United States
Environmental Protection
Agency
Office of Environmental
Information
Washington, DC 20460
EPA745-B-00-017
May 2000
&EPA Emergency Planning and Community Right-
To-Know Act Section 313 Reporting Guidance
for Rubber and Plastics Manufacturing
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT vii
OVERVIEW viii
CHAPTER 1 - INTRODUCTION 1-1
1.0 PURPOSE 1-1
1.1 Background on EPCRA Section 313 and PPA Section 6607 1-2
CHAPTER 2 - REPORTING REQUIREMENTS 2-1
2.0 PURPOSE 2-1
2.1 Must You Report? 2-2
2.2 SIC Code Determination 2-4
2.3 Number of Employees 2-7
2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section
313 Chemicals or Chemical Categories 2-8
2.5 Activity Categories 2-11
2.6 Persistent, Bioaccumulative, and Toxic (PBT) Chemicals 2-15
2.7 How Do You Report? 2-18
2.8 Form R 2-18
2.9 Alternate Threshold and Form A 2-19
2.10 Trade Secrets 2-20
2.11 Recordkeeping 2-21
CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL CATEGORY
ACTIVITY THRESHOLD DETERMINATIONS 3-1
3.0 PURPOSE 3-1
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported), Processed, or
Otherwise Used 3-1
Qualifiers 3-4
3.2 Step 2. Identify the Activity Category and Any Exempt Activities for
Each EPCRA Section 313 Chemical and Chemical Category 3-7
3.2.1 Concentration Ranges for Threshold Determination 3-12
3.2.2 Evaluation of Exemptions 3-13
3.2.2.1 DeMinimisExemption 3-13
3.2.2.2 Articles Exemption 3-16
3.2.2.3 Facility-Related Exemption 3-18
Laboratory Activity Exemption 3-18
3.2.2.4 Activity-Related Exemptions (Otherwise Use
Exemptions) 3-18
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TABLE OF CONTENTS (Continued)
Page
3.2.3 Additional Guidance on Threshold Calculations for Certain
Activities 3-20
3.2.3.1 Reuse Activities 3-20
3.2.3.2 Remediation Activities 3-21
3.2.3.3 Recycling Activities 3-22
3.3 Step 3. Calculate the Quantity of Each EPCRA Section 313
Chemical and Chemical Category and Determine Which Ones
Exceed an Activity Threshold 3-22
CHAPTER 4 - ESTIMATING RELEASES AND OTHER WASTE MANAGEMENT
QUANTITIES 4-1
4.0 PURPOSE 4-1
4.1 General Steps for Determining Release and Other Waste
Management Activity Quantities 4-1
4.1.1 Step 1: Prepare a Process Flow Diagram 4-3
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and
Chemical Categories and Potential Sources of Chemical
Release and Other Waste Management Activities 4-3
4.1.3 Step 3: Identify Release and Other Waste Management
Activity Types 4-4
4.1.4 Step 4: Determine the Most Appropriate Method(s) and
Calculate the Estimates for Release and Other Waste
Management Activity Quantities 4-17
4.1.4.1 Monitoring Data or Direct Measurement (code M) . . . 4-19
4.1.4.2 Mass Balance (code C) 4-20
4.1.4.3 Emission Factors (code E) 4-21
4.1.4.4 Engineering Calculations (code O) 4-23
4.1.4.5 Estimating Release and Other Waste Management
Quantities 4-24
4.2 Determination of Release and Other Waste Management Activity
Quantities from Rubber and Plastic Manufacturing Processes 4-30
4.2.1 Synthetic Rubber Manufacturing and Rubber Processing .... 4-31
4.2.2 Rubber Product Manufacturing 4-41
4.2.3 Tire Manufacturing 4-51
4.2.4 Plastic Product Manufacturing 4-56
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TABLE OF CONTENTS (Continued)
Page
Appendix A EPCRA SECTION 313 GUIDANCE RESOURCES
Appendix B BASIC CALCULATION TECHNIQUES
Appendix C EPCRA SECTION 313 GUIDANCE FOR REPORTING SULFURIC ACID
Appendix D EPCRA SECTION 313 GUIDANCE FOR REPORTING AQUEOUS
AMMONIA
Appendix E LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING
Appendix F UNIT CONVERSION FACTORS
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LIST OF TABLES
Page
2-1 SIC Codes Covered by EPCRA Section 313 Reporting 2-4
2-2 SIC Codes for Rubber and Plastics Manufacturing Facilities 2-5
2-3 EPCRA Section 313 Chemicals and Chemical Categories Commonly Encountered
in Rubber and Plastics Manufacturing (SIC Codes 2822, 301, 302, 305, 306, and
308) 2-10
2-4 Activity Categories 2-12
2-5 Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals 2-16
3-1 Reporting Thresholds 3-8
3-2 Definitions and Examples of Manufacturing Subcategories 3-9
3-3 Definitions and Examples of Processing Subcategories 3-10
3-4 Definitions and Examples of Otherwise Use Subcategories 3-11
3-5 EPCRA Section 313 Reporting Threshold Worksheet 3-25
3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet 3-26
4-1 Summary of Liquid Residue Quantities From Pilot-Scale Experimental
Study 4-9
4-2 Potential Data Sources for Release and Other Waste Management
Calculations 4-18
4-3 Release and Other Waste Management Quantity Estimation Worksheet .... 4-26
4-4 Sources and Types of EPCRA Section 313 Chemicals for Rubber
Manufacturing and Processing 4-38
4-5 Source and Types of EPCRA Section 313 Chemicals for Rubber Product
Manufacturing 4-45
4-6 Sources and Types of EPCRA Section 313 Chemicals for Tire
Manufacturing 4-53
4-7 Sources and Types of EPCRA Section 313 Chemicals for Plastic Product
Manufacturing 4-60
IV
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LIST OF FIGURES
Page
2-1 EPCRA Section 313 Reporting Decision Diagram 2-3
4-1 Releases and Other Waste Management Activity Calculation Approach 4-2
4-2 Possible Release and Other Waste Management Activity Types for
EPCRA Section 313 Chemicals and Chemical Categories 4-5
4-3 Typical Emulsion Process for Manufacturing Synthetic Rubber 4-32
4-4 Comparison Between Emulsion and Solution Polymerization Process 4-33
4-5 Processing Rubber to Prepare for Product Manufacture 4-34
4-6 Typical Rubber Product Manufacturing 4-43
4-7 Typical Tire Manufacturing 4-52
4-8 Typical Plastic Product Manufacturing 4-57
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ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of the Rubber Manufacturers Association (RMA), the Society of the Plastics Industry (SPI), and
the International Institute of Synthetic Rubber Producers (HSR?). Without the insight provided
by those in the industry with actual experience in fulfilling the reporting requirements of EPCRA
Section 313, we would not have been able to produce a document that we believe will be of great
assistance to those who must prepare future EPCRA Section 313 reports. Special thanks go to
Ms. Tracey Norberg, Director, Environmental Affairs, RMA; Ms. Maureen Healey, Director of
Environmental and Transportation Issues, SPI; and Mr. Jim McGraw, Deputy Managing
Director, IISRP for their hard work.
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OVERVIEW
This document supersedes the booklet entitled Title III Section 313 Release
Reporting Guidance, Estimating Chemical Releases From Rubber Production and
Compounding, dated March 1988. It is intended to assist establishments and facilities in the
rubber and plastics manufacturing industry in complying with the Emergency Planning and
Community Right-To-Know Act (EPCRA) Section 313 and Pollution Prevention Act (PPA)
Section 6607 reporting requirements, the preparation of Form R or the alternate certification
statement, Form A. The EPCRA Section 313 program is commonly referred to as the Toxic
Chemical Release Inventory (TRI).
The principal differences in this new document include:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
U.S. Environmental Protection Agency's (U.S. EPA's) interpretive guidance on
various issues specific to rubber and plastics manufacturing; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
documents.
This document is designed to be a supplement to the annual issue of the Toxic
Chemical Release Inventory Reporting Forms and Instructions, ( TRI Forms and Instructions). It
is organized to provide a step-by-step guide to compliance with EPCRA Section 313 and PPA
Section 6607, starting with how to determine if your facility must report and ending with
guidance for estimating release and other waste management activity quantities.
Chapter 1 introduces EPCRA Section 313 and PPA Section 6607 reporting and
provides a brief background on Section 313 of EPCRA and Section 6607 of PPA.
Chapter 2 discusses reporting requirements and begins with how to determine if
your facility must report. This determination is based on your answers to a series of four
questions:
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Is your facility's primary Standard Industry Classification (SIC) Code on the
EPCRA Section 313 list?
Does your facility employ ten or more full-time employees or the equivalent?
Does your facility manufacture, process, or otherwise use any EPCRA Section
313 chemicals or chemical categories?
Does your facility exceed any of the activity thresholds for an EPCRA Section
313 chemical or chemical category?
If the answer to ANY ONE of the first three questions is "No" you are not
required to submit an EPCRA Section 313 report for any chemicals. If you answer "Yes" to the
first three questions and "No" to the fourth, you are not required to submit an EPCRA Section
313 report for that chemical or chemical category. If you answer "Yes" to ALL four questions,
the next step is to determine what kind of report you must prepare, a Form R or the alternate
certification statement, Form A. Chapter 2 provides detailed information on the requirements for
each kind of report. Chapter 2 concludes with a discussion on how to address trade secrets and
the records that should be kept to support your reporting.
Chapter 3 discusses how to calculate the activity thresholds (manufacture,
process, and otherwise use) for the EPCRA Section 313 chemicals or chemical categories.
Information is provided on how to determine which EPCRA Section 313 chemicals or chemical
categories your facility manufactures, processes, or otherwise uses and how to calculate the
quantities of each. Detailed information is also provided on the various exemptions:
• De minimis exemption;
• Article exemption;
• Facility-related exemption; and
• Activity-related exemptions.
Chapter 3 concludes with a discussion of how to determine which EPCRA
Section 313 chemicals or chemical categories exceed a reporting threshold.
Chapter 4 discusses how to estimate the release and other waste management
activity amounts for those EPCRA Section 313 chemicals and chemical categories for which you
must prepare a report. The first part of this chapter provides a step-by-step approach designed to
minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical or
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chemical category and any potential sources or types of release and other waste management
activities. This procedure consists of:
Preparation of a detailed process flow diagram;
Identification of EPCRA Section 313 chemicals and chemical categories and
potential sources of chemical release and other waste management activities;
Identification of the potential types of release and other waste management
activities from each source; and
Determination of the most appropriate methods for estimating the quantities of
EPCRA Section 313 chemical and chemical category release and other waste
management activities.
The second part of Chapter 4 is organized by the typical processes in rubber and
plastics manufacturing: rubber manufacturing, rubber product manufacturing, tire
manufacturing, and plastic product manufacturing. The commonly used EPCRA Section 313
chemicals and chemical categories, process descriptions, release and other waste management
activity estimates, example calculations, and common problems are presented.
This document includes examples and common errors applicable to rubber and
plastics manufacturing. These examples are based on information identified during voluntary
site surveys of facilities that have filed EPCRA Section 313 reports in the past, discussion with
representatives of the Rubber Manufacturers Association, the Society of the Plastics Industry,
and the International Institute of Synthetic Rubber Producers, and on questions received by the
EPCRA Hotline.
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CHAPTER 1 - INTRODUCTION
i.o PURPOSE
The purpose of this guidance manual two-fold. The primary purpose is to assist
rubber and plastics manufacturing facilities in complying with the reporting requirements of
Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
and of Section 6607 of the Pollution Prevention Act of 1990 (PPA). This manual explains the
EPCRA Section 313 reporting requirements and discusses specific release and other waste
management activities encountered at many rubber and plastics manufacturing facilities. Since
each plant is unique, the recommendations presented may have to be modified for your particular
facility. The secondary purpose is to provide information to other interested parties (such as
management, legal professionals, inspectors, consultants, teachers, students, and the general
public) about the processes and some of the toxic chemicals used in this industry.
This manual is intended solely for guidance and does not alter any statutory or
regulatory requirements. The document should be used in conjunction with the appropriate
statutes and regulations but does not supersede them. Accordingly, the reader should consult
other applicable documents (for example, the statute, the Code of Federal Regulations (CFR),
relevant preamble language, and the current Toxic Chemical Release Inventory Reporting Forms
and Instructions (TRI Forms and Instructions)).
This document supersedes the 1988 document entitled Title III Section 313
Release Reporting Guidance, Estimating Chemical Releases from Rubber Production and
Compounding. This new document includes:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
PPA Section 6607 reporting requirements;
U.S. Environmental Protection Agency's (U.S. EPA's) interpretive
guidance on various issues specific to rubber and plastics manufacturing;
and
EPCRA Section 313 issues regarding processes not discussed in the earlier
document.
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It is intended to supplement the TRI Forms and Instructions document that is updated and
published annually by U.S. EPA. It is essential that you use the current version of the TRI Forms
and Instructions to determine if (and how) you should report. Changes or modifications to
EPCRA Section 313 reporting requirements are reflected in the annual TRI Forms and
Instructions and should be reviewed before compiling information for the report.
The objectives of this manual are to:
• Reduce the level of effort expended by those facilities that prepare an
EPCRA Section 313 report; and
• Increase the accuracy and completeness of the data being reported.
U.S. EPA cannot anticipate every potential issue or question that may apply to
your facility. Therefore, this manual attempts to address those issues most prevalent or common
for rubber and plastics manufacturing. Used in conjunction with the most current TRI Forms and
Instructions and Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (1999 version), facilities should be able to provide complete and
accurate information for EPCRA Section 313 reporting. Additional discussions on specific
issues can be found in U.S. EPA's current edition of EPCRA Section 313, Questions and
Answers (the 1998 edition is EPA 745-B-98-004), which is available on the U.S. EPA's TRI
website (http://www.epa.gov/tri) or by contacting the EPCRA Hotline at 1-800-424-9346 In
the Washington, DC metropolitan area, call 703-412-9810.
1.1 Background on EPCRA Section 313 and PPA Section 6607
The following overview of EPCRA Section 313 and Section 6607 of the PPA,
will provide you with a basic understanding of the objectives and requirements of this program,
and will help you in completing your forms.
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One of the primary goals of EPCRA is to increase the public's knowledge of, and
access to, information on both the presence of toxic chemicals in their communities and on
releases into the environment and other waste management activities of those chemicals.
EPCRA Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2,
Section 2.2) to submit annual reports (commonly referred to as Form R reports and Form A
reports) on over 600 EPCRA Section 313 chemicals and chemical categories. Covered facilities
report the amounts released or otherwise managed as waste. However, if a facility meets the
reporting criteria for listed toxic chemicals, the facility must report even if there are no releases
or other waste management quantities associated with these chemicals. Throughout this
document, whenever EPCRA Section 313 chemicals are discussed, the discussion includes
chemical categories, as appropriate. Chemicals or chemical categories may be added or deleted
from the list. Therefore, before completing your annual report, be sure to check the most current
list included with the TRI Forms and Instructions when evaluating the chemicals and chemical
categories present at your facility. Copies of the reporting package can be requested from the
EPCRA Hotline, 1-800-424-9346.
All facilities meeting the EPCRA Section 313 reporting criteria must report the
annual release and other waste management activity quantities (routine and accidental) of
EPCRA Section 313 chemicals and chemical categories to all environmental media. A separate
report is required for each EPCRA Section 313 chemical or chemical category that is
manufactured (including imported), processed, or otherwise used above the reporting threshold.
The reports must be submitted to U.S. EPA and State or Tribal governments, on or before July 1,
for activities in the previous calendar year. The owner/operator of the facility on July 1 is
primarily responsible for the report, even if the owner/operator did not own the facility during the
reporting year. However, property owners with no business interest in the operation of the
facility, other than or lesser interest, are exempt from reporting requirements.
EPCRA also mandates U.S. EPA to establish and maintain a publicly available
database system consisting of the information reported under Section 313 and under Section
6607 of the PPA. This database, known as the Toxic Chemical Release Inventory (TRI)
database, can be accessed through the following sources:
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U.S. EPA Internet site, http://www.epa.gov/tri;
Envirofacts Warehouse Internet site, http://www.epa.gov/enviro; and
Right-to-Know network, http://www.rtk.net/trisearch.html.
However, information qualifying as a trade secret, in accordance with the
regulatory requirements is protected from public release. In addition to being a resource for the
public, TRI data are also used in the research and development of regulations related to EPCRA
Section 313 chemicals and chemical categories.
To reduce the reporting burden for small businesses, U.S. EPA established an
alternate activity threshold of one million pounds manufactured, processed, or otherwise used for
facilities with total annual reportable amounts of 500 pounds or less for each EPCRA Section
313 chemical or chemical category. Provided the facility does not exceed either the reportable
amount or the alternate threshold, the facility may file a certification form (Form A) rather than a
Form R. By filing the Form A, the facility certifies that they do not exceed the reportable amount
of 500 pounds or exceed the alternate threshold of one million pounds for the respective
chemical or chemical category.
Note that the annual reportable amount includes the quantity of the EPCRA
Section 313 chemical or chemical category in all production-related waste management
activities, not just releases (see the discussion in Section 2.8 for more detail). Also note that
either a Form A or a Form R, but not both, must be submitted for each EPCRA Section 313
chemical or chemical category above any reporting threshold, even if there are zero release and
other waste management activity quantities.
Violation of EPCRA Section 313 reporting provisions may result in federal civil
penalties of up to $27,500 per day for each violation (61 FR 69360). State enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.
Members of the Rubber Manufacturers Association, the Society of the Plastics
Industry, and the International Institute of Synthetic Rubber Producers provided input on
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common problems specific to rubber and plastics manufacturing encountered by those
completing the EPCRA Section 313 reports. U.S. EPA has combined this input with questions
forwarded to the EPCRA Hotline and those identified during voluntary site surveys of facilities
that have filed EPCRA Section 313 reports in the past. Selected issues and guidance addressing
these common problems are presented throughout this document as applicable.
The TRI Forms and Instructions and The 1994 and 1995 Toxic Release Inventory
Data Quality Report., EPA 745-R-98-002 also contain discussions of common problems in
completing the EPCRA Section 313 reports. You are encouraged to read both documents before
filling out the Form R (or Form A) for your facility.
If, after reading this manual, you still have questions about EPCRA Section 313
reporting, please contact the EPCRA Hotline at 1-800-424-9346 or refer to the U.S. EPA's TRI
website, http://www.epa.gov/tri. Assistance is also available from the designated EPCRA
Section 313 Coordinator in the U.S. EPA regional office and the EPCRA contact in your state
(see the TRI Forms and Instructions for a current list of these contacts). Additional guidance is
also available in the resources listed in Appendix A.
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CHAPTER 2 - REPORTING REQUIREMENTS
2.0 PURPOSE
The purpose of this chapter is to help you determine if you must prepare an
EPCRA Section 313 report(s) and, if so, what kind of report(s) should be prepared (Form R or
the alternate certification statement, the Form A). This chapter presents the EPCRA Section 313
reporting requirements to help you determine if these requirements apply to your facility. It also
discusses the reporting of trade secrets and the records that must be kept.
To understand the following discussion you must first understand how EPCRA
defines a facility. The term "facility" is defined as, "all buildings, equipment, structures, and
other stationary items which are located on a single site or on contiguous or adjacent sites and
which are owned or operated by the same person (or by any person who controls, who is
controlled by, or who is under common control with such person). A facility may contain more
than one "establishment" (40 CFR 372.3). An "establishment" is defined as, "an economic unit,
generally at a single physical location, where business is conducted, or where services or
industrial operations are performed" (40 CFR 372.3).
U.S. EPA recognizes that for business reasons it may be easier and more
appropriate for establishments at one facility to report separately. However, the combined
quantities of EPCRA Section 313 chemicals and chemical categories manufactured, processed, or
otherwise used in all establishments making up that facility must be considered for threshold
determinations. Also, the combined release and other waste management activity quantities
reported singly for each establishment must total those for the facility as a whole.
Note that if a facility is comprised of more than one establishment, once an
activity threshold is met by the facility, providing the facility meets the SIC Code and employee
threshold criteria, release and other waste management activities from all establishments at the
facility must be reported.
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Example - Multiple Establishments
Your facility has several different establishments, all with SIC Codes covered under EPCRA Section 313. One
establishment used 7,000 pounds of toluene, an EPCRA Section 313 chemical, during the year to clean
equipment. Another establishment purchased and used 4,000 pounds of toluene during the year as a solvent to
separate a component from a mixture, with recovery of the toluene for reuse. Both activities constitute otherwise
use of the EPCRA Section 313 chemical (as presented in Section 2.5 and described in detail in Chapter 3) and the
total for the facility exceeded the 10,000-pound otherwise use threshold for the year. Thus, if your facility meets
the employee threshold, you must file one Form R for toluene from your facility, or two Form Rs, one from each
establishment. Please note that you may be eligible to file one Form A for the facility but you cannot file a
separate Form A for each establishment.
2.1 Must You Report?
How do you determine if your facility must prepare an EPCRA Section 313
report? Your answers to the following four questions will help you decide (illustrated by
Figure 2-1):
1) Is the primary SIC Code for your facility included in the list covered by
EPCRA Section 313 reporting (see Section 2.2)?
2) Does your facility have 10 or more full-time employees or the equivalent
(see Section 2.3)?
3) Does your facility manufacture (which includes importation), process, or
otherwise use EPCRA Section 313 chemicals or chemical categories (see
Section 2.4)?
4) Does your facility exceed any applicable thresholds of EPCRA Section
313 chemicals or chemical categories (for non-PBT chemicals: 25,000
pounds per year for manufacturing; 25,000 pounds per year for processing;
or 10,000 pounds per year for otherwise use - see Section 2.5; for PBT
chemicals: see Section 2.6 for applicable thresholds)?
If you answered "No" to any of the first three questions, you are not required to
prepare any EPCRA Section 313 reports. If you answered "Yes" to ALL of the first three
questions, you must complete a threshold calculation for each EPCRA Section 313 chemical and
chemical category at the facility, and submit an EPCRA Section 313 report for each chemical
exceeding the applicable threshold.
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Is Your Facility's Primary SIC Code Included
on the EPCRA Section 313 List?
(See Section 2.2)
NO
YES
Does Your Facility Have 10 or More Full-Time
Employees or the Equivalent?
(See Section 2.3)
NO
YES
Does Your Facility Manufacture, Process, or
Otherwise Use any EPCRA Section 313
Chemicals or Chemical Categories?
(See Section 2.4)
NO
STOP
NO EPCRA
SECTION 313 REPORTS
REQUIRED FOR ANY
CHEMICALS OR
CHEMICAL CATEGORIES
YES
Does Your Facility Exceed Any of the
Thresholds for a Chemical or Chemical
Category (after excluding quantities that are
exempt from threshold calculations)
(See Section 2.6)
NO
AN EPCRA SECTION 313 REPORT IS
NOT REQUIRED FOR THIS CHEMICAL
OR CHEMICAL CATEGORY
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
Is the Amount Manufactured, OR Processed, OR Otherwise Used less than or equal to 1,000,000
pounds AND is the Reportable Amount less than or equal to 500 Ib/yr
(See Section 2.9)
YES
NO
FORM A OR FORM R
IS REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY (FOR PBT
CHEMICALS, A FORM R IS REQUIRED)
FORM R IS REQUIRED FOR THIS
CHEMICALORCHEMICAL
CATEGORY (FORM A CANNOT BE
SUBMITTED)
Figure 2-1. EPCRA Section 313 Reporting Decision Diagram
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2.2
SIC Code Determination
Facilities with the SIC Codes presented in Table 2-1 are covered by the EPCRA
Section 313 reporting requirements.
Table 2-1
SIC Codes Covered by EPCRA Section 313 Reporting
SIC Codes
10
12
20 through 3 9
4911, 4931, and 4939
4953
5169
5171
7389
Industry
Metal Mining
Coal Mining
Manufacturing
Electric and Other Services and
Combination Utilities
Refuse Systems
Chemicals and Allied Products
Petroleum Bulk Stations and Terminals
Business Services
Qualifiers
Except SIC Codes 1011, 1081, and 1094
Except SIC Code 1241
None
Limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce
Limited to facilities regulated under
RCRA Subtitle C
None
None
Limited to facilities primarily engaged in
solvent recovery services on a contract or
fee basis
Table 2-2 presents a listing of each SIC Code for rubber and plastics
manufacturing facilities, with brief descriptions. You should determine the SIC Code(s) for your
facility, based on the activities on site. For assistance in determining which SIC Code best suits
your facility refer to Standard Industrial Classification Manual, 1987 published by the Office of
Management and Budget.
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Table 2-2
SIC Codes for Rubber and Plastics Manufacturing Facilities
SIC Code
2822
3011
3021
3052
3053
3061
3069
3081
3082
3083
3084
3085
3086
3087
3088
3089
Description
Synthetic Rubber (vulcanizable elastomers)
Tires and Inner Tubes
Rubber and Plastics Footwear
Rubber and Plastics Hose and Belting
Gaskets, Packing and Sealing Devices
Molded, Extruded, and Lathe-Cut Mechanical Rubber Goods
Fabricated Rubber Products, (not elsewhere classified)
Unsupported Plastics Film and Sheet
Unsupported Plastics Profile Shapes
Laminated Plastics Plate, Sheet, and Profile Shapes
Plastics Pipe
Plastics Bottles
Plastics Foam Products
Custom Compounding of Purchased Plastic Resin
Plastics Plumbing Fixtures
Plastics Products, (not elsewhere classified)
Most rubber and plastics manufacturing facilities are in SIC Major Group 30 and are required to
prepare EPCRA Section 313 reports if they meet the employee and chemical activity threshold
criteria.
Note that auxiliary facilities can assume the SIC Code of another covered
establishment if the primary function is to service the covered establishment's operations. For
the purpose of EPCRA Section 313, auxiliary facilities are defined as those that are primarily
engaged in performing support services for another covered establishment or multiple
establishments of a covered facility, and are in a different physical location from the primary
facility. In addition, auxiliary facilities perform an integral role in the primary facility's
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activities. In general, the auxiliary facility's basic administrative services (e.g., paperwork,
payroll, employment) are performed by the primary facility. If an auxiliary facility's primary
function is to support/service a facility with a covered SIC Code, the auxiliary facility assumes
the covered SIC Code as its primary SIC Code and must consider the other reporting
requirements (40 CFR Section 372.22) to determine if it must comply with the EPCRA Section
313 reporting requirements. However, if the SIC Code for the primary facility is not covered by
EPCRA Section 313, then neither the primary nor the auxiliary facility is required to submit a
report.
If your facility has more than one SIC Code (i.e., several establishments with
different SIC Codes are owned or operated by the same entity and are located at your facility),
you are subject to reporting requirements if:
All the establishments have SIC Codes covered by EPCRA Section 313;
OR,
The total value of the products shipped or services provided at
establishments with covered SIC Codes is greater than 50% of the value of
the entire facility's products and services; OR,
Any one of the establishments with a covered SIC Code ships and/or
produces products or provides services whose value exceeds the value of
services provided, products produced, and/or shipped by every other
establishment within the facility.
Example - Primary SIC Code
A facility has two establishments. The first, a scrap and waste materials facility, is in SIC Code 5093. SIC Code
5093 is not a covered SIC Code. However, the second establishment, a plastic products not elsewhere classified
facility, is in SIC Code 3089, which is a covered SIC Code. The facility also determines the waste plastic product
is worth $500/unit as received from the establishment in the non-covered SIC Code and the value of the plastic
sheet product is $l,500/unit after processing by the establishment in the covered SIC Code. The value added by
the establishment in the covered SIC Code is more than 50% of the product value; therefore, the primary SIC
Code is 3089, a covered SIC Code. Thus, the establishment is covered by EPCRA Section 313 reporting and the
entire facility is subject to reporting.
A pilot plant within a covered SIC Code is considered a covered facility and is
subject to reporting, provided it meets the employee and activity criteria (note that pilot plants are
not eligible for the laboratory exemption, which is discussed in Chapter 3). Warehouses on the
same site as facilities in a covered SIC Code and warehouses that qualify as auxiliary facilities of
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covered facilities are also subject to reporting provided all applicable reporting requirements are
met.
While you are currently required to determine your facility's reporting eligibility
based on the SIC code system described above, it is important to be aware that the SIC code
system will be replaced by a new system in the future. On April 9, 1997 (62 FR 17287), the
Office of Management and Budget promulgated the North American Industrial Classification
System (NAICS). NAICS is a new economic classification system that replaces the SIC code
system as a means of classifying economic activities for economic forecasting and statistical
purposes. The transition to the new NAICS may require regulatory actions. As a result, the SIC
code system is still required to be used as the mechanism to determine your facility's reporting
eligibility. EPA will issue notice in the Federal Register to inform you and other EPCRA
Section 313 facilities of its plans to adopt the NAICS and how facilities should make their
NAICS code determination.
2.3 Number of Employees
If your facility meets SIC Code and activity threshold criteria, you are required to
prepare an EPCRA Section 313 report if your facility has 10 or more full-time employees or the
equivalent. A full-time employee equivalent is defined as a work year of 2,000 hours. If your
facility's employees hours total 20,000 or more hours in a calendar year, you meet the 10 or more
employee threshold criterion.
The following information should be included in your employee calculations:
Owners;
Operations/manufacturing staff;
Clerical staff;
Temporary employees;
Sales personnel;
Truck drivers (employed by the facility);
Other non-manufacturing or off-site facility employees directly supporting
the facility;
Paid vacation and sick leave; and
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• Contractor employees (maintenance, construction, etc. but excluding
contracted truck drivers and minor intermittent service vendors (e.g., trash
handlers)).
In general, if an individual is employed or hired to work at the facility, all the
hours worked (including paid leave and overtime) by that individual for the facility should be
counted in determining if the 20,000-hour criterion has been met.
Example - Employee Equivalent Calculation
Your facility has six full-time employees working 2,000 hours/year. You also employ two full-time sales people
and a delivery truck driver (employed by the facility) who are assigned to the plant, each working 2,000
hours/year but predominantly on the road or from their homes. The wastewater treatment system (on site and
owned by the facility) is operated by a contractor who spends an average of two hours per day and five days per
week at the plant. Finally, you built an addition to the plant warehouse during the year, using four contractor
personnel who were on site full time for six months (working on average of 1,000 hours each). You would
calculate the number of full-time employee equivalents as follows:
• Hours for your nine full-time employees (six plant personnel, two salespeople, and one
delivery truck driver) are:
(9 employees) * (2,000 hours/year) = 18,000 hours/year;
• Hours for the wastewater treatment system operator are:
(2 hours/day) x (5 days/week) x (52 weeks/year) = 520 hours/year; and
• Hours for the construction crew are:
(4 contractors) x (1,000 hours) = 4,000 hours/year.
Your facility has a total of 22,520 hours for the year, which is above the 20,000 hours/year threshold; therefore,
you meet the employee criterion.
2.4 Manufacturing. Processing, and Otherwise Use of EPCRA Section 313
Chemicals or Chemical Categories
If you are in a covered SIC Code and have 10 or more full-time employee
equivalents, you must determine which EPCRA Section 313 chemicals and chemical categories
are manufactured, processed, or otherwise used at your facility. You should prepare a list which
includes all chemicals and chemical categories found in mixtures and trade name products at all
establishments at the facility. This list should then be compared to the CURRENT list of
EPCRA Section 313 chemicals and chemical categories found in the TRIForms and Instructions
document for that reporting year (also available from the EPCRA Hotline, 1-800-424-9346).
Once you identify the EPCRA Section 313 chemicals and chemical categories at your facility,
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you must evaluate the activities involving each chemical and chemical category and determine if
any activity thresholds have been met.
The original list of chemicals and chemical categories subject to EPCRA Section
313 reporting was a combination of lists from New Jersey and Maryland. Refinements to the list
have been made and changes are anticipated to continue. The list can be modified by U.S. EPA
initiatives or industry or the public can petition U.S. EPA to modify the list. When evaluating a
chemical or chemical category for addition or deletion from the list, U.S. EPA must consider the
chemical's potential acute human health effects, chronic human health effects, or its adverse
environmental effects. U.S. EPA reviews these petitions and initiates a rulemaking to add or
delete the chemical from the list, or publishes an explanation why it denied the petition.
Note that chemicals and chemical categories are periodically added, delisted, or
modified. Therefore, it is imperative that you refer to the appropriate reporting year's list. You
can refer to the U.S. EPA's TRI website, http://www.epa.gov/tri, for updated guidance. Also,
note that a list of synonyms for EPCRA Section 313 chemicals and chemical categories can be
found in the U.S. EPA publication Common Synonyms for Chemicals Listed Under Section 313
of the Emergency Planning and Community Right-To-Know Act (EPA 745-R-95-008). Table 2-3
lists the EPCRA Section 313 chemicals and chemical categories most frequently reported for
rubber and plastics manufacturing. This list is not intended to be all inclusive and should only be
used as a guide.
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Table 2-3
EPCRA Section 313 Chemicals and Chemical Categories Commonly
Encountered in Rubber and Plastics Manufacturing
(SIC Codes 2822, 301, 302, 305, 306, and 308)
CASRN
71-55-6
1717-00-6
106-99-00
7664-41-7
NA
NA
75-15-0
NA
7782-50-5
75-45-6
NA
NA
1163-19-5
117-81-7
75-09-2
111-42-2
NA
131-11-3
100-41-4
107-21-1
50-00-0
110-54-3
7647-01-0
NA
7439-92-1
NA
67-56-1
80-62-6
78-93-3
108-10-1
Chemicals
1,1,1 -Trichloroethane
1 , 1 -Dichloro- 1 -fluorethane
1,3 -Butadiene
Ammonia (anhydrous and 10% of
aqueous)
Antimony compounds
Barium compounds
Carbon Bisulfide
Certain Glycol ethers
Chlorine
Chlorodifluoromethane
Chromium compounds
Cobalt compounds
Decabromodiphenyl oxide
Di (2-Ethylhexyl) phthalate
Dichloromethane
Diethanolamine
Diisocyanates
Dimethyl phthalate
Ethyl benzene
Ethylene glycol
Formaldehyde
n-Hexane
Hydrochloric acid (acid aerosols)
Lead compounds
Lead
Manganese compounds
Methanol
Methyl methacrylate
Methyl ethyl ketone
Methyl isobutyl ketone
Process
Solvent
Flame Retardant
Monomer for Rubber Manufacturing
Reaction Product, Wastewater Treatment, Catalyst
Rubber and Plastic Product Compounding Additive,
Flame Retardant
Compounding Additive, Heat-Stabilizer
Coincidentally Manufactured
Process Oils, Lubricants
Water treatment, Waste Water Treatment, Surface
Glaze
Flame Retardant, Solvent
Compounding Additive
Polymerization Chemical Additive, Plastic Finishing
Chemical
Flame Retardant
Compounding Additive
Plastic Compounding Additive
Vulcanization Accelerator
Monomer, Plasticizer
Plastic Product Chemical
Plastic Compounding Additive
Monomer or Polymerization Reactant
Cord or Yarn Surface Coating Constituent, Fabric
Latex Coating, Coincidental Manufacture in Boilers
Solvent
Coincidentally Manufactured
Vulcanizing Agent/ Accelerator
Heat Stabilizer/Compounding Additive
Initiators
Typically Present in Solutions of Formaldehyde
Monomer
Carrier in Primer, Adhesives, and Paints
Carrier in Primer, Adhesives, and Paints Solvent
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Table 2-3 (Continued)
CASRN
NA
7697-37-2
108-95-2
100-42-5
7664-93-9
137-26-8
108-88-3
26471-62-5
584-84-9
91-08-7
79-01-6
1330-20-7
NA
Chemicals
Nickel compounds
Nitric acid
Phenol
Styrene
Sulfuric acid (acid aerosols)
Thiram (tetramethyl thiuram disulfide)
Toluene
Toluene diisocyante (mixed isomers)
Toluene-2,4-diisocyanate
Toluene-2,6-diisocyanate
Trichloroethylene
Xylene (mixed isomers)
Zinc compounds
Process
Rubber Product Compounding Additive,
Polymerization Chemical Additive,
Wastewater Treatment
Finishing Chemical-Protective Agent, Compounding
Chemical Additive, Cleaning Agent
Monomer used in Rubber & Plastic Industry
Coincidentally Manufactured in Cooling Towers,
Storage Tanks, and Boiler Stacks
Accelerator in Rubber Compounding
Solution Polymerization Solvent
Monomer
Monomer
Monomer
Monomer
Solvent
Rubber Product Compounding Additive
Vulcanizing Agent/ Accelerator
2.5
Activity Categories
EPCRA Section 313 defines three activity categories for the listed chemicals and
chemical categories: manufacturing (which includes importing), processing, and otherwise use.
The activity thresholds are 25,000 pounds per year for manufacturing, 25,000 pounds per year for
processing, and 10,000 pounds per year for otherwise use1. These thresholds apply to each
chemical or chemical category individually. The quantity of chemicals or chemical categories
stored on site or purchased is not relevant for threshold determinations. Rather, the
determination is based solely on the annual quantity actually manufactured (including imported),
processed, or otherwise used. Therefore, EPCRA Section 313 chemicals and chemical categories
that are brought on site and stored, but are not prepared in the reporting year for distribution in
that year or subsequent years or are not otherwise used on site during the reporting year, are not
considered towards any activity threshold.
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Expanded definitions with examples of each of the three activities are found in
Chapter 3, Tables 3-2, 3-3, and 3-4. The terms are briefly defined in Table 2-4.
Table 2-4
Activity Categories
Activity
Category
Definition
Threshold1
(lbs/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical or
chemical category. Manufacture also applies to an EPCRA Section 313 chemical
that is produced coincidentally during the manufacture, processing, otherwise use,
or disposal of another chemical or mixture of chemicals as a byproduct, and an
EPCRA Section 313 chemical or chemical category that remains in that other
chemical or mixture of chemicals as an impurity during the manufacturing,
processing, or otherwise use or disposal of any other chemical substance or
mixture. An example would be the production of ammonia or nitrate compounds
in a wastewater treatment system.
25,000
Process
To prepare a listed EPCRA Section 313 chemical, or a mixture or trade name
product containing an EPCRA Section 313 chemical, for distribution in
commerce. For example, the addition of EPCRA Section 313 listed pigments to
paint should be reported if you exceeded the reporting threshold. Processing
includes the preparation for sale to your customers (and transferring between
facilities within your company) of a chemical or formulation that you manufacture.
For example, if you manufacture an EPCRA Section 313 chemical or chemical
category or product, package it, and then distribute it into commerce, this
chemical has been manufactured AND processed by your facility.
25,000
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
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Activity
Category
Definition
Threshold1
(lbs/yr)
Otherwise
Use
Generally, use of an EPCRA Section 313 chemical or chemical category that does
not fall under the manufacture or process definitions is classified as otherwise use
An EPCRA Section 313 chemical or chemical category that is otherwise used does
not function by being incorporated into a product that is distributed in commerce,
but may be used instead as a manufacturing or processing aid (e.g., catalyst), in
waste processing, or as a fuel (including waste fuel). For example, xylene used as
a carrier solvent for paint is classified as otherwise used.
OnMay 1, 1997 U.S. EPA revised the interpretation of otherwise use. The
following new otherwise use definition became effective with the 1998 reporting
year (62 FR 23834, May 1, 1997):
Otherwise use means "any use of a toxic chemical contained in a mixture
or other trade name product or waste, that is not covered by the terms
manufacture or process. Otherwise use of a toxic chemical does not
include disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction unless:
1) The toxic chemical that was disposed, stabilized, or treated for
destruction was received from off site for the purposes of further waste
management; OR
2) The toxic chemical that was disposed, stabilized, or treated for
destruction was manufactured as a result of waste management activities
on materials received from off site for the purposes of further waste
management activities."
10,000
'These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT
chemicals.
COMMON ERROR - Coincidental Manufacture
The coincidental manufacture of an EPCRA Section 313 chemical or chemical category, outside the primary
product process line but in direct support of the process, is frequently overlooked. For example, a tire
manufacturer (SIC Code 3011) uses steam heated pressure vessels for the vulcanization process. These vessels
use large quantities of steam which is generated on site by a coal-fired steam plant. The burning of coal will
potentially result in the coincidental manufacture of several EPCRA Section 313 chemicals including the aerosol
forms of sulfuric and hydrochloric acid, metal compounds, and formaldehyde. The amount of each coincidentally
manufactured EPCRA Section 313 chemical or chemical category must be included in any threshold
determinations and, if a threshold is exceeded, any subsequent release and other waste management activity
quantity calculations.
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COMMON ERROR - Definition of "Compounding"
Do not include rubber or plastic compounding in the manufacturing threshold determination. The EPCRA
Section 313 definition of manufacture includes the term compounding. Compounding is defined, for the purpose
of EPCRA Section 313 reporting, as generation of an EPCRA Section 313 chemical, not the mixing of EPCRA
Section 313 chemicals to form a new product. This may be different than compounding as typically used in
rubber and plastic manufacturing where it is usually a type of mixing operation. The mixing of an EPCRA
Section 313 chemical to form a new product is considered processing if the chemical remains as part of the
product or otherwise used if the chemical does not intentionally remain as part of the product.
For example, plastic pellets containing the EPCRA Section 313 listed monomer styrene (CAS Registry No. 100-
42-5) are compounded with various additives at a plastic product manufacturing facility. Because the styrene
remains with the product, it is considered processed. The addition of a cobalt catalyst to the compounding
operation would be defined as otherwise use, because the catalyst does not intentionally remain with the product.
Example - Treatment of Wastes from Off Site
A covered facility receives a waste containing 12,000 pounds of Chemical A, an EPCRA Section 313 chemical,
from off site. The facility treats the waste, destroying Chemical A and in the treatment process manufactures
10,500 pounds of Chemical B, another EPCRA Section 313 chemical. Chemical B is disposed on site.
Since the waste was received from off site for the purpose of waste management, the amount of Chemical A must
be included in the otherwise use threshold determination for Chemical A. The otherwise use threshold is 10,000
pounds and since the amount of Chemical A exceeds this threshold, all release and other waste management
activities for Chemical A must be reported.
Chemical B was manufactured in the treatment of a waste received from off site. Accordingly, the quantity of
chemical B should be counted towards the manufacturing threshold. However, the facility disposed of Chemical
B on site and "otherwise use" of a toxic chemical includes disposal, stabilization (without subsequent distribution
in commerce) or treatment for destruction if the toxic chemical that was disposed, stabilized, or treated for
destruction was manufactured as a result of waste management activities on materials received from off site for
the purposes of further waste management activities. Therefore, the amount of Chemical B must also be
considered in the otherwise use threshold determination. Thus, at 10,500 pounds, the otherwise use reporting
threshold for Chemical B has been exceeded and all release and other waste management activities for Chemical
B must be reported.
Relabeling or redistribution of an EPCRA Section 313 chemical or chemical
category where no repackaging occurs does not constitute manufacturing, processing, or
otherwise use of that chemical. This type of activity should not be included in threshold
determinations.
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Examle - Relabelin
You buy a mixture in small containers that contains an EPCRA Section 313 chemical. When it arrives you put
your own label on each container, put the containers in a larger box with several other items you manufacture, and
sell the larger box as a kit. The quantity of the EPCRA Section 313 chemical in the small containers should not
be counted toward the processing threshold (because you did not repackage the chemical) or the otherwise use
threshold, nor should it be counted toward the manufacturing activity threshold unless the small containers were
imported. However, you must consider other EPCRA Section 313 chemicals that you manufactured in the kit
imported. However, you must consider other EPCRA Section 3
toward manufacturing and processing threshold determinations.
Also, note that the threshold determinations for the three activity categories
(manufacturing, processing, and otherwise use) are mutually exclusive. That is, you must
conduct a separate threshold determination for each activity category and if you exceed any
threshold, all release and other waste management activities of that EPCRA Section 313
chemical or chemical category at the facility must be considered for reporting.
2.6 Persistent. Bioaccumulative., and Toxic (PBT) Chemicals
U.S. EPA promulgated the final rule for Persistent, Bioaccumulative, and Toxic
(PBT) chemicals in the October 29, 1999 Federal Register (64 FR 209). This rule applies for the
reporting year beginning January 1, 2000 (for EPCRA Section 313 reports that must be filed by
July 1, 2001).
In this rule, U.S. EPA has added seven chemicals and lowered the reporting
thresholds for 18 chemicals and chemical categories that meet the EPCRA Section 313 criteria
for persistence and bioaccumulation. The PBT chemicals and their thresholds are listed in Table
2-5.
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Table 2-5
Reporting Thresholds for EPCRA Section 313 Listed PBT Chemicals
Chemical Name or Chemical Category
Aldrin
Benzo(g,h,i)perylene
Chlordane
Dioxin and dioxin-like compounds category
(manufacturing; and the processing or otherwise
use of dioxin and dioxin-like compounds if the
dioxin and dioxin-like compounds are present as
contaminants in a chemical and if they were
created during the manufacturing of that chemical)
Heptachlor
Hexachlorobenzene
Isodrin
Methoxychlor
Octachlorostyrene
Pendimethalin
Pentachlorobenzene
Polycyclic aromatic compounds category
Polychlorinated biphenyl (PCBs)
Tetrabromobisphenol A
Toxaphene
Trifluralin
Mercury
Mercury compounds
CASRN
309-00-2
191-24-2
57-74-9
NA
76-44-8
118-74-1
465-73-6
72-43-5
29082-74-4
40487-42-1
608-93-5
NA
1336-36-3
79-94-7
8001-35-2
1582-09-8
7439-97-6
NA
Section 313 Reporting Threshold (in
pounds unless noted other-wise)
100
10
10
0.1 grams
10
10
10
100
10
100
10
100
10
100
10
100
10
10
U.S. EPA also added two chemicals to the polycyclic aromatic compounds
(PACs) category that is listed above:
• Benzo(j,k)fluorene (fluoranthene)
• 3-methyl chloanthrene
These two chemicals are not to be reported individually; rather, they should be included within
the PACs compound category.
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U.S. EPA finalized two thresholds based on the chemicals' potential to persist and
bioaccumulate in the environment. The two levels include setting Section 313 manufacture,
process, and otherwise use thresholds to 100 pounds for PBT chemicals and to 10 pounds for that
subset of PBT chemicals that are highly persistent and highly bioaccumulative. One exception is
the dioxin and dioxin-like compounds category. EPA set the threshold for the dioxin and dioxin-
like compound category at 0.1 gram.
U.S. EPA eliminated the de minimis exemption for the PBT chemicals. However,
this action does not affect the applicability of the de minimis exemption to the supplier
notification requirements (40 CFR 372.45(d)(l)). U.S. EPA also excluded all PBT chemicals
from eligibility for the alternate threshold of 1 million pounds (see Section 2.9) and eliminated
range reporting of PBT chemicals and chemical categories for on-site releases and transfers off-
site for further waste management.
Concurrent with the additions and lowered thresholds discussed above, U.S. EPA
added "vanadium, except when contained in an alloy" and "vanadium compounds" to the list of
toxic chemicals subject to reporting under EPCRA Section 313. The corresponding thresholds
for vanadium and vanadium compounds remain 10,000 pounds if otherwise used, 25,000 pounds
if processed, and 25,000 pounds if manufactured. Please refer to the discussion on "Qualifiers"
in Section 3.1 if vanadium is a concern at your facility.
Note that U.S. EPA is currently developing five guidance documents for
chemicals modified by the PBT rule:
Dioxins and dioxin-like compounds;
Mercury and mercury compounds;
Vanadium and vanadium compounds;
Polycyclic aromatic compounds (PACs) category; and
Other PBT chemicals.
Please refer to this guidance if applicable to your facility.
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2.7 How Do You Report?
You must submit an EPCRA Section 313 report for each EPCRA Section 313
chemical or chemical category that exceeds a threshold for manufacturing, OR processing, OR
otherwise use (providing you meet the employee and SIC Code criteria). Provided you do not
exceed certain alternate activity thresholds and total annual reportable amounts, you may prepare
a Form A (See Section 2.9) rather than a Form R. The TRI Forms and Instructions contain
detailed directions for the preparation and submittal of EPCRA Section 313 reports for the
reporting year. The TRI Forms and Instructions are sent to all facilities that submitted EPCRA
Section 313 reports the preceding year. However, if you do not receive a courtesy copy, you may
request copies of the TRI Forms and Instructions from the EPCRA Hotline (1-800-424-9346).
2.8 FormR
Form R is the report in which the information required by EPCRA Section 313 is
reported. If you are submitting a Form R, it is essential that you use the TRI Forms and
Instructions for the appropriate reporting year. U.S. EPA encourages the electronic submittal of
the Form R, via the Automated Toxic Chemical Release Inventory Reporting Software (ATRS).
Use of the ATRS will save preparation time in data entry and photocopying and will reduce
errors via on-line validation routines and use of pick lists. The ATRS can be found on the
Internet at:
• http://www.epa.gov/atrs
The ATRS is available in both DOS and Windows versions. More information can be found in
the TRI Forms and Instructions and by calling the ATRS User Support Hotline at (703) 816-
4434.
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The Form R consists of two parts:
Part I. Facility Identification Information. This part may be photocopied and re-
used for each Form R you submit, except for the signature, which must be original
for each submission.
Part II. Chemical Specific Information. You must complete this part separately
for each EPCRA Section 313 chemical or chemical category; it cannot be reused
year to year even if reporting has not changed.
Submission of incomplete EPCRA Section 313 reports may result in issuance of a
Notice of Technical Error (NOTE), Notice of Significant Error (NOSE), or Notice of Non-
Compliance (NON). See the current TRI Forms and Instructions for more detailed information
on completing the Form R and submitting the EPCRA Section 313 report.
2.9 Alternate Threshold and Form A
U.S. EPA developed the Form A, also referred to as the "Certification Statement,"
to reduce the annual reporting burden for facilities with minimal amounts of EPCRA
Section 313 chemicals or chemical categories released and otherwise managed as waste (59 FR
61488, November 1994; applicable beginning reporting year 1994 and beyond). On Form A, you
certify that you are not required to report the release and other waste management information
required by EPCRA Section 313 and PPA Section 6607. A facility must meet the following two
criteria to use a Form A:
First, the total annual reportable amount of the EPCRA Section 313
chemical or chemical category manufactured, processed, OR otherwise
used cannot exceed 500 pounds per year. The "reportable amount" is
defined as the sum of the on-site amounts released (including disposal),
treated, recycled, and combusted for energy recovery, combined with the
sum of the amounts transferred off site for recycling, energy recovery,
treatment, and/or release (including disposal). This total corresponds to
the total of data elements 8.1 through 8.7 on the 1999 version of the
Form R.
Second, the amount of the EPCRA Section 313 chemical cannot exceed
one million pounds. It is important to note that the quantities for each
activity are mutually exclusive and must be evaluated independently. If
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the quantity for any one of the activities exceeds 1,000,000 pounds a
Form A cannot be used.
Example - Form A Threshold
If the combined annual reportable amounts from all activities does not exceed 500 pounds, a facility that
manufactures 900,000 pounds of anEPCRA Section 313 chemical and processes 150,000 pounds of the same
chemical is eligible to use the Form A because the facility did not exceed the one million pound threshold for
either activity, even though the total activity usage exceeds one million pounds.
The Form A Certification Statement must be submitted for each eligible EPCRA
Section 313 chemical or chemical category. The information on the Form A will be included in
the publicly accessible TRI database; however, these data are marked to indicate that they
represent certification statements rather than Form Rs. Note that separate establishments at a
facility cannot submit separate Form As for the same chemical or chemical category; rather, only
one Form A per EPCRA Section 313 chemical or chemical category can be submitted per
facility.
While Form A requests facility identification and chemical identification
information, no release and other waste management quantity estimations to any media are
required. You must simply certify that the total annual reportable amount did not exceed 500
pounds and that amounts manufactured, processed, or otherwise used did not exceed one million
pounds. Once the facility has completed estimates to justify the submission of a Form A, there is
a considerable time savings in using the Form A, especially in subsequent years providing
activities involving the chemical or chemical category did not change significantly. It is strongly
recommended that you document your initial rationale and refer to it every year to verify you
have not modified a part of the process that would invalidate the initial rationale supporting
submission of a Form A.
2.10 Trade Secrets
If you submit trade secret information, you must prepare two versions of the
substantiation form as prescribed in 40 CFR Part 350 (see 53 FR 28801, July 29, 1988) as well as
two versions of the EPCRA Section 313 report. One set of reports should be "sanitized" (i.e., it
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should provide a generic name for the EPCRA Section 313 chemical or chemical category
identity). This version will be made available to the public. The second version, the
"unsanitized" version, should provide the actual identity of the EPCRA Section 313 chemical or
chemical category and have the trade secret claim clearly marked in Part I, Section 2.1 of the
Form R or Form A. The trade secrets provision only applies to the EPCRA Section 313 chemical
and chemical category identity. All other parts of the Form R or Form A must be filled out
accordingly.
Individual states may have additional criteria for confidential business information
and the submittal of both sanitized and unsanitized reports for EPCRA Section 313 chemicals
and chemical categories. Facilities may jeopardize the trade secret status of an EPCRA Section
313 chemical or chemical category by submitting an unsanitized version to a state agency or
tribal government that does not require an unsanitized version.
More information on trade secret claims, including contacts for individual state's
submission requirements, can be found in the TRI Forms and Instructions.
2.11 Recordkeeping
Complete and accurate records are absolutely essential to meaningful compliance
with EPCRA Section 313 reporting requirements. Compiling and maintaining good records will
help you to reduce the effort and cost in preparing future reports, and to document how you
arrived at the reported data in the event of U.S. EPA compliance audits. U.S. EPA requires you
to maintain records substantiating each EPCRA Section 313 report submission for a minimum of
three years. Each facility must keep copies of every EPCRA Section 313 report along with all
supporting documents, calculations, work sheets, and other forms that you used to prepare the
EPCRA Section 313 report. U.S. EPA may request this supporting documentation during a
regulatory audit.
Specifically, U.S. EPA requires the following records be maintained for a period
of three years from the date of the submission of a report (summarized from 40 CFR 372.10):
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1) A copy of each EPCRA Section 313 report that is submitted.
2) All supporting materials and documentation used to make the compliance
determination that the facility or establishment is a covered facility.
3) Documentation supporting the report submitted, including:
• Claimed allowable exemptions,
• Threshold determinations,
• Calculations for each quantity reported as being released, either on
or off site, or otherwise managed as waste,
• Activity determinations, including dates of manufacturing,
processing, or use,
• The basis of all estimates,
• Receipts or manifests associated with transfers of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
4) For facilities submitting a Form A, all supporting materials used to make
the compliance determination that the facility or establishment is eligible
to submit a Form A, including:
• Data supporting the determination the alternate threshold applies,
• Calculations of annual reportable amounts, and
• Receipts or manifests associated with the transfer of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
Because EPCRA Section 313 reporting does not require additional testing or
monitoring you must determine the best readily available source of information for all estimates.
Some facilities may have detailed monitoring data and off-site transfer records that can be used
for estimates while others may only have purchase and inventory records. Examples of records
that you should keep, if applicable, might include:
Each EPCRA Section 313 report submitted;
EPCRA Section 313 Reporting Threshold Worksheets (sample worksheets
can be found in Chapter 3 of this document as well as in the TRI Forms
and Instructions);
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EPCRA Section 313 Reporting Release and Other Waste Management
Quantity Estimation Worksheets (sample worksheets can be found in
Chapter 4 of this document);
Engineering calculations and other notes;
Formulation sheets;
Purchase records from suppliers;
Inventory data;
Material Safety Data Sheets (MSDS);
New Source Performance Standards (NSPS);
National Pollutant Discharge Elimination System (NPDES)/State Pollutant
Discharge Elimination System (SPDES) permits and monitoring reports;
EPCRA Section 312, Tier II reports;
Monitoring records;
Air permits;
Flow measurement data;
Resource Conservation Recovery Act (RCRA) hazardous waste
generator's reports;
Pretreatment reports filed with local governments;
Invoices from waste management firms;
Manufacturer's estimates of treatment efficiencies;
Comprehensive Environmental Response, Conservation, and Liability Act
of 1980 (CERCLA) Reportable Quantity (RQ) reports;
RCRA manifests; and
Process flow diagrams (including emissions, releases, and other waste
management activities).
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CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR
CHEMICAL CATEGORY ACTIVITY THRESHOLD DETERMINATIONS
3.0 PURPOSE
This chapter provides a step-by-step procedure for determining if any EPCRA
Section 313 chemicals or chemical categories exceed a reporting threshold. Threshold
determinations are essentially a three-step process:
Step 1) Identify any EPCRA Section 313 chemicals and chemical
categories you manufacture/import, process, or otherwise use.
Step 2) Identify the activity category and any exempt activities for each
EPCRA Section 313 chemical or chemical category.
Step 3) Calculate the quantity of each EPCRA Section 313 chemical or
chemical category and determine which ones exceed an activity
threshold.
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported). Processed, or Otherwise
Used
Compile lists of all chemicals and mixtures at your facility. For facilities with
many different chemicals and mixtures it is often helpful to prepare two lists: one with the pure
(single ingredient) chemicals (including chemical compounds) and one with the mixtures and
trade name products. On the second list, under the name of each mixture/trade name product,
write the names of all chemicals in that product. Next, compare the chemicals and chemical
categories on both lists to the current EPCRA Section 313 chemicals and chemical categories list
found in the TRI Forms and Instructions (remember that chemicals and chemical categories may
be periodically added and deleted and you should use the current reporting year's instructions).
Highlight the EPCRA Section 313 chemicals and chemical categories that are on your lists.
Review the lists to be sure each chemical and chemical category is shown by its
correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical
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found in rubber and plastics manufacturing operations is toluene. Toluene (Chemical Abstracts
Service (CAS) Registry No. 108-88-3) has several synonyms including methylbenzene,
methylbenzol, phenylmethane, and toluol. It must be reported on Form R (or Form A), Item 1.2,
by its EPCRA Section 313 chemical name, toluene. Synonyms can be found in the U.S. EPA
document Common Synonyms for Chemicals Listed Under Section 313 of the Emergency
Planning and Community Right-to-Know Act (EPA 745-R-95-008).
While you must consider every chemical on the EPCRA Section 313 chemical
and chemical category list, you should be aware of the chemicals and chemical categories
typically used in rubber and plastics manufacturing. As a guide, the most frequently reported
EPCRA Section 313 chemicals and chemical categories for reporting year 1995 by rubber and
plastics manufacturing facilities, SIC Codes 301, 302, 305, 306, and 308, and the processes they
are typically used in, are listed in Table 2-3.
COMMON ERROR - Vinvl Chloride
Vinyl chloride (CAS Registry No. 75-01-4) is an EPCRA Section 313 reportable chemical. Polyvinyl chloride is
a polymer of vinyl chloride but it is NOT an EPCRA Section 313 reportable chemical. However, any unreacted
vinyl chloride monomer mixed with the polymerized material, in excess of the 0.1% de minimis concentration,
must be included in activity threshold determinations.
A computerized spreadsheet may be helpful in developing your facility's chemical
and chemical category list and performing threshold calculations. The spreadsheet could show
the chemical, chemical category, or chemical mixture with corresponding component
concentrations; the yearly quantity manufactured, processed, or otherwise used; and the CAS
Registry number. The spreadsheet could also be designed to identify the total quantity by activity
category (amounts manufactured, processed, and otherwise used) for each EPCRA Section 313
chemical or chemical category in every mixture, compound, and trade name product.
An initial investment of time will be required to develop this spreadsheet;
however, the time and effort saved in threshold calculations in subsequent years will be
significant. Such a system will also reduce the potential of inadvertently overlooking EPCRA
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Section 313 chemicals or chemical categories present in mixtures purchased from off-site
sources.
To develop the chemical and chemical category list and the associated activity
categories you may want to consult the following:
Material Safety Data Sheets (MSDSs);
• Facility purchasing records;
• New Source Performance Standards (NSPS);
• Inventory records;
• Air and water discharge permits;
• Individual manufacturing/operating functions; and
• Receipts of manifests associated with the transfer of each EPCRA Section
313 chemical and chemical category in waste to off-site locations.
The following is suggested useful information needed to prepare your EPCRA
Section 313 reports and should be included for each chemical and chemical category on your
spreadsheet:
• The mixture name and associated EPCRA Section 313 chemical and
chemical category names;
• The associated Chemical Abstract Service (CAS) Registry numbers;
• The trade name for mixtures and compounds;
• The throughput quantities; and
• Whether the chemical or chemical category is manufactured, processed, or
otherwise used at the facility (be sure to include quantities that are
coincidentally manufactured and imported, as appropriate).
MSDSs provide important information for the type and composition of chemicals
and chemical categories in mixtures, and for determining whether you have purchased raw
materials that contain EPCRA Section 313 chemicals and chemical categories. As of 1989,
chemical suppliers to facilities in SIC Major Group Codes 20 through 39 are required to notify
manufacturing customers of any EPCRA Section 313 chemicals and chemical categories present
in mixtures or trade name products distributed to facilities. The notice must be provided to the
receiving facility and may be attached or incorporated into that product's MSDS. If no MSDS is
required, the notification must be in a letter that accompanies the first shipment of the product to
your facility each year. This letter must contain the chemical name, CAS Registry number, and
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the weight or volume percent (or a range) of the EPCRA Section 313 chemical or chemical
category in mixtures or trade name products.
Carefully review the entire MSDS. Although new MSDSs must list whether
EPCRA Section 313 chemicals and chemical categories are present, the language and location of
this notification is not currently standardized. Depending on the supplier, this information could
be found in different sections of the MSDS. The most likely sections of an MSDS to provide
information on EPCRA Section 313 chemicals and chemical categories are:
Physical properties/chemical composition section;
Regulatory section;
Hazardous components section;
Labeling section; and
Additional information section.
Also, many EPCRA Section 313 chemicals or chemical categories are present as
impurities in mixtures. These quantities must also be considered in threshold determinations
unless the concentration is below the de minimis value (see Section 3.2.2.1).
COMMON ERROR - Mixture Components
Facilities often overlook EPCRA Section 313 chemicals that are present in small quantities of bulk solutions. For
example, a common chemical used in rubber and plastics manufacturing is xylene. Xylene is often purchased in
large quantities for use as a solvent, among other things. Most facilities correctly report for xylene; however,
ethylbenzene is typically present at up to 15% in solutions of xylene commercially available. Many facilities have
historically overlooked the ethylbenzene in their bulk xylene purchases.
Qualifiers
Several chemicals on the EPCRA Section 313 chemical and chemical category list
include qualifiers related to use or form. Some chemicals are reportable ONLY if manufactured
by a specified process or classified in a specified activity category. For example, isopropyl
alcohol is only reportable if it is manufactured using the strong acid process and saccharin is
reportable only if it is manufactured. Some other chemicals are only reportable if present in
certain forms. For example, only yellow or white phosphorus is reportable, while black or red
phosphorus is not reportable.
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The qualifiers and associated chemicals and chemical categories are presented
below. Please make special note of the discussion pertaining to vanadium and vanadium
compounds.
• Aluminum oxide (fibrous) - Aluminum oxide is only subject to threshold
determination and release and other waste management calculations when
it is handled in fibrous forms. U.S. EPA has characterized fibrous
aluminum oxide for purposes of EPCRA Section 313 reporting as a man-
made fiber commonly used in high-temperature insulation applications
such as furnace linings, filtration, gaskets, joints, and seals.
• Ammonia - (includes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources) On June 26, 1995,
U.S. EPA qualified the listing for ammonia (CAS Registry No. 7664-41-7)
and deleted ammonium sulfate (solution) (CAS Registry No. 7783-20-2)
from the EPCRA Section 313 chemical list. Both the qualification and the
deletion were effective as of reporting year 1994. The qualifier for
ammonia means that anhydrous forms of ammonia are 100% reportable
while only 10% of the total aqueous ammonia is reportable. Any
evaporation of ammonia from aqueous ammonia solutions is considered
anhydrous ammonia. This qualifier applies to both activity threshold
determinations and release and other waste management calculations.
Note that while ammonium sulfate is no longer an EPCRA Section 313
chemical, 10% of the aqueous ammonia formed from the dissociation of
ammonium sulfate (and all other ammonium salts) is reportable, and must
be included in both activity threshold determinations and release and other
waste management calculations. Additionally, any ammonium nitrate
must also be included in the threshold determination and the nitrate
portion included in the release and other waste management calculations,
for the nitrate compounds category. U.S. EPA has published guidance on
reporting for ammonia and ammonium salts in Emergency Planning and
Community Right-to-Know, EPCRA Section 313, Guidance for Reporting
Aqueous Ammonia, EPA 745-R-95-012 (see Appendix D).
• Asbestos (friable) - Asbestos only needs to be considered when it is
handled in the friable form. Friable refers to the physical characteristics of
being able to crumble, pulverize, or reduce to a powder with hand
pressure. Please refer to EPCRA Section 313 Questions and Answers,
Revised 1998 Version (EPA 745-B-98-004) for more information on
asbestos, if applicable.
• Fume or dust - Two metals (aluminum and zinc) are qualified with "fume
or dust." This definition excludes "wet" forms such as solutions or
slurries, but includes powder, particulate, or gaseous forms of these
metals. There is no particle size limitation for particulates. For example,
use of zinc metal as a paint component is not subject to reporting unless
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the zinc is in the form of a fume or dust. However, even though elemental
zinc is reportable only in the fume or dust form, all forms of zinc
compounds are reportable. Note that the entire weight of all zinc
compounds should be included in the threshold determination for zinc
compounds, while only the metal portion of metal compounds is reported
in the release and other waste management amounts. Prior to reporting
year 2000, vanadium was also qualified with "fume or dust." As of
reporting year 2000 the qualifier has been removed for vanadium such that
all physical forms are now reportable unless the vanadium is contained in
an alloy. Please see the discussion on vanadium and vanadium
compounds below, if applicable.
Hydrochloric acid (acid aerosols) - On July 25, 1996, US EPA
promulgated a final rule delisting non-aerosol forms of hydrochloric acid
(CAS Registry No. 7647-01-0) from the EPCRA Section 313 chemical list
(effective for the 1995 reporting year). Therefore, threshold
determinations and release and other waste management estimates now
apply only to the aerosol forms. Under EPCRA Section 313, the term
aerosol covers any generation of airborne acid (including mists, vapors,
gas, or fog) without any particle size limitation. Therefore, any process
that sprays hydrochloric acid "manufactures" hydrochloric acid aerosol
and should include this quantity in the manufacturing threshold
determination.
Manufacturing qualifiers - Two chemicals, saccharin and isopropyl
alcohol, contain qualifiers relating to manufacture. The qualifier for
saccharin means that only manufacturers of the chemical are subject to the
reporting requirement. The qualifier for isopropyl alcohol means that only
facilities that manufacture the chemical by the strong acid process are
required to report. Facilities that only process or otherwise use these
chemicals are not required to report. Thus, a facility that uses isopropyl
alcohol as a solvent should not report for isopropyl alcohol.
Nitrate Compounds (water dissociable; reportable only in aqueous
solution) - A nitrate compound is covered by this listing only when in
water and if water dissociable. Although the complete weight of the
nitrate compound must be used for threshold determinations for the nitrate
compounds category, only the nitrate portion of the compound must be
considered for release and other waste management calculations. One
issue recently raised by industry is how to report nitrate compounds in
wastewater and sludge that is applied to farms as a nitrogen source (either
on site or off site). Although during such use, nitrate compounds may be
taken up by plants and cycled back into the ecosystem, U.S. EPA
considers the nitrate compounds in wastewater/sludge to be managed as
waste. In this scenario, nitrate compounds should be reported as being
disposed to land (either on site or off site as appropriate). U.S. EPA has
published guidance for these chemicals in List of Toxic Chemicals Within
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the Water Dissociable Nitrate Compounds Category and Guidance for
Reporting, EPA 745-R-96-004 (see Appendix C).
Phosphorus (yellow or white) - Only manufacturing, processing, or
otherwise use of phosphorus in the yellow or white chemical forms require
reporting. Black and red phosphorus are not subject to EPCRA
Section 313 reporting.
Sulfuric acid (acid aerosols) - On June 26, 1995, U.S. EPA promulgated
a final rule delisting non-aerosol forms of sulfuric acid (CAS Registry No.
7664-93-9) from the EPCRA Section 313 toxic chemical list (effective for
the 1994 reporting year). Therefore, threshold determinations and release
and other waste management estimates now apply only to the aerosol
forms. Under EPCRA Section 313, the term aerosol covers any generation
of airborne acid (including mists, vapors, gas, or fog) without any particle
size limitation. Therefore, any process that sprays sulfuric acid
"manufactures" sulfuric acid aerosol and should include this quantity in
the manufacturing threshold determination. U.S. EPA has published
guidance for acid aerosols in Guidance for Reporting Sulfuric Acid, EPA
745-R-97-007.
Vanadium and vanadium compounds - Note that prior to reporting year
2000 (December 31, 1999 for EPCRA Section 313 reports that must be
filed by July 1, 2001), the fume or dust qualifier also applied to vanadium.
As of December 31, 1999, U.S. EPA removed this qualifier for vanadium
for reporting year 2000 and beyond. Concurrently, U.S. EPA exempted all
physical forms of metallic vanadium that are present in alloys. Therefore,
vanadium that is present in any physical forms of alloys should not be
considered for EPCRA Section 313 reporting. However, if vanadium is
separated from the alloy, all physical forms of the vanadium are
considered to be manufactured and the quantity manufactured should be
applied to the 25,000-pound manufacturing threshold. Jf the vanadium is
subsequently processed or otherwise used, the applicable quantity should
also be applied to the processing or otherwise use threshold(s). If a
threshold is exceeded, all quantities released or otherwise managed as
waste must be reported as appropriate.
Concurrent with this rulemaking, U.S. EPA also added vanadium
compounds to the list of toxic chemicals subject to reporting under
EPCRA Section 313. U.S. EPA specifically excluded vanadium
compounds from the fume or dust qualifier and from the alloy exemption.
Therefore, all physical forms of vanadium compounds must be included in
threshold determinations and release and other waste management
activities estimates.
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3.2 Step 2. Identify the Activity Category and Any Exempt Activities for Each
EPCRA Section 313 Chemical and Chemical Category
The next step is to determine the activity category (or categories) and any exempt
activities for each EPCRA Section 313 chemical and chemical category on your list. Table 3-1
lists the reporting thresholds for each of these activity categories (Tables 3-2 through 3-4 provide
detailed definitions of subcategories for each activity category). Each threshold must be
individually calculated; they are mutually exclusive and are not additive.
Table 3-1
Reporting Thresholds
Activity Category
Manufacturing (including importing)
Processing
Otherwise Used
Threshold2
25,000 pounds per year
25,000 pounds per year
10,000 pounds per year
2These reporting thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds
applicable to PBT chemicals.
Example -Threshold Determination
If your facility manufactures 22,000 pounds of an EPCRA Section 313 chemical and you also otherwise use
8,000 pounds of the same chemical, you have not exceeded either threshold and an EPCRA Section 313 report for
that chemical is not required. However, if your facility manufactures 28,000 pounds per year of an EPCRA
Section 313 chemical and otherwise uses 8,000 pounds of the same chemical, you have exceeded the
manufacturing threshold and ALL release and other waste management quantities (except those specifically
exempted) of that chemical must be reported on the Form R, including those from the otherwise use activity.
Each of the activity categories is divided into subcategories. As discussed in the
TRI Forms and Instructions, you are required to designate EACH category and subcategory that
applies to your facility. Detailed definitions, including descriptions of subcategories for each
activity and examples, are presented in Tables 3-2, 3-3, and 3-4.
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Table 3-2
Definitions and Examples of Manufacturing Subcategories
Manufacturing Activity
Subcategory
Definition
Examples in Rubber and
Plastics Manufacturing*
Produced or imported for
on-site use/processing
A chemical or chemical category that is produced
or imported and then further processed or
otherwise used at the same facility.
Import of monomers or
additives for rubber/plastic
manufacturing
Produced or imported for
sale/distribution
A chemical or chemical category that is produced
or imported specifically for sale or distribution
outside the manufacturing facility.
Produced as a byproduct
A chemical or chemical category that is produced
coincidentally during the production, processing,
or otherwise use of another chemical substance or
a mixture and is separated from that substance or
mixture. EPCRA Section 313 chemicals or
chemical categories produced and released as a
result of waste treatment or disposal are also
considered byproducts.
Chemicals coincidentally
manufactured during
vulcanization (e.g., carbon
disulfide)
Generation of sulfuric acid
and hydrochloric acid
aerosols
Produced as an impurity
A chemical or chemical category that is produced
coincidentally as a result of the manufacture,
processing, or otherwise use of another chemical
and remains primarily in the mixture or product
with that other chemical.
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
COMMON ERROR - Overlooking Coincidental Manufacturing
Twenty-three facilities in SIC Major Group 30 were surveyed for The 1994 and 1995 Toxic Release Inventory
Data Quality Report, EPA 745-R-98-002. The activity classification for EPCRA Section 313 chemicals by these
facilities was almost evenly split between processing and otherwise used with no manufacturing of EPCRA
Section 313 chemicals reported. However, facilities that burn large amounts of fossil fuels should be careful to
not overlook the coincidental manufacturing of combustion products such as polycyclic aromatic hydrocarbons,
sulfuric acid aerosols, and metal compounds that may result from such activities.
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Table 3-3
Definitions and Examples of Processing Subcategories
Processing Activity
Subcategory
Definition
Examples in Rubber and
Plastics Manufacturing*
Reactant
A natural or synthetic chemical or chemical
category used in chemical reactions for the
manufacture of another chemical substance or
product. Examples include feedstocks, raw
materials, intermediates, and initiators.
Initiators and Accelerators:
Formulation component
A chemical or chemical category that is added to a
product or product mixture prior to further
distribution of the product and acts as a
performance enhancer during use of the product.
Examples include additives, dyes, reaction
diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame
retardants, and rheological modifiers.
Initiators:
Monomers: styrene,
ethylene glycol, 1-3-
butadiene
Flame Retardants:
antimony oxide
Article component
A chemical or chemical category that becomes an
integral component of an article distributed for
industrial, trade, or consumer use.
Heat Stabilizers: zinc, lead,
barium-cadmium
compounds
Repackaging only
A chemical or chemical category that is processed
or prepared for distribution in commerce in a
different form, state, or quantity. May include, but
is not limited to, the transfer of material from a
bulk container, such as a tank truck, to smaller
containers such as cans or bottles.
Preparation of repair kits for
conveyor belts
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Example - Packing Foam
A manufacturing facility, which meets the SIC Code and equivalent number of employees criteria for EPCRA
Section 313 reporting, buys methylene bis(phenylisocyanate) (MDI) (CAS Registry No. 101-68-8), a member of
the EPCRA Section 313 diisocyanates chemical category, to use as an ingredient in making packing foam. The
MDI is blown into a foam and used as packing material in shipping containers to protect delicate items from
damage during transportation from the manufacturing facility to the customers. The amount of MDI used for this
purpose must be included in the processing threshold determination as it is incorporated into a product that is
distributed in commerce.
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Example - Chemical Mixtures
A tennis ball manufacturer, SIC Code 3949, purchases natural and synthetic rubber in slabs and adds chemicals to
achieve the desired properties. The purchased rubber is considered to be a mixture for EPCRA Section 313
reporting and any EPCRA Section 313 chemicals in the rubber mixture must be included in the processing
threshold determination, providing their concentrations are above the de minimis concentration limits. The
amount of any such chemicals can be estimated by multiplying the weight percent of the chemical by the total
weight of the rubber mixture. Likewise, any EPCPxA Section 313 chemicals added on site must be included in the
processing activity threshold determination.
Table 3-4
Definitions and Examples of Otherwise Use Subcategories
Otherwise Use Activity
Subcategory
Definition
Examples in Rubber and
Plastics Manufacturing*
Chemical processing aid
A chemical or chemical category that is added to a
reaction mixture to aid in the manufacture or
synthesis of another chemical substance but is not
intended to remain in or become part of the
product or product mixture. Examples include
process solvents, catalysts, inhibitors, initiators,
reaction terminators, and solution buffers.
Catalysts: cobalt
compounds, nickel
compounds
Solvents: n-hexane,
toluene, cyclohexane
Product Cleaning Agents:
phenol
Manufacturing aid
A chemical or chemical category that aids the
manufacturing process but does not become part of
the resulting product and is not added to the
reaction mixture during the manufacture or
synthesis of another chemical substance. Examples
include process lubricants, metalworking fluids,
coolants, refrigerants, and hydraulic fluids.
Glycol ethers, hexane
Ancillary or other use
A chemical or chemical category that is used for
purposes other than aiding chemical processing or
manufacturing. Examples include cleaners,
degreasers, lubricants, fuels (including waste
fuels), and chemicals used for treating wastes.
Glycol ethers
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Example - Chemical Processing Aid
A plastics parts manufacturing facility performs spray painting using toluene as the carrier solvent. Ideally all the
solvent would evaporate; however, studies have shown 1% of the applied solvent remains on the product. Since
the function of the solvent is to improve the application of the paint and is a non-incorporative activity, the entire
amount of toluene is considered otherwise used. If the solvent's function was such that it was intended to remain
with the product, it would be considered processed, as is the case for pigments, binders, and other paint
components intended to remain with the product.
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3.2.1 Concentration Ranges for Threshold Determination
You should use the best readily available information or where such data are not
available, reasonable estimates, for all calculations in EPCRA Section 313 reporting; however,
the exact concentration of an EPCRA Section 313 chemical or chemical category in a mixture or
trade name product may not be known. The supplier or MSDS may only list ranges, or upper or
lower bound concentrations. U.S. EPA has developed guidance on how to use information in
this situation for threshold determinations.
• If the concentration is provided as a lower and upper bound or as a range,
you should use the mid-point in your calculations for the threshold
determination. For example, the MSDS for the trade name product states
methanol is present in a concentration of not less than 20% and not more
than 40%, or it may be stated as present at a concentration between 20 to
40%. You should use the mid-point value of 30% methanol in your
threshold calculations.
• If only the lower bound concentration of the EPCRA Section 313 chemical
or chemical category is specified and the concentration of other
components are given, subtract the other component values from 100%.
The remainder should be considered the upper bound for the EPCRA
Section 313 chemical or chemical category and you should use the given
lower bound to calculate the mid-point as discussed above. For example,
the MSDS states that a solvent contains at least 50% methyl ethyl ketone
(MEK) and 20% non-hazardous surfactants. Subtracting the
non-hazardous contents from 100% leaves 80% as the upper bound for
MEK. The mid-point between upper (80%) and lower (50%) bounds is
65%, the value you should use in your threshold calculation.
• If only the lower bound is specified and no information on other
components is given, you should assume the upper bound is 100% and
calculate the mid-point as above.
• If only the upper bound concentration is provided, you should use this
value in your threshold calculation.
Special guidance for concentration ranges that straddle the de minimis value is presented in
Section 3.2.2.1.
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3.2.2 Evaluation of Exemptions
When determining thresholds, you can exclude quantities of any EPCRA
Section 313 chemicals and chemical categories that are manufactured, processed, or otherwise
used in exempt activities. Exemptions are divided into four classes:
1. De minimis exemption;
2. Article exemption;
3. Facility-related exemption; and
4. Activity-related exemptions.
COMMON ERROR - Exempt Activities
If an EPCRA Section 313 chemical or chemical category is used in exempt activities, the quantity used in these
activities does not need to be included in your threshold determinations or release and other waste management
calculations, even if the chemical or chemical category is used in a reportable activity elsewhere in the facility.
3.2.2.1 De Minimis Exemption
If the amount of EPCRA Section 313 chemical(s) or chemical categories present
in a mixture or trade name product processed or otherwise used is below its de minimis
concentration level, that amount is considered to be exempt from threshold determinations and
release and other waste management calculations. Note that this exemption does not apply to
manufacturing, except for importation or as an impurity as discussed below. Also note that the
de minimis exemption does not apply to the manufacturing, processing, or otherwise use of the
PBT chemicals (refer to Section 2.6). The de minimis concentration for EPCRA Section 313
chemicals and chemical categories is 1%, except for Occupational Safety and Health
Administration (OSHA)-defmed carcinogens, which have a 0.1% de minimis concentration.
Note that if a mixture contains more than one member of an EPCRA Section 313 chemical
category, the weight percent of all members must be summed. If the total meets or exceeds the
category's de minimis level, the de minimis exemption does not apply. U.S. EPA has published
several detailed questions and answers and a directive in the current edition of EPCRA Section
313, Questions and Answers (Appendix A, Directive #2 in 1998 edition (EPA 745-B-98-004))
that may be helpful if you have additional concerns about the de minimis exemption. The TRI
> 1O
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Forms and Instructions list each EPCRA Section 313 chemical and chemical category with the
associated de minimis value.
Once the de minimis level has been equaled or exceeded, the exemption no longer
applies to that process stream, even if the EPCRA Section 313 chemical or chemical category
later falls below the de minimis concentration. All release and other waste management activities
that occur after the de minimis concentration has been equaled or exceeded are subject to
reporting. The facility does not have to report release and other waste management activities that
took place before the de minimis concentration was equaled or exceeded.
Example - De Minimis
Your facility uses a mixture containing 1.1% nitric acid and 0.6% manganese. The de minimis exemption would
apply to manganese because the concentration is below 1% which is the de minimis level for manganese;
however, it would not apply to nitric acid. All of the nitric acid must be included in threshold determinations,
release, and other waste management calculations.
The de minimis exemption also applies to EPCRA Section 313 chemicals and
chemical categories that are coincidentally manufactured below the de minimis level only if that
chemical is manufactured as an impurity in a mixture that is subsequently distributed in
commerce. In addition, the exemption applies to EPCRA Section 313 chemicals and chemical
categories below the de minimis concentration in an imported mixture or trade name product.
For some mixtures the concentration of EPCRA Section 313 chemicals and
chemical categories may be available only as a range. U.S. EPA has developed guidance on how
to determine quantities applicable to threshold determinations and release and other waste
management calculations when this range straddles the de minimis value. In general, only the
quantity of the processed or otherwise used EPCRA Section 313 chemical or chemical category
whose concentration exceeds the de minimis must be considered. Therefore, U.S. EPA allows
facilities to estimate the quantity below the de minimis and exclude it from further consideration.
The following examples illustrate this point.
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Examples - De Minimis Concentration Ranges
Example 1:
A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is subject to a 1% de
minimis concentration exemption. The amount of mixture subject to reporting is the quantity containing manganese above the
de minimis concentration:
(8,000,000) x (0.0125 -0.0099) - (0.0125 -0.0025)
The average concentration of manganese that is not exempt (above the de minimis) is:
(0.0125+ 0.01)-(2)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management
estimates is:
(8,000,000) x (Q.0125-0.0099)
(0.0125-0.0025)
(0.0125+0.01)
(2)
= 23,400 pounds
= 23,400 pounds manganese (which is below the processing threshold)
In this example, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was
used to determine the amount below the de minimis concentrations. If the information was available to one decimal place, 0.9
should be used, as in Example 2 below.
Example 2:
As in Example 1, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS states the mixture
contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above de minimis) is:
(8,000,000) x (0.012 - 0.009) - (0.012 -0.002)
The average concentration of manganese that is not exempt (above de minimis) is:
(0.012+ 0.01)-(2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management
estimates is:
(8,000,000) x (0.012-0.009)
(0.012-0.002)
(0.012+0.01)
(2)
= 26,400 pounds
= 26,400 pounds manganese (which is above the processing threshold)
The exemption does not apply to EPCRA Section 313 chemicals and chemical
categories coincidentally manufactured as byproducts and separated from the product, nor does it
apply to EPCRA Section 313 chemicals and chemical categories coincidentally manufactured as
a result of waste management activities, from either on site or off site (under EPCRA Section
313, U.S. EPA does not consider waste to be a mixture). For example, facilities that perform
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biological waste treatment of process wastewaters may be generating ammonia. The ammonia
would be considered to be coincidentally manufactured as part of the waste treatment process and
the de minimis exemption does not apply. Thus, 10% of the aqueous ammonia created should be
counted toward the 25,000-pound manufacturing threshold.
3.2.2.2 Articles Exemption
An article is defined as a manufactured item that:
• Is formed to a specific shape or design during manufacture;
• Has end-use functions dependent in whole or in part upon its shape or
design; and
• Does not release an EPCRA Section 313 chemical or chemical category
under normal conditions of processing or otherwise use of the item at the
facility.
If you receive a manufactured article from another facility or you produce the
article in your facility and process or otherwise use it without changing the shape or design, and
your processing or otherwise use does not result in the release into the environment of more than
0.5 pound of the EPCRA Section 313 chemical or chemical category in a reporting year for all
like articles, then the EPCRA Section 313 chemical or chemical category in that article is exempt
from threshold determinations and release and other waste management calculations (U.S. EPA
allows a release of 0.5 pound or less to be rounded to zero; the 0.5-pound limit does not apply to
each individual article, but applies to the sum of all releases from processing or use of all like
articles). Section 313 chemicals or chemical categories used to produce an article, however, do
not qualify for the article exemption.
The shape and design can be changed somewhat during processing and otherwise
use as long as part of the item retains the original dimensions. That is, as a result of processing
or otherwise use, if an item retains its initial thickness or diameter, in whole or in part, then it
still meets the article definition. If the item's original dimensional characteristics are totally
altered during processing or otherwise use, the item would not meet the definition. As an
example, items that do not meet the definition would be items that are cold extruded, such as lead
ingots formed into wire or rods. However, cutting a manufactured item into pieces that are
3-16
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recognizable as the article would not change the exemption status as long as the diameter and the
thickness of the item remain unchanged. For instance, metal wire may be bent and sheet metal
may be cut, punched, stamped, or pressed without losing the article status as long as no change is
made in the diameter of the wire or tubing or the thickness of the sheet and no releases above 0.5
pound per year occur for all like articles.
Any processing or otherwise use of an article that results in a release above 0.5
pound per year for each EPCRA Section 313 chemical or chemical category for all like articles
also negates the exemption. Cutting, grinding, melting, or other processing of a manufactured
item could result in a release of an EPCRA Section 313 chemical or chemical category during
normal conditions of use and, therefore, could negate the article exemption if the total annual
releases from all like articles exceed 0.5 pound in a year. However, if all of the resulting waste is
recycled or reused either on site or off site, so that the release of the EPCRA Section 313
chemical or chemical category does not exceed 0.5 pound for the calendar year, then the article's
exemption status is maintained. If the processing or otherwise use of similar manufactured items
results in atotal release of less than or equal to 0.5 pound of any individual EPCRA Section 313
chemical or chemical category to any environmental media in a calendar year, U.S. EPA will
allow this quantity to be rounded to zero and the manufactured items maintain their article status.
The 0.5-pound limit does not apply to each individual article, but applies to the sum of all
releases from processing or otherwise use of like articles for each EPCRA Section 313 chemical
or chemical category. The current edition of EPCRA Section 313 Questions and Answers (1998
edition is EPA 745-B-98-004) presents several specific question and answers/discussions
pertaining to the articles exemption.
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COMMON ERROR - Articles Exemption
A covered manufacturer makes plastic bottles by blow molding a mixture of plastic resin and polymer pellets that
contain lead chromate, an EPCRA Section 313 listed chemical category for both lead compounds and chromium
compounds. After the plastic bottles are made, they are given a quality assurance check. Bottles that do not pass
the quality check are discarded in the facility trash for ultimate disposal in the local municipal landfill, a RCRA
Subtitle C landfill. The Article Exemption under EPCRA Section 313 does NOT include the manufacture of
articles such as these bottles, it only applies to processing or otherwise use of such articles. Thus, the lead
chromate sent to the landfill would be considered a release of both a lead compound and a chromate compound,
and reported in Part II, Section 5.5.1 A, providing the 25,000 pound per year processing activity thresholds for
these compounds have been exceeded by the facility.
3.2.2.3 Facility-Related Exemption
Laboratory Activity Exemption
EPCRA Section 313 chemicals or chemical categories that are manufactured,
processed, or otherwise used in laboratories under the supervision of a technically qualified
individual are exempted from the threshold determination (and subsequent release and other
waste management calculations). This exemption may be applicable in circumstances such as
laboratory sampling and analysis, research and development, and quality assurance and quality
control activities. It does not include pilot plant scale or specialty chemical production.
Example - Laboratory Activity Exemption
A plastic products manufacturing facility has a research laboratory that applies various formulations of organic
coatings containing EPCRA Section 313 chemicals and chemical categories to product samples for testing for a
toy manufacturer. The testing is under the supervision of a technically qualified individual in the laboratory. The
EPCRA Section 313 chemicals and chemical categories used in this activity would be exempt from EPCRA
Section 313 reporting and should not be included in any threshold determination or release and other waste
management calculations.
3.2.2.4 Activity-Related Exemptions (Otherwise Use Exemptions)
Some exemptions apply to the otherwise use of an EPCRA Section 313 chemical
and chemical category. The specific quantities of EPCRA Section 313 chemicals and chemical
categories used in these activities do not need to be included in facility threshold determinations
(nor the associated release and other waste management calculations). The following otherwise
use activities are considered exempt:
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EPCRA Section 313 chemicals and chemical categories used in routine
janitorial or facility grounds maintenance. Examples are bathroom
cleaners, fertilizers, and garden pesticides similar in type or concentration
to consumer products. Materials used to clean process equipment do not
meet this exemption.
Personal use of items. Examples are foods, drugs, cosmetics, and other
personal items including those items within a facility operated cafeteria,
store, or infirmary. Office supplies such as correction fluid are also
exempt.
Structural components of the facility. Exemptions apply to EPCRA
Section 313 chemicals and chemical categories present in materials used to
construct, repair, or maintain structural components of a facility. An
example common to all facilities would be the solvents and pigments used
to paint the buildings. Materials used to construct, repair, or maintain
process equipment are not exempt.
EPCRA Section 313 chemicals and chemical categories used with
facility motor vehicles. This exemption includes the use of EPCRA
Section 313 chemicals and chemical categories for the purpose of
maintaining motor vehicles operated by the facility. Common examples
include gasoline, radiator coolant, windshield wiper fluid, brake and
transmission fluid, oils and lubricants, cleaning solutions, and solvents in
paint used to touch up the vehicle. Motor vehicles include, but may not be
limited to, cars, trucks, forklifts, locomotives, and aircraft. Note that this
exemption applies to the OTHERWISE USE of EPCRA Section 313
chemicals and chemical categories. The coincidental manufacture of
EPCRA Section 313 chemicals and chemical categories resulting from
combustion of gasoline is not exempt and should be considered toward the
manufacturing threshold.
Example - Motor Vehicle Exemption
Methanol is purchased for use as a processing aid and as a windshield washer anti-
freeze in company vehicles. Only the amount used as a processing aid would be used in
facility threshold calculations. Even if the facility still exceeds the otherwise use
threshold, the amount in the anti-freeze is exempt from release and other waste
management calculations.
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This exemption does NOT apply to stationary process equipment. The use
of lubricants and fuels for stationary process equipment (e.g., pumps and
compressors) and stationary energy sources (e.g., furnaces, boilers,
heaters), are NOT exempt.
Example - Process Equipment Chemical Use
Lubricants containing EPCRA Section 313 chemicals and chemical categories used on
facility vehicles or on-site structural maintenance activities that are not integral to the
process are exempt activities. However, lubricants used to maintain pumps and
compressors that aid facility process operations are not exempt and the amount of the
EPCRA Section 313 chemical or chemical category in the lubricant should be applied to
the otherwise use threshold.
EPCRA Section 313 chemicals and chemical categories in certain air
or water drawn from the environment or municipal sources. Included
are an exemption for EPCRA Section 313 chemicals and chemical
categories present in process water and non-contact cooling water drawn
from the environment or a municipal source, or chemicals and chemical
categories present in air used either as compressed air or as an oxygen
source for combustion.
Example - Chemicals in Process Water
A facility uses river water for one of its processes. This water contains approximately
100 pounds of an EPCRA Section 313 chemical or chemical category. The facility
ultimately returns the water that contains the entire 100 pounds of the EPCRA Section
313 chemical or chemical category to the river. The EPCRA Section 313 chemical or
chemical category in the water can be considered exempt because the EPCRA Section
313 chemical or chemical category was present as it was drawn from the environment.
The facility does not need to consider the EPCRA Section 313 chemical or chemical
category drawn with river water for threshold determinations or release and other waste
management calculations.
3.2.3
Additional Guidance on Threshold Calculations for Certain Activities
This section covers three specific situations in which the threshold determination
may vary from normal facility operations: reuse, remediation, and recycling activities of EPCRA
Section 313 chemicals and chemical categories.
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3.2.3.1 Reuse Activities
Threshold determinations of EPCRA Section 313 chemicals or chemical
categories that are reused at the facility are based only on the amount of the EPCRA Section 313
chemical or chemical category that is added to the system during the year, not the total volume in
the system. For example, a facility operates a refrigeration unit that contains 15,000 pounds of
anhydrous ammonia at the beginning of the year. The system is charged with 2,000 pounds of
anhydrous ammonia during the year. The facility has therefore otherwise used only 2,000 pounds
of the EPCRA Section 313 chemical or chemical category and is not required to report (unless
the facility has additional otherwise use activities of ammonia that, when taken together, exceed
the reporting threshold). If, however, the whole refrigeration unit was recharged with 15,000
pounds of anhydrous ammonia during the year, the facility would exceed the otherwise use
threshold, and be required to report.
COMMON ERROR - Threshold Determination. Recirculation
Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals in a
recirculation system rather than the amount actually used in the reporting year. The amount of the EPCRA
Section 313 chemical that is actually manufactured (including the quantity imported), processed, or otherwise
used, not the amount in storage or in the system, should be the amount applied to the threshold determination. For
example, a solvent containing an EPCRA Section 313 chemical is used, recirculated on site, and reused as a
solvent. The amount of EPCRA Section 313 chemical recirculated in the on-site recycling process is not
considered in the threshold determination because it is considered a direct reuse and is not reportable. Only the
amount of new chemical added to the system should be included in the otherwise used threshold calculation.
However, if you send a solvent containing an EPCRA Section 313 chemical off site for distillation and subsequent
recycling, it should be reported as a transfer to an off-site location for recycling (Form R, Part II, Section 6.2 and
8.5) because the distillation is considered a waste management activity. The amount of solvent returned to you
and subsequently used in the same reporting year must be included in the threshold determination. If the
reporting threshold is exceeded, the total quantity recycled should be reported in Section 8.4; i.e., the amount
recycled must be reported in Section 8.4 each time it is recycled.
3.2.3.2 Remediation Activities
EPCRA Section 313 chemicals and chemical categories undergoing remediation
(e.g., Superfund remediation) are not being manufactured, processed, or otherwise used.
Therefore, they are not included in the threshold determinations.
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However, if you are conducting remediation of an EPCRA Section 313 chemical
or chemical category that is also being manufactured, processed, or otherwise used by the facility
above an activity threshold level, you must consider this activity for release and other waste
management calculations. You must report any release or other waste management quantities of
an EPCRA Section 313 chemical or chemical category due to remediation in Part II, Sections 5
through 8, accordingly, of the 1999 Form R. Those quantities would also be considered as part
of the amount for determining Form A eligibility. EPCRA Section 313 chemicals and chemical
categories used for remediation should be considered toward threshold determinations. If an
EPCRA Section 313 chemical or chemical category exceeds one of the reporting thresholds
elsewhere at the facility, all release and other waste management activity quantities of that
chemical or chemical category must be reported, including release and other waste management
activity quantities resulting from remediation.
Excavation (that is considered part of the remedial action ) of material already
landfilled does not constitute a manufacturing, processing, or otherwise use activity. However,
routine activities (e.g., dredging a lagoon), even if not performed every year, are not considered
to be remedial actions and are always subject to reporting.
3.2.3.3 Recycling Activities
For on-site recycling and reuse systems where the same EPCRA Section 313
chemical or chemical category is recycled and reused multiple times, the quantity recycled or
reused should be counted only once (at the time it is introduced into the system) for threshold
calculations. (Please note that for reporting on-site waste management activities the quantity of
the EPCRA Section 313 chemical or chemical category should be counted every time it exits the
recycling unit in Section 8 of the Form R) EPCRA Section 313 chemicals and chemical
categories recycled off site and returned to the facility should be treated as newly purchased
materials for purposes of EPCRA Section 313 threshold determinations.
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3.3 Step 3. Calculate the Quantity of Each EPCRA Section 313 Chemical and
Chemical Category and Determine Which Ones Exceed an Activity
Threshold
The final step is to determine the quantity and which EPCRA Section 313
chemicals and chemical categories exceed an activity threshold. At this point you should have:
1. Identified each EPCRA Section 313 chemical and chemical category at
your facility.
2. Determined the activity category for each EPCRA Section 313 chemical
and chemical category (manufactured, processed, or otherwise used).
Now, you must sum the amount for each EPCRA Section 313 chemical and
chemical category by activity category, subtract all exempt quantities, and compare the totals to
the applicable thresholds. Each EPCRA Section 313 chemical and chemical category exceeding
any one of the activity thresholds requires the submission of an EPCRA Section 313 report.
Provided you meet certain criteria you may prepare a Form A rather than a Form R (see Section
2.8).
COMMON ERROR - Assuming a Threshold is Exceeded.
U.S. EPA recently published a report, The 1994 and 1995 Toxic Release Inventory Data Quality Report, EPA
745-R-98-002, with the site survey results of over 100 facilities (including rubber and plastic manufacturing
facilities) to evaluate EPCRA Section 313 reporting quality. One of the findings of this survey was that facilities
which simply assumed that chemical activity thresholds were exceeded were often in error. This resulted in many
of these facilities filing EPCRA Section 313 reports when thresholds were actually not exceeded. Unless the
facility has strong grounds to support such an assumption, the time spent in explicitly calculating the activity
threshold is well spent.
COMMON ERROR - Zero Release and Other Waste Management Quantities
If you meet all reporting criteria and exceed any activity threshold for an EPCRA Section 313 chemical, you must
file an EPCRA Section 313 report for that chemical, even if you have zero release and other waste management
activity quantities. Exceeding the chemical activity threshold, not the quantity released and otherwise managed as
waste determines whether you must report. Note that if the release and other waste management activity quantity
is 500 pounds or less for each chemical or chemical category you may be eligible to use the alternate certification
statement, Form A, rather than a Form R (see Section 2.9).
> O">
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To determine if an EPCRA Section 313 chemical or chemical category exceeds a
reporting threshold, you must calculate the annual activity amount of that chemical or chemical
category. Start with the amount of chemical at the facility as of January 1, add any amounts
brought on site during the year and the amount manufactured (including imported), and subtract
the amount left in the inventory on December 31. If necessary, adjust the total to account for
exempt activities (see Section 3.2.2 for a discussion of exemptions). You should then compare
the result to the appropriate threshold to determine if you are required to submit an EPCRA
Section 313 report for that chemical or chemical category. Keep in mind that the threshold
calculations are independent for each activity category: manufactured, processed, and otherwise
used. If more than one activity category applies, the amount associated with each category is
determined separately.
Example - Xylene Isomers
Rubber and plastics manufacturers use large amounts of xylene, with the mixed isomers, CAS Registry No. 1330-
20-7, being the most frequently reported type. Xylene is listed on the EPCRA Section 313 chemicals list in three
isomeric forms and a mixture of these, namely ortho-, meta-, para-, and mixed. The mixed isomer classification
can be used when a mixture contains any combination of two or three of the isomers. The threshold determination
for xylene should be calculated for each form individually. For example, a covered facility annually uses 8,000
pounds of para-xylene, 6,000 pounds of ortho-xylene, and 8,000 pounds of mixed isomers as carrier solvents in
three separate processing lines. All three activities of xylene are classified as otherwise use as the carrier is
intended to evaporate and not remain with the product. There are no other uses of any form of xylene in the
facility. The otherwise use activity threshold of 10,000 pounds/year has not been reached for any of the xylenes
and an EPCRA Section 313 report need not be prepared for any of the xylenes. However, if any two streams mix,
the otherwise use activity threshold would be exceeded for mixed isomers and an EPCRA Section 313 would
have to be prepared for the mixed isomers.
Table 3-5 presents a work sheet that may be helpful when conducting your
threshold determinations. Table 3-6 illustrates how the work sheet can be used for the following
example:
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Example - Threshold Worksheet
Assume your facility purchases two mixtures that contain xylene (mixed isomers) in the applicable reporting year.
You purchased 25,000 pounds of Mixture A (which is 50% xylene, by weight, according to the MSDS) and
110,000 pounds of Mixture B (which contains 20% xylene, by weight). Further, you determine that you process
the entire quantity of Mixture A, while you process only half of Mixture B and otherwise use the other half. You
do not qualify for any exempt activities.
In this example, you would have processed a total of 23,500 pounds of xylene (12,500 pounds from activities
associated with Mixture A and 11,000 pounds from activities associated with Mixture B). You would also have
otherwise used a total of 11,000 pounds (all from Mixture B). Therefore, you would not have exceeded the
25,000 pound threshold for processing; however, you would have exceeded the 10,000 pound threshold for
otherwise use and would be required to submit an EPCRA Section 313 report that includes releases and other
waste management quantities from all activities (including processing).
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Table 3-5. EPCRA Section 313 Reporting Threshold Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of chemical manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source
Total Weight
Ob)
Percent
EPCRA
Section 313
Chemical
by Weight
EPCRA
Section 313
Chemical
Weight (Ib)
Amount of the EPCRA Section 313 Chemical
by Activity (Ib):
Manufactured
(A) Ib.
Processed
(B) Ib.
Otherwise Used
(C) Ib.
oo
to
Exempt quantity of chemical that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility,
activity)
Fraction or Percent Exempt
(if Applicable)
Amount of the EPCRA Section 313 Chemical
Exempt from Above (Ib):
Manufactured
(A,) Ib.
Processed
(B,) Ib.
Otherwise Used
(C,) Ib.
Ib.
Ib.
Amount subject to threshold: (A-Aj)_
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities3: 25.000 Ib. 25.000 Ib.
If any one of the thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
Ib.
10.000 Ib.
3These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT chemicals.
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Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet
Facility Name: ABC Rubber Corporation
EPCRA Section 313 Chemical or Chemical Category: Xvlene (mixed isomers)
CAS Registry Number: 1330-20-7
Reporting Year: 1999
Date Worksheet Prepared: March 1. 2000
Prepared By: A.B. Galloway
Amounts of chemical manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Information
Source
MSDS
MSDS
Total Weight
Ob)
25,000
110,000
Percent
EPCRA
Section 313
Chemical
by Weight
50%
20%
EPCRA
Section 313
Chemical
Weight (Ib)
12,500
22,000
Amount of the EPCRA Section 313 Chemical
by Activity (Ib):
Manufactured
—
—
(A) 0 Ib.
Processed
12,500
11,000
(B) 23,500 Ib.
Otherwise Used
—
11,000
(C) 11,000 Ib.
oo
to
Exempt quantity of chemical that should be excluded.
Mixture Name as Listed Above
1. Mixture A
2. MixtureB
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)
none
none
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical
Exempt from Above (Ib):
Manufactured
(Aj) 0 Ib.
Processed
(Bj) 0 Ib.
Otherwise Used
(CO 0 Ib.
Amount subject to threshold: (A-Aj) 0 Ib. (B-Bj) 23,500 Ib. (C-Cj) 11,000 Ib.
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities3: 25.000 Ib. 25.000 Ib. 10.000 Ib.
If any one of three thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
3These activity thresholds are for non-PBT chemicals. See Section 2.6 for the activity thresholds applicable to PBT chemicals.
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CHAPTER 4 - ESTIMATING RELEASES AND OTHER
WASTE MANAGEMENT QUANTITIES
4.0 PURPOSE
This chapter is intended to guide the user in developing a systematic approach for
estimating release and other waste management quantities of EPCRA Section 313 chemicals and
chemical categories from rubber and plastics manufacturing processes. Figure 4-1 diagrams a
recommended approach for estimating quantities of reportable EPCRA Section 313 chemicals or
chemical categories.
This chapter also includes common EPCRA Section 313 reporting and
compliance issues as they apply to rubber and plastics manufacturers. The general discussion
(Section 4.1) is followed by a presentation of specific examples and issues (Section 4.2).
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities
Release and other waste management activity quantities can be determined by
completing the following four steps, described in detail in the following sections.
Step 1) Prepare a process flow diagram.
Step 2) Identify EPCRA Section 313 chemicals and chemical categories
and potential sources of chemical release and other waste
management activities.
Step 3) Identify release and other waste management activity types.
Step 4) Determine the most appropriate method(s) and calculate the
estimates for release and other waste management activity
quantities.
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STEP 1: Prepare Process
Flow Diagram
STEP 2: Identify EPCRA
Section 313 Chemicals
or Chemical Categories*
STEP 2: Identify Sources of Release
and Other Waste
Management Activities
Source 1
Source 2
STEP 3: Define the
Operation
Source 3
STEP 3: Identify Releases and Other
Waste Management Activity
Types
to
r
Fugitive Point Discharge Underground Land
Air Air to Injection On Site
Waterbody
POTW Transfer
Off Site for
Recycling
Transfer Transfer
Off Site for Off Site for
Energy Recovery Treatment
Transfer On-Site On-Site On-Site
Off Site for Waste Energy Recycling
Disposal Treatment Recovery
i
STEP 4: Review Available
Data & Choose
Estimation Method
STEP 4: Calculate Estimates for
Releases and Other Waste
Management Activity
Quantities
Figure 4-1. Releases and Other Waste Management Activity Calculation Approach
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For EPCRA Section 313 purposes, "sources" means the streams or units that
generate the release and other waste management activity (such as process vents, container
residue, or spills) and "types" means the environmental media corresponding to elements in
Sections 5 through 8 of the 1999 Form R (for example, releases to fugitive air, releases to stack
air, discharges to receiving streams or POTWs, or releases to land).
4.1.1 Step 1: Prepare a Process Flow Diagram
Preparing a process flow diagram will help you to identify potential sources and
types of EPCRA Section 313 chemicals and chemical categories released and otherwise managed
as waste at your facility. Depending on the complexity of your facility, you may want to diagram
individual processes or operations rather than the entire facility. The diagrams should show how
materials flow through the processes and identify material input, generation, and output points.
Looking at each operation separately, you can determine where EPCRA Section 313 chemicals
and chemical categories are used and the medium to which they may be released or otherwise
managed as waste.
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories
and Potential Sources of Chemical Release and Other Waste Management
Activities
Once a process flow diagram has been developed, you must determine the
potential sources and the EPCRA Section 313 chemicals and chemical categories may be
released and otherwise managed as waste from each unit operation and process. Remember to
include upsets and routine maintenance activities. Potential sources include:
Accidental spills and • Fittings;
releases; • Flanges;
Air pollution control devices • Process discharge streams;
(e.g., baghouses, electrostatic • Process vents;
precipitators, and scrubbers); • Pumps;
Clean up and housekeeping • Recycling and energy
practices; recovery byproducts;
Combustion byproducts. • Relief valves;
Container residues; • Stock pile losses;
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Storage tanks; • Treatment sludge;
Storm water runoff; • Volatilization from process
Tower stacks; or treatment areas; and
Transfer operations; • Waste treatment discharges.
Next, you must identify the EPCRA Section 313 chemicals and chemical
categories that may be released or otherwise managed as waste from each source. A thorough
knowledge of the facility operations and processes is required for this determination. You should
also consider whether any of the EPCRA Section 313 chemicals and chemical categories are
coincidentally manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals
and chemical categories typically used in rubber and plastics manufacturing. This table can be
used as an aid in identifying which chemicals and chemical categories are found in your process.
The list may not include all the EPCRA Section 313 chemicals and chemical categories your
facility uses, and it may include many chemicals and chemical categories that you do not use.
4.1.3 Step 3: Identify Release and Other Waste Management Activity Types
For each identified source of an EPCRA Section 313 chemical or chemical
category, you should examine all possible release and other waste management activity types.
Figure 4-2 schematically represents the possible release and other waste management activity
types as they correspond to individual data elements of the Form R. Remember to include both
routine operations and accidents when identifying types. This diagram along with the following
descriptions can be used as a checklist to make sure all possible types of release and other waste
management activities have been considered.
a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) -
Includes all emissions to the air that are not released through stacks, vents,
ducts, pipes, or any confined air stream. Examples include:
• Equipment leaks from valves, pump seals, flanges, compressors,
sampling connections, open-ended lines, etc.;
• Releases from building ventilation systems, such as a roof fan in an
open room;
• Evaporative losses from solvent cleaning tanks, surface
impoundments, and spills; and
• Emissions from any other fugitive or non-point source.
4-4
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Point Sources
(Part II, Sections
5.2 and 8.1)
Fugitive Emissions
(Part II, Sections
5.1 and 8.1)
Toxic Chemical In
Operation
T
Transfer Off Site for Recycling
(Part II, Sections 6.2 and 8.5)
Transfer Off Site for Energy Recovery
(Part II, Sections 6.2 and 8.3)
Transfer Off Site for Treatment
(Part II, Sections 6.2 and 8.7)
Transfer Off Site for Disposal
(Part II, Sections 6.2 and 8.1)
On-Site Treatment
(Part II, Sections 7A and 8.6)
On-Site Energy Recovery
(Part II, Sections 7B and 8.2)
On-Site Recycling
(Part II, Sections 7C and 8.4)
POTW
(Part II, Sections
6.1 and 8.1, or8.7)
Underground Injection
(Part II, Sections
Receiving Streams 5.4 and 8.1)
(Part II, Sections Land on site (landfill,
5.3 and 8.1) land treatment,
surface impoundment)
(Part II, Sections
5.5 and 8.1)
Figure 4-2. Possible Release and Other Waste Management Activity
Types4 for EPCRA Section 313 Chemicals and Chemical Categories
b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) -
Includes all emissions to the air that occur through stacks, vents, ducts,
pipes, or any confined air stream, including the emissions from storage
tanks and air pollution control equipment. Air emissions from paint
booths are often channeled through vapor recovery systems and/or air
pollution control devices. These are considered stack emissions. Note
that emissions released from general room air through a ventilation system
are not considered stack or point releases for the purpose of EPCRA
Section 313 reporting unless they are channeled through an air pollution
control device. Instead, they are considered fugitive releases. However,
you should note that for certain state reporting requirements not associated
with EPCRA Section 313 reporting, some state air quality agencies
consider ventilation systems to be a stack or point source.
"Sections refer to 1999 Form R - Quantities released to the environment as a result of remedial actions, catastrophic
events, or one-time events should be reported in Part II, Section 8 as Subsection 8.8
4-5
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c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3
of Form R) - Includes direct wastewater discharges to a receiving stream
or surface water body. Discharges usually occur under a NPDES or
SPDES permit.
d. Underground Injection On-Site to Class I Wells (Part II, Section 5.4.1
of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of
Form R) - Includes releases into an underground well at the facility.
These wells may be monitored under an Underground Injection Control
(UIC) Program permit. RCRA Hazardous Waste Generator Reports may
be a good source of information for wastes injected into a Class I well.
Injection rate meters may provide information for all the well classes.
e. Disposal to Land On-Site (Part II, Section 5.5 of Form R) - Includes
all releases to land on site, both planned (i.e., disposal) and unplanned
(i.e., accidental release or spill). The four predefined subcategories for
reporting quantities released to land within the boundaries of the facility
are:
(1) Landfill - The landfill may be either a RCRA-permitted (Part II,
Section 5.5.1 A of Form R) or a non-hazardous waste landfill (Part
II, Section 5.5. IB of Form R). Both types are included if they are
located on site. Leaks from landfills in the years subsequent to the
disposal of the EPCRA Section 313 chemicals or chemical
categories in the landfill do not need to be reported as a release.
(2) Land treatment/application farming - Land treatment is a
disposal method in which a waste containing an EPCRA
Section 313 chemical or chemical category is applied to or
incorporated into soil. Volatilization of an EPCRA Section 313
chemical or chemical category due to the disposal operation must
be included in the total fugitive air releases and should be excluded
from land treatment/application farming to avoid double counting.
Sludge and/or aqueous solutions that contain biomass and other
organic materials are often collected and applied to farm land.
This procedure supplies a nitrogen source for plants and supplies
metabolites for microorganisms. U.S. EPA considers this
operation to be land treatment/farming if it occurs on site. If a
facility sends this material off site for the same purpose, it is
considered to be a "transfer to an off-site location, disposal" and
should be reported under Sections 6.2 and 8.1 of the Form R.
The ultimate disposition of the chemical or chemical category after
application to the land does not change the required reporting. For
example, even if the chemical or chemical category is eventually
4-6
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biodegraded by microorganisms or plants, it is not considered
recycled, reused, or treated.
(3) Surface impoundment - A surface impoundment is a natural
topographic depression, man-made excavation, or diked area
formed primarily of earthen materials that is designed to hold an
accumulation of wastes containing free liquids. Examples include:
holding, settling, storage, and elevation pits; ponds; and lagoons.
Quantities of the toxic chemical released to surface impoundments
that are used merely as part of a wastewater treatment process
generally must not be reported in this section. However, if the
sludge from the surface impoundment contains the EPCRA
Section 313 chemical or chemical category, then the EPCRA
Section 313 chemicals or chemical categories in the sludge must be
estimated in this section unless the sludge is removed and
subjected to another waste management activity.
(4) Other disposal - Releases to land that do not fit the categories of
landfills, land treatment, or surface impoundment are classified as
other disposal. This disposal may include any spills or leaks of the
EPCRA Section 313 chemical or chemical category to land.
f. Discharges to Publicly Owned Treatment Works (POTW) (Part II,
Section 6.1 of Form R) - Includes the amount of EPCRA Section 313
chemical or chemical category in water transferred to an off-site POTW.
Note that metals and metal compounds transferred to a POTW must also
be reported in Section 8.1.
g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of
Form R) - Includes all off-site transfers containing the EPCRA Section
313 chemical or chemical category for the purposes of waste treatment,
disposal, recycling, or energy recovery. Off-site transfer for disposal
includes underground injection, landfill/surface impoundment, other land
disposal, and transfer to a waste broker for disposal. The amount
transferred off site for disposal must also be reported in Section 8.1.
Also reported in Section 6.2 would be any residual EPCRA Section 313
chemicals in "empty" containers transferred off site. U.S. EPA expects
that all containers (bags, totes, drums, tank trucks, etc.) will have a small
amount of residual solids and/or liquid. On-site cleaning of containers
must be considered for EPCRA Section 313 reporting. If the cleaning
occurs with a solvent (organic or aqueous), you must report the disposition
of the waste solvent as appropriate. If the containers are sent off site for
disposal or reclamation, you should report the EPCRA Section 313
chemical or chemical category in this section.
4-7
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COMMON ERROR - Shipping Container Residue
Do not overlook residual chemicals or chemical categories in containers. U.S. EPA
recently published The 1994 and 1995 Toxic Release Inventory Data Quality Report,
EPA 745-R-98-002, presenting the site survey results of over 100 facilities to evaluate
EPCRA Section 313 reporting quality. This survey found the largest source of
overlooked release and other waste management activities was from container residue.
So-called "empty" drums may contain an inch or more of liquid after draining and
similarly "empty" bags may contain residues of dust and powder. Even though each
individual drum or bag may only contain a small amount of an EPCRA Section 313
chemical or chemical category, for facilities that receive hundreds or thousands of
drums or bags each year the annual cumulative amount of an EPCRA Section 313
chemical or chemical category can be substantial. The quantities should typically be
reported in Section 6.2 (see Table 4-1 for estimates of liquid drum residual and the text
of this section for estimates of residual from solids). Please note that unlike RCRA,
EPCRA Section 313 does not define what constitutes an "empty" container. EPCRA
Section 313 is merely trying to account for all the quantities of toxic chemicals released
and otherwise managed as waste.
4-8
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Table 4-1
Summary of Liquid Residue Quantities From
Pilot-Scale Experimental Studya'b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244 - 0.472
0.404
0.032-0.080
0.054
0.020-0.039
0.033
0.031-0.042
0.038
0.024 - 0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266-0.458
0.403
0.026-0.039
0.034
0.016-0.024
0.019
0.033-0.034
0.034
0.020 - 0.040
0.033
Motor Oil*
1.97-2.23
2.06
1.70-3.48
2.30
0.677 - 0.787
0.737
0.328-0.368
0.350
0.100-0.121
0.111
0.133-0.191
0.161
0.112-0.134
0.127
Surfactant
Solution*
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental
Protection Agency, Office of Pesticides and Toxic Substances, Washington DC Contract No. 68-02-4248. June 30,
1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid
materials. At viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information
on this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
Tor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 97 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactant solution viscosity = 3 centipoise, surface tension =31.4 dynes/cm2
4-9
-------
Actual data and a knowledge of the unloading methods at your facility can
be used to estimate the quantity of residual EPCRA Section 313 chemicals
or chemical categories in containers. However, U.S. EPA has developed
guidance to assist facilities if no site-specific information is available.
Table 4-1 provides results from a study of liquid residue quantities left in
drums and tanks when emptied. These results are presented as the mass
percent of the vessel capacity, and are categorized based on unloading
method, vessel material, and bulk fluid material properties such as
viscosity and surface tension. No testing was conducted for residual solids
in this study. If data or on-site specific knowledge is available to estimate
the quantity of solid residual in containers, it should be considered. If no
data are available, U.S. EPA believes an estimate of 1% residual solid is
reasonable.
The following example describes how the information in the table can be
used to estimate the quantity of an EPCRA Section 313 chemical or
chemical category in water that was used to clean drums on site.
Example - Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical must be submitted. The facility
purchases and uses one thousand 55-gallon steel drums that contain a 10% aqueous solution of the chemical.
Further, it is assumed that the physical properties of the solution are similar to water. The solution is pumped
from the drums directly into a mixing vessel and the "empty" drums are triple-rinsed with water. The rinse water
is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
From Table 4-1, the average drum residue quantity for this scenario is 2.29%. In this example, it can be assumed
that all of the residual solution in the drums was transferred to the rinse water. Therefore, the quantity of the
EPCRA Section 313 chemical transferred to the drum reclaimer should be reported as "zero."
The annual quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the
mean weight percent of residual solution remaining in a pumped steel drum by the total annual weight of solution
in the drums. If the density is not known, it may be appropriate to use the density of water (8.34 pounds per
gallon):
(0.0229) x (55 gal/drum) x (1,000 drums) x (8.34 Ib/gal) = 10,504 pounds solution
The concentration of the EPCRA Section 313 chemical in the solution is only 10%.
(10,504 Ib solution) x (0.1) = 1,050 pounds of the EPCRA Section 313 chemical
Therefore, 1,050 pounds of the EPCRA Section 313 chemical are transferred to the POTW, and should be
reported in Part II, Sections 6.1 and 8.7 of the 1999 FormR. Because they cannot be destroyed, metals cannot be
reported as being treated, and metals and metal portions of metal compounds should be reported in Part II,
Section 6.1 and 8.1 of the 1999 Form R.
h. On-Site Waste Treatment (Part II, Section 7A of Form R) - Includes all
on-site waste treatment of EPCRA Section 313 chemicals or chemical
categories. The information reported in Section 7A focuses on the
treatment of the entire waste stream, not the specific EPCRA Section 313
4-10
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chemical or chemical category. The information includes type of waste
stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment
methods or sequence; influent concentrations of the EPCRA Section 313
chemical or chemical category; treatment efficiency (combined removal
and destruction) of the entire method or sequence; and whether efficiency
data are based on actual operating data. Metals and metal portions of
metal compounds treated in a combustion process are not destroyed but
should still be reported as going through the treatment process, with a
treatment efficiency of zero. Note that only the metal portion of metal
compounds should be reported in the Form R. The following example
illustrates how Section 7A should be completed for on-site treatment of a
wastewater stream containing three EPCRA Section 313 chemicals or
chemical categories.
Example - On-Site Waste Treatment
A process at the facility generates a wastewater stream containing an EPCRA Section 313 chemical (chemical A).
A second process generates a wastewater stream containing two EPCRA Section 313 chemicals, a metal
(chemical B) and a mineral acid (chemical C). Thresholds for all three chemicals have been exceeded and you are
in the process of completing separate Form Rs for each chemical.
The two wastewater streams are combined and sent to an on-site wastewater treatment system before being
released to a POTW. This system consists of an oil/water separator that removes 99% of chemical A; a
neutralization tank in which the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C);
and a settling tank where 95% of the metal (chemical B) is removed from the water (and eventually land filled off
site).
Section 7 A should be completed slightly differently when you file the Form R for each of the chemicals or
chemical categories. The table accompanying this example shows how Section 7A should be completed for each
chemical or chemical category. First, on each Form R you should identify the type of waste stream in Section
7A. la as wastewater (aqueous waste, code W). Next, on each Form R you should list the code for each of the
treatment steps that is applied to the entire waste stream, regardless of whether the operation affects the chemical
or chemical category for which you are completing the Form R (for instance, the first four blocks of Section
7 A. Ib of all three Form Rs should show: P19 (liquid phase separation), C11 (neutralization), P11
(settling/clarification), and N/A (to signify the end of the treatment system). Note that Section 7A.lb is the only
section of the Form R that is not chemical or chemical category specific. It applies to the entire waste stream
being treated. Section 7 A. Ic of each Form R should show the concentration of the specific chemical or chemical
category in the influent to the first step of the process (oil/water separation). For this example, assume chemicals
or chemical categories A, B, and C are all present at concentrations greater than 1%. Therefore, code "1" should
be entered. Section 7A. Id is also chemical specific. It applies to the efficiency of the entire system in destroying
and/or removing the chemical or chemical category for which you are preparing the Form R. You should enter
99% when filing for chemical A, 95% for chemical B, and 100% for chemical C. Finally, you should report
whether the influent concentration and efficiency estimates are based on operating data for each chemical or
chemical category, as appropriate.
4-11
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7A.la
w
7A.lb
3. Pll
6.
Chemical A
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.la
w
7A.lb
3. Pll
6.
7A.lc
—
7A.ld
99 %
7A.le
Yes No
X
Chemical B
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.la
w
7A.lb
3. Pll
6.
7A.lc
—
7A.ld
95 %
7A.le
Yes No
X
Chemical C
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
—
7A.ld
100 %
7A.le
Yes No
X
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
Section 7A. Id refers to the amount of EPCRA Section 313 chemical or chemical category destroyed and/or
removed from the applicable waste stream. The amount actually destroyed should be reported in Section 8.6
(quantity treated on site). For example, when completing the Form R for chemical B you should report "0"
pounds in Section 8.6 because the metal has been removed from the wastewater stream, but not actually
destroyed. The quantity of chemical B that is ultimately land filled off site should be reported in Section 6.2 and
8. 1. However, when completing the Form R for chemical C you should report the entire quantity in Section 8.6
because raising the pH to 7.5 will completely destroy the mineral acid.
On-Site Energy Recovery (Part II, Section 7B of Form R) - Includes all
on-site energy recovery of reported EPCRA Section 313 chemicals and
chemical categories. U.S. EPA's view is that EPCRA Section 313
chemicals or chemical categories that do not contribute significant heat
energy during combustion processes should not be considered for energy
recovery. Therefore, only EPCRA Section 313 chemicals or chemical
categories with a significant heating value that are combusted in an energy
recovery unit, such as an industrial furnace, kiln, or boiler can be reported
for energy recovery. If an EPCRA Section 313 chemical or chemical
category is incinerated on site but does not significantly contribute energy
to the process, (e.g., chlorofluorocarbons (CFCs)) it must be considered
on-site waste treatment (see 4.1.3, h. above). Metals and metal portions of
metal compounds will never be combusted for energy recovery. Note that
only the metal portion of metal compounds should be reported in the Form
R.
On-Site Recycling (Part II, Section 7C of Form R) - Includes all on-site
recycling methods used on EPCRA Section 313 chemicals or chemical
categories.
4-12
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k. Source Reduction and Recycling Activities (Part II, Section 8 of Form
R)1 - Provide information about source reduction and recycling activities
related to the EPCRA Section 313 chemical or chemical category for
which release and other waste management activities are being reported.
Section 8 uses some data collected to complete Part n, Sections 5 through
7. For this reason, Section 8 should be completed last. The relationship
between Sections 5, 6, and 8.8 to Sections 8.1, 8.3, 8.5, and 8.7 are
provided in equation forms below.
(1) Quantity Released (Part II, Section 8.1 of Form R) - The
quantity reported in Section 8.1 is the quantity reported in all of
Section 5 plus the quantity of metals and metal compounds
reported as discharged off site to POTWs in Section 6.1 plus the
quantity reported as sent off site for disposal in Section 6.2 minus
the quantity reported in Section 8.8 that was released on site or sent
off site for disposal:
§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal) -
§8.8 (on-site release or off-site disposal only)
(2) Quantity Used for Energy Recovery On-Site (Part II, Section
8.2 of Form R) - Estimate the quantity of the EPCRA Section 313
chemical or chemical category in wastes combusted for energy
recovery on site. This estimate should be the quantity of the
chemical or chemical category combusted in the process for which
codes were reported in Section 7B. Test data from trial burns or
other monitoring data may be used to estimate the quantity of the
EPCRA Section 313 chemical or chemical category combusted for
energy recovery purposes. If monitoring data are not available,
vendor specifications regarding combustion efficiency may be used
as they relate to the EPCRA Section 313 chemical or chemical
category. A quantity must be reported in Section 8.2 when a
method of on-site energy recovery is reported in Section 7B and
vice versa.
Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical (1) must have a significant heating
value and (2) must be combusted in an energy recovery unit, such
as a waste heat boiler, an industrial furnace, or a kiln. If an
EPCRA Section 313 chemical or chemical category that does not
have a significant heating value (except metals and metal
compounds) is combusted for energy recovery on site, it must be
considered on-site waste treatment (see 4.1.3.h). However, this
'The Subsection 8.1 through 8.8 designations are for the 1999 Form R. Please refer to the current reporting year TRI
Forms and Instructions for any changes.
4-13
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does not apply to metals and metal compounds. Metals and metal
compounds in a waste that are combusted on site will never be
combusted for energy recovery or treated for destruction and are
therefore normally disposed. Note that "NA" should be reported
for EPCRA Section 313 chemicals or chemical categories that do
not have a significant heating value. This includes metals, metal
portions of metal compounds, halogens, hydrochlorofluorocarbons
(HCFCs), and CFCs.
(3) Quantity Used for Energy Recovery Off-Site (Part II, Section
8.3 of Form R) - The quantity reported in Section 8.3 is the
quantity reported in Section 6.2 for which energy recovery codes
are reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for energy recovery:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical or chemical category (1) must have a
significant heating value and (2) must be combusted in an energy
recovery unit, such as a waste heat boiler, an industrial furnace, or
a kiln. If an EPCRA Section 313 chemical or chemical category
that does not have a significant heating value (except metals and
metal compounds) is sent off site for energy recovery, it must be
considered off-site waste treatment (see 4.1.3 .g). However, this
does not apply to metals and metal compounds. Metals and metal
compounds sent off site for combustion in energy recovery units
must be considered as sent off site for disposal because typically
they will ultimately be disposed. Metals and metal portions of
metal compounds will never be treated or combusted for energy
recovery. Note that only the metal portion of metal compounds
should be reported in the Form R. Also note that "NA" should be
reported for EPCRA Section 313 chemicals or chemical categories
that do not have a significant heating value. This includes metals,
metal portions of metal compounds, halogens, HCFCs, and CFCs.
(4) Quantity Recycled On-Site (Part II, Section 8.4 of Form R) -
Estimate the quantity of the EPCRA Section 313 chemical or
chemical category recycled in wastes on site. This estimate should
be the quantity of the chemical or chemical category recycled in the
process for which codes were reported in Section 7C. A quantity
should be reported in Section 8.4 when a method of on-site
recycling is reported in Section 7C and vice versa. To estimate this
quantity, you should determine if operating data exist that indicate
a recovery efficiency and use that efficiency value combined with
4-14
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throughput data to calculate an estimate. If operating data are
unavailable, available vendor specifications may be appropriate.
(5) Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -
The quantity reported in Section 8.5 must be the same as the
quantity reported in Section 6.2 for which recycling codes are
reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for recycling:
If the facility has knowledge about metals being recovered, this
quantity should be reported in Section 8.5.
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
COMMON ERROR - Direct Reuse vs. Recycling
The direct reuse of an EPCRA Section 313 chemical does not need to be
included in the amount reported in Part II, Section 8 of Form R. However,
recycling of the chemical should be included.
(6) Quantity Treated On-Site (Part II, Section 8.6 of Form R) -
Waste treatment in Section 8 is limited to the destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category in wastes. The quantities reported in Section 8.6
will be those that have undergone processes that are a subset of the
processes for which codes were reported in Section 7 A, where
treatment includes physical removal from a waste stream. To
estimate the quantity treated, you should determine if operating
data exist that indicate a treatment efficiency (e.g., destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category) and use that efficiency value combined with
throughput data to calculate an estimate. Because metals cannot be
destroyed or chemically converted into something other than the
metal or metal compound, metals cannot be reported as treated in
Section 8.6. Note that conversion of a metal from one oxidation
state to another (e.g., Cr(VI) to Cr(in)) is not considered treatment
for Section 8.6. If operating data are unavailable, available vendor
specifications may be appropriate. Section 7A must be completed
if a quantity is entered in Section 8.6.
(7) Quantity Treated Off-Site (Part II, Section 8.7 of Form R) -
The quantity reported in Section 8.7 must be the same as the
quantity reported in Section 6.2 for which treatment codes are
reported plus quantities sent to a POTW as reported in Section 6.1
except for metals and metal compounds. If a quantity is reported in
Section 8.8, subtract any associated off-site transfers for treatment:
4-15
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§8.7 = §6.1 (except metals and metal compounds) + §6.2
(treatment) - §8.8 (off-site treatment)
Because metals cannot be destroyed or chemically converted into
something other than the metal or metal compound, metals cannot
be reported as treated in Section 8.7. Quantities of metals reported
in Section 6.1 and 6.2 should be reported in Section 8.1 (Quantity
Released) unless the facility has knowledge that the metal is being
recovered.
(8) Quantity Released to the Environment as a Result of Remedial
Actions, Catastrophic Events, or One-Time Events Not
Associated with Production Processes (Part II, Section 8.8 of
Form R) - The purpose of this section is to separate quantities
recycled off site, used for energy recovery off site, treated off site,
or released (including disposed) that are associated with normal or
routine production from those quantities that are not. The quantity
reported in Section 8.8 is the quantity of the EPCRA Section 313
chemical or chemical category released directly into the
environment or sent off site for recycling, waste treatment, energy
recovery, or disposal during the reporting year due to any of the
following events:
• Remedial actions;
• Catastrophic events such as earthquakes, fires, or floods; or
• One-time events not associated with normal or routine
production processes.
The quantity reported in Section 8.8 should not be included with
quantities reported in Part n, Sections 8.1 through 8.7 of Form R,
but should be included in Part II, Sections 5 and 6 of Form R as
appropriate.
Spills that occur as a routine part of production operations and
could be reduced or eliminated by improved handling, loading, or
unloading procedures are included in the quantities reported in
Section 8.1 through 8.7 as appropriate. This includes small
drippings and spills that often occur during transfer operations and
loading/unloading operations.
On-site releases and off-site transfers for further waste
management from remediation of an EPCRA Section 313 chemical
or chemical category or an unpreventable accident unrelated to
production (such as a hurricane) are reportable in Section 8.8.
On-site treatment, energy recovery, or recycling of EPCRA Section
313 chemicals or chemical categories in wastes generated as a
4-16
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result of remedial actions, catastrophic events, or one-time events
not associated with production processes are not reported in Part n,
Section 8.8, nor in Sections 8.1 through 8.7 of Form R.
COMMON ERROR - Double Counting
Release and other waste management activities should not be"double counted." A single wastewater discharge
should not be listed as both a release to water (on site) and a discharge to POTW (off site). Similarly, a release to
land should not be listed as both a release to land (on site) and a transfer to an off-site landfill. Estimates of
releases and other waste management activities should be prepared for Sections 5 through 7 of the Form R. For
the most part, Section 8 relies on the data collected to complete these previous sections. Therefore, Section 8
should be completed last. However, the data elements of Section 8 (8.1 through 8.7) are mutually exclusive and
care should be taken to avoid double counting.
4.1.4 Step 4: Determine the Most Appropriate Method(s) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
After you have identified all of the potential sources for release and other waste
management activity types, you must estimate the quantities of each EPCRA Section 313
chemical and chemical category released and otherwise managed as waste. U.S. EPA has
identified four basic methods that may be used to develop estimates (each method has been
assigned a code that must be included when reporting). The methods and corresponding codes
are:
• Monitoring Data or Direct Measurement (M);
• Mass Balance (C);
• Emission Factors (E); and,
• Engineering Calculations (O).
Descriptions of these techniques are provided in the U.S. EPA publication,
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
Forms. They are also briefly described below. A more detailed discussion including examples
of selected calculation techniques is presented in Appendix B. U.S. EPA does not require you to
conduct additional sampling or testing for EPCRA Section 313 reporting; however, you are
required to use the best, readily available information to determine the method that will result in
the most accurate estimate. For example, it may not be appropriate to use emission factors or
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engineering calculations if more accurate data, such as stack testing results, are available. You
are required to identify the primary method used for each estimation.
Many potential sources of data exist for these (and other) methods of developing
estimates. Table 4-2 presents potential data sources and the estimation methodology in which
they are most likely to be used. Based on site-specific knowledge and potential data sources
available, you should be able to determine the best method for calculating each release and other
waste management activity quantity.
Once all potential release and other waste management activity sources, types, and
estimation methods have been determined, an estimate for each EPCRA Section 313 chemical
and chemical category can be developed corresponding to the elements on Form R.
Table 4-2
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data
• Air permits
* Continuous emission monitoring
• Effluent limitations
• Hazardous waste analysis
• Industrial hygiene monitoring data
• NPDES permits
• Outfall monitoring data
• pH for acids and bases
• POTW pretreatment standards
• RCRA permit
• Stack monitoring data
• New Source Performance Standards
• Title V permit data
Emission Factors
Mass Balance
• Air emissions inventory
• Hazardous material inventory
• Hazardous waste manifests
• MSDSs
• Pollution prevention reports
• Spill event records
• Supply and purchasing records
AP-42 chemical specific emission factors
Facility or trade association derived chemical-
specific emission factors
Engineering Calculations
* Facility non-chemical specific emission factors.
• Henry's Law
• Raoult's Law
• SOCMI* or trade association non-chemical
specific emission factors
• Solubilities
• Volatilization rates
*Synthetic Organic Chemicals Manufacturing Industry.
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4.1.4.1 Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for
developing chemical release and other waste management activity quantity estimates. Your
facility may be required to perform monitoring under provisions of the Clean Air Act (CAA),
Clean Water Act (CWA), RCRA, or other statutory or regulatory requirements. If so, data should
be available for developing estimates. Data may have also been collected for your facility
through an occupational health and safety assessment. If only a small amount of direct
measurement data is available or if you believe the monitoring data are not representative, you
must decide if another estimation method would give a more accurate result.
Example - Monitoring Data
Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in the
discharge is 2 mg/L. The wastewater treatment facility processed 1.5 million gallons of water during the year.
The treated wastewater is discharged to an off-site POTW. The amount of copper transferred off site to the
POTW (for Sections 6.1 and 8.1 of the FormR) is estimated as follows:
Amount of copper transferred
= (2 mg/L) x [ i 1 x [ I*? 1 x I 1 1 x ^ 500 000 j/ \
^ 1,000 mgj ( 453.59 g) ( 0.2642 galj
= 25 Ib/yr
This quantity should be reported in Part II, Sections 6.1 and 8.1 of the 1999 Form R since the discharged
chemical is a metal. Had the discharged EPCRA Section 313 chemical not been a metal it should be reported in
Part II, Section 6.1 and 8.7 of the 1999 Form R.
COMMON ERROR - Treatment Efficiencies
Vendor data on treatment efficiencies often represent ideal operating conditions. You should adjust such data to
account for downtime and process upsets during the year that would result in lower efficiencies. Remember that
efficiencies reported by vendors are often general and may not apply to specific chemicals. For example, an
incinerator or flare may be 99.99% efficient in destroying certain organic chemicals, but will have a 0% efficiency
in destroying metals.
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4.1.4.2
Mass Balance (code C)
A mass balance involves determining the amount of an EPCRA Section 313
chemical or chemical category entering and leaving an operation. The mass balance is written as
follows:
Input + Generation = Output + Consumption
where:
Input refers to the materials (chemicals) entering an operation. For
example, chlorine added to process water as a disinfectant would be
considered an input to the water treatment operation.
Generation identifies those chemicals created during an operation
(manufactured, including coincidental manufacturing). For example,
when nitrogen sources are used in biological wastewater treatment
systems, nitrate compounds and additional ammonia may be coincidentally
manufactured.
Output refers to the materials (chemicals) leaving an operation by various
avenues. Output (avenues) may include on-site release and other on-site
waste management activities; transfers off site for recycling, energy
recovery, treatment, storage, or disposal; or the amount of chemical that
leaves with the final product.
Consumption refers to the amount of chemical converted to another
substance during the operation (i.e., reacted). For example, nitric acid
would be consumed by neutralization during wastewater treatment.
The mass balance technique may be used for manufactured, processed, or
otherwise used EPCRA Section 313 chemicals or chemical categories. It is typically most useful
for otherwise used chemicals that do not become part of the final product, such as catalysts,
solvents, acids, and bases. For large input and output streams, a mass balance may not be the
best estimation method because slight uncertainties in mass calculations can yield significant
errors in the release and other waste management quantity estimates.
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Example - Mass Balance
A facility otherwise uses a volatile EPCRA Section 313 chemical as a refrigerant and adds 20,000 pounds to the
refrigeration system (to make up for system losses). The chemical is released to the air from relief vents during
system filling operations and from leaks in valves and fittings. During system maintenance, the lines are bled
directly into water and the system is vented to the air. Monitoring data of the wastewater, including chemical
concentrations and wastewater throughput, indicate that 1,200 pounds of the chemical were discharged to the
wastewater. The remaining losses are assumed to be fugitive air releases and are estimated as follows:
Fugitive air releases of the EPCRA Section 313 chemical
Amount input (Ib/yr) - Amount released to wastewater (Ib/yr)
20,000 Ib/yr -1,200 Ib/yr
18,800 Ib/yr
COMMON ERROR - Mass Balances for Otherwise Used Chemicals
Facilities often do not account for the entire quantity of EPCRA Section 313 chemicals or chemical categories
that are otherwise used. Many EPCRA Section 313 chemicals and chemical categories in rubber and plastics
manufacturing are classified as otherwise used. Such chemicals and chemical categories may or may not leave the
facility with the product. For those instances where the EPCRA Section 313 chemical or chemical category does
not leave the facility in the product, all throughput may be lost during processing through on-site releases to air,
water, or land, or it may be shipped off site for further waste management activities. Thus, the entire throughput
is often reportable on Form R as release and other waste management activities to various media. Be sure to
consider the entire throughput in these circumstances and partition it as appropriate. A mass balance may be the
best starting point to estimate the release and other waste management quantities.
4.1.4.3 Emission Factors (code E)
An emission factor is a representative value that attempts to relate the quantity of
a chemical or chemical category released with an associated activity. These factors are usually
expressed as the weight of chemical or chemical category released divided by a unit weight,
volume, distance, or duration of the activity releasing the chemical (e.g., pounds of chemical
released per pounds of product produced). Emission factors, commonly used to estimate air
emissions, have been developed for many different industries and activities. You should
carefully evaluate the source of the emission factor and the conditions for its use to determine if
it is applicable to the situation at your facility. If there are more than one EPA published
emission factors, you should determine which is the most appropriate for your operations and
document your rationale.
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The most widely known and used source for emission factors is U.S. EPA's
publication Compilation of Air Pollutant Emission Factors (AP-42). Volume I of AP-42
contains information on over 200 stationary source categories, including process descriptions and
potential sources of air emissions from these processes. Methodologies for estimating the
quantity of air pollutant emissions from these sources are presented as Emission Factors. For
EPCRA Section 313 purposes only CHEMICAL-SPECIFIC emission factors can be reported as
Code "E" - Emission Factor in Part n, Section 5, Column B, Basis for estimate, of the Form R.
AP-42 contains emission factors for individual chemicals and for the chemical group Volatile
Organic Compounds (VOCs). The VOC emission factors are NOT chemical specific and when
used must be reported in Column B as Code "O" - Engineering Calculations. Each chapter in
Volume I covers a major industry or source category. Of special interest to rubber and plastic
manufacturing facilities would be Chapter 4: Evaporation Loss Sources, in particular Sections
4.2.2.14: Surface Coating of Plastic Parts for Business Machines; 4.4: Polyester Resin Plastic
Product Fabrication; and 4.12: Manufacture of Rubber Products (Section 4.12 is currently in draft
status), Chapter 6: Organic Chemical Process Industry, in particular Sections 6.6: Plastics and
6.10: Synthetic Rubber, and Chapter 7: Liquid Storage Tanks.
AP-42 can be accessed at the following Internet site:
• http://www.epa.gov/ttn/chief/ap42.html
In an effort to provide current emissions data in an easy-to-access format, U.S.
EPA has prepared a CD-ROM entitled Air CHIEF (Air ClearingHouse for Inventories and
Emission Factors). The Air CHIEF CD-ROM is updated annually and is available from the
Government Printing Office and can be ordered from their Web site. In addition to AP-42, the
Air CHIEF CD-ROM contains the Factor Information Retrieval (FIRE) data system, a database
management system containing U.S. EPA's recommended emission estimation factors for
criteria and hazardous air pollutants. The CD-ROM also contains installable copies of software
programs for air emission estimation models such as "TANKS" for VOC emission from storage
tanks; "WATERS" for air emissions from wastewater systems; and "CHEMDAT8" for VOC
emissions from Treatment, Storage, and Disposal Facility (TSDF) processes. Additional
information on Air CHIEF and the CD-ROM is available at:
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• http://www.epa.gov/ttn/chief/airchief.html
Your facility may have developed non-chemical-specific emission factors for
fugitive or stack emissions based on stack tests for various air permits. Be sure to consider these
emission factors if appropriate. However, if such factors are used, they are considered
"engineering calculations" for the purposes of EPCRA Section 313 reporting.
Example - Emission Factors
Emission factors have been developed for air releases of fuel constituents and combustion products from boiler
operations. AP-42 lists a range of formaldehyde emission factors when No. 6 fuel oil is consumed:
0.024 to 0.061 Ib formaldehyde generated/103 gal No. 6 fuel oil fired.
Assuming a facility met reporting requirements for formaldehyde, the facility operating a boiler using No. 6 fuel
oil could use the above emission factor to determine the amount of formaldehyde generated and subsequently
released to the air. If 1,000,000 gallons of No. 6 fuel oil is used during a reporting year, the amount of
formaldehyde generated would be between:
(0.024 lb/103 gal) x (1,000,000 gal) and (0.061 lb/103 gal) x (1,000,000 gal)
= 24 and 61 Ib of formaldehyde generated
If there are no engineering controls or air pollution control devices that would destroy or remove the
formaldehyde, this quantity should be reported in Part II, Sections 5.2 and 8.1 of the 1999 FormR.
NOTE: No. 6 fuel oil contains other EPCRA Section 313 chemicals and chemical categories and EPCRA Section
313 chemicals and chemical categories may also be coincidentally manufactured during combustion. All should
be considered for EPCRA Section 313 reporting.
4.1.4.4 Engineering Calculations (code O)
Engineering calculations are assumptions and/or judgments used to estimate
quantities of EPCRA Section 313 chemicals and chemical categories released or otherwise
managed as waste. The quantities are estimated by using physical and chemical properties and
relationships (e.g., Ideal Gas law, Raoult's law) or by modifying an emission factor to reflect the
chemical properties of the chemical in question. Engineering calculations rely on the process
parameters; you must have a thorough knowledge of your facility operations to complete these
calculations.
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Engineering calculations can also include computer models. Several computer
models are available for estimating emissions from storage tanks, landfills, water and wastewater
treatment, and other processes. See discussion in Section 4.1.4.3 for details on these models and
how they may be accessed.
Non-chemical-specific emission factors, Synthetic Organic Chemicals
Manufacturing Industry (SOCMI) emission factors, industry-determined emission factors for
processes or equipment, and site-specific emission factors also can be used, but must be
classified as "Engineering Calculations" for EPCRA Section 313 reporting.
Examples - Engineering Calculations
Stack monitoring data are available for xylene but you are required to report for toluene. Toluene is used in the
same application as xylene at your facility and the concentrations of the chemicals in the liquid feedstock are
approximately the same. You can estimate the emissions of toluene by adjusting the monitoring data of xylene by
a ratio of the vapor pressure for xylene to toluene. This example is an engineering calculation based on physical
properties and process operation information:
From facility stack monitoring data, you determine that an estimated 200 Ib of xylene are released as air emissions
during the reporting year. Toluene is also present in the air emissions, but not monitored. The stack operates at
approximately 20°C. Based on literature data, the vapor pressure at 20°C for toluene is 22 millimeters of mercury
(mmHg) atmospheres and for xylene is 6 mmHg. Using a ratio of the vapor pressures, the amount of toluene
released as air emissions from the stack can be calculated:
X Ib/yr toluene = 22 mmHg (vapor pressure of toluene^
200 Ib/yr xylene 6 mmHg (vapor pressure of xylene)
X Ib/yr toluene = (22 mmHg^ (1.44 arm toluene^)
(6 mmHg xylene)
Completing the calculation, you determine the facility determines that 730 Ibs of toluene were released as stack
air emissions during the reporting year. The quantity of toluene released should be reported in Section 5.2 of the
1999 Form R.
4.1.4.5 Estimating Release and Other Waste Management Quantities
Once all sources, types, and appropriate estimation methodologies have been
identified, you can estimate the release and other waste management activity quantities of
EPCRA Section 313 chemicals or chemical categories for each element of the Form R. The
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recommended approach is that you estimate amounts from all sources at your facility to each type
as identified by the elements of Form R. Table 4-3 presents a work sheet that may be helpful in
compiling this information.
If you prepare a Form R, you must also enter on-site treatment information in
Section 7 A, including the code for each treatment method used, the destruction and removal
efficiency for the EPCRA Section 313 chemical or chemical category in the treated waste stream,
and the concentration of the EPCRA Section 313 chemical or chemical category in the influent to
treatment. You should report treatment methods that do not actually destroy or remove the
chemical or chemical category by entering "zero (0)" for removal efficiency. Similarly, on-site
energy recovery methods and on-site recycling methods must be reported in Sections 7B and 7C,
respectively.
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Table 4-3
Release and Other Waste Management Quantity Estimation Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared by:
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses, Spills, Surface Impoundments
Total =
5. land 8. lor 8.8
5. land 8. lor 8. 8
5. land 8. lor 8.8
5. land 8. lor 8. 8
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
5. 2 and 8.1 or 8. 8
5.2 and 8. lor 8.8
5.2 and 8. lor 8. 8
5.2 and 8. lor 8.8
5. 2 and 8. lor 8. 8
RECEIVING STREAM/WATER BODY DISCHARGE
Stormwater Discharge
On-Site Treatment Plant Discharge
Total =
5. 3 and 8.1 or 8. 8
5. 3 and 8. lor 8.8
5. 3 and 8.1 or 8. 8
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II - V Wells
Total =
5. 4 and 8. lor 8. 8
5.4 and 8. lor 8.8
5. 4 and 8. lor 8. 8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
ON-SITE LAND
RCRA Subtitle C Landfill
Other Landfill
Land Treatment/Application Farming
Surface Impoundment
Other Disposal
Total =
ON-SITE ENERGY RECOVERY
Industrial Kiln
Industrial Furnace
Industrial Boiler
Other Energy Recovery Methods
Total =
ON-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Acid Regeneration
Other Reuse or Recovery
Total =
ON-SITE TREATMENT
Air Emissions Treatment
Biological Treatment
Chemical Treatment
Incineration/Thermal Treatment
Physical Treatment
Solidification/Stabilization
Total =
5. 5 and 8. lor 8. 8
5. 5 and 8. lor 8.8
5. 5 and 8.1 or 8. 8
5.5 and 8. lor 8.8
5. 5 and 8.1 or 8. 8
5. 5 and 8. lor 8.8
8.2
8.2
8.2
8.2
8.2
8.4
8.4
8.4
8.4
8.4
8.6
8.6
8.6
8.6
8.6
8.6
8.6
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
Off-Site Location
(name)
OFF-SITE DISPOSAL
Solidification/Stabilization (metals and
metal compounds only)
Amount of metal and metal compounds to
POTW
Wastewater Treatment (excluding
POTWs) metals and metal compounds
only
Underground Injection
Landfill/Surface Impoundment
Land Treatment
Other Land Disposal
Other Off-Site Management
Total =
6.2 and 8. lor 8. 8
6.1 and 8. lor 8. 8
6. 2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8. 8
OTHER AMOUNTS SENT OFF SITE
Amounts sent for storage
Amounts sent for unknown waste
management practice
Total =
6.2 and 8. lor 8. 8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
OFF-SITE TREATMENT
Solidification/Stabilization
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Wastewater Treatment (to POTW
excluding metals and metal compounds)
Wastewater Treatment (excluding POTW
and metal and metal compounds)
Sent to Waste Treatment Broker
Total =
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.1 and 8. 7 or 8. 8
6.2 and 8.7 or 8.8
6.2 and 8. 7 or 8. 8
6.2 and 8.7 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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Table 4-3 (Continued)
OFF SITE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1999 version)
Off-Site Location
(name)
OFF-SITE ENERGY RECOVERY
Off-Site Energy Recovery
Sent to Energy Recovery Broker
Total =
6.2 and 8.3 or 8.8
6.2 and 8.3 or 8.8
6.2 and 8. 3 or 8. 8
OFF-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Sent to Recycling Waste Broker
Total =
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not
associated with production process.
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4.2 Determination of Release and Other Waste Management Activity Quantities
from Rubber and Plastic Manufacturing Processes
Rubber and plastics manufacturing is comprised of various processes and
activities. This section will present specific information on processes, release and other waste
management types and sources, and sample calculations for estimating quantities released and
otherwise managed as waste, from these activities. Four processes, and their corresponding use
of typical EPCRA Section 313 chemicals, will be discussed:
• Synthetic rubber manufacturing and rubber processing (Section 4.2.1);
• Rubber product manufacturing (Section 4.2.2);
• Tire manufacturing (Section 4.2.3); and
• Plastic product manufacturing (Section 4.2.4).
Each of the above processes has multiple unit operations many of which include
EPCRA Section 313 chemicals. For instance: synthetic rubber manufacturing activities include
polymerization during which chemicals such as catalysts, activators, and initiators are processed
or otherwise used in the reactors; rubber processing chemical activities include coagulation and
cleaning operations; at rubber product and tire manufacturing sites, operations such as building,
vulcanizing, and finishing operations include chemical activities using reinforcing materials and
adhesives, vulcanizing agents and accelerators, and finishing chemicals, which may contain
EPCRA Section 313 chemicals; compounding and mixing operations at plastic product
manufacturing facilities may include the use of EPCRA Section 313 chemicals in foaming
agents, catalysts, lubricants and plasticizers; finally, finishing operations may include chemical
activities such as coating, dyeing, and/or spraying.
Historical data show that the primary EPCRA Section 313 chemicals reported
from the manufacture of rubber and plastic products are solvents. The most commonly
encountered solvents include acetone, toluene, methyl ethyl ketone (MEK), 1,1,1 -
trichloroethane, and dichloromethane. Large quantities of metals including copper, lead and lead
compounds and zinc compounds are also commonly reported.
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4.2.1 Synthetic Rubber Manufacturing and Rubber Processing
Rubber manufacturing and processing facilities produce synthetic rubber and
process natural and synthetic rubber into material for use in the manufacturing of rubber
products. The major synthetic rubber manufacturing operations are monomer inhibitor removal,
polymerization, distillation, steam stripping, and monomer separation/recycling. Synthetic
rubber manufacturing facilities may use an emulsion polymerization process or a solution
polymerization process. The major difference is that solution polymerization uses organic
solvents, such as cyclohexane, toluene, and n-hexane and has an additional solvent recovery step.
Therefore it does not generate wastewater. Emulsion polymerization uses a soap and water
solution to add activators, catalysts, modifiers, and imitators to the monomer mix. This results in
the generation of wastewater from this process. Synthetic and natural rubber processing steps
may include coagulation and screening, rinsing and dewatering, cutting and rolling, and drying
steps. The final product is a strong elastic material that can be used to manufacture items such as
tires, belts, hoses, and a myriad of other rubber products.
Step 1: Prepare a Process Flow Diagram
Figure 4-3 shows a typical synthetic rubber manufacturing emulsion process and
Figure 4-4 depicts the differences between the emulsion polymerization process and the solution
polymerization process. Figure 4-5 shows a basic process flow diagram for processing the
natural and synthetic rubber to prepare it for the manufacturing of rubber products.
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Fugitive and Stack Air
Inhibited Monomer •
Caustic •
Uninhibited Monomer •
Soap Solutions; Activators; •
Catalysts; Modifiers;
Initiators (Solutions)
Monomer
Inhibitor
Removal
Wastewater
Container Residue
Uninhibited Monomer
Process Feed
Polymerization
Reactors
Polymer Feed
Vacuum
Distillation
Polymer Feed
Steam
Stripping
Fugitive and Stack Air
^ Wastewater/Slurries
Recycled
Monomer
Monomer
Separation
Unpolymerized
Monomer
Unpolymerized Monomer
Fugitive and Stack Air
^ Wastewater
Polymer (Synthetic Rubber)
Process Stream
Potential Type of EPCRA Section 313 Chemical Release or Other Waste Management
Figure 4-3. Typical Emulsion Process for Manufacturing Synthetic Rubber
(Ref: U.S. EPA, Title III Section 313 Release Reporting Guidance, Estimating Chemical Releases from Rubber
Production and Compounding (EPA 560/4-88-004q). March 1988.)
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Emulsion Process
Monomer Process Feed/ •
Recycle Feed
WATER •
Soap Solutions; Activators;
Catalysts; Modifiers;
Initiators (Solutions)
Emulsion
Polymerization
Fugitive or Stack Air
^- Wastew ater/Slurries
Polymer Process Stream
Solution Process
Monomer Process Feed/ •
Recycle Feed
ORGANIC SOLVENTS •
Activators; Catalysts;
Modifiers; Initiators (Solutions)
Processed Solvents
{Typically Cyclohexane,
Toluene, or n-Hexane}
Solution
Polymerization
Recycled Solvents
"^ Spent Solutions
Polymer Process Stream
^Fugitive or Stack Air
Process Stream
Potential Type ofEPCRA Section 313 Chemical Release or Other Waste Management
Figure 4-4. Comparison Between Emulsion and Solution Polymerization Process
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Antioxidant
Natural & Synthetic
Rubber
Coagulating Brine/
Coagulating Sulfuric Acid
Carbon Black/Extender Oil
Latex
Storage
Fugitive and Stack Air
Rubber Feed
Coagulation &
Screening
Wastewater/Slurries
Rubber Feed
PROCESSING
STEPS
(Coagulation and Screening
Rinsing & Dewatering
Cutting and Draining,
Rolling, etc.)
Wastewater
Solid Waste
Processed Rubber
Drying &
Baling
>• Fugitive and Stack Air
^ Solid Waste
Finished Processed Rubber
{Natural or Synthetic}
Process Stream
Potential Type ofEPCRA Section 313 Chemical Release or Other Waste Management
Figure 4-5. Processing Rubber to Prepare for Product Manufacture
(Ref: U.S. EPA, Title III Section 313 Release Reporting Guidance, Estimating Chemical Releases from
Rubber Production and Compounding (EPA 560/4-88-004q). March 1988.)
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
EPCRA Section 313 chemicals in air may come from sources such as absorber
vents, pumps, relief valves, and fittings located throughout the facility. Loading/unloading and
transfer operations are sources of fugitive air releases. Fugitive emissions most likely occur
during inhibitor removal and during the addition of any volatile EPCRA Section 313 chemical
from storage tanks. Major unit operations that are potential sources of EPCRA Section 313
chemicals to air include monomer recovery, solvent recovery for solution polymerization, and
drying operations. Sources such as storage tank and reactor vents may generate stack air
emissions of EPCRA Section 313 chemicals. Air pollution control devices located on equipment
vents, such as solvent recovery units, monomer separators, and polymerization reactors may also
be a source of stack air emissions.
AP-42 devotes an entire chapter, Chapter 7: Liquid Storage Tanks, to estimating
emissions from storage tanks. The equations are presented for various tank types including:
fixed roof; external and internal floating roof; covered floating roof; variable vapor space; and
low and high pressure. In addition to physical parameters of the tank, the equations consider
properties of the liquid including: vapor pressure; molecular weight; temperature (daily
maximum and minimum and average); meteorological conditions including temperature; and
solar absorbance. The equations can be complex and labor intensive; therefore, U.S. EPA has
developed a software program called "TANKS" that computes estimates of volatile organic
compound emissions from fixed and floating roof storage tanks. For purposes of EPCRA
Section 313 reporting all emission estimates calculated using the TANKS program are
considered stack emissions and reported in Part II, Section 5.2 of the Form R. TANKS can be
downloaded from the U.S. EPA web page:
• http://www.epa.gov/ttn/chief/tanks.html.
Potential liquid sources of EPCRA Section 313 chemicals include equipment
leaks and process operations during monomer inhibitor removal, polymerization, steam stripping,
monomer separation, rubber rinsing and draining, coagulation and screening and final cleaning
4-35
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and finishing. Spent solutions such as polymer reactor slurries may contain EPCRA Section 313
chemicals. Wastewater or liquid slurries may also come from wastewater treatment operations,
rinsing of shipping containers, utility operations, or equipment cleaning (e.g., reactor cleaning).
You should also consider spill clean-ups and housekeeping practices when determining liquid
sources of EPCRA Section 313 chemicals.
Solid sources of EPCRA Section 313 chemicals include disposal or cleaning of
"empty" shipping containers; residue in shipping containers can be estimated using values listed
in Table 4-1. Materials from processing (e.g., cutting), drying and baling operations may contain
EPCRA Section 313 chemicals. Reactor cleaning may also generate solid or slurry materials
containing EPCRA Section 313 chemicals. Off-specification materials and suspended solids in
process wastewater are two other sources of solid wastes that may contain EPCRA Section 313
chemicals.
COMMON ERROR - Direct Reuse vs. Recycling
The direct reuse of an EPCRA Section 313 chemical does not need to be included in the amount reported in
Part II, Section 8 of Form R. However, recycling of the chemical should be included.
Step 3: Identify Release and Other Waste Management Activity Types
EPCRA Section 313 chemicals may be released or otherwise managed as waste
on site or transferred off site through wastewater, fugitive and stack air, sludges and slurries, and
other materials. Fugitive and stack air emissions could include volatile compounds (e.g.,
solvents) and particulates (e.g., dust) from process or transfer operations.
EPCRA Section 313 chemicals such as monomers may become airborne during
unloading and transfer at the inhibitor removal step. Volatile chemicals may be emitted or
collected at process vents and control devices; solvents such as toluene, cyclohexane, and/or
n-hexane are typically used during solution polymerization and may be vented during solvent
recovery.
4-36
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Wastewater types could include off-site transfer to a POTW, on-site treatment
and/or underground injection.
Solid wastes can be transferred off site for recycling or reuse and/or treatment and
disposal.
Table 4-4 summarizes the typical release and other waste management activity
sources and types and lists the typical EPCRA Section 313 chemicals associated with each for
rubber manufacturing and processing operations.
4-37
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Table 4-4
Sources and Types of EPCRA Section 313 Chemicals for Rubber
Manufacturing and Processing
Unit Operation/
Source Activity
Monomer Inhibitor
Removal
Emulsion Polymerization
Solution Polymerization
Monomer Separation
(Includes Distillation and
Steam Stripping)
Latex Storage
Coagulation and Screening
Rinsing and Dewatering
Cutting, Rolling and
Draining
Drying and Baling
Release and Other Waste
Management Types
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Fugitive and Stack Air
On-site land or off-site
disposal
Fugitive and Stack Air
Receiving stream or POTW
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Receiving stream or POTW
Receiving stream or POTW
On-site land or off-site
disposal
Fugitive and Stack Air
On-site land or off-site
disposal
Typical EPCRA Section 313 Chemicals
Monomers: 1,3-Butadiene, acrylic acid,
acrylonitrile, butyl acrylate, chloroprene,
epichlorohydrin, ethyl acrylate, methyl
methacrylate, ethylene, ethylene glycol, ethylene
oxide, propylene, styrene
Cobalt compounds, nickel compounds, titanium
tetrachloride, hydroquinone
Solvents: n-Hexane, cyclohexane, toluene
Catalysts, Modifiers, Initiators and Activators
Unpolymerized monomers (see monomer list
above)
Remaining solvents, monomers, antioxidants;
phenylenediamine
Spent slurries and solutions
Chemicals rinsed from rubber
Any EPCRA Section 313 chemicals incorporated
into products that are also present in rubber
material scraps
Monomers (see list above)
Off-specification product
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Due to the complex process of rubber manufacturing and processing, calculating
release and other waste management activity quantities often entails the use of multiple methods.
If direct monitoring data are not available, you may use a combination of emission factors, mass
balances, and engineering calculations to determine the reportable amount of an EPCRA
Section 313 chemical.
4-38
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Fugitive air emissions may occur during loading and unloading operations. The
amount of an EPCRA Section 313 chemical emitted can be calculated using emission factors
such as those in U.S. EPA's Compilation of Air Pollutant Emission Factors (AP-42), using
EPA's TANKS program, or using other engineering calculations. Emissions of EPCRA Section
313 solvents used as processing aids can be determined by mass balance calculations; it may be
appropriate to assume all solvents are emitted to the air if they are not expected to remain with
the product. You should then partition the air emissions between fugitive and stack. If an air
pollution control device is used, the efficiency of the system should be considered to determine
the quantity treated on site, and the quantity actually released. Emissions from these control
device systems should be considered stack emissions.
Air emission data may be available from process monitoring information (vent
flows and concentrations), air operating permits, or the technical literature. Available
information may be in the form of total Volatile Organic Compounds (VOC) and particulate
emissions. Engineering calculations and assumptions can be used with monitoring data or
emission factors to convert available information into chemical-specific estimates, as shown in
the following example.
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Example - VOC Emissions
(AP-42 emission factor for VOC and subsequent on-site treatment)
A monomer plant produces 40,000 tons of crumb emulsion latex annually. Measurement data are unavailable and
an accurate mass balance is difficult to perform because of the large input and output streams. The facility air
from the monomer plant is sent to a flare before release to the atmosphere. Based on vendor information and
facility test data, the flare destruction efficiency is assumed to be 90%. According to AP-42 emission factors,
total volatile organic emissions are approximately 5.2 pounds per ton of latex produced. Note that this is "non-
chemical-specific." Therefore, it is not considered an emission factor for EPCRA Section 313 purposes. Rather,
it should be reported as an engineering calculation. An occupational monitoring program at this plant indicated
that 1,3-butadiene concentrations in the ambient air were typically nine times greater than styrene concentrations.
Styrene and 1,3-butadiene make up the majority of the VOC emissions at this plant; therefore, you can assume
that the total amount of 1,3-butadiene and styrene in the air is 5.2 pounds per ton of latex. Based on the 9-to-l
ratio, the amount of 1,3-butadiene and styrene in the air can be calculated as follows:
Amount of 1,3-butadiene in air:
(40,000 tons latex) x (5.2 Ib VOC/ ton latex) x (90%) = 187,200 Ib
Amount of styrene in air:
(40,000 tons latex) x (5.2 Ib VOC/ ton latex) x (10%) = 20,800 Ib
Amount of 1,3-butadiene in stack emissions (Part II, Sections 5.2 and 8.1 of 1999 Form R):
(187,200 Ib) x (10%) = 18,720 Ib
Amount of styrene in stack emissions (Part II, Sections 5.2 and 8.1 of 1999 Form R):
(20,800 Ib) x (10%) = 2,080 Ib
Amount of 1,3-butadiene treated on site (Part II, Section 8.6 of 1999 Form R):
(187,200 Ib) x (90%) = 168,480 Ib
Amount of styrene treated on site (Part II, Section 8.6 of 1999 Form R):
(20,800 Ib) x (90%) = 18,720 Ib
The on-site waste treatment should be noted on the Form R as follows: in Part II, Section 7A. la, enter "A," in
Section 7A. Ib, enter"A01," in Section 7A. Ib, 2, enter "N/A;" in Section 7A.lc, enter"!," in Section 7 A. Id,
enter "90%," and in Section 7A. le, check the "yes" box.
Mass balance estimations are applicable to rubber manufacturing operations
because of the precision required when weighing out additives for the rubber recipe. Given
detailed information on chemical inputs and the quantity of a chemical retained in the product, a
facility can calculate the amount released and otherwise managed as waste. The following
example shows how a mass balance may be used to estimate EPCRA Section 313 chemicals
incorporated into the manufactured or processed rubber. Mass balances are also effective in
calculating quantities of otherwise used chemicals, such as catalysts, solvents, acids, and bases.
Because these chemicals are not incorporated into the final product, the quantity used will often
equal the quantity released and otherwise managed as waste. Engineering assumptions may then
be applied to determine the fate of these chemicals.
4-40
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Example - Use of Mass Balance in Synthetic Rubber Production
A synthetic rubber manufacturing facility produced 80,000 tons of polybutadiene during the reporting year.
Cobalt chloride, CoCl2, was used as a catalyst in the reaction process, and is the only use of a cobalt compound at
the facility. Purchasing and inventory records show 64,000 pounds of CoQ2 were processed during the year.
Analysis of the polybutadiene showed it contained an average of 170 ppm of cobalt.
Threshold estimates for metal compounds should be based on the weight of the entire compound while release
and other waste management quantity estimates should be based on the weight of the parent metal. Thus, for the
threshold determination, the amount of the cobalt compound, 64,000 pounds per year, exceeds the 25,000 pounds
per year processing threshold; therefore, an EPCRA Section 313 report must be submitted. For the release and
other waste management quantity estimation only the amount of the parent metal, cobalt, is considered.
Assuming the only two discharges of cobalt are as a component of the polybutadiene and in the equipment
cleaning wastewater, the amount in each stream can be estimated using a mass balance (code C) as follows:
[Atomic weight of Co = 59; molecular weight of CoCl2 = 130]
Amount of cobalt entering the process:
(64,000 Ib CoCl2) x (59 Ib Co/130 Ib CoCl2) = 29,046 Ib Co
Amount of cobalt in the polybutadiene:
(80,000 tons) x (2,000 Ib/ton) x (170 Ib Co /106 Ib polybutadiene)
= 27,200 Ib Co
Amount of cobalt in wastewater:
(29,046) - (27,200) = 1,846 Ib Co
Since the reportable amount of cobalt is greater than 500 pounds per year, a Form R must be prepared. If
untreated wastewater from the facility was discharged directly to a POTW, the facility would report 1,846 pounds
of cobalt in Section 6.1 of the Form R and include in Section 8.1. If pretreatment was provided on site and a
sludge was generated, the amount of cobalt released or otherwise managed as a solid waste would have to be
estimated as appropriate.
4.2.2 Rubber Product Manufacturing
Rubber product manufacturing is defined as the compounding and processing of
natural and/or synthetic rubber into a product. The unit operations involved may include
compounding of the raw material into the desired formulation, extrusion, calendering, injection
molding, building, vulcanization, and finishing operations. The compounding step mixes natural
and/or synthetic rubber with carbon black, oils, and other chemicals to produce a rubber with
product-specific qualities. EPCRA Section 313 chemicals may be introduced into the process as
processing aids, vulcanizing agents, activators, accelerators, age resistors, and fillers.
4-41
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Step 1: Prepare a Process Flow Diagram
Figure 4-6 shows a typical process flow diagram for rubber product
manufacturing. Depending on the product, forming steps may include calendering, extruding, or
injection molding operations.
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Vents or dust collection control devices used during compounding and mixing
operations are sources of EPCRA Section 313 chemicals in air. Fugitive dust emissions or spills
may be generated by storage of dry chemicals in open bins and weighing of chemicals before
mixing. Volatile solvent evaporation can occur via sources such as equipment cleaning and
molding operations. During vulcanization processes, EPCRA Section 313 chemicals can be
coincidentally manufactured and emitted to the air. Operations such as coating, grinding, and
cutting are also potential sources of releases and other waste management activities.
4-42
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Cooling Water
& Adhesives
Accelerators
<
Chemical
Storage
,
:
Compounding
& Mixing
i
Milling and
Calendering
i
r
i
i
Extruding
i
Coa
Applic
i
ting
ations
r
Cooling &
Cutting
i
r
Building
i
Vulca
(injection
i
lizing
molding)
i
*
Grinding
1 :-
--»
Fugitive and Stack Air
Container Residue
Fugitive and Stack Air
Wastewater
Solid Waste
Fugitive and Stack Air
Solid Waste
-K Fugitive and Stack Air
*• Wastewater
Fugitive and Stack Air
Solid Waste
Container Residue
Wastewater
Solid Waste
Fugitive and Stack Air
Solid Waste
Fugitive and Stack Air
Wastewater
Solid Waste
Fugitive and Stack Air
Wastewater
Solid Waste
T
Finished Rubber Product
Process Stream
Potential Type of EPCRA Section 313 Chemical Release or Other Waste Management
Figure 4-6. Typical Rubber Product Manufacturing
(Ref: U.S. EPA, Sector Notebook Project, Profile of the Rubber and Plastics Industry
(EPA 310-R-95-016), September 1995.)
4-43
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COMMON ERROR - Coincidental Manufacturing
Coincidentally manufactured chemicals are often overlooked when determining sources of EPCRA Section 313
chemicals. AP-42 lists Rubber Manufacturers Association emission factors for various process steps. These
factors can be used to calculate the amount of EPCRA Section 313 chemicals coincidentally manufactured. The
de minimis exemption only applies to coincidentally manufactured impurities present in products if it they remain
in the product for distribution into commerce. De minimis exemption, however, does not apply to EPCRA
Section 313 chemicals manufactured as byproducts, regardless of whether the byproduct is a result of waste
treatment.
Please note not all of the chemicals listed in AP-42 for various rubber processing steps may be introduced to the
process as raw materials in various mixtures. The facility must determine which reportable chemicals, if any, are
coincidentally manufactured.
Water discharges may be generated by direct contact heating and/or cooling,
vulcanizing, and equipment cleaning operations. Process water may include spent solutions or
rinsing water from various operations. Water used for spill clean-up or general housekeeping
such as equipment and area washdowns are potential sources of EPCRA Section 313 chemical
releases or other waste management activities. Wastewater may contain carbon black or
additives rinsed from the processing operations. Equipment sources include extruder cooling
conveyors and vulcanization equipment. Residual material from container cleaning operations is
also a source of water discharges.
Solid and other wastes or materials may be released or otherwise managed as
waste throughout the facility during compounding, forming, building, and finishing operations.
Equipment cleaning, collection of dust on dry filters (fabric filters and/or bag houses), and
residual material in "empty" shipping container disposal or cleaning may result in solid waste
generation. Residues in "empty" shipping containers can be estimated using the values in Table
4-1. Operations such as surface grinding generate dust that may then be controlled in a
baghouse, cyclone, or electrostatic precipitator; this collected material may then be disposed or
treated. Scorched or waste rubber sources can occur throughout the facility from mixing,
milling, calendering, molding, etc.
4-44
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Step 3: Identify Release and Other Waste Management Activity Types
Rubber product manufacturing releases and other waste management activity
types include stack and fugitive air emissions, water discharges, and solid wastes that are
managed on site or transferred off site. Table 4-5 summarizes the release and other waste
management activity sources and types and lists the typical EPCRA Section 313 chemicals
associated with each for rubber product manufacturing operations.
Table 4-5
Source and Types of EPCRA Section 313 Chemicals for
Rubber Product Manufacturing
Unit Operation/
Source Activity
Chemical Storage
Compounding and
Mixing
Milling and
Calendering
Extruding
Building
Vulcanizing
Grinding
Coating Application
Release and Other Waste
Management Activity Type
Fugitive and Stack Air
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and stack air, on-site or
off-site waste management
Typical EPCRA Section 313 Chemicals
Solvents in tanks and drums; empty bag residue
for zinc oxide and TMTD
Antimony compounds, carbon disulfide, dibutyl
phthalate, nickel compounds, zinc compounds
Coincidentally manufactured chemicals such as
hexane; zinc compounds in wastewater and
scrap rubber
Coincidentally manufactured chemicals such as
hexane; zinc compounds in wastewater and
scrap rubber
Toluene, MEK, and xylene
Vulcanizing agents: Lead compounds, selenium
compounds, zinc compounds
Accelerators: Diethanolamine, ethylene
thiourea, zinc compounds, lead compounds
Retardants: n-Nitrosodiphenylamine
Reaction products: Ammonia, carbon disulfide
Protective agents: Phenol, p-phenylenediamine,
zinc compounds
MEK, xylene, toluene, container residue
4-45
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Volatile chemicals (e.g., solvents) are often released to the atmosphere, but may
be controlled (e.g., by a scrubber) prior to release. Fugitive air particulates such as dusts from the
mixing and compounding area may be collected in a baghouse or other air pollution control
device; the collected dust is typically either disposed, reused or recycled. Dusts released to the
atmosphere such as zinc may also be washed away with storm water into a facility's discharge
point or wastewater treatment system.
The process wastewater generated at the facility may be treated on site, discharged
to surface waters, or transferred off site for treatment. Lubrication, hydraulic, and process oils
are typically transferred to an off-site location for waste management activities.
Solid and other wastes or material types include scrap and scorched rubber,
off-specification products, collected dust, rubber trimmings, and residue in shipping containers.
Solids and slurries may also be collected and subsequently disposed or waste managed from
equipment cleaning. Uncured rubber waste is often recycled on site, cured rubber waste may be
recycled or sold off site, and off-specification rubber may either be disposed of on or off site or
sold to other companies.
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
In lieu of site-specific data, air emission factors may be appropriate to determine
the amount of an EPCRA Section 313 chemical emitted to the air or generated during operations.
Section 4-12 of AP-42 lists chemical-specific emission factors for rubber product manufacturing
operations. Please note VOC emission factors are not chemical specific and their use must be
classified as engineering calculations (Code O) for EPCRA Section 313 reporting purposes.
Mass balances are also often appropriate for use in determining the amount of
EPCRA Section 313 chemical released or otherwise managed as waste. Compounded rubber
mixtures typically have set concentrations for the chemicals added. The total amount of
chemical processed during the year can be determined by knowing the annual throughput of the
rubber mixture, along with its corresponding chemical compound recipe. The quantities used but
4-46
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not incorporated into the final product can be similarly calculated. Engineering assumptions and
calculations can then be used to determine the release or other waste management activity
quantity and medium type for each EPCRA Section 313 chemical.
A potential for double counting of VOC emissions exists when compiling air
emission data for a rubber manufacturing facility using a combination of mass balance and
emission factor calculations. It arises in the use of solvents for the application of cements,
solvent tackifiers, and release agents in the manufacture of rubber products, including tires. The
mass balance calculation often assumes 100% loss of the solvent at the time of application to the
rubber substrate. Anecdotal evidence suggests that as much as 5% of the solvent applied to the
surface of the rubber may migrate into the rubber and show up later in the process as a volatile
emission. Caution should therefore be exercised when compiling a facility wide solvent
emission inventory that combines the use of mass balance and emission factor calculations.
(From: Draft of Chapter 4.12 "Manufacture of Rubber Products" of AP-42 currently under
review).
The following example shows a mass balance calculation for a metal compound
processed as part of a rubber mixture.
4-47
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Example - Estimating Quantities of Metal and Metal Compounds Using Mass Balance
A rubber product manufacturing facility prepares a mixture by adding chemicals to the synthetic rubber received
from a rubber processing plant. One of the chemicals, zinc oxide (ZnO), is added such that the final concentration
is 2.5% by weight. A careful review of the MSDS information for all the other additives indicates no other
EPCRA Section 313 chemicals or compounds are present. Production records show 2,000 tons of the rubber
mixture was processed during the reporting year. Inventory and purchasing records reveal the facility had 10,000
pounds of ZnO on hand at the beginning of the year, 100,000 pounds were purchased during the year, and 5,000
pounds remained at the end of the year. The threshold determination for this processed chemical is based on the
entire weight of the zinc compound.
Amount of ZnO processed:
Beginning inventory + Purchased amount - Final inventory = Amount processed
10,000 pounds + 100,000 pounds - 5,000 pounds = 105,000 pounds
This amount exceeds the processing threshold of 25,000 pounds and an EPCRA Section 313 report must be
prepared.
Only the amount of the parent metal, zinc (Zn), should be included in the release and other waste management
amount estimation. The following mass balance can be used for this determination:
[Atomic weight of Zn = 65.4; molecular weight of ZnO = 81.4]
(Zn released or otherwise managed as waste) = (amount of Zn processed) -
(amount of Zn in product)
Amount of ZnO in product =
(2,000 tons product) x (2,000 Ib/ton) x (2.5% ZnO)
= 100,000 pounds ZnO
Amount of ZnO released or otherwise managed =
105,000 pounds processed -100,000 pounds in product = 5,000 pounds ZnO
Amount of Zn released or otherwise managed =
(5,000 pounds ZnO) x (65.4 pounds Zn/81.4 pounds ZnO) = 4,000 pounds Zn
This quantity of zinc should be partitioned to the applicable sections of the Form R (Part II, Sections 5, 6 and 8 of
1999 Form R) for zinc compounds as appropriate.
Note that, since the combined annual reportable amount exceeds 500 pounds, the facility is not eligible for the
Form A and a Form R must be submitted.
COMMON ERROR - Consumed Chemicals
Be sure to consider a consumption term in your mass balance. Chemicals added for rubber product
manufacturing may be consumed or reacted during the process. For example, an accelerator added to the rubber
mixture may react during vulcanization. Some or all of the accelerator may be consumed during the process.
Knowledge of the chemical reactivity and facility operations can help you determine the extent that an EPCRA
Section 313 chemical has been consumed.
4-48
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Monitoring data and engineering calculations may also be used to determine the
amount of an EPCRA Section 313 chemical released or otherwise waste managed. Typical
examples of monitoring data may be from stack test results for compliance with air permits or
from testing wastewater discharge or transfer points for NPDES permits. Knowledge of facility
operations may be used with monitoring data to perform engineering calculations. For example,
sulfuric acid aerosols may be coincidentally manufactured in facility cooling towers, storage
tanks, or boiler stacks. Monitoring of sulfuric acid or sulfur trioxide (SO3), which reacts with
water to form sulfuric acid, would allow a facility to determine how much of the acid aerosol is
generated. The following example demonstrates the calculation for the coincidental manufacture
of sulfuric acid aerosols.
4-49
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Example - Coincidental Manufacture of Sulfuric Acid Aerosols
Detailed information on reporting for sulfuric acid aerosols can be found in U.S. EPA's EPCRA Section 313,
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms
of any particle size), EPA-745-R-97-007, November 1997, Updated March 3, 1998 (see Appendix C). The
example below shows how a facility may determine the amount of sulfuric acid aerosol coincidentally
manufactured and the subsequent release and other waste management activity quantity. All sulfuric acid
produced within the stack, including the gas and the mist, falls under the EPCRA Section 313 definition of a
sulfuric acid aerosol.
A rubber products plant has oil-fired boilers on site, which burn approximately 3,000,000 gallons of No. 6 fuel oil
annually. All boiler stack emissions are controlled by scrubbers that are 95% efficient for removal of sulfuric
acid (H2SO4). Section 3.1.7 of the above referenced document provides data on the typical sulfur content of
various types of fuel oil, and an emission factor to determine the amount of H2SO4 generated by the combustion of
each gallon of oil.
Fuel oil No. 6 typically contains 3.97% sulfur (Appendix C). The H2SO4 emission factor for industrial boilers for
uncontrolled combustion of fuel oil is:
(0.00245) x (weight percent of sulfur) = pound of H2SO4/gallons of fuel oil burned
Thus, for this facility, the amount of H2SO4 coincidentally manufactured is:
= (0.00245) x (3.97; weight % sulfur) x (3,000,000 gal/year; fuel oil burned)
= 29,180 pounds/year
The amount of sulfuric acid aerosol generated on site exceeds the manufacturing threshold of 25,000 pounds per
year; therefore an EPCRA Section 313 report must be submitted. The quantity of sulfuric acid aerosol that should
be reported includes any release or other waste management activity quantities. The amount of sulfuric acid
aerosol treated by the scrubber is:
H2SO4 treated:
= (29,180 pounds) x (95% scrubber efficiency)
= 27,721 pounds
H2SO4 released as stack air emissions:
= (29,180 pounds) x (5% scrubber inefficiency)
= 1,459 pounds
The 27,721 pounds removed by the scrubber is converted to a non-aerosol form and is therefore considered to be
treated. Part II, Section 7 should be completed as appropriate and the quantity treated for destruction should be
reported in Part II, Section 8.6. The quantity of stack air emissions and H2SO4 aerosols should be reported in
Sections 5.2 and 8.1
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4.2.3 Tire Manufacturing
Tire manufacturing is considered a special segment of rubber product
manufacturing. It has many of the same processing steps as other rubber products, with the
major variations in the extrusion and building steps. Many rubber components are used during
building operations to form tires.
Step 1: Prepare a Process Flow Diagram
Figure 4-7 shows a typical process flow diagram for tire manufacturing.
Operations for tire manufacturing that are not included in other rubber product manufacturing are
the rubber coating of bead wires in an extruding process, rubber coating of fabrics in a
calendering process, assembly of the final product on a tire-building machine, lubrication of the
tires (known as green tire spraying), cementing processes, and scrap tire disposal.
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
All of the sources listed in rubber product manufacturing also apply to tire
production (see Section 4.2.2). Additional consideration should be taken for sources of VOC
emissions from processes unique to tire manufacturing and the generation of scrap tires. EPCRA
Section 313 chemicals, specifically solvents, may be emitted during building, cementing, and
green tire spraying operations. Sources may include process equipment vents, control devices,
valves, or general room air vents. Operations such as coating, grinding, and cutting can also
result in releases and other waste management activities of dusts and excess rubber material
containing EPCRA Section 313 materials. Off-specification rubber or tires and scrap materials
may be generated during extruding, calendering, cutting, building, and vulcanization operations.
4-51
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s-i i 7 T-T j
Chemical t1 eed
n in 11
Processed Rubbers
Beads (Extruding)
'
n , . , . .
Fabric (Calendaring)
Contact Cooling
Water
Reinforcing Materials
& Adhesives
Vulcanizing Agents;
,, , .
Accelerators
^ Chemical P-Fugitive and Stack Air
Storage
^- Container Residue
i >• Fugitive and Stack Air
Compounding ^ ,T7
~* & Mixing » Wastewater
i ^. Solid Waste
i >• Fugitive and Stack Air
PROCESSING STEP
(Extruding Beadwires,
Milling Tread and Sidewalls r ^ Wastewater/Slurnes
and Calendering
Rubber and Fabrics)
1 *• Solid Waste
Cooling & *> Wastewater
Cutti"g -—^ Solid Waste
Fugitive and Stack Air
Building
Solid Waste
i >• Fugitive and Stack Air
-H Vulcanizing ^Wastewater
1 ^ Solid Waste
i ^- Fugitive and Stack Air
Finishing ^Wastewater
1 *• Solid Waste
Finishing Agents
Finished Tire Product
^ Process Stream
^- Potential Type ofEPCRA Section 313 Chemical Release or Other Waste Management
Figure 4-7. Typical Tire Manufacturing
(Ref. U.S. EPA Sector Notebook Project, Profile of the Rubber and Plastics Industry
(EPA310-R-95-016) September 1995.)
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Step 3: Identify Release and Other Waste Management Activity Types
Tire manufacturing release and other waste management activity types typically
include stack and fugitive air emissions, water discharges, and solid wastes that are managed on
site or transferred off site. The release and waste management types described in Section 4.2.2
for rubber product manufacturing also apply to tire manufacturing. Additionally, solvents
applied to tire components during building operations typically result in air emissions.
Cementing operations may also result in the volatilization of EPCRA Section 313 chemicals.
Control devices may be located on equipment, such as scrubbers that may transfer the chemicals
to a water medium where the chemicals may be treated on site, transferred off site, or discharged
to water. Scrap tires may be disposed, recycled, or transferred off site.
Table 4-6 summarizes the release and other waste management activity sources
and types and lists the typical EPCRA Section 313 chemicals associated with each for tire
manufacturing operations.
Table 4-6
Sources and Types of EPCRA Section 313 Chemicals for Tire Manufacturing
Unit Operation/ Source
Activity
Chemical Storage
Compounding and
Mixing
Extruding
Calendering
Cooling and Cutting
Building
Release and Other Waste
Management Activity Type
Fugitive and Stack Air
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
On-site land or off-site disposal
Typical EPCRA Section 313 Chemicals
Empty bag residue for ZnO and TMTD adhesives
in drums and tanks
Antimony compounds, phenol, zinc compounds
Formaldehyde and styrene from fabric dripping
Zinc and cobalt compounds
Adhesives and adhesive solvents:
4-53
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Table 4-6 (Continued)
Unit Operation/ Source
Activity
Vulcanizing
Finishing
Release and Other Waste
Management Activity Type
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site disposal
Typical EPCRA Section 313 Chemicals
Vulcanizing agents: lead compounds, selenium
compounds, zinc compounds
Accelerators: diethanolamine, ethylene thiourea,
zinc compounds, lead compounds
Retardants: n-nitrosodiphenylamine
Reaction products: ammonia, carbon disulfide
Protective Agents: phenol, p-phenylenediamine,
zinc compounds, solvents
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
As with rubber product manufacturing, emission factors may be used to determine
the amount of a volatile EPCRA Section 313 chemical, such as a solvent, that is emitted to the
air and subsequently released or managed as waste. AP-42 lists chemical emission factors for
various unit operations. See discussion on potential for double counting of solvent emissions in
Section 4.2.2., Step 4.
Emission factors associated with processes but not chemical specific may be used
to determine reportable quantities; these factors are considered to be engineering calculations.
Engineering calculations may be used to determine reportable quantities by using non-chemical-
specific emission factors.
Mass balances are also often appropriate for estimating chemical releases and
quantities otherwise managed. Formulations for rubber mixes and the final tire chemical
concentration can be used in conjunction with production data and purchase and inventory
records to determine the amount of a chemical leaving with the product and the amount sent off
site or recycled with scrap tires and other waste streams.
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Example - Use of Emission Factor to Estimate Air Emissions of Methyl Ethyl Ketone
A rubber tire manufacturing facility has determined it must file an EPCRA Section 313 report for methyl ethyl
ketone (MEK). The following rubber products, along with their corresponding production amounts (P), are
compounded and mixed on site:
Compound 1: Tire Inner Liner ~ 1,500,000 pounds per year;
Compound 2: Tire Ply Coat - 1,020,000 pounds per year;
Compound 3: Tire Belt Coat - 1,020,000 pounds per year;
Compound 4: Tire Base/Sidewall - 1,800,000 pounds per year;
Compound 5: Tire Apex ~ 500,000 pounds per year;
Compound 6: Tire Tread - 1,550,000 pounds per year; and
Compound 7: Tire Bladder ~ 700,000 pounds per year.
The following MEK (or 2-butanone) emission factors (EF) apply to internal mixing and milling of each tire
component [Ref: Draft of Chapter 4.12 "Manufacture of Rubber Products" of AP-42 currently under review].
Compound 1:5.91 Ib MEK /106 Ib rubber;
Compound 2: 1.59 Ib MEK /106 Ib rubber;
Compound 3: 0.90 Ib MEK /106 Ib rubber;
Compound 4: 2.74 Ib MEK /106 Ib rubber;
Compound 5: 1.53 Ib MEK /106 Ib rubber;
Compound 6: 0.44 Ib MEK /106 Ib rubber; and
Compound 7: 1.40 Ib MEK /106 Ib rubber.
The MEK air emissions from compound 1 are calculated as shown below:
MEK emissions = (EF) x (P)
MEK emissions (Compound 1) = (5.91 Ib MEK/106 Ib rubber) x (1,500,000 Ib/yr)
= 8.9 pounds per year
The MEK emissions for the remaining compounds are calculated in the same manner and the resulting annual
emissions are listed below
Compound 1: 8.9 Ib MEK Compound 5: 0.77 Ib MEK
Compound 2: 1.6 Ib MEK Compound 6: 0.68 Ib MEK
Compound 3: 0.92 Ib MEK Compound 7: 0.98 Ib MEK
Compound 4: 4.9 Ib MEK
The emissions resulting from the mixing and milling of all seven tire rubber components are calculated to total 19
pounds. If appropriate, you should consider the removal and destruction by air pollution control devices when
determining the stack releases and quantities treated on site.
Air emissions should be reported in Sections 5 and 8.1
COMMON ERROR - Off-Specification Tires
Neither the article exemption nor the motor vehicle activity exemption applies to off-specification cured tires that
are sent off site for disposal, recycling, or other waste management. EPCRA Section 313 chemicals present in
the tires sent off site for disposal or recycling must be considered in threshold determinations and release and
other waste management activity estimates. However, EPCRA Section 313 chemicals in tires that a facility
purchases and uses for on-site vehicles are exempt.
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4.2.4 Plastic Product Manufacturing
Plastic product manufacturing facilities make a variety of plastic products from
plastic pellets, resins, etc. Depending on the product, which ranges from toys and footwear to
industrial tower packing, various additives may be used to impart the desired properties to the
finished product.
Step 1: Prepare a Process Flow Diagram
Figure 4-8 shows a typical process flow diagram for plastic product
manufacturing. Various unit operations may be used in the manufacture of plastic products. The
major steps are compounding, forming or molding, cooling, trimming, and finishing. Forming
processes used in plastic product manufacture include casting and encapsulation, heating,
injection systems, extrusion, thermoforming, and calendering. Types of molding operations
include injection, rotational, transfer and compression, reaction, and blow molding.
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Plastic Pellets/Resin
Foaming Agents; Catalysts; Lubricants;
Heat Stabilizers; Plasticizers; etc.
Direct Contact
Cooling Water
Coating Promoters; Dyestuff;
Paints; Sprays, etc.
Chemical * Fugltlve and stack Alr
Storage
^- Solid Waste (Container Residue)
, ^. pugitive and Stack Air
Compounding ^ Wastewater/Slurries
& Mixing
i
i ^. plastic Pellet Spills/Container Residue
FORMING STEP
(Casting & Encapsulation, * Fugitive and Stack Air
Calendering, Extrusion,
Heating, Injection System, ^ Wastewater
Thermoforming)
»
, ^. pugitive and Stack Air
MOLDING
OPERATIONS
(Injection, Reaction Injection, ^ Wastewater
Transfer & Compression, Blow
Molding, Rotational)
i ^. solid Waste
Plastic
^ Cooling »> Wastewater
i'
Trimming *• Wastewater
Operations
*• Solid Waste
i ^ Fugitive and Stack Air
Finishing [. >• Wastewater/Slurries
Operations
i ^ Solid Waste
Finished Plastic Product
^ Process Stream
^ Potential Type ofEPCRA Section 313 Ch em ical Release or Other Waste Management
Figure 4-8. Typical Plastic Product Manufacturing
(Ref: U.S. EPA, Sector Notebook Project, Profile of the Rubber and Plastics Industry (EPA 310-R-95-016),
September 1995.)
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The main sources of air emissions are typically the molding and extruding
processes, during which chemicals are processed under high heat and pressure and emitted.
Chemical storage, compounding equipment, and finishing operations are also sources of air
emissions. Fugitive air sources are typically fittings, valves, pumps, etc. Unloading, storage, and
transferring of additives may result in fugitives of volatile components or particulates. Stack air
sources include equipment vents and air pollution control devices employed at the facility.
During forming and molding operations, water is used to cool or heat the plastic
products or to clean the surface of the products and equipment. Water may also be used during
finishing operations. The water may contact and retain EPCRA Section 313 chemicals during
these operations. Spill clean-ups and housekeeping practices such as area and equipment
washdowns are also sources of EPCRA Section 313 chemicals. Note that small spills that are
"routinely observed," such as polymer pellets falling on the floor, are not considered to be a
result of one-time events and should not be included in Part II, Section 8.8 (of the 1999 Form R)
calculations.
The trimming and cutting process generates solid plastic waste, which may
contain EPCRA Section 313 chemicals. Finishing operations such as coating and cleaning may
also be sources for the release and other waste management of EPCRA Section 313 chemicals.
Solid wastes potentially containing EPCRA Section 313 chemicals may include unreacted pellets
and resins in wastewater or floor sweepings, off-specification plastic products, and dusts
captured in air pollution control systems (baghouses, dry filters, etc.). Residual chemicals from
equipment cleaning and waste management of "empty" shipping containers should also be
considered when determining liquid and solid waste or other material sources; estimates can be
calculated using the values listed in Table 4-1.
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Step 3: Identify Release and Other Waste Management Activity Types
Fugitive emissions are the most common air releases. Fugitive dust emissions
that contain EPCRA Section 313 chemicals can occur during the handling of raw materials.
Typical metals in particulate matter, including cadmium and zinc, may be collected in a baghouse
or other air pollution control device or released through equipment or general room air vents.
Collected dust that is otherwise managed should be included in the calculations for the
appropriate release type.
Wastewater containing EPCRA Section 313 chemicals may be generated from
contact water used during the cooling or heating of plastic parts, process equipment cleaning,
spills, leaks, and finishing water. During cleaning operations, organics such as phenol, and
metals such as zinc may be transferred to the water. Facilities may treat this wastewater on site,
discharge the wastewater to a surface water, or transfer the wastewater to a POTW or other
off-site facility.
Solid from plastics manufacturing may be reused or recycled on site or sent off
site for treatment, recycling, or disposal. High heat value plastics may be combusted for energy
recovery, or on or off site.
Table 4-7 summarizes the release and other waste management activity sources
and types and lists the typical EPCRA Section 313 chemicals associated with each for plastic
product manufacturing operations.
4-59
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Table 4-7
Sources and Types of EPCRA Section 313 Chemicals for
Plastic Product Manufacturing
Unit Operation/
Source
Release and Other Waste
Management Activity Type
Typical EPCRA Section 313 Chemicals
Chemical Storage
Fugitive and Stack Air
On-site land or off-site
disposal
Recycling
Compounding and
Mixing
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Chloroform, dichloromethane, ethylbenzene, phenol
Thermoplastics & Monomers (such as 1,3-butadiene,
ethylene, propylene, styrene, styrene-acrylonitrile,
vinyl chloride)
Heat Stabilizers: lead, zinc, barium, and cadmium
compounds
Impact Resistor: acrylic acid, acrylamide
Flame Retardants: antimony compounds
Forming
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Chemicals from compounding and mixing:
Cleaning Agents: phenol, zinc
Molding
Fugitive and Stack Air
Receiving stream or POTW
On-site land or off-site
disposal
Chemicals from compounding and mixing:
Cleaning Agents: phenol, zinc
Cooling and
Trimming
Receiving stream or POTW
On-site land or off-site
disposal
Dimethyl phthalate, di-n-butyl phthalate
Finishing
Fugitive and Stack Air
Receiving stream or POTW/
Slurries
On-site land or off-site
disposal
Dimethyl phthalate, cobalt compounds, phenol
Dyestuff/Paints: phenol, selenium
Sprays: vinyl chloride (monomer)
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Emission factors or engineering calculations may be used to determine the amount
of an EPCRA Section 313 chemical emitted to the air. Chemical specific emission factors for
unit operations are available from AP-42. Process operation emission factors or other
engineering calculations may be used to determine the release and other waste management
4-60
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activity quantities of volatile chemicals. The following example uses AP-42 information to
determine the reportable quantities of an EPCRA Section 313 solvent.
Monitoring information may be available to determine the amount of an EPCRA
Section 313 chemical emitted to the air, discharged to water, transferred off site, or treated on
site. For permit applications or worker exposure data, facilities may have monitored for dusts
generated during compounding and mixing operations. Facilities may also have to monitor their
wastewater discharges.
Using production, purchase, and inventory records, mass balance calculations can
be performed for EPCRA Section 313 chemicals incorporated into the product or otherwise used,
e.g., a catalyst, during plastic product manufacturing.
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Example - Estimates from Surface Coating of Plastic Parts
A plastic parts facility performs surface coating during its finishing operations and uses approximately 15,000
gallons of the coating mixture during the year. According to the MSDS, the coating contains 10% xylene by
volume, and the density of xylene is approximately 7.2 pounds per gallon. The coating is applied in a paint booth
using an air atomized spray and the particles from spraying are controlled by a scrubber. According to AP-42, an
air atomized spray has a 25% transfer efficiency for prime, color, texture, touch up, and fog coatings. Vendor and
facility testing information show the scrubber as having a 95% capture efficiency (i.e., the amount of particles
captured by the control device) and 95% control efficiency (i.e., the amount of particles removed from the
captured air); the scrubber water is then sent to a POTW for treatment.
The amount of xylene in the spray coating is calculated as shown below:
(15,000 gal) x (10%) x (7.2 Ib/gal) = 10,800 Ib xylene
Assume 25% of the xylene in the spray coating will remain on the plastic product:
(10,800 Ib xylene) x (25% on product) = 2,700 Ib xylene on product
Therefore, 8,100 pounds of xylene do not remain on the product. Fugitive air emissions of xylene equals the 5%
not captured by the scrubber, calculated as shown below:
Fugitive Air Emissions of Xylene: (5%) x (8,100 Ib) = 405 Ib
Xylene Captured by Scrubber: 8,100 - 405 = 7,695 Ib
Stack air emissions equal the 5% of the captured xylene which is not controlled by the scrubber:
Stack Air Emissions of Xylene: (5%) x (7,695 Ib) = 385 Ib
The remaining quantity of xylene captured by the scrubber becomes part of the scrubber water and is discharged
to the POTW for treatment.
Xylene Transferred to the POTW: 7,695 - 385 = 7,310 Ib
The xylene remaining on the plastic part, 2,700 pounds, will most likely volatilize during drying operations. The
dryer stack gas is not controlled; therefore, 100% of the volatilized xylene is assumed to be released as stack
emissions through the dryer vent. The total stack air emissions from the spraying and drying operations is 3,085
pounds:
Total Xylene Stack Air Emissions: 2,700 + 385 = 3,085 Ib
Assuming these operations are the only sources of reportable xylene quantities, the facility would report, 405
pounds fugitive air emissions (Section 5.1), 3,085 pounds stack air emissions (Section 5.2) and 7,310 pounds
discharged to a POTW (Section 6.1) on its Form R for xylene. A Form A cannot be completed for xylene
because the total reportable quantity exceeds 500 pounds per year.
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Appendix A
TRI GUIDANCE RESOURCES
-------
Appendix A
TRI GUIDANCE RESOURCES
A.1 EPCRA Section 313 RELATED REFERENCES
40 CFR 372. Toxic Chemical Release Reporting: Community Right-to-Know: Final Rule
See 53 FR 4500, February 16, 1988.
Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting
Year - See also Automated Toxic Chemical Release Inventory Reporting Software (ATRS) under
Section A.2, Internet Sites.
U.S. EPA publishes this document each year to provide current guidance for preparing the Form
R and Form A reports. This document contains the most up-to-date list of chemicals for which
reports are required. It includes a blank Form R and Form A and provides step-by-step
instructions for completing each report. It also has a list of U.S. EPA regional and state contacts
for EPCRA Section 313 reporting. The current version of this document should always be
consulted in preparing the EPCRA Section 313 report.
Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the Emergency
Planning and Community Right-to-Know Act (EPA 745-R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the
reporting requirements of EPCRA Section 313. The glossary was developed to aid in
determining whether a facility manufactures, processes, or uses a chemical subject to EPCRA
Section 313 reporting.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-
Know Act ffiPCRA^ and Section 112frt of the Clean Air Act (as amended^ (EPA 740-R-95-001)
List of chemicals covered by EPCRA Sections 302 and 313, CERCLA Hazardous Substances,
and CAA 112(r). The list contains the chemical name, CAS Registry Number, and reporting
requirement(s) to which the chemical is subject.
The Emergency Planning and Community Right-to-Know Act: EPCRA Section 313 Release
Reporting Requirements. August. 1995 (EPA 745/K-95-052)
This brochure alerts businesses to their reporting obligations under EPCRA Section 313 and
assists in determining whether their facility is required to report. The brochure contains U.S. EPA
Regional contacts, the list of EPCRA Section 313 toxic chemicals and a description of the
Standard Industrial Classification (SIC) codes subject to EPCRA Section 313.
EPCRA Section 313 Questions and Answers: 1998 Version. (EPA 745-B-97-004).
Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements: Questions and Answers (EPA 745-R-95-011)
This document assists federal facilities in complying with Executive Order 12856. This
information has been compiled by U.S. EPA from questions received from federal facilities. This
document is intended for the exclusive use of federal facilities in complying with Sections 302,
A-l
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303, 304, 311, 312, and 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA) of 1986 and the Pollution Prevention Act of 1990, as directed by the Executive Order.
Supplier Notification Requirements (EPA 560/4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification
requirements under EPCRA Section 313. The pamphlet explains the supplier notification
requirements, gives examples of situations which require notification, describes the trade secret
provision, and contains a sample notification.
Toxic Chemical Release Inventory - Data Quality Checks to Prevent Common Reporting Errors
on Form R/Form A (EPA 745-R-98-012)
This is a compilation of Notices of Data Change, Significant Error, Noncompliance, or Technical
Error. It provides a listing of common errors found on the Form R reports submitted to U.S.
EPA. It also provides a discussion of the types of errors which result in each of the above
Notices as well as a list of Notice of Technical Error codes and descriptions.
Trade Secrets Rule and Form
See 53 FR 28772, July 29, 1988. This rule implements the trade secrets provision of the EPCRA
(Section 322) and includes a copy of the trade secret substantiation form.
A.2 INFORMATION SOURCES
Most of the materials included as reference in this manual are available from the following
sources:
National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OH 45242-2419
(800)490-9198
Fax:(513)489-8695
Internet: http://www. epa.gov/ncepihom/index.html
Emergency Planning and Community Right-to-Know (EPCRA) Information Hotline
U.S. Environmental Protection Agency
(800) 424-9346 or (703) 412-9810 (for the Washington, D.C. metropolitan area)
TDD: (800)553-7672
Internet Sites
TRI homepage: http://www.epa.gov/tri
This site contains information on the Toxic Release Inventory and provides links
to a variety of data and documents related to the TRI program.
Automated Toxic Chemical Release Inventory Reporting Software (ATRS):
http://www. epa.gov/atrs
This site provides access to the automated EPCRA Section 313 reporting forms
for electronic submittal of required data to U.S. EPA.
A-2
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Air CHIEF CD-ROM
http://www.epa.gov/ttn/chief/airchief.html
This site provides information on the Air CHIEF CD-ROM, contents, ordering
information, system requirements, and sources for additional information.
Clearinghouse for Inventories and Emission Factors (CHIEF):
http://www. epa.gov/ttn/chief/
This site provides access to the latest information and tools for estimating
emissions of air pollutants and performing emission inventories.
Code of Federal Regulations, 40 CFR: http://www.epa.gov/epacfr40
This site was created by U.S. EPA to expand access to Title 40 - Environmental
Protections of the Code of Federal Regulations.
Compilation of Air Pollutant Emission Factors (AP-42):
http://www. epa.gov/ttn/chief/ap42etc. html
This site provides access to files containing guidance for estimating emissions
from specific sources and emission factors.
Federal Register Notice: http://www.epa.gov/EPA-TRI
This site provides access to all Federal Register notices related to the TRI program
from 1994 to current.
Material Safety Data Sheets (MSDSs):
http://msds.pdc. Cornell, edu/issearch/msdssrch.htm
A key word searchable database of 325,000 MSDSs.
TANKS: http://www. epa.gov/ttn/chief/tanks.html
This site contains information on TANKS, a DOS-based computer software
program that computes estimates of VOC emissions from fixed and floating-roof
storage tanks.
WATER8/CHEMDATS: http://www. epa.gov/ttn/chief/software. html#water8
WATERS is an analytical model for estimating compound-specific air emissions
from wastewater collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3
spreadsheet for estimating VOC emissions from TSDF processes.
A-3
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A.3 INDUSTRY-SPECIFIC TECHNICAL GUIDANCE DOCUMENTS
In 1988 and 1990, U.S. EPA developed a group of individual guidance documents for industries
or activities in industries who primarily manufacture, process, or otherwise use EPCRA
Section 313 chemicals. See list of industries/activities below. U.S. EPA is currently revising
some of these documents and preparing additional documents. The newer versions will be
available beginning in the Fall of 1998.
Chemical Distribution Facilities. January 1999 (EPA 745-B-99-005)
Coal Mining Facilities. January 1999 (EPA 745-B-99-002)
Coincidental Manufacture/By-Products (EPA 745-B-00-014)
Electricity Generating Facilities. January 1999 (EPA-745-B-99-003)
Estimating Releases and Waste Treatment Efficiencies
Food Processors. September 1998 (EPA 745-R-98-011)
Formulation of Aqueous Solutions
Foundry Operations (EPA 745-B-00-016)
Leather Tanning and Finishing Industry. April 2000 (EPA 745-B-00-012)
Metal Mining Facilities. January 1999 (EPA 745-B-99-001)
Metal Working and Electroplating Operations. April 2000 (EPA 745-B-00-015)
Monofilament Fiber Manufacture (EPA 745-B-00-013)
Petroleum Terminals and Bulk Storage Facilities. January 1999 (EPA 745-B-99-006)
Pulp. Paper, and Paperboard Production (EPA 745-B-00-010)
Presswood & Laminated Wood Products Manufacturing
Printing Industry. April 2000 (EPA 745-B-00-005)
RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities. January 1999 (EPA 745-B-99-
004)
Rubber and Plastics Manufacturing. April 2000 (EPA 745-B-00-017)
Semiconductor Manufacture (EPA 745-R-99-007)
A-4
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Smelting Operations (EPA 745-B-00-009)
Spray Application and Electrodeposition of Organic Coatings. December 1998 (EPA 745-B-99-
014)
Textile Processing Industry. April 2000 (EPA 745-B-00-008)
Welding Operations (EPA 745-B-00-011)
Wood Preserving Operations (EPA 745-B-00-007)
U.S. EPA, Office of Compliance, published a series of documents in 1995 called Sector
Notebooks. These documents provide information of general interest regarding environmental
issues associated with specific industrial sectors. The Document Control Numbers (DCN) range
from EPA/310-R-95-001 through EPA/310-R-95-018.
A.4 CHEMICAL-SPECIFIC GUIDANCE DOCUMENTS
U.S. EPA has also developed a group of guidance documents specific to individual chemicals
and chemical categories. These are presented below.
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting Aqueous Ammonia. July 1995 (EPA 745-R-95-012)
Emergency Planning and Community Right-to-Know EPCRA Section 313: List of Toxic
Chemicals within the Chlorophenols Category. November 1995 (EPA 745-B-95-004)
Estimating Releases for Mineral Acid Discharges Using pH Measurements. U.S. Environmental
Protection Agency. June 1991.
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size). November 1997 (EPA-745-R-97-007)
Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and
Guidance for Reporting. May 1995 (EPA 745-R-95-006)
Toxic Release Inventory List of Toxic Chemicals within the Nicotine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-004)
Toxic Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category
and Guidance for Reporting. February 1995 (EPA 745-R-95-001)
Toxic Release Inventory List of Toxic Chemicals within the Polycyclic Aromatic Compounds
Category. February 1995 (EPA 745-R-95-003)
Toxic Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-005)
A-5
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Toxic Release Inventory List of Toxic Chemicals within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting. May, 1996 (EPA 745-R-96-004)
Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid
Category. November 1994 (EPA 745-B-94-003).
Toxics Release Inventory - Copper Phthalocyanine Compounds Excluded for the Reporting
Requirements Under the Copper Compounds Category on the EPCRA Section 313 List. April
1995 (EPA 745-R-95-007).
Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category. November 1994
(EPA 745-B-94-004).
A.5 OTHER USEFUL REFERENCES
Burgess, W.A. Recognition of Health Hazards in Industry. Harvard School of Public Health.
Boston, Massachusetts, John-Wiley & Sons.
CRC Handbook of Chemistry and Physics. Latest Edition, Robert C. Weast, Editor, CRC Press,
Inc., Florida.
Donofrio, J., "Zinc Phosphating;" Organic Finishing Guidebook and Directory, May 1996, pages
68-85.
Locating and Estimating Air Emissions from Various Sources. Available from: National
Technical Information Services (NTIS), (703) 487-4650.
The Merck Index. Latest Edition, Merck & Co., Inc., New Jersey.
Perry, R.H. and C.H. Chilton, Chemical Engineer's Handbook. Latest Edition, McGraw-Hill
Book Company, New York.
Sax, N.I. and R. J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van
Nostrand Reinhold Company, New York.
A-6
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Appendix B
BASIC CALCULATION TECHNIQUES
-------
Appendix B
BASIC CALCULATION TECHNIQUES
This section will provide the basic techniques needed to use specific types of data or engineering
calculations. Examples are provided for:
(1) Stack monitoring data;
(2) Industrial hygiene data;
(3) Raoult's Law;
(4) Air emission factors;
(5) RCRA hazardous waste analysis data;
(6) NPDES monitoring data.
(1) Stack Monitoring Data
The following is an example of a release calculation using monitoring data.
Example: Stack monitoring data are available for a paint booth. The measured
average concentration of toluene is 0.1 ppmv (dry gas basis). The moisture
content in the stack is typically 10%, and stack conditions are maintained at 80°C
and atmospheric pressure. The stack gas velocity is 8 m/s. The diameter of the
stack is 0.3 m. Calculate the point air release of toluene.
Step 1. Calculate volumetric flow of stack gas stream.
Volumetric flow = (gas velocity) x [(IT) x (internal stack diameter)2/4)]
Volumetric flow = (8.0 m/s) x [(71) x (0.3 m)2/4] = 0.6 m3/s
Step 2. Correct for moisture content in stack gas stream.
Stack exhausts may contain large amounts of water vapor. The concentration of
the chemical in the exhaust is often presented on a dry basis. For an accurate
release rate, correct the vent gas flow rate for the moisture content by multiplying
by the term (1 - fraction water vapor). The dry gas rate can then by multiplied by
the chemical concentration.
(Note: If the toluene concentration is on a wet gas basis, no correction is necessary
for moisture content.)
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Dry volumetric flow = (Volumetric flow) x (1-fraction water vapor)
Dry volumetric flow = (0.6 m3/s) x (1-0.10) = 0.5 m3/s
Step 3. Convert ppmv to mg/m3.
• ppmv is defined as one part of a chemical in 106 parts of gas (1.0 m3/106
m3).
• Use the molar volume of a gas, corrected for stack temperature and
pressure conditions, calculated by the ideal gas law (PV = nRT). Note that
the molar volume of an ideal gas at 237 K and 1 atm is 22.4 L/mole.
• Molecular weight of toluene (MW) = 92.14 g/mole.
R = the Ideal Gas Constant (0.082057 L - atm per mole-Kelvin)
To calculate the molar volume of stack gas, use the ideal gas equation.
™ i i V RT
Molar volume = — =
For the example, the stack conditions are 80° C (353 K) and atmospheric pressure
(1 atm).
Molar volume = 0.082057 L atm x (353 K)/(latm)
I mole-Kj
= 29.0 L/mole
The conversion of ppmv to mg/m3 can now be calculated.
—- = (concentration of chemical, ppmv) x x (MW)
m31 ^ molar volume of gas)
B-2
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( 1,000 mg\ n - /3
— ^ = 0.3 mg/m3
I 1 § )
Using the example, the concentration of toluene is calculated as follows:
0.1 m3] x ( mole } x [92.14 g^l x [ L ^
106 m3 I 29.0 L! I mole J 1(T3 m3.
Step 4. Calculate air releases.
Air releases are calculated as follows:
Air Release=(volumetric flow, m3/s) x (concentration, mg/m3) x (operating time, s/yr)
The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year.
/-v *• *• I o hr | f . day ) f .~ week | ~ non , ,
Operating time = 8 x 5 y— x 52 = 2,080 hr/yr
^ dayj ^ weekj ^ yr )
A r> i m« 3/\ mi / ^ i 3,600s) f 2,080 hr) [ Ib
Air Release = (0.5 m /s) x (0.3 mg/m ) x I _? 1 x I -^ 1 x '
hr j ^ yr ) ( 454 gj ^ 1,000 mg
= 2.5 Ib/yr of toluene
It is important to note that this calculation assumes the measured emissions are
representative of actual emissions at all times; however, this is not always the case. Ideally, a
continuous emissions monitor provides the most representative data.
Also note that monitoring and stack data may have units that are different than
those used in the example. Modify conversion factors and constants to reflect your data when
calculating air releases.
(2) Industrial Hygiene Data
The following is an example of a release calculation using industrial hygiene data.
Example: Occupational industrial hygiene data shows that workers are exposed
to an average of 0.1 ppmv benzene (wet gas basis). The density of benzene vapor
is 0.2 lb/ft3. The ventilation system exhausts 20,000 acfm of room air at 70°F.
The plant operates 24 hours per day, 330 days per year.
The benzene concentration is on a wet gas basis, therefore a moisture correction
of the ventilation flow rate is not necessary. The industrial hygiene data is
collected at the same ambient conditions as the ventilation system, therefore no
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adjustment for temperature or pressure needs to be performed. A conservative
estimation of benzene fugitive releases could be calculated as follows:
Air Release = (ventilation flow rate, ft3/min) x (operating time, rnin/yr) x
(concentration of chemical, ppmv) x (vapor density of chemical, lb/ft3)
Benzene releases per year would be calculated as follows:
20,000 ft3 [60 mini I 24 hr) f 330 day) 0.1 ft3 benzene 0.2 Ib
x x x x x
min ) { hr ) { day ) ( yr ) ( 1Q6 ft3 air } ( ft3
= 190 Ib/yr of benzene
(3) Raoult's Law
The following is an example of a release calculation using Raoult's Law. Raoult's
Law states that the partial pressure of a compound in the vapor phase over a solution may be
estimated by multiplying its mole fraction in the liquid solution by the vapor pressure of the pure
chemical.
PA ~ XAiLP° - XA]GPT
where:
P° = Vapor pressure of pure liquid chemical A;
XAL = Mole fraction of chemical A in solution;
XA,G = Mole fraction of chemical A in the gas phase;
PA = Partial pressure of chemical A in the gas phase; and
PT = Total pressure.
Example: A wash tank holds a solution containing 10% by weight of
o-xylene (A) and 90% by weight of toluene (B). The tank is vented to the atmosphere; the
process vent flow rate is estimated as 100 acfm (2.83m3/min) based on a minimum fresh air
ventilation rate. The molecular weight of o-xylene is 106.17 g/mole and toluene is 92.14 g/mole.
The vapor pressure of o-xylene is 10 mm of Hg (0.19 psia). The total pressure of the system is
14.7 psia (atmospheric conditions). The process tank is in service 250 days/yr. Calculate the air
release of o-xylene.
Step 1: Calculate the mole fraction of o-xylene in the liquid solution.
B-4
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X
A,L
wt fraction A
MWA
wt fraction A wt fraction B
MW,
MWt
Where:
XA,L
MW
wt fraction
Mole fraction of chemical A in liquid solution;
Molecular weight of chemical, g/mole; and
Weight fraction of chemical in material.
X
A,L
0.1
106.17
0.1 0.9
+
106.17 92.14
XA,L = °-09
Step 2: Calculate the mole fraction of o-xylene in the gas phase.
X
A,G
where:
X
X
P°
PT
A,G
A,L
Mole fraction of chemical A in gas phase;
Mole fraction of chemical A in liquid solution;
Vapor pressure of pure liquid chemical A, psia; and
Total pressure of system, psia.
XAG = [0.09]
VA,G
0.19 psia
14.7 psia
= 0.001
Step 3: Calculate releases using Raoult's Law.
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Emissions = (X, r) x (APR) x (t) x (MWA) x _L
V A,G' V J \ > \ A' A/rr j
MV
where:
Emissions = Air release of pollutant A, g-A/yr;
XA G = Mole fraction of chemical A in gas phase;
APR = Air flow rate of room, m3/min;
t = Operating time of wash tank, min/yr;
MW = Molecular weight of chemical, g/g-mole; and
MV = Gas molar volume (22.4 L/mole at standard temperature
and pressure).
If conditions vary from standard temperature and pressure the gas molar volume
can be calculated using the ideal gas law and tank conditions as presented in
Example 1.
Emissions = (0.001) x
2.83m3l ( 250 day) ( 24 br\ ( 60 min) ( mole ) ( 106.17 g] I L
X
min ) ( yr ) ( day ) ( hr } (22AL) { mole } ( 10^3m3,
= 4.8 x 106g/yr
The emission of o-xylene is calculated as shown below.
Emissions = (4.8 x 106 g/yr) x —°_ = 10,570 Ib/yr of o-xylene
I 454 gj
Air releases for toluene can be calculated in a similar manner.
(4) Air Emission Factor
The following is an example of a release calculation using air emission factors.
Example: An industrial boiler uses 300 gallons per hour of No. 2 fuel oil. The
boiler operates 2,000 hours per year. Calculate emissions of formaldehyde using
the AP-42 emission factors.
AE = (EF) x (AU) x (QT)
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where:
AE = Annual emissions of pollutant, Ib/yr
EF = Emission factor of pollutant, lb/103 gallon of fuel. EF for
formaldehyde for an industrial boiler burning No. 2 fuel oil is
0.035 to 0.061 lb/103 gallons.
AU = Quantity of fuel used, gal/yr.
OT = Operating time, hr/yr.
Using an emission factor of 0.061 pounds of formaldehyde per gallon of fuel, the
air releases are calculated as follows:
AT7 0.061 Ib ( 300 gal} ( 2,000 hr^ ., , ,,, ,, ,, , , , ,
AE = x °— x -L = 36.6 Ib/yr of formaldehyde
[lO3 gal } ( hr ) ( yr J
(5) RCRA Waste Analysis
The following is an example of a calculation using RCRA waste analysis data.
Example: Spent paint wastes were disposed at an off-site waste treatment
facility. The quantity of paint waste shipped was five 55-gallon drums per year.
Analysis of the waste showed 5% cadmium by weight. Estimating the density of
the paint waste to be 9.5 Ib/gallon, the amount of cadmium to off-site disposal is
calculated as follows:
Amount of cadmium = (amount of paint waste disposed, gal/yr) x (concentration of cadmium, Ib/lb)
(density of paint waste, Ib/gal)
f 55 gal] [ 9.5 Ib | f 51b Cd | 101 ,, , , , .
x §_ x x = 131 Ib/yr of cadmium
^ drum } V gal J ^ lOOlb waste,)
(6) NPDES Data
The following is an example of a calculation using NPDES data.
NPDES permits require periodic monitoring of the effluent stream. In this
example, quarterly samples were taken to be analyzed for silver content. Each sample was an
hourly, flowrate-based composite taken for one day to be representative of the discharge for that
day. The total effluent volume for that day was also recorded. The following data were collected
on each sample day.
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Yearly Quarter Discharge Flow Rate
Sample Number (IP6 gal/dav) Total Silver (LJQ/L)
1 0.5 10
2 0.6 10
3 0.4 6
4 0.2 <3
To calculate the amount of silver in pounds discharged on each sample day, the
concentration of silver in the discharge is multiplied by the discharge flow rate for that day, as
shown below for the first quarter sample.
Amount of silver = (daily flow rate) x (silver concentration)
r. „ [ lOugl lg I lib 1 f 3.785L] 0.5 x io6gal
First Quarter: —^& x &_ x x &
I L ) lOVg 1454§J I gal H day
= 0.041b/day of silver
The amount of silver discharged during each of the other three monitoring events
was similarly determined to be:
0.05 Ib/day; 0.02 Ib/day, and 0.005 Ib/day.
For the last data point the concentration of silver was reported by the laboratory to
be less than the detection limit of 3 |ig/L. For this calculation the detection limit was used to
calculate the daily discharge, a conservative assumption.
The average daily discharge was calculated to be:
Ib/day = 0.03 Ib/day
0.04+ 0.05+0.02 + 0.005'!
4 J
The plant operates 350 days/year (plant shuts down for two weeks in July).
The estimated annual discharge of silver is calculated as follows:
Annual discharge = (350 day/yr) (0.03 Ib/day) = 10.5 Ib of silver/yr
B-S
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Appendix C
EPCRA SECTION 313 GUIDANCE FOR REPORTING SULFURIC ACID
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&EPA
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
EPCRA Section 313
Guidance for Reporting Sulfuric Acid (acid aerosols including mists,
vapors, gas, fog, and other airborne forms of any particle size)
Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using listed toxic chemicals
to report their environmental releases of such chemicals annually. Beginning with the 1991 reporting year, such
facilities also must report pollution prevention and recycling data for such chemicals, pursuant to section 6607 of the
Pollution Prevention Act, 42 U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic
chemicals that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA section 313(d)
authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth criteria for these actions.
CONTENTS
Section 1.0 Introduction C-l
1.1 Who Must Report C-l
1.2 Thresholds C-2
1.3 What Constitutes Aerosol Forms of Sulfuric Acid and Their
Manufacture, Processing, or Otherwise Use C-2
Section 2.0 Guidance on Sulfuric Acid Aerosols For Certain Specific Activities That
Generate Aerosols Forms C-3
2.1 Sulfuric Acid Aersosols Generated in Acid Reuse Systems C-3
2.2 Sulfuric Acid Aerosols Removed By Scrubbers C-4
2.3 Sulfuric Acid Aerosols Generated In Storage Tanks C-4
Section 3.0 Sulfuric Acid and Its Formation in Air C-4
3.1 Industrial Sources of Sulfuric Acid Aerosols C-5
3.1.1 Pulp and Paper Mills C-7
3.1.2 Acid Aerosols From Sulfuric Acid Manufacture C-8
3.1.3 Smelters C-10
3.1.4 Petroleum Refining C-ll
3.1.5 Sulfuric Acid Aerosol Formation In Stackes From
Combustion Processes C-l 1
3.1.6 Coal Combustion C-12
3.1.7 Fuel Oil Combustion C-13
Section 4.0 Measurement Methods C-14
References C-14
Appendix 1 C-17
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Section 1.0. Introduction
On June 30, 1995 (60 FR 34182), EPA modified the listing for sulfuric acid
(Chemical Abstracts Service Number 7664-93-9) on the list of toxic chemicals subject to the
reporting requirements under section 313 of the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA) (5). EPA modified the listing by deleting non-aerosol forms of
sulfuric acid from the section 313 list based on the conclusion that they cannot reasonably be
anticipated to cause adverse effects on human health or the environment. EPA added a modifier
to the listing for sulfuric acid to exclude the non-aerosol forms. The listing now reads "Sulfuric
acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle
size)." Therefore, beginning with the 1994 reporting year, facilities are no longer required to
include non-aerosol forms of sulfuric acid in threshold and release determinations. In this
document we will use the term "sulfuric acid aerosols" to indicate airborne forms of sulfuric acid
as listed in section 313 of EPCRA.
The purpose of this document is to assist facilities in determining the sources and
amounts of sulfuric acid aerosols that are to be included in threshold and release determinations
under EPCRA section 313. This document is not meant to be exhaustive, but rather provide some
guidance to help facilities in their determination of threshold and release quantities. Threshold
and release determinations for sulfuric acid aerosols are highly dependent on site specific
conditions and equipment. Therefore, this document can only provide general information
concerning the possible formation and release of sulfuric acid aerosols.
Section 1.1. Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA section
313, if it meets all three of the following criteria:
• It is included in the primary Standard Industrial Classification (SIC) codes 20
through 39 and beginning January 1, 1998, it is in one of the following industries:
Metal Mining, SIC code 10 (except SIC codes 1011, 1081, and 1094); Coal
Mining, SIC code 12 (except SIC code 1241); Electric Utilities, SIC codes 4911,
4931, or 4939 (each limited to facilities that combust coal and/or oil for the
purpose of generating power for distribution in commerce); Commercial
Hazardous Waste Treatment, SIC code 4953 (limited to facilities regulated under
the Resource Conservation and Recovery Act, subtitle C, 42 U.S.C. section 6921
et seq.); Chemicals and Allied Products-Wholesale, SIC code 5169; Petroleum
Bulk Terminals and Plants, SIC code 5171; and, Solvent Recovery Services, SIC
code 7389 (limited to facilities primarily engaged in solvent recovery services on
a contract or fee basis); and
• It has 10 or more full-time employees (or the equivalent of 20,000 hours per year);
and
• It manufactures (includes imports), processes or otherwise uses any of the toxic
chemicals listed on the EPCRA section 313 list in amounts greater than the
threshold quantities specified below.
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In addition, pursuant to Executive Order 12856 entitled "Federal Compliance with
Right-to-Know Laws and Pollutant Prevention Requirements," federal facilities are required to
comply with the reporting requirements of EPCRA Section 313 beginning with calendar year
1994. This requirement is mandated regardless of the facility's SIC code.
Section 1.2. Thresholds
Thresholds are specified amounts of toxic chemicals manufactured, processed, or
otherwise used during the calendar year that trigger reporting requirements. Reporting is required
for sulfuric acid aerosols if the following thresholds are exceeded.
• If a facility manufactures or imports 25,000 pounds of sulfuric acid aerosols over
the calendar year.
• If a facility processes 25,000 pounds of sulfuric acid aerosols over the calendar
year.
• If a facility otherwise uses 10,000 pounds of sulfuric acid aerosols over the
calendar year.
The quantities of sulfuric acid aerosols included in threshold determinations are
not limited to the amounts of sulfuric acid aerosols released to the environment. All sulfuric acid
aerosols manufactured, processed, or otherwise used are to be counted toward threshold
determinations. This includes any amount of sulfuric acid aerosols that may be generated in
closed systems or that are generated in stacks prior to or after being treated by scrubbers.
Section 1.3. What Constitutes Aerosol Forms of Sulfuric Acid and Their Manufacture,
Processing, or Otherwise Use
For the purposes of the reporting requirements under EPCRA section 313, sulfuric
acid aerosols include mists, vapors, gas, fog, and other airborne forms of any particle size. Note
that there is no size limit for particles that must be included under the EPCRA section 313
sulfuric acid aerosols listing. Although the qualifier includes the terms mists, vapors, gas, and fog
these terms are not specifically defined for EPCRA section 313 since the last part of the qualifier
"other airborne forms of any particle size" makes it clear that any airborne form is covered by the
listing. The specific terms mists, vapors, gas, and fog are included to make it clear that sulfuric
acid that is identified as being in one of these forms would be covered by the sulfuric acid
aerosols listing.
If sulfuric acid is present in the form of a gas, fog, vapor, or mist or any other
airborne formthen sulfuric acid is considered to be in the aerosol form and is covered by the
EPCRA section 313 sulfuric acid aerosols listing. Solutions of sulfuric acid which do not become
airborne are not covered by the EPCRA section 313 sulfuric acid aerosols listing but such
solutions may generate sulfuric acid aerosols during their manufacture, processing or otherwise
use. In general, sulfuric acid aerosols are manufactured any time a solution of sulfuric acid is
made to become airborne such as when it is sprayed or distilled. If the generation of sulfuric acid
aerosols through spraying or other means is intentional (i.e., it is intended that the sulfuric acid
aerosol be generated for a particular use activity) then, in addition to manufacturing the sulfuric
acid aerosol, such aerosols are also being otherwise used. Thus, spraying of sulfuric acid aerosols
C-2
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on to an item for cleaning, etching, or other purposes constitutes the manufacture and otherwise
use of sulfuric acid aerosols. If sulfuric acid aerosols are used in a process in which any part of
the sulfuric acid becomes incorporated into a product which is then distributed in commerce
then, under EPCRA section 313, the sulfuric acid aerosols are considered to have been processed.
Section 2.0. Guidance On Sulfuric Acid Aerosols For Certain Specific Activities That
Generate Aerosols Forms
EPA has provided the following guidance for specific activities that generated
sulfuric acid aerosols. The guidance in sections 2.1, 2.2, and 2.3 is intended to apply only to the
specific situations discussed in these sections. If you are not sure whether this guidance applies to
the situation at your facility, then EPA should be consulted before using this guidance.
Section 2.1. Sulfuric Acid Aerosols Generated In Acid Reuse Systems
When solutions of sulfuric acid are aerosolized the "manufacture" of a listed
chemical (sulfuric acid aerosols) has occurred. This is a result of the qualifier to the sulfuric acid
listing, which excludes non-aerosol forms and limits the reporting to aerosol forms only. The
addition of the acid aerosol qualifier has an impact on certain processes that, prior to the addition
of the qualifier, would not have been considered to be "manufacturing" a listed chemical. Acid
reuse systems that use aqueous solutions of sulfuric acid to generate acid aerosols, use the acid
aerosols, condense them back into solution, and then reuse the acid solution again and again are
impacted by the addition of the acid aerosol qualifier. In such processes, the continuous reuse of
the acid solutions generates very large quantities of acid aerosols that technically should be
counted towards the "manufacture" [the generation of the acid aerosol is the "manufacture" of
sulfuric acid (acid aerosol)] and "otherwise use" thresholds. This may result in many facilities
greatly exceeding the "manufacture" and "otherwise use" reporting thresholds that, prior to the
addition of the qualifier, would not have exceeded thresholds.
While it is technically correct to apply all of the quantities of acid aerosols
generated in such systems towards the "manufacture" and "otherwise use" reporting thresholds,
EPA did not intend to increase the reporting burden as a result of addition of the sulfuric acid
aerosol qualifier. In addition, under EPA's general approach to reuse systems, a toxic chemical is
not counted toward thresholds each time it is reused but only once per reporting period, and that
approach would apply to sulfuric acid reuse systems were it not for the aerosol qualifier.
Therefore, EPA is providing the following guidance to reduce the reporting burden for facilities
that operate such processes and to bring the treatment of such systems into alignment with EPA's
general approach to reuse.
Rather than having facilities count all quantities of acid aerosol generated in such
systems towards the "manufacture" and "otherwise use" thresholds, EPA will allow facilities to
apply the total volume of acid in these systems only once to these thresholds. For example, if an
acid reuse system starts the year with 2000 pounds of acid and 500 pounds is added during the
year then the total amount applied towards acid aerosol thresholds would be 2500 pounds. This
reflects a one time per year counting of all of the acid molecules as being in the acid aerosol form
rather than counting them over and over again each time the acid aerosol form is generated and
subsequently used. Since in these acid reuse systems the acid aerosols are "manufactured" and
then "otherwise used" the 10,000 pound "otherwise use" threshold would be the threshold that
would first trigger reporting from such systems.
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This guidance applies only to acid reuse systems and the reporting of sulfuric acid
aerosols under EPCRA section 313. This guidance does not apply to any other types of processes
or to any other listed chemical.
2.2. Sulfuric Acid Aerosols Removed By Scrubbers
When a scrubber is used to remove sulfuric acid aerosols prior to or in a stack, the
acid aerosols are usually converted to the non-aerosol form. The non-aerosol forms of sulfuric
acid are not reportable under EPCRA section 313 because the qualifier to the sulfuric acid listing
includes only acid aerosol forms. Sulfuric acid as a discrete chemical has not actually been
destroyed by the scrubber, but the form of sulfuric acid reportable under EPCRA section 313 has
been destroyed. Therefore, since sulfuric acid aerosols removed by scrubbers are converted to a
non-reportable form, the quantity removed by the scrubber can be reported as having been treated
for destruction.
2.3. Sulfuric Acid Aerosols Generated In Storage Tanks
Sulfuric acid aerosols are generated in the empty space (head space) above
sulfuric acid solutions contained in storage tanks. The amounts of acid aerosols generated in such
storage tanks are to be applied towards the "manufacture" threshold for sulfuric acid aerosols. In
such storage tanks the sulfuric acid molecules are constantly moving between the atmosphere and
the solution. EPA does not intend for facilities to count such movement of the acid molecules in
and out of the stored acid solution as continuous "manufacture" of sulfuric acid aerosols. For
such storage tanks the amount of acid aerosol to be applied towards the "manufacture" threshold
is the average amount that existed in the atmosphere above the acid solution during the year.
Each facility should determine the average conditions for their specific storage
tank (i.e., the capacity of the tank, the average amount in the tank, the average head space in the
tank, the concentration of the acid solution stored, the temperature, and other information that
may have an impact on aerosol calculations) and make the appropriate calculation of the amount
of acid aerosol to apply towards the "manufacture" threshold. Any amounts of sulfuric acid
aerosols that may be released from the storage tank through venting or fugitive releases must also
be included in the threshold determination. If the storage tank is refilled and drawn down several
times during the year then the calculations should be based on all of the acid that was stored in
the tank. For example, if a 10,000 pound capacity tank is refilled and drawn down 6 times during
the year (such that 60,000 pounds of acid were stored in the tank during the year) then the tank
calculations, based on the average condition for one 10,000 pound tank of acid, should be
multiplied by 6.
Section 3.0. Sulfuric Acid And Its Formation In Air
Sulfuric acid (H2SO4) is miscible in water in all proportions and has a strong
attraction for water. The anhydrous chemical boils at 279.6EC (1). Commercial sulfuric acid
normally contains 93 to 98% sulfuric acid with the remainder being water. A boiling point-
composition diagram (Figure 1, Appendix 1) for aqueous sulfuric acid, indicates that below 75%
H2SO4, the vapor evaporating from a solution of the acid is essentially water. This fact is
illustrated in Table la of Appendix 1, which contains the partial pressure of sulfuric acid and
total vapor pressure of the solution over aqueous sulfuric acid solutions at various concentrations
C-4
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(1). Since the partial pressure of concentrated sulfuric acid is very low, little sulfuric acid is
expected to volatilize from sulfuric acid solutions such as may be present in storage tanks.
However, as discussed above, the amount of acid aerosols generated is dependent on the quantity
of acid in the tank(s) during the year, the concentration, temperature, and other factors. The
information in Appendix 1 and the guidance in section 2.3 can be used to assist in determining if
significant amounts of sulfuric acid aerosols are present in storage tanks.
Sulfuric acid containing dissolved sulfur trioxide (SO3) is known as oleum,
fuming sulfuric acid or disulfuric acid. The vapor pressure of sulfuric acid over oleum containing
10% to 30% of free SO3 by weight is shown in Table 2a of Appendix 1 (2). Since the vapor
pressure of sulfur trioxide over oleum is high, sulfuric acid aerosols also form when oleum is
exposed to air containing moisture.
Sulfuric acid is generally formed by the oxidation of sulfur dioxide (SO2) and the
reaction of the resulting sulfur trioxide (SO3) with water.
so2 + y2o2 -»> so3
SO3 + H2O ->> H2SO4
While thermodynamically, SO2 has a strong tendency to react with oxygen to form SO3; under
normal tropospheric (lower atmosphere) conditions the reaction rate is very slow in the gas phase
(3, 17, 18, 19). Other than within a reaction chamber, SO2 is unlikely to generate SO3 and then
sulfuric acid. However, once SO3 is formed, it is converted to H2SO4 so rapidly (within
milliseconds) at normal humidities, that any reaction in which SO is formed in moist air is
equivalent to forming H2SO4 (3,18). In stacks from combustion processes, moisture in the stack
would be expected to convert any SO3 present into sulfuric acid aerosols. This being the case, the
quantity of SO generated in such stacks (multiplied by 98.08/80.07, the molecular weight of
sulfuric acid divided by the molecular weight of sulfur trioxide) should be included with those of
H2SO4. If SO3 is produced within a stack or unit of the plant without moisture present, sulfuric
acid aerosols would not be produced. Although the SO3 releases may be converted to H2SO4 in
the environment, facilities are not responsible for conversions that may take place in the
environment after a chemical that is not listed under EPCRA section 313, such as SO3, has been
released. Therefore, if SO3 is the chemical that is released from the facility, the facility is not
required to include it, or any H2SO4 produced in the environment from the released SO3, in any
EPCRA section 313 calculations of thresholds or releases.
Section 3.1. Industrial Sources Of Sulfuric Acid Aerosols
It is clear that industries required to report sulfuric acid aerosol releases will be
among those that had previously reported sulfuric acid releases to air under EPCRA section 313.
Facilities that previously reported over 25,000 pounds of sulfuric acid releases to air have
exceeded the manufacturing threshold quantity of sulfuric acid aerosols necessary for reporting
under the new listing. Additional facilities may be required to report because releases of sulfuric
acid to air would not have included, for example, amounts of sulfuric acid aerosols that were
produced in the stack and subsequently removed by scrubbers or produced internally during
sulfuric acid manufacturing, processing, or use and that were removed by scrubbers prior to the
stack. Since these amounts of sulfuric acid aerosols do count towards the EPCRA section 313
threshold determinations, facilities with less than 25,000 pounds of air releases are not excluded
from reporting. In addition, some facilities may be using sulfuric acid aerosols in excess of
C-5
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10,000 pounds and would also be required to report. According to the 1993 Toxics Release
Inventory (TRI), there were 191 facilities reporting releases of 25,000 pounds or more of sulfuric
acid to air. The number of these facilities in each of 2-digit standard industrial categories (SIC) is
shown in Table 1, as well as the prominent types of industries within the category that have
reported sulfuric acid emissions to air. The industries shown in italics include 34 facilities that
are in the 80th percentile (over 178,000 pounds per year) for sulfuric acid releases to air. These
34 facilities' air emissions are almost entirely from point sources, suggesting that either sulfuric
acid is formed in the stack from sulfur trioxide or sulfuric acid is aerosolized in a process that
leads to its release in the stack. Thirty two of these sites reported producing the sulfuric acid; the
copper smelters and phosphate fertilizer plants produced sulfuric acid for sale or distribution.
Table 1. Industrial Categories of Facilities Emitting over 25,000 Ibs/yr of Sulfuric Acid
Aerosols in 1993
Category (SIC Code)
Paper and Allied Products (26)
Chemicals and Allied Products (28)
Primary metal industries (33)
Food and Kindred Products (20)
Lumber, Wood Products (24)
Stone, clay, glass, concrete (32)
Petroleum refining (29)
Metal Products, except machinery (34)
Tobacco Manufacturers (21)
No. Sites*
185
53
23
11
8
6
4
4
1
Major Industries**
Pulp, paper and paperboard mills.
Phosphate fertilizers; Industrial inorganic chemicals.
Copper smelting; Blastfurnaces and steel mills
Wet corn milling; fats and oils; liquors; malt beverages.
Sawmills; Reconstituted wood products
Glass
Petroleum refining
Metal coatings
Tobacco stemming and redrying
*A site may list more that one SIC code.
** The industries shown in italics include facilities that are in the 80th percentile for sulfuric acid releases to air.
The industrial breakdown does not necessarily indicate that emissions result from
processes unique to the industry. For example, phosphate fertilizer manufacturers, which use
sulfuric acid to make phosphoric acid and normal superphosphate, may produce their own
sulfuric acid from elemental sulfur and may also use it captively. Sulfuric acid emissions from
phosphate fertilizer manufacturing may therefore be primarily from sulfuric acid manufacturing.
Similarly, sulfuric acid is a known component in flue gas from fossil fuel combustion and waste
incineration. The SO3/H2SO4 (SO3, as stated previously is immediately transformed into sulfuric
acid in the presence of water) produced from combustion sources is between 1 and 3% of the SOX
emitted by these sources (the rest being SO2). It is not clear why sulfuric acid is emitted from
combustion sources. A possible explanation is that there are substances in the flue gas or on the
stack walls that catalyze the oxidation of sulfur dioxide to sulfur trioxide, similar to the
heterogeneous reactions that can occur in the atmosphere (17-19). Sulfuric acid is also formed in
some flue desulfurization processes (7).
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Section 3.1.1 Pulp and Paper Mills
The kraft pulping process involves the digesting of wood chips at elevated
temperature in "white liquor", an aqueous solution of sodium sulfide and sodium hydroxide, to
dissolve the lignin that binds the cellulose fibers of the wood together. The spent liquor used to
digest wood chips, called "black liquor", is combusted in recovery furnaces to recover heat and
cooking chemicals. Sulfuric acid is present in flue gas from kraft recovery furnaces and has been
cited as being one of the five most prevalent air toxics released from recovery furnaces of the
direct contact evaporator (DCE) and non-direct contact evaporator (NDCE) types (21). In a DCE,
the flue gas comes in contact with the black liquor, whereas in a NDCE, it does not. Field tests
on five Kraft recovery furnaces showed SO3/H2SO4 levels ranging from 0 to 3 ppm in the flue
gas, with an average level of 0.81 ppm, or about 10% of that found in fossil fuel plants burning
fuel containing 1-3% sulfur (4). In these tests, no correlation was found between SO2 and
SO3/H2SO4 levels. Therefore, one cannot estimate emission factors for SO3/H2SO4 based on those
for SO2. While EPA has compiled emission factors for pollutants from kraft, acid sulfite, and
neutral sulfite semichemical (NSSC) pulping (9), no emissions factors have been presented for
SO3/H2SO4. However, industry tests of Kraft recovery furnaces have been performed between
1989 and 1993 and the results are presented in Table 2 (20).
Table 2. Emission Factors from Kraft Recovery Furnaces *
Mill Code (date built/rebuilt)**:
Control device/ Type evaporator
A: WB, Cascade
B:ESP
RFI (1973): WB ESP, Cascade
RFRIG1 (1991):WB ESP, Cyclone
RFRIG2 (1991): WB ESP, Cyclone
SUMMARY
C:DB
D: DB ESP
E:ESP
RFO (1986): DB ESP
SUMMARY
Type
DCE
DCE
DCE
DCE
DCE
DCE
NDCE
NDCE
NDCE
NDCE
NDCE
BLS
MPPD
3.12
16.56
0.85
2.63
9.84
18.60
12.00
1.90
H2SO4 Emissions in Ib/ton BLS
Range
ND to 4.7E-02
NDto 1.5E-02
4.60 ND to 2.5E-02
NDto 1.9E-02
NDto 1.9E-02
0.21 to 0.91 ppm
0.17 to 2. 98 ppm
0.49 to 1.71 ppm
NDto 1.6E-01
Average
1.6E-02
8.4E-03
1.4E-02
ND(2.0E-02)
8.2E-03
8.4E-03 (Median)
3.3E-02
7.1E-02
5.1E-02
ND(1.3E-02)
4.2E-02 (Median)
* Abbreviations: BLS = black liquor solids; ND = not detected; DCE = direct contact evaporator; NDCE = non-direct
contact evaporator; ESP = electrostatic precipitator; WB = wet bottom; DB = dry bottom; MPPD = million pounds
per day. Type evaporator given for DCE types only.
** Mills with codes not preceded by "RF " are from a 1980 study (4). Dates when these mills were built or rebuilt
are not available.
The median sulfuric acid emissions from the direct contact (DCE) and non-direct
contact (NDCE) evaporator recovery furnaces, 8.4E-03 pounds per ton black liquor solids (BLS)
and 4.2E-02 pounds per ton BLS, respectively, can be used to estimate sulfuric acid emissions.
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For example, if a kraft mill using 1100 air dry tons of unbleached pulp per day (ADTUBPD)
generates 3300 pounds BLS per ADTUBPD and operates two DCE furnaces 365 days per year,
the pounds of H2SO4, H, emitted during the year will be:
H = 1100 ADTUBPD x 365 days/year x (3300 Ibs. BLS/ADTUBPD x ton BLS/2000 Ibs BLS)
x 8.4E-03 Ibs. H SO /ton BLS = 5,565 Ibs. of H2SO4
The pounds of sulfuric acid aerosols produced in recovery furnaces on site should be combined
with that produced from fuel oil and coal combustion. Should the total equal or exceed 25,000
pounds per year, reporting would be required under EPCRA Section 313. It should be noted that
sulfuric acid used at the site for such purposes as C1O2 generation, pH control, and ion exchange
generation no longer must be reported since aerosol forms of H2SO4 are not involved.
Section 3.1.2 Acid Aerosols from Sulfuric Acid Manufacture
Sulfuric acid may be manufactured commercially by either the lead chamber
process or the contact process. However, sulfuric acid is usually produced by the contact process
(1, 2, 10, 22). In the contact process, sulfur is oxidized to SO2 which is subsequently fed into a
converter where it is catalytically oxidized to SO3. Finally, the sulfur trioxide is absorbed in a
strong sulfuric acid solution or oleum. Sulfuric acid plants are further classified by feedstock:
elemental sulfur burning, spent sulfuric acid and hydrogen sulfide burning, and metal sulfide ores
and smelter gas burning. Contact sulfuric acid plants vary in design depending on the raw
material used to produce SO2. Oleum is also produced in contact plants, where SO3-containing
gases are passed through a special oleum tower. Regeneration of spent sulfuric acid is another
form of sulfuric acid manufacture, often performed in order to comply with antipollution
regulations (1).
Sulfuric Acid Manufacture
The amount of sulfuric acid aerosols produced in sulfuric acid manufacture is a
function of the type of sulfur feedstock, the concentration of the absorbing acid, and the
conditions in the absorber (1, 2, 22). Elemental sulfur produces little acid mist when burned
because there is little water present. However the hydrocarbons in other feedstock (such as spent
acid) produce water vapor during combustion. The affect of acid strength on mist production is
illustrated by results showing 0.5 to 5.0 kilograms (kg) of uncontrolled acid aerosol emissions
per Megagram (Mg) of acid produced (1.0 to 10.0 pounds (Ib) of acid emissions per ton of acid
produced) from oleum plants burning spent acid compared with 0.2 to 2.0 kg/Mg (0.4 to 4.0
Ib/ton) of emissions from 98% sulfuric acid plants burning elemental sulfur. In addition, the
aerosol particle size from oleum plants is finer than that from the 98% sulfuric acid plants. The
operating temperature of the absorption tower affects SO3 absorption and, accordingly, acid mist
formed in the exit gas. In an elemental sulfur burning plant, after the sulfur is burned to SO2 and
catalytically converted to SO3, the gas enters one or multiple absorption towers (packed
columns), usually operated in countercurrent, in which the sulfur trioxide is absorbed in sulfuric
acid of 98-99% concentration to form more sulfuric acid (1, 2, 22). The optimal operating
temperature of the absorption tower depends on the strength of the acid produced, throughput
rate, inlet sulfur trioxide concentrations and other factors peculiar to a particular plant. The
optimal concentration of the absorbing acid is the azeotrope (see Appendix 1), 98.3%, where the
combined vapor pressures of H2SO4, SO3, and water are at a minimum. At lower concentrations,
the water vapor partial pressure is higher and there is a greater risk of sulfuric acid mist
-------
formation. At higher concentrations the tail gas will contain increased amounts of H2SO4 and SO3
because of their higher partial pressures. Both sulfuric acid mist formed within the system and
gaseous sulfuric acid vaporized from the concentrated acid in the absorption towers and carried
along with the predominant sulfur trioxide gas, constitute sulfuric acid aerosols that are being
manufactured and therefore contributing to the manufacturing threshold of sulfuric acid aerosols
for reporting under section 313 of EPCRA. Sulfuric acid mists entrained in tail gas are separated
by special filters and determined by measurement of the acid content.
Regeneration of Spent Sulfuric Acid
The regeneration of spent sulfuric acid normally comprises two major steps,
concentration to the highest feasible level and decomposition of the spent acid (1). Water is
essentially the only substance evaporated (other than volatile organic impurities) in concentrating
the acid to <75% H2SO4. Vapors evolved during the concentration of spent sulfuric acid to a
more highly concentrated state (93-98% H2SO4) contain significant quantities of gaseous sulfuric
acid (1). The formation of this gaseous sulfuric acid contributes to the manufacturing threshold of
sulfuric acid aerosols for reporting under section 313 of EPCRA. Spent sulfuric acid may be
concentrated in either vacuum or drum concentrators. While vacuum concentrators yield
negligible emissions, those from drum concentrators contain acid mist. Exit gas is passed through
scrubbers before being vented to the atmosphere. Emissions from acid drum concentrators
operating at 55, 73, and 100% of capacity are reported to be 7034, 2401, and 2334 metric ton/day
(12).
Acid Aerosol Emissions
Nearly all the sulfuric acid aerosols emitted from sulfuric acid manufacturing
plants come from the absorber exit gases. The exit gas contains small amounts of SO2, even
smaller amounts of SO3, and sulfuric acid vapor and mist. Even with efficient gas drying, mist
formation is impossible to eliminate completely. Once formed, these aerosols are of such a fine
particle size and so stable that only a small amount can be removed in the absorber. Sulfuric acid
is normally combined with SO3 in determining an emission factor because SO3 reacts so rapidly
with water vapor. The emission factor for SO3 is calculated as 100% H SO and added to the
H2SO4 value.
Sulfuric acid mists are always formed when sulfur trioxide combines with water
vapor at temperatures below the dew point of sulfur trioxide. The dew point is a function of gas
composition and pressure and is generally around 140-170EC. Equations are available that
predict the dewpoint for different concentrations of H2O and H2SO4 (4). Examples are given in
Section 3.1.5 in Tables 6 and 8 for coal and fuel oil combustion.
Use of Sulfuric Acid Emission Monitoring Data
Some sulfuric acid manufacturing facilities may have sulfuric acid emission
monitoring data available that can be used to estimate emissions for sulfuric acid mist under the
Clean Air Act New Source Performance Standards (NSPS). Sulfuric acid plants constructed or
modified after August 17, 1971, are subject to a sulfuric acid mist emissions limit of 0.15 pounds
of sulfuric acid per ton of 100% sulfuric acid produced (see Part 60 Subpart H of Title 40 of the
Code of Federal Regulations). If such information is available, it is preferable to use such data for
estimating uncontrolled emissions of sulfuric acid, rather than published emission factors since
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monitoring data should be the best available data. If the measured data available is for controlled
emissions, then the amount of sulfuric acid generated prior to emission controls should be
calculated based on the average actual control efficiency for the acid mist.
Uncontrolled H2SO4 emissions = actual emissions to air/(l-efficiency)
(Efficiency expressed as a fraction)
Emission factors for sulfuric acid plants have been compiled by EPA (10).
Uncontrolled emission factors for various sulfuric acid plants are shown in Table 3. Table 4
contains emission factors for plants using three of the most commonly used fiber mist eliminator
control devices, vertical tube, vertical panel, and horizontal duel pad types.
Table 3. Uncontrolled Emission Factors for Sulfuric Acid Plants
Raw material
Recovered sulfur
Bright virgin sulfur
Dark virgin sulfur
Spent acid
*
Oleum produced
% Total output
0-43
0
0-100
0-77
Emissions of H2SO4 aerosol per unit product
kg/Mg
0.174-0.4
0.85
0.16-3.14
1.1-1.2
Ib/ton
0.348-0.8
1.7
0.32-6.28
2.2-2.4
*Sulfuric acid containing dissolved sulfur trioxide. Also known as fuming sulfuric acid or disulfuric acid.
Table 4. Controlled Emission Factors for Sulfuric Acid Plants
Raw material
Elemental sulfur
Dark virgin sulfur
Spent acid
*
Oleum produced
% Total output
—
0-13
0-56
Emissions of H2SO4 aerosol per unit product
kg/Mg
0.064
0.26-1.8
0.014-0.20
Ib/ton
0.128
0.52-3.6
0.28-0.40
*Sulfuric acid containing dissolved sulfur trioxide. Also known as fuming sulfuric acid or disulfuric acid.
Section 3.1.3. Smelters
Sulfuric acid is a byproduct of metals production, notably copper, and is
accordingly sometimes referred to as smelter acid. Smelters produce sulfuric acid by the contact
process with the raw material being classified as 'metal sulfide ores and smelter gas burning' (see
Section 3.1.2). The smelter gas (SO2 from the smelter furnace) is passed through cyclone dust
collectors, electrostatic dust and mist precipitators, and scrubbing and gas cooling towers to
remove dust, acid, mist and other impurities. The gas is then converted to SO3 and then H2SO4 in
processes similar to those used in sulfuric acid plants using elemental sulfur as a raw material
(Section 3.1.2). Therefore, the potential for sulfuric acid aerosols formation is similar to the
described above in the third paragraph of Section 3.1.2.
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Section 3.1.4. Petroleum Refining
Crude oil contains a small amount of sulfur as an impurity. As a result, sulfur
oxides are emitted from petroleum refineries. EPA has compiled emission factors of sulfur
oxides, SOX, for petroleum refining, but factors for sulfuric acid are not provided (11). However,
according to information provided by the American Petroleum Institute (API), the staff in API's
Health and Environmental Sciences Department uses the following EPA reference for sulfuric
acid emission factors: EPA. 1995. Compilation of Air Pollutant Emission Factors. Vol. 1:
Stationary Point and Area Sources. Section 8.10, AP-42, 5th ed. (January 1995). Research
Triangle Park, NC: U.S. EPA, OAQPS.
Section 3.1.5. Sulfuric Acid Aerosol Formation In Stacks From Combustion Processes
Sulfuric acid aerosols are often formed in flue gas in a stack during combustion of
fuel oil, coal, or other sulfur-containing fuels. Both water and sulfur trioxide are combustion
products and they have great affinity for each other; as discussed they react quickly to form
sulfuric acid. When flue gas is cooled to temperatures at or below the dew point, a sulfuric acid
mist will form from any sulfuric acid gas present (16). The dew point is the temperature at which
the air becomes saturated and produces dew; sulfuric acid mists are always formed when sulfur
trioxide combines with water vapor at temperatures below the dew point of sulfur trioxide.
Because of the enormous attraction between sulfur trioxide and water "only a very small amount
of sulfur trioxide in combustion gas is required to draw water from the gas and form a fairly
concentrated acid" (16). In fact, flue gas containing 1% sulfuric acid has the corrosive properties
of 85% sulfuric acid solution. All sulfuric acid produced within the stack, including the gas not
just the mist, falls under the EPCRA section 313 definition of a sulfuric acid aerosol. The
information on dew points can be used to determine if any of the sulfuric acid present as gas will
form a mist that could potentially condense inside the stack.
Tables 5 and 7 below contain expected sulfur trioxide levels in flue gas resulting
from the combustion of fuel oil and coal, respectively, as a function of the sulfur content of the
fuel and the percent of excess air available (16). If water is present in the stack, Tables 5 and 7
can be used to estimate the amount of sulfuric acid gas that can be formed. Tables 6 and 8
contain empirically-derived dew points of SO3 for different concentrations of SO3 in stack gas of
oil- and coal-fired units, respectively. These tables can be used to determine whether the stack
temperature is below the dew point of SO3 and sulfuric acid mists are being formed in the stack
in flue gas. Examples of how to use these tables to determine the dew point of SO3 are given
below.
Assume a typical oil-fired unit is burning fuel oil containing 2% sulfur and that
17% excess air is present. From Table 5, we see that 15 ppm of SO3 will be present in the flue
gas and available to form sulfuric acid gas. From Table 6, we find that the dew point of SO3
should be 139°C. Therefore, if the temperature in the stack is at or below 139°C, sulfuric acid
mists will very likely form in the stack.
As an example dealing with coal combustion, assume a typical unit is burning
coal containing 3% sulfur in the presence of 25% excess air. From Table 7, we see that between
20 and 40 ppm of SO3 will be present in the flue gas and available to form sulfuric acid gas.
From Table 8, we find that the dew point should be between 136°C and 143 °C . Therefore, if the
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temperature in the stack is at or below 136°C to 143 °C, sulfuric acid mists will very likely form
in the stack.
Table 5. SO3 Production in Oil Fired Units
Excess air (%)
Sulfur in fuel (%)
5
11
17
25
SO3 Concentration in Flue Gas (ppm)
0.5
2
6
10
12
1.0
3
7
13
15
2.0
3
8
15
18
3.0
4
10
19
22
4.0
5
12
22
26
5.0
6
14
25
30
Table 6. Dew Point of SO3 in Stacks of Oil Fired Units*
SO in gas (ppm)
Dew point (°C)
5
130
10
135
15
139
20
141
25
143
30
145
35
147
40
148
45
149
50
150
55
151
60
152
65
153
70
154
*Using typical value of 10% water in oil
Table 7. SO3 Production in Coal Fired Units
Excess air (%)
Sulfur in fuel (%)
25
SO3 Concentration in Flue Gas (ppm)
0.5
3-7
1.0
7-14
2.0
14-28
3.0
20-40
4.0
27-54
5.0
33-66
Table 8. Dew Point of SO3 in Stacks of Coal Fired Units*
SO in gas (ppm)
Dew point (°C)
5
125
10
130
15
134
20
136
25
138
30
140
35
142
40
143
45
144
50
145
55
146
60
147
65
148
70
149
*Using typical value of 6% water in coal
Steel stacks are generally designed and operated so that a temperature between 135 °C (275 °F)
and 149°C (300°F) is maintained throughout the stack (16). These stack temperatures are such
that they may be below the dew point for SO3 in the flue gas, leading to the formation of sulfuric
acid mists in the stacks.
Section 3.1.6. Coal Combustion
Sulfuric acid aerosols are produced as a byproduct from boilers during coal
combustion. U.S. coals contain from 0.2% to 7% sulfur by weight (13). On average, about 95%
of sulfur present inbituminous coal will be emitted as gaseous sulfur oxides (SOX) when burned,
whereas somewhat less will be emitted when subbituminous coal is burned (15). In general,
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boiler size, firing configuration, and boiler operations have little effect on the percent conversion
of sulfur in fuel to sulfur oxides. About 0.7% of fuel sulfur is emitted as SO3/H2SO4 (15). This
information can be expressed as an uncontrolled emission factor (EF) of 0.43 x S pounds H2SO4
per ton of coal burned, where S is the weight percent sulfur in coal. The uncontrolled emission
factor also represents the amount of sulfuric acid produced in the stack, as well as that released to
the atmosphere in the absence of scrubbers or other emission control devices. The emission
factor for sulfur oxides (SOX) for bituminous coal combustion should not be used to estimate
sulfuric acid emissions since the factor includes sulfur dioxide. If C is the tons of coal burned,
the pounds of H2SO4 generated (H), would be:
H = 0.43 x S x C
For example, if 9,000 tons of coal were burned and the coal contained 3% sulfur, then:
H = 0.43 x 3 x 9,000 = 11,610 pounds of H2SO4
Note that the values for the variables C and S have been chosen as an illustration. Values must be
chosen that are appropriate for the particular operations at each facility.
Section 3.1.7. Fuel Oil Combustion
Sulfuric acid aerosols are produced during fuel oil combustion from the oxidation
of sulfur contained in the fuel. There are various types of fuel oil combustion operations; the type
of operation depends on the type of fuel oil burned. There are mainly five types of fuel oil used
for commercial, industrial, and residential use in the U.S. The No. 1 and No. 2 fuel oils are
known as distillate oils. They have high volatility, low viscosity, and <0.3% sulfur by weight.
They are primarily used in domestic and small commercial operations. The No. 5 (also called low
sulfur No. 6) and No. 6 fuel oils are known as residual oils. They have low volatility, high
viscosity, and high sulfur content. They are mainly used in industrial operations. The No. 4 fuel
oil is a mixture of distillate and residual oils and can be used for both types of operations. Typical
sulfur contents of fuel oil are (13):
Fuel Oil Grade Sulfur Content (wt %)
No. 1 0.09
No. 2 0.22
No. 4 1.35
No. 5 0.84
No. 6 3.97
Uncontrolled SOX emissions are almost entirely dependent on the sulfur content of
the fuel and are not affected by boiler size and design or the grade of fuel being burned. On the
average, over 95% of the sulfur in fuel oil is converted to SO2 on combustion; about 1 to 5
percent is further oxidized to sulfur trioxide where it readily reacts with water vapor in flue gas to
form sulfuric acid aerosols. The emission factor (°F) for uncontrolled fuel oil combustion from
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industrial boilers is 0.002 x S pounds SO3 per gallon of fuel oil burned (14) or 0.00245 x S
pounds H2SO4 per gallon of fuel oil burned, where S is the weight percent sulfur in the fuel oil.
The uncontrolled emission factor also represents the amount of sulfuric acid produced in the
stack, as well as that released to the atmosphere in the absence of scrubbers or other emission
control devices. An example of the use of the emission factor (°F) to calculate the pounds of
sulfuric acid generated is shown below. If F is the number of gallons of fuel oil burned, the
pounds of H2SO4 generated (H), would be:
H = 0.00245 x S x F
For example, if 4,500,000 gallons of fuel oil were burned and the fuel oil contained 3.97% sulfur,
then:
H = 0.00245 x 3.97 x 4,500,000 = 43,769 pounds of H2SO4
Note that the values for the variables F and S have been chosen as an illustration. Values must be
chosen that are appropriate for the particular operations at each facility.
Section. 4.0. Measurement Methods
For source sampling, EPA has specified extractive sampling trains and analytical
procedures for SO3 and sulfuric acid aerosols (7, 8). Separation of particles containing Na2SO4
may present problems in cases such as Kraft paper mills (4). If sodium sulfate is present,
analytical results for sulfuric acid would be high.
References
(1) Muller H. 1994. Sulfuric Acid and Sulfur Trioxide. Ullmann 's Encyclopedia of Industrial
Chemistry, Vol A25, pp. 635-702.
(2) Donovan JR, Salamone JM. 1983. Sulfuric Acid and Sulfur Trioxide. Kirk Othmer
Encyclopedia of Chemical Technology, 3rd ed. Vol 22, pp. 190-232.
(3) Calvert JG. 1984. SO2, NO andNO2 Oxidation Mechanisms: Atmospheric Considerations.
Buttersworth Publishers, pp. 1-62.
(4) National Council for Air and Stream Improvement (NCASI). 1980. A Study of SOX
measurement procedures and their use at Kraft recovery furnaces. Atmospheric Quality Technical
Bulletin No. 106, National Council for Air and Stream Improvement, New York, NY. April 17,
1980.
(5) EPA. 1995. Sulfuric acid: Toxic chemical release reporting: Community right-to-know. Final
rule. 60 FR 34182. June 30, 1995.
(6) Wolff GT. 1991. Air pollution. Kirk Othmer Encyclopedia of Chemical Technology, 4th ed.
Vol Al, pp. 725.
(7) Crocker BB. 1991. Air pollution control methods. Kirk Othmer Encyclopedia of Chemical
Technology, 4th ed. Vol 1, pp. 749-825.
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(8) EPA. 1975. Part 60 - Standards of performance for new stationary sources. Emission mon-
itoring requirements and revisions to performance testing methods. 40 FR 46250 October 1975.
(9) EPA. 1990. Compilation of Air Pollutant Emission Factors (AP-42). Wood Products Industry.
Chemical Wood Pulping. 10.2-1 to 10.2-20. September, 1990. Research Triangle Park, NC: U.S.
EPA, OAQPS.
(10) EPA. 1993. Compilation of Air Pollutant Emission Factors (AP-42). Inorganic Chemical
Industry. Sulfuric acid. 8.10-1 to 8.10-10. July, 1993. Research Triangle Park, NC: U.S. EPA,
OAQPS.
(11) EPA. 1993. Compilation of Air Pollutant Emission Factors (AP-42). Petroleum industry.
Petroleum refining. 5.1-1 to 5.1-16. January, 1995. Research Triangle Park, NC: U.S. EPA,
OAQPS.
(12) Gerstle RW, Katari VS. 1977. Industrial Process Profiles for Environmental Use: Chapter
23. Sulfur, Sulfur Oxides and Sulfuric Acid. Prepared for Industrial Environmental Research
Laboratory, Cincinnati, OH, Austin, TX: Radian Corporation. [NTIS PB-281 490]
(13)PerryRH, Green DW. 1984. Perry's Chemical Engineers' Handbook, 6th Edition, pp. 3-68,
9-38 to 9-50. New York, NY: McGraw-Hill Book Company.
(14) EPA. 1995. Compilation of Air Pollutant Emission Factors (AP-42). Fuel Oil Combustion
(AP-42). pp. 1.3-1 to 1.3-34. January 1995. Research Triangle Park, NC: U.S. EPA, OAQPS.
(15) EPA. 1995. Compilation of Air Pollutant Emission Factors (AP-42). Bituminous and
Subbituminous Coal (AP-42). pp. 1.1-1 to 1.1-40. January 1995. Research Triangle Park, NC:
U.S. EPA, OAQPS.
(16) Pierce R. 1977. Estimating acid dew points in stack gases. Chemical Engineering, April 11,
1997, vol. 89, pp. 125-128.
(17) Eatough DJ, Caka FM, Farber RJ. 1994. The conversion of SO2 to sulfate in the atmosphere.
Israel Journal of Chemistry 34: 301-314.
(18) EPA. 1982. Air Quality Criteria for Paniculate Matter and Sulfur Oxides, Volume II, EPA-
600/8-82-029b. Research Triangle Park, NC: U.S. EPA, Environmental Criteria and Assessment
Office, pp. 2-1 to 2-100.
(19) EPA. 1988. Acid Aerosols Issue Paper. EPA-600/8-88-005a. Washington, D.C.: Office of
Heath and Environmental Assessment, pp. 2-1 to 2-74.
(20) National Council for Air and Stream Improvement (NCASI). 1995. Compilation of 'Air
Toxic' and total hydrocarbon emission data for sources at chemical wood pulp mills. Volume 2.
Technical Bulletin No. 701, National Council for Air and Stream Improvement, Research
Triangle Park, NC. October 1995.
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(21) National Council for Air and Stream Improvement (NCASI). 1996. Proceedings of the 1995
NCASI Southern Regional Meeting. Volume 2. Special Report No. 96-01, National Council for
Air and Stream Improvement, Research Triangle Park, NC. October 1995. P. 326.
(22) Muller TL. 1992. Air Pollution Engineering Manual. Buonicore, AJ and Davis WT, eds,
Van Nostrand Reinhold, New York., pp.469-476.
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APPENDIX 1
Figure la. Boiling curves for sulfuric acid at 1013 mbar a)
Vapor; b) Liquid (reference 1).
Information in the above figure shows that if the vapor above a solution of 85%
sulfuric acid, boiling at 223 °C, were to be completely condensed it would contain approximately
7 percent H2SO4. At concentrations below approximately 75% H2SO4, the vapor that evaporates
from the solution is essentially water.
Table la. Sulfuric Acid Partial Pressure and Total Vapor Pressure (bar) over Aqueous Sulfuric Acid*
°F
32
68
104
140
176
212
302
392
482
572
Weight Percent Sulfuric Acid
20.0
.843E-20
(.534E-02)
.769E-18
(.205E-01)
.389E-16
(.649E-01)
.121E-14
(.175)
.254E-13
(.417)
.381E-12
(.891)
.106E-09
(4.132)
.883E-08
(13.107)
.312E-06
(31.939)
.591E-05
(64.407)
40.0
.344E-17
(.326E-02)
.193E-15
(.130E-01)
.649E-14
(.427E-01)
.144E-12
(.119)
.225E-11
(.290)
.264E-10
(.634)
.460E-08
(3.090)
.278E-06
(10.245)
.793E-05
(26.056)
.130E-03
(54.869)
60.0
.438E-14
(.836E-03)
.149E-12
(.367E-02)
.317E-11
(.131E-01)
.462E-10
(.395E-01)
.492E-09
(.104)
.402E-08
(.244)
.316E-06
(1.392)
.975E-05
(5.312)
.156E-03
(15.351)
.156E-02
(36.361)
80.0
.161E-10
(.197E-04)
.305E-09
(.115E-03)
.379E-08
(.531E-03)
.334E-07
(.204E-02)
.222E-06
(.668E-02)
.117E-05
(.192E-01)
.343E-04
(.170)
.457E-03
(.913)
.358E-02
(3.439)
.266E-01
(9.916)
98.0
.187E-08
(.117E-07)
.224E-07
(.121E-06)
.191E-06
(.914E-06)
.122E-05
(.538E-05)
.622E-05
(.257E-04)
.261E-04
(.103E-03)
.493E-03
(.180E-02)
.470E-02
(.166E-01)
.278E-01
(.985E-01)
.117E-00
(.425)
0.0
.228E-08
(.323E-08)
.273E-07
(.435E-07)
.230E-06
(.425E-06)
.147E-05
(.319E-05)
.743E-05
(.193E-04)
.310E-04
(.966E-04)
.574E-03
(.287E-02)
.538E-02
(.427E-01)
.314E-01
(.389)
.130E-00
(2.476)
* Total pressure is in parentheses. Conversion Factors: 1 bar = 0.98677 atmospheres = 14.7 psia = 760 mm Hg = 0.1
MPa
C-17
-------
The above table contains the partial pressure of sulfuric acid and total vapor
pressure of the solution (in parentheses) over aqueous sulfuric acid solutions in the concentration
range of 20 to 100 weight percent sulfuric acid (1). From Table la we see that the partial pressure
of sulfuric acid above a sulfuric acid solution is very low compared to the total vapor pressure for
sulfuric acid solutions below 80% sulfuric acid; the bulk of the vapor being composed of water.
Consequently when a solution of sulfuric acid boils, more water than sulfuric acid is volatilized,
so that the concentration of the remaining acid increases and the boiling point of the solution
rises. This process continues until the acid concentration reaches 98.3 weight % H2SO4, when an
azeotrope (a mixture of two liquids that boils at constant composition; i.e., the composition of the
vapor is the same as that of the liquid) is formed and the concentration of sulfuric acid in the
vapor is the same as that of the solution. The vapor above sulfuric acid solutions containing more
than 98.3 weight % H2SO4 also includes considerable amounts of SO3, thus the difference
between the partial pressure and total pressure of 100% sulfuric acid is the partial pressure of
sulfur trioxide. Since the partial pressure of concentrated sulfuric acid is very low, little sulfuric
acid is expected to volatilize from sulfuric acid solutions such as may be present in storage tanks.
No experimental data are available on sulfuric acid aerosol emissions from storage tanks.
Above 340°C, H2SO4 decomposes into sulfur trioxide and water. The vapor-phase
reaction of sulfur trioxide and water results in aerosols of sulfuric acid. The H2SO4/H2O/SO3
system is important in the production of sulfuric acid by the contact process as well as in the
prevention of corrosionfrom condensing sulfuric acid in stack emissions from the combustion of
sulfur-containing fuels. Sulfuric acid containing dissolved sulfur trioxide is known as oleum,
fuming sulfuric acid or disulfuric acid. The vapor pressure of sulfuric acid over oleum containing
10% to 30% of free SO3 by weight is shown in Table 2a (2). Since the vapor pressure of sulfur
trioxide over oleum is high, sulfuric acid aerosols also form when oleum is exposed to air
containing moisture.
Table 2a. Sulfuric Acid Partial Pressure (bar) over Oleum *
°c
20
40
60
80
100
Free SO3 in oleum, %
10
.227 E-08
.1467E-07
.7333 E-07
.3066 E-06
.1067E-05
20
.120 E-08
.667 E
.400 E-07
.1600 E-06
.5333 E-06
30
.40 E-09
-08 .267 E-08
.1333 E-07
.600 E-07
.2133 E-06
Conversion Factors: 1 bar = 0.98677 atmospheres = 14.7 psia = 760 mm Hg = 0.1 Mpa;
°F=1.8(°C) + 32.
C-18
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Appendix D
GUIDANCE FOR REPORTING AQUEOUS AMMONIA
-------
United States Environmental
Protect! on_Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
July 1995
EPA745-R-95-012
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
EPCRA Section 313
Guidance for Reporting Aqueous Ammonia
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using
listed toxic chemicals to report their environmental releases of such chemicals annually.
Beginning with the 1991 reporting year, such facilities also must report pollution prevention and
recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42
U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals
that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section
313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth
criteria for these actions.
CONTENTS
Section 1. Introduction D-2
1.1 Who Must Report D-2
1.2 Thresholds D-2
1.3 Chemical Sources of Aqueous Ammonia D-3
1.4 De Minimis Concentrations D-3
Section 2. Guidance for Reporting Aqueous Ammonia D-4
2.1 Determining Threshold and Release Quantities for Ammonia D-4
2.2 Chemical Sources of Aqueous Ammonia D-5
2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous
Ammonia
in Water D-5
2.2.2 Reporting of Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate) D-6
2.2.3 Reporting of Aqueous Ammonia Generated from the Dissociation
of Ammonium Nitrate D-7
Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia . . D-10
D-l
-------
Section 1. Introduction
On June 30, 1995 EPA finalized four actions in response to a petition received in
1989 to delete ammonium sulfate (solution) from the list of toxic chemicals subject to reporting
under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA), 42 U.S.C. 11001. The four actions taken are summarized as follows: (1)
deleted ammonium sulfate (solution) from the EPCRA Section 313 list of toxic chemicals, (2)
required that threshold and release determinations for aqueous ammonia be based on 10 percent
of the total aqueous ammonia present in aqueous solutions of ammonia, (3) modified the
ammonia listing by adding the following qualifier: 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), and (4) deleted ammonium nitrate (solution)
as a separately listed chemical on the EPCRA Section 313 list of toxic chemicals. All actions are
effective for the 1994 reporting year for reports due July 1, 1995, with the exception of the
deletion of ammonium nitrate (solution) as a separately listed chemical, which is effective for the
1995 reporting year for reports due July 1, 1996. At the time that these actions were finalized,
EPA indicated that the Agency would develop, as appropriate, interpretations and guidance that
the Agency determines are necessary to facilitate accurate reporting for aqueous ammonia. This
document constitutes such guidance for reporting under the ammonia listing.
Section 1.1 Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA Section
313, if it meets all three of the following criteria:
• It conducts manufacturing operations (is included in Standard Industrial
Classification (SIC) codes 20 through 39); and
• It has 10 or more full-time employees (or the equivalent 20,000 hours per
year); and
• It manufactures, imports, processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than
the "threshold" quantities specified below.
Section 1.2 Thresholds
Thresholds are specified amounts of toxic chemicals used during the calendar year
that trigger reporting requirements.
If a facility manufactures or imports any of the listed toxic chemicals, the
threshold quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility processes any of the listed toxic chemicals, the threshold quantity will
be:
• 25,000 pounds per toxic chemical or category over the calendar year.
D-2
-------
If a facility otherwise uses any of the listed toxic chemicals (without incorporating
it into any product or producing it at the facility), the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
Section 1.3 Chemical Sources of Aqueous Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia or
aqueous ammonia, they must report under the ammonia listing. EPA is providing a table of
Chemical Abstract Service (CAS) numbers and chemical names to aid the regulated community
in determining whether they need to report under the ammonia listing for aqueous ammonia.
This table includes a list of water dissociable ammonium salts which, when placed in water, are a
source of aqueous ammonia. The table contains only commonly used ammonium salts and
therefore is not exhaustive. If a facility manufactures, processes, or otherwise uses aqueous
ammonia, regardless of its source, it must report under the ammonia listing, even if the source of
the aqueous ammonia is not listed in the table provided in this document.
Section 1.4 DeMinimis Concentrations
The ammonia listing is subject to the one percent de minimis concentration. Thus,
solutions containing aqueous ammonia at a concentration in excess of one percent of the 10
percent reportable under this listing should be factored into threshold and release
determinations.
D-3
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Section 2. Guidance for Reporting Aqueous Ammonia
Note: for the purposes of reporting under the ammonia listing for aqueous
ammonia, water dissociable ammonium salts means that the ammonium ion dissociates from its
counterion when in solution.
Section 2.1 Determining Threshold and Release Quantities for Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia., the
quantity applied towards threshold determinations for the ammonia listing is the total quantity of
the anhydrous ammonia manufactured, processed, or otherwise used. The quantity reported
when calculating the amount of ammonia that is released, transferred, or otherwise managed is
the total quantity of anhydrous ammonia released or transferred.
If the facility manufactures, processes, or otherwise uses anhydrous ammonia in
quantities that exceed the appropriate threshold and subsequently dissolves some or all of the
anhydrous ammonia in water, then the following applies: 1) threshold determinations are based
on 100 percent of the anhydrous ammonia (simply 10 percent of aqueous ammonia); 2) release,
transfer, and other waste management quantities for the aqueous ammonia are calculated as 10
percent of total ammonia; 3) release, transfer, and other waste management quantities for the
anhydrous ammonia are calculated as 100 percent of the anhydrous ammonia.
If a facility manufactures, processes, or otherwise uses aqueous ammonia, the
quantity applied toward threshold determinations for the ammonia listing is 10 percent of the
total quantity of the aqueous ammonia manufactured, processed, or otherwise used. The quantity
reported when calculating the amount of ammonia that is released, transferred, or otherwise
managed is 10 percent of the total quantity of aqueous ammonia released or transferred.
If a facility dissolves a water dissociable ammonium salt in water that facility has
manufactured aqueous ammonia and 10 percent of the total aqueous ammonia manufactured
from these salts is to be included in manufacturing threshold determinations under the ammonia
listing.
If aqueous ammonia from water dissociable ammonium salts is processed or
otherwise used, then 10 percent of the total aqueous ammonia is to be included in all processing
and otherwise use threshold determinations under the ammonia listing.
Example 1: In a calendar year, a facility places 25,000 Ibs of anhydrous ammonia in water for
processing and processes 25,000 Ibs of aqueous ammonia from an ammonium salt. The
facility must include all of the 25,000 Ibs of anhydrous ammonia in the determination of the
processing threshold, but only 10 percent (or 2,500 Ibs) of the aqueous ammonia from the
ammonium salt in the processing threshold determination.
Total aqueous ammonia is the sum of the two forms of ammonia (un-ionized,
NH3, and ionized, NH4+) present in aqueous solutions. A precise calculation of the weight of
total aqueous ammonia would require determining the ratio of the two forms of ammonia present
using the pH and temperature of the solution. The weight of total aqueous ammonia can be more
D-4
-------
easily calculated by assuming that aqueous ammonia is comprised entirely of the NH4+ form or
the NH3 form. For the purpose of determining threshold and release quantities under EPCRA
Section 313, EPA recommends that total aqueous ammonia be calculated in terms of NH3
equivalents (i.e., for determining weights, assume total ammonia is comprised entirely of the
NH3 form). This method is simpler than using pH and temperature data to determine the ratio of
the two forms present and is consistent with the presentation of total ammonia toxicity in a
separate EPA document, Ambient Water Quality Criteria for Ammonia (EPA document #440/5-
85-001, January 1985).
Section 2.2 Chemical Sources of Aqueous Ammonia
Aqueous ammonia may be generated in solution from a variety of sources that
include the release of anhydrous ammonia to water and the dissociation of ammonium salts in
water. Water dissociable ammonium salts are not reportable in their entirety under the ammonia
listing; these salts are reportable to the extent that they dissociate in water, and only 10 percent of
the total aqueous ammonia that results when these salts dissociate is reportable. If these salts are
not placed in water, they are not reportable.
If these salts are purchased neat or as solids by a facility, then placed in water by
that facility, the facility is manufacturing aqueous ammonia.
Section 2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous Ammonia in
Water
If the source of aqueous ammonia is anhydrous ammonia in water, total aqueous
ammonia (calculated in terms of NH3 equivalents) is equal to the quantity of anhydrous ammonia
manufactured, processed, or otherwise used. A hypothetical scenario demonstrating the
calculations involved in reporting aqueous ammonia generated from anhydrous ammonia in
water is given in Example 2.
Example 2: In a calendar year, a facility uses 30,000 pounds of anhydrous ammonia to
neutralize acids in a wastewater stream. The neutralized waste stream (containing aqueous
ammonia from dissociated ammonium salts) is then transferred to a POTW. The quantity to
be applied toward threshold determinations is the total quantity of anhydrous ammonia used in
the waste stream neutralization, or 30,000 pounds. The quantity of ammonia reported as
transferred is 10 percent of the total quantity of aqueous ammonia transferred, or 3,000
pounds.
Section 2.2.2 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate)
If the source of aqueous ammonia is the dissociation of ammonium salts in water,
total aqueous ammonia (calculated in terms of NH3 equivalents) is calculated from the weight
percent (wt%) of the NH3 equivalents of the ammonium salt. The NH3 equivalent wt% of an
ammonium salt is calculated using the following equation:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium salt) x 100
D-5
-------
If the source of aqueous ammonia is a monovalent compound (such as ammonium chloride,
NH4C1, ammonium nitrate, NH4NO3, or ammonium bicarbonate (NH4HCO3), the NH3 equivalent
weight is equal to the MW of NH3 (17.03 kg/kmol). If divalent compounds are involved (such as
ammonium carbonate, (NH4)2CO3), then the NH3 equivalent weight is equal to the MW of NH3
multiplied by two. Similarly, if trivalent compound are involved, then the NH3 equivalent weight
is equal to the MW of NH3 multiplied by three.
Example 3:
The NH3 equivalent wt% of ammonium chloride is calculated as follows:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = (17.03)7(53.49) x 100
NH3 equivalent wt% = 31.84%
The NH3 equivalent wt% of ammonium carbonate is calculated as follows:
NH3 equivalent wt% = 2 x (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = 2 x (17.03)7(96.09) x 100
NH3 equivalent wt% = 35.45%
To aid the regulated community in reporting under the ammonia listing for
aqueous ammonia, the table of chemical sources of aqueous ammonium provided in Section 3 of
this document includes, in addition to CAS number, chemical name, and molecular weight, the
NH3 equivalent wt% of the commonly used, water dissociable ammonium salts listed in this
table.
Example 4: In a calendar year, a facility uses 100,000 pounds of ammonium chloride, NH4C1,
in aqueous solution which is released to wastewater streams, then transferred to a POTW. The
NH3 equivalent wt% of ammonium chloride is 31.84% (taken from Table 1 in Section 3 below
or calculated as in Example 3 above). The total quantity of aqueous ammonia present in
solution is 31.84% of the 100,000 pounds of ammonia chloride used, or 31,840 pounds. The
quantity applied towards threshold determinations for the ammonia listing is 10 percent of the
total quantity of aqueous ammonia present in solution, or 3,184 pounds. The quantity of
ammonia reported as released or transferred is 10 percent of the total quantity of aqueous
ammonia released or transferred, or 3,184 pounds.
D-6
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Example 5: In a calendar year, a facility uses 500,000 pounds of ammonium carbonate,
(NH4)2CO3, and 400,000 pounds of ammonium bicarbonate, NH4HCO3, in aqueous solution
which is released to wastewater streams, then transferred to a POTW. The NH3 equivalent
wt% of ammonium carbonate is 35.45%, and the NH3 equivalent wt% of ammonium
bicarbonate is 21.54% (taken from Table 1 in Section 3 below or calculated as in Example 3
above). The quantity of aqueous ammonia present in solution from ammonium carbonate is
35.45% of the 500,000 pounds of ammonia carbonate used, or 177,250 pounds. The quantity
of aqueous ammonia present in solution from ammonium bicarbonate is 21.54% of the
400,000 pounds of ammonia bicarbonate used or 86,160 pounds. The total quantity of
aqueous ammonia present in solution is 263,410 pounds. The quantity applied towards
threshold determinations for the ammonia listing is 10 percent of the total quantity of aqueous
ammonia present in solution, or 26,341 pounds. The quantity of ammonia reported as released
or transferred is 10 percent of the total quantity of aqueous ammonia released or transferred, or
26,341 pounds.
Section 2.2.3 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Nitrate
Some sources of aqueous ammonia may be reportable under other EPCRA
Section 313 category listings. Ammonium nitrate (solution) is relevant to reporting under the
ammonia listing to the extent that 10 percent of the total aqueous ammonia that results when
ammonium nitrate dissociates is reported when determining thresholds and calculating releases.
However, under the nitrate compound category listing, ammonium nitrate (and other mixed salts
containing ammonium and nitrate) must be reported in its entirety. When reporting ammonium
nitrate under this category listing, the total nitrate compound, including both the nitrate ion
portion and the ammonium counterion, is included when determining threshold quantities.
However, only the nitrate ion portion is included when determining the amount of ammonium
nitrate that is released, transferred, or otherwise managed in wastes. The calculations involved in
determining threshold and release quantities for reporting under the nitrate compound category
listing are described in a separate directive, List of Toxic Chemicals within the Water Dissociable
Nitrate Compounds Category and Guidance for Reporting (EPA document #745-R-95-002,
February 1995). Note: reporting ammonium nitrate under the ammonia listing and nitrate
compounds category listing is effective for the 1995 reporting year for reports due July 1, 1996.
D-7
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Example 6: In a calendar year, a facility uses 1,250,000 pounds of ammonium nitrate,
NH4NO3, in aqueous solution which is released to wastewater streams, then transferred to a
POTW. The NH3 equivalent wt% of ammonium nitrate is 21.28% (taken from Table 1 in
Section 3 below or calculated as in Example 3 above). The total quantity of aqueous ammonia
present in solution is 21.28% of the 1,250,000 pounds of ammonia chloride used, or 266,000
pounds. The quantity applied towards threshold determinations for the ammonia listing is 10
percent of the total quantity of aqueous ammonia present in solution, or 26,600 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 26,600 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February, 1995).
D-8
-------
Example 7: In a calendar year, a facility transfers 100,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid is neutralized with anhydrous ammonia, and
treatment efficiency is 95 percent (the nitrate compound formed as a result of the treatment is
ammonium nitrate, NH4NO3). The neutralized waste stream (containing aqueous ammonia
from dissociated ammonium nitrate) is then transferred to a POTW. The quantity of nitric acid
neutralized is 95 percent of 100,000 pounds or 95,000 pounds. The quantity of nitric acid
neutralized is converted first to kilograms then to kilomoles using the following equations:
Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)
Substituting the appropriate values into the above equations yields:
Kilograms HNO3 neutralized = 95,000 Ibs x 0.4536 kg/lb = 43,092 kg
Kilomoles HNO3 neutralized = 43,092 kg + 63.01 kg/kmol = 683.9 kmol
The quantity of anhydrous ammonia used in kilomoles in the acid neutralization and the
quantity of ammonium nitrate generated in kilomoles from the neutralization are equal to the
quantity of nitric acid neutralized (683.9 kmol). The quantity of anhydrous ammonia used in
kilograms and pounds in the acid neutralization is calculated as follows:
Kilograms NH3 used = (kmol NH3) x (MW of NH3 in kg/kmol)
Pounds NH3 used = (kg NH3) x (2.205 Ibs/kg)
Substituting the appropriate values into the above equation yields:
Kilograms NH3 used = (683.9 kmol) x (17.03 kg/kmol) = 11,647 kmol
Pounds NH3 used = (11,647 NH3) x (2,205 Ibs/kg) = 25,682 pounds
The quantity reported applied towards threshold determinations for the ammonia listing is the
total quantity of anhydrous ammonia used in the acid neutralization, or 25,682 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 2,568 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February 1995).
D-9
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Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report under the ammonia listing
for aqueous ammonia. If a facility manufactures, processes, or otherwise uses, in aqueous
solution, a chemical which is listed below, they must report 10 percent of the total aqueous
ammonia that is the result of the dissociation of this chemical. However, this list is not
exhaustive. If a facility manufactures, processes, or otherwise uses, in aqueous solution, a water
dissociable ammonium compound, they must report 10 percent of the total aqueous ammonia that
is the result of the dissociation of the compound, even if the compound does not appear in the
following table.
Table D-l
Listing by CAS Number and Molecular Weight of
Some Chemical Sources of Aqueous Ammonia
Chemical Name
Ammonium acetate
Ammonium aluminum sulfate
(Ammonium aluminum disulfate)
Ammonium antimony fluoride
(Diammonium pentafluoroantimonate)
Ammonium arsenate
(Ammonium arsenate, hydrogen)
(Ammonium arsenate, dihydrogen)
Ammonium arsenate
(Diammonium arsenate)
(Diammonium arsenate, hydrogen)
(Diammonium arsenate, monohydrogen)
Ammonium arsenite
Ammonium azide
Ammonium benzenesulfonate
Ammonium benzoate
Ammonium bromate
Ammonium bromide
Ammonium cadmium chloride
(Ammonium cadmium trichloride)
Ammonium carbamate
Ammonium carbonate carbamate
Ammonium carbonate
(Diammonium carbonate)
Molecular
Weight*
77.08
237.14
252.82
158.97
176.00
124.96
60.06
175.20
139.15
145.94
97.94
236.81
78.07
157.13
96.09
NH3
Equivalent
Wt%
22.09
7.181
13.47
10.71
19.35
13.63
28.35
9.720
12.24
11.67
17.39
7.191
21.81
21.68
35.45
CAS Number
631-61-8
7784-25-0
32516-50-0
13462-93-6
7784-44-3
13462-94-7
12164-94-2
19402-64-3
1863-63-4
13843-59-9
12124-97-9
18532-52-0
1111-78-0
8000-73-5
506-87-3
D-10
-------
Table D-l (Continued)
Chemical Name
Ammonium carbonate, hydrogen
(Ammonium bicarbonate)
Ammonium cerium nitrate
(Ammonium hexanitratocerate)
(Ammonium hexanitratocerate (IV))
(Diammonium cerium hexanitrate)
Ammonium cerous nitrate
(Ammonium cerous nitrate, tetrahydrate)
Ammonium chlorate
Ammonium perchlorate
Ammonium chloride
Ammonium chromate
(Ammonium chromate (VI))
(Diammonium chromate)
Ammonium chromate
(Ammonium dichromate)
(Ammonium dichromate (VI))
(Ammonium bichromate)
(Diammonium dichromate)
Ammonium chromium sulfate
(Ammonium chromic sulfate)
Ammonium citrate
(Ammonium citrate, monohydrogen)
(Ammonium citrate, dibasic)
(Diammonium citrate)
(Diammonium citrate, hydrogen)
Ammonium citrate
(Ammonium citrate, tribasic)
(Triammonium citrate)
Ammonium cobalt sulfate
(Ammonium cobaltous sulfate)
Ammonium cupric chloride
(Ammonium chlorocuprate (II))
(Diammonium copper tetrachloride)
(Diammonium tetrachlorocuprate)
Ammonium cyanate
(Ammonium isocyanate)
Ammonium cyanide
Ammonium cyanoaurate, monohydrate
(Ammonium tetracyanoaurate, monohydrate)
Molecular
Weight*
79.06
548.23
486.22
101.49
117.49
53.49
152.07
252.06
265.17
226.19
243.22
289.14
241.43
60.06
44.06
319.07
NH3
Equivalent
Wt%
21.54
6.213
7.005
16.78
14.49
31.84
22.40
13.51
6.422
15.06
21.01
11.78
14.11
28.35
38.65
5.337
CAS Number
1066-33-7
16774-21-3
13083-04-0
10192-29-7
7790-98-9
12125-02-9
7788-98-9
7789-09-5
13548-43-1
3012-65-5
3458-72-8
13596-46-8
15610-76-1
22981-32-4
12211-52-8
14323-26-3
D-ll
-------
Table D-l (Continued)
Chemical Name
Ammonium cyanoaurate
(Ammonium dicyanoaurate)
Ammonium ferricyanide
(Ammonium hexacyanoferrate (III))
(Triammonium hexacyanoferrate)
Ammonium ferrocyanide
(Ammonium hexacyanoferrate (II))
(Tetraammonium ferrocyanide)
(Tetraammonium hexacyanoferrate)
Ammonium fluoride
Ammonium fluoride
(Ammonium difluoride)
(Ammonium bifluoride)
(Ammonium fluoride, hydrogen)
(Ammonium difluoride, hydrogen)
(Ammonium bifluoride, hydrogen)
Ammonium fluoroborate
(Ammonium tetrafluoroborate)
Ammonium fluorogermanate (IV)
(Ammonium hexafluorogermanate (IV))
(Diammonium hexafluorogermanate)
Ammonium fluorophosphate
(Ammonium hexafluorophosphate)
Ammonium fluorosulfate
(Ammonium fluorosulfonate)
Ammonium formate
Ammonium gallium sulfate
Ammonium hydroxide
Ammonium iodide
Ammonium iridium chloride
(Ammonium chloroiridate (III))
(Ammonium hexachloroiridate)
(Triammonium hexachloroiridate)
Ammonium iron sulfate
(Ammonium ferric sulfate)
(Ammonium iron disulfate)
Ammonium iron sulfate
(Ammonium ferrous sulfate)
(Diammonium iron disulfate)
(Diammonium ferrous disulfate)
Molecular
Weight*
267.04
266.07
284.11
37.04
57.04
104.84
222.66
163.00
117.10
63.06
282.90
35.05
144.94
459.05
269.02
286.05
NH3
Equivalent
Wt%
6.377
19.20
23.98
45.98
29.86
16.24
15.30
10.45
14.54
27.01
6.020
48.59
11.75
11.13
6.330
11.91
CAS Number
31096-40-9
14221-48-8
14481-29-9
12125-01-8
1341-49-7
13826-83-0
16962-47-3
16941-11-0
13446-08-7
540-69-2
15335-98-5
1336-21-6
12027-06-4
15752-05-3
10138-04-2
10045-89-3
D-12
-------
Table D-l (Continued)
Chemical Name
Ammonium lactate
(Ammonium 2-hydroxypropionate)
Ammonium laurate
(Ammonium dodecanoate)
Ammonium magnesium sulfate
Ammonium malate
Ammonium malate, hydrogen
(Ammonium bimalate)
Ammonium molybdate
(Diammonium molybdate)
Ammonium molybdate
(Ammonium heptamolybdate)
(Ammonium molybdate, hydrate)
(Ammonium molybdate, tetrahydrate)
(Ammonium />aramolybdate, tetrahydrate)
Ammonium nickel chloride, hexahydrate
Ammonium nickel sulfate
(Ammonium nickel sulfate, hexahydrate)
(Ammonium nickel disulfate, hexahydrate)
(Diammonium nickel disulfate, hexahydrate)
Ammonium nitrate
Ammonium nitrate sulfate
Ammonium nitrite
Ammonium oleate
Ammonium oxalate
Ammonium palladium chloride
(Ammonium chloropalladate (II))
(Ammonium tetrachloropalladte (II))
(Diammonium tetrachloropalladate)
Ammonium phosphate
(Ammonium orthophosphate)
Ammonium phosphate
(Ammonium biphosphate)
(Ammonium phosphate, hydrogen)
(Ammonium phosphate, dihydrogen)
(Ammonium orthophosphate, dihydrogen)
(Ammonium phosphate, monobasic)
Molecular
Weight*
107.11
217.35
252.50
168.15
151.12
196.01
1,163.8
183.09
286.88
80.04
212.18
64.04
299.50
124.10
284.31
149.09
115.03
NH3
Equivalent
Wt%
15.90
7.835
13.49
20.26
11.27
17.38
8.780
9.301
11.87
21.28
24.08
26.59
5.686
27.45
11.98
34.27
14.80
CAS Number
515-98-0
2437-23-2
14727-95-8
6283-27-8
5972-71-4
13106-76-8
12054-85-2
16122-03-5
7785-20-8
6484-52-2
12436-94-1
13446-48-5
544-60-5
1113-38-8
13820-40-1
10124-31-9
7722-76-1
D-13
-------
Table D-l (Continued)
Chemical Name
Ammonium phosphate
(Ammonium phosphate, hydrogen)
(Ammonium orthophosphate, monohydrogen)
(Ammonium phosphate, dibasic)
(Ammonium orthophosphate, dibasic)
(Diammonium phosphate)
(Diammonium orthophosphate)
(Diammonium phosphate, hydrogen)
(Diammonium phosphate, monohydrogen)
(Diammonium orthophosphate, hydrogen)
Ammonium phosphinate
(Ammonium hypophosphite)
Ammonium phosphite
(Ammonium biphosphite)
(Ammonium phosphite, dihydrogen)
Ammonium picramate
Ammonium propionate
Ammonium rhodium chloride
(Ammonium chlororhodate (III))
(Ammonium hexachlororhodate (III))
(Triammonium rhodium hexachloride)
(Triammonium hexachlororhodate)
Ammonium salicylate
(Ammonium 2-hydroxybenzoate)
Ammonium selenide
Ammonium silicon fluoride
(Ammonium fluorosilicate)
(Ammonium hexafluorosilicate)
(Diammonium silicon hexafluoride)
(Diammonium fluorosilicate)
(Diammonium hexafluorosilicate)
Ammonium stearate
(Ammonium octadecanoate)
Ammonium succinate
(Diammonium succinate)
Ammonium sulfamate
(Ammonium amidosulfate)
(Ammonium amidosulfonate)
Ammonium sulfate
(Diammonium sulfate)
Molecular
Weight*
132.06
83.03
99.03
216.15
91.11
369.74
155.15
115.04
178.15
301.51
152.15
114.12
132.13
NH3
Equivalent
Wt%
25.79
20.51
17.20
7.879
18.69
13.82
10.98
29.61
19.12
5.648
22.39
14.92
25.78
CAS Number
7783-28-0
7803-65-8
13446-12-3
1134-85-6
17496-08-1
15336-18-2
528-94-9
66455-76-3
16919-19-0
1002-89-7
2226-88-2
7773-06-0
7783-20-2
D-14
-------
Table D-l (Continued)
Chemical Name
Ammonium sulfate
(Ammonium bisulfate)
(Ammonium sulfate, hydrogen)
(Ammonium sulfate, monohydrogen)
Ammonium />ersulfate
(Ammonium peroxysulfate)
(Ammonium peroxydisulfate)
(Diammonium persulfate)
(Diammonium peroxydifulsite)
Ammonium sulfide
(Ammonium bisulfide)
(Ammonium sulfide, hydrogen)
Ammonium sulfide
(Ammonium monosulfide)
(Diammonium sulfide)
Ammonium sulfide
(Diammonium pentasulfide)
Ammonium sulfite, monohydrate
(Diammonium sulfite, monohydrate)
Ammonium sulfite
(Ammonium bisulfite)
(Ammonium sulfite, hydrogen)
Ammonium tetrachloroaurate (III), hydrate
Ammonium thiocarbamate
Ammonium thiocarbonate
(Diammonium trithiocarbonate)
Ammonium thiocyanate
(Ammonium isothiocyanate)
(Ammonium sulfocyanate)
(Ammonium rhodanate)
(Rhodanid)
Ammonium dithionate
Ammonium thiosulfate
(Ammonium hyposulfite)
(Diammonium thiosulfate)
Ammonium tin bromide
(Ammonium bromostannate (IV))
(Ammonium hexabromostannate (IV))
(Diammonium hexabromostannate)
Molecular
Weight*
115.10
228.19
51.11
68.14
196.39
116.13
99.10
356.82
94.13
144.27
76.12
196.19
148.20
634.19
NH3
Equivalent
Wt%
14.80
14.93
33.32
49.99
17.34
29.33
17.18
4.772
18.09
23.61
22.37
17.36
22.98
5.371
CAS Number
7803-63-6
7727-54-0
12124-99-1
12135-76-1
12135-77-2
7783-11-1
10192-30-0
13874-04-9
16687-42-6
13453-08-2
1762-95-4
60816-52-6
7783-18-8
16925-34-1
D-15
-------
Table D-l (Continued)
Chemical Name
Ammonium tin chloride
(Ammonium chlorostannate (IV))
(Ammonium hexachlorostannate (IV))
(Diammonium tin hexachloride)
(Diammonium hexachlorostannate)
Ammonium titanium fluoride
(Ammonium fluorotitanate (IV))
(Ammonium hexafluorotitanate (IV))
(Diammonium titanium hexafluoride)
(Diammonium hexafluorotitanate)
Ammonium titanium oxalate, monohydrate
(Diammonium dioxalatooxotitanate, monohydrate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Hexaammonium tungstate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />oratungstate)
(Decaammonium tungstate)
Ammonium valerate
(Ammonium pentoate)
Ammonium zinc chloride
(Ammonium chlorozincate)
(Ammonium tetrachlorozincate)
(Diammonium tetrachlorozincate)
Molecular
Weight*
367.48
197.95
276.00
1,779.2
3,058.6
119.16
243.27
NH3
Equivalent
Wt%
9.269
17.21
12.34
5.743
5.568
14.29
14.00
CAS Number
16960-53-5
16962-40-6
10580-03-7
12028-06-7
11120-25-5
42739-38-8
14639-97-5
*For hydrated compounds, e.g., ammonium sulfite, monohydrate, the molecular weight excludes the weight of the
hydrate portion.
D-16
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Appendix E
LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE NITRATE
COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING
-------
United States
Environmental Protection
Agency
Office of Pollution Prevention and
Toxics
Washington, DC 20460
Revised May 1996
EPA 745-R-96-004
TOXICS RELEASE INVENTORY
List of Toxic Chemicals Within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using
listed toxic chemicals to report their environmental releases of such chemicals annually.
Beginning with the 1991 reporting year, such facilities also must report pollution prevention and
recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42
U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals
that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section
313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth
criteria for these actions.
CONTENTS
Section 1. Introduction E-2
1.1 Who Must Report E-2
1.2 Thresholds E-2
1.3 Chemicals within the Water Dissociable Nitrate Compounds Category E-3
1.4 De Minimis Concentrations E-3
Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category E-4
2.1 Chemicals within the Water Dissociable Nitrate Compounds Category E-4
2.2 Determining Threshold and Release Quantities for Nitrate Compounds E-4
2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid E-5
2.3.1 Estimating Nitric Acid Releases E-6
2.3.2 Estimating Treatment Efficiencies for Nitric Acid
Neutralization E-8
2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid E-9
2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment . . E-10
Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category E-l 1
E-l
-------
Section 1. Introduction
On November 30, 1994 EPA added 286 chemicals and chemical categories, which
include 39 chemicals as part of two delineated categories, to the list of toxic chemicals subject to
reporting under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA), 42 U.S.C. 11001. These additions are described at 59 FR 61432, and are
effective January 1, 1995 for reports due July 1, 1996. Six chemical categories (nicotine and
salts, strychnine and salts, polycyclic aromatic compounds, water dissociable nitrate compounds,
diisocyanates, and polychlorinated alkanes) are included in these additions. At the time of the
addition, EPA indicated that the Agency would develop, as appropriate, interpretations and
guidance that the Agency determines are necessary to facilitate accurate reporting for these
categories. This document constitutes such guidance for the water dissociable nitrate compounds
category.
Section 1.1 Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA Section
313, if it meets all three of the following criteria:
• It conducts manufacturing operations (is included in Standard Industrial
Classification (SIC) codes 20 through 39); and
• It has 10 or more full-time employees (or the equivalent 20,000 hours per
year); and
• It manufactures, imports, processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than
the "threshold" quantities specified below.
Section 1.2 Thresholds
Thresholds are specified amounts of toxic chemicals used during the calendar year
that trigger reporting requirements.
If a facility manufactures or imports any of the listed toxic chemicals, the
thresholds quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility processes any of the listed toxic chemicals, the threshold quantity will
be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility otherwise uses any of the listed toxic chemicals (without
incorporating it into any product or producing it at the facility), the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
E-2
-------
EPCRA Section 313 requires threshold determinations for chemical categories to
be based on the total of all chemicals in the category manufactured, processed or otherwise used.
For example, a facility that manufactures three members of a chemical category would count the
total amount of all three chemicals manufactured towards the manufacturing threshold for that
category. When filing reports for chemical categories, the releases are determined in the same
manner as the thresholds. One report is filed for the category and all releases are reported on this
form.
Section 1.3 Chemicals Within the Water Dissociable Nitrate Compounds Category
EPA is providing a list of CAS numbers and chemical names to aid the regulated
community in determining whether they need to report for the water dissociable nitrate
compounds category. The list includes individual chemicals within the water dissociable nitrate
compounds category. If a facility is manufacturing, processing, or otherwise using a chemical
which is on this list, they must report this chemical. However, this list is not exhaustive. If a
facility is manufacturing, processing, or otherwise using a water dissociable nitrate compound,
they must report the chemical, even if it does not appear on the list.
Section 1.4 De Minimis Concentrations
The water dissociable nitrate compounds category is subject to the one percent de
minimis concentration. Thus, mixtures that contain members of this category in excess of the de
minimis should be factored into threshold and release determinations.
E-3
-------
Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category
Note: for the purposes of reporting under the nitrate compounds category, water
dissociable means that the nitrate ion dissociates from its counterion when in solution.
Section 2.1 Chemicals within the Water Dissociable Nitrate Compounds Category
Chemicals within the nitrate compounds category are only reportable when in
aqueous solution. All water dissociable nitrate compounds are included in the nitrate compounds
category, including ammonium nitrate. Specifically listed EPCRA Section 313 chemicals are
not included in threshold determinations for chemical categories such as the water dissociable
nitrate compounds category. Specifically listed toxic chemicals are subject to their own
individual threshold determinations. As of December 1, 1994, ammonium nitrate (solution) is
not an individually listed chemical on the EPCRA Section 313 list. However, ammonium nitrate
is still subject to reporting under the nitrate compounds category. In addition, the aqueous
ammonia from the dissociation of ammonium nitrate when in aqueous solution is subject to
reporting under the ammonia listing.
Section 2.2 Determining Threshold and Release Quantities for Nitrate Compounds
The total nitrate compound, including both the nitrate ion portion and the
counterion, is included in the nitrate compounds category. When determining threshold amounts,
the total weight of the nitrate compound is to be included in all calculations. However, only the
nitrate ion portion is to be included when determining the amount of the chemicals within the
nitrate compounds category that is released, transferred, or otherwise managed in wastes.
Example 1: In a calendar year, a facility processes 100,000 pounds of ammonium nitrate
(NH4NO3), in aqueous solution, which is released to wastewater streams then transferred to a
POTW. The quantity applied towards threshold calculations for the nitrate compounds
category is the total quantity of the nitrate compound or 100,000 pounds. Since this quantity
exceeds the 25,000 pound processing threshold, the facility is required to report for the nitrate
compounds category. Under the nitrate compounds category, only the weight of the nitrate ion
portion of ammonium nitrate is included in release transfer calculations. The molecular
weight of the ammonium nitrate is 80.04 and the weight of the nitrate ion portion is 62.01 or
77.47 percent of the molecular weight of ammonium nitrate. Therefore, the amount of nitrate
ion reported as transferred to the POTW is 77.47 percent of 100,000 pounds or 77,470 pounds
(reported as 77,000 pounds). The aqueous ammonia from ammonium nitrate is reportable
under the EPCRA Section 313 listing for ammonia. For determining thresholds and
calculating releases under the ammonia listing, see the separate directive, Guidance for
Reporting Aqueous Ammonia (EPA document #745-R-95-0003, July 1995).
E-4
-------
Example 2: In a calendar year, a facility manufactures as by-products 20,000 pounds of
sodium nitrate (NaNO3) and 10,000 pounds of calcium nitrate (Ca(NO3)2), both in aqueous
solutions, and releases these solutions to wastewater streams. The total quantity of nitrate
compounds manufactured by the facility is the sum of the two chemicals, or 30,000 pounds,
which exceeds the manufacturing threshold quantity of 25,000 pounds. The facility therefore
is required to report for the nitrate compounds category. By weight, the nitrate ion portion is
72.96 percent of sodium nitrate and is 75.57 percent of calcium nitrate. Of the 20,000 pounds
of the sodium nitrate in solution, 72.96 percent or 14,592 pounds is nitrate ion, and similarly,
of the 10,000 pounds of the calcium nitrate in solution, 75.57 percent or 7,557 pounds is
nitrate ion. The total nitrate ion in aqueous solution released by the facility is the sum of the
nitrate ion in the two solutions or 22,149 pounds (reported as 22,000 pounds).
Section 2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid
Nitric acid is an individually listed chemical on the original EPCRA Section 313
list and is reported as a separate chemical if the manufacture, process, or otherwise use thresholds
are exceeded. The partial or complete neutralization of nitric acid results in the formation of
nitrate compounds which are reported as chemicals within the nitrate compounds category if their
manufacture, process, or otherwise use thresholds are exceeded.
Mineral acids such as nitric acid may be present in aqueous waste streams that are
sent to on-site neutralization or are discharged to a publicly owned treatment works (POTW) or
other off-site treatment facility. As stated in the Toxic Chemical Release Inventory Reporting
Form R and Instructions document (revised 1993 version, EPA 745-K-94-001), on-site acid
neutralization and its efficiency must be reported in Part II, section 7 A of Form R (waste
treatment methods and efficiency section). For purposes of reporting on Form R, EPA considers
a waste mineral acid at a pH 6 or higher to be 100 percent neutralized (water discharges to
receiving streams or POTWs are reported as zero). The nitrate compounds produced from the
complete neutralization (pH 6.0 or above) of nitric acid are reportable under the nitrate
compounds category and should be included in all threshold and release calculations. Two Form
R reports would be required if the manufacture, process or otherwise use thresholds are exceeded
for nitric acid and for the nitrate compounds category.
If the nitric acid treatment efficiency is not equal to 100 percent (pH is less than
6), the amount of the acid remaining in the waste stream which is released to the environment on-
site or off-site must be reported in Part n of Form R. The nitrate compounds produced from the
partial neutralization of nitric acid are reportable under the nitrate compounds category and
should be included in all threshold and release calculations. Two reports would again be
required if the manufacture, process or otherwise use thresholds are exceeded for nitric acid and
for the nitrate compounds category.
E-5
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Section 2.3.1 Estimating Nitric Acid Releases
The pH of the waste stream can be used to calculate the amount of nitric acid in
the stream and the efficiency of neutralization. The pH is a measure of the acidity or alkalinity of
a waste stream and can be obtained readily using a pH meter or pH sensitive paper. The pH scale
itself varies from 0 to 14.
The total nitric acid concentration (ionized and un-ionized) in pounds per gallon
can be calculated by using the pH value of the solution, the molecular weight and ionization
constant of the acid, and appropriate conversion factors. The total acid concentration for nitric
acid for different pH values is listed in Table 1. The calculation of mineral acid concentrations
and the derivation of Table 1 are discussed in a separate directive, Estimating Releases for
Mineral Acid Discharges Using pH Measurements., and an addendum to this directive.
The procedure outlined in this guidance document for calculating the quantity of
nitrate compounds formed from the complete or partial neutralization of nitric acid can be used if
nitric acid is the only mineral acid in a solution. In addition, the calculation of nitric acid
releases using only pH measurements is a rough estimate. The subsequent calculation of nitrate
compound releases is therefore also only a rough estimate. The estimates can be made for a
waste stream with a steady pH below 6 or for one whose pH temporarily drops to below pH 6.
Facilities should use their best engineering judgement and knowledge of the solution to evaluate
how reasonable the estimates are.
Example 3: In a calendar year, a facility transfers 1.0 million gallons of a solution containing
nitric acid (HNO3), at pH 4, to a POTW. Using Table 1 (next page), a pH of 4 corresponds to
a concentration of 0.0000520 Ibs HNO3/gallon of solution. The weight of HNO3 transferred
can be estimated using the equation:
Transfer of HNO3 = (Concentration of HNO3) x (effluent flow rate)
Substituting the example values into the above equation yields:
Transfer of HNO3 = 0.0000520 Ibs/gal HNO3 x 1,000,000 gal solution/year = 52 Ibs/year
Example 4: A facility had an episodic release of nitric acid (HNO3) in which the waste stream
was temporarily below pH 6. During the episode, the wastewater (pH 2.0) was discharged to a
river for 20 minutes at a rate of 100 gallons per minute. Using Table 1, a pH of 2.0 for HNO3
represents a concentration of 0.0052000 Ibs HNO3/gallon of solution. The amount of the
HNO3 released can be estimated using the following equation:
Release of HNO3 = (concentration of HNO3) x (effluent flow rate)
Substituting the example values in the above equation:
Release of HNO3 = 0.0052000 Ibs/gal x 100 gal/min x 20 min
= 10 Ibs
E-6
-------
Table E-l
Nitric Acid Concentration Versus pH
pH
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
Nitric Acid Concentration
(Ibs/gallon)
0.5200000
0.3300000
0.2100000
0.1300000
0.0830000
0.0520000
0.0330000
0.0210000
0.0130000
0.0083000
0.0052000
0.0033000
0.0021000
0.0013000
0.0008300
pH
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
4.8
5.0
5.2
5.4
5.6
5.8
6.0
Nitric Acid Concentration
(Ibs/gallon)
0.0005200
0.0003300
0.0002100
0.0001300
0.0000830
0.0000520
0.0000330
0.0000210
0.0000130
0.0000083
0.0000052
0.0000033
0.0000021
0.0000013
0.0000008
0.0000005
Section 2.3.2 Estimating Treatment Efficiencies for Nitric Acid Neutralization
Nitric acid solutions that are neutralized to a pH of 6 or above have a treatment
efficiency of 100 percent. If nitric acid is neutralized to a pH less than 6, then the reportable
treatment efficiency is somewhere between 0 and 100 percent. It is possible to estimate the
neutralization treatment efficiency using nitric acid concentration values directly from Table 1 in
the equation given below. The concentrations correspond to the pH values before and after
treatment.
(I-E)
Treatment efficiency = —;—X 100
where:
I
E
Acid concentration before treatment; and
Acid concentration after treatment.
E-7
-------
Example 5: A nitric acid (HNO3) waste stream of pH 2.4 is neutralized to pH 4.6. Using
Table 1, the initial nitric acid concentration is 0.0021000 mol/liter and the final concentration
is 0.0000130 mol/liter. Substituting these values into the equation for treatment efficiency:
(0.0021000-0.0000130)
Treatment Effunency = - - x 100
= 99.4 percent
For strong acids only (including nitric acid), the net difference in pH before and
after treatment can be used to estimate the treatment efficiency since pH is directly proportional
to the acid concentration. For example, a pH change of one unit results in a treatment efficiency
of 90 percent, whether the pH change is from pH 1 to pH 2 or from pH 4 to pH 5. Table 2
summarizes treatment efficiencies for various pH changes (the pH change is the difference
between the initial pH and the pH after neutralization). In the table, some pH changes result in
the same treatment efficiency values due to rounding to one decimal place.
E-S
-------
Table E-2
Nitric Acid Treatment Efficiencies for Various pH Changes
pH Unit Change
1.0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
Treatment Efficiency
(%)
90.0
92.1
93.7
95.0
96.0
96.8
97.5
98.0
98.4
98.7
pH Unit Change
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
3.0
Treatment Efficiency
(%)
99.0
99.2
99.4
99.5
99.6
99.7
99.8
99.8
99.8
99.9
99.9
Example 6: If a nitric acid (HNO3) waste stream of pH 2 is treated to pH 4, the pH change is 2
units. Using Table 2 above, the treatment efficiency is given as 99.0 percent.
Section 2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid
The nitrate compounds produced from the complete neutralization (pH 6.0 or
above) or partial neutralization (pH less than 6) or nitric acid are reportable under the nitrate
compounds category if the appropriate threshold is met and should be included in all threshold
and release calculations. In order to determine the quantity of a nitrate compound generated and
released, the quantity of nitric acid released must be known (or calculated from the equations
used in Examples 3 and 4 above) as well as the nitric acid treatment efficiency (calculated from
the equations used in Examples 5 and 6 above).
The neutralization of nitric acid will most likely result in the generation of
monovalent nitrate compounds (such as sodium nitrate and potassium nitrate). The quantity of
these compounds formed in kilomoles will be equal to the quantity of the nitric acid neutralized
in kilomoles. If divalent nitrate compounds are formed (such as calcium nitrate), the quantity of
these compounds formed in kilomoles will be equal to one-half the quantity of the nitric acid
neutralized in kilomoles. Similarly, if trivalent nitrate compounds are formed (such as iron (HI)
nitrate), the quantity formed of these compounds in kilomoles will be equal to one-third the
quantity of the nitric acid neutralized in kilomoles. Note: to calculate the releases of nitrate
compounds generated from the neutralization of nitric acid, the molecular weight of the nitrate
compound formed must be used. Molecular weights of some of the individual chemicals within
the water dissociable nitrate compounds category are given in Table 3.
E-9
-------
Example 7: In a calendar year, a facility transfers 50,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid treatment efficiency is 95 percent, and the nitrate
compound formed as a result of the treatment is sodium nitrate (NaNO3). The quantity of
nitric acid transferred that is neutralized (generating sodium nitrate) is 95 percent of 50,000
pounds or 47,500 pounds. The molecular weight of nitric acid is 63.01 kg/kmol, and the
molecular weight of sodium nitrate is 84.99 kg/kmol. The quantity of nitric acid neutralized is
converted first to kilograms then to kilomoles using the following equations:
Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)
Substituting the example values into the above equation yields:
Kilograms HNO3 neutralized = 47,500 Ibs x 0.4536 kg/lb = 21.546 kg
Kilomoles HNO3 neutralized = 21,546 kg H- 63.01 kg/kmol = 341.9 kmol
The quantity of sodium nitrate generated in kilomoles is equal to the quantity of nitric acid
neutralized (341.9 kmol). The quantity of sodium nitrate generated in kilomoles is converted
first to kilograms then to pounds using the following equations:
Kilograms NaNO3 generated = (kmol NaNO3) x (MW of NaNO3 in kg/kmol)
Pounds NaNO3 generated = (kg NaNO3) x (2.205 Ibs/kg)
Substituting the values into the above equation yields:
Kilograms NaNO3 generated = 341.9 kmol x 84.99 kg/kmol = 29,058 kg
Pounds NaNO3 generated = 29,058 kg x 2.205 Ibs/kg = 64,073 pounds
(reported as 64,000 pounds)
The 64,000 pounds of sodium nitrate generated is the quantity used to determine whether
thresholds have been met or exceeded. The quantity of nitrate ion released is calculated as in
Example 1 above.
Section 2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment
If a facility treats wastewater on-site biologically, using the activated sludge
process, for example, the facility may be generating nitrate compounds as by-products of this
biological process. The nitrate ion generated from this process will be associated with various
countedons (e.g., sodium ion, potassium ion). In the absence of information on the identity of
the counted on, a facility should assume for the purposes of EPCRA Section 313 threshold
determinations that the counterion is sodium ion.
E-10
-------
Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report for the water dissociable
nitrate compounds category. If a facility is manufacturing, processing, or otherwise using a
chemical which is listed below, they must report this chemical. However, this list is not
exhaustive. If a facility is manufacturing, processing, or otherwise using a water dissociable
nitrate compound, they must report this chemical, even if it does not appear on the following list.
Table E-3
Listing by CAS Number and Molecular Weight of Some of the Individual
Chemicals within the Water Dissociable Nitrate Compounds Category
Chemical Name
Aluminum nitrate, nonahydrate
Ammonium nitrate
Cerium (III) ammonium nitrate, tetrahydrate
Cerium (IV) ammonium nitrate
Barium nitrate
Beryllium nitrate, trihydrate
Cadmium nitrate
Cadmium nitrate, tetrahydrate
Calcium nitrate
Calcium nitrate, tetrahydrate
Cerium (III) nitrate, hexahydrate
Cesium nitrate
Chromium (III) nitrate, nonahydrate
Cobalt (II) nitrate, hexahydrate
Copper (II) nitrate, trihydrate
Copper (II) nitrate, hexahydrate
Dysprosium (III) nitrate, pentahydrate
Erbium (III) nitrate, pentahydrate
Gadolinium (III) nitrate, hexahydrate
Gallium nitrate, hydrate
Iron (III) nitrate, hexahydrate
Iron (III) nitrate, nonahydrate
Lanthanum (III) nitrate, hexahydrate
Lead (II) nitrate
Molecular Weight*
213.00
80.04
486.22
548.23
261.34
133.02
236.42
236.42
164.09
164.09
326.13
194.91
238.01
182.94
187.56
187.56
348.51
353.27
343.26
255.73
241.86
241.86
324.92
331.21
CAS Number
7784-27-2
6484-52-2
13083-04-0
10139-51-2
10022-31-8
7787-55-5
10325-94-7
10022-68-1
10124-37-5
13477-34-4
10294-41-4
7789-18-6
7789-02-8
10026-22-9
10031-43-3
13478-38-1
10031-49-9
10031-51-3
19598-90-4
69365-72-6
13476-08-9
7782-61-8
10277-43-7
10099-74-8
E-ll
-------
Table E-3 (Continued)
Chemical Name
Lithium nitrate
Lithium nitrate, trihydrate
Magnesium nitrate, dihydrate
Magnesium nitrate, hexahydrate
Manganese (II) nitrate, tetrahydrate
Neodymium (III) nitrate, hexahydrate
Nickel (II) nitrate, hexahydrate
Potassium nitrate
Rhodium (III) nitrate, dihydrate
Rubidium nitrate
Samarium (III) nitrate, hexahydrate
Scandium (III) nitrate
Scandium (III) nitrate, tetrahydrate
Silver nitrate
Sodium nitrate
Strontium nitrate
Strontium nitrate, tetrahydrate
Terbium (III) nitrate, hexahydrate
Thorium (IV) nitrate
Thorium (IV) nitrate, tetrahydrate
Yttrium (III) nitrate, hexahydrate
Yttrium (III) nitrate, tetrahydrate
Zinc nitrate, trihydrate
Zinc nitrate, hexahydrate
Zirconium (IV) nitrate, pentahydrate
Molecular Weight*
68.95
68.95
148.31
148.31
178.95
330.25
182.70
101.10
288.92
147.47
336.37
230.97
230.97
169.87
84.99
211.63
211.63
344.94
480.06
480.06
274.92
274.92
189.39
189.39
339.24
CAS Number
7790-69-4
13453-76-4
15750-45-5
13446-18-9
20694-39-7
16454-60-7
13478-00-7
7757-79-1
13465-43-5
13126-12-0
13759-83-6
13465-60-6
16999-44-3
7761-88-8
7631-99-4
10042-76-9
13470-05-8
13451-19-9
13823-29-5
13470-07-0
13494-98-9
13773-69-8
131446-84-9
10196-18-6
13986-27-1
*For hydrated compounds, e.g., aluminum nitrate, nonahydrate, the molecular weight excludes the weight of the
hydrate portion. For example, the same molecular weight is provided for aluminum nitrate, nonahydrate and
aluminum nitrate.
E-12
-------
Appendix F
UNIT CONVERSION FACTORS
(From U.S. Coast Guard Commandant Instruction M.16465.12A)
-------
CONVERSION FACTORS
To Convert
To
Multiply By
Length
inches
inches
feet
feet
feet
feet
yards
yards
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
miles (U.S. statute)
meters
meters
meters
nautical miles
millimeters
feet
inches
meters
yards
miles (U.S. statute)
feet
miles (U.S. statute)
feet
yards
meters
nautical miles
feet
yards
miles (U.S. statute)
miles (U.S. statute)
25.4
0.0833
12
0.3048
0.3333
0.0001894
3
0.0005682
5280
1760
1609
0.868
3.271
1.094
0.0006214
1.152
Area
square inches
square inches
square feet
square feet
square meters
square miles
square yards
square centimeters
square feet
square inches
square meters
square feet
square yards
square feet
6.452
0.006944
144
0.09290
10.76
3,097,600
9
Volume
cubic inches
cubic inches
cubic feet
cubic feet
cubic feet
cubic meters
liters
quarts (U.S. liquid)
U.S. gallons
U.S. gallons
U.S. gallons
barrels (petroleum)
Imperial gallons
milliliters
cubic centimeters
cubic feet
cubic inches
cubic meters
U.S. gallons
cubic feet
quarts (U.S. liquid)
liters
barrels (petroleum)
cubic feet
Imperial gallons
U.S. gallons
U.S. gallons
cubic centimeters
16.39
0.0005787
1728
0.02832
7.481
35.31
1.057
0.9463
0.02381
0.1337
0.8327
42
1.201
1
F-l
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Time
seconds
seconds
seconds
minutes
minutes
minutes
hours
hours
hours
minutes
hours
days
seconds
hours
days
seconds
minutes
days
0.01667
0.0002778
0.00001157
60
0.01667
0.0006944
3600
60
0.04167
Mass or Weight
pounds
pounds
pounds
pounds
tons (short)
tons (metric)
tons (long)
kilograms
tonnes (metric tons)
kilograms
short tons
long tons
metric tons
pounds
pounds
pounds
pounds
kilograms
0.4536
0.0005
0.000464
0.0004536
2000
2205
2240
2.205
1000
Energy
calories
calories
Btu (British thermal units)
Btu
joules
joules
Btu
joules
calories
joules
calories
Btu
0.003968
4.187
252.0
1055
0.2388
0.0009479
Velocity
feet per second
feet per second
feet per second
meters per second
meters per second
miles per hour
miles per hour
knots
knots
knots
pounds per cubic foot
grams per cubic centimeter
grams er cubic centimeter
kilograms per cubic meter
meters per second
miles per hour
knots
feet per second
miles per hour
meters per second
feet per second
meters per second
miles per hour
feet per second
grams per cubic centimeter
pounds per cubic foot
kilograms per cubic meter
grams per cubic centimeter
0.3048
0.6818
0.5921
3.281
2.237
0.4470
1.467
0.5148
1.151
1.689
0.01602
62.42
1000
0.001
F-2
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Pressure
ponds per square inch (absolute) (psia)
psia
psia
psia
pounds per square inch (gauge) (psig)
millimeters of mercury (torr)
millimeters of mercury (torr)
inches of water
kilograms per square centimeter
inches of water
kilograms per square centimeter
atmospheres
kilograms per square centimeter
atmospheres
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2)
bars
kilonewtons per square meter (kN/m2) 6.895
atmospheres 0.0680
inches of water 27.67
millimeters of mercury (torr) 51.72
psia add 14.70
psia 0.01934
kN/m2 0.1333
psia 0.03614
millimeters of mercury (torr) 735.6
kN/m2 0.2491
atmospheres 0.9678
kN/m2 101.3
psia 14.22
psia 14.70
kN/m2 100
psia 0.1450
atmospheres 0.9869
atmospheres 0.009869
kilograms per square centimeter 1.020
Viscosity
centipoises
pounds per foot per second
centipoises
centipoises
poises
grams per centimeter per second
Newton seconds per square meter
pounds per foot per second 0.0006720
centipoises 1488
poises 0.01
Newton seconds per square meter 0.001
grams per centimeter per second 1
poises 1
centipoises 1000
Thermal Conductivity
Btu per hour per foot per °F
Btu per hour per foot per °F
watts per meter-kelvin
kilocalories per hour per meter per °C
kilocalories per hour per meter per °C
watts per meter-kelvin
kilocalories per hour per meter per °C
Btu per hour per foot per °F
watts per meter-kelvin
Btu per hour per foot per °F
1.731
1.488
0.5778
1.163
0.6720
Heat Capacity
Btu per pound per °F
Btu per pound per °F
joules per kilogram-kelvin
calories per gram per °C
calories per gram per °C
joules per kilogram-kelvin
Btu per pound per °F
Btu per pound per °F
1
4187
0.0002388
1
Concentration (in water solution)
parts per million (ppm)
milligrams per liter
milligrams per cubic meter
grams per cubic centimeter
grams per cubic centimeter
milligrams per liter
ppm
grams per cubic centimeter
milligrams per cubic meter
pounds per cubic foot
1
1
IxlO'9
IxlO9
62.42
F-3
-------
To Convert
CONVERSION FACTORS (Continued)
To Multiply By
Temperature
degrees Kelvin (°K)
degrees Rankine (°R)
degrees centigrade (°C)
degrees Fahrenheit (°F)
degrees centigrade (°C)
degrees Fahrenheit (°F)
degrees Rankine (°R)
degrees Kelvin (°K)
degrees Fahrenheit (°F)
degrees centigrade (°C)
degrees Kelvin (°K)
degrees Kelvin (°K)
1.8
0.5556
first multiply by 1.8, then add 32
first subtract 32, then multiply by
0.5556
add 273.2
add 459.7
Flow
cubic feet per second
U.S. gallons per minute
Universal Gas Constant (R)
U.S. gallons per minute
cubic feet per second
448.9
0.002228
8.314 joules per gram mole-kelvin
1.987 calories per gram mole-kelvin
1.987 Btu per pound mole per °F
10.73 psia-cubic feet per pound mole per °F
82.057 arm-cubic centimeters per gram mole-kelvin
62.361 millimeters mercury liter per gram mole-kelvin
F-4
-------
INDEX
The pages listed in bold text in the index correspond to the primary uses or definitions of the
associated term. Additionally, this index includes a list of primary purposes for examples and
common errors that are presented throughout the document.
Acid aerosols (see Sulfuric acid and hydrochloric acid) 2-10, 2-11, 3-6, 3-7, 3-9, 4-49
Activity
Chemical use subcategories 3-9 to 3-11
Exemption (see Exemptions)
Thresholds (see Thresholds)
Air emissions
Fugitive or non-point 4-4, 4-21, 4-35, 4-36, 4-39, 4-45, 4-53 to 4-55, 4-62
Stack or point source 4-5, 4-22, 4-24, 4-35, 4-36, 4-39, 4-45, 4-50,
4.53 to 4-55, 4-58, 4-62
Article exemption (see Exemption)
Building 4-45, 4-51 to 4-53
Byproduct 2-12, 3-9, 4-44
Chemical-specific
Acid aerosols 2-10, 2-11, 3-6, 3-7, 3-9, 4-49
Ammonia 2-10, 2-12, 3-5, 3-16, 3-21, 4-20, 4-45, 4-54
Ethylene glycol 2-10, 3-10, 4-38
Formaldehyde 2-10, 2-13, 4-23, 4-53
Glycol ethers 2-10, 3-11
Hydrochloric acid 2-10, 2-13, 3-6, 3-9
Metal compounds 2-13, 3-6, 3-9, 4-7, 4-10 to 4-16, 4-41, 4-47
Methanol 2-10, 3-12, 3-19
Methyl ethyl ketone 2-10, 3-12, 4-30, 4-54, 4-55
Nitrate compounds 2-12, 3-5, 3-6, 4-20, Appendix E
Phenol 2-11, 3-11, 4-45, 4-53, 4-54, 4-59, 4-60
Sulfuric acid 2-11, 3-7, 3-9, 4-49
Toluene 2-2, 2-11, 3-2, 3-11, 4-24, 4-30, 4-31, 4-36, 4-38, 4-45
Zinc . . . 2-11, 3-5 to 3-6, 3-10, 4-30, 4-45, 4-46, 4-48, 4-53 to 4-54, 4-59 to 4-60
Chemical processing aid 3-11
Coating applications 4-42, 4-45, 4-51, 4-58
Combustion 3-19, 3-20, 4-3, 4-11 to 4-14, 4-23, 4-49
For energy recovery off-site 4-14
For energy recovery on-site 4-13
For treatment off-site 4-15
For treatment on-site 4-10, 4-15
Common errors
Articles Exemption 3-18
Coincidental Manufacture 2-13, 4-44
Compounding 2-14
Consumed Chemicals 4-48
Direct Reuse vs. Recycling 4-15, 4-36
Double Counting 4-17
Index-1
-------
Exempt Activities 3-13
Mass Balances for Otherwise Used Chemicals 4-21
Mixture Components 3-4
Off-Specification Tires 4-55
Overlooking Coincidental Manufacturing 3-9
Shipping Container Residue 4-8
Threshold: Assuming One is Exceeded 3-23
Threshold Determination, Recirculation 3-21
Treatment Efficiencies 4-19
Vinyl Chloride 3-2
Zero Release and Other Waste Management Quantities 3-23
Compounding 2-5, 2-10, 2-14, 4-31 to 4-34, 4-41 to 4-46, 4-53, 4-56 to 4-58, 4-60, 4-61
Container residue 4-3, 4-7 to 4-10, 4-45
De minimis (see Exemptions)
Example, de minimis 3-14
Example, de minimis concentration ranges 3-15
Disposal 2-12, 4-7, 4-13
Off-site 4-7
On-site 4-6
Documentation (see Recordkeeping)
Double counting 4-6, 4-17, 4-47, 4-54
Common error, double counting 4-17
Emission factors 4-17, 4-18, 4-21 to 4-24, B-6
Employee equivalent calculation 2-7
Example, calculating employees 2-8
Energy recovery (see Combustion for energy recovery)
Engineering calculations 4-17, 4-23
Example, engineering calculations 4-24
EPCRA hotline 1-2, 1-5
Establishment 2-1, 2-5
Example, primary SIC code 2-6
Examples
Chemical Mixtures 3-11
Chemical Processing Aid 3-11
Chemicals in Process Water 3-20
Coincidental Manufacture of Sulfuric Acid Aerosols 4-50
Container Residue 4-10
De Minimis 3-14
De Minimis Concentration Ranges 3-15
Emission Factors 4-23
Emission Factors to Estimate Air Emissions of Methyl Ethyl Ketone 4-55
Employee Equivalent Calculation 2-8
Engineering Calculations 4-24
Form A Threshold 2-20
Laboratory Activity Exemption 3-18
Mass Balance 4-21
Mass Balance, Estimating Quantities of Metal and Metal Compounds Using 4-48
Index-2
-------
Mass Balance in Synthetic Rubber Production 4-41
Monitoring Data 4-19
Motor Vehicle Exemption 3-19
Multiple Establishments 2-2
Packing Foam 3-10
Primary SIC Code 2-6
Process Equipment Chemical Use 3-20
Relabeling 2-15
Surface Coating of Plastic Parts 4-62
Threshold Determination 3-8
Threshold Worksheet 3-25
Treatment of Wastes from Off Site 2-14
VOC Emissions 4-40
Waste Treatment, On-Site 4-11
Xylene Isomers 3-24
Exemptions 3-13
Activity-related 3-13, 3-18
Article 3-10, 3-16 to 3-18
De minimis 2-17, 3-2, 3-13, D-3, E-3
Facility-related 3-13, 3-18
Grounds maintenance 3-19
Janitorial 3-19
Laboratory 2-6, 3-18
Motor vehicle 3-19
Personal use 3-16, 3-19
Structural components 3-19
Vanadium 2-17, 3-5 to 3-7
Facility
Auxiliary facility 2-6
Covered facility 2-5
Multi-establishment facilities (see Establishments)
Pilot plant 2-6, 3-18
Facility-related exemption (see Exemption)
Finishing operations 2-10, 2-11, 4-30, 4-44, 4-54, 4-58 to 4-61
Form A 1-4, 2-19
Example Form A threshold 2-20
Form R 1-3 to 1-5, 2-18, 4-4 to 4-17, 4-25 to 4-29
Glycol ethers (see Chemical specific)
Impurity 2-12, 3-9, 3-13, 3-14
Laboratory exemption (see Exemption)
Manufacture/Manufacturing 2-12, 3-9
Byproduct 2-12, 3-9
Coincidental manufacture 2-13, 3-19, 4-44, 4-49
Manufacturing subcategories 3-9
Mass balance 4-20
Example, mass balance 4-21
Methods (see Reportable amount estimate methods)
Index- "•
-------
Mixture 2-12, 2-14, 3-1 to 3-4, 3-9 to 3-15, 3-24
Monitoring data 4-19, B-l
Example, monitoring data 4-19
Monomer 2-10, 2-14, 3-2, 4-31, 4-35, 4-38, 4-39, 4-60
Motor vehicle exemption (see Exemption)
MSDS 3-3, 3-12,
Otherwise use 2-8, 2-13, 3-11
Common error, mass balance for otherwise used chemicals 4-21
Owner/operator 1-3
PBT chemicals 2-15 to 2-17
Penalties 1-4
Pilot plant (see Facility)
Point source (see Air emissions)
Polymerization 2-10, 4-30 to 4-38
POTW 4-7, 4-10, 4-11, 4-15, 4-17 to 4-19, 4-28, 4-37, 4-41, 4-45, 4-53, 4-59 to 4-62
Process equipment 3-19, 3-20, 4-51, 4-59
Example, process equipment chemical use 3-20
Process water 3-20, 4-20, 4-44
Example, chemicals in process water 3-20
Processing subcategories 3-10
Qualifiers 3-4 to 3-6
Recordkeeping 2-21
Recycling 3-22
Off-site 4-15
On-site 4-14
Release Chapter 4
Accidental 4-16
Estimates (steps to calculate) 4-1, 4-17
Sources 4-3, 4-35, 4-42, 4-51, 4-58
Types 4-4, 4-36, 4-45, 4-53, 4-59
Reportable amount 2-19
Reporting criteria Chapter 2
Reuse 3-21
Rubber processing 4-31
Rubber product/manufacturing 4-31
Solvent recovery 2-4, 4-31, 4-35, 4-36
Sources (see Release)
Standard Industrial Classification (SIC) 2-4
Primary SIC code 2-6
Supplier notification 2-17
Technically qualified individual 3-18
Thresholds 3-8
Example, Form A threshold 2-20
PBT chemical trhesholds 2-16
Threshold determination Chapter 3
Threshold worksheet 3-24 to 3-26
Tire manufacturing 4-51
Index-4
-------
Trade secret 2-20
Transfers 4-7, 4-14 to 4-16, 4-20
Treatment efficiency 4-11, 4-15
Treatment for destruction
Off-site 4-15
On-site 4-10 to 4-15
Types (see Release)
Vulcanizing 2-10, 2-11, 4-30, 4-41, 4-44, 4-45, 4-54
Waste management Chapter 4
Waste treatment (see Treatment for destruction)
Common error, treatment efficiencies 4-19
Example, on-site waste treatment 4-11, 4-40
Wastewater discharge 4-6
Index-5
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