 Limitations of Conventional Accounting 12-1
12.2 What is Environmental Cost Accounting? 12-2
12.3 How Can ECA Benefit Metal Finishing Operations? 12-3
12.4 What Are "Environmental Costs"? 12-4
12.5 What Can Metal Finishers Use ECA For? 12-9
12.6 What's Involved in ECA? 12-10
12.7 Who Should Be Involved? 12-10
12.8 Information Sources 12-11
12.9 Key Steps in ECA 12-11
12.9.1 Determining the Scale 12-12
12.9.2 Defining the Goals 12-12
12.9.3 Determining the Scope 12-12
12.9.4 Developing a Process Flow Diagram 12-13
12.9.5 Identifying the Environmental Costs 12-14
12.9.6 Quantifying the Environmental Costs 12-17
12.9.6.1 How Do I Calculate the Costs? 12-18
12.9.6.2 What if One Activity Applies to Several Chemicals or Wastes? 12-18
12.9.6.3 What if I Can't Calculate the Costs Exactly? 12-19
12.9.6.4 Calculating Total Costs 12-20
12.9.7 Accounting for the Time Value of Money 12-20
12.10 Implementing the Results and Institutionalizing ECA 12-23
12.11 Where To Go for Further Information About ECA 12-24
12.11.1 Clearinghouse and Hotlines 12-24
12.11.2 Software Programs 12-25
12.11.3 ECA Guidance Document for the Metal Finishing Industry 12-26
12.12 References 12-26
Appendix 12-A Financial Analysis of Pollution Prevention Projects
Appendix 12-B Environmental Accounting Resource List
12.1 Limitations of Conventional Accounting
Most companies systematically underestimate their regulatory
compliance costs, as well as the financial advantages of pollution
prevention investments. Here's why:
¦ Many costs are hidden. Conventional accounting buries
many environmental costs, such as cleaning, degreasing, and
pollution control, in overhead and other nonspecific
accounts. This makes it difficult for managers and decision-
makers to include the costs of these activities when assessing
environmental costs.
¦ Many costs are overlooked. Attempts to quantify
environmental costs often ignore less tangible costs and
benefits—such as increased liability, expanding market share,
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
reducing public liability, or improving public good will.
These costs and benefits can be substantial.
¦ The impact of time is often ignored. We all know that a
dollar today is worth more than a dollar tomorrow because of
inflation and because of the investment return the dollar can
generate. Yet managers often fail to factor the time value of
money when deciding whether to invest in pollution
prevention. This can make pollution prevention investments
seem more costly than they really are.
For all these reasons, conventional accounting provides a distorted
picture of the financial pros and cons of a company's environmental
opportunities, options, and liabilities. Managers who rely on
conventional accounting data are handicapped in their ability to
identify areas for improvement and to assess the true value of
pollution prevention investments.
12.2 What Is Environmental Cost Accounting?
In recent years, a number of institutions have been working to
remedy this situation by developing management accounting tools1
specifically designed to integrate environmental considerations into
the decision-making process. These methods are typically known as
"environmental cost accounting' (EGA.). They provide systematic
approaches to identifying environmental costs and linking them to
the activities that spawn them. The basic goals of all EGA
techniques are to determine:
¦ Which are the true environmental costs faced by the
organization?
¦ How large are these costs?
¦ Where do they arise?
¦ How can they be better managed?
1 Management accounting is the process of identifying, collecting, and analyzing information primarily for internal
management purposes.
The term environmental accounting also is sometimes used in the context of financial accounting (i.e., the
preparation of financial reports for use by investors, lenders, and others) to mean the estimating and public
reporting of environmental liabilities and financially material environmental costs (EPA, I 995). This chapter does
not address financial accounting.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Two primary methods of ECA are activity-based cost accounting
and total cost accounting (Box 12-1).
Box 12-1 Types of ECA
¦ Activity-Based Cost (ABC) Accounting. ABC accounting tracks and reports costs
by activity or process, rather than by the budget categories used in conventional
accounting systems. For example, ABC accounting can be used to identify all the
environmental costs related to one or more company activities and to systematically
track those costs alongside the traditional financial data. The ECA example provided
in Figure 12-1 and Table 12-1 later in this chapter is a form of ABC accounting.
¦ Total Cost Accounting (TCA). Total cost accounting includes ABC and it considers
the time value of money. TCA identifies and quantifies the full spectrum of private
environmental costs and benefits associated with one or more of an organization's
processes or products. (Private environmental costs are costs that directly affect a
company's bottom line—see Section 12.4.) Companies can use TCA to compare the
costs and benefits of two or more investments or process changes in order to identify
the option that maximizes future cash flows. The process of TCA involves identifying
relevant costs and benefits, calculating net present value (NPV—see Section 12.9.7)
and taking into account qualitative factors in decision-making. It also helps firms
capture many of the indirect cost savings not typically accounted for in traditional
capital budgeting models. EPA has selected TCA as the preferred system for
evaluating pollution prevention activities. Box 12-7 at the end of this chapter
illustrates the application of TCA to a metal finishing operation.
12.3 How Can ECA Benefit Metal Finishing Operations?
ECA allows companies to make business decisions based on financial
data that relates environmental issues to the bottom line.
Specifically, you can use ECA to:
¦ Better understand and manage your operation's
environmental costs. Every manager in a company should
be aware of how his or her actions impact expenditures. An
ECA system provides the information managers need to
understand the environmental costs associated with their
decisions and make informed decisions about environmental
management.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
¦ Identify pollution prevention opportunities and other
options to reduce these costs. Box 12-2 shows how one
company used EGA to justify a pollution prevention project
that saved $14,000 per year in compliance costs.
¦ Make strategic management decisions. Product lines that
may seem marginal under a traditional cost accounting
system may actually be big financial winners when the full
environmental costs are comprehended, or vice versa. ECA
improves strategic decision-making by providing more
accurate cost information.
¦ Incorporate consideration of environmental costs into
the pricing of products and services.
¦ Increase market share by identifying and marketing
environmentally preferable "green" products.
12.4 What Are "Environmental Costs"?
Environmental costs are costs directly associated with any form of
environmental management, including compliance and prevention.
Environmental costs may include both "private costs" (those that
direcdy affect a company's bottom line) and "social costs" (costs that
do not directly affect the bottom line).
Box 12-3 lists private environmental costs and divides these costs
into three categories:
¦ Potentially hidden costs. These include labor, equipment,
materials, supplies, utilities, structures, and other costs (such
as taxes and fees) associated with environmental activities.
Potentially hidden costs may occur:
— Prior to the operation of a process, system, or facility (e.g.,
costs of siting, design of environmentally preferable
products, etc.). (These are called "upfront" costs in Box
12-3.)
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Environmental Cost Accounting
Part H, Chapter 12
Box 12-2 Using ECA To Reduce Regulatory Compliance Costs at a Metal Finishing
Operation
This example illustrates how one company used ECA to identify and reduce a costly compliance area.
Their efforts cut compliance costs by almost $l 4,000 per year.
The Lightolier Inc's Aluminum Processing Company (APC) is a metal fabricator with plating and
coating operations. The company's APC division, located in Fall River, Massachusetts, fabricates
aluminum reflectors for track and recessed lighting units. The division employs several hundred
people. After forming, the metal reflectors are sent to one of three degreasers before going to the
plating or coating lines. At the time of the assessment, all three degreasers used trichloroethylene
(TCE), a regulated chemical.
The ECA assessment revealed substantial regulatory compliance costs associated with TCE use:
¦ The plant engineer spent about 10 percent of his time monitoring the degreasers and
manifesting the used TCE sent out for recycling.
¦ Reporting spills and leaks and complying with SARA Tide III reporting requirements
consumed another 40 to 50 hours a year.
¦ Two other engineers conducted right-to-know training sessions that covered TCE and a few
other chemicals, as required under SARA Tide III. About 40 percent of the approximately 75
hours of training the engineers provided each year was spent specifically on TCE.
¦ The manufacturing engineering department spent 20 minutes labeling every 50-gallon drum
of incoming and outgoing TCE.
To reduce compliance costs, the company decided to eliminate the use of TCE over a 2-year period.
They did this by substituting a nonpetroleum based oil in the forming process for Hydroform oil, by
replacing one degreascr with an aqueous model, and by replacing another degreaser with a
combination degreaser/electrostatic powder coater unit. The combination unit eliminated most of the
toxic air pollutants emitted in the old spray coating booths. The compliance-related savings from
this decision, totaling $13,905, are broken down below:
Compliance-Related Activity Savings Calculation
Monitoring/Manifesting
56,000
200 hours of the environmental
engineer's time at $30 per hour
Right-to-know training
S900
30 hours of training time attributable
to use of TCE at $30 per hour
Labeling
$4,500
150 hours of labor at $30 per hour
Spill/Leak incident reporting
$1,350
40-50 hours of labor at $30 per hour
Toxic Use Reduction Act fees
$1,155
Set annual rate
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Box 12-3 Examples of Environmental Costs Incurred by Firms
Potentially Hidden Costs
Operating (Voluntary/
Operating (Regulatory)
Upfront
Beyond Compliance)
¦ Notification
¦ Site studies
¦ Community relations/
¦ Reporting
¦ Site preparation
outreach
¦ Monitoring'Testing
¦ Permitting
¦ Monitoring/Testing
¦ Studies/Modeling
¦ R
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Environmental Cost Accounting
Part II, Chapter 12
— During the operation of a process, system, or facility
(often these costs are buried in overhead accounts).
— In the future (e.g., the future cost of decommissioning
equipment). These prospective costs, referred to as "back-
end" environmental costs in Box 12-3, often are
overlooked because they are not well documented or
accrued in accounting systems.
¦ Contingent costs (i.e., costs that may or may not be
incurred at some point in the future). These include the
costs of remedying and compensating for future accidental
releases of contaminants, fines and penalties for future
regulatory violations, and legal expenses the company may
incur as a result of a release or violation. (These costs are
sometimes referred to as contingent liabilities.)
¦ Image and relationship costs. These are the costs
associated with activities that affect the perceptions of
management, customers, employees, communities, and
regulators. These costs may include the cost of annual
environmental reports and community relations activities, for
example. While the costs themselves may be concrete, the
benefits (improved relationships and image, public support
for or opposition to your operation, customer interest in
"green" products, worker morale, etc.) are intangible and
often hard to quantify. These costs are sometimes referred to
as intangible costs.
Box 12-3 does not list "social costs." Social costs are costs to
individuals, community, and the environment that are frequently
outside the company's control. Social costs include, for example,
environmental damage, depletion of natural resource, or public
health impacts associated with use, emission, and disposal of
materials and products. EGA. may or may not include social costs.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
12.5 What Can Metal Finishers Use ECA For?
ECA is a very flexible tool that can be implemented on a variety of
scales on a systematic or as-needed basis. For example, metal
finishers can use ECA:
¦ For specific business decisions. At the simplest level, you
can use ECA to evaluate the pros and cons of specific
environmental management choices, such as whether to
invest in new equipment that will help prevent pollution.
This means you will apply ECA only in connection with
specific business decisions.
¦ To evaluate a specific process, chemical, or option. You
can focus ECA on one or a few specific areas within your
operation. For example, you may want to focus on an area
that your "gut" tells you likely has high environmental costs.
¦ To conduct a baseline inventory. ECA can also be a useful
tool when you are conducting a baseline inventory in
connection with starting a pollution program or an
environmental management system (see Chapters 10 and
11). You could use ECA to get a comprehensive idea of your
operation's current regu.atory compliance costs. You could
then use these results to identify opportunities for
environmental improvement, to establish priorities for your
environmental management system, and to raise awareness
among staff about the costs of their environmental activities.
Because environmental costs change over time, you may want
to repeat this assessment periodically.
¦ As an informal tool. You can train managers in ECA so
that they can use this approach to evaluate areas within their
area of control. You can do this on a companywide basis or
only in a particular facility, department, or division.
¦ To implement a companywide system. Over time, some
operations may want to institutionalize ECA on a
companywide basis so that certain activity-based costs are
tracked on a permanent basis.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
12.6 What's Involved In ECA?
Whatever the scope of an ECA project or system, your firm will
need to invest some personnel time to gather and analyze data.
How much time will depend on your goals for the project.
Like pollution prevention and development of an environmental
management system, ECA. requires a shift in thinking because it
challenges the traditional way of doing business. Costs and benefits
are assessed in unconventional ways and information must be shared
across organizational boundaries. Therefore, whatever your goals,
ECA will likely be most successful if you start small and expand
incrementally. For example, you can begin by conducting a pilot
project in which you explore and define the ECA approach that
works best for your company or a portion of your company. As
your firm learns about and becomes comfortable with ECA
techniques, you can expand and institutionalize ECA as appropriate.
Using ECA does not imply a complete overhaul of your company's
accounting and information systems. In fact, the success of ECA
may depend on finding ways to work within your organization's
current accounting structure. For example, you can supplement the
data provided by the current system or define limited workable
changes to the system.
There is no single approach to or tool for ECA that will work for all
types and sizes of firms. This chapter reviews basic principles
common to various ECA approaches. Section 12.11 indicates where
you can find more detailed information on ECA, as well as
information about ECA tools currently being developed specifically
for metal finishers.
12.7 Who Should Be Involved?
ECA may entail new ways of sharing information, tracking and
accounting for costs, measuring performance, and making business
decisions. Therefore, the success of any ECA project often depends
on support by top management.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Like the development of an environmental management system
(Chapter 11), ECA crosses traditional corporate boundaries. EGA
therefore will benefit from the involvement of a cross section of
individuals representing different aspects of the company's
operations, departments, and managerial levels. For example, an
ECA project may bring together designers, engineers, chemists,
senior managers, environmental managers, production managers,
operators, purchasing and accounting staff, and so on. Those closest
to the operations will likely have important insights.
12.8 Information Sources
A major component of an ECA analysis is gathering data to identify
the nature and magnitude of the environmental costs and trace the
costs back to their sources. To do this successfully, the individual
or team conducting the ECA analysis will need to understand the
overall business landscape, including the firm's current accounting
system and the type of data it can provide, the processes and
products that fall within the scope of the analysis, and the
environmental challenges associated with these activities. Sources
for this type of information include:
¦ Engineering interviews and records.
¦ Accounting interviews and records.
¦ Manifest documents.
¦ Audit results.
¦ Vendor data.
¦ Regulatory documents.
¦ Any existing related efforts at the company such as pollution
prevention activities or environmental auditing.
12.9 Key Steps in ECA
This section describes some of the key steps typically included in an
ECA project—including determining the scale, goals, and scope of
an ECA, developing a process flow diagram, and identifying and
quantifying environmental costs. This material is intended as an
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
introduction to the subject rather than comprehensive guidance.
Other approaches and variations on these steps may also be used.
If you are considering conducting ECA for your facility, be sure to
obtain more in-depth information on the subject from the sources
listed in Section 12.11.
12.9.1 Determining the Scale
ECA can be conducted at a wide variety of scales. For example, the
project may cover:
¦ Only a single process, system, product, or product line
¦ Multiple processes, systems, products, or product lines
¦ A department
¦ A entire facility or group of facilities at a'single location
¦ A group of departments or facilities at different locations
¦ An entire corporate division or company
As mentioned earlier, ECA generally will be most successful if you
start on a smaller scale and expand to larger scales as your firm
becomes knowledgeable about and comfortable with the ECA
process. As you embark on an ECA project, one of the first steps is
to define the project scale.
12.9.2 Defining the Goals
As mentioned in Section 12.5 above, ECA can be used for many
different purposes. You will need to clearly define the goals for an
ECA analysis, in order to focus the analysis and make appropriate
choices about what to include in the analysis. Initial ECA projects
will be more likely to succeed if the goals are not overly ambitious.
For example, an initial project may seek to identify the major cost
drivers associated with a particular process, or to evaluate the costs
and benefits of a potential pollution prevention investment.
12.9.3 Determining the Scope
One kev to conducting an ECA analysis or implementing an ECA
system is to define practical boundaries about the type and extent
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
of data the system will track. Even larger companies tend to focus
on the most important data rather than trying to track all
environmental costs.
A major scope issue to decide before gathering data is which
categories of costs you will include in your analysis. For example, an
ECA could be restricted to "potentially hidden costs" listed in Box
12-3. A broader scope ECA would also include contingent costs
and/or image and relationship costs. Contingent and
image/relationship costs can be difficult to quantify. At a minimum,
you can list and evaluate these factors subjectively. If they seem
potentially significant, you can then decide whether to attempt to
include quantitative estimates for these costs in the analysis.
Some environmental expenses may also bring clear productivity
benefits. For example, an environmentally beneficial process change
may also reduce operating time. In such cases, you will need to
decide whether to record operating time as an environmental cost.
In deciding whether to consider contingent costs, firms may need to
consider political and legal realities. For example, firms may be
reluctant to quantify potential liabilities for current and future
actions for fear of triggering financial disclosure requirements
( World Resource Institute, 1995). Firms may be reluctant to record
benefits from pollution prevention investments that accrue from
reduced liabilities, since Securities Exchange Commission
regulations require that liabilities that are material to a company's
financial health be covered by reserves.
The "right" decision about what to include in an ECA will depend on
the goals of the project and on your firm's particular situation and
culture. Whatever you decide, be sure to identify any assumptions
you made, record your decisions, and apply them uniformly.
12.9.4 Developing a Process Flow Diagram
No matter which scope you have identified for your efforts, the first
step is to develop a process flow diagram or map for the process or
processes that fall within the scale and scope of your ECA. This is
the same type of diagram you would develop if you were exploring
pollution prevention opportunities. It breaks the process down into
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
its component parts, and it shows the major materials inputs and
waste outputs generated by each stage in the process.
Figure 12-1 provides an example of a process flow diagram for a
silver plating operation. Each activity in the silverplating process
corresponds to a box on the process map. Arrows drawn above and
below each box show raw materials used and wastes generated by
each activity. The estimated costs associated with the process
wastes in this figure are itemized in Table 12-1 (see Section 12.9.6
for a discussion of these costs).
12.9.5 Identifying the Environmental Costs
Once the process map has been created, you will need to identify
the environmental costs (see Section 12.4) associated with each
activity. Some costs—such as purchase, installation, and operation
of pollution control equipment, or permit fees—are clearly
"environmental." Other costs are not. For example, the cost of
purchasing equipment that enhances energy efficiency may or may
not be categorized as environmental.
The decision about whether to classify these "gray zone" costs as
environmental must be made on a case-by-case basis. The goal of an
ECA is to systematically as;emble and analyze all important and
relevant information about environmental costs to enable informed
decision-making. Therefore, an ECA project should focus on
identifying the major cost drivers, rather than including every
possible environmental cost.
Which costs will classify as environmental must be decided
individually for each ECA project based on the goals and intended
uses of the analysis. Some costs may be environmental for one
analysis, but not another. Box 12-4 lists environmental costs
typically incurred by metal finishing firms.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
1. Parts
2. Stripping
3. Acid Wash
*~ i v ;I ;r
4. Rinse
^on
»*¦
"if
5. Polishing
i r
C>-"*
•HO**
6. Clean
J~T~J~T
7. Neutralize
I V
o**'
8. Rinse
~ T
9. Plating
**5>»
sxv*^
jf 5 J
10. Still Rinse
*•'
~T
11. Continuous
Rinse
3 J
,*•* V*"
12. Polishing
i J
y*op
13. Storage
Figure 12-1 Process Map for Silver Electroplating.
Source: Kerry L. Bartlett, Richard R. Lester and Robert B.Pojasek. "Prioritizing P2 Opportunities with
Activity-Based Costing." Pollution Prevention Review, Vol. 5, No. 4 (Autumn, 1995). John Wiley &.
Son: NY. (Reproduced with permission.)
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Table 12-1 Activity-Based Cost Analysis for Silver Electroplating Operations
(Total Environmental Cost: $10,000)
Stripping
Acid Wash
Rinses
Polishing |
Environmental
Cost
Sodium-
Cyanide
Solution
(SL)
Sludge
(SS)
Vapors
(SV)
Muriatic
Acid
Solution
(AL)
Sludge
(SS)
Vapors
(AV)
Wastewater
(RW)
Panicles
(BP)
Worn
Buffing
Materials
(BM)
Permitting
SI5
$140
$15
$15
$30
$15
$15
$0
$0
Reporting
$15
$60
$5
$5
$15
$5
$10
$0
$0
Monitoring/
Recordkeeping
$50
$140
$20
$15
$35
$20
$25
$0
$25
Inspections
$25
$70
$10
$5
$15
$10
$5
$0
$0
Disposal
$150
$850
$0
$60
$140
$0
$20
$25
$50
Waste treatment
$325
$500
$0
$100
$60
$0
$20
$0
$0
Training
$15
$200
$15
$5
$40
$15
$0
$0
$0
Protective
$10
$100
$10
$5
$25
$10
$0
$10
$0
equipment
Lab analyses
$40
$350
SO
$15
$50
SO
$10
$15
$0
Labeling
$25
$50
SO
$5
$15
SO
$0
$0
$0
Audits
$15
$80
$10
$15
$15
$10
$5
$0
so
Raw materials
$50
$20
$0
$20
$5
$0
$50
$5
$10
Sum
$735
$2,560
$85
$265
$445
$85
$160
$55
$85
Percent
7.35
25.60
0.85
2.65
4.45
0.85
1.60
0.55
0.85
1
Cleaning
Neutralizing Rinse
Plating j
Environmental
Cost
Caustic
Solution
(CL)
Sludge
(CS)
Vapors
(CV)
Sulfuric
Acid
Solution
(NL)
Sludge
(NS)
Vapors
(NV)
Silverplating
Solution
(PL)
Sludge
(PS)
Filter
Waste
(PF)
Permitting
$30
$50
$15
$5
$20
$15
$40
$90
$0
Reporting
$25
$30
$5
$5
$10
$5
$25
$40
$0
Monitoring/
Recordkeeping
$20
$75
$35
$5
$15
$20
$25
$90
$0
Inspections
$0
$25
$20
$5
$10
$10
$0
$45
$0
Disposal
$65
$350
$0
$25
$100
$0
$100
$525
$80
Waste treatment
$85
$275
$0
$45
6+0
$0
$125
$325
$0
Training
$25
$100
$20
$5
$25
$15
$25
$150
$25
Protective
$30
$45
$15
$5
$10
$10
$35
$55
$0
equipment
Lab analyses
$0
$150
$0
$5
$40
$0
$0
$230
$0
Labeling
$20
$25
$0
$5
$5
$0
$25
$30
$10
Audits
$0
$40
$10
$5
$10
$10
$0
$50
$0
Raw Materials
$20
$10
$0
$5
$5
$0
$950
$300
$0
Sum
$320
$1,175
$120
$120
$256
$85
$1,350
$1,930
$1 15
Percent
3.20
11.75
1.20
1 20
2.56
0.85
13.50
19.30
1.15
Source: Bartlett, K. L., R. R. Lester, and R. B. Pojasek. 1995. Prioritizing P2 opportunities with activity-based costing. Pollution Prevention
Review, 5^4). Autumn. New York, NY: John Wilev 5k Sons. (Reproduced with permission.)
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Box 12-4 "Hidden" Environmental Regulatory Compliance Costs Most Rele-
vant to Metal Finishers
¦
Monitoring
¦
Handling
¦
Insurance
¦
Lab fees
¦
Inspections
¦
Personal injury
¦
Reporting
¦
Notification
¦
Fines and penalties
¦
Recordkeeping
¦
Spill response
¦
Fees/Taxes
¦
Training and
materials
¦
Protective equipment
¦
Regulation-driven
R&D
¦
Manifesting and
labeling
¦
Closure/Postclosure
care
12.9.6 Quantifying the Environmental Costs
At this stage, you can create a table with environmental cost
categories in the left-hand column and the waste materials for each
stage in your process flow diagram across the top. You will find this
approach illustrated in Table 12-1 for the silver electroplating
operation depicted in Figure 12-1. Now, you can work through each
element in the table grid to quantify or estimate the specific cost
expended for each chemical or waste in each category.
The example in Table 12-1 contains far more cost detail than may
be readily available to many metal finishers. This example is
provided to illustrate how costs can be displayed rather than what
level of detail should be achieved. As mentioned above, metal
finishers should focus their efforts on quantifying the most
important environmental cost drivers. When actual cost
breakdowns for these drivers are not readily available, it is quite
acceptable to estimate (or even arbitrarily assign) an overall total
cost for an environmental cost item (see Section 12.9.6.3).
Displaying environmental costs in a table makes it easy to determine
which activities are generating the highest total environmental costs.
In the silver electroplating example, the highest environmental cost
driver is sludge generated by stripping, which accounts for
approximately 25 percent of the total environmental costs.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
12.9.6.1 How Do I Calculate the Costs?
For each item, you should consider overhead (see Box 12-5), labor
(see Box 12-6), material, and equipment costs. For example,
suppose you strip your plating racks with ethyl acetate and dispose
of the spent ethyl acetate. If you process eight barrels of spent ethyl
acetate each month, it may take 90 minutes (or 1.5 hours) each
month for an employee to prepare the manifests. On an annual
basis, this job would consume approximately 18 hours per year (1.5
hours/month x 12 months/year = 18 hours/year). If total labor costs
are $30 per hour, annual manifesting costs for ethyl acetate from
stripping operation are:
18 hours x $30/hour = $540/year
Any overhead, material, or equipment costs can then be added to
the labor costs to give a total cost associated with the activity.
12.9.6.2 What if One Activity Applies to Several Chemicals
or Wastes?
Some activities apply to several chemicals or waste streams. For
example, suppose your company conducts right-to-know training as
required under SARA Title III. One training session may cover a
number of chemicals. How do you apportion this type of cost?
First, you'll need to figure out the overall cost of the training. This
may include trainer's time, time for employees to take the training,
and the costs of any training supplies. Once you have calculated the
total training costs, then you'll need to figure out what percentage
of the overall training time is spent on each particular chemical and
apportion the costs accordingly.
For example, suppose two plant engineers spend 75 hours each year
providing SARA Tide III training to different groups of employees.
They estimate that 40 percent of the training time was spent
covering the use of trichloroethylene (TCE) and the remainder was
related to other chemicals. Therefore, although the company would
still have to conduct right-to-know training even if the company
used a less toxic chemical instead of TCE, the training would involve
2 Sources: Northeast Waste Management Officials' Association and the Massachusetts Office of Technical
Assistance. 1994. Improving your competitive position: Strategic and financial iissessment of pollution prevention projects.
Training manual.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
less of the engineers' time. The elimination of TCE would reduce
the facilities costs for right-to-know training by 40 percent—a total
of $900 ($30/hr x 75 hours x 0.4).
Box 12-5 Allocating Overhead Costs
Overhead includes all costs that are not allocated to a particular product, process,
system, or facility. For example, overhead often includes the cost of building rent,
maintenance, utilities, supervisors' salaries, and waste disposal costs.
Typically a number of costs included in a company's overhead account are
environmental. As long as these costs remain buried in overhead, managers and others
cannot know the full cost of particular activities and products, so they have inadequate
information and incentives to reduce these costs.
One important task of ECA is to identify the environmental costs currently hidden in
overhead accounts and allocate them to the specific activities that produce these costs:
¦ Sometimes costs can be directly allocated to specific activities. For example, the
costs of disposing of a particular waste can be fully allocated to the process that
produces the waste. If more than one process produces the waste, the cost can
be divided proportionately among the processes.
¦ More general overhead costs associated with personnel or equipment (such as
benefits, cc^t of renting or leasing space) mav be added as appropriate to
personnel or equipment costs. For example, if a particular pollution control
activity takes a certain proportion of floor space (space that could potentially be
used for other activities if the need for pollution control could be eliminated),
then it may be appropriate to allocate a portion of the building costs to that
activity.
12.9.6.3 What if I Can't Calculate the Costs Exactly?
Often, the costs associated with certain chemicals or processes will
be substantially higher than others. These high-cost areas may offer
the greatest opportunities for environmental cost reduction. The
goal at this stage of an ECA is to determine which activities or
outputs generate the greatest environmental costs. Therefore, the
exact costs of each item are not as important as assigning relative
costs (Bartlett et al., 1995).
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Box 12-6 Calculating the Hourly Cost of Labor
For labor costs, you'll need to calculate the number of personnel hours expended and
then multiply that by the cost per labor hour. When you calculate the cost per labor
hour, be sure to include not only the employee's immediate salary, but also any
overhead costs (such as benefits) associated with personnel time. For example, to
calculate the hourly rate for a full-time employee who makes $30,000 per year and
works an average of 40 hours per week, you will need to find out from your accounting
department the full cost of annual benefits the employee receives. Let's suppose this is
25% of salary, or $7,500 per year. The annual cost to your company for this employee
is $37,500. There are 2080 work hours per year (40 hours per week x 52 weeks per
year). Therefore, this employee's labor costs your company $37,500/2080 hours =
$18.03/hour.
When exact costs are unknown or unavailable, you can roughly
estimate (or even arbitrarily assign) the total costs associated with
an environmental cost area (such as "labeling" or other items listed
in the left-hand column of the table, for example). You can then
estimate how that cost is distributed among the various components
of the process being analyzed based on your estimate of the relative
proportion of cost used by each activity. Estimates usually will give
you a reasonable idea of which activities generate the greatest costs.
You can then go on to determine the actual costs for the "highest
contributors."
12.9.6.4 Calculating Total Costs
Once you have calculated or estimated costs for each item in your
cost matrix, add the costs in each column. This will give you a total
cost per chemical used or waste produced.
12.9.7 Accounting for the Time Value of Money
As mentioned earlier, a dollar today is worth more than a dollar
tomorrow because of inflation and investment return. These two
factors, referred to as the "time value of money," can significantly
influence environmental cost assessments. A pollution prevention
investment that appears to be unprofitable or less profitable when
the time value of money is not considered may be clearly profitable
when the time value of money is factored into the analysis, as
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
illustrated by the example described in Box 12-7. The most
powerful way to factor the time value of money into an ECA
analysis is to use NPV analysis.
To understand NPV analysis, it is important to understand what
"Present Value" means. Essentially, Present Value is the value that
tomorrow's dollar is worth today. For example, suppose you invest
$100 today at a 10 percent interest rate. Your investment will be
worth $110 in one year and $121 in two years. Thus, working
backwards, the Present Value of $121 in two years is $100,
assuming an interest rate of 10 percent. (The "discount rate" used
to convert future costs and revenues to current dollars should be
based on the actual rate of return that the money invested could be
earning elsewhere, or the interest rate that the company would be
charged if they borrowed money to finance the investment.)
The NPV calculation captures this concept so that businesses can
adequately assess the value of their investments. The calculation
works by discounting the value of future costs and revenues (cash
flows). These discounted cash flows are then added together to
calculate the NPV. The NPV indicates how much extra return a
project generates above the percent return that is required by a
firm's owners or managers. NPV analysis often makes a pollution
prevention project look favorable compared either to current
practice or to alternative practices that have high waste management
and disposal costs.
Appendix 12-A provides more information on Net Present Value
analysis, as well as two other common methods that can be used to
characterize a project's profitability: payback period analysis and
internal rate of return. These concepts can sometimes be difficult
to understand if you don't have an accounting or financial
background. Fortunately, a number of spreadsheets and software
programs have been developed that can perform the necessary
calculations based on relatively straightforward inputs. Section
12.11.2 describes some ECA software programs currently being
developed specifically for metal finishers.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Box 12-7 Using Total Cost Accounting To Evaluate the Benefits of a
Pollution Prevention Investment
Precision Circuits is a circuit board maker based in Washington State. Total Cost
Accounting, a form of ECA that accounts for the time value of money (see Box 12-1),
helped the firm understand the true vaiue of a pollution prevention investment it had
made. Before using TCA, the firm had underestimated the value of this investment by
at least $33,000.
In 1993 Precision Circuits prepared a Pollution Prevention Plan, as required by the
State of Washington. The company estimated that replacing its stainless steel racks
with plastic-coated copper-splined racks would save $555 over a 5-year period. The
firm's estimate took into account the costs of purchasing and installing the racks and
the savings from eliminating the purchase and disposal of the nitric acid used to strip
the racks. The initial analysis did not account for the time value of money, or for
savings from improvements in the quality of the circuit boards.
Although the estimated savings were minimal, the company decided to go ahead with -
the purchase because they wanted to eliminate worker exposure to the nitric acid.
Coating the stainless steel racks was another and less expensive option. The company
preferred to purchase the plastic-coated copper-splined racks, however, because they
distribute the electrical current more evenly. This results in an accurate and consistent
plating process with a better quality output.
After the racks were replaced, the Pacific Northwest Pollution Prevention Research
Center (PPRC) arranged for a team of researcher^ from the University of Washington to
perform a TCA analysis of the project. They wanted to assess whether TCA was suited
to small manufacturers. Their analysis determined that the 5-year net present value
(NPV) of the switchover to the plastic-coated racks was $33,589, as compared with the
firm's initial estimate of $555. The payback period for the racks (i.e., the period of time
it would take the project to return the original investment) was just over 1 year, as
compared to the firm's 5-year payback estimate. TCA analysis showed that the biggest
cost savings—$8,660 annually—came from the improvement in quality that resulted
from using the new racks.
Precision Circuits uses a computer package called SCS, marketed by a local company, to
do a full range of business activities including project scheduling and management.
They use a bar-coding system to track labor and materials used for each job. Some of
the information collected by this system provided input into the TCA. Other
information was collected from members of the accounting, purchasing, and production
departments. Gathering information for the TCA only required 12 hours of Precision
Circuit's staff time, in part, because they were able to access information from their
computerized system.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
Box 12-7 Using Total Cost Accounting To Evaluate the Benefits of a
Pollution Prevention Investment (cont.)
The researchers from the University of Washington used the "P2 Finance" spreadsheet
program available from Tellus Institute (see Section 12.11.2) to perform the Total Cost
Assessment for Precision Circuits. Tellus is planning to develop specialized TCA
software for the metal finishing industry in 1997. The Pacific Northwest Pollution
Prevention Research Center is currently helping a Western Washington metal plater use
a simplified spreadsheet program in a pilot project to demonstrate TCA to metal
finishers.
Sources:
¦ Scott, G. 1996. Precision Circuits. Personal communication. March 11.
¦ Leviten, D. 1996. Pacific Northwest Pollution Prevention Research Center.
Personal communication. March 8.
¦ Badgett, L., B. Hawke, and K. Humphrey. 1995. An analysis of pollution
prevention and waste minimization opportunities using Total Cost Assessment:
A case study in the electronics industry. Pacific Northwest Pollution Prevention
Research Center. September.
12.10 Implementing the Results and Institutionalizing ECA
An ECA project provides information about the particular area (i.e.,
process, facility, etc.) investigated. Once the analysis is completed,
the information can be used to fulfil the original goals of the
analysis—for example, to decide whether to invest in pollution
prevention equipment.
The project (especially a pilot project) also provides information
about the potential value of further ECA analysis to the company.
Management can use the initial ECA experience to decide whether
and how to continue using ECA within the company.
As corporate experience with ECA grows, management may also
consider institutional changes, based on the kind of information
that ECA has and will continue to provide within the company.
Options include, for example:
¦ Promoting awareness about the value of ECA and the
importance of considering the full spectrum of environmental
costs.
December 1996
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Environmental Cost Accounting
Part U, Chapter 12
¦ Integrating ECA into other business practices such as
strategic planning, capital budgeting, new product
development, or corporate reengineering.
¦ Establishing a system to hold managers accountable and/or
reward them for effectively managing environmental costs.
¦ Changing the company's accounting, environmental, or
management practices.
12.11 Where To Go for Further Information About ECA
A number of organizations are sponsoring or involved in developing
ECA mechanisms and computer software. EPA has been tracking
developments in this field and maintains a clearinghouse of
information on ECA, as described below. In addition, efforts are
underway to develop ECA software and tools specific to the metal
finishing industry. The ECA field is rapidly evolving and additional
tools specific to the metal finishing industry may well be developed
in the future.
12.11.1 Clearinghouse and Publications
The EPA's Pollution Prevention Information Clearinghouse (PPIC)
maintains and disseminates information on ECA and other guidance
and tools related to pollution prevention. Resources available from
PPIC include:
¦ Environmental Accounting Resource List (Publication Number:
EPA 742-B-95-001). This is a comprehensive list of
publications compiled by EPA's Office of Pollution
Prevention and Toxics from government and industry
sources. A copy of the list which was updated in February
1996 is included in Appendix 12-B. (Some additional
references also are listed in Section 12.12 below.)
¦ Application for membership in EPA's Environmental
Accounting Project Network for Managerial Accounting and
Capital Budgeting.
¦ The following web site provides biannual updates on EPA's
ECA resources: http://es.inel.gov/partners/acctg.
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
For more information, contact:
Pollution Prevention Information Clearinghouse (3404)
U.S Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
202-260-1023
12.11.2 Software Programs
The Tellus Institute has developed a user-friendly spreadsheet
software program, called P2/FINANCE, that is designed to guide
companies in data collection and analysis for evaluating pollution
prevention projects. P2/FINANCE offers a valuable starting point
for introducing a Total Cost Assessment approach that provides for:
¦ A broader inventory of environmental costs and savings.
¦ Allocation of costs and savings to specific process and
product lines rather than overhead accounts.
¦ Expanded time horizons to capture long-term benefits.
¦ Use of profitability indie \tors that incorporate the time value
of money.
This software program is available for a fee from the Tellus Institute.
It will be available at no charge from PPIC by the end of 1996.
In addition, the Tellus Institute is developing a specialized software
program for the metal finishing industry that is scheduled to be
available in 1997.
For more information contact:
Tellus Institute
11 Arlington Street
Boston, MA 02116
617-266-5400
December 1996
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Environmental Cost Accounting
Part II, Chapter 12
12.11.3 EGA. Guidance Document for the Metal Finishing
Industry
EPA and the Waste Reduction Institute for Training and
Applications Research (WRITAR) are testing the application of
ECA methodologies in the metal finishing industry. Based on these
results, a guidance document is being prepared on the development
and application of ECA methodologies for key operations in the
metal finishing industry for use in pollution prevention project
reviews. The document is scheduled for publication by EPA in the
end of 1996. Its working title is Feasibility of Adoption of ECA
Methodologies in the Metal Finishing Industry. The document is
targeted for technical assistance providers, but may also be useful to
some metal finishers who want to explore the application of TCA to
their business. For more information, contact EPA's Environmental
Accounting Project at 202-260-4164.
12.12 References
World Resources Institute. 1995. Green ledgers: case studies in
corporate environmental accounting. D. Ditz, }. Ranganathan, and D.
Banks, eds.
U.S. Environmental Protection Agency. 1995. An introduction to
environmental accounting as a business tool: Key concepts and terms. EPA
742-R-95-001. Office of Pollution Prevention and Toxics,
Washington, DC.
Bartlett, K.L., R.R. Lester, and R.B. Pojasek. 1995. Prioritizing P2
opportunities with activity-based costing. Pollution Prevention Review
5(4). New York, NY: John Wiley and Sons.
December 1996
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APPENDIX 12-A
FINANCIAL ANALYSIS OF
POLLUTION PREVENTION PROJECTS
-------
ONoEFft
Number 33
October 1995
State of Ohio
Environmental Protection Agency
Fact Sheet
Pollution Prevention
Financial Analysis of
Pollution Prevention Projects
'Pollution prevention pays!" 'Waste reduction always pays!" "Profit from pollution pre-
vention!" These slogans used by 3M, Dow, and people promoting the concept of pollu-
tion prevention are familiar adages about reducing waste and saving money. But moti-
vational slogans cannot predict if a particular pollution prevention project will be suc-
cessful in reducing waste and saving money.
Financial analysis of a pollution prevention project will assist
a company in determining if that particular investment will
add economic value to the company. This value can be
assessed by calculating cash flows over the life of the project
and applying measures of profitability. However, many of the
costs and potential savings of pollution prevention projects are
not included or are underestimated in conventional financial
analysis.
Pollution prevention projects may not effectively compete in
the capital budgeting process because the conventional cost
accounting systems were not specifically designed to evaluate
such projects. Conventional cost accounting systems are used
to provide information to management, investors, regulators
?:,d other external entities on the financial performance of a
business, and also to provide management with information to
make decisions.
Traditional cost categories include direct materials, direct
labor, and overhead. Many indirect costs may be hidden in
the overhead category and traditional financial analysis may
underestimate the potential savings from a pollution preven-
tion project Also, conventional cost accounting might not
evaluate the project over a long time period and usually does
not consider numerous important qualitative issues, possibly
causing the pollution prevention project to be rejected.
What can you do to try to overcome some of these obstacles
and to determine the true costs and savings of a pollution
prevention project? This fact sheet can help by covering
the basic financial evaluation of a pollution prevention
project, including the following steps:
$$
Collecting cost Liformation on current process costs and
proposed project costs;
*5 Applying measures of profitability.
$$ Considering less tangible costs;
$$ Presenting the pollution prevention project to decision
makers.
You might read this overview and think, "I don't have time lo
do all these steps or to design a new accounting system!"
Remember, the goal of this analysis is to look at costs and
savings associated with a pollution prevention project in a new
way, not necessarily to fundamentally change your accounting
system. Try this analysis on one small project first to see how
it might work, or try portions of the analysis as your time and
resources allow.
Collecting cost information on
current process costs and proposed
project costs
The first phase of the financial analysis of a pollution
prevention project entails gathering complete and accurate
data for costs that have a material impact on the decision and
that are useful to those who evaluate the project proposal.
These costs should be expressed as the differences between the
costs of the current process and the projected costs of the
proposed project. All costs should be converted to total annual
amounts in order to perform the financial analysis with
common metrics. The following procedures can be used to
determine these costs (NEWMOA/OTA, 1994).
$$
Draft a process flow diagram of the existing process that
will be altered by changes in equipment, materials, process
design or other pollution prevention techniques. The diagram
should include the primary process and oilier secondary
process flows that are related to or affected by the main
process.
recydable pap^led ^ Office of Pollution Prevention, Ohio Environmental Protection Agency, PO. Box 10-19,
Columbus, OH 43216-1049, (614) 644-3469
-------
Pollution Prevention
Financial Analysis of Pollution Prevention Projects
$$ Use the process flow diagram to chart all the labor
activities, materials equipment and other operating expense
items that are involved in the production process and
secondary processes. In a pollution prevention project the
most important activities to be aware of arc those related to the
tracking, treatment and disposal of waste, and those related to
purchasing, handling and using hazardous chemicals.
A conventional cost accounting system may hide indirect costs
in an overhead account. To determine the full cost of a
pollution prevention project, you will want to know aJj the
costs, including the "hidden" costs, that are attributed to a
specific process and what drives those costs. Refer to
Table 1, "Potential Operating Costs," for a checklist of
potential operating costs, including "hidden costs," that should
be considered.
$$ Repeat the first two steps for the new process. Refer to
Table 2, "Potential Initial Costs" for a checklist of potential
initial costs that should be considered. Look carefully for the
"hidden" costs and savings.
$$
Identify all the places where labor activities, materials,
equipment and other operating costs are likely to change.
$$
Determine the costs in the current process and in the
proposed project for those activities and items that will change
because of the proposed project
$$ Calculate the differences between the current and
proposed processes. Be sure to express the costs in after-tax
amounts. For example, depreciation of equipment will reduce
the taxable income of a company.
Sources of cost information include interviews with
operational and environmental personnel; logs of various
activities or materials; records from purchasing, payroll, and
accounting", receipts and invoices; and vendors.
It is possible that by looking for all of the costs and savings
associated with a process or project, you might identify more
costs than originally anticipated. The additional costs might
cause the proposed pollution prevention project to be rejected.
This might be discouraging, but remember that your primary
goal is to determine if a particular pollution prevention project
will reduce waste and save money when compared to a current
process. Keep the rejected project on file and try the financial
analysis again at a later time when costs and savings figures
may have changed.
Applying measures of profitability
A measure of profitability is a single number that is calculated
to characterize project profitability in a concise,
understandable form. There are three common methods, or
measures of profitability, used to assist the decision makers in
a financial analysis to determine if a pollution prevention
project will add economic value to a company. These
measures include: Payback period. Net Present Value (NPV).
and Internal Rate of Return (ERR). Each method is briefly
explained here, including appropriate uses, advantages, and
limitations (following NEWMOA/OTA, 1994). The reader is
encouraged to consult the references at the end of the fact
sheet for a more detailed explanation with examples for each
of these methods.
If you do not have a background in financial analysis or feel
you do not have time to perform numerous calculations, don't
despair! There are numerous spreadsheets and relatively
straightforward computer programs that can do most of the
work for you. If you have identified and collected cost and
savings information, you have already done much of the work.
Payback period analysis (simple payback) measures how
long a project will take to return its original investment and
ranks projects according to the length of the period: the
shorter the period, the more attractive the project The
payback period is the amount of time required for an
investment to generate enough cash flow to just cover the
initial capital outlay for that investment (Tellus, 1995). Cash
flow from an investment is the dollars coming to the company
(cash inflow) or paid out by the company (cash outflow)
resulting firom a given investment (Tellus, 1995).
Depending on the nature of the cash flows, payback period can
be calculated as follows:
$$ If annual cash flows are equal, the initial investment
amount is divided by the annual cash flow. For example, if
the initial investment is $12,000 and the first year annual cash
flow is $15,000, then the pa>back period is 12,000/15,000 =
0.8 years.
$$ If the first year cash flow is greater than the initial
investment, the initial investment amount is divided by the
first year cash flow.
$$ If cash flows vary, and the initial investment is greater
than the first year cash flow, succeeding years' cash flows are
added incrementally until they equal the initial investment
amount.
2
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Fact Sheet
$<£<£<£<£<£(£<£<£<£<£<£<£<£
Cp Cp Cp Cp Cp Cp Cp *>p ^ ^ ^
Payback period analysis has two drawbacks: it ignores the
time value of money, and it ignores cash flows that occur after
the initial investment has been recouped and does not show
costs and savings past the point where the project has paid for
itself. A chart that tracks the percentage payback of all cash
flows over the life of the project may increase the payback
method's usefulness.
Payback analysis provides a useful preliminary assessment of a
project's attractiveness. If the payback is very short and the
project is relatively simple, payback period analysis may be
sufficient. However, this initial assessment should be verified
by a Net Present Value analysis.
Net Present Value (NPV) analysis relies heavily on the
concept of the time value of money and is the most powerful
tool for assessing profitability over the life of a project. The
time value of money recognizes that receiving $100 today is
not equivalent to receiving $ 100 at some point in the future,
because the S100 today can be invested to earn a return. Net
Present Value is the present value of the future cash flows of
an investment, minus the investment's current cost (Tellus,
1995).
The time value of money measures the value of money at
afferent points in time as determined by a discount rate. The
discount rate is the interest rate that is used to relate the future
value of the money to the present value of the money. The
discount rate is the rate of interest or return that a business or
person can earn on the best alternative use of the money at the
same level of risk. The discount rate is a function of what that
company must pay to acquire capital (money) and what rate of
return for a given level of risk it must earn on the investment
to satisfy management and shareholders. Note that discount
rates are not inflation rates, although they usually incorporate
the projected rate of inflation. An example of how Net Present
Value can be calculated is shown in Table 3.
Net Present Value analysis should be used when initially
evaluating major pollution prevention projects and for the
final analysis of most projects. Advantages of Net Present
Value analysis are it considers the time value of money and it
measures the risk-adjusted value added to the company.
Disadvantages include that it is more information and
calculation intensive, requires the estimation of cash flows
over the life of the project and requires the calculation of a
discount rate.
Internal Rate of Return (TRR) is a profitability measure,
expressed in percentage terms, that is analogous to an average
rate of return from an investment. IRR is the discount rate
that will yield a net present value of zero for a given stream of
cash flows. This method allows a comparison between the
IRR of a project and a company's self-determined discount
rate. A financial calculator or computer spreadsheet should be
used to determine IRR. In general, if the IRR is greater than
the discount rate, the project will be accepted. If the IRR is
less than the discount rate, the project will be rejected.
The IRR can provide a convenient way of examining the
return that a project will generate. Using the NPV and the
IRR approaches result in the same alternative being chosen
because these approaches are essentially the same. IRR shows
the rate of return that a project generates, while NPV shows
the present day dollar value of the return that a project
generates. However, IRR analysis ignores the impact of the
scale of a project. For example, a project that requires an
investment of SI 00 and returns $125 in one year will have the
same IRR as a project that requires a $200,000 investment and
returns $250,000 in one year. IRR should only be used to
judge if a project is profitable, not for prioritizing projects.
Use NPV for prioritizing and comparing projects because it
yields consistently valid results.
Net Present Value is generally the most valuable, problcm-frcc
measure of profitability. Other indicators that consider the
time value of money, such as Internal Rate of Return, arc also
useful. Payback should be used only for small projects, for a
first-cut rough screening analysis, or to complement NPV and
IRR information. (Tellus. 1995)
If you have accurately estimated cash flows mid selected t he
appropriate discount rate, all projects with a positive NPV are
profitable and may be worth implcmcnu'ng. If you have
several projects competing for funding, or more than one
pollution prevention option, choose the alternative with the
highest NPV, not the highest IRR. (U.S. EPA, 1994)
Considering less tangible costs
Pollution prevention projects may have other factors that affect
a business that are difficult to quantify, but mnv still have
strategic significance. Issues such as product qualify,
productivity, market share, stakeholder relations, employee
health and safety, public image, a proactive environmental
strategy, and criminal and financial liability can be very
3
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Pollution Prevention
Financial Analysis of Pollution Prevention Projects
Table 1. Potential Operating Costs
Materials
direct product materials
catalysts and solvents
•wasted raw materials
transport
storage
Waste Management
(Materials & Labor)
pre-treatment
on-site handling
storage
hauling
insurance
disposal
Utilities
electricity
steam
cooling & process water
refrigeration
fuel (gas or oil)
plant air & inert gas
sewerage
Direct Labor
operating labor & supervision
manufacturing clerical labor
inspection (QA & QC")
worker productivity changes
Indirect Labor
maintenance (materials & labor)
miscellaneous (housekeeping)
medical surveillance
Regulatory Compliance
monitoring
manifesting
reporting
notification
recordkeeping
training (nght-to-know,
safety etc.)
training materials
inspections
protective equipment
labeling
penalties/fines
lab fees
insurance
R&D to comply with regulations
handling (raw materials and waste)
closure & post-closure care
Revenues
sale of product
marketable by-product
manufacturing through-put change
change in sales from:
increased market share
improved corporate image
Future Liability
fines & penalties
persona' injury
This list is from NEWMOA/OTA, 1994, as adapted from material published by the Tellus Institute.
The non-italicized items are those most likely not to be included in the financial analysis of a pollution
prevention project either because they are hidden in overhead or because their allocation is insufficiently
specific.
4
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Fact Sheet
$<£<£(£<£(£<£<£(£<£<£(£<£<£
cp
Table 2. Potential Initial Costs
Purchased Equipment
equipment
sales tax
price for initial spare parts
process equipment
monitoring equipment
preparedness/protective equipment
safety eauipment
storage & materials handling equipment
laboratory/analytical equipment
freight, insurance
Utility Connections and New Systems
electricity
steam
cooling & process water
refrigeration
fuel (gas or oil)
plant air
inert gas
general plumbing
sewerage
Installation
vendor
contractor
in-house staff
construction/installation
labor & supervision
taxes & insurance
equipment rental
Start-up & Training
vendor/contractor
in-house
trials/manufacturing variances
Materials
piping
electrical
instruments
structural
insulation
building construction materials
painting materials
ducting materials
Site Preparation
demolition, clearing etc.
disposal of old equipment, rubbish
walkways, roads, and fencing,
grading, landscaping
Engineering/Contractor
(in-house & external)
planning
engineering
procurement
consultai ts
design
drafting
accounting
supervision
Permitting - Fees & In-House Staff
Initial Charge for Catalysts and Chemicals
Working Capital
(raw materials, inventory, materials/supplies)
Salvage Value
This list is from NEWMOA/OTA, 1994, as adapted from material published by the Tellus Institute.
Many of these costs may or may not be capitalized depending upon the judgment of a company's financial
staff.
5
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Pollution Prevention
Financial Analysis of Pollution Prevention Projects
Table 3. Net Present Value calculation
Present Value of an Investment
What is the value of future cash flows today? For example, what amount of money invested now at 10% will equal
SI30 in two years?
PV = FV / (1 + r)T
PV = SI 30/(1 + 0.1):
PV = SI 30/1.21
PV = $107.44
PV = Present value, the value of the money received today (PV = S107.44)
FV = Value that will be received in the future, when invested at r (FV = $130)
r = The rate at which funds received today could be invested (r = 10%)
T = The number of time periods in which interest is earned (T = 2)
Receiving $ 130 in two years is equivalent to receiving $107.44 today and investing it for two years at 10 percent.
Net Present Value Analysis
Net Present Value (NPV) analysis compares the PV of the cash inflows to the initial investment. How do these present
values relate to the initial cash outlays/ For example, in the present value analysis above, we could ask whether a
projected income of $130 in two years is worth an initial investment of $100. To determine if this is a worthwhile
investment, we subtract the initial investment from the PV of the cash received in year 2, as shown here.
NPV = PV (cash inflows) - PV (cash outflows)
NPV = $107.44 -$100
NPV = $7.44
The NPV indicates how much extra return a project generates above the percent return that is required by a firm's
owners or managers. In this example, the investment generates $7.44 in excess of the 10 percent return that is re-
quired.
If NPV is greater than zero, the project should be accepted.
If NPV is less than zero, the project should be rejected?
If NPV equals zero, the project generates exactly the return that is required.
NPV can be calculated for investments that cover different time periods. Present Value tables are also available that
calculate PV factors for different discount rates and years. Refer to the document, "Improving your competitive
position: Strategic and financial assessment of pollution prevention projects" (NEWMOA/OtA, 1994) for more
information.
important criteria in the analysis of a pollution prevention
project. Potential liability categories include disposal, storage,
transportation, real property damage, civil actions, toxic tort
suits, fines, penalties, and criminal liability.
Try to keep in mind that businesses deal with probabilities of
success and failure of many aspects of their work all the time.
Now you will be trying to apply this probabilistic/qualitative
approach to the analysis of a pollution prevention project.
Decide which issues have a strategic significance to the
company and which issues are related to a particular pollution
prevention project. Assess the possible impacts of those issues
and include the issues and the assessment in your presentation
of the pollution prevention project to decision makers. More
detai led discussion of how to evaluate qualitative issues and
how to communicate their importance in a pollution
prevention project is presented in "Improving your competitive
position: Strategic and financial assessment of pollution
prevention projects" (NEWMOA/OTA, 1994).
Presenting the pollution prevention
project to decision makers
After completing your financial analysis, whether or not the
pollution prevention project is approved and funded may
partially depend on how you present the project to the decision
makers. Because you have accumulated good cost information
and performed many supporting calculations, you may be
tempted to present numerous pages of technical financial data.
A better approach is to begin the proposal with a short
executive summary, including a concise project description, a
graph illustrating the project's profitability using the measure
6
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i LCVx t ky i iv/ v/ c
vp vp Cp Cp vp vp y Cp Cp ^ ^
that best suits your project, and a very brief discussion of the
most important qualitative benefits of the project These areas
can then be supplemented with more detailed information in
following pages.
If you are not successful in your first attempt at obtaining
funding for the pollution prevention project, try to determine
the reasons for rejection and critically review and revise the
proposal. Remember that changes in cost accounting methods
to include all the costs and savings of a pollution prevention
project and careful consideration of the qualitative aspects of
the project may be new ways of thinking about capital
budgeting for the decision makers. You might want to try this
approach on one small project to demonstrate the benefits of a
different approach to thinking about costs of a pollution
prevention project.
Some pollution prevention projects are not approved during
their first review. Revise your proposal and submit it agaia
You might also want to consider assistance available from
Ohio EPA and the State of Ohio to strengthen your proposal,
such as low interest loans (see below) and pollution prevention
technical assistance from the Ohio EPA's Office of Pollution
Prevention.
State of Ohio Pollution Prevention
Loan Program
The Ohio Environmental Protection Agency and the Ohio
Department of Development are offering low-interest capital-
improvement loans to small and medium sized businesses in
the State of Ohio for Pollution Preventioa The program is a
revolving loan fund and has ten million dollars total set aside
for 1995 and 1996. Loans are available from $25,000 to
S350,000, at a fixed interest rate currently set at two-thirds of
the prime rate. The loans can be used for part of the costs of
acquisition or renovation of machinery and equipment for
pollution prevention and/or energy conservation. Preferential
interest rales are available on a case-by-case basis in distressed
areas of the state.
Ohio EPA performs a technical review of the application and
then forwards it to the Ohio DOD to determine loan eligibility.
Applicants are asked to describe the amount of pollution
currently generated and how much will be prevented.
Companies must be able to demonstrate measurable
environmental improvements through pollution prevention for
the program.
Contact: William Narotski
Ohio Environmental Protection Agency
Office of Pollution Prevention
P.O. Box 1049
Columbus, OH 43216-1049
614/644-3469
Brad Biggs
Ohio Department of Development
Economic Development Division
77 South High Street, 28th floor
Columbus, OH 43215-0606
614/466-4551
Office of Pollution Prevention
Technical Assistance Activities
Technical assistance is a major portion of the Office of
Pollution Prevention's services, and the Office has several
staff assigned to providing pollution prevention information.
On-site visits, mail, lelephone and other communications and
services are provided. In addition to conducting on-site
pollution prevention assessments at Ohio business, the Office
of Pollution Prevention (OPP) provides information on
pollution prevention facility planning to many Ohio
companies by conducting meetings and facility visits. Both
efforts help facilities help themselves in initiating or
improving their own programs.
OPFs technical assistance activities are provided in a non-
regulatory manner. However, in addilion lo this voluntary
program, OPP is able lo provide information directly rclaicd lo
regulatory issues. The Office often assisis in addressing
regulatory issues of Ohio businesses and others through
pollution prevention.
OPP creates, collects and distributes current pollution
prevention information. OPP provides presentations to about
100 groups per year, mostly business organizations. The
Office also assists in the planning of several pollution
prevention seminars and conferences per year in cooperation
with local and state business organizations and others.
7
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Pollution Prevention
Financial Analysis of Pollution Prevention Projects
Acknowledgements
Much of Lhe information for this fact sheet was modified and
directly quoted from the Northeast Waste Management
Officials' Association and the Massachusetts Office of
Technical Assistance publications, "Improving your
competitive position: Strategic and financial assessment of
pollution prevention projects," Training manual and
Instructor's guide (two separate publications). We are grateful
for their assistance with this fact sheet
References and Resources
(For more information on how to obtain these publications,
please contact Ohio EPA's Office of Pollution Prevention at
614-644-3469)
American Institute for Pollution Prevention. 1992. A primer
for financial analysis of pollution prevention projects. AIPP,
Cincinnati, Ohio.
Northeast Waste Management Officials' Association and the
Massachusetts Office of Technical Assistance. 1994.
Improving your competitive position: Strategic and financial
assessment of pollution preven,;on projects. Training manual
and Instructor's guide (two separate publications).
NEWMOA and MA OTA, Boston, Massachusetts.
Pacific Northwest Pollution Prevention Research Center.
1993. Environmental economics: What's the bottom line?
Pollution Prevention Northwest, Spring/Summer, 1993.
Rooney, Charles. 1993. Economics of pollution prevention:
How waste reduction pays. Pollution Prevention Review,
Summer, 1993.
U.S. EPA. 1994. Environmental accounting resource listing:
Design for the Environment (DfE) accounting and capital
budgeting for environmental costs. EPA 742-F-94-004. U.S.
EPA, Office of Pollution Prevention and Toxics, Washington,
DC.
U.S. EPA. 1994. Green Lights Program Lighting Upgrade
Manual. Financial Considerations chapter. U.S.EPA, Office
of Air and Radiation, Global Change Division, Washington,
DC.
White, Allen, Monica Becker, and Deborah Savage. 1993.
Environmentally-smart accounting: Using total cost
assessment to accelerate industrial pollution prevention.
Pollution Prevention Review, Summer, 1993.
White, Allen and Deborah Savage. 1995. Environmental
cost accounting and capital budgeting. Tellus Institute,
Boston, Massachusetts. July 12, 1995 Videoconference,
Modern Manufacturing series. National Technological
University, Fort Collins, Colorado.
World Resource Institute. 1995. Green ledgers: Case studies
in corporate environmental accounting. World Resource
Institute.
This is the thirty-third in a scries of fact sheets that Ohio
EPA has prepared on pollution prevention. For more
information, call the Office of Pollution Prevention at
(614) 644-3469.
The Office of Pollution Prevention was created to
encourage multi-media pollution prevention activities
within the state of Ohio, including source reduction and
environmentally sound recycling practices. The office
analyzes, develops, and publicizes information and data
related to pollution prevention. Additionally, the office
increases awareness of pollution prevention opportuni-
ties through education, outreach, and technical assis-
tance programs directed toward business, government,
and the public.
Pollution prevention means the use of source reduction
techniques in order to reduce risk to public health,
safety, welfare and the environment and, as second
preference, the use of environmentally sound recycling
to achieve these same goals. Pollution prevention
avoids cross-media transfers of waste and/or pollutants
and is multi-media in scope. It addresses all types of
waste and environmental releases to the air, water and
land.
8
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United Scales Office of Pollutiou Prevention EPA742-B-95-001
Environmental Protection and Toxics February 1995
Agency Washington. DC 20460
Environmental Accounting
Resource List
(Revised February 1995)
A Product of the Design for the. Environment
(DfE) Environmental Accounting Project:
Promoting Improved Management
Accounting and Capital Budgeting for
Environmental Costs
-------
Table of Contents
Topic Page
Activity Based Costing L
Bibliographies 1
Curricula 2
Case Studies 3
Corporate Environmental Accounting 3
Environmental Accounting in Other Sectors 7
Financial and Economic Analysis 8
Pollution Prevention 9
Quality Costs 9
Preface
This resource listing presents selected information sources and includes ordering information and
cost (if applicable). Most of these sources are non-EPA sources. A listing of all documents on this topic
written by EPA's Environmental Accounting Project can be obtained by calling the Pollution Prevention
Information Clearinghouse at (202) 260-1023.
The information in this resource list is obtained from industry and government sources believed to
be reliable and compiled by ICF Incorporated for EPA's Environmental Accounting Project. The
Accounting Project created this resource listing to provide information on non-EPA environmental
accounting resources to those active or interested in enviromental accounting. The analyses and
summaries, nor the contents of the resources, necessarily reflect EPA's views.
If you know of additional materials that should be included in future revisions of this
resource guide, please send a copy of the material and a short narrative including the title, short
description of the material, contact information, cost if any, and publication date to:
Holly El wood
US EPA
Pollution Prevention Division (7409)
401 M Street, SW
Washington, DC 20460
Fax: (202) 260-0178
-------
ENVIRONMENTAL ACCOUNTING RESOURCE LISTING
ACTIVITY-BASED COSTING
1. An ABC Manager's Primer Straight Talk on
Activity-Based Costing
Cokins, Stratton. &. Helbling. The authors, who
have led many ABC projects, take the mystique
out of ABC. The primer, written in simple, clear
language, gives a headstart for action in
implementing an ABC program. (93282/Cost
S15).
To order contact:
The Institute of Management Accountants
10 Paragon Drive
Montvale. NJ 07645-1760
Phone: (800) 638-4427
Fax: (201) 573-0639
2. Implementing Activity Based Costing
Editor Frank Collins (1991). This book
introduces the concept of activity-based costing.
(Cost S59.95) ISBN 0471112372
3. Implementing Activity-Based Cost
Management: Moving from Analysis to Action
Cooper, Kaplan, Maisel, Morrissey, Oehm. This
research study documents key implementation
issues and results, based on real-life examples
and case studies of eight companies. (92268/Cost
535)
To order contact:
The Institute of Management Accountants
10 Paragon Drive
Monrvaie, NJ 07645-1760
Phone: (800) 63S-4427
Fax: (201) 573-0639
To order contact:
John Wiley and Sons
1 Wiley Drive
Somerset, NJ 08875
Phone: (800) 225-5945
BIBLIOGRAPHIES
4. Environmental Accounting: Current Issues,
Abstracts and Bibliographies, United Nations
No.: E.92.II.A.23. This publication is a guide to
literature in the field of corporate environmental
accounting. It focuses on financial reporting and
national accounting. (Cost S15 plus S3.50
shipping and handling, pre-paid.
To order contact:
The Institute of Management
Accountants (IMA) library has an extensive list
of bibliographies on areas of interest to
management accountants, including Activity-
Based Costing, Capita] Budgeting, and
Environmental Accounting. The bibliographies
are free to members and cost $15 each for
nonmembers. For more information, call the
IMA library at (201) 573-9000.
United Nations Publications
Sales Section
Room DC2-0853, Dept. 600
2 United Nations Plaza
New York, NY 10017
Phone:' (212) 963-8302
Fax: (212) 963-34*9
= New Listing
Revised February 1995
1
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CURRICULA
*5. Improving Your Competitive Position:
Strategic and Financial Assessment of Pollution
Prevention Projects—Instructor's Guide and
Training Manual
1994. (Update for Costing and Financial
Analysis of Pollution Prevention Projects) These
documents provide an overview of capital
budgeting and the objectives of financial analysis.
The manuals define the parameters of cost
information and describe the procedures and
sources for gathering and developing this
information. In addition, the manuals detail
alternative methods for using cost data to
perform financial analysis and explain the
advantages and disadvantages of the different
measures of profitability. The manuals also
introduce various qualitative issues to be
considered in conjunction with a financial
analysis to determine the impact of a proposed
project. The training manual costs S7.50 for
nonprofit organizations and S15 for profit,
organizations. The instruction guide costs S15
for nonprofit organizations and S30 for profit
organizations.
To order contact:
Tcrri Goldberg
P2 Program Manager
NEWMOA
129 Portland Street, 5th Floor
Boston, MA 02114
Phone: (617) 367-8558
*6. Industrial Pollution Prevention Handbook
This textbook is a guide for managers or
engineers on how to implement a pollution
prevention strategy. It contains two chapters
that discuss total cost assessments. The first
chapter provides a theoretical description of total
cost assessment and includes three examples
showing how TCA provides a clearer picture of
the financial viability of investments. The other
chapter reviews the purpose of managerial
accounting information, the inadequacies of
current accounting systems to provide useful
managerial information, and proposals for
environmental information enhancements to
current systems to better reflect the
environmental cost burden to the firm.
To order contact:
Customer Service
McGraw-Hili, Inc.
1221 Avenue of the Americas
New York, NY 10020
Phone: (800) 722-4726
7. Costing and Financial Analysis of Pollution
Prevention Projects
Developed by the Northeast Waste Management
Officials' Association (1992). This packet on
costing and financial analysis of pollution
prevention projects was designed for use in a
workshop to introduce state pollution prevention
staff to concepts and methods of conducting
financial analysis for pollution prevention
projects. In addition to the workshop
curriculum, it includes case studies of pollution
prevention efforts in four small Massachusetts
companies. (Cost S20 for non-profit
organizations, S40 for all other organizations.)
To order contact:
Terri Goldberg
P2 Program Manager
NEWMOA
129 Portland Street, 5th Floor
Boston, MA 02114
Phone: (617) 367-8558
8. Curriculum Module on Environmental
Accounting
Developed by the National Pollution Prevention
Center, at the University of Michigan, this
regularly updated module provides an
introduction to the application of pollution
prevention to business accounting. It is a
continuously evolving resource list of educational
materials. Case studies can be purchased for Si
each and course syllabii for S2.50.
To order contact:
The University of Michigan,
School of Natural Resources and
Environment
430 E. University, Dana Building
Ann Arbor, MI 48109-1115
Phone: (313) 764-14i2
resource listing, see case studies #11 and #12.
For additional curricular materials in this
• - New Listing
Revised February 1995
2
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CASE STUDIES
'9. The Cost of Changing—Total Cost Analysis
of Solvent Alternatives
December 1993. Massachusetts Toxics Use
Reduction Institute. This free paper presents six
case studies to reveal the benefits of total cost
accounting and notes interesting trends in the
use of new cleaning technologies.
To order contact:
Janet Clark
Massachusetts Toxics Use Reduction Institute
University of Massachusetts
1 University Avenue
Lowell. MA 01854-2881
Phone: (508) 934-3346
Fax: (508) 934-3050
10. Polaroid: Managing Environmental
Responsibilities and Their Costs
Harvard Business School, N9-194-052, December
2, 1993. Written by Richard D. Stark under the
supervision of Professors Mary E. Barth and
Marc J. Epstein. A case prepared for class
discussion. (Cost S5.25)
To order contact:
11. Teaching Case Studies Applicable to Full
Cost Accounting and Capital Budgeting
The Management Institute for Environment and
Business have three teaching case studies:
Bayerische Motoren Werke (BMW); AT&T and
Tempes (a fictional company). The case studies
cost S5 each and should be'requested by the
name of the company.
To order contact:
Rebeckah Paulson
MEB
1220 16th Street, N.W.
Washington, D.C. 20036
Phone: (202) 833-6556
Fax: (202) 833-6228
Email: Meb@gwuvm.gwu.edu
For additional case studies in this
resource listing; see entries #3, #7, #8,
#13, #36, and #43. To obtain EPA'
case studies, contact PPIC at (202) 260-
1023.
Publishing Division
Harvard Business School
Boston, MA 02163
Phone: (617) 495-6 17
CORPORATE ENVIRONMENTAL ACCOUNTING
*12. Accounting for the Environment
Rob Gray, Jan Bebbington, and Diane Walters
(1993). This book provides a general
introduction to environmental accounting
including sources of advice, further reading, and
information on the research process used to gain
empirical evidence on the "greening" of the
accountancy practice. ISBN l55876075X(hc)-
I558760768(pb)
To order contact:
Markus Wiener Publishing
114 Jefferson Road
Princeton, NJ 08540
Phone: (908) 225-2727
*13. Accelerating Corporate Investment in
Cleaner Technologies Through Enhanced
Managerial Accounting Systems
Organization for Economic Cooperation and
Development. (1994) This report suggests how
companies can modify current capital budgeting
practices to ensure that clean technology projects
receive an unbiased evaluation. Total cost
accounting is described in detail and illustrated
in two case studies.
To order contact:
Environmental Directorate, OECD
2, rue Andrd Pascal
75775 Paris CEDEX 16
France, Attention: PPCD
*14. Business Environmental Cost Accounting
Practices Survey: Summary of Responses
Includes a summary of the survey responses on
environmental cost accounting practices. The
• = New Listing
Revised February 1995
3
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CORPORATE ENVIRONMENTAL ACCOUNTING (Continued)
survey was distributed at the GEMI 1994
conference.
To order contact:
Bristol-Myers Squibb Company
P.O. Box 182
E. Syracuse, NY 13057
Phone: (315) 432-2731
Fax: (315) 432-4761
*15. Enviro-Management--How Smart
Companies Turn Environmental Costs into
Profits
D. Keith Denton. (Prentice Hall, 1994) This
book outlines the challenges and benefits of the
new "green" corporate thinking by providing
managers with tools to profit from better
environmental management. The author
discusses life cycle costing, full cost accounting,
and using pollution management as a revenue
generator. ISBN 0130735035
To order contact:
Prentice Hall
Englewood Cliffs, NJ 07632
Phone: (201) 592-2000
* 16. Environmental Strategies Handbook: A
Guide to Effective Policies & Practices
edited by Rao V. Kolluru. The Handbook
features contributions by more than 30 experts
from the fields of environmental science, public
health, business, and law. It offers insights into
how industries can develop optimal
environmental strategies and integrate them into
long-term strategic plans to ensure growth and
competitive advantage at the national and
international levels. The Handbook also lists
environmental regulatory agencies, industry
associations, and environmental consulting firms
and support groups that can assist managers and
executives in profitably reconciling corporate
ambitions with environmental stewardship and
sustainable development.
To order contact:
McGraw-Hill, Inc
11 West 19th Street - 4th floor
New York, NY 10011
Attn: Tim Pletscher
Phone: (800) 2-MCGRAVV
Fax: (212) 337-4092
*17. Finding Cost-Effective Pollution Prevention
Initiatives: Incorporating Environmental Costs
Into Business Decision Making—A Primer
Global Environmental Management Initiative
(GEMI). (1994) This primer on "finding cost-
effective pollution prevention initiatives" explains
how businesses can improve their decision
making processes by using total quality
environmental management principles. The
book describes how to evaluate sustainable
pollution prevention initiatives and other
investment options by appropriately including
environmental costs and savings for each option.
The primer is intended to help a broad audience
of professionals to improve their decision making
skills using comprehensive cost information.
To order contact:
Global Environmental Management Initiative
(GEMI)
2000 L Street, N.W., Suite 710
Washington, D.C. 20036
Phone: (202) 296-7449
* 18. Getting to the Bottom Line: How TCA
Shows the Real Cost of Solvent Substitution
This article illustrates the application of total
cost accounting at two facilities and explores the
value of such analysis as a tool to support
pollution prevention and reveal the hidden costs
of solvent substitution. This article, written by
Mitchell Kennedy, president of P2 Consulting,
Inc. (P2C) in Hartford, Connecticut, was printed
in the Spring 1994 issue of Pollution Prevention
Review pp. 155-164.
• = New Listing
Revised February 1995
4
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CORPORATE ENVIRONMENTAL ACCOUNTING (Continued)
*19. Measuring Corporate Environmental
Performance: Best Practices For Costing and
Managing an Effective Environmental Strategy
Marc Epstein. This book surveys the
management of a number of large organizations
in an attempt to determine how environmental
costs and strategies affect decision making.
(Cost S35/95301)
To order contact:
Institute of Management Accountants
10 Paragon Drive
Montvale. NJ 07645-1760
Phone: (201) 573-9000
Fax: (201) 573-0639
20. Accounting for Environmental Compliance:
Crossroad of GAAP, Engineering, and
Government: A Survey of Corporate America's
Accounting for Environmental Costs
This 1992 report is the second Price Waterhouse
survey of accounting practices for environmental
compliance and related management issues.
To order contact:
Dean Petracca
Environmental Services, Price Waterhouse
600 Grant Street
Pittsburgh, PA 15219
Phone: (412) 355-6000
21. Accounting for the Environment
(Management Accounting Issues Paper 1)
The Society of Management Accountants of
Canada. This 1992 issue paper identifies key
issues in environmental accounting and offers
guidelines on improving environmental
accountability. It also addresses the role of the
management accountant in developing an
environmental agenda and designing performance
measures. (Cost S7 for non-members)
To order contact:
The Society of Management Accountants of
Canada (SMAC)
120 King Street West, Suite 850
P.O. Box 176
Hamilton Ontario
CANADA, LSN 3C3
SMAC Direct. Order Line: (800) 263-7622
22. Background Discussion of Total Cost
Accounting Within Petroleum Operations
This four-page paper developed by the American
Petroleum Institute's Pollution Prevention Task
Force explains the importance of total cost
accounting concepts for the petroleum industry
and suggests types of costs that should be
included in project evaluations.
To order contact:
Pollution Prevention Information
Clearinghouse (PPIC)
EPA Headquarters Library
401 M Street, SW 3404
Washington, D.C. 20460
Phone: (202) 260-1023
Fax: (202) 260-0178
23. Coming Clean: Corporate Environmental
Reporting (1993)
This survey report was published by Deloitte
Touche Tohmatsu International, the
International Institute for Sustainable
Development and Sustainability. The Green
Growth Company reviews environmental
disclosure information reported by companies
worldwide. The report identifies best practices
and business motives for disclosure and
concludes that many companies are 'ill prepared"
to respond to growing disclosure needs and that
pressures for more disclosure will continue to
grow. (Cost S25)
To order contact:
Erik Gilberg
Deloitte Touche
50 Fremond Street, Suite 2800
San Francisco, CA 94105
Phone: (415) 247-4872
24. Environmental Accounting: What's the
Bottom Line?
120 minute audio cassette and handouts. A
presentation on July 20, 1993 by F.lliot
Berkihiser, Chair of the Economic Council of the
American Institute of Pollution Prevention, on
defining and allocating costs and benefits (Cost
S10 plus Si.50 shipping and handling, make
check payable to PPRC)
• = New Listing
Revised February 1995
5
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CORPORATE ENVIRONMENTAL ACCOUNTING (Continued)
To order contact:
PPRC Communication;
1326 Fifth Avenue. Suite 650
Seattle, Wa 98101
Phone: (206) 223-1151
Fax: (206) 223-1165
25. Environmental Auditing and the Role of the
Accounting Profession
The Canada Institute of Chartered Accountants
(CICA) Research Report. This 1992 report of a
Study Group discusses what services constitute
environmental auditing, now and in the future,
and provides recommendations to the accounting
profession as to the roles it should play in
environmental auditing. (Cost S34.50)
To order contact:
The Canada Institute of Chartered
Accountants
277 Wellington Street West
Toronto, Ontario
CANADA, M5V 3H2
Phone: (416)204-3364
Fax: (416) 204-3414
26. Environmental Cost Accounting: Key
Definitions and Terms
This ten-page paper developed by the Business
Roundtable defines key terms commonly
associated with environmental cost accounting.
The definitions are intended to provide a brief
overview on this topic and to illustrate the
differences and relationships between various
terms and techniques.
To order contact:
The Business Roundtable
1615 L Street, NW
Washington, D.C. 20036-5610
Phone: (202) 872-1260
(requests by mail are preferred)
27. Environmental Cost Accounting: The
Bottom Line for Environmental Quality
Management
William G. Russell, Steven L Skalak, and Gail
Miller. Spring 1994, Total Quality
Environmental Manaeement. pp. 255-268. This
article discusses current cost accounting systems
available to support environmental management
systems. (Cost SI59 to subscribe, S39 for
individual book issue, prepayment is required)
To order contact:
John Wiley and Sons
1 Wiley Drive
Somerset, NJ 08875
Phone: (800) 225-5945
28. Environmental Costs and Liabilities:
Accounting and Financial Reporting Issues
The Canadian Institute of Chartered Accountants
(CICA) Research Report. This 1993 report of a
Study Group discusses information needs and
presents proposals and positions on accounting
for and reporting on environmental issues. (Cost
S34.50)
To order contact:
The Canada Institute of Chartered
Accountants
277 Wellington Street West
Toronto, Ontario
CANADA, M5V 3H2
Phone: (416) 204-3364
Fax: (416) 204-3414
29. Environmental Stewardship: Management,
Accountability and the Role of Chartered
Accountants
The Canada Institute of Chartered Accountants
(CICA). The CICA Board of Governors
accepted this 1993 report as providing guidance
to the profession.
To order contact:
The Canada Institute of Chartered
Accountants
277 Wellington Street West
Toronto, Ontario
CANADA, M5V 3H2
Phone: (416) 204-3364
Fax: (416) 204-3414
• = New Listing
Revised February 1995
6
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CORPORATE ENVIRONMENTAL ACCOUNTING (Continued)
JO. Management Accounting (The Official
Magazine of the Institute of Management
Accountants)
The February 1994 issue of this monthly journal
has articles on accounting for environmental
liabilities, deduction vs. capitalization of cleanup
costs, ABC and life cycle costing for
environmental expenditures, and environmental
management systems. (Cost S10 per copy, S20
yearly subscription for members. S125 for non-
members)
To order contact:
Institute of Management Accountants
10 Paragon Drive
Montvale. NJ 07645-1760
Phone: (201) 573-9000
Fax: f201) 573-0639
31. Reporting on Environmental Performance
The Canada Institute of Chartered Accountants.
The purpose of this 1993 discussion paper was to
stimulate comments on issues relating to
reporting on environmental performance. The
paper explores factors influencing organizations'
decisions to report information on environmental
performance and provides a generalized
framework for organizing such information.
(Cost S37.50)
To order contact:
The Canada Institute of Chartered
Accountants
277 Wellington Street West
Toronto, Ontario
CANADA, M5V 3H2
Phone: (416) 204-3364
Fax: (416) 204-3414
ENVIRONMENTAL ACCOUNTING IN OTHER SECTORS
Federal Government
32. Creating a Government thai Works Better
and Costs Less: Reinventing Environmental
Management, Accompanying Report to the
National Performance Review
Vice President A1 Gore, September 1993. This
report of the National Performance review
recommends among other things, that the
Federal Government should "Improve Federal
Decision Making Through Environmental Cost
Accounting." (Cost S14)
To order contact:
U.S. Government Printing Office
Superintendent of Documents
Mail Stop: SSOP
Washington. D.C. 20402-9328
Phone: (202) 512-1800
Military
assure the significant costs of environmental
effects are reflected in life cycle cost estimates
for major defense acquisitions.
To order contact:
Office of Secretary of Defense
Program Analysis and Evaluation
1800 Defense Pentagon
Washington, D.C 20301-1800
Phone: (703) 697-0317
Logistics
34. Logistics Spectrum-Journal of the Society
of Logistics Engineers, Volume 27, Issue 2
Special issue, September 1993: New Directions
in Logistics. First all environmental issue of this
quarterly. Member subscription: annual
membership dues include a S10 yearly
subscription; nonmember subscription: S50 U.S.,
S60 all others.
33. Environmental Costs: A New Element in To order contact:
Life Cycle Cost Estimates for DOD Acquisition
Programs Roger Nash
A keynote address presented to the International Logistics Spectrum
Society of Parametric Analysts, 16th Annual SOLE International Headquarters
Conference; June 2, 1994, by Michael R. 8100 Professional Place, Suite 211
Anderberg. This presentation describes what Hyattsville, MD 20785
DOD's Office of Secretary of Defense is doing to Phone: (301) 459-8446
• = New Listing
Revised February 1995
7
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FINANCIAL AND ECONOMIC ANALYSIS
*35. Alternative Approaches to the Financial
Evaluation of Industrial Pollution Prevention
Investments (Revised Executive Summary, June
1993)
This document provides support for the idea that
improved managerial accounting systems,
including accurate measurement and allocation
of both physical and cost aspects of waste
generation, are essential for achieving a clear,
unbiased perspective on the profitability of
industrial pollution prevention investments.
To order contact:
AJlen White, PhD. or
Deborah Savage, PhD.
Risk Analysis Group
Tellus Institute
11 Arlington Street
Boston, MA 02116-3411
Phone: (617) 266-5400
Fax: (617) 266-8303
*36. New Applications of Total Cost Assessment
This article (Pollution Prevention Review, Winter
1994/1995) describes a TCA case study
performed for the chemical manufacturing
division of a multinational, high technology firm.
The analysts of the costs and benefits of a closed-
loop, multi-purpose batch still solvent recovery
system illustrated the integral, quantifiable
connection between environmental investment
and production flexibility and planning at the
firm's facilities.
To order contact:
Deborah E. Savage, PhD. or
Allen L. White, PhD.
Tellus Institute
11 Arlington Street
Boston, MA 02116-3411
Phone: (617) 266-5400
Fax: (617) 266-8303
*37. Will Polluting Less Save You Money? A
Workbook for Total Cost Assessment
1994. This document explores using total cost
assessment to evaluate options, justify project
worth, and track project success. The handbook
provides users with the tools necessary to
examine pollution prevention projects using total
cost assessment. The exercises are designed to
teach skills in gathering data, performing the
analysis, and considering factors such as liability
and media shifting. The handbook can also be
used as an instructor's guide for inter-active
lessons on total cost accounting.
To order contact:
P2c
P.O. Box 231214
Old State House Square
Hartford, CT 06123
Phone: (203) 236-5911
38. A Primer for Financial Analysis of Pollution
Prevention Projects
(EPA/600/R-93-059) Introduces the time value
of money concept into analysis of pollution
prevention investments.
The Center for Environmental Research
Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45628
Phone: (513) 569-7562
Fax: (513) 569-7566
39. Cost Analysis (or Pollution Prevention
This four-page document, published by the
Washington State Department of Ecology,
dercribes a simple hand calculation to complete
the net present value of a pollution prevention
investment. It contains step-by-step directions.
(R-HWTR-93-129)
To order coatact:
Peggy Morgan
Washington State Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
Phone: (206) 407-6752
= New Listing
Revised February 1995
8
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POLLUTION PREVENTION
40. Facility Guide for Pollution Prevention
An EPA Guide to Setting up an effective
corporate pollution prevention program. EPA-
600-R-92-088.
To order contact:
The Center for Environmental Research
Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45628
Phone: (513) 569-7562
Fax: (513) 569-7566
41. Waste Minimization Guidance, Interim
Final Guidance to Hazardous Waste Generators
on a Waste Minimization 'Program in Place*
(May 28, 1993)
This guidance recommends improved
environmental accounting practices as pan of a
successful Waste Minimization Program.
To order contact:
Becky Cuthbertson: Office of Solid Waste
(703) 308-8447 or
RCRA Hotline: (800) 424-9346
TDD: (800) 553-7642
QUALITY COSTS
*42. Measuring, Planning, and Controlling
Quality Costs
Wayne J. Morse, Harold P. Roth, and Kay M.
Poston, Institute of Management Accountants.
(1987) This book uses the results of a study as
an introduction to quality costs; identifies major
issues in the measurement, planning, and control
of quality costs; summarizes the experience and
success of selected companies in measuring
quality costs; and provides guidance in
implementing a quality cost system. ISBN
0866411496.
To order contact:
Institute of Management Accountants
10 Paragon Drive
Montvale, NJ 07645-1760
Phone: (201) 573-9000
Fax: (201) 573-0639
43. Current Trends in Cost of Quality: Linking
the Cost of Quality and Continuous
Improvement
John Hawley Atkinson, Jr., Gregory Hohn«;r,
Bany Mundt, Richard B. Troxel, William
Winchell. This 1991 successor study to a 1987
report on Cost of Quality analyzes four case
studies and discusses the tactics and techniques
required to convert an organization to a
continuous quality improvement philosophy.
The document describes different ways of
measuring costs that would be useful in total cost
accounting. (Cost S35; 91259)
To or er contact:
Institute of Maaagemeat Accountants
10 Paragon Drive
Montvale, NJ 07645-1760
Phone: (201) 573-9000
Fax: (201) 573-0639
= New Listing
Revised February 1995.
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Notes
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CHAPTER 13
Superfund and Contaminated Properties
13.1 Introduction 13-3
13.2 Liabilities and Requirements 13-4
13.3 Sources of Contamination: How Does a Property Get Polluted? 13-8
13.4 Investigating Contamination 13-11
13.5 Remediation Standards (How Clean Is Clean?) 13-13
13.6 Remediation Technologies (What Are Common Cleanup Options?) 13-19
13.7 Facility Process Line Decontamination and Decommissioning 13-23
13.8 Incentives and Mechanisms for Voluntary Cleanups 13-27
13.9 Using Consultants and Attorneys 13-31
13.10 State Requirements 13-33
13.11 Where To Co for More Information About Contaminated Properties 13-34
There is potential for onsite contamination at metal finishing operations.
Under federal and state laws, metal finishers are liable for the costs of
cleaning up any soil or ground-water contamination associated with their
property or operation, including contamination created by previous owners.
This liability imposes a significant financial burden; cleanup costs can far
exceed the company's assets. Failure to address these liabilities can make it
difficult to sell, expand, or close a metal finishing operation. Fortunately,
many rapidly evolving government and private sector initiatives are now
making it possible to effectively manage the liabili ies associated with
contaminated property.
This chapter reviews the legal and technical issues concerning contaminated
property. First, you will learn about the potential liabilities connected with a
contaminated property and how a property becomes contaminated. Then
you'll find out about the current standards for cleanup activities (How clean is
clean?) and the various remediation options available. Next, the chapter
describes some of the new federal, state, and private sector initiatives that
provide incentives and mechanisms for metal finishers and others to manage
and clean up contaminated properties. Finally, you'll get some guidance on
how to go about hiring the legal and technical specialists you likely will need to
assist you in any contaminated property management activities you undertake.
December 1996
13-1
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Table of Contents Page
13.1 Introduction 13-3
13.2 Liabilities and Requirements 13-4
13.2.1 Federal Laws 13-4
13.2.1.1 RCRA 13-4
13.2.1.2 Superfund 13-6
13.2.2 State Laws 13-8
13.3 Sources of Contamination: How Does a Property Get Polluted? 13-8
13.3.1 Historic Land Use and Disposal Practices 13-9
13.3.2 Accidental Spills 13-9
13.3.3 Releases 13-10
13.3.4 Underground Storage Tanks 13-10
13.4 Investigating Contamination 13-11
13.4.1 Conducting a Site Investigation 13-11
13.4.2 Factors Affecting the Extent of Contamination 13-12
13.4.2.1 Soil and Ground-Water Contamination 13-12
13.4.2.2 Surface Water Contamination 13-13
13.5 Remediation Standards (How Clean Is Clean?) 13-13
13.5.1 Federal Standards and Guidelines 13-14
13.5.2 Cleanup Procedures 13-16
13.5.3 State Cleanup Criteria 13-17
13.6 Remediation Technologies (What Are Common Cleanup Options?) 13-19
13.6.1 Soil Remediation 13-19
13.6.2 Ground Water Remediation 13-20
13.6.2.1 Petroleum Products and VOCs 13-21
13.6.2.2 Metals 13-22
13.7 Facility Process Line Decontamination and Decommissioning 13-23
13.7.1 Waste Management Issues 13-24
13.7.2 Wastewater Management Issues 13-24
13.7.3 Health and Safety Issues 13-25
13.7.3.1 Chemic J Hazards 13-25
13.7.3.2 Physical Hazards 13-26
13.7.4 How Clean Should Decontaminated and Decommissioned Equipment
and Facilities Be? 13-27
13.8 Incentives and Mechanisms for Voluntary Cleanups 13-27
13.8.1 Federal Initiatives and Funding 13-28
13.8.1.1 Progress on Protecting Purchasers From Liability 13-28
13.8.1.2 RCRA Corrective Action 13-28
13.8.1.3 Brownfields Economic Redevelopment Initiative 13-29
13.8.2 State Initiatives 13-29
13.8.3 Private Sector Financing 13-30
13.9 Using Consultants and Attorneys 13-31
13.10 State Requirements 13-33
13.11 Where To Go for More Information About Contaminated Properties 13-34
Appendix 13-A Compliance Schedule for Federal Superfund Requirements
Appendix 13-B OSHA Consultation Project Directory
Appendix 13-C EPA Brownfields Coordinators
December 1996
13-2
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
13.1 Introduction
In the past couple of decades, a number of laws have been enacted
at both the federal and state levels to identify and clean up property
contaminated by hazardous substances. In general, these laws make
owners and operators of a contaminated site liable for the cost of
investigating and remediating the site.
When and to what extent a site must be cleaned up will vary
depending on the specific circumstances of the site and applicable
laws and policy. At a minimum, however, remediation issues usually
must be addressed when business owners or operators seek a
business loan or wish to sell the property or business. Financial
institutions are unlikely to make loans to an individual or company
with outstanding environmental liability. Similarly, buyers usually
will not invest in a property or business with outstanding
environmental liability.
Investigation and remediation can be very expensive—so much so
that some metal finishers (as well as other small business operators)
may reach a point where they face a seemingly unresolvable
dilemma: they cannot afford the cleanup that may be required to
stay in business and they cannot afford the cleanup required to go
out of business. Fortunately, a number of evolving federal, state,
and private sector programs now provide reasonable mechanisms for
metal finishers and others to manage their liabilities and
responsibilities concerning contaminated property.
If you own or run your operation on property that is or may be
contaminated, this chapter will help you understand your potential
liabilities and requirements, the type of action you may need to
take, and how to start getting the help you will need for site
investigation and/or cleanup.
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
13.2 Liabilities and Requirements
13.2.1 Federal Laws
At the federal level, two laws contain provisions covering
contaminated property. The Resource Conservation and Recovery
Act (RCRA) has provisions that cover contaminated property at
currently operating facilities. The Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), better
known as Superfund, covers abandoned or uncontrolled sites.
CERCLA was reauthorized in 1986 by enactment of the Superfund
Amendments and Reauthorization Act (SARA).
13.2.1.1 RCRA
Under the 1984 Hazardous and Solid Waste Amendments (HSWA)
to RCRA, EPA has the authority to require owners and operators of
facilities that are currendy active or planning to close to investigate
and clean up contamination associated with their operations. EPA
can mandate investigations and remedial actions by an
administrative order or impose them as a condition of a RCRA
permit, including post-closure permits at those facilities that have
been designated by EPA as "treatment, storage, or disposal facilities"
(TSDFs). (Some metal finishing operations have been designated
as TSDFs because they operated leaching ponds or treated
hazardous waste.)
These types of activities take place under EPA's RCRA Corrective
Action Program. Often, EPA negotiates with the states about who
will direct the cleanup of properties under the program. The RCRA
Corrective Action Program covers any location on a property
containing wastes (including nonhazardous wastes) that have
migrated or could migrate to contaminate surrounding soil, ground
water, surface water, or sediments. For example, the program covers
areas formally set aside for waste disposal, such as surface
impoundments, as well as any other areas where waste materials
mav simplv have been placed on the property. Both types of areas
are referred to in RCRA terminology as Solid Waste Management
Units, or SWMUs (pronounced "schmoos"). The RCRA Corrective
Action Program particularly impacts metal finishers with former
December 1996
13-4
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
surface impoundments (predominantly in the Northeast). Under
the RCRA Corrective Action Program, EPA has compiled a list of
high-priority sites. These are the known sites that appear to have
the greatest potential for causing significant environmental
contamination. The list is known as the RCRA High Priority
Corrective Action List.
A number of the many metal finishing operations are on this list.
Certain staff at many of the listed operations already know that
their operation is listed.
If your operation is listed, you are not necessarily required to take
any action unless it is specifically requested by EPA or designated
state personnel. However, regulatory agencies are encouraging
voluntary investigation and some degree of remediation or
stabilization. Additionally, it's important for you to know that the
RCRA High Priority Corrective Action List is publicly-available
information. Most prospective buyers or lenders will consult this
list when deciding whether to go forward with a purchase or loan
(much as prospective buyers of residential property conduct a title
search to determine if there is a lien against a property before
completing the purchase). An operation's presence on the list
signals a potential liability. Therefore, you likely will have difficulty
selling your property or obtaining a loan until you can demonstrate
the extent of the contamination and that it is controlled and,
preferably, cleaned up.
In the interest of being removed from the RCRA High Priority
Corrective Action List, you may wish to pursue what is known as a
"voluntary action." The purpose of the voluntary action is to
conduct the necessary remediation or stabilization so that site
contamination no longer presents a risk to public health or the
environment. Voluntary cleanup actions are conducted under EPA
or state-approved plans using risk-based cleanup levels. When the
voluntary action is complete, EPA and the state can be petitioned
to remove the site from the High Priority Corrective Action List. If
the site is no longer conducting TSDF operations, the site maybe
removed from the Corrective Action program completely, and no
further action will be required under this program.
December 1996
13-5
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
13.2.1.2 Superfund
EPA's Superfund program covers abandoned sites, where no
operations are currently taking place and the current owner often
cannot be located or has limited assets. It also covers uncontrolled
sites. These can be working operations where contamination poses
a public health or environmental danger but the owner, operator,
and any others responsible for the contamination lack the resources
to pay for investigation and cleanup.
Under the Superfund program, EPA identifies abandoned or
uncontrolled contaminated sites that may pose a public health or
environmental danger. Once a site is identified, EPA's first course
of action generally is to persuade or compel (via an administrative
order or law suit) those responsible for the contamination to clean
up the site. Under Superfund, those potentially responsible for the
contamination (referred to as "responsible parties") include:
¦ Owners and operators of the site at the time the
contamination occurred.
¦ Any subsequent owners or operators of the site.
¦ Anyone who arranged for the transportation of the materials
to the site.
¦ Anyone who arranged for the treatment or disposal of
materials at the site.
A responsible party may be an individual, a company, or some other
type of organization (e.g., a church or municipality). Liability
applies to any one and/or all of the responsible parties associated
with contamination at a site, regardless of who was at fault. It
applies retroactively, even when the materials were disposed of
many years ago in accordance with the law at that time.
Under Superfund, the definition of contamination is wide ranging.
Properties containing only small amounts of any of a large number
and variety of chemicals are considered "contaminated."
Responsible parties are potentially liable for the costs of cleanup,
monetary damages for harm to natural resources, and the costs to
study whether the contamination may have public health
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part li, Chapter 13
consequences. When responsible parties cannot be located or they
have insufficient funds, EPA may use money from a trust fund,
established under CERCLA, to pay for cleanup activities. EPA often
delegates authority for managing cleanup activities at Superfund
sites to the state.
Key implications of Superfund for metal finishers include:
¦ If you own or operate a site that is contaminated, you are
liable for the costs of investigation and cleanup even if you
did not cause the contamination. You are personally liable
and your company is liable. Under Superfund, this liability
only kicks in if and when the contaminated property is
abandoned. However, most people won't want to invest in a
property or company that has potential liability associated
with it. Therefore, you likely will need to address this
potential liability (i.e., clean up the site) before you can sell
your property or business or obtain a loan.
¦ If you owned or operate a metal finishing operation that
became contaminated before or during your involvement
with the property, you may become liable in the future if the
current owner or operator abandons the property or lacks
sufficient resources to pay fc: remediation.
¦ Anyone who abandon their operations or property hoping to
avoid incurring investigation and remediation costs remain
liable.
To date, EPA has compiled a list of over 33,000 known
contaminated properties throughout the country that are potentially
subject to Superfund actions. This list—known as the
Comprehensive Environmental Response, Compensation, Liability
Information System, or CERCLIS—is available from National
Technical Information Service 1-800-553-6847, or online at
http://wvvw.epa.gov/Superfund. Many of the CERCLIS sites are
metal finishing operations. (EPA only occasionally updates the list.
Therefore, some of the listed CERCLIS sites already have been
cleaned up but have not yet been removed from the list.)
The National Priorities List, or NPL, is a subset of the CERCLIS
list. The NPL identifies the over 1,250 CERCLIS sites that pose the
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most significant threat to human health or the environment as
determined by a ranking model developed by EPA.
As with the RCRA list, responsible parties connected with a
CERCLIS site do not always know their site is on the list. If you are
a responsible party connected with a listed site, you are potentially
liable for the costs of remediation, investigation, and damages, as
described above. You are not required to take any action unless
requested by EPA or the designated state authority. It is important
to be aware of your liabilities, however, and it is generally prudent
to reduce them where possible.
13.2.2 State Laws
All states now have their own mini-Superfund programs. Some
states also have programs that parallel the RCRA Corrective Action
Program. Most states already have identified contaminated
properties and have programs in place to clean up those properties.
A number of the state programs impose more liability and use
broader definitions of hazardous materials than the federal program.
If you think that your operation or property may be potentially
impacted by RCRA- or Superfund-type programs, check with the
contact given in Table 13-1 (at the end of this chapter) to obtain
details about your state's clear up program, including any list of
contaminated properties that your state may have developed.
13.3 Sources of Contamination
How Does a Property Get Polluted?
Contamination of your property (including the soil surface, soil
subsurface, ground water, surface water, and stream sediments) may
have occurred already, may be ongoing today, or may occur in the
future. Sources of contamination include historic land use and
disposal practices, accidental spills, releases, and leaking
underground storage tanks, as described below. This description
may provide useful insight to the types of contamination that may
have occurred or mav occur at your operation and the potential
location of that contamination.
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13.3.1 Historic Land Use and Disposal Practices
Land treatment and disposal of wastes at metal finishing facilities
used to be common and legal. For example, process wastewater and
metal hydroxide sludges historically were placed in surface
impoundments, setding lagoons, ponds, drying beds, landfills, and/or
waste piles. These storage and disposal units are usually classified
as SWMUs under the EPA RCRA Corrective Action Program.
In areas of the country where Clean Water Act requirements were
implemented prior to RCRA, land discharge of wastewater treatment
residues for dewatering and disposal was common. Old surface
impoundments, waste piles, and drying beds were unlined, which
increased their potential impact on the environment.
Other historic sources of contamination at metal finishing
operations include industrial wastewater discharges to septic
systems, dry wells, and the ground surface; spills of chemicals during
container handling; and leakage through plating line trenches, floor
drains, sumps, and floor cracks. Grinding sludges were also
commonly buried as fill at many manufacturing facilities and, over
time, may have released contaminants to the environment, and in
some parts of the country foundry sands were used when leveling
property.
13.3.2 Accidental Spills
Spills occur at metal finishing facilities. Spills can be directiy caused
by people, as when containers or drums are tipped, a forklift
operator punctures a chemical holding tank, or tanks are overfilled
due to inattention. They also can occur due to the mechanical or
physical failure of system components (e.g., valve malfunctions or
computer controller glitches on automated material and waste
handling systems).
While less common, spills can also occur as a result of unexpected
chemical reactions caused by temperature (e.g., sensitive drums
exposed to heat or cold) or by the mixing of incompatible chemicals.
Parking lots, loading docks, chemical storage and handling areas,
above-ground storage tanks, plating areas, and wastewater treatment
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areas are all susceptible to spillage. Spills in these areas may flow
into sumps, floor drains, the ground surface, and stormwater
drainage systems. Each of these receptors can discharge to and
impact subsurface soils, surface water, and ground water.
13.3.3 Releases
Spills are generally sudden, unexpected, and one-time events.
Releases, on the other hand, occur over a longer period of time,
incrementally releasing contaminants. Ongoing releases can occur
from historic spill areas, disposal areas (e.g., waste piles), or other
buried materials as contaminants are dissolved or mobilized by
infiltrating rainwater to be carried into subsoil, ground water, or
surface water. Over time, chemicals can also migrate through
apparent barriers such as concrete floors, trenches, and sumps to
contaminate soils (and potentially ground water) below buildings or
around concrete holding tanks.
Releases can also be the result of historic or ongoing wastewater
discharge to surface water, sanitary sewers, or the ground surface.
Drips from vents over solvent stills or chrome tanks are an often
overlooked source of releases. Similarly, accumulations on roofs
from air exhausts that mobilize with rainwater can result in releases
of contaminants to the environment.
The significance of any release, or spill, depends on the type of
contaminant(s), quantity released over time, release area
characteristics, and migration pathways.
13.3.4 Underground Storage Tanks
Underground storage tanks, or USTs, are typically constructed of
steel or fiberglass, and usually contain gasoline or heating oils,
although underground solvent storage used to be a common
practice. Recently installed USTs generally must contain leak
detection systems and are of double-wall construction. (Chapter 6
provides detail on the regulations concerning USTs.) Older USTs
are generallv of single-wall construction, frequently riveted with
seams, and do not contain leak detection systems. The older the
UST, the greater the likelihood that leakage has occurred.
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Although riot officially USTs (see Chapter 6 for definitions),
concrete underground tanks, which are not used for petroleum
product storage, are used by industry. Concrete USTs are often
used for wastewater treatment, and frequently used for temporary
storage prior to offsite effluent disposal or as emergency storage for
treated effluent.
Leaks from any type of underground vessel (concrete, steel, or
fiberglass), can occur at piping joints, the feed line/tank interface, or
tank seams and/or holes created during installation or as the tank
and piping system deteriorate due to corrosion from tank contents
or the surrounding environment.
13.4 Investigating Contamination
13.4.1 Conducting a Site Investigation
The type and extent of remedial action that may be needed at a
contaminated property depends on the type and extent of the
contamination. Cleanup may be relatively inexpensive when only
a small area is affected. On the other hand, cleanup costs can be
significant if the contaminants have migrated from the original
release area to contaminate (or potentially contaminate) important
resources, such as ground water and surface water. When a property
may be contaminated, the first major step is to investigate the
contamination. This investigation seeks to determine:
¦ Is there contamination?
¦ What caused the contamination?
¦ How far has the contamination spread? What environmental
media (soil, sediments, ground water, and surface water) have
become contaminated?
¦ What pollutants are present in contaminated areas and in
what concentrations?
¦ What are the reportable levels of contamination?
¦ Has a reportable release occurred?
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Such investigations usually requires fairly sophisticated approaches
and technology. Many consulting firms specialize in this type of site
investigation. If you suspect contamination at your operation, you
likely will need to obtain expert assistance to investigate it. Some
of the characteristics of contamination that are factored into this
type of analysis are described below.
13.4.2 Factors Affecting the Extent of Contamination
The extent of contamination caused by the release of a hazardous
material varies depending on the characteristics of the contaminant
and the physical nature of the area where the release occurs. For
example, a release of chromium is unlikely to migrate quickly from
its release site, whereas a similar volume of solvent released in the
same hydrogeological setting could contaminate an extensive area of
soil and ground water. Similarly, the impact from a release of metals
to an area of fine-grained soils (e.g., clay) would likely be relatively
small compared to a similar release in an area with coarsed-grained
sand where ground water moves much more rapidly.
The science of determining and predicting the extent and degree of
the contamination caused by a specific release, or accumulated
historic releases, is a rapidly growing field. Typically,
hydrogeologists use a knowledge of the contaminant's mobility,
density, surface tension, vapor pressure, and solubility and the land
area's soil and ground-water characteristics to project the degree and
extent of a release's impact on the surface and subsurface
environment.
13.4.2.1 Soil and Ground-Water Contamination
Depending on the porosity and hydraulic conductivity of the soil,
the depth to ground water, and the hydraulic gradients of that
ground water, a release in a given area may spread as quickly as
several feet per day or as slowly as a few feet per year. It may
remain near the top of the ground water or may descend deeper into
the aquifer.
For anv chemical release, a certain amount of the chemical may
dissipate; another portion may be adsorbed in the soil; another
portion mav seep through the soil to float on top of the ground
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water, or sink to the bottom of the aquifer as a separate phase; or it
may become dissolved in the ground water.
13.4.2.2 Surface Water Contamination
Surface water can be contaminated in several ways from both
nonpoint sources, such as urban and agricultural runoff, septic
systems, and contaminated ground-water discharges, and from point
sources, such as sewage treatment facilities, and wastewater and
stormwater pipe discharges. Once released into a specific body of
water, pollutants will follow that water's path from creek to lake,
river, or sea. Depending on the volume and speed of the water flow,
contaminants will be diluted, may settle to the bottom sediment,
and may be ingested or absorbed by aquatic life.
Except for limited removal of contaminated sediments, it is generally
impractical to cleanup surface water directly. A combination of
water flow and the load of pollutants already in, or being added, will
determine how quickly and effectively a specific body of water can
clean itself.
Since the most effective way to reduce the level of pollution in
surface waters is to reduce the amount of pollutants they receive,
federal and state efforts have concentrated on cleaning up
contaminant sources and preventing contamination from occurring.
Remediation of soil and ground-water contamination has improved,
and will continue to improve, the quality of receiving surface waters.
13.5 Remediation Standards
How Clean Is Clean?
Some cleanups are required under RCRA, CERCLA, or state laws.
Others are performed voluntarily to reduce environmental liability.
In both cases, however, the parties involved in the cleanup must
decide: How extensive should the cleanup be? To reduce liability,
voluntary cleanups will generally need to meet the same standards
as required cleanups. As described below, there is no fixed standard
that every' cleanup must meet, but a number of criteria have
evolved. These provide useful markers for parties involved in a
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cleanup when rhey are deciding "How clean is clean?" at a specific
site.
In the past, the appropriate cleanup level for most remedial actions
usually was decided on a case-bv-case basis. In making this
determination, the federal or state agency involved typically
considered some or all of the following factors:
¦ Site-specific considerations
¦ Cost
¦ Technical feasibility and efficiency
¦ Relevant standards and cleanup criteria
Increasingly, federal and state agencies have been developing
regulations that define remediation procedures, goals, and
measurable standards. Some of the factors influencing cleanup
standards are summarized in Box 13-1.
13.5.1. Federal Standards and Guidelines
The cleanup criteria for sites listed on the NPL are based on
Applicable or Relevant and Appropriate Requirements (ARARs).
ARARs are the relevant federal environmental laws, and any more
stringent state laws, that address conditions at the site. Box 13-2
summarizes some of the important federal standards that may
address conditions at a site. ARARs may be modified based on local
public or state input and site-specific considerations, provided
protection of public health and the environment is still ensured.
At NPL sites, the various cleanup possibilities are evaluated based
on their cost, technical feasibility, and effectiveness in achieving the
ARARs. A final remediation plan is then agreed to based on the
following factors:
¦ Ability to provide overall protection of human health and the
environment.
¦ Long- and short-term effectiveness.
¦ Permanence of the solution.
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¦ Ability to reduce the toxicity, mobility, or volume of
contaminants.
¦ Implementability.
¦ State agency acceptance.
¦ Community acceptance.
The NPL procedures and criteria generally also form the basis for
procedures and results required under the RCRA Corrective Action
Program and other cleanup programs.
Box 13-1 Types of Cleanup Criteria That May Be Included in Federal and
State Cleanup Standards
¦ Cleanup to Precontamination (i.e., Background) Levels. This criteria requires
removing or treating the contaminant until the area contaminated by the
release has the same characteristics as an area unaffected by a release. The
definition of background levels is usually subject to much debate and is
typically agreed to on a case-bv-case basis.
¦ Technology-Based Levels. This criteria requires cleanup to the extent that it is
technologically possible using proven remediation technologies. EPA tracks
and reviews remediation and treatment technologies to establish or revise
specific performance standards.
¦ Precedent Levels. This criteria requires cleanup to levels achievable by or
specified in remedial action plans for other, similar sites.
¦ Levels Specified by Existing Standards and Guidelines. This approach sets
cleanup levels based on standards that have been established specifically for
cleanups or for other purposes, such as Safe Drinking Water Standards,
CERCLA Soil. Screening Levels, or RCRA Corrective Action Rules.
¦ Levels Based on Health-Based Criteria. This approach requires cleanup to
levels that protect human health and the environment. Sufficient cleanup is
conducted to ensure that exposure to any remaining contaminants is at levels
deemed "safe" or "acceptable" by regulatory agencies.
¦ Limits of Analytical Detection or Lower. This criteria requires cleanup to a
concentration that is at or below the concentration that can be detected with
current analvtical technology.
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Box 13-2 Key Federal Standards Relevant to Contaminated Sites
¦ MCLs. Under the Safe Drinking Water Act, EPA has established maximum
contaminant levels (MCLs) for public drinking water that, if exceeded, may
adversely affect public health. MCLs are based on the scientific/technological
ability to detect, measure, and cost-effectively remove or treat a specific
existing, or potential, public water supply contaminant.
¦ Superfund Soil Screening Levels (SSLs). In 1993, EPA proposed specific soil
concentrations for 30 contaminants. These concentrations are used as a
screening tool to determine which sites will likely require further remedial
investigation. Contamination levels below those listed in the SSLs usually do
not require cleanup. However, some states have established more stringent
screening and/or cleanup levels. In April 1996, EPA expanded the original list
of 30 contaminants to 110 contaminants. The current SSLs are available
through the National Technical Information Service (NTIS) (Document
Numbers: PB96-963505, PB96-963502)
¦ RCRA Corrective Action Levels. As proposed in 1990, this rule establishes
processes to develop site-specific levels for contaminants in soil and ground
water. Remedial action is required when contamination exceeds these levels.
MCLs serve as the action levels for substances with MCLs. For other
hazardous substances, the action level is based on increased cancer risks (with
one standard for known and probable carcinogens and a second standard for
possible carcinogens). The resulting standards are generally as stringent as the
site-specific levels often agreed to for a Super and cleanup.
¦ PCB Spill Cleanup Requirements. Under the Toxic Substances Control Act
(TSCA), which banned the manufacture of PCBs (polychlorinated biphenyls),
any release of PCBs in concentrations greater than 50 ppm (parts per million)
warrants corrective action. The 1987 rule categorizes releases by weight and
type of release area.
¦ Clean Water Act. The Clean Water Act requires EPA to set permissible levels
of pollutant in waters used for public water supply, recreation, fish and wildlife
protection, and/or agricultural and industrial use. EPA established
pretreatment standards and effluent guidelines for 65 toxic constituents. All
but a few of the standards are based on best available technology.
15.5.2 Cleanup Procedures
As specified in the National Contingency Plan (NCP), cleanup of an
NPL site is conducted in four stages (see Box 13-3). Although most
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metal finishing operations are not NPL sites, cleanups will generally
proceed through similar phases:
¦ Preliminary assessment and investigation.
¦ An investigation and feasibility study, including setting
remediation goals.
¦ Design and implementation of a remedial action plan.
¦ Ongoing site operations and maintenance, including
continued monitoring.
Investigation and remediation of a site is a costly and time-
consuming process. The general approach and stages of a site
investigation/remediation project under a Superfund program are
described in Box 13-3. The approach and stages of a RCRA
remediation are very similar, but the level of oversight, complexity,
and cost often is significantly less. Likewise, procedures typically
used for state-initiated and voluntary cleanups follow equivalent
steps, and are also less complex and expensive.
13.5.3 State Cleanup Criteria
Cleanup at most contaminated sites is overseen by the states rather
than EPA. The federal guidelines and criteria, in effect, provide
minimum standards a state must follow to warrant EPA's approval
of its cleanup program. As with federal cleanups, most state-
approved actions so far have involved site-specific criteria.
However, several states have recently established their own
comprehensive cleanup standards and procedures in an effort to
ensure cleanups that are both cost effective and protective. In many
cases, these states have adopted specific concentration limits for soil
and ground-water contaminants, while allowing alternative levels to
be developed based on the site setting, a site-specific risk
assessment, technological feasibility, implementability, and cost.
Many states have also allowed remediation to a less stringent
standard when it is tied to the property's use. Highlights of state
cleanup criteria can be found in Table 13-1.
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Box 13-3 Four Stages of Cleanup at NPL Sites
Stage 1: Preliminary Assessment and Site Investigation
¦ Preliminary Assessments (PAs) are typically conducted by EPA, a state regulatory agency, or
private consultants. The scope of a PA can range from a simple review of existing
information in agency files and other readily available information regarding the property to
a comprehensive detailed inspection of the property.
¦ Depending on the results of the PA, a more detailed Site Investigation (SI) may be
warranted. This may include sampling and analysis of property soil and groundwater.
¦ Results of the PA and/or SI result will then be used to evaluate the real and potential risk to
human health and the environment posed by contamination on the property.
Stage 2: Remedial Investigation and Feasibility Study (RI/FS)
¦ The first major investigation for a site is the Remedial Investigation (RI). This is a very
detailed investigation of the site and, often, offsite media to determine real and potential
impacts to human health and the environment. The Ri incorporates or is followed by a
human and ecological risk assessment to identify the need for cleanup and the appropriate
standards the cleanup should be designed to achieve.
¦ Once the need for cleanup is established, a Feasibility Study (FS) is performed to identify
feasible remediation options. Starting with the universe of potential cleanup solutions, the
FS evaluates technical performance, reliability, and implementability of potential cleanup
options; financial considerations; and institutional requirements, such as compliance with
other laws.
¦ The final outcome c the Rl/FS is a set of recommendations for stabilizing or cleaning up the
property or property area. Typically, Rl/FS costs are well over SI million. The Rl/FS can be
performed by PRPs (Potentially Responsible Parties), by state regulatory agencies, or by EPA.
PRPs on a Superfund site range from a single company to hundreds of parties.
Stage 3: Design and Implementation of a Remedial Action Plan
¦ Recommended cleanup actions from the RI/FS are memorialized by EPA through a Record of
Decision (ROD). Once the ROD is established, actual remedial design and construction
occur. Remedial solutions can be a single technology or a combination of technologies to
address the real and potential risks by a contaminated property.
Stage 4: Ongoing Site Operations and Maintenance
¦ Onlv in rare instances are cleanups complete in a short time frame. Typical cleanups occur
over a period of years, or decades. With current technologies, some sites cannot be
completely cleaned up, or are so costly to cleanup that cleanup is not justified economically.
Until a permanent remedv is achieved, remedial svstems require maintenance, monitoring,
and repair. Site conditions are also periodically monitored to evaluate the progress of the
cleanup
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13.6 Remediation Technologies
What Are Common Cleanup Options?
Many options are available for cleaning up contaminated properties.
Which remediation technology is used at a particular site depends
on several factors, including:
¦ The type of contaminant.
¦ Whether the contaminant is in the vapor, adsorbed, separate,
or dissolved phase.
¦ The costs/benefits, efficiency, and effectiveness of the
technology remediation technologies are traditionally divided
into two categories: those used to remediate soil and those
used for contaminated ground water. Soil and ground-water
remediation technologies are described below. A good
understanding of the contaminant's nature, extent, and
environmental setting is critical to making a wise decision
about which remedial technique to use. Thorough up-front
investigation, planning, and design can reduce total costs,
remedial time frames, and unanticipated surprises during the
remediation process.
13.6.1 Soil Remediation
Soil cleanup techniques can be divided into two categories:
¦ Ex Situ (Out of Ground) Techniques. Generally ex situ
techniques require excavation followed by either direct
disposal or treatment. Treated soils may be reused as fill or
construction material, or they may require disposal, but at a
lower cost than untreated soil.
¦ In Situ (In Place) Technologies. These technologies either
reduce the volume and/or toxicity of contaminants or
stabilize the contamination in place.
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Many treatment options are available. The most appropriate choice
depends on the volume, concentrations, and types of contaminants,
as well as geologic and hydrologic environmental constraints. For
example, potential ex situ and in situ options for soils contaminated
with petroleum or volatile organic compounds (VOCs) (i.e.,
solvents) include:
¦ Ex sitii excavation, followed by any of these procedures.
— Disposal permitted facility
— Onsite or offsite asphalt batching
— Biological treatment in containers
— Low- or high-temperature soil roasting
— Incineration
¦ In situ remediation followed by any of these methods.
— Capping with a low-permeabilitv covering.
— Soil vapor extraction (vapors could then be directly
discharged, incinerated, catalytically oxidized, or treated
via carbon adsorption).
— Biological enhancement.
— Bioventing.
These techniques generally are inappropriate for soils contaminated
solely with heavy metals. Techniques that may be appropriate for
this type of soil include encapsulation, solidification (in situ or ex
situ), soil washing, or possibly utilizing the bioaccumulation
properties of certain plants.
13.6.2 Ground Water Remediation
Ground water contamination can also be remediated ex situ or in
situ. With ex situ treatment, the extracted ground water must be
appropriately managed. It may be either directly discharged to a
sanitary sewer, if that is allowed, or treated. The treated water may
then be discharged back to the subsurface, to surface waters, or to
sanitary sewers, depending on regulatory constraints.
In situ treatment, when feasible, generally is less expensive and
requires less time than ex situ treatment. However, many
contaminants cannot feasiblv be treated in situ due to the nature of
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the contaminant, geologic or hvdrogeologic factors, or land use. In
these situations, ex situ treatment must be used, even though it is
often costly and requires significant time.
13.6.2.1 Petroleum Products and VOCs
Petroleum products and certain VOCs (e.g., toluene) are lighter than
water. If sufficient quantities are present, they can form a separate
laver that "floats" on the ground water. Other VOCs (e.g.,
perchloroethviene) are heavier than water and can "sink" through
the ground water until they encounter a confining layer, such as
bedrock. Then they can move laterally. These products can also
dissolve in ground water.
A floating layer, referred to as a light non-aqueous phase liquid
(LNAPL), almost always requires removal. Available removal
techniques include passive removal, using hydrophilic wicks or
membranes, and active removal, via pumping.
A layer of contaminant that setdes in ground water is called a dense
non-aqueous phase liquid (DNAPL). DNAPLs are extremely
difficult to remove with existing technology. They are often
controlled by treating the dissolved ground-water contamination,
which is usually also present. A number of technologies exist for
treating petroleum or VOCs dissolved in ground water. Depending
on the type of petroleum product or VOC, cleanup of the ground
water may include either:
¦ Ex situ removal via pumping or other collection techniques,
followed by any of the following:
— Direct sewer discharge (and treatment at the local sewage
treatment plant).
— Air stripping.
— Carbon adsorption.
— Spray aeration.
— Dechlorination.
¦ In situ treatment utilizing any of the following:
— Air sparging (where air is injected at multiple points in
the contaminant plume) coupled with vapor extraction (to
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recover die resulting contaminated air above the water
table).
— Oxidation (injecting hydrogen peroxide instead of air).
— Bioventing (which is similar to air sparging except air is
injected at a slower rate to facilitate biological activity).
— Biological degradation (through addition of nutrients
and/or chemical-specific microbes).
In situ treatment, if feasible based on hydrogeologic factors, is often
more cost effective for dissolved petroleum and VOCs than ex situ
treatment. The effectiveness of remedial techniques varies by
contaminant type.
13.6.2.2 Metals
Metals and other inorganic contaminants are often more difficult to
treat ex situ (and always more difficult to treat in situ) than organic
compounds:
¦ Ex situ treatment requires removal via pumping or another
collection technique followed by any of the following:
— Chemical precipitation (including pH adjustment).
— Reverse osmosis.
— Microfiltration.
— Chemical reduction.
— Other treatment techniques often used in metal working
facilities to treat wastewater streams.
— Stabilization.
— Soil washing.
¦ Currently available in situ technologies are effective only on
a limited number of metals. Accepted techniques are limited
to:
— Oxidation, which can effectively precipitate certain metals
(e.g., iron and manganese) into the surrounding soils, but
is generally ineffective for most other metals.
— In situ chemical treatment, which can immobilize a
greater range of metals. Thus, treatment can be conducted
onlv when the horizontal and vertical extent of
contamination and the hydrogeologic environment are
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very well defined, so that chemical treatment can be
effective without causing other unanticipated water
quality concerns.
13.7 Facility Process Line Decontamination and Decommis-
sioning
Decontamination of metal finishing equipment is necessary during
both routine and nonroutine maintenance and renovation activities.
It includes such activities as:
¦ Pumping free liquids from holding and conveyance systems
¦ Removing accumulated sludges by physical means
¦ Washing or scraping residues from surfaces
Decommissioning takes place when metal finishing equipment is taken
out of service, when a department is closed, or when a facility is
closed. Decommissioning involves removing manufacturing
equipment from service and, subsequently, decontaminating all
equipment and surrounding building surfaces. See Section 13.7.4.
Spills and waste generated during decontamination and
decommissioning (D&JD) of equipment or a building can be a source
of contamination at metal finishing operations. Also, D&JD
operations can potentially expose employees to dangerous levels of
toxic chemicals. Following appropriate procedures for D&JD is
important to:
¦ Ensure compliance with applicable federal and state
regulations and guidelines concerning waste management and
D&JD activities.
¦ Ensure compliance with applicable federal and state
regulations concerning employee health and safety.
¦ Ensure that the facility or equipment is sufficiently clean for
reuse, sale, or disposal.
¦ Prevent unnecessary contamination.
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D&JD may be conducted by contractors specializing in D&JD or by
internal staff. Many metal finishers use contractors because of the
importance of following proper procedures. If you use a contractor,
be sure that the facility personnel and contractors work closely
together to correctly identify chemical hazards and maintain safe
conditions at all times. This section describes some considerations
and procedures concerning waste management, wastewater
management, and health and safety that should be followed for any
D&JD activities your firm may undertake internally.
13.7.1 Waste Management Issues
All liquid, sludge, and solid chemical residues removed from
production equipment are immediately subject to the requirements
for the handling and proper disposal of hazardous waste (see
Chapter 5). The process of decontaminating and/or
decommissioning metal finishing and related equipment can make
complying with hazardous waste regulatory requirements
challenging. Procedures for safe handling of waste materials during
D&JD activities include:
¦ Keep waste storage containers closed when they are not being
actively filled or emptied.
¦ Segregate waste types to ensure chemical compatibility.
Mixing of the wrong types of hazardous wastes can have
disastrous results.
¦ Properly mark and identify waste types to ensure proper
storage and disposal.
¦ Store waste containers in locations designed to contain
possible spills and control fire hazards.
13.7.2 Wastewater Management Issues
Wastewater from plating line decommissioning may contain a
different mixture or a more concentrated mixture of contaminants
than the wastewater for which the treatment system was originally
designed. Introduction of these wastewaters may, in some cases,
upset the treatment svstem. And, a wastewater discharge permit
may specifv that it covers onlv the treatment of dilute rinsewaters.
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Thus, even when a treatment system can successfully treat more
concentrated waste solutions, regulatory agencies may construe such
activity as a permit violation and levy a fine.
Metal finishers should consult their permit application, discharge
permit authorization, and wastewater system design specifications
to determine whether the treatment system may be used to treat
D&D wastewater. When in doubt, a qualified wastewater treatment
engineer or the local control authority should be consulted.
13.7.3 Health and Safety Issues
Both decontamination and decommissioning generate health as well
as safety concerns beyond those associated with routine metal
finishing operations. Therefore, special procedures described below
are needed to ensure employee health and safety and appropriate
waste disposal during D&D activities.
13.7.3.1 Chemical Hazards
The potential for exposure to hazardous chemicals may be greater
during D&D than during routine operations:
¦ Airborne concentrations of hazardous chemicals mav be
higher and ventilation systems may be turned off. Thus, air
samples taken during normal production activities will not
necessarily indicate potential inhalation exposures during
D&D.
¦ In addition, during D&D workers often are handling
concentrated chemical residues that are different than the
ones they are used to working with. This increases the
chance that skin, eyes, and lungs may be exposed to
potentially hazardous chemical concentrations.
¦ Chemicals used to D&D are designed to react with the
residue and "neutralize" it. The process of reacting poses a
threat.
Owners and operators of metal finishing operations should take a
number of steps to ensure employee health and safety. These
include:
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
¦ Determine the applicability of health and safety training
regulations, particularly those pertaining to hazard
communication, personal protective equipment, confined
space entrv, and lockout-tagout. (For more information on
the pertinent health and safety regulations, contact the
Occupational Safety and Health Administration
[OSHA]—see Appendix 13-B for an OSHA contact
directory.)
¦ Conduct a hazard assessment before starting
decontamination or decommissioning to determine what level
of personal protective equipment (PPE) is needed to
adequately protect workers. OSHA's Permissible Exposure
Limits (PELs) specify the concentrations of various chemical
or physical agents that employees can be safely exposed to.
PPE suitable for regular production activities may need
modification when hazardous chemicals are being handled.
Respiratory protection may also be required, and its use is
subject to Occupational Safety and Health Administration
standards. (For more information on these standards,
contact OSHA—see Appendix 13-B.)
¦ Design and implement an effective health and safety plan to
protect maintenance workers.
¦ Provide adequate training for employees in the hazards of the
chemicals they are handling and the capabilities, limitations,
and proper use of PPE.
13.7.3.2 Physical Hazards
Phvsical hazards often are greater during D&D than during routine
operations. Steps to promote safe conditions include:
¦ Maintain good housekeeping to minimize the potential for
slips, trips, and falls.
¦ Follow lockout and tagout procedures to ensure that all
electrical systems are deenergized and all chemical product
lines are closed or blanked to prevent fluids or gases from
entering the work space.
¦ Close and secure all tank valves.
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
¦ Assess fire prevention and protection needs before D&D
(since these activities may provide ignition sources in
flammable atmospheres).
¦ As necessary, install and/or repair eyewash and emergency
shower stations before commencing D&D activities.
¦ Follow confined-space entry rules when activities require
cleaning of tank, sump, pipe interiors, etc.
13.7.4 How Clean Should Decontaminated and Decom-
missioned Equipment/Facilities Be?
The answer to this question depends on the planned future use of
the equipment or building and the types of contaminants that might
remain. At a minimum, best management practices require that no
free liquids, sludges, or solid residues are associated with
decontaminated plating equipment or building materials. Some
states have adopted clean standards based on human health risks
and are applying these standards to facility decommissioning. These
standards consider exposure scenarios (ingestion and inhalation) and
the toxicity of specific elements and chemicals. Typically, some
form of a wipe test is used to determine residual levels of
contamination.
Scrap metals that are free of solid and liquid waste residues can
generally be recycled at a commercial metal recycling facility.
However, certain state and local requirements may apply to this
activity. Equipment that is being sold or transferred for reuse must
be below applicable D&JD standards to allow transport over public
roads. Storage of old equipment outside a manufacturing building
may contaminate stormwater runoff.
13.8 Incentives and Mechanisms for Voluntary Cleanups
In recent years, EPA and some states have been experimenting with
a varietv of incentives and mechanisms (including financial
assistance, regulatory flexibility, and liability protection) to
encourage current owners, potential developers, and host
municipalities to clean up contaminated sites. In addition, a
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
number of private sector mechanisms are emerging that can provide
sources of capital for activities concerning contaminated properties.
Most of these initiatives target abandoned or underutilized
industrial or commercial properties, commonly referred to as
"brownfields." A brownfield is a site, or portion thereof, that has
actual or perceived contamination and potential for redevelopment
or reuse. This section describes the types of initiatives for voluntary
cleanup that have been emerging in the federal, state, and private
sectors.
13.8.1 Federal Initiatives and Funding
13.8.1.1 Progress on Protecting Purchasers From Liability
A key issue impeding the purchase and/or voluntary cleanup of
brownfields is the potential liability of the purchasers and lenders,
as well as the responsible parties who clean up the property in
accordance with standards. This issue is likely to be addressed in
any Superfund reauthorization.
In May 1995, EPA published a revision to its Guidance on Agreements
With Prospective Purchasers of Contaminated Properly and Model
Prospective Purchaser Agreement (in Volume 60, Number 127, of the
July 3, 1995, Federal Register, beginning on page 34792). The
revised document significandy expands the situations in which EPA
might be willing to enter into an agreement that protects a
prospective innocent purchaser. EPA will now consider such
protection in two cases:
¦ When there is a substantial direct benefit to EPA in terms of
cleanup or funds for cleanup.
¦ When there is a substantial indirect benefit to the
community along with a less direct benefit to EPA.
13.8.1.2 RCRA Corrective Action
EPA mav require corrective action at any facility for which a RCRA
Part A or Part B permit application (see Appendix 5-1) has been
filed. However, there are more than 5,000 such facilities and EPA
currently takes 3 person-vears to process the corrective action
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
permit that precedes corrective action. Therefore, EPA has shifted
its focus to encouraging "stabilization" actions. Stabilization is an
interim cleanup activity, or series of activities, that provides partial
cleanup and lowers environmental- and health-based risks. EPA is
providing incentives for those who voluntarily undertake
stabilization as a part of corrective action. These incentives include:
¦ A more limited scope of investigation.
¦ No requirement for a regulatory review or approval of a
detailed work plan or report.
¦ A flexible schedule for implementation.
EPA has also announced that, by the year 2000 it will pursue
enforcement action against any facility on the RCRA High Priority
Corrective Action List that does not undertake "voluntary"
stabilization. More recently, EPA has approved remediation
measures" beyond stabilization and is beginning to approve voluntary
implementation of the entire corrective action program.
13.8.1.3 Brownfields Economic Redevelopment Initiative
EPA's Brownfields Economic Redevelopment Initiative is designed
to empower states, communities, and other stakeholders in
economic redevelopment to work together to assess, safely clean up,
and sustainably reuse brownfields. EPA plans to fund at least 50
Brownfields Pilot Projects in 1995 and 1996, at up to $200,000
each, to support creative 2-year explorations and demonstrations of
brownfield solutions. By the end of September 1995, EPA had
awarded 29 of the 50 pilots.
13.8.2 State Initiatives
Many states have recently enacted programs that offer companies
technical, financial, or legal incentives to expedite mandated
cleanups and undertake voluntary investigation and cleanup at
contaminated sites. Most of these programs are targeted at
brownfields, but several apply to sites not on a Superfund list or
subject to a regulatory' agency order. Table 13-1 summarizes the
programs in selected states.
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
These voluntary programs are unique to each state. The advantages
of a voluntary program may include:
¦ Limited or no oversight by the regulatory agency.
¦ An ability to withdraw from the process without penalty.
¦ Flexibility in implementation schedules.
¦ Availability of grants or low interest loans.
¦ Tax advantages.
¦ Protection, via Covenants-Not-To-Sue, from future liability
for past contamination that is either undiscovered or newly
regulated.
A few states offer limited liability protection to responsible parties.
Most states only offer such protection to lenders, municipalities, or
nonresponsible parties. The availability and provisions of
Covenants-Not-To-Sue and mechanisms for cleanup approval vary
widely and necessitate expert legal counsel (see Section 13.9).
Several states, including Connecticut, Massachusetts, and Ohio,
have delegated some level of oversight authority to privately licensed
or registered professionals; others have set times frames within
which cleanups must be reviev sd or deemed approved.
13.8.3 Private Sector Financing
Most business transactions involving real property occur without
government intervention. When an owner of a small electroplating
job shop or mid-sized manufacturing firm needs capital to finance
business expansion or environmental cleanup, the preferred choice
of financier generally is the local bank. However, the environmental
liabilities associated with potentially contaminated properties make
conventional lending difficult at best. And, when an owner wants
to sell a contaminated property, prospective purchasers are limited.
In recent vears, private sector banks, underwriters, developers, and
advisors have begun to see new market opportunities in investing in
contaminated properties. A varietv of unconventional sources of
capital have evolved. A few examples are described in Box 13-4.
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Box 13-4 Examples of Emerging Private Sector Finance Mechanisms for
Contaminated Properties
¦ LandBank. LandBank acquires title and security interests in contaminated
properties that have been underutilized due to the economic, regulatory, and
liability concerns of prospective purchasers, lessees, developers, and lenders.
LandBank tvpicallv partners with real estate developers, insurance underwriters,
and environmental engineers. Contact: Christopher Carpentier, New York, NY,
212-207-4141.
¦ Remediation Financial, Inc. Remediation Financial Inc. (RFI) specializes in the
acquisition, financing, and risk allocation of environmentally contaminated real
estate. As part of this process, RFI creates indemnification and liability
transaction packages that protect clients from the risks associated with the
disposition or the acquisition of properties. This process removes contingent
liabilitv from the corporate balance sheet and caps the remedial and regulatory
costs of contaminated property. Contact: Timothy E. Lewis, Phoenix, AZ, 602-
241-1960.
¦ Environ Realty Advisors, LLC. Environ Realty Advisors, LLC is an
advisory/brokerage firm that specializes in the acquisition and sale of commercial
and industrial properties, located in the Northeast, that have been impacted by
hazardous materials. Contact: Andrew D. Fineberg, Trumbull, CT 203-268-3224.
¦ North American Realty Advisory Services. North American Realty Advisory
Services is a full-service management consulting firm t.iat specializes in the
redevelopment and marketing of "difficult" sites, including environmentally
contaminated sites, throughout the United States and Canada. Contact: David J.
Daddario, New York, NY, 212-883-0500.
13.9 Using Consultants and Attorneys
The expertise of lawyers and consultants is essential to metal
finishers in those situations involving contaminated properties, the
liabilities associated with contaminated property, and the many
potential cleanup options. If you want to reduce the liabilities
associated with subsurface contamination and increase your
property's (and business's) value, then a competent team of outside
resources is essential.
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Tips for finding a qualified consultant or attorney who can provide
valuable expertise for your situation include:
¦ Become an informed service purchaser by acquiring a basic
understanding of the characteristics of subsurface
contamination and the many relevant laws and regulatory
programs.
¦ Seek the advice of the attorney who handles your corporate
affairs. This person probably can offer an important
perspective because he or she knows much about your
company. (Don't rely solely on your attorney's expertise,
however, since he or she may know little about
environmental law.)
¦ Seek recommendations about which specialists to use (or
avoid!) from fellow metal finishers who have contracted with
specialists to investigate and remediate contamination.
¦ Contact the state resources listed in the right-hand column of
Table 13-1 (you may wish to do this anonymously). These
individuals work with consultants and attorneys daily. Some
states may not be able to make specific recommendations,
but they at least may be able to provide lists of approved
consultants and attornevs or Licensed Site Professionals in
your state.
¦ Contact your state metal finishing trade association.
Consulting and law firms are often "associate"
members/sponsors of the organization and are quite familiar
with the industry.
¦ Avoid using the Yellow Pages as a sole source to find an
attorney or environmental consultant.
¦ Interview prospective attorneys and consultants at their
offices. Meet the people with whom you will work closely;
discuss their experience; assess their technical, regulatory, and
evolving public policy knowledge; and evaluate their
relationships with regulatory agencies.
¦ Request proposals from a select number of candidates.
Proposals should include a section that details the scope of
work ("this is how we are going to help you"). Evaluate the
December 1996
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
approach being suggested. Don't let price tag overly
influence your opinion of a particular candidate.
¦ In addition to the technical qualifications of the candidate
individuals and firms, consider how much you feel you can
trust them as well as their willingness to work as a team. By
contracting with an attorney and/or consultant, you are
assembling a team (which may also include members of your
own staff) to diagnose and solve a problem. You delegate
responsibility to team members to do the work, and you
maintain the final control and authority over decisions and
actions.
¦ Negotiate contracts that include a scope-of-work section, a
description of terms and conditions, a schedule, and a list of
costs. Continually revise your agreement as you learn more.
¦ Clearly define who on your team is going to do what, and
how your team members will communicate with each other
and with regulatory agencies.
¦ If you are not the property owner, keep the owner(s)
participating in all significant decision making.
¦ Attend all meetings with regulatory agencies.
¦ Maintain control at all times.
13.10 State Requirements
Table 13-1 summarizes the cleanup programs and criteria of 25
states and lists a contact person for further information. All these
programs are relatively new and rapidly evolving. Be sure to obtain
the most current information for your state if you are contemplating
action under one of these programs.
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
13.11 Where To Go for More Information About Contaminated
Properties
In addition to the state contacts listed in Table 13-1, further
information on contaminated properties can be obtained from:
¦ EPA RCRA contacts (Appendix 5-J).
¦ EPA Brownfields coordinators (Appendix 13-C).
Also, the OSHA contacts listed in Appendix 13-B can provide
further information on OSHA regulations relevant to
decontamination and decommissioning.
December 1996
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Table 13-1 Summary of Contaminated Property Information for Selected States
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Cleanup
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Contacl(s)
AZ
June 1995 - DEQ proposes to establish
uniform standards and procedures for
soil remediation; interim emergency
rule uses background standards and
health-based soil and ground-water
criteria as guidance.
Michelle Robertson (Standards)
(602) 207-4415
Ethel DeMarr (DEQ; Interim Policy
Guidance)
(602) 207-2381
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CA
The Voluntary Cleanup Program, begun in 1993, excludes all
state and federal Superfund sites, any petroleum contaminated
site, and those sites which are under the jurisdiction of the
Regional Water Quality Control Board unless the agency with
jurisdiction transfers responsibility for cleanup to the State
Department of Toxic Substances Control (DTSC). Part ies
initiating a voluntary cleanup negotiate a site-specific
agreement which includes payment for DTSC oversight. Under
tlie 1994 Expedited Remedial Action Reform Act, the DTSC
has implemented a pilot program embracing up to 30
brownfield sites which must meet the same criteria as those
eligible for inclusion in the Voluntary Cleanup Program. Sites
accepted into the expedited pilot program are potentially
eligible for funding assistance and parties may receive future
liability protection.
Expedited Remedial Action Program
(DTSC)
Megan Cambridge, (916) 255-3727
Voluntary Cleanup Program,
Regional Contacts:
Southern CA: Don Johnson,
Clendale
(815)551-2862
Central CA: Eric Garcia,
Sacramento
(916) 255-3709
Central CA: Tom Kovac, Clovis
(209) 297-3939 (Fresno satellite)
North Coast CA: Lynn Nakashima,
Berkely
(510)540-3839
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Legislation passed in 1995 allows voluntary cleanups to be
overseen and approved hy Licensed Environmental
Professionals in the following circumstances: l) with DEP
approval, for sites listed on the State Inventory of Hazardous
Waste Sites, or subject to property transfer restrictions as a
result of past site use; or 2) if the site is not under order, is
located in an area restricted to industrial or commercial use,
and the ground water is not classified for drinking water use.
Covenants-Not-To-Sue for past contamination may be issued
to parties successfully completing cleanups in accordance with
the state's remediation standards. A Contaminated Properly
and Remediation Fund will provide low interest loans to
municipalities and other parties to conduct site assessments
and investigations.
1996 regulations set numeric soil and
ground-water standards with
alternative criteria and land use
restrictions available.
Betsey Wingfield
CT DEP
(860) 424-3791
Part II, Chapter 13
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Table 13-1 Summary of Contaminated Property Information for Selected States
CJ
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State
Remediation Incentives and
Voluntary Programs
Cleanup
Criteria
Contact(s)
n.
1990 regulations for petroleum
cleanups; proposals to change in 1994.
Douglas Jones
Bureau of Waste Site Cleanup
FL 1)ER
(904) 488-0190
CA
Voluntary program under development; Hazardous Site
Response Act stipulates fees and procedures governing
cleanups.
Regulations establish numeric soil and
ground-water screening criteria; site-
specific determinations of cleanup
requirements are based on use.
1 im ('ash, Director (or any
compliance officer)
Hazardous Site Response Program
CA DNIi
(404) 657-8600
II.
The 1988 Pre-Notice Site Cleanup Program and subsequent
Brownfields Redevelopment Fund governs remediations of sites
not on the NPL or subject to order. In 1991, U.S. EPA signed
a Memorandum of Agreement with the Illinois EPA stating that
EPA Region V would not initiate any action against Illinois
EPA approved cleanups under Superfund except in a case
where there was an emergency or imminent threat. State
grants non-transferable Covenants-Not-To-Sue.
I hree tiers of standards: background,
numeric standards under development,
and site specific determinations.
Terri Myers
Div. of I.and Pollution Control
1L EPA
(217) 524-4863
IN
Voluntary Remediation Program for sites not listed on NPL or
state Superfund list. Covenants not to sue are tied to a use
standard and are available to PRPs as an incentive to clean up
historic contamination, if the site is not already subject to a
state or federal order. State has signed an agreement with EPA
to extend protection from federal liability to sites' cleanup in
accordance with a state-approved plan.
1 hree tiers of standards:
1) Background levels.
2) Generic risk-based residential and
non-residential criteria.
3) Site specific assessments.
Larry Studcbaker (Standards)
(317) 308-3141
Carla Gill (Voluntary
Remediations)
317-308-3123
KY
Brownfields initiative under development; regulations including
voluntary cleanup incentives adopted, but expired 4/12/96,
because of objections by affected property owners and
legislature.
Numeric cleanup standards,
background or detection limits for
petroleum contamination; soil and
ground-water numeric screening levels
for single media. Current standards,
adopted in 1995, expire in April 1996
due to legislative objection but
standards are likely to be used as
guidance until new regulations are
adopted.
James Hale, DEP Division of
Regulatory Development
(Standards)
(502) 564-2225, Ext. 221
Jeff Pratt, Superfund Branch
(502) 564-2225, Ext. 223.
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Table 13-1 Summary of Contaminated Propert^tnformation for Selected States
State
Remediation Incentives and
Voluntary Programs
Cleanup
Criteria
Contact(s)
MA
The 1994 Clean Sites Initiative—The Massachusetts
Contingency Plan and its amendments establishes a Licensed
Site Professional Program and cleanup standards by which
Licensed Site Professionals (LSP's) can perform investigations
and cleanups with little to no DEI' oversight for all but a small
category of severely contaminated properties. Covenants-Not-
To-Sue are available to non-PRPs for properties not subject to
an order.
Massachusetts Contingency Plan sets
forth detailed cleanup methodologv
and standards.
Malt Cogliano
liureau of Waste Management
MA DCP
(ft 17) 292-5990
Ml)
Initiating a voluntary program in summer of I996.
No established standards, will begin
development with this year's funding;
in interim site specific determinations
govern cleanups
Hob DeMarco, Senior
Environmental Quality Analyst
Dept. of F.nviromncntal
(•410) Ml-3437
Ml
The Land Recycling Act—State law allows the transfer of
government liability protection to private purchasers and also
authorizes Covenants-Not-To-Sue with prospective purchasers
of sites deemed not to pose a health or safety threat.
1990 regulation fur two levels of
cleanup and 1993 guidelines for third
site-specific standard for soils and
groundwater; revised 1/96.
Seg Norgbcy, PhD
Lnv. Response Division
Ml DNR
(517) 373-4808
MN
In 1988 the state established a Voluntary Investigation and
Cleanup Program (VIC!) which offers municipalities and some
other public entities technical (for a fee) and financial
assistance, and some liability protection. In 1992 the
legislature enacted the Contamination Cleanup Program to
provide private parties with similar opportunities. $7.8 million
was designated to provide matching grants to fund cleanup
sites with significant development potential. The law also
authorizes a seven county Metropolitan Council to raise up to
$6.6 million a year to fund grants for cleanups in the region.
The state offers various written liability assurances following
voluntary cleanup including "no action," "off-site
determination," and "no association determination" letters or
agreements and Certificates of Completion.
Background or site-specific goals based
on health risk and prevention of further
degradation, soil and ground-water
criteria used as guidelines.
MN Pollution Control
(ft 12) 296-7290
Deb DeLuca
VIC Coordinator
MO
The 1994 Voluntary Cleanup Program includes any site not
listed on the NPL or subject to another enforcement action
regarding the contamination. A responsible party (PRP) may
participate, but if remediation is not completed an enforcement
action can be initiated.
Generic and site specific soil
regulations being adopted.
Karen Northop
llzils. Waste Program
MO DNR
(314) 751-8333
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Stale
NC
N)
Remediation Incentives and
Voluntary Programs
Brownfield Site Initiative
The 1993 Industrial Site Recovery Act amended and renamed the
state's Environmental Contamination and Response Act and
provided $55 million in loans and grants to enable investigation
and cleanup of contaminated properties. Of that initial $55
million, approximately $8.9 M had been obligated for
expenditure through 1995. The initial money was separated into
7 funds with the following amounts and uses:
$8.25 M for loans to private parties in targeted municipalities;
$5.5 M for loans to private parties undertakin voluntary
cleanups;
$ l l M for loans to those under order to remediate;
$8.25 M for loans or grants to municipalities and private parties
to carry out remediation when there was an imminent threat
to health or the environment;
$5.5 M for loans or grants to municipalities and private parties
for remediation when there is not an immediate threat; and
$ I 1 M for grants to innocent private parties.
Loans are for 10 years with a 5% interest rate and recipients may
receive up to $ 1 M.
10/95 proposed chromium cleanup criteria.
Cleanup
Criteria
1993 regulation, site specific soil
standards for non-petroleum
contamination; ground-water standards
use background or detection
components and are designed to
prevent further degradation.
Soil and ground-water standards and
site specific alternatives.
Contact(s)
Bill Meyer (Standards)
Department of Environmental
Health and Natural Resources;
Division of Soils and Hazardous
Waste
(919) 733-4996, Ext. 202
Jack Butler (Brownfield Site
Initiatives)
Superfund Division
(919) 733-2801, Ext. 293
Bradi Sklar (DEI')
(609) 633-7141
Arnold Gray
Div. of llesp. I'arty Site Reined.
N) DEI'
(609)633-1 179
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Table 13-1 Summary of Contaminated Property^lnformation for Selected States
State
Remediation Incentives and
Voluntary Programs
Cleanup
Criteria
Contact(s)
NY
In 1994 the state established a Voluntary Cleanup Program
open to certain responsible parties and other owners,
operators, prospective purchasers, municipalities, and lenders.
Volunteers enter into binding agreement with Department
which may be limited to site investigation; volunteers granted
"no further action" liability protection for cleanup consistent
with land use. Reopeners include unknown contamination,
land use change, or new scientific information that determines
health threat or fraud.
Ground-water standards set to protect
to drinking water standard; site-
specific determinations include land
use considerations and are based on
1992 health risk guidelines.
Chris Costopoulos (5 15) 457-381 I
Larry Ennist (5 I 5) 485-7719
Hazardous Waste Remediation
Division
NY Dept. of Conservation
(515) 485-8403
OH
The state's 1995 Real Estate Cleanup and Reuse Program
excludes sites under CERCLA, RCRA, LUST, TSCA and
SOW A enforcement. Cleanups can be overseen by
independent registered site professionals. Site Professional's
No Further Action letters trigger an automatic Covenant Not
To Sue unless Ohio EPA has determined site cleanup required
a special multi-permit "Consolidated Standards Permit." The
state provides a 10 year tax credit tied to the cost of cleanup
and specifically allows the party undertaking a volunteer
cleanup to sue those at fault for cost recovery.
Adopted 1995(?) - use driven.
Gavin Armstrong
Div. of Emergency and Remedial
Responsibility
OH EPA
(614) 644-2329
OK
1991 Regulation for ground water used
for drinking; 1992 site specific
remediation index guideline used in
making site-specific determinations for
other cleanups.
Mary )ane Calvi (Standards)
Solid Waste Mgmt. Services
OK DEQ
(405) 745-7100
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Table 13-1 Summary of Contaminated Property Information for Selected States
State
Remediation Incentives and
Voluntary Programs
Cleanup
Criteria
Contact(s)
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The 1995 Land Recycling and Environmental Standards Act
and Community Redevelopment and Remediation Loan
Program constituted a major effort by Pennsylvania to hasten
cleanup of contaminated properties. Although any site not
being remediated to background or health-based criteria, must
undergo a site specific assessment, those that have been
abandoned or are in enterprise zones may qualify for a special
standard which only requires remediation of an imminent
threat. State and local permits are not required for remedial
activities under this act and owners or developers of a site
remediated to the required standard are protected from
liability for further cleanup costs. A $ 15 million Industrial
Sites Cleanup Fund provides grants and low interest loans for
up to 75% of the cost of investigation and cleanup to innocent
parties undertaking cleanups. A second fund provides moneys
for municipalities and non-profit and governmental agencies.
The state provides Covenants-Not-To-Sue to innocent
prospective purchasers and landowners. For other cleanups
conducted in accordance with the state's standards, liability
protection is qualified, and subject to reopeners.
1991 guideline: to background, or
technology based and site specific risk
assessment; numeric criteria under
development.
Karen Bassett
PA DED
Don Killian, Waste Mgmt. Div. of
Remed.
PA DER
(717) 783-9475
Rl
The state's Voluntary Cleanup Program for prospective
purchasers includes Convenants-Not-To-Sue; A pilot
brownfield program targets high profile sites and is state
funded and overseen
Draft proposed regulations out for
public comment (4/96), currently site
specific determination.
Rl DEM - Division of Site
Remediation
Timothy O'Conner or Greg Fien
(401) 277-3872
SC
TN
k
Voluntary technical review and oversight of cleanup of most
sites.
1985 ground-water regulation based
on MCLs, site specific soil standards
made on basis of ingestion and long-
term ground-water contamination.
Tom Knight
Div. of Water Quality Assessment
and Enforcement, SC Dept. of
Health &. Env. Control
(803) 734-5227
Voluntary Cleanup Oversight and Assistance Program for
PRPs and others requires a $5,000 participation fee; Cleanup
plan agreed to in a mutual consent order which protects
participant from the state filing a notice of hazardous
substance with regard to the property or a lien on the
property.
1991 guideline proposed for soil and
ground water with site specific
possibility; 9/95 rule revises guidance
criteria for remediation goals and lists
state's inactive hazardous substance
sites.
Ajidrew Shivas (Director)
(615) 532-0912
Div. of Superfund
TN Department of Environment &.
Conservation
Andy Binford (Standards)
(615) 532-0911
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Table 13-1 Summary of Contaminated Property Information for Selected States
Stale
Remediation Incentives and
Voluntary Programs
Cleanup
Criteria
Contact(s)
TX
In 1994 the state established a Voluntary Cleanup Program
for sites not subject to enforcement actions under state or
federal laws or currently undergoing permitted remediation.
The state offers prospective purchasers and lenders (Jovenants-
Not-To-Sue.
Background, health based &.site
specific; 1993 regulation. 1995 rule
incorporates federal standards 40 CFR
300 - Hazard Ranking System and
establishes damage assessment
requirements.
Wesley Newberry
Texas Natural Resource
Conservation Commission,
Pollution Cleanup Division
(512) 239-2512
WA
The Voluntary Cleanup Program; Covenants-Not-To-Sue are
available following completion of a state supervised cleanup.
Health based, site specific and EDR or
specific levels in 1991 regulation.
Steve Robb
Toxic Cleanups Program
Dept. of Ecology
(360) 438-3057
WI
The Mav 1994 Land Recycling Program governs cleanup by
responsible (PRPs) as well as innocent volunteer parties. A
participating responsible party is subject to enforcement action
for failure to complete the cleanup. The state does grant a
release from liability imposed under its Hazardous Substance
Discharge (Spill) Law following an approved cleanup in the
form of a "certificate of completion" for a new innocent
purchaser, a current innocent owner who acquired the
property under certain circumstances and before certain date;
unknown contain.
2/95 regulations define simple and
complex sites to establish soil
standards and numeric standards for
selecting remedial action options.
Cara Norland/Jacki Jarvis
(Voluntary Cleanups)
(608) 267-0540
Information line on Land Recycling
Program
(800) 367-6076 (in state)
Jennie Sommers (Standards)
Bureau Solid Waste and Hazardous
Waste Management
(608) 264-5008
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APPENDIX 13-A
COMPLIANCE SCHEDULE FOR FEDERAL
SUPERFUND REQUIREMENTS
-------
Regulatory Compliance and Environmental Management Calendar
Due Date and
Frequency
Item Required
Gov. Reg.
Requirement
Submit To
Page in
Manual
CHATTER 13 - SUPERFUND AND CONTAMINATED PROPERTIES
Milestone Events
Dy year 2000
Initiate voluntary
stabilization
RCRA
Beginning in 2000, EPA will pursue enforcement
action against any facility on RCRA High Priority
Corrective Action List that has not undertaken
voluntary stabilization
13-29
Regular or Periodic Events
Other Events
-------
APPENDIX 13-B
OSHA CONSULTATION PROJECT DIRECTORY1
' Source: http.v/H'ww.osha.gov/oshdir/consul.html (October 14. 1996).
-------
SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Consultation
Alabama
7(c)(1) Onsite Consultation Program
432 Martha Parham West
P.O. Box 870388
Tuscaloosa, Alabama 35487
Attn: Director - (205) 348-3033
Fax: (205) 348-3049
E-Mail: BVVEEMS@ua.edu
Alaska
Division of Consultation and Training
ADOL/OSHA
3301 Eagle Street
P.O. Box 107022
Anchorage, AK 99510
Attn: Chief - (907) 269-4954
Fax: (907) 269-4950
E-Mail: dwavnehouck@labor.sute.us
Arizona
Consultation and Training
Division of Occupational Safety (St Health
Industrial Commission of Arizona
800 West Washington
Phoenix, Arizona 85007-9070
Attn: Consult. Mngr. 602) 542-5795
Fax: (602) 542-1614
Arkansas
OSHA Consultation
Arkansas Department of Labor
10421 West Markham
Little Rock, Arkansas 72205
Attn: Administrator - (501) 682-4522
Fax: (501) 682-4532
California
CAL/OSHA Consultation Service
Department of Industrial
Relations, Room 5246
455 Golden Gate Avenue
San Francisco, CA 94102
Attn: Program Manager - (415) 703-4441
Fax:(415)972-8513
Project Directory
Colorado
Occupational Safety and Health Section
Colorado State University
1 10 Veterinary Science Building
Fort Collins, Colorado 80523
Attn: Project Manager - (303) 491-6151
Fax: (303) 491-7778
E-Mail: jdsand@lamar.colostate.edu
Connecticut
Division of Occupational Safety &. Health
Connecticut Department of Labor
200 Folly Brook Boulevard
Wethersfield, Connecticut 06109
Attn: Director - (203) 566-4550
Fax: (203) 566-6916
Delaware
Occupational Safety and Health
Division of Industrial Affairs
Delaware Department of Labor
4425 Market Street
Wilmington, Delaware 19802
Attn: Director - (302) 761-8219
Fax: (302) 761-8219
E-Mail: rhair@state.de.us
District of Columbia
Office of Occupational Safety and Health
DC Dept. of Employment Services
950 Upshur Street, N.W.
Washington, DC 20011
Attn: Safety Super. (202) 576-6339
Fax: (202) 576-7282
Florida
7(c)( 1) Onsite Consultation Prog. Div. of Safety
Florida Dept. of Labor and Employment
Security
2002 St. Augustine Road, Building E, Suite 45
Tallahassee, Florida 32399-0663
Attn: Prog. Coord. - (904) 488-3044
Fax: (904) 922-4538
December 1996
13-B1
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
7(c)(1) Onsite Consultation Program
Georgia Institute of Technology
O'Keefe Building, Room 22
Atlanta, Georgia 30332-0837
Attn: Prog. Manager - (404) 894-2646
Fax: (404) 894-8275
e-mail: paul.middendorf@gtri.gatech.edu
webpage: http://eoeml-www.gtri.gatech.edu/
Guam
OSHA Onsite Consultation
Dept. of Labor, Government of Guam
Post Office Box 9970
Tamuning, Guam 9693 1
Attn: Proj. Manager - (671) 475-0136
Fax: (671) 477-2988
Hawaii
Consultation and Training Branch
Dept of Labor and Industrial Relations
830 Punchbowl Street
Honolulu, Hawaii 96813
Attn: Prog. Manager - (808) 586-9100
Fax: (808) 586-9099
Idaho
Safety and Health Consultati. n Program
Boise State University, Dept. of Health Studies
1910 University Drive, ET-338A
Boise, Idaho 83725
Attn: Prog. Director - (208) 385-3283
Fax: (208) 385-4411
E-Mail: lstokes@bsu.idbsu.edu
Illinois
Illinois Onsite Consultation
Industrial Service Division
Department of Commerce &. Community
Affairs
State of Illinois Center, Suite 3-400
100 West Randolph Street
Chicago, Illinois 60601
Attn: Manager - (3 12) 814-2337
Fax: (312) 814-7238
Indiana
Division of Labor
Bureau of Safety, Education
and Training, Room W195
402 West Washington
Indianapolis, Indiana 46204-2287
Attn: Director - (3 17) 232-2688
Fax: (317) 232-0748
Iowa
7(c)(1) Consultation Program
Iowa Bureau of Labor
1000 East Grand Avenue
Des Moines, Iowa 50319
Attn: Proj. Director - (515) 281-5352
Fax: (515) 281-4831
Kansas
Kansas 7(c)(1) Consultation Program
Dept. of Human Resources
512 South West 6th Street
Topeka, Kansas 66603-3150
Attn: Project Manager - (913) 296-7476
Fax: (913) 296-1775
Kentucky
Division of Education and Training
Kentucky Labor Cabinet
1049 U.S. Highway 127, South
Frankfort, Kentucky 40601
Attn: Director - (502) 564-6103
Fax: (502) 564-4769
Louisiana
7(c)(1) Consultation Program
Louisiana Department of Labor
Post Office Box 94094
Baton Rouge, Louisiana 70804-9094
Attn: Manager - (504) 342-9601
Fax: (504) 342-5158
Maine
Division of Industrial Safety
Maine Bureau of Labor
State House Station #82
Augusta, Maine 04333
Attn: Director - (207) 624-6460
Fax: (207) 624-6449 E-Mail:
M£BLS@bls.labor.state.me.us
December 1996
13-B2
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Maryland
Division of Labor and Industry
501 Saint Paul Place, 3rd Floor
Baltimore, Maryland 21202
Attn: Proj. Manager - (410) 333-4210
Fax: (410) 333-8308
Massachusetts
The Commonwealth of Massachusetts
Dept. of Labor &_ Industries
1001 Watertown Street
West Newton, Massachusetts 02165
Attn: Proj. Manager - (617) 969-7177
Fax: (617) 969-4581
E-Mail: jlamaIva@N2I8.osha.gov
Michigan
Michigan Dept of Public Health
Division of Occupational Health
3423 North Logan Street, P. O. Box 30195
Lansing, Michigan 48909
Attn: Proj. Manager - (517) 335-8250
Fax: (517) 335-8010
Michigan Department of Labor
Bureau of Safety and Regulation
7150 Harris Drive
Lans::ig, Michigan 48909
Attn: Proj. Manager - (517) 322-1809
Fax: (517) 322-1775
Minnesota
Dept. of Labor and Industry
Consultation Division
443 LaFavette Road
Saint Paul, Minnesota 55 155
Attn: Director - (612) 297-2393
Fax: (612) 297-1953
Mississippi
Mississippi State University
Center for Safety and Health
2906 North State Street
Suite 201
Jackson, Mississippi 39216
Attn: Director - (601) 987-3981
Fax: (601) 987-3890
E-Mail: mico(aosha85.osha-slc.gov
Missouri
Onsite Consultation Program
Division of Labor Standards
Dept. of Labor &. Industrial Relations
3315 West Truman Boulevard
Jefferson City, Missouri 65109
Attn: Project Manager - (573) 751-3403
Fax: (573) 751-3721
Montana
Dept. of Labor and Industry
Bureau of Safety
Post Office Box 1 728
Helena, Montana 59624-1728
Attn: Proj. Manager - (406) 444-6418
Fax: (406) 444-4140
E-Mail: dfolsom@mt.gov
Nebraska
Division of Safety Labor &. Safety Stds
Nebraska Department of Labor
State Office Building, Lower Level
301 Centennial Mall, South
Lincoln, Nebraska 68509-5024
Attn: Proj. Manager - (402) 471-4717
Fax: (402) 471-5039
Nevada
Division of Preventive Safety
Department of Industrial Relations, Suite 106
2500 West Washington
Las Vegas, Nevada 89106
Attn: Asst. Administrator - (702) 486-5016
Fax: (702) 486-5018
New Hampshire
OSHA Consultation
New Hampshire Dept. of Health
Division of Public Health Services
6 Hazen Drive
Concord, New Hampshire 03301-6527
Attn: Proj. Manager - (603) 271-2024
Fax: (603) 271-2667
E-Mail: jake@nh7cl.mv.com
December 1996
13-B3
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
New Jersey
Division of Workplace Stds
New Jersev Department of Labor
Station Plaza 4, CN953
22 South Clinton Avenue
Trenton, New Jersey 08625-0953
Attn: Proj. Manager - (609) 292-3923
Fax: (609) 292-4409
New Mexico
New Mexico Environment Dept
Occupational Health and Safety Bureau
1 190 St. Francis Drive
Post Office Box 261 10
Santa Fe, New Mexico 87502
Attn: Prog. Manager - (505) 827-2877
Fax: (505) 827-4422
New York
Division of Safety and Health
State Office Campus
Building 12, Room 457
Albany, New York 12240
Attn: Prog. Director - (518) 457-2481
Fax: (518) 457-5545
North Carolina
Bureau of Consultative Services
North Carolina Dept. of Labor
Suite 105
3 19 Chapanoke Road
Raleigh, North Carolina 27603-3432
Attn: Bureau Chief - (919) 662-4644
Fax: (919) 662-4671
E-Mail: wjoyner@dol.state.nc.us
North Dakota
Division of Environmental Engineering
Room 304
1200 Missouri Avenue
Bismarck, North Dakota 58506-5520
Attn: Proj. Director - (701) 328-5188
Fax: (701) 328-5200
E-Mail: ccmail.lhuber@ranch.state.nd.us
Ohio
OSHA Onsite Consultation
Bureau of Employment Services
145 S. Front Street
Columbus, Ohio 432 16
Attn: Tech. Coord. - (614) 644-2246
Fax: (614) 644-3133
Oklahoma
Oklahoma Department of Labor
OSHA Division
4001 North Lincoln Boulevard
Oklahoma City, Oklahoma 73105-5212
Attn: Director - (405) 528-1500
Fax: (405) 528-5751
Oregon
Department of Consumer and Business Services
Oregon Occupational Safety and Health
Division
350 Winter Street NE, Room 430
Salem, Oregon 973 10
Attn Manager: (503) 378-3272
1-800-922-2689
E-mail: steve.g.beech@state.or.us
or consult.web@state.or.us
webpage:
http://www.cbs.sute.or.us/extemal/osha/consult/
consult.htm
Pennsylvania
Indiana University of-Pennsylvania
Safety Sciences Department
205 Uhler Hall
Indiana, Pennsylvania 15705
Attn: Proj. Manager - (412) 357-2561
Fax: (412) 357-2385
Puerto Rico
Occupational. Safety and Health Office
Dept. of Labor &. Human Resources, 21 st Floor
505 Munoz Rivera Avenue
Hato Rev, Puerto Rico 00918
Attn: Proj. Manager - (809) 754-2188
Fax: (809) 767-605 I
December 1996
13-B4
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Rhode Island
Division of Occupational Health
Rhode Island Department of Health
Division of Occupational Health
206 Cannon Building, 75 Davis Street
Providence, Rhode Island 02908
Attn: Chief - (401) 277-2438
Fax: (401) 277-6953
E-Mail: oshacon@ids.net
South Carolina
South Carolina Department of Labor,
Licensing and Regulation
3600 Forest Drive
Post Office Box 11329
Columbia, South Carolina 292 11
Attn: Administrator - (803) 734-9614
Fax: (803) 734- 734-9716
E-Mail: scoshaovp@infoave.net
South Dakota
Engineering Extension
Onsite Technical Division
South Dakota State University
Box 510
West Hall
907 Harvey Dunn Street
Brc okings, South Dakota 57007
Attn: Director - (605) 688-4101
Fax: (605) 68$-6290
Tennessee
OSHA Consultative Services
Tennessee Department of Labor
710 James Robertson Parkway, 3rd F1
Nashville, Tennessee 37243-0659
Attn: Chief- (615) 741-7036
Fax: (615) 741-3325
Texas
Workers' Health and Safety Division
Workers' Compensation Commission
Southfield Building
4000 South I H 35
Austin, Texas 78704
Attn: Director - (5 12) 440-3834
Fax: (512) 440-3831
Utah
Utah Industrial Commission
Consultation Services
160 East 300 South
Salt Lake City, Utah 84114-6650
Attn: Proj. Manager - (801) 530-6868
Fax: (801) 530-6992
E-Mail: icman.nanderso@state.ut.us
Vermont
Division of Occupational Safety &. Health
Vermont Department of Labor and Industry
National Life Building, Drawer #20
Montpelier, Vermont 05602
Attn: Proj. Director- (802) 828-2765
Fax: (802) 828-2195
E-Mail: web@!abor.lab.state.vt.us
Virginia
Virginia Department of Labor and Industry
Occupational Safety and Health
Training and Consultation
13 South 13th Street
Richmond, Virginia 23219
Attn: Director - (804) 786-6613
Fax: (804) 786-8418
Virgin Islands
Division of Occupational Safety and Health
Virgin Islands Department of Labor
Lagoon Street Government. Complex
Building 2, Room 207
Frederiksted, Virgin Island 00840
Attn: Director - (809) 772-1315
Fax: (809) 772-4323
Washington
WA Dept of Labor and Industries
Division of Industrial Safety and Health
Post Office Box 44643
Olvmpia, Washington 98504
Attn: Prog. Manager - (360) 902-5638
Fax: (360) 902-5459
E-Mail: jame235@lni.wa.gov
December 1996
13-B5
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
West Virginia
West Virginia Department of Labor
Capitol Complex Building #3
Room 3 19
1800 East Washington Street
Charleston, West Virginia 25305
Attn: Proj. Manager - (304) 558-7890
Fax: (304) 558- 3797
Wisconsin
Wisconsin Department of Health
and Human Serv., Division of Health
Section of Occupational Health, Room 112
1414 East Washington Avenue
Madison, Wisconsin 53703
Attn: Chief - (608) 266-8579
Fax: (608) 266-9711
Wisconsin Department of Industry
Labor and Human Relations
Bureau of Safety Inspections, Suite C
401 Pilot Court
Waukesha, Wisconsin 53188
Attn: Proj. Manager - (414) 548-5188
Fax: (414) 521-8614
Wyoming
Wvoming Department of Employment
Workers' Safety and Compensation Division
Herschler Building, 2 East
122 West 25th Street
Cheyenne, Wyoming 82002
Attn: Proj. Manager (307) 777-3646
Fax: (307) 777-5805
December 1996
13-86
-------
APPENDIX 13-C
EPA BROWNFIELDS CONTACTS2
2 Maas.James@epamail.epa.gov. Revised May 23, 1996.
URL: hup://\vww.epa.gov/Vverosps/bf/regcntct.htm
-------
SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
EPA RCRA Contacts
Region 1
One Congress Street
John F. Kennedy Federal Building
Boston, MA 02203-0001
Kevin McSweenev, Associate Director
Waste Policy Division
Office of Ecosystem Protection (CAA)
Telephone No. 617-565-3559
Fax No. 617-565-4940
Secretary: Virginia Ranauro-Walshe 617-565-
3478
Region 2
290 Broadway
New York, NY 10007-1866
George C. Meyer
Hazardous Waste Compliance Branch
(2AWM/HWF)
Telephone 212-637-4144
Fax No. 212-637-4949
Secretary: Brenda Lawson, 212-637-4145
Andrew J. Bellina, Chief
Hazardous Waste Facilities Branch
Telephone No. 212-637-4109
Fax No. 212-637-4437
Region 3
841 Chestnut Street
Philadelphia, PA 19017
Maria Parisi Vickars
Office of RCRA Programs (3HW03)
Telephone No. 215-566-149
Fax No. 215-566-31 14
Secretary, Sondra Alien 2 15-566-3110
Region 4
345 CourtJand Street, N.E.
Adanta, GA 30365
Alan Farmer (Permits)
RCRA Branch
Waste Management Division
Telephone No. 404-347-3433
Fax No. 404-347-0076
Kent Williams, Acting Chief
RCRA Permitting Section
Waste Management Division (4WD-RCRA)
Telephone No. 404-347-3433
Fax No. 404-347-1918
Jeaneanne Williams, Acting Chief
RCRA Compliance Section
Waste Management Division
Telephone No. 404-347-7603
Fax No. 404-347-5202
Region 5
77 West Jackson Boulevard
Chicago, IL 60604
Karl Bremer (CA &. Permits)
Waste Management Branch
Waste, Pesticides &.Toxics Division (DRP-8J)
Telephone No. 312-353-0398
Fax No. 312-353-4788
Gerald Phillips
Telephone No. 312-886-0977
Fax No. 312-353-6514
Region 6
First Interstate Bank Tower at Fountain Place
12th Floor, Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
Stephen A. Gilrein (Permits)
RCRA, Multimedia Planning &_ Permitting
Division (6PL)
Telephone No. 214-665-8179
Fax No. 2 14-665-2 164
Secretary, Janice Garland 214-665-7200
Region 7
726 Minnesota Avenue
Kansas City, ICS 66101
Larry Hacker (CA, Permits for Iowa and all SP)
Air, RCRA, St. Toxics Division
Telephone No. 913-551-7602
Fax No. 913-551-7521
Secretary, T.R. Lohmever 913-55 1 -7676
December 1996
13-C1
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
JoAnn M. Heiman (CA &. Permits)
RCRA Permitting &. Compliance Branch
Air, RCRA, &. Toxics Division
Telephone No. 913-551-7323
Fax No. 9 13-55 1 -7947
Region 8
999 18th Street
Suite 500
Denver, CO 80202-2466
Wanda Taunton, Director
Hazardous Waste Program (8P2-HW)
Telephone No. 303-312-7081
Fax No. 303-312-6064
Secretary, Judy Geise 303-312-642 1
Paul Arell, Manager
Corrective Action Unit (8P2-SA)
Hazardous Waste Program
Telephone No. 303-312-6649
Fax No. 303-312-6064
Tom Bums, Team Leader
State Liaison—Assistance Team
(8P2-HW)
Telephone No. 303-312-6421
Fax No. 303-312-6064
Martin Hestmark, Director
Technical Enforcement
(8ENF-T)
Telephone No. 303-312-6778
Fax No. 303-312-6897
Jack Hidinger, Director
Pollution Prevention Program (Solid Waste)
(8P2-P2)
Telephone No. 303-312-6004
Fax No. 303-312-6363
Carol Rushin, Assistant RA
Office of Enforcement, Compliance and
Environmental Justice
(8-ENF)Telephone No. 303-312-
6406
Fax No. 303-312-6558 (or use 6191
[temporary])
Region 9
75 Hawthorne Street
San Francisco, CA 94105
Richard Vaile
Waste Compliance Branch
Telephone No. 415-744-2090
Fax No. 415-744-1044
Secretary, Buu Quach 415-744-2108
Michael Feelev (Permits &.CA)
Facilities Branch (H-3)
Telephone No. 415-744-2138
Fax No. 415-744-1044
Secretary, Susan Chiu 415-744-2060
Region 10
1200 Sixth Avenue
Seattle, WA 94105
Michasl Bussell
Office of Waste and Chemicals Management
(WCM-127)
Telephone No. 206-553-4198
Fax No. 206-553-8509
Korina Layne-Jones
Resources Managment &. State Programs Unit
(WCM-122)
Telephone No. 206-553-6915
Fax No. 206-553-8509
Kerrigan G. Clough, Assistant RA
Office of P-2, State &. Tribal Programs
(8P-2)
Telephone No. 303-312-6241
Fax No. 303-312-6038
December 1996
13-C2
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APPENDIX 13-D
EPA BROWNFIELDS CONTACTS2
2 Maas.|ames@epamail.epa.gov. Revised May 23. I996.
URL: http://w\vw.epa.gov/swerospvbf/regcntct.htm
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
EPA Brownfields Contacts
Region 1
John F. Kennedv Federal Building
Boston, MA 02203
Podhurski, John
617-573-9681
Fax: 617-573-9662
O'Learv, Pat
617-573-4992
Fax: 617-565-3346
Region 2
U.S.EPA
18th Floor
290 Broadvvav
New York, NY 10278
D'Andrea, Larry
212-637-4314
Fax: 212-637-4360
dandrea.lany@epamail.epa.gov
Josephson, Jeff
212-637-3010
Fax: 212-637-4439
josephson. jeff(®epamail.epa.gov
Walter H. Schoepf
212-637-4319
Fax: 212-637-3256
schoepf.walter@epamail.epa.gov
Region 3
841 Chestnut Building
Philadelphia, PA 19107
Stolle, Tom
215-597-1 166
Fax: 215-597-3150
stolle.tom@epamail.epa.gov
Matsinger, Josie
2 15-597-3 182
Fax: 215-597-3182
matsinger. josie@epamail.epa.gov
Region 4
345 Courtland Street, N.E.
Adanta, GA 30365
Dick, Barbara
404-347-3555 extl 6273
Fax: 404-347-3058
dick.barbara@epamail.epa.gov
Robbins, Matt
404-347-5059 ext. 6212
Fax: 404-347-3058
robbins.matt@epamail.epa.gov
Region 5
77 West Jackson Boulevard
Chicago, IL 60604-3507
Touhy, Mary Beth
312-886-7596
Fax: 312-886-2403
touhy.marybeth@epamail.epa.gov
Bower, Jim
312-886-1423
Fax: 31.1-353-1120
bower.james@epamail.epa.gov
Dufficy, Joe
312-886-1960
Fax: 312-353-9306
Didier, Mai:
312-886-6711
Fax: 312-886-0168
didier.matt@epamail.epa.gov
Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Hitt, Sun
214-665-6736
Fax: 214-665-6660
hitt.sunlev@epamail.epa.gov
December 1996
13-01
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SUPERFUND AND CONTAMINATED PROPERTIES
Part II, Chapter 13
Region 7
726 .Minnesota Avenue
Kansas Citv, KS 66101
Hemdon, Kerrv
913-551-7286'
Fax: 913-551-7063
hemdon.kerrv@epamail.epa.gov
Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
Ostrander, David
303-312-6931
Fax: 303-312-6071
ostrander.david@epamail.epa.gov
Region 9
75 Hawthorne Street
San Francisco, CA 94105
Nikzat, Sherry
415-744-2360
Fax: 415-744-1917
nikzat.sherry@epamail.epa.gov
Kahan, Bobbie
415-744-2191
Fax: 415-744-1796
kahan.bobbie@epamail.epa.gov
Opalskii Dan
415-744-2362
Fax: 415-744-1917
opalski.dan@epamail.epa.gov
Mix, Tom
415-744-2378
Fax: 415-744-1917
mlx.tom@epamail.epa.gov
Keener, Bill
415-744-1356
Fax: 415-744-1041
keener.bill@epamail.epa.gov
Region 10
1200 Sixth Avenue
Seattle, WA 98101
Cohen, Lori
206-553-6523
Fax: 206-553-0124
cohen.lori@epamail.epa.gov
Drake, Bob
206-553-4803
Fax: 206-553-4803
drake.robert@epamail.epa.gov
December 1996
13-D2
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Notes
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Notes
15
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