oEPA
United States
Environmental Protection Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
February 2000
EPA 745-B-00-003
EPCRA Section 313
Industry Guidance
COAL MINING FACILITIES
Section 313 of the
Emergency Planning and
Community Right-to-Know Act
Toxic Chemical Release Inventory
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TABLE OF CONTENTS
OVERVIEW iii
Acknowledgment v
Chapter 1 - Introduction 1-1
1.0 PURPOSE 1-1
1.1 Background onEPCRA 1-2
Chapter 2 - Reporting Requirements 2-1
2.0 PURPOSE 2-1
2.1 Must You Report? 2-1
2.2 Definition of "Facility" 2-3
2.3 SIC Code Determination 2-4
2.4 Number of Employees 2-6
2.5 Manufacturing, Processing, and Otherwi se Use of EPCRA
Section 313 Chemicals 2-7
2.6 Activity Thresholds 2-8
2.7 How Do You Report? 2-10
2.8 Form R 2-10
2.9 Form A 2-11
2.10 Trade Secrets 2-12
2.11 Recordkeeping 2-13
Chapter 3 - EPCRA Section 313 Threshold Determinations 3-1
3.0 PURPOSE 3-1
3.1 Step 1. Determining which EPCRA Section 313 chemicals are manufactured (including
imported), processed, or otherwise used 3-1
3.2 Step 2. Determining the quantity of each EPCRA Section 313 chemical manufactured
(including imported), processed, or otherwise used 3-8
3.2.1 Concentration Ranges for Threshold Determination 3-44
3.2.2 Evaluation of Exemptions 3-45
3.2.2.1 Coal Extraction Activities Exemption 3-46
3.2.2.2 Laboratory Activities Exemption 3-47
3.2.2.3 De minimis Exemption 3-47
3.2.2.4 Article Exemption 3-51
3.2.2.5 Exemptions That Apply to the Otherwise Use of EPCRA
Section 313 Chemicals 3-52
3.2.3 Additional Guidance on Threshold Calculations for
Certain Activities 3-54
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3.2.3.1 On-site Reuse Activities 3-55
3.2.3.2 Remediation Activities 3-55
3.3 Step 3. Determine which EPCRA Section 313 chemicals
exceed a threshold 3-55
Chapter 4 - Estimating Releases and Other Waste Management Quantities 4-1
4.0 PURPOSE 4-1
4.1 General Steps for Determining Releases and Other
Waste Management Activities 4-3
4.1.1 Step 1. Identify Potential Sources of Chemical Release and Other Waste
Management Activities 4-3
4.1.2 Step 2. Prepare a Process Flow Diagram 4-4
4.1.3 Step 3. Identify On-Site Releases, Off-Site Transfers and On-Site Waste
Management Activity Types 4-4
4.1.4 Step 4. Determine the Most Appropriate Method(s) to Develop the Estimates
for Releases and Other Waste Management Activity Quantities and Calculate
the Estimates 4-15
4.1.4.1 Monitoring Data or Direct Measurement (code M) 4-16
4.1.4.2 Mass Balance (code C) 4-17
4.1.4.3 Emissions Factors (codeE) 4-19
4.1.4.4 Engineering Calculations (code O) 4-20
4.1.4.5 Estimating Releases and Other Waste Management Quantities . . . 4-21
4.1.5 Other Form R Elements 4-24
4.1.5.1 Maximum Amount On-Site (Part H, Section4.1 ofFormR) .... 4-24
4.1.5.2 Production Ratio or Activity Index (Part H, Section 8.9 of
Form R) 4-24
4.1.5.3 Source Reduction (Part H, Sections 8.10 and 8.11 ofFormR) . . 4-25
4.2 Calculating Release and Other Waste Management Estimates at Coal Mining Faciliie£6
4.2.1 Coal Mining Overview 4-26
4.2.2 Fugitive Air Emissions, Section 5.1 of Form R 4-34
4.2.3 Stack or Point Source Air Emissions, Section 5.2 of Form R 4-35
4.2.4 Discharges to Receiving Streams or Water Bodies, Section 5.3 of Form R; and
Discharges to Publicly Owned Treatment Works (POTWs), Section 6.1 of
Form R 4-40
4.2.5 Disposal to Land On-site, Section 5.5 of Form R 4-43
4.2.6 Transfers Off-site, Section 6.2 of Form R 4-45
4.2.7 On-site Waste Management Methods, Section 7A, 7B, and 7C
of Form R 4-46
4.2.8 Source Reduction and Recycling Activities 4-47
4.2.9 Source Reduction Activities 4-48
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Appendix A - TRI Guidance Resources A-1
OVERVIEW
On May 1, 1997, the U.S. Environmental Protection Agency (EPA) promulgated a final rule
(62 FR 23834) adding several new industrial sectors to the list of facilities subject to the Emergency
Planning and Community Right-To-Know Act (EPCRA) Section 313 reporting requirements. Facilities
affected by this rule are subject to the annual reporting requirements beginning with activities conducted
during the 1998 calendar year, with their first reports due by July 1, 1999.
This document supersedes the document entitled Section 313 Emergency Planning and
Community Right-to-Know Act, Guidance for Coal Mining Recovery Facilities, dated October
1997. It is intended to assist establishments and facilities designated by Standard Industrial
Classification (SIC) code 12 (except 1241) in making compliance determinations under the EPCRA
Section 313 reporting requirements and preparing Form R(s) or the Form A certification statement(s)
as required. The EPCRA Section 313 program is commonly referred to as the Toxic Chemical
Release Inventory (TRI) program.
The principal differences in the new document include the following:
More detailed examples;
Additional interpretive guidance prepared by EPA on various issues specific to Coal
Mining facilities;
Industry process issues not discussed in the earlier document; and
General format changes for program consistency.
This document is designed to be a supplement to the Toxic Chemical Release Inventory
Reporting Forms and Instructions (TRI Forms and Instructions), issued annually. It is organized to
provide a step-by-step guide to compliance with EPCRA Section 313, starting with how you determine
if your facility must report through completion of the Form R or Form A. While certain information
provided in this document may be used as a reference, specific information available to facilities, such
as amounts of chemicals in mixtures and other trade name products used at the facility, may be more
accurate and more appropriate for use in developing threshold determinations and estimating releases
and other waste management amounts. Under EPCRA Section 313, facilities are instructed to use the
best "readily available data", or when such data are not available, "reasonable estimates", in fulfilling
their reporting requirements. This document is organized in the following manner.
Chapter 1 serves as an introduction to TRI reporting and provides a brief background on the
Emergency Planning and Community Right-to-Know Act and information on where to obtain additional
compliance assistance.
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Chapter 2 begins with how to determine if your facility must report. This determination is based
on your answers to a series of four questions:
1. Is your facility's primary SIC code on the EPCRA Section 313 list?
2. Does your facility employ ten or more full time equivalent employees?
3. Does your facility manufacture, process, or otherwise use any EPCRA Section 313
chemicals?
4. Does your facility exceed any of the activity thresholds for an EPCRA Section 313
chemical?
If the answer to ANY ONE of the four questions above is "No" you are not required to submit
an EPCRA Section 313 report. If you answer "Yes" to ALL four questions, the next step is
determining which form(s), Form R or Form A, your facility should file. Chapter 2 provides detailed
information on the requirements for each kind of submission.
Chapter 2 concludes with a discussion on how you address trade secrets in your reporting and
the kinds of records you should be keeping to support your reporting.
Chapter 3 discusses how you calculate the activity thresholds (manufacture, process, and
otherwise use) for the EPCRA Section 313 chemicals. Information is provided on how you determine
which EPCRA Section 313 chemicals your facility manufactures, processes, or otherwise uses and how
you calculate the quantities of each. Detailed information is also provided on the various exemptions.
Chapter 3 concludes with a discussion of how to determine which EPCRA Section 313
chemicals exceed a reporting threshold, including focused discussions on issues specific to coal mining
facilities.
Chapter 4 discusses how you calculate the release and other waste management amounts for
those EPCRA Section 313 chemicals for which you must prepare a report. This chapter provides a
step-by-step approach designed to minimize the risk of overlooking an activity involving an EPCRA
Section 313 chemical and any potential sources or types of releases and other waste management
activities that your facility may conduct. This procedure consists of the following steps:
Identification of potential sources of EPCRA Section 313 chemicals released and
otherwise managed as wastes;
Preparation of a detailed process flow diagram;
Identification of the potential types of releases and other waste management activities
from each source; and
Determination of the most appropriate methods for estimating the quantities of listed
EPCRA Section 313 chemical releases and other waste management activities.
The main part of Chapter 4 is organized around activities common to coal mining facilities
where EPCRA Section 313 chemicals are manufactured, processed, or otherwise used. A list of
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EPCRA Section 313 chemicals likely to be manufactured, processed, or otherwise used by coal mining
facilities; process descriptions; guidance on thresholds determinations; release and other waste
management estimation techniques; and problems these types of facilities are likely to face in complying
with EPCRA Section 313 are also presented in this chapter.
This document includes examples of chemical management activities that coal mining facilities
may conduct, illustrating how these activities should be considered for EPCRA Section 313 reporting
purposes. This chapter also notes area where potential errors in reporting might be encountered
generally by coal mining facilities, which are based on information from written comments received from
industry representatives, as well as from comments made by participants in EPA-sponsored EPCRA
workshops.
ACKNOWLEDGMENT
EPA would like to recognize the valuable contributions made by staff at Kennecott Energy and
Thunder Basin Coal Company, whose industry insight and understanding of EPCRA Section 313
requirements have greatly assisted in increasing the utility of this document. Special thanks go to Bob
Green, Environmental Manager at Kennecott Energy and Jerry Fiore, Environmental Manager at
Thunder Basin Coal Company.
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Chapter 1 - Introduction
1.0 PURPOSE
The purpose of this guidance document is to assist facilities in SIC 12 (except 1241) comply
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),
commonly referred to as the Toxic Release Inventory (TRI). On May 1, 1997, EPA promulgated a
rule (62 FR 23834) to require coal mining facilities, along with other industry groups, to be included on
the list of facilities subject to the EPCRA Section 313 reporting requirements. The new facilities are
subject to annual reporting requirements beginning with activities occurring in the 1998 calendar year,
with the first reports due by July 1, 1999.
This document explains the EPCRA Section 313 and PPA Section 6607 reporting
requirements (collectively referred to as the EPCRA Section 313 reporting requirements) and discusses
specific release and other waste management activities encountered at many facilities in this industry.
Because each facility is unique, the recommendations presented may have to be adjusted to the specific
nature of operations at your facility.
This document supersedes the document entitled Section 313 Emergency Planning and
Community Right-to-Know Act, Guidance for Coal Mining Facilities., dated October 1997.
The document is intended to supplement the Toxic Chemical Release Inventory Reporting
Forms and Instructions (TRI Forms and Instructions) document which is updated and published
annually by the U.S. Environmental Protection Agency (EPA). It is essential that you use the most
current version of the TRI Forms and Instructions to determine whether (and how) you should report.
Changes or modifications to TRI 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:
Clarify EPCRA Section 313 requirements for industry;
Increase the accuracy and completeness of the data being reported by coal mining
facilities; and
Reduce the level of effort expended by those facilities that prepare an EPCRA Section
313 report.
While it is not possible to anticipate every potential issue or question that may apply to your
facility, this document attempts to address those issues most prevalent or common to coal mining
facilities. Facilities should also rely on EPA's Estimating Releases and Waste Treatment
Efficiencies for the Toxic Chemical Release Inventory Form document to assist in providing
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complete and accurate information for EPCRA Section 313 reporting. Additional discussion
addressing specific issues can be found in EPA's current version of EPCRA Section 313 Questions
and Answers. All of these documents are available on the 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. The EPCRA TDD Hotline number is 1-800-553-7672 or 703-412-3323 for
calls within the Washington, DC metropolitan area.
1.1 Background on EPCRA
One of EPCRA's primary goals is to increase the public's knowledge of, and access to,
information on both the presence and release and other waste management activities of EPCRA
Section 313 chemicals in their communities. Under EPCRA Section 313, certain facilities (see SIC
code discussion, Chapter 2.3) exceeding certain thresholds (see Chapter 2.5) are required to submit
reports (commonly referred to as Form Rs or Form A certification statements) annually for over 600
EPCRA Section 313 chemicals and chemical categories and the amounts that enter an environmental
medium or are otherwise managed as waste, even if there are no release or other waste management
quantities associated with these chemicals. Chemicals are considered by EPA for inclusion on the
EPCRA Section 313 list based on their potential for acute health effects, chronic health effects, and
environmental effects. Chemicals 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 managed at your facility. Copies of the reporting package
can be requested from the EPCRA Hotline, as indicated above, or from the Internet at
http://www.epa.gov/tri/report.htm.
All facilities meeting the EPCRA Section 313 reporting criteria must submit either a Form R or
Form A. A separate submission is required for each EPCRA Section 313 chemical or chemical
category that is manufactured (including imported), processed, or otherwise used above the reporting
threshold. Reports must be submitted to 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 of the reporting
deadline 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, for example, owners of an industrial park who only have a real estate interest, are not
responsible for any reporting requirements.
EPCRA also mandates that EPA establish and maintain a publicly available database consisting
of the information reported under Section 313, and applicable PPA information. This database, known
as the Toxic Chemical Release Inventory (TRI), can be accessed through the following sources:
National Library of Medicine (NLM) TOXNET on-line system;
EPA's Internet site, http://www.epa.gov/tri;
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Envirofacts Warehouse Internet site,
http://www.epa.gov/enviro/html/tri s/tris_overview.html;
CD-ROM from the Government Printing Office (GPO);
Microfiche in public libraries;
Magnetic tape and diskettes from the National Technical Information Service; and
EPA's annual TRI data release materials (summary information).
In addition to being a resource for the public, TRI is also used in the research and development
of regulations related to EPCRA Section 313 chemicals.
Alternative Submission (Form A)
To reduce the burden for facilities that must comply with EPCRA Section 313, EPA has
established an alternate threshold of one million pounds manufactured, processed, or otherwise used for
facilities with total annual reportable amounts of 500 pounds or less of the EPCRA Section 313
chemical. 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 it did not exceed the reportable amount or exceed the alternate threshold (see Chapter 2.9
for more detail).
Note that the annual reportable amount includes the quantity of EPCRA Section 313 chemicals
in all production-related waste management activities, not just releases (see the waste management
discussion in Chapter 4 for more detail). Also, a covered facility must submit either a Form A or a
Form R for each EPCRA Section 313 chemical exceeding an applicable reporting threshold even if
there are no releases and other waste management quantities.
Enforcement
Violation of Section 313 reporting provisions may result in federal civil penalties of up to
$27,500 per day. State enforcement provisions may also be applicable depending on the state's
adoption of any "EPCRA Section 313-like" reporting regulations.
Regulatory Assistance Resources
The TRI Forms and Instructions also contain a discussion of common problems in completing
the Form R. You are encouraged to read this section before filling out the Form R (or Form A) for
your facility. If, after reading both the TRI Forms and Instructions and this guidance document, you
still have questions about EPCRA Section 313 reporting, please contact the EPCRA Hotline at 1-800-
424-9346 or 703-412-9810 for calls within the Washington, DC metropolitan area. The EPCRA
TDD Hotline number is 1-800-553-7672 or 703-412-3323 for calls within the Washington, DC
metropolitan area. Assistance is also available from the designated EPCRA Section 313 Coordinator
in the EPA regional office and the EPCRA contact in your state (see the TRI Forms and Instructions
for a current list of these contacts). Appendix A contains a list of additional reference sources.
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Chapter 2 - Reporting Requirements
2.0 PURPOSE
The purpose of this chapter is to help you determine whether you must prepare an EPCRA
Section 313 submission(s) and, if so, what kind of a submission(s) you should prepare (Form R or
Form A). This chapter presents the EPCRA Section 313 reporting requirements to help you determine
whether these requirements apply to your facility. It also discusses the records that you must keep.
The following terms and concepts are described in this chapter to help you understand the scope of
Section 313 reporting and determine whether you need to report, including:
Definition of facility;
SIC code determination;
Employee determination;
Definitions of manufacture, process, and otherwise use; and
Determination of whether you exceed one of the thresholds.
2.1 Must You Report?
How do you determine if your facility must prepare an EPCRA Section 313 report? This is
decided by your answers to the following four questions (illustrated by Figure 2-1):
1) Is the primary SIC code(s) for your facility included in the list covered by EPCRA
Section 313 reporting (see Chapter 2.3)?
2) Does your facility employ 10 or more full time employees or the equivalent (see
Chapter 2.4)?
3) Does your facility manufacture (which includes importation), process, or otherwise use
EPCRA Section 313 chemicals (see Chapter 2.5)?
4) Does your facility exceed any applicable thresholds of EPCRA Section 313 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 Chapter 2.6)?
If you answered "No" to any of the four questions above, you are not required to prepare any
submissions under EPCRA Section 313. If you answered "Yes" to ALL of the first three questions,
you must perform a threshold determination for each EPCRA Section 313 chemical at the facility, and
submit a Form R or Form A for each chemical exceeding a threshold.
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Figure 2-1: TRI Reporting Determination Diagram
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2.2 Definition of "Facility"
To understand the applicability of EPCRA Section 313, 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 which controls, is controlled by, or 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 services or industrial operations are performed" (40 CFR 372.3).
EPA recognizes that some facilities have unique and separate activities ("establishments") taking
place at the same facility, and for some of these facilities it may be easier and more appropriate for
individual establishments to manage their chemical usage and management information separately. EPA
provides for these cases and allows individual establishments at the same facility to report separately.
However, for threshold determinations, quantities of EPCRA Section 313 chemicals manufactured,
processed, or otherwise used in all establishments in that facility must be combined and considered
together. Also, the combined releases and other waste management activities reported separately for
each establishment must equal those for the facility as a whole.
Example - Multiple Establishments
Your facility is comprised of two different establishments, with SIC codes covered by EPCRA Section 313. One
establishment used 3,000 pounds of an EPCRA Section 313 chemical for boiler cleaning during the year. Another
establishment used 8,000 pounds of the same chemical as a coolant during the same year. Both activities
constitute an "otherwise use" of the listed EPCRA Section 313 chemical (as presented in Section 2.5 and
described in detail in Chapter 3) and together, the total quantity otherwise used at the facility exceeded the
10,000 pound otherwise use threshold for the year. If your facility meets the employee threshold, you must file
either a Form R or a Form A for that chemical. EPA allows multi-establishment facilities to submit Form Rs from
each establishment for an EPCRA Section 313 chemical when thresholds have been exceeded at the facility level.
Please note that Form A eligibility is also made at the facility-level, but only one Form A can be submitted per
chemical for the entire facility.
Contiguous and/or Adjacent Facilities. In defining the parameters of your facility, you must
consider all buildings and other stationary items located on multiple contiguous or adjacent sites that are
owned or operated by the same person for EPCRA reporting purposes. For example, an industrial
park could contain a manufacturing company and a solvent recovery operation, both operated
independently, but owned by the same parent company. Since the two establishments are contiguous
or adjacent to each other, they are considered one "facility." The amount of each EPCRA Section 313
chemical manufactured, processed, or otherwise used and the number of employees must be
aggregated for all of these contiguous or adjacent sites to determine whether the entire facility meets
reporting thresholds. If a company's operations are carried out at two distinctly separate, physical sites
that are not contiguous or adjacent, that company is operating two separate facilities for the purposes of
EPCRA reporting. The company, therefore, must make SIC code, employee, threshold
determinations, and if appropriate, release and other waste management estimates individually for each
facility.
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If two establishments owned or operated by the same company are connected to each other by
a piece of property that is owned by one of the establishments or the same parent corporation, or if
they are separated by an easement (e.g., railroad tracks, public road, public catchment basin), they are
still considered to be contiguous or adjacent and are therefore part of the same facility. Both
"establishments" may report together as the same facility or they may report separately provided
threshold determinations are based on activities at the entire facility and that the sum of the releases of
the establishments reflects the total releases of the whole facility. Facility operations that are not
connected to each other by a piece of property, that is commonly owned, controlled, or operated by
the same person(s), are not considered contiguous and may be considered two separate facilities.
However, if these operations are relatively near each other, they may be considered adjacent; in which
case, they would be part of the same facility.
2.3 SIC Code Determination
Facilities with the SIC codes presented in Table 2-1 are covered by the EPCRA Section 313
reporting requirements. 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.
Table 2-1
SIC Codes Covered by EPCRA Section 313 Reporting
SIC Code Industry Sectors
SIC Codes
10
12
20 through 3 9
49 11, 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 101 1, 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
Facilities in SIC code 12, except 1241 (contract mining), must prepare Form R and/or Form A
submissions if they exceed the employee and chemical activity thresholds. While SIC code 1241 is not
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a covered SIC code, any contract mining activities that occur at a covered facility (e.g., coal mine)
would be applied to the facility's employee and chemical activity thresholds.
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 statutory and/or 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.
Primary SIC Code Determination. Assuming your facility has several establishments with
different SIC codes that are owned or operated by the same entity, you will need to determine if your
facility has a primary SIC code that is subject to EPCRA Section 313. Your facility is subject to
EPCRA Section 313 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 or
products produced and/or shipped by all of the other establishments within the facility
on an individual basis.
To determine the value of production or service attributable to a particular establishment, you
can subtract the product or service value obtained from other establishments from the total product or
service value of the facility. This procedure eliminates the potential for "double counting" production or
service in situations where establishments are engaged in sequential production activities at a single
facility.
Auxiliary Facilities. Some companies may own and/or operate a non-contiguous and non-
adjacent facility that primarily supports a covered EPCRA Section 313 facility. These auxiliary facilities
assume the SIC code of a covered facility that it directly supports. For example, an off-site warehouse
that directly supports a covered coal mine (SIC code 1221) must assume the SIC code 1221 itself.
For the purposes of EPCRA Section 313, auxiliary facilities must be engaged in performing support
services for another facility or establishment within a covered facility. Therefore, if an auxiliary facility's
primary function is to support/service a covered coal mining facility, the auxiliary facility may assume the
SIC code of the main facility and may then be covered by the EPCRA Section 313 reporting
requirements for purposes of the facility's SIC code.
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2.4 Number of Employees
Facilities must also meet or exceed the 10 or more full-time employees or equivalent criterion to
be subject to EPCRA Section 313 reporting requirements. A full-time employee equivalent is defined
as a work year of 2,000 hours. If your facility's staff (including contractors and certain other non-
company personnel) work 20,000 or more hours in a calendar year, you meet the 10 or more full-time
employee criterion. While many facilities may easily exceed this criterion, your facility may be small or
highly automated and your on-site staff may be small. In these cases, in particular, you should carefully
consider all personnel supporting your operations to determine if you meet the 10 or more full-time
employee criterion.
The following personnel and time should be included in your employee calculations:
Owners working at the facility;
Operations staff;
Clerical staff;
Temporary employees;
Sales personnel;
Truck drivers (employed by the facility);
Other off-site facility employees directly supporting the facility;
Paid vacation and sick leave; and
Contractor employees (excluding contract truck drivers).
In general, if an individual is employed or hired to work at the facility, all the hours worked by
that individual must be counted in determining if the 20,000 hour criterion has been met.
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Example - Calculating Employees
Your facility has four full-time employees working 2,000 hours/year in the mine and three full-time employees
working 2,000 hours/year in the preparation plant. There is also one full-time sales person and a delivery truck
driver (employed by the facility) assigned to the plant, each working 2,000 hours/year but predominantly not at
the facility. The wastewater treatment plant (WWTP) (on-site and owned by the facility) is operated by a
contractor who spent 1,000 hours working at the plant during the year. The hours of the employees and the
WWTP contractor are tracked by controlled-access card reader (scan in/out) system. 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 based on invoices). You would calculate the number of full-time
employee equivalents as follows:
Hours for your nine full-time employees (four mining personnel, three plant personnel, one
salesperson, and one delivery truck driver) for the year are:
9 employees x 2,000 hours/year = 18,000 hours;
Hours for the wastewater treatment plant operator are:
1,000 hours; and
Hours for the construction crew are:
4 contractors x 1,000 hours = 4,000 hours.
This is a total of 23,000 hours for the year, which is above the 20,000 hours/year threshold; therefore, you meet
the employee criterion.
POSSIBLE ERROR - Construction Workers
Remember to include construction contractors, even if involved in non-process related construction activities
(e.g., office building renovations or construction) in your calculation.
2.5 Manufacturing. Processing, and Otherwise Use of EPCRA Section 313 Chemicals
If you have determined that your facility meets the SIC code and employee threshold
determinations, you must determine what EPCRA Section 313 chemicals are manufactured, processed,
or otherwise used at your facility during the reporting year and whether an activity threshold was
exceeded. This section of the chapter will introduce the terms and concepts behind this determination;
whereas, Chapter 3 will take you through a detailed step-by-step process to determine whether you
need to report for any EPCRA Section 313 chemicals.
Identifying Chemicals 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 are manufactured,
processed, or otherwise used at your facility in excess of threshold quantities. To assist in doing this,
you should prepare a list of all chemicals manufactured, processed, or otherwise used by all
establishments at the facility, including the chemicals present in mixtures and other trade name products
and managed in wastes received from off-site. This list should then be compared to the CURRENT list
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of EPCRA Section 313 chemicals found in the TRI Forms and Instructions document for that
reporting year (available from the EPCRA Hotline, 1-800-424-9346 or 703-412-9810 for calls within
the Washington, DC metropolitan area, or at the website, http://www.epa.gov/tri). In addition to the
individually listed chemicals, the list of EPCRA Section 313 chemicals includes several chemical
categories (discussed in detail in Chapter 3). You must include chemical compounds that are members
included in any of these categories when evaluating activities at the facility for threshold determinations
and release and other waste management calculations. Once you identify the EPCRA Section 313
chemicals and chemical categories at your facility, you must evaluate the activities involving each
chemical or chemical category and determine whether any activity thresholds have been met.
Note that chemicals are periodically added, delisted, or modified. Therefore, it is imperative
that you refer to the appropriate reporting year's list. Also, note that a list of synonyms for EPCRA
Section 313 chemicals can be found in the EPA publication Common Synonyms for Chemicals
Listed Under Section 313 of the Emergency Planning and Community Right-To-Know Act
(updated March 1995).
2.6 Activity Thresholds
There are three activity thresholds for the EPCRA Section 313 chemicals defined in EPCRA
Section 313: 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 use. These thresholds apply to each chemical individually. The
determination is based solely on the quantity actually manufactured (including imported), processed, or
otherwise used. Only the amounts of the listed EPCRA Section 313 chemical that meet activity
definitions are considered towards threshold determinations. Any other amounts not considered to be
manufactured, processed, or otherwise used are not considered toward threshold determinations. For
example, EPCRA Section 313 chemicals that are brought on-site (excluding amounts imported) and
stored for future use or disposal, but are not incorporated into a product for distribution or are not
otherwise used on-site during the reporting year, are NOT considered towards any activity threshold
for that reporting year.
More detailed explanations of threshold activities (manufactured, processed, or otherwise
used), with examples of each are found in Chapter 3. These terms are briefly defined in Table 2-2,
with a detailed discussion to follow.
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Table 2-2
Activity Thresholds
Activity
Definition
Threshold
(Ibs/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical.
"Manufacture" 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 or impurity.
Examples would be the production of ammonia or nitrate compounds in a
wastewater treatment system or the creation of metal compounds during the
combustion of coal.
25,000
Process
The preparation of an EPCRA Section 313 chemical, after its manufacture, for
distribution in commerce:
(1) In the same form or physical state as, or in a different form or
physical state from, that in which it was received by the person so
preparing such chemical; or
(2) As part of an article containing the EPCRA Section 313 chemical.
For example, if you receive a mixture containing an EPCRA Section 313
chemical and package it, including transferring from a storage tank to a tank
truck, and then distribute it into commerce, this chemical has been processed
by your facility.
25,000
Otherwise
Use
Generally, use of an EPCRA Section 313 chemical that does not fall under the
manufacture or process definitions is classified as otherwise use. An EPCRA
Section 313 chemical that is otherwise used is not intentionally 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, methanol used as a cleaning solvent
is classified as otherwise used.
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 an EPCRA
Section 313 chemical does not include disposal, stabilization (without
subsequent distribution in commerce), or treatment for destruction
unless the:
1) EPCRA Section 313 chemical that was disposed, stabilized, or
treated for destruction was received from off-site for the purposes of
further waste management; or
2) EPCRA Section 313 chemical that was disposed, stabilized, or
treated for destruction that 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
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There are some activities which do not meet the definitions of manufacture, process, or
otherwise use. For instance, storage, relabeling, or redistribution of an EPCRA Section 313 chemical
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 calculations. In addition, transfers of
EPCRA Section 313 chemicals in waste for energy recovery, treatment, or disposal are not considered
"distribution into commerce."
Also, note that the threshold determinations for the three threshold activities (manufacturing,
processing, and otherwise use) are mutually exclusive. That is, you must conduct a separate threshold
determination for each threshold activity and if you exceed any threshold, all releases and other waste
management activities of EPCRA Section 313 chemicals at the facility must be considered for
reporting.
Example - Storage
A coal mining facility applies ethylene glycol to prevent freezing of coal during its preparation and storage on-site
The facility receives 30,000 pounds of ethylene glycol and places it in storage in the current reporting year. In th
course of the reporting year, 9,000 pounds is removed from storage and is applied to coal. Is the otherwise use
threshold exceeded?
Because storage is not considered a reportable activity, only the amount actually applied to coal is considered
otherwise used. Therefore, the facility has only otherwise used 9,000 pounds of ethylene glycol and the
otherwise use threshold has not been exceeded. If, however, ethylene glycol is manufactured, processed, or
otherwise used in excess of the applicable thresholds elsewhere at the facility, all release and other waste
management calculations must be completed for ethylene glycol including amounts that may result from storage
activities.
2.7 How Do You Report?
You must file a report (Form R) for each EPCRA Section 313 chemical that exceeds a
threshold for manufacturing, OR processing, OR otherwise use (providing you meet the employee and
SIC code criteria). As an alternative, you may file a Form A certification statement rather than a Form
R if you meet certain criteria as explained in Chapter 2.9. The TRI Forms and Instructions contain
detailed directions for the preparation and submittal of Form R and Form A for each EPCRA Section
313 chemical for the reporting year. The TRI Forms and Instructions are sent to all facilities which
submitted Form Rs or Form As the preceding year. However, if you do not receive a courtesy copy or
did not report in the preceding year, then copies of the TRI Forms and Instructions can be requested
from the EPCRA Hotline (1-800-424-9346 or 703-412-9810 for calls within the Washington, DC
metropolitan area) or obtained from EPA's TRI website (http://www.epa.gov/tri).
2.8 FormR
If you are submitting a Form R, it is essential that you use the TRI Forms and Instructions for
the appropriate reporting year. EPA encourages the electronic submittal of the Form R, via the
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Automated TRI Reporting System (ATRS). Use of the ATRS saves time in data entry and
photocopying and reduces errors by means of automated validation procedures. The ATRS produces
a certification letter with each validated submission (set of EPCRA Section 313 reports) which
provides for an original signature to certify that the submission is accurate and correct. The ATRS is
available free of charge from EPA's TRI website at http://www.epa.gov/opptintr/afr.
The ATRS is available in both DOS and Windows versions. More information can be found in
the TRI Forms and Instructions, EPA's TRI website, or by calling the ATRS User Support Hotline at
(703)816-4434.
Each Form R must consist of two parts:
Part I. Facility Identification Information This part of the form provides general information to
identify the facility, including the name and address of the facility, parent company information,
and identification numbers used under reporting regulations. When submitting hard copies of
Form R, this part may be photocopied and re-used for each Form R you submit, except for the
signature which must be original for each Form R; and
Part n. Chemical Specific Information. This part of the form provides chemical-specific
information on the reportable activities, releases, other waste management estimates, and
source reduction activities for the reporting year. This must be completed separately for each
EPCRA Section 313 chemical or chemical category and not reused year to year even if
reporting has not changed.
Submission of incomplete Form Rs may result in an 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 and submitting the Form R.
The ATRS has a validation program which helps to identify and eliminate many potential data entry
errors.
2.9 Form A
EPA developed the Form A, also referred to as the "Certification Statement," to reduce the
annual burden for facilities with lesser amounts of EPCRA Section 313 chemicals released and/or
otherwise managed as a waste, applicable beginning reporting year 1995 and beyond (59 FR 61488;
November 30, 1994). A facility must meet the following two criteria in order to use a Form A:
First, the amount of the chemical manufactured, processed, OR otherwise used cannot
exceed 1,000,000 pounds. It is important to note that the quantities for each activity
are mutually exclusive and must be evaluated independently. If the quantity for any one
of the activities exceeds 1,000,000 pounds, a Form A cannot be submitted.
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Second, the total annual reportable amount of the EPCRA Section 313 chemical
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 in Part n of the Form R
(explained in Chapter 4).
Example - Form A Threshold
As requested by its customers, a coal mining facility applies ethylene glycol to prevent coal freezing during
transport. This activity constitutes "processing" because the ethylene glycol is intentionally incorporated into
the product for distribution into commerce. Over the course of the reporting year, the facility estimates that the
quantity of ethylene glycol processed is 30,000 pounds, exceeding the 25,000-pound threshold. While the
majority of the EPCRA Section 313 chemical remains with the coal that is distributed into commerce, the total
reportable quantity of ethylene glycol (the sum of Sections 8.1 through 8.7 of the Form R) is 270 pounds due to
spills on application to the product. Because the facility did not exceed the one million pound threshold for
manufacturing, processing, or otherwise use of ethylene glycol and the facility's total reportable quantity of
ethylene glycol does not exceed 500 pounds, the facility has the option of submitting a Form R or a Form A.
The Form A Certification Statement must be submitted for each eligible EPCRA Section 313
chemical. The information on the Form A is 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;
rather, only one Form A per EPCRA Section 313 chemical can be submitted per facility.
Like the Form R, Form A includes facility identification information. However, no release and
other waste management estimations to any media are provided. You must simply certify that the total
annual reportable quantity of the chemical or chemicals addressed in the Form A did not exceed 500
pounds and that amounts manufactured, or processed, or otherwise used did not exceed one million
pounds. Once a 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 provided activities related
with the chemical do not change significantly. It is strongly recommended that you document your initial
rationale and reconfirm it every year to verify that you have not made any modifications to the process
that would invalidate the initial rationale supporting submission of a Form A.
2.10 Trade Secrets
EPCRA's trade secrets provision only applies to the EPCRA Section 313 chemical identity. If
you submit trade secret information, you must prepare two versions of the substantiation form as
prescribed in 40 CFR Part 350, published in the Federal Register on July 29, 1988, (53 FR 28801)
as well as two versions of the Form R. One set of forms should be "sanitized" (i.e., it should provide a
generic name for the EPCRA Section 313 chemical identity). This version will be made available to the
public. The second version, the "unsanitized" version, should provide the actual identity of the EPCRA
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Section 313 chemical and have the trade secret claim clearly marked in Part I, Section 2.1 of the
Form R or Form A. 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. Facilities may
jeopardize the trade secret status of an EPCRA Section 313 chemical by submitting an unsanitized
version to a state agency or Indian tribe 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 most current version of 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 an EPA compliance audit. EPA requires you to maintain records substantiating the Form R
or Form A submission for a minimum of three years from the date of submission. Each facility must
keep copies of the Form R or Form A along with all supporting documents, calculations, work sheets,
and other forms that you use to prepare the Form R or Form A. EPA may request this supporting
documentation during a regulatory audit.
Specifically, EPA requires that 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):
1) A copy of each report that is submitted;
2) All supporting materials and documentation used by the person to make the compliance
determination that the facility or establishment is a covered facility;
3) Documentation supporting the report that is submitted, including documentation
supporting:
Threshold determinations
Employee threshold determinations (including timesheets);
Claimed allowable exemptions;
Calculations for each quantity reported as being released, either on or off site,
or otherwise managed as waste;
Activity use determinations, including dates of manufacturing, processing, or
otherwise use;
Basis of all estimates;
Receipts or manifests associated with transfers of waste to off-site locations;
and
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Waste treatment methods, estimates of treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps, and operating
data to support efficiency claims.
4) All supporting materials used to make the compliance determination that the facility or
establishment is eligible to submit a Form A;
5) Documentation supporting the Form A, including:
Data supporting the determination that the alternate threshold applies;
Calculations of annual reporting amounts; and
Receipts or manifests associated with the transfer of each chemical in waste to
off-site locations.
Because EPCRA Section 313 reporting does not require additional testing or monitoring, you
must determine the best "readily available data" to make reporting determinations. Alternatively, you
may use "reasonable estimates" to make reporting determinations. The amount and type of data and
records will vary from facility to facility. Examples of records that you should keep, if applicable,
include the following:
Each Form R or Form A submitted;
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);
Engineering calculations and other notes;
Purchase records and MSDSs from suppliers;
Inventory and receipt data;
Analytical results and profiles for wastes received from off site;
NPDES/SPDES permits and monitoring reports;
EPCRA Section 312, Tier H reports;
Monitoring records;
Air permits;
Flow measurement data;
RCRA hazardous waste generator's reports;
Pretreatment reports filed with local governments;
Invoices from waste management firms;
Manufacturer's estimates of treatment efficiencies;
CERCLA Reportable Quantity (RQ) reports;
EPCRA Section 304 follow-up release notifications;
RCRA manifests; and
Process flow diagrams (including emissions, releases and other waste management
activities).
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Chapter 3 - EPCRA Section 313 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 at your facility.
Step 1) Determine if you manufacture (including import), process, or otherwise use any
EPCRA Section 313 chemicals.
Step 2) Determine the quantity of each EPCRA Section 313 chemical you manufacture
(including import), process, or otherwise use.
Step 3) Determine which EPCRA Section 313 chemicals exceed a threshold.
3.1 Step 1: Determining which EPCRA Section 313 chemicals are manufactured (including
imported), processed, or otherwise used
Compiling Chemical Lists. Compile lists of all chemicals, mixtures, other trade name
products, and wastes at your facility. Coal mining facilities may find it helpful to generate a list of
chemicals otherwise used at the facility, including purchased chemicals and chemicals received from off-
site for waste management (e.g., chemicals in ash from electricity generating facilities). For those coal
mines which combust coal or other fuels for thermal drying operations, preparing a list of chemicals
manufactured during combustion will be useful. When developing the list of chemicals manufactured,
refer to information your facility may have or have access to regarding specific chemical constituents
and their concentrations, in combination with information found later in this chapter. For the otherwise
use list, identify the name of each mixture or other trade name product or waste name or waste code
(e.g., chemicals in ash received from off-site for on-site disposal) and write the names of all chemicals
contained in each mixture or other trade name product or waste identified. Next, compare the
individual chemicals on both lists to the current EPCRA Section 313 chemicals list found in the TRI
Forms and Instructions (remember that chemicals may be periodically added and deleted and you
should always use the most current instructions which contain an updated list of chemicals). Flighlight
the EPCRA Section 313 chemicals that are on your list. You must perform threshold determinations
for these chemicals.
Review the list to be sure each chemical is shown by its correct EPCRA Section 313 name.
For example, a common EPCRA Section 313 chemical used at a coal mining facility for pH control is
ammonia. Ammonia (CAS No. 7664-41-7) has several synonyms, including ammonium amide and
spirit of Hartshorn. It must be reported on Form R (or Form A), Item 1.2, by its EPCRA Section 313
chemical name, ammonia. Synonyms can be found in the U.S. EPA document Common Synonyms
for Chemicals Listed Under Section 313 of the EPCRA (EPA 745-R-95-008) (updated March
1995). EPA's Automated TRI Reporting System (ATRS) has a pick list containing a complete list of
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EPCRA Section 313 chemicals and chemical category names and the corresponding CAS numbers
and category codes which helps to simplify this reporting element.
While every chemical and chemical category on the EPCRA Section 313 chemical list must be
considered, certain chemicals are more likely than others to be encountered at coal mining facilities,
while others may not. As a guide, chemicals that coal mining facilities may manufacture, such as during
combustion, process, and/or otherwise use are provided in Table 3-1. While this is not a
comprehensive list of all chemicals that may be manufactured, processed, or otherwise used at coal
mining facilities, it is a starting point to assist the facility in identifying chemicals for threshold
determinations.
Table 3-1
Common Chemicals Manufactured, Processed, and Otherwise Used at Coal
Mining Facilities
EPCRA Section 313 Chemicals that Coal
Mining Facilities May Manufacture During
Combustion for Thermal Drying
EPCRA Section 313 Chemicals that Coal
Mining Facilities May Process
Antimony compounds
Arsenic compounds
Barium compounds
Cadmium compounds
Chromium compounds
Copper compounds
Lead compounds
Manganese compounds
Nickel compounds
Selenium compounds
Silver compounds
Vanadium (fume or dust)
Zinc compounds
Mercury/Mercury compounds
(Above metal compounds also may be otherwise
used in ash received from off-site for
reclamation)
Hydrochloric acid (acid aerosols only)
Hydrogen fluoride
Formaldehyde
Ozone
Ethylene Glycol
EPCRA Section 313 chemicals in ash produced
on-site for use in gypsum manufacturing or sent
off-site for use in concrete manufacturing.
EPCRA Section 313 Chemicals that Coal
Mining Facilities May Otherwise Use
Ammonia
Benzene
Chlorine
Copper compounds
Ethylene glycol
Nickel compounds
Zinc compounds
(See also manufacturing list for chemicals that
may be otherwise used when ash is received
from off-site for reclamation)
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Use of Spreadsheets or Databases A computerized spreadsheet or database may be
helpful in developing your facility's chemical list and performing threshold calculations. The type of
information useful as input in a spreadsheet or database includes the chemical name, mixture or other
trade name product, or waste name with corresponding chemical component, concentrations, the CAS
number, and the yearly quantity manufactured, processed, or otherwise used. The spreadsheet or
database could also be designed to identify the total quantity by activity threshold (amounts
manufactured, processed, and otherwise used) for each EPCRA Section 313 chemical in every mixture
and other trade name product.
Smaller facilities that do not have an established electronic method of tracking their chemical
usage and waste managed, should consider developing a spreadsheet to assist them in their chemical
management activities. Developing a spreadsheet will require an initial investment of time; however, the
time and effort saved in threshold calculations in subsequent years can be significant. Such a system will
also reduce the potential of inadvertently overlooking EPCRA Section 313 chemicals that are present in
wastes received or mixtures purchased from off-site sources.
EPCRA Section 313 Chemicals in Purchased Chemicals
To develop the chemical list and identify the associated threshold activities for purchased
chemicals you may want to consult the following:
Material Safety Data Sheets (MSDS);
Facility purchasing records;
Inventory records;
Individual manufacturing/operating functions; and
Operation and process knowledge.
For purchased chemicals, MSDSs are generally considered to be good sources of information
for the type and composition of chemicals in mixtures and other trade name products. Coal mining
facilities may receive MSDSs for any mixture or other trade name product purchased for use as fuel,
equipment cleaning and maintenance, water treatment, froth flotation, or other operations. As of 1989,
chemical suppliers of facilities in SIC codes 2000 through 3999 are required to notify customers of any
EPCRA Section 313 chemicals present in mixtures or other trade name products that are 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. This letter must contain the chemical name, CAS number,
and the weight or volume percent of the chemical (or a range) in the mixture or other trade name
product. Beginning with the 1998 reporting year, seven new industries will be covered by most of the
EPCRA Section 313 reporting requirements and, therefore, facilities in SIC codes 2000 through 3999
will be required to provide these new industries with this supplier notification information. While the
new industries are not required to prepare supplier notifications for materials that they distribute, they
are encouraged to pass along the notification to customers receiving these materials who may be
subject to EPCRA Section 313. For more information on supplier notification requirements, see TRI
Forms and Instructions, EPCRA Section 313 Question and Answers, Revised 1998 Version -
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Appendix A, Directive 9 (EPA-745-B-98-004) or Supplier Notification Requirements., (EPA-
560/4-91-006).
Carefully review the entire MSDS for your purchased chemicals. Although MSDSs must list
whether EPCRA Section 313 chemicals are present, the language and location of this notification is not
currently standardized. Depending on the supplier, this information can be found in different sections of
the MSDS. The most likely sections of an MSDS to provide information on identity and concentration
of EPCRA Section 313 chemicals in purchased chemicals are:
Hazardous components section;
Regulatory section;
Physical properties/chemical composition section;
Labeling section; and
Additional information section.
Chemicals Manufactured During Combustion for Thermal Drying
Some coal mining facilities may conduct thermal drying of the coal product. This activity
typically involves the combustion of coal or other fuel types. This combustion operation may result in
the manufacture of several EPCRA Section 313 chemicals as byproducts. To identify the chemicals
manufactured, you should use the best "readily available data". This information could include analytical
data on fuels used and combustion equipment (e.g., stack emission testing, combustion tests), process
knowledge, other facility derived data, information from industry associations and EPA sources, and
information on chemicals releases or in wastes leaving the facility. This chapter will discuss many of the
metals and metal compounds, acids, and organics that may be manufactured during combustion.
EPCRA Section 313 Chemical List
In order to identify which chemicals are EPCRA Section 313 chemicals, and (in some cases)
the form in which they are reportable, you need to compare your list of chemicals managed at your
facility to the current Section 313 list of chemicals. Appendix B contains the list of EPCRA Section
313 chemicals (as of RY 1998), and correlates the list with various RCRA lists, such as the list of
hazardous constituents (40 CFR Part 261, Appendix Vm and the list of underlying hazardous
constituents from the Land Disposal Restriction program (40 CFR Section 268.48). The most current
list of EPCRA Section 313 chemicals can be found in the TRI Forms and Instructions document for
the current reporting year. The following discussion is a brief overview of the EPCRA Section 313 list
of chemicals, including a description of possible chemical qualifiers.
The original list of EPCRA Section 313 chemicals and chemical categories was comprised from
two lists developed by New Jersey and Maryland. EPA refined the list and anticipates changes to
continue. The list can be modified by an EPA initiative or though a petition process. When evaluating a
chemical for addition or deletion, EPA must consider potential acute and chronic human health effects
and adverse environmental effects and the Agency publishes its findings and any regulatory action
through the Federal Register.
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The EPCRA Section 313 chemical list includes individually listed chemicals and several
chemical categories. If you meet the SIC code criterion and exceed the employee threshold, you must
file a Form R or Form A for each EPCRA Section 313 chemical or chemical category manufactured,
processed, or otherwise used above threshold quantities. When conducting threshold determinations
for individually listed chemicals, simply compare the amount of that chemical manufactured, processed,
or otherwise used, to each threshold quantity. If you exceed the threshold, you must file a Form R or
Form A for that chemical. When determining thresholds for chemical categories, you must total the
weights of all members of the category, and compare this sum to each activity threshold. It is important
that you compare the amount of compounds in a category separately to each individual activity
threshold (manufacturing, processing, or otherwise use). If you exceed any of the three activity
thresholds for a chemical category, you must file a Form R or Form A for that chemical category.
Examples - Chemical Categories
Example 1 A facility otherwise uses 5,000 pounds of l,3-bis(methylisocyanate)-cyclohexane, 3,000
pounds of 1,5-naphthalene diisocyanate, and 3,000 pounds of 2,2,4-trimethylhexamethylene diisocyanate. All
three of these chemicals are members of the diisocyanates category, an EPCRA Section 313 chemical category.
The facility otherwise uses 11,000 pounds of diisocyanates, which exceeds the 10,000 pound threshold for
otherwise use. The facility must file a Form R or Form A for diisocyanates category.
Example 2 A facility otherwise uses 6,000 pounds of zinc oxide, manufactures 20,000 pounds of zinc
sulfate, and processes 18,000 pounds of zinc sulfide. All three compounds are members of the zinc compounds
category, an EPCRA Section 313 chemical category. Because the facility does not exceed the otherwise use,
manufacturing, or processing thresholds, the facility is not required to file a Form R or Form A for the zinc
compound category.
Many of the EPCRA Section 313 chemical categories are metal compound categories (e.g.,
chromium compounds). Metal compound categories include any unique chemical substance that
contains the metal as part of that chemical's infrastructure. When calculating thresholds for metal
compound categories, you must consider the entire weight of the metal compound, not just the weight
of the parent metal. However, if you exceed an activity threshold for a metal compound category and
you are filing a Form R for that metal compound category, you need only use the weight of the parent
metal when calculating quantities released or otherwise managed as waste. Elemental forms of metals
(e.g., chromium) are also individually listed on the EPCRA Section 313 chemical list. You must make
separate threshold determinations for the elemental metal and the metal compound category (e.g.,
chromium and chromium compounds). If you exceed thresholds for both the metal and metal
compound category, you may submit separate Form Rs, or one Form R for both the metal and metal
compound category. However, if both the metal and the metal compound qualify for Form A
reporting, you must submit separate Form A certifications for the metal and metal compound category.
Several chemicals on the EPCRA Section 313 chemical list include qualifiers related to use or
form. A few chemicals are reportable ONLY if manufactured by a specified process or in a specified
threshold activity. For example, isopropyl alcohol is only reportable if it is manufactured using the
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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 are
reportable, while black or red phosphorus are not.
Example - Lead and Lead Compounds
A facility has determined that it needs to report under EPCRA Section 313 for both elemental lead and lead
compounds. Can this facility file one Form R that takes into account both the releases and other waste
management activities of lead and lead compounds, or is it required to report separately?
If a covered facility exceeds thresholds for both the parent metal and compounds of that same metal, it is
allowed to file one joint report (e.g., one report for lead compounds and elemental lead). However, the report
filed will indicate amounts of the metal compound. EPA allows this because the release and other waste
management information reported in connection with metal compounds will be the total pounds of the parent
metal released and otherwise managed as a waste. For data management purposes, EPA requires that the
chemical category name and code be placed on the Form R (Sections 1.1 and 1.2).
The qualifiers associated with these chemicals which may be applicable to the coal mining
industries are presented below. A detailed discussion of the qualifier criteria can be found in the TRI
Forms and Instructions.
Fume or dust - Three metals (aluminum, vanadium, and zinc) are qualified as "fume or
dust forms only." This definition excludes "wet" forms such as solutions or slurries, but
includes powder, particulate, or gaseous forms of these metals. For example, on-site
disposal of a waste received from off-site containing elemental zinc metal needs to be
considered in threshold determinations if the zinc is in the form of a fume or dust.
However, if zinc (fume or dust) are found during treatment of a zinc-containing waste
stream, then these amounts would need to be considered toward the facility's
manufacturing threshold. Additionally, the entire weight of all zinc compounds should be
included in the threshold determination for zinc compounds. Keep in mind that most
metals in most wastes are expected to be in the compound form.
Ammonia has the following qualifier: "ammonia (includes anhydrous ammonia and
aqueous ammonia from water dissociable salts and other sources; 10% of total aqueous
ammonia is reportable under this listing)." Aqueous ammonia is formed from the
dissociation of ammonium salts (including ammonium sulfate, ammonium nitrate, and
ammonium chloride) in water and is an EPCRA Section 313 chemical. You must
determine the amount of aqueous ammonia generated from solubilizing these chemicals
in water and apply it toward the threshold for ammonia. EPA has published guidance
on reporting for ammonia, and ammonium salts in EPCRA Section 313 Question and
Answers, Revised 1998 Version -AppendixA, Directive 8. Additionally, ammonium
nitrate in aqueous solutions must be included in threshold determinations and release
3-6
-------
and other waste management calculations for the nitrate compounds category. (See
below)
Nitrate Compounds (water dissociable; reportable only in aqueous solution) -
A nitrate compound is covered by this listing only when in water and if dissociated.
Although the complete weight of the nitrate compound must be used for threshold
determinations for the nitrate compounds category, only the nitrate ion portion of the
compound must be considered for release and other waste management determinations.
Nitrate compounds are manufactured during the neutralization of nitric acid and in
biological treatment of wastewater. EPA has published guidance for these chemicals in
Water Dissociable Nitrate Compounds Category and Guidance for Reporting (see
Appendix A for more information).
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.
Asbestos (friable) - Asbestos only need be considered when it is handled in the
friable form. Friable refers to the physical characteristic of being able to crumble,
pulverize, or reduce to a powder with hand pressure.
Aluminum oxide (fibrous) - Beginning with reports for calendar year 1989, aluminum
oxide is only subject to threshold determination when it is handled in fibrous forms.
EPA has characterized fibrous aluminum oxide for purposes of EPCRA Section 313
reporting as a man-made fiber that is commonly used in high-temperature insulation
applications such as furnace linings, filtration, gaskets, joints, and seals.
Sulfuric acid (acid aerosols) and hydrochloric acid (acid aerosols) - EPA delisted
non-aerosol forms of sulfuric acid (CAS No. 7664-93-9) and hydrochloric acid (CAS
No. 7647-01-0) from the EPCRA Section 313 chemical list beginning in the 1994 and
1995 reporting years, respectively. Threshold determinations and release and other
waste management estimates now only apply to the aerosol forms. EPA considers the
term aerosol to cover any generation of airborne acid (including mists, vapors, gas, or
fog) without any particle size limitation. Sulfuric acid and hydrochloric acid (acid
aerosols) are manufactured during the combustion of sulfur containing wastes (for
sulfuric acid) and chlorine containing wastes (for hydrochloric acid). EPA has
published guidance for sulfuric acid in Guidance for Reporting Sulfuric Acid (acid
aerosols including mists, vapors, gas, fog, and other airborne forms of any
particle size) (see Appendix A for more information).
3-7
-------
3.2 Step 2: Determining the quantity of each EPCRA Section 313 chemical manufactured
(including imported), processed, or otherwise used
The next step is to determine the quantities manufactured (including imported), processed, and
otherwise used for each EPCRA Section 313 chemical on your list (developed in Step 1). Table 3-2
lists the annual reporting thresholds for each of these threshold activities (Table 3-3 provides detailed
definitions of subcategories for the manufacturing threshold activity).
Table 3-2
Reporting Thresholds
Activity
Manufacturing (including importing)
Processing
Otherwise used
Threshold
More than 25,000 pounds per EPCRA
Section 313 chemical
More than 25,000 pounds per EPCRA
Section 313 chemical
More than 10,000 pounds per EPCRA
Section 313 chemical
For each EPCRA Section 313 chemical or chemical category during the reporting year, each
threshold must be individually calculated; they are mutually exclusive and are not additive.
Example -Threshold Determination
If your facility manufacturers 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 activity 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 non-exempt releases and other waste management activities of that chemical must
be reported on the Form R, including those from the "otherwise use" activity. Additionally, you must also
indicate on the Form R in Part II, Section(s) 3.1, 3.2, and 3.3, all non-exempt activities involving the reportable
EPCRA Section 313 chemical.
Example -Threshold Determination
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 previously disposed, is the amount applied to the
threshold determination. For example, your coal mining facility disposes of nickel compounds received in ash
transferred from off-site in its on-site reclamation activities. The reclamation site contains hundreds of thousands
of pounds of nickel compounds. Over the course of the reporting year, you dispose of an additional 5,000
pounds of nickel compounds in wastes received from off-site. In this example, only the 5,000 pounds that were
disposed of in the current year count toward the "otherwise use" threshold. Therefore, unless you "otherwise
use" more than 5,000 pounds elsewhere at the facility, the "otherwise use" threshold has not been exceeded and
you would not have to report for nickel compounds.
3-8
-------
Each of the threshold activities is divided into subcategories. As discussed in the TRI Forms
and Instructions, you are required to designate EACH activity and subcategory that applies to your
facility not only those for which a threshold was exceeded.
Manufacturing
Manufacturing means producing, preparing, importing, or compounding an EPCRA Section
313 chemical. While coal mining facilities may not intend to manufacture EPCRA Section 313
chemicals during their operations, combustion of coal or other fuels will produce certain EPCRA
Section 313 chemicals that must be considered towards the manufacturing threshold. The facility will
need to consider if EPCRA Section 313 chemicals are produced coincidentally during combustion (or
any of your other operations), even if the chemical exists for only a short period of time, and later is
destroyed by air control equipment such as sulfuric acid aerosol.
The following discussion describes the various activities included under manufacturing (see
Table 3-3), and other manufacturing threshold issues that are relevant to coal mining facilities.
Table 3-3
Examples of Manufactured Chemicals
Manufacturing Activity
Subcategory
Examples
Produced or imported for on-site
use/processing
Importation of chemicals in mixtures used for such activities as
froth flotation.
Produced or imported for
sale/distribution
Importation of coal from coal mining facilities outside the
customs territory of the U.S.A. for sale or distribution.
Produced as a by-product
The coincidental manufacturing of EPCRA Section 313
chemicals from the combustion of coal, such as thermal drying.
Sulfuric acid aerosols formed during application of sulfuric acid
as a conditioner for fine-grade coal.
Produced as an impurity
May not occur in concentrations at or above de minimis
levels.
The coincidental manufacturing of metal compounds during the
addition of lime, sodium carbonate, or sodium
hydroxide/sulfuric acid (as conditioners) to coal.
*More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Coal Combustion By-Products from Thermal Drying. As a result of froth flotation and
other activities, some coal mines will combust coal to thermally dry coal fines prior to distribution into
commerce. Most commonly, the combustion of coal to operate these thermal dryers will result in the
manufacture of new metal compounds (usually as a result of oxidation), acid aerosols, formaldehyde,
and other organic compounds, or convert metal compounds to the parent metal. For example, current
3-9
-------
information estimates that mercury compounds found in coal convert to either divalent mercury or
elemental mercury during combustion. At this point, the percent conversion of either form of mercury is
unknown [Study of Hazardous Air Pollutant Emissions from Electricity Utility Steam Generating
Units -FinalReport to Congress, Volume 1, page 7-5, U.S. EPA, OAQPS (February 1998)
453/R-98-004a]. Therefore, while divalent mercury will readily combine to form a compound, EPA is
allowing facilities to use the lower weight elemental form of mercury when making their threshold
determinations.
Manufacture of Metals and Metal Compounds During Combustion. During
combustion, if a metal compound is converted to an elemental metal, or if one metal compound is
converted to another metal compound (even if it is within the same EPCRA Section 313 metal
compound category) then manufacturing has occurred, and the quantity of the EPCRA Section 313
metal or metal compound manufactured must be counted towards the 25,000 pound threshold. You
must apply the entire weight of a metal compound manufactured during combustion toward the 25,000
pound threshold, not just the weight of the parent metal. There may be cases in which a metal
compound is not changed at all during
combustion. For example, beryllium
oxide in coal may remain as beryllium
oxide during combustion. In this case,
a beryllium compound has not been
manufactured and no amounts of
beryllium compounds would need to
be considered toward the
manufacturing threshold.
How Do I Calculate Amounts of Metal Compounds
Manufactured During Combustion?
In the absence of better facility-specific data, use Tables 3-4
and 3-6 to calculate amounts of metal compounds manufactured
during coal combustion.
To use the tables, simply look under the column titled
"Approximate Tons of Coal Needed To Be Consumed to
Manufacture 25,000 Lbs. of the Metal Oxide. " For each metal
compound, compare this value to the amount of fuel combusted
at your facility during the reporting year. If the amount
combusted exceeds the value in the table, you have exceeded
the threshold for that metal compound, and you must prepare a
Form R or Form A for that metal compound category. For
example, if you combust more than 1,800 tons of coal during the
reporting year, you must prepare a Form R or Form A for zinc
compounds.
To calculate the amount of
Section 313 metal compounds
manufactured during combustion,
facilities must first estimate the
concentration of each metal present in
the coal or other fuels used. These
metals are likely to exist as metal
compounds in the fuel. The best
"readily available data" should be used
to estimate the approximate concentration of the metal. If a facility has data regarding chemical
concentrations in the fuel used by the facility, and the facility believes that this is the best "readily
available data", then the facility should use this information. If specific concentration data of EPCRA
Section 313 chemicals in coal does not exist at your facility, there are several sources where the facility
can find this concentration data. Examples include nationally assembled data such as the U.S.
Geological Survey's (USGS) coal quality database
(http://energy.er.usgs.gov/products/databases/CoalQual/) or Electrical Power Research Institute's
(EPRI) PISCES database on coal constituents.
5-10
-------
As an alternative, if no other information is available, facilities can assume that most of these
metal compounds convert to the lowest weight oxide possible. You may use the default values for
metal and metal compound concentrations in coal provided in Table 3-4 or Table 3-6. When you have
determined the concentration of metals and metal compounds in the fuel used, you must then determine
the quantity of metals and metal compounds manufactured during combustion. In determining how
much of a metal or metal compound the facility may actually manufacture during combustion, the facility
may assume that most metal compounds convert to the lowest weight oxide. This information is also
provided in Tables 3-4 and 3-6. These tables list concentrations of EPCRA Section 313 metals
typically found in different types of coal, the associated pounds of metal oxide manufactured per ton of
coal combusted, and as a quick reference, the estimated tons of coal needed to be consumed to
manufacture 25,000 pounds of the corresponding metal oxide for each coal type [Table 3-4 was
derived from data in Appendix D of the Study of Hazardous Air Pollutants Emissions from Utility
Steam Generating Units, U.S. EPA, OAQPS (February 1998) 453/R-98-004a]. To support the
facility's threshold calculations, the facility should document the type of coal it uses.
While most coal mining facilities that conduct thermal drying will use their own coal product for
fuel, some facilities may use other fuel types, such as fuel oil. For information on metal and metal
compounds that may be produced from the combustion of other fuel sources, refer to Compilation of
Air Pollutant Emission Factors (AP-42) or to EPA's EPCRA Section 313 Guidance for
Electricity Generating Facilities.
5-11
-------
Table 3-4
Concentrations of EPCRA Section 313 Metals and their Compounds in Coal and Pounds of
Metal Oxide Manufactured per Ton of Coal Combusted, by State and Coal Rank
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Alaska (Subbituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beiyllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.9
3
0.5
0.15
20
5
53.93b
95b
5.4
88
0.07
10
1.6
4.6E-03
7.92E-03
2.78E-03
3.42E-04
5.24E-02
1.27E-02
NA
NA
1.17E-02
2.27E-01
1.46E-04
2.56E-02
4.51E-03
5.48
3.16
8.99
73.10
0.48
1.97
NA
NA
2.14
0.11
171
0.98
5.54
Alabama (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
1.82
53
1.88
0.06
22.8
8.2
380b
127b
7
41
0.19
17.5
4.37E-03
1.40E-01
1.05E-02
1.37E-04
5.97E-02
2.08E-02
NA
NA
1.51E-02
1.06E-01
3.95E-04
4.48E-02
5.72
0.18
2.39
182.75
0.42
1.20
NA
NA
1.65
0.24
63.26
0.56
5-12
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Selenium/SeO2
Metal Concentration in
Coal in Units of
Micrograms/Gram
1.88
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
5.30E-03
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
4.72
Arkansas (Lignite)
Antimony /Sb 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO2
1.17
4.3
2.4
0.29
16.9
6
142b
63b
9.8
119
0.25
11.8
5
2.80E-03
1.12E-02
1.33E-02
6.61E-04
4.43E-02
1.52E-02
NA
NA
2.12E-02
3.07E-01
5.20E-04
3.02E-02
1.41E-02
8.90
2.20
1.87
37.81
0.56
1.64
NA
NA
1.18
0.08
48.08
0.83
1.77
Arkansas (Subbituminous)
Antimony /Sb 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO,
0.47
2.1
1.1
0.1
4.6
2.1
200b
79b
9
27
0.07
4.8
1.5
1.13E-03
5.55E-03
6.12E-03
2.28E-04
1.21E-02
5.33E-03
NA
NA
1.94E-02
6.97E-02
1.46E-04
1.23E-02
4.23E-03
22.22
4.5
4.09
109.65
2.07
4.69
NA
NA
1.29
0.36
172
2.03
5.91
> 10
5-1J
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Colorado (Bituminous)
Antimony /Sb 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO2
0.91
1.34
0.36
0.18
1.89
10.3
92.97b
98.78b
5.44
10.83
0.07
1.25
0.87
2.18E-03
3.54E-03
2.00E-03
4.10E-04
4.95E-03
2.62E-02
NA
NA
1.18E-02
2.79E-02
1.46E-04
3.20E-03
2.45E-03
11.5
7.07
12.49
60.92
5.05
0.96
NA
NA
2.13
0.89
172
7.81
10.19
Iowa (Bituminous)
Antimony /Sb 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO2
0.35
1.03
0.84
0.08
4.1
1.6
118b
99b
3.5
32
0.14
7.9
0.89
8.35E-04
2.72E-03
4.67E-03
1.82E-04
1.07E-02
4.06E-03
NA
NA
7.56E-03
8.26E-02
2.91E-04
2.02E-02
2.51E-03
30
9.2
5.35
137.06
2.33
6.15
NA
NA
3.31
0.30
86
1.24
9.96
5-14
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Illinois (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.82
6.78
1.31
0.98
12.66
3.19
1136.07b
84.14b
24.51
33.74
0.08
12.74
1.72
1.96E-03
1.79E-02
7.28E-03
2.23E-03
3.32E-02
8.10E-03
NA
NA
5.29E-02
8.70E-02
1.66E-04
3.26E-02
4.85E-03
12.76
1.4
3.43
11.19
0.75
3.09
NA
NA
0.47
0.29
150
0.77
5.15
Indiana (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.4
10.1
2.82
0.49
15.4
5.2
1032.79b
65b
10.9
38
0.11
17.9
2.17
3.35E-03
2.67E-02
1.57E-02
1.12E-03
4.03E-02
1.32E-02
NA
NA
2.35E-02
9.80E-02
2.29E-04
4.58E-02
6.12E-03
7.47
0.84
1.59
22.38
0.62
1.89
NA
NA
1.06
0.25
109
0.55
4.09
5-15
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Kansas (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.85
25
1.47
10
10.1
15
2500b
64b
111
160
0.19
41
2.7
2.03E-03
6.6E-02
8.17E-03
2.28E-02
2.65E-02
3.81E-02
NA
NA
2.40E-01
4.13E-01
3.95E-04
1.05E-01
7.61E-03
12.3
0.38
3.06
1.10
0.94
0.66
NA
NA
0.10
0.06
63.3
0.24
3.28
Kentucky (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.13
19.1
3.17
0.16
16.3
6.6
1139
86
10.6
32
0.15
17.5
3.83
2.7E-03
5.05E-02
1.76E-02
3.65E-04
4.27E-02
1.68E-02
NA
NA
2.29E-02
8.26E-02
3.12E-04
4.48E-02
1.08E-02
9.26
0.50
1.42
68.53
0.59
1.49
NA
NA
1.09
0.30
80
0.56
2.31
5-16
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Louisiana (Lignite)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.82
3.7
1.9
0.15
11.4
3.3
115b
83b
5.5
141
0.19
7.8
6
1.96E-03
9.75E-03
1.06E-02
3.42E-04
2.99E-02
8.38E-03
NA
NA
1.19E-02
3.64E-01
3.95E-04
2.00E-02
1.69E-02
12.76
2.56
2.37
73.10
0.84
2.98
NA
NA
2.10
0.07
63.25
1.25
1.48
Maryland (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.81
26
2.01
0.14
26.7
11
914b
107b
10
13
0.42
22
3.8
1.95E-03
6.85E-02
1.12E-02
3.19E-04
7.00E-02
2.79E-02
NA
NA
2.16E-02
3.35E-02
8.74E-04
5.63E-02
1.07E-02
12.92
0.36
2.24
78.32
0.36
0.89
NA
NA
1.16
0.75
28.62
0.44
2.33
5-17
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Missouri (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.6
10
2.01
0.8
12.2
6.7
1701. 64b
60b
67
99
0.17
23
4.2
3.83E-03
2.64E-02
1.12E-02
1.82E-03
3.20E-02
1.70E-02
NA
NA
1.45E-01
2.55E-01
3.54E-04
5.89E-02
1.18E-02
6.54
0.94
2.24
13.71
0.78
1.47
NA
NA
0.17
0.10
70.07
0.42
2.11
Montana (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.69
7
0.52
0.08
3.1
1.5
80b
104b
3
37
0.09
3.9
0.7
1.65E-03
1.85E-02
2.89E-03
1.82E-04
8.12E-03
3.81E-03
NA
NA
6.48E-03
9.55E-02
1.87E-04
9.98E-03
1.97E-03
15.15
1.36
8.65
137.06
3.08
6.56
NA
NA
3.86
0.26
133.55
2.50
12.66
5-18
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Montana (Lignite)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.92
18
1.04
0.11
0.94
0.8
67b
159b
4.8
68
0.12
4
0.72
2.20E-03
4.75E-02
5.78E-03
2.51E-04
2.46E-03
2.03E-03
NA
NA
1.04E-02
1.75E-01
2.50E-04
1.02E-02
2.03E-03
11.36
0.52
4.32
99.68
10.15
12.30
NA
NA
2.41
0.14
100.2
2.44
12.31
Montana (Subbituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.69
7
0.52
0.08
3.1
1.5
80b
104b
3
37
0.09
3.9
0.7
1.65E-03
1.85E-02
2.89E-03
1.82E-04
8.12E-03
3.81E-03
NA
NA
6.48E-03
9.55E-02
1.87E-04
9.98E-03
1.97E-03
15.16
1.36
8.65
137.06
3.08
6.56
NA
NA
3.86
0.26
133.55
2.50
12.66
5-19
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
North Dakota (Lignite)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.58
8.4
0.82
0.11
7
2.7
110b
34b
3.73
86
0.13
4.1
0.79
1.39E-03
2.22E-02
4.56E-03
2.51E-04
1.83E-02
6.86E-03
NA
NA
8.06E-03
2.22E-01
2.70E-04
1.05E-02
2.23E-03
18.04
1.12
5.48
99.68
1.36
3.65
NA
NA
3.10
0.11
92.46
2.38
11.22
New Mexico (Subbituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.07
1.8
2.7
0.16
6
2.65
95b
87b
31
45
0.06
4.6
1.94
2.56E-03
4.75E-03
1.50E-02
3.65E-04
1.57E-02
6.73E-03
NA
NA
6.70E-02
1.16E-01
6.5E-05
1.18E-02
5.47E-03
9.78
5.26
1.67
68.53
1.59
3.71
NA
NA
0.37
0.22
384.62
2.12
4.57
5-20
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Ohio (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.81
23.2
2.39
0.12
14.3
0.9
719b
92b
7.3
28.3
0.22
14.9
3.8
1.94E-03
6.1E-02
1.33E-02
2.74E-04
3.75E-02
2.29E-03
NA
NA
1.58E-02
7.30E-02
4.58E-04
3.81E-02
1.07E-02
12.92
0.40
1.88
91.37
0.67
10.94
NA
NA
1.59
0.34
54.63
0.66
2.33
Oklahoma (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.69
24
0.86
0.1
15
6.2
267b
77b
10
74
0.17
17
1.8
1.65E-03
6.35E-02
4.78E-03
2.28E-04
3.93E-02
1.57E-02
NA
NA
2.16E-02
1.91E-01
1.84E-04
4.35E-02
5.08E-03
15.16
0.40
5.23
109.65
0.64
1.59
NA
NA
1.16
0.13
136.16
0.57
4.93
5-21
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Pennsylvania (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
1.23
32.1
2.45
0.1
20.1
7.9
1096b
78b
10.8
23.5
0.29
20.4
3.55
2.94E-03
8.45E-02
1.36E-02
2.28E-04
5.27E-02
2.01E-02
NA
NA
2.33E-02
6.06E-02
6.03E-04
5.22E-02
l.OOE-02
8.50
0.30
1.84
109.65
0.47
1.25
NA
NA
1.07
0.41
41.43
0.48
2.50
Texas (Lignite)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.82
3.7
1.9
0.15
11.4
3.3
115b
83b
5.5
141
0.19
7.8
6
1.96E-03
9.75E-03
1.06E-02
3.42E-04
2.99E-02
8.38E-03
NA
NA
1.19E-02
3.64E-01
3.95E-04
2.00E-02
1.69E-02
12.76
2.56
2.37
73.10
0.84
2.98
NA
NA
2.10
0.07
63.26
1.25
1.48
5-22
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Utah (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.23
0.89
0.61
0.08
7.7
2.7
219.67b
57b
3.9
8
0.04
4.1
2
5.50E-04
2.35E-03
3.39E-03
1.82E-04
2.02E-02
6.86E-03
NA
NA
8.42E-03
2.06E-02
8.32E-05
1.05E-02
5.64E-03
45.50
10.64
7.37
137.06
1.24
3.65
NA
NA
2.97
1.21
300.48
2.38
4.43
Vermont (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.93
11
1.66
0.05
12.5
6.3
930b
74b
5.8
19
0.14
11.2
2.7
2.23E-03
2.91E-02
9.23E-03
1.14E-04
3.28E-02
1.60E-02
NA
NA
1.25E-02
4.90E-02
2.91E-04
2.87E-02
7.61E-03
11.24
0.86
2.71
219.30
0.76
1.56
NA
NA
2.00
0.51
85.91
0.87
3.28
3-1
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Washington (Subbituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.3
1.5
1.1
0.11
0.7
4.7
103.28b
14b
2.8
41
0.06
7.9
0.4
7.15E-03
3.96E-03
6.12E-03
2.51E-04
1.83E-03
1.19E-02
NA
NA
6.05E-03
1.06E-01
1.25E-04
2.02E-02
1.13E-03
34.86
6.32
4.09
99.68
13.63
2.09
NA
NA
4.13
0.24
200.32
1.24
22.16
West Virginia (Bituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeO,
0.93
10.6
2.78
0.1
15.3
7.2
1216b
58b
7.2
19.1
0.16
14.2
3.97
2.23E-03
2.8E-02
1.55E-02
2.28E-04
4.01E-02
1.83E-02
NA
NA
1.56E-02
4.93E-02
3.33E-04
3.64E-02
1.12E-02
11.24
0.90
1.62
109.65
0.62
1.37
NA
NA
1.61
0.51
75.12
0.69
2.23
5-24
-------
Section 313 Metal/ Lowest
Weight Metal Oxide3 That
May Be Manufactured
from the Metal
Metal Concentration in
Coal in Units of
Micrograms/Gram
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
Approximate Million Tons
of Coal Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
Wyoming (Subbituminous)
Antimony /Sb , O,
Arsenic/As,O,
Beryllmm/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl,O
Fluorine/F,O
Lead/PbO
Manganese/MnO
Mercury /Hg,O
Nickel/NiO
Selenium/SeQ,
0.73
0.69
0.18
0.13
2.82
0.87
118.3b
43.7b
2.07
5.65
0.08
2.17
0.51
1.75E-03
1.82E-03
l.OOE-03
2.96E-04
7.39E-03
2.21E-03
NA
NA
4.47E-03
1.46E-02
1.66E-04
5.56E-03
1.44E-03
14.32
13.72
24.98
84.35
3.38
11.31
NA
NA
5.59
1.72
150.24
4.50
17.38
a. As discussed above, mercury compounds in coal may not convert to the lowest weight oxide, but may reduce to
elemental mercury. At this time, EPA does not require facilities to make threshold determinations based on the
weight of mercury compounds, but instead allows facilities to use the lower weight of elemental mercury.
b. These elements are not metals and subsequently do not produce metal oxides. They will produce hydrochloric
acid (acid aerosols) and hydrofluoric acid, respectively. This is addressed elsewhere in the document.
A significant percentage of bituminous coal from most Eastern and Midwestern locations
undergo a "cleaning process" to meet customer specifications for heat, ash, and sulfur content. Based
on findings in EPA's OAQPS study [Study of Hazardous Air Pollutant Emissions from Electricity
Utility Steam Generating Units FinalReport to Congress (February 1998) 453/R-98-004a], this
cleaning process can affect the concentrations of some of the constituents in coal. In order to account
for this, Table 3-5 has been included to provide "cleaning factors" to be used to adjust for this coal type
taken from these locations that are subjected to a cleaning process. An example of how these cleaning
factors may be used is provided immediately after Table 3-5. Note, based on the analysis used to
develop information in Tables 3-4 and 3-5, it was identified that bituminous coal from Illinois and
Colorado was not subject to cleaning processes; therefore, the factors in Table 3-5 should not be used
for bituminous coal from these two states.
5-25
-------
Table 3-5
Coal Cleaning Factors for Bituminous Coals
Constituent
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Chlorine
Fluorine
Lead
Manganese
Mercury
Nickel
Selenium
Cleaning Factor
0.715
0.554
0.711
0.624
0.512
0.537
0.496
0.496
0.449
0.382
0.790
0.568
0.745
ExampleUse of Coal Cleaning Factor
A coal mining facility burns bituminous coal from Alabama and Kentucky. The facility
estimates that it has exceeded the manufacturing threshold for elemental mercury. Based on
information obtained by the facility from the USGS Coal Quality Database, along with
information provided in Tables 3-3 and 3-4 in this document, the facility estimates that it
manufactured approximately 32,000 pounds of elemental mercury from coal combustion.
Based on the knowledge that the coal combusted had been cleaned prior to combustion, the
facility recalculated the amount elemental mercury manufactured to be:
32,000 Ibs Hg x 0.790 (Coal Cleaning Factor for Hg) = 25,280 Ibs Hg manufactured.
Information on a few metals and metal compounds believed to be present in coal, and included
in EPA's previous versions of the Coal Mining and Electricity Generating Facilities guidance
documents, was not provided for coal types analyzed in the Study of Hazardous Air Pollutant
5-26
-------
Emissions from Electric Utility Steam Generating Units. Facilities should consider the specific
information they have for the coal they use to determine whether or not these chemicals are present and
at what concentrations. If the facility does not have additional information, they should consider
information on those metals and metal compounds provided in Table 3-6 for purposes of threshold and
release and other waste management calculations. As discussed above, there are several sources of
information, such as the U.S. Geological Survey's Coal Quality database or EPRI's PISCES database,
that provide amounts of constituents in coal types from various locations that may represent better
information than that provided in Table 3-6. However, facilities are instructed to use their best "readily
available data" when developing these estimates, and if the facility does not have better information,
then Table 3-6 should be considered.
Table 3-6
Concentrations of Additional EPCRA Section 313 Metals and their
Compounds in Coal and Pounds of Metal Oxide Manufactured per Ton of
Coal Combusted
EPCRA Section 313 Metal Constituents of Coal and the Estimates of the
Corresponding Metal Oxide for Metals Not Present in Table 3-4
EPCRA Section
313 Metal/ Lowest
Weight Metal
Oxide That May
Be Manufactured
from the Metal
Zinc/ZnO
Barium/BaO
Copper/Cu2O
Silver/Ag2O
Metal
Concentration
in Coal in Units
of Micrograms/
Gram
5,600
250
185
0.08
Oxide
Factor
1.24
1.12
1.125
1.07
Pounds of
Metal Oxide
Manufactured
per Ton of
Coal
Combusted
13.88
0.56
0.42
1.7E-04
Tons of Coal
Needed To Be
Consumed to
Manufacture
25,000 Lbs. of
the Metal Oxide
1,800
44,643
60,060
1.46E08
Note: The table consists of the lowest weight oxide per metal possible for the particular metal. The metal
concentration for amounts in coal were adapted from Economic Analysis of the Final Rule to Add Certain Industry
Groups to EPCRA Section 313, Appendix D, Table D-2, based on high end concentration values and Appendix E,
Table E-3. Quantities are given in short tons, where 1 short ton = 2,000 Ibs.
One exception to the assumption that metal compounds in fuel convert to lowest weight metal
oxides during combustion is mercury. Mercury likely exists as a compound in coal. Unlike other metal
compounds in coal, mercury is not likely to convert to an oxide, but instead may convert to elemental
mercury and be released in a gaseous state. In this case, elemental mercury is considered manufactured
for threshold purposes. Unless facilities have information to indicate otherwise, they should assume
that they manufacture elemental mercury during combustion, and apply the weight of the metal, rather
5-27
-------
than the metal oxide, toward the manufacturing threshold for mercury. If the facility does not have
information on the concentration of mercury compounds in coal used, there are several sources of
information to obtain this as previously discussed. Otherwise, EPA has provided default values in
Table 3-4. Unless you have information indicating otherwise, assume that 100% of the mercury portion
of the mercury compounds in the coal converts to elemental mercury.
Manufacture of Acid Aerosols During Combustion . During combustion of fuel, facilities
may manufacture hydrochloric acid (HC1) aerosols, hydrogen fluoride (HF), and sulfuric acid aerosols.
If aerosol forms of hydrochloric or sulfuric acid are produced, then amounts produced must be applied
toward the manufacturing threshold for these EPCRA Section 313 chemicals. To estimate quantities of
acid aerosols manufactured during combustion, facilities can use monitoring data, equipment
specifications, air permits, and industry literature. In the absence of better data, facilities can use the
HC1 and HF emission factors presented in Table 3-7. Use the emission factor that corresponds to the
type of coal being combusted. If your facility combusts a mixture of coal types, and knows the mixture
ratio, you may apply this ratio to the emission factors in Table 3-7. Facilities that do not know the type
of coal they use should assume the coal is bituminous or subbituminous, since these types are most
commonly used. The factors in Table 3-7 are considered more appropriate than AP-42 factors when
the coal type is known. Emission Factors in AP-42 are averages for various types of coal.
Example - Manufacture of Sulfuric Acid (Acid Aerosols^
A coal mining facility combusts coal for thermal drying of coal fines. As a result of the combustion operation, th
facility emits sulfur dioxide (SO2), sulfur trioxide (SO3), and particulate sulfates through a point source. Once
emitted, the sulfur trioxide readily reacts with water vapor (both in air and in flue gases that have exited the
stack) to form a sulfuric acid aerosol mist. For purposes of EPCRA Section 313, must the facility report on the
manufacture of sulfuric acid?
No. The sulfuric acid aerosol formed in the chemical reaction of sulfur trioxide and water that often occurs in the
air after releasing sulfur trioxide is not included in threshold determinations. The facility owner/operator is not
responsible for tracking or reporting on the formation of an EPCRA Section 313 chemical once a chemical is
released from a facility. However, if the reaction of sulfur trioxide and water takes place prior to being emitted
(e.g., in the stack), the facility would be required to factor the quantity of sulfuric acid aerosol mist generated
towards the manufacture threshold. If the threshold is exceeded, the facility owner/operator must report all
releases and other waste management estimates of sulfuric acid aerosols from the facility.
For guidance on calculating the amount of sulfuric acid manufactured during
combustion, refer to: Emergency Planning and Community Right-to-Know ActSection 313:
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size)., EPA, March 1998, available on EPA's website at
http://www.epa.gov/tri.
5-28
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Table 3-7
Emission Factors For HC1 and HF Manufactured During Combustion of
Coal
Coal Type
Anthracite Coal (pulverized coal and traveling grate
stokers)
Bituminous Coal (pulverized coal: wet and dry bottom,
cyclone, spreader stoker, traveling grate (overfeed)
stoker, pulverized coal: dry bottom (tangential firing,
atmospheric fluidized bed))
Subbituminous coal (pulverized coal: wet and dry
bottom cyclone, spreader stoker, traveling grate
(overfeed) stoker, pulverized coal: dry bottom
(tangential firing)),
Lignite (pulverized coal, pulverized coal: tangential
firing, cyclone, traveling grate (overfeed) stoker,
spreader stoker)
Emission factor3
HF
0.18
0.23
0.23
0.01
HC1
0.91
1.9
1.9
0.01
Source: Hydrogen Chloride and Hydrogen Fluoride Emission Factors for the NAPAP Emission Inventory, U.S.
EPA, Office of Research and Development, 1985.
a. Pound per ton of coal.
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Calculating Thresholds for Hydrochloric (Acid Aerosols) Acid and Selenium
A facility in Alaska combusts 1 million tons of subbituminous coal in the reporting year. What quantity of
selenium compounds and HC1 (acid aerosol) are manufactured?
Hydrochloric Acid (Acid Aerosols):
The HCl emission factor for subbituminous coal is 1.9 Ib/ton coal (see Table 3-7).
1.9 Ib HCl/ton coal x 1,000,000 tons coal = 1,900,000pounds HCl (acid aerosols)
Therefore, 1.9 million pounds of HCl (acid aerosols) are manufactured and the 25,000 pound threshold has
been exceeded. Form R reporting for HCl (acid aerosols) is required.
Selenium Compounds:
Based on the concentration estimates of selenium in Table 3-4, the emission factor for selenium oxide (SeO^ is
1.44x1 a3 Ib SeOj/ton coal.
1.44x1 a3 Ib SeO/ton coal x 1,000,000 tons of coal = 1,440 pounds ofSeO2 emitted.
Therefore, 1,440 pounds of selenium compounds are manufactured and the 25,000 pound threshold was not
exceeded. Form R reporting for selenium compounds is not required.
Manufacture of Formaldehyde During Combustion. Table 3-8 lists emission factors of
formaldehyde produced during the combustion of coal, No. 6 fuel oil, No. 2 fuel oil, and natural gas.
Based on these emission factors, the amount of fuel consumed to manufacture more than 25,000
pounds of the EPCRA Section 313 chemical is also provided. In the absence of better information, the
emission factors in these tables can be used to calculate threshold determinations.
Table 3-8
Emission Factors and Triggering Thresholds For Formaldehyde
Manufactured During Combustion
Fuel Source
Coal
Natural Gas
No. 2 Fuel Oil
No. 6 Fuel Oil
Emission Factor
(units of measure)
2.4e-04 Ib/ton
1.55e-01 lb/M-ft3
61 lb/Mgala
33 Ib/Mgal
Combusted to Manufacture 25,000 Ibs.
of Formaldehyde
104Mtons
161,290M-ft3
410Mgal
758 Mgal
Source: AP-42, External Combustion Sources, Tablesl.4-4, 1.3-7, 1.3-8, and 1.1-13.
Note: M-ft3, Mgal andMtons indicate millions of cubic feet, millions of gallons, and millions of tons, respectively.
5-30
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a Emission factor is the upper range for No. 2 fuel oil combustion.
Fine Coal Conditioning
Some mines may perform fine coal conditioning using sulfuric acid solutions to adjust pH to
facilitate the flotation process. While the sulfuric acid is only reportable when in aerosol form, the use
of sulfuric acid solutions may produce the aerosol form of the acid, which must be applied to the
manufacturing threshold. For guidance on estimating the quantities for sulfuric acid aerosols produced,
refer to Emergency Planning and Community Right-to-Know ActSection 313: Guidance for
Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other airborne
forms of any particle size) mentioned earlier in this chapter.
Coal Pile Runoff
When stored in exposed piles, coal may be exposed to rainwater, snowfall, spraying for dust
control, or underground streams, which may create an acidic leachate. Manufacture of metal
compounds may result from the dissolution of metal compounds in a coal pile into stormwater runoff.
The acidity of the leachate may increase the solubility of some metal compounds, thereby dissociating
these compounds, removing them from the coal pile, and carrying them off in the runoff. Depending on
various factors (pH, coal composition, temperature, and length of exposure), these compounds may or
may not form new metal compounds in the runoff. For example, the facility may know that the copper
present in the coal is in the form of copper oxide. During dissolution, copper oxide in runoff may be
converted to copper hydroxide. Facilities must use the best "readily available data" to determine
whether a new metal compound is created during reactions that take place in the coal pile or runoff.
This may include monitoring data or discharge monitoring reports (DMRs). The quantity of metal
compound created must be applied towards the 25,000 pound manufacturing threshold.
In absence of better information, facilities should assume that the quantity of metals in coal pile
run-off are not exempt (i.e., assume that a new metal compound has been manufactured). Typically,
most facilities may have data on the concentrations of metals present but not on whether the metals are
present as compounds and what conversions may or may not have taken place. The chemical formulas
and conversions for the lowest weight oxides of metals typically found in coal are listed in Table 3-4.
This quantity of lowest weight oxides could then be applied to calculating your manufacturing threshold
for metal compounds. For threshold determinations, facilities may assume that the EPCRA Section
313 metal compound that has been manufactured is the lowest weight oxide. EPA recognizes that
oxides are not formed in water, but is allowing facilities to make this assumption for simplicity and
consistency with the combustion assumptions. Note that if a facility has better "readily available data,"
they are required to use it.
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A mining facility stores coal or ore outside. One or more EPCRA Section 313 chemicals are contained witl
the storage piles. Due to exposure and weathering influences, other EPCRA Section 313 chemicals are
manufactured in the storage piles and may subsequently run-off onto land or surface water. How should the
facility consider the manufacturing of EPCRA Section 313 chemicals within a storage pile?
Amounts of Section 313 chemicals known to be "manufactured" on-site from the storage of raw materials,
mixtures, or other trade name products must be considered toward the "manufacturing" threshold for those
chemicals. The term "manufacture" means "to produce, prepare, import, or compound a toxic chemical." If
the mining facility has knowledge that an EPCRA Section 313 chemical is "manufactured" on-site, the
facility should count the amount of the EPCRA Section 313 chemical "manufactured" toward the
"manufacturing" threshold.
Importing. The "manufacture" threshold includes importing an EPCRA Section 313 chemical if
the facility has caused the chemical to be imported. If your facility orders or enters into an agreement
to obtain or accept an EPCRA Section 313 chemical (or a mixture or other trade name product or
waste containing an EPCRA Section 313 chemical) from a source outside the customs territory of the
United States (the 50 states, the District of Columbia, and Puerto Rico) then your facility has imported
a EPCRA Section 313 chemical and amounts must be considered toward the manufacturing threshold.
Note that if an entity other than the facility, such as a third party not directly associated with the facility
(e.g., a chemical broker), ordered the chemical without specific direction from the facility, then that third
party has "caused" the chemical to be imported, and the facility does not need to consider the EPCRA
Section 313 chemical toward their manufacturing threshold. Imported chemicals, as well as any others
that undergo a manufacturing activity, may also be subsequently processed and/or otherwise used, and
amounts associated with these activities need to be applied to all appropriate threshold determinations.
Processing
Processing means preparing an EPCRA Section 313 chemical, or a mixture or other trade
name product containing an EPCRA Section 313 chemical (usually the intentional incorporation of an
EPCRA Section 313 chemical into a product) for distribution in commerce. Perhaps the most pivotal
element of the processing definition is that the EPCRA Section 313 chemical must be prepared for
distribution into commerce. If a material is produced or recovered for use on-site, the material has
not been prepared for distribution into commerce, and thus is not counted towards the processing
threshold (see the discussion of otherwise use for the applicability of chemicals used on-site). In
addition, distribution into commerce does not only mean that the material must be sold to a customer.
Distribution in commerce includes any distributive activity in which benefit is gained by the transfer, even
if there is no direct monetary gain (e.g., intra-company transfers). The following table describes the
subsections of processing for reporting purposes.
Table 3-9
Examples of Processed Chemicals
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Processing Activity
As a reactant
As a formulation component
As an article component
Repackaging for distribution into
commerce
Examples
May not occur in the coal mining industry.
The addition of ethylene glycol to prevent freezing for
transportation to an off-site location.
Ash (from coal combustion, such as thermal drying) used
directly in the manufacture of gypsum.
Ash (from thermal drying) sent off-site for use in concrete
manufacturing.
Processing of Ore. A primary example of a processing activity likely to take place at coal
mining facilities is the preparation of coal for distribution into commerce. Extraction of ore containing
EPCRA Section 313 chemicals for subsequent distribution in commerce constitutes the "processing" of
those listed chemicals. Amounts of materials that undergo a "processing" step as part of the facility's
preparation of a material for distribution in commerce are considered "processed." For example, metal
compounds in the ore are considered process. These materials must be considered toward the facilities
"processing" threshold even if the original compound, such as a metal compound that converts to
another metal compound, no longer exists in its original form. This is because a portion of that original
compound is incorporated into the product being prepared for distribution in commerce. Therefore,
metal compounds in extracted ore are processed, even if they are later converted to different
compounds. Keep in mind, however, that metal compounds in coal are expected to be present below
de minimis levels and amounts of EPCRA Section 313 chemicals processed in concentrations below
the de minimis levels are exempt from threshold determinations and release and other waste
management calculations (see Chapter 3.2.2, Evaluation of Exemptions).
Example - Distribution into Commerce
If ore is extracted for ultimate distribution in commerce, are EPCRA Section 313 chemicals in ore that
are not actually distributed during the reporting year considered to be processed for threshold
determination purposes, since they were prepared for distribution during the reporting year?
Yes. The total amounts of the EPCRA Section 313 chemicals contained in the ore are considered toward
the facility's processing threshold in the year that the amounts undergo a processing step. For
purposes of EPCRA Section 313 threshold determination, extraction is considered a processing step
and all amounts extracted for preparation of a product to be distributed in commerce are considered
"processed" in the year they are extracted.
Anti-freezing Agents. Depending on regional weather conditions, antifreezing agents are used
to facilitate the movement of coal in cold climates. The application of EPCRA Section 313 chemicals,
such as ethylene glycol for the purposes of enhancing the product for the customer, is considered a
> o O
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processing activity and amounts must be applied to the processing threshold of 25,000 pounds.
Alternatively, ethylene glycol may be sprayed on coal to prevent freezing during storage. Use of a
chemical in this manner, to prevent freezing of coal on-site, must be applied to the otherwise use
threshold of 10,000 pounds.
Ash Management. Some coal mining facilities conduct thermal drying on-site that may create
ash. The distribution of ash into commerce for direct reuse in concrete or gypsum manufacturing is
considered a processing activity. Ash sent off-site for this type of activity, would be eligible for the de
minimis exemption when considering amounts toward the processing threshold. A facility may also
distribute ash off-site for recycling (e.g., vanadium recycling). Facilities that send ash off-site for
recycling must also count amounts of EPCRA Section 313 chemicals in the ash towards their
processing thresholds. However, amounts transferred off-site for this purpose would not be eligible for
the de minimis exemption because these amounts are being managed as a waste.
Transfers Off-site for Recycling. Amounts of EPCRA Section 313 chemicals sent off-site
for recycling also must be considered toward the processing threshold of 25,000 pounds. Amounts of
materials containing EPCRA Section 313 chemicals sent off-site for recycling are prepared for
distribution into commerce. Materials sent off-site for recycling must undergo a recovery step and are,
therefore, considered a waste and not eligible for the de minimis exemption. Wastes destined for off-
site recycling are considered wastes sent off-site for further waste management, which are not eligible
for the de minimis exemption and must be reported on the Form R in Sections 6 and 8.
Transferring a waste which contains an EPCRA Section 313 chemical off-site for energy
recovery is not considered processing, even if the waste has been blended with other wastes and
repackaged. For example, a facility should not count EPCRA Section 313 chemicals in high carbon
ash or spent solvents that are sent off-site for energy recovery toward their processing threshold.
However, if a threshold for EPCRA Section 313 chemicals contained in these materials has been
exceeded elsewhere at the facility, then these amounts would be reported as transferred off-site for
energy recovery.
Transfers Off-site for Direct Reuse. Amounts of EPCRA Section 313 chemicals sent off-
site for direct reuse must be considered toward the processing threshold of 25,000 pounds. Materials
are considered to be sent off-site for direct reuse if the materials are distributed into commerce and are
going to be directly used in an operation or application without any recovery steps including the
extraction of contaminants. Materials sent off-site for direct reuse are not reported on the Form R in
Sections 6 and 8 as recycled or released because the materials are not considered wastes. Because
materials sent off-site for direct reuse are not considered wastes, these materials may qualify for the de
minimis exemption if any EPCRA Section 313 chemical in the material is below the de minimis level
(see Chapter 3.2.2.3). EPCRA Section 313 chemicals in waste that are sent off-site for further waste
management (e.g., disposal) are not considered to be reused.
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Otherwise Use
"Otherwise use" is any use of an EPCRA Section 313 chemical that does not fall under the
definitions of "manufacture" or "process." Chemicals otherwise used are not incorporated into a
product that is distributed into commerce and includes such uses as a processing or manufacturing aid
and for such ancillary uses as treating wastes.
Otherwise use of an EPCRA Section 313 chemical also includes disposal, stabilization (without
subsequent distribution in commerce), and treatment for destruction if the:
(1) EPCRA Section 313 chemical that was disposed, stabilized, or treated for destruction
was received from off-site for the purposes of further waste management, or
(2) EPCRA Section 313 chemical that was disposed, stabilized, or treated for destruction
that was manufactured as a result of waste management activities of materials received
from off-site for the purpose of further waste management.
The following discussion describes the subsections of the otherwise use threshold for reporting
purposes (see Table 3-10).
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Table 3-10
Examples of Otherwise Used Chemicals
Otherwise Use Activity
Subcategory
Examples
As a chemical processing aid
May include conditioners, additives for froth flotation and
thickening/sedimentation, and flocculents for filtration drying
As a manufacturing aid
Ethylene glycol sprayed on coal to prevent freezing during
storage at the plant
Ancillary or other use
Ammonia used for pH control.
The use of EPCRA Section 313 chemicals in support activities
such as cleaning, maintenance, purification, or reclamation
(e.g., pesticides, fertilizers).
Ash containing EPCRA Section 313 chemicals used for mine
reclamation/road aggregate.
Ash containing EPCRA Section 313 chemicals received from
off-site for disposal.
* More complete discussions of the industry-specific examples can be found in Section 5 of this guidance document.
Combustion. All EPCRA Section 313 chemicals contained in fuels combusted are considered
otherwise used. For example, metal compounds contained in coal in addition to the high BTU organic
compounds are considered otherwise used. This type of chemical use is eligible for the de minimis
exemption and many of the EPCRA Section 313 chemicals contained in fuels commonly used exist in
below de minimis concentrations. Facilities do not have to apply chemicals present in coal and oil that
exist below de minimis levels towards the otherwise use activity threshold.
Unless a facility has other information, they may assume that chemicals in coal are below de
minimis levels. Other fuel types, however, may contain EPCRA Section 313 chemicals above de
minimis levels. In the absence of better facility-specific data, facilities may use this table to calculate
threshold quantities for EPCRA Section 313 chemicals otherwise used in fuels.
Froth Flotation. Some facilities produce a fine-grade coal which may require special cleaning
techniques. Froth flotation is a technique that may be used by these facilities for cleaning their fine-
grade coal. Flotation typically will be conducted using air, water, coal slurry, and flotation agents (e.g.,
collectors, activators, depressants, dispersants, or flocculents) specifically selected to recover the
desired fine coal. Collectors (promoters), may include fuel oil and kerosene. Table 3-11 shows the
EPCRA Section 313 chemical constituents typically present in collecting agents commonly used.
Depressants may also be used, but these are not likely to contain EPCRA Section 313 chemicals.
Froth activators function by reducing surface tension, thus allowing froth formation, however, these
products are also not likely to contain EPCRA Section 313 chemicals.
5-36
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Table 3-11
Estimated Concentration Values of EPCRA Section 313 Constituents in
Crude Oil and Petroleum Products (Weight Percent)
Section 313
Chemical
Benzene
Biphenyl
Bromine
Chlorine
Cyclohexane
Ethylbenzene
n-Hexane
MTBEb
Naphthalene
Phenanthrene
Phenol
PACs"
Styrene
Toluene
1, 2, 4-Trim ethyl-
benzene
Xylene
Antimony3
Arsenic3
Beryllium3
Cadmium3
Chromium3
Cobalt3
Copper3
Lead Compounds
Manganese3
De Minimis
Level*
0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0.1
0.1
1.0
1.0
1.0
0.1
0.1/1.0 '-
0.1/1.0 '
0.1/1.0 '-
0.1/1.0 d
1.0
1.0
1.0
(organic)
0.1 (inorg.)
1.0
Crude Oil
0.446 R
0.060 R
N/A
N/A
0.700
0.346 R
2.4631
N/A
0.219 E
N/A
0.323
0.0004
N/A
0.878E
0.326
1.420 R
l.OE-05
2.0E-05
2.0E-07
4.0E-07
4.0E-05
0.0003
4.0E-05
N/A
N/A
Gasoline
(Various
Grades)
1.608R
0.010 R
N/A
N/A
0.240
1.605E
1.0T
15.00
0.444 E
N/A
0.055
N/A
N/A@
7.212R
2.5Qt
7.170 E
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
No. 2 Fuel
Oil/ Diesel
Fuel
8.0E-04A
0.100
N/A
N/A
N/A
0.013 A
1.0 A
N/A
0.550
0.125
0.064
N/A
0.032 '
0.032 A
1.0 t
0.290A
N/A
8.5E-°6
5.0 E-°s
2.1 M5
9.5 E-°5
N/A
5.6E-04
N/A
2.1E-05
Jet Fuel
(JP-4)
1.0A
0.120E
N/A
N/A
1.240
0.50 A
1.5 T
N/A
0.468 R
N/A
N/A
N/A
N/A
3.20A
N/A
3.20 A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Kerosene
0.004 A
0.120 R
N/A
N/A
N/A
0.127 A
0.005 A
N/A
0.733 E
N/A
0.770
N/A
N/A
.13 T
N/A
0.31 A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Lubri-
cating
Oil
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
No. 6
Fuel
Oil
0.001
N/A
3.0E-06
0.0131"
N/A
0.0022
N/A
N/A
0.10
N/A
N/A
1.13
N/A
0.006
N/A
0.013
l.OE-06
3.06E-
05D
2.7E-
06D
2.0E-
06D
3.15-05
1.63E-
04D
3.0E-05
1.41E-
04D
3.55-05
Aviatio
n
Gasolin
e
0.515 E
N/A
N/A
N/A
N/A
0.432 E
0.126 R
N/A
0.10 E
N/A
N/A
N/A
N/A
7.327
N/A
2.204
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.14-
(organic)
N/A
5-37
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Section 313
Chemical
Mercury3
Nickel-
Selenium3
Silver-
Zinc Compounds
De Minimis
Level*
1.0
0.1
1.0
1.0
1.0
Crude Oil
0.0006
0.0055
4.0E-05
N/A
N/A
Gasoline
(Various
Grades)
N/A
N/A
N/A
N/A
N/A
No. 2 Fuel
Oil/ Diesel
Fuel
4.0E-05
3.38E-04
N/A
N/A
N/A
Jet Fuel
(JP-4)
N/A
N/A
N/A
N/A
N/A
Kerosene
N/A
N/A
N/A
N/A
N/A
Lubri-
cating
Oil
N/A
N/A
N/A
N/A
1.0
No. 6
Fuel
Oil
9.25-07
2.65-03
9.5^-06
2.0E-08
N/A
Aviatio
n
Gasolin
e
N/A
N/A
N/A
N/A
N/A
Unless otherwise noted, Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix B "Composition of
Crude Oil and Petroleum Products."
A American Petroleum Institute report prepared for Mr. Jim Durham, EPA (December 23, 1993), regarding revised estimates of heavy petroleum product
liquid constituents that are listed as hazardous air pollutants (HAPs) under section 112 of the Clean Air Act Amendments (CAAA).
R Radian Corporation report prepared for Mr. James Durham, EPA (August 10, 1993), regarding liquid HAP concentrations of various petroleum
products.
D Appendix D, Study of Hazardous Air Pollution Emissions from Electric Utility Steam Generating Units--Final Report to Congress, USEPA, OAQPS
(February 1998) 453/R-98-004b.
T These values have been revised to be consistent with the current version of EPA's emission estimation program TANKS 4.0.
* The de minimis concentration values for the metals is for the metal compound.
~ Lead compounds concentration for Aviation Gasoline 100 (Exxon-MSDS).
* Concentrations updated with comments received from API.
a Constituents are most likely metal compounds rather than the elements. Elements are listed in this table because concentration data are for only the
metals occurring in the fuel. Concentrations for metal compounds would be somewhat higher depending on the metal compound. For threshold
determination, if the weight of the compound is not known, facilities may use the weight of the lowest metal compound likely to be present.
@ Data from EPA report prepared by Radian Co. for this constituent are considered suspect and are not recommended for use, based on discussion with
Jim Durham of EPA on November 30, 1998.
b MTBE may be present to enhance octane in concentrations from 0-15% (industry practice, not sampling results).
c The de minimis level for inorganic compounds is 0.1; for organic compounds is 1.0.
d The de minimis level for chromium VI compounds is 0.1; for chromium III compounds is 1.0.
e The petroleum products may contain one or more of the following chemicals under the polycyclic aromatic compounds (PACs) category:
benz(a)anthracene, benzo (b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranthene, benzo(rst)pentaphene, benzo(a)phenanthrene, benzo(a)pyrene,
dibenz(a,h)acridine, dibenz(a,j)acridine, dibenzo(a,h)anthracene, 7H-Dibenzo(c,g)carbazole, dibenzo(a,e)fluoranthene, dibenzo(a,e)pyrene,
dibenzo(a,h)pyrene, dibenzo(a,l)pyrene, 7,12-dimethylbenz(a)anthracene, indeno[l,2,3-cd]pyrene, 5-methylchrysene, 1-nitropyrene. For No. 6 fuel oil, the
value given is for benzo(a)anthracene.
Reclamation Mines will often use a variety of substances during mine reclamation. Under
EPCRA Section 313, reclamation activities are considered distinct and separate from extraction
activities and any non-exempt use of EPCRA Section 313 chemicals during these activities must be
considered toward threshold and release and other waste management calculations. Section 313
chemicals contained in non-exempt materials which are used in mine reclamation are subject to the
otherwise use threshold of 10,000 pounds. Examples of such materials include coal ash, fertilizer, non-
exempt top soil, overburden, and waste rock. When mine reclamation activities occur simultaneously
with, or as a result of, coal extraction activities, which involve materials containing EPCRA Section 313
chemicals, these chemicals are considered eligible for the coal mining extraction exemption, and the
facility does not have to consider these amounts toward activity thresholds or release or other waste
management calculations. For example, mines may conduct cast blasting operations in which
overburden is displaced to gain access to a coal body. In this case, the overburden displaced to gain
access to an extraction site, while possibly aiding in the backfilling or reclamation of a completed area,
is considered covered by the coal extraction activities exemption and the amount of any EPCRA
Section 313 chemicals that may be present in the overburden is exempt from threshold determinations
5-38
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and release and other waste management calculations. Likewise, topsoil, overburden, and waste rock
recovered on-site that are otherwise displaced to gain access to a coal body, such as with the use of
drag lines and haul trucks, are also eligible for the coal extraction activities exemption. Also, amounts
of EPCRA Section 313 chemicals contained in these materials are exempt from threshold
determinations and release and other waste management calculations, including disposal back into the
area from which it came.
Ash generated on-site or received from off-site may be applied to the land as backfill for mine
reclamation or for pH control of the soil. Ash used in this manner is not considered analogous to a
substitute material with a commercial value. This application of ash to the land is considered a waste
management of the ash and therefore the EPCRA Section 313 chemicals contained in the ash are not
eligible for the de minimis exemption.
The application to land of mixtures and other trade name products, such as commercial
fertilizers, in mine reclamation activities is also considered an otherwise use activity and the EPCRA
Section 313 chemicals that may be present in these mixtures and other trade name products are eligible
for the de minimis exemption.
Example - Soil Reclamation
A mining facility receives waste sewage sludge from off-site for use in soil
reclamation. Is the application of sewage sludge to land considered an otherwise
use? Are the EPCRA Section 313 chemicals used in the soil reclamation activit
eligible for the de minimis exemption?
The mine is otherwise using the EPCRA Section 313 chemicals contained in the
waste sewage sludge as soil building material. However, because the EPCRA
Section 313 chemicals contained in the waste sludge are being managed as a
waste. The amounts of EPCRA Section 313 chemicals being otherwise used are
In any case, it is important to note that if an activity threshold is exceeded and EPCRA Section
313 reporting is required, you must considered all non-exempt applications to land of reportable
EPCRA Section 313 chemicals as releases to land (Section 5.5 of the Form R), including from mine
reclamation activities.
Other Activities. Otherwise use includes the use of EPCRA Section 313 chemicals in
activities such as cleaning, maintenance, and pH control. The use of an EPCRA Section 313 chemical
to treat another chemical constitutes an otherwise use.
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Example - Storage
A coal mine receives a flotation agent containing an EPCRA Section 313 chemical in December of 1998, b
does not use it until January of 1999. Is the amount of EPCRA Section 313 chemical in the flotation agent
considered for threshold determinations in the 1998 reporting year?
No. Storage in itself of an EPCRA Section 313 chemical is not considered a manufacturing, processing, or
otherwise use activity and, therefore, is not subject to threshold determinations. However, the facility is
required to include any amounts released or otherwise managed that occur during storage of the EPCRA
Section 313 chemical, provided a threshold has been exceeded elsewhere at the facility. When the EPCRA
Section 313 chemical is used in 1999, the facility will include the amount of EPCRA Section 313 chemical
used towards the 10,000 pound "otherwise use" threshold, or the 25,000 pound threshold for processing,
whichever is appropriate.
Other Examples of EPCRA Section 313 Chemicals that Coal Mining Facilities "Otherwise-Use"
High alloy metals used to replace worn parts in brakers or rollers (some of these uses
may be in parts that are eligible for the article exemption, see Chapter 3.2.2.3);
Ammonia used for pH control or water treatment;
Chemicals in fuel used in any on-site equipment (other than motor vehicles eligible for
the motor vehicle maintenance exemption), such as for belt lines (e.g., conveyors);
Chemicals in ash (or other wastes) that are received from off-site and disposed on-site;
Chemicals in ash used for pH control of soil during mine reclamation;
Chemicals used to clean boilers and other equipment;
Chemicals in materials that are used to maintain process equipment (e.g., lubricants,
solvents);
Chemicals used to treat boiler make-up water, or cooling tower water (e.g., chlorine,
chlorine dioxide, bromine); and
Chemicals used to treat wastes, such as coagulants, flocculents, or ammonia in
sedimentation ponds.
Waste Management Activities. For purposes of the otherwise use definition, EPA
interprets waste management activities to include recycling, combustion for energy recovery, treatment
for destruction, waste stabilization, and release, including disposal. However, for calculating thresholds,
the only quantity that should be applied to the otherwise use threshold are those that are treated for
destruction, stabilized, or disposed on-site. Waste management does not include the storage, container
transfer, or tank transfer of an EPCRA Section 313 chemical if no recycling, combustion for energy
recovery, treatment for destruction, waste stabilization, or release of the chemical occurs at the facility
(62 FR 23850; May 1, 1997).
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Table 3-12
EPA Guidance Related to Waste Management Activities
Waste Management
Activity
Description
Recycling
As referenced in the May 1, 1997, Federal Register and defined in the document,
Interpretations of Waste Management Activities: Recycling, Combustion for Energy
Recovery, Treatment for Destruction, Waste Stabilization, and Release (April 1997),
recycling means: (1) the recovery for reuse of an EPCRA Section 313 chemical from a
gaseous, aerosol, aqueous, liquid, or solid stream; or (2) the reuse or the recovery for use
of an EPCRA Section 313 chemical that is a RCRA hazardous waste as defined in 40 CFR
Part 261. Recovery is the act of extracting or removing the EPCRA Section 313 chemical
from a waste stream and includes: (1) the reclamation of the EPCRA Section 313 chemical
from a stream that entered a waste treatment or pollution control device or process where
destruction of the stream or destruction or removal of certain constituents of the stream
occurs (including air pollution control devices or processes, wastewater treatment or
control devices or processes, Federal or state permitted treatment or control devices or
processes, and other types of treatment or control devices or processes); and (2) the
reclamation for reuse of an "otherwise used" EPCRA Section 313 chemical that is spent
or contaminated and that must be recovered for further use in either the original or any
other operations.
Combustion for
energy recovery
Combustion for energy recovery is interpreted by EPA to include the combustion of an
EPCRA Section 313 chemical that is (1) (a) a RCRA hazardous waste or waste fuel, (b) a
constituent of a RCRA hazardous waste or waste fuel, or © a spent or contaminated
"otherwise used" material; and that (2) has a significant heating value and is combusted
in an energy or materials recovery device. Energy or materials recovery devices are
boilers and industrial furnaces as defined in 40 CFR §372.3 (See 62 FR 23891). If a
reported toxic chemical is incinerated but does not contribute energy to the process (e.g.,
metal, metal compounds, and chloroflorocarbons), it must be considered treatment for
destruction. In determining whether an EPCRA Section 313 chemical is combusted for
energy recovery, the facility should consider the heating value of the EPCRA Section 313
chemical and not the heating value of the chemical stream.
Treatmentfor
destruction
Means the destruction of an EPCRA Section 313 chemical in waste such that the
substance is no longer the EPCRA Section 313 chemical subject to reporting. Treatment
for destruction does not include the destruction of an EPCRA Section 313 chemical in
waste where the EPCRA Section 313 chemical has a heat value greater than 5,000 British
Thermal Units (BTU) and is combusted in any device that is an industrial boiler or
furnace. (See 40 CFR §372.3.) "Treatment for destruction" includes acid or alkaline
neutralization if the EPCRA Section 313 chemical is the entity that reacts with the acid or
base. "Treatment for destruction" does not include: (1) neutralization of a waste stream
containing EPCRA Section 313 chemicals if the EPCRA Section 313 chemicals themselves
do not react with the acid or base (See 40 CFR §372.3), (2) preparation of an EPCRA
Section 313 chemical for disposal, (3) removal of EPCRA Section 313 chemicals from
waste streams, and (4) activities intended to render a waste stream more suitable for
further use or processing, such as distillation or sedimentation. (Note: Amounts of
metals CAN NOT be destroyed and therefore should not be reported as treated for
destruction.)
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Waste stabilization
Means any physical or chemical process used to either reduce the mobility of hazardous
constituents in a hazardous waste or eliminate free liquid as determined by a RCRA
approved test method (e.g., Test Method 9095). A waste stabilization process includes
mixing the hazardous waste with binders or other materials and curing the resulting
hazardous waste and binder mixture. Other synonymous terms used to refer to this
process are "stabilization," "waste fixation," or "waste solidification." (See 40 CFR
§372.3.)
Release
Release is defined by EPCRA Section 329(8) to mean any spilling, leaking, pumping,
pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or
disposing into the environment (including the abandonment or discarding of barrels,
containers, and other closed receptacles) of any EPCRA Section 313 chemical. (See 40
CFR §372.3.)
Disposal
Disposal means any underground injection, placement in landfills/surface
impoundments, land treatment, or other intentional land disposal. (See 40 CFR §372.3.)
(See EPA document, Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery,
Waste Stabilization and Release for further detail.)
Waste management activities conducted by a facility on EPCRA Section 313 chemicals in
wastes generated on-site are not considered an otherwise use of that chemical. The otherwise use
threshold applies to amounts disposed, stabilized (without subsequent distribution in commerce), or
treated for destruction from wastes received from off-site or from chemicals generated from waste
received from off-site. For example, Section 313 chemicals in ash received from an electricity
generating facility for disposal must be applied to the otherwise use threshold. Because the Section 313
chemicals in the ash are being managed as waste, they are not eligible for the de minimis exemption.
Example - Otherwise Use
A facility captures leachate from a landfill, treats the leachate with an EPCRA Section 313 chemical, and then use
the treated leachate (which now contains the EPCRA Section 313 chemical) as on-site irrigation water. Is the
facility "otherwise using" the EPCRA Section 313 chemical in the irrigation water, and should the facility report
the EPCRA Section 313 chemical as a release to land in Section 5.5.4, Other Disposal?
Yes. Use of EPCRA Section 313 chemicals contained in the treated leachate for irrigation purposes is considered
an "otherwise use" and amounts of these chemicals contained in the treated leachate must be counted toward the
"otherwise use" threshold. Any EPCRA Section 313 chemicals manufactured during the treatment of the leachate
would also need to be considered toward the "manufacturing" threshold. The treated leachate, and EPCRA
Section 313 chemicals contained in the treated leachate, are also considered a waste and any "otherwise use" of
EPCRA Section 313 chemicals contained in the treated leachate is not eligible for the de minimis exemption. The
"otherwise use" of these chemicals for irrigation constitutes a release to land and would be reportable in Part II
5.5.4 Other Disposal.
> A O
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Special "Otherwise-Use" Activities to Consider for Coal Mining Facilities.
When considering what EPCRA Section 313 chemicals are managed during the year,
you should consider not only the amount of each of those chemicals in wastes that are
treated or disposed during the year, but also the amount of virgin EPCRA Section 313
chemicals used at the facility (e.g., to facilitate the treatment processes or for cleaning
operations). These chemicals must be included in calculations of the otherwise use
threshold.
EPCRA Section 313 chemicals used in support activities such as froth flotation,
process-related equipment maintenance, and dewatering activities are also typically
classified as "otherwise use" activities.
Any EPCRA Section 313 chemicals that a facility uses as processing or manufacturing
aids or for treating waste are "otherwise used."
EPCRA Section 313 chemicals in materials used as fuel or for maintaining equipment
operations, other than for maintaining motor vehicles, should be included in the
threshold determination for "otherwise use" activities.
Any EPCRA Section 313 chemicals in materials used in waste management processes
should also be included in the threshold determination for "otherwise use" activities.
For example, any material that is used as feedstock in a recovery process, as auxiliary
fuel in incineration, as a chemical in the treatment process (e.g., flocculation agents,
acids), or as an additive to reclaimed materials prior to customer delivery should be
included in the threshold determinations.
Example - Timing
A facility receives waste containing an EPCRA Section 313 chemical from off-site and disposes the waste on-site.
Should the facility count the EPCRA Section 313 chemicals in the waste towards the 'otherwise use' threshold upc
receipt of the waste shipment (e.g., signing the hazardous waste manifest) or upon actual disposal?
The facility must count the amount of the EPCRA Section 313 chemical towards its otherwise use threshold upon
actual disposal of the waste. EPCRA Section 313 chemicals are applied toward the otherwise use threshold upon
the performance of those activities. The facility does not "otherwise use" the EPCRA Section 313 chemical in the
waste received from off-site until the facility disposes the waste.
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3.2.1 Concentration Ranges for Threshold Determination
You are required to use your best "readily available data" for estimating EPCRA Section 313
threshold determinations and release and other waste management calculations. In some cases, the
exact concentration of an EPCRA Section 313 chemical in a mixture or other trade name product or in
a waste may not be known. In these cases, the waste profile, customer, supplier, or MSDS may only
provide ranges, or upper or lower bound concentrations. EPA has developed the following guidance
on how to determine concentrations from this type of information for use in threshold determinations:
If exact concentration is provided, use it.
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
waste profile 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 30% methanol in your threshold calculations.
If only the upper bound concentration is provided you must use this value in your
threshold calculation.
If only the lower bound concentration of the EPCRA Section 313 chemical 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 and you should use the given lower bound to calculate
the mid-point as discussed above. For example, the waste profile states that a solvent
contains at least 50% 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%, which is the value
you should use in your threshold calculation.
If only the lower bound is specified and no information on other components is given
assume the upper bound is 100% and calculate the mid-point as above.
Even if the concentration of a chemical is known through engineering knowledge only, the
facility is still required to consider the chemical for threshold determinations. For example, facility
engineers may have knowledge that nitric acid is manufactured in an on-site incinerator. If there are no
waste profiles or permit information specifically listing nitric acid, the facility must still consider the
chemical for threshold determinations. This determination should be made based on their best "readily
available data", be it process knowledge or other reasonable estimation techniques.
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When determining concentration information for wastes, it is important to understand that the de
minimis exemption does NOT apply to wastes. If your waste profiles (or other information) indicate
that there are chemicals present that are below the detection limit, you may still need to include those
chemicals in your threshold determinations and release and other waste management calculations. If
you have no information to indicate that the chemical exists in the waste stream, you may assume that
the concentration is zero. However, if the facility has reason to believe that the EPCRA Section 313
chemical is present in the waste, you may use half of the detection limit for that chemical when making
threshold determinations and release and other waste management calculations.
Example - Average Concentration
Is it appropriate for a coal mining facility to develop an average concentration for an EPCRA Section 313 chemical
contained in many different shipments of ash received from off-site for disposal and then use that average as a basi
of threshold determination? If so does EPA have a recommended approach for developing such an average?
EPCRA allows facilities to use best "readily available data" to provide information required under EPCRA Section
313. When data are not readily available, EPCRA allows facilities to use "reasonable estimates" of the amounts
involved. A facility must use its best judgment to determine whether data are "readily available." Thus, with
regard to use of average concentration levels, a facility must use its best judgment to decide whether the raw data
from which it might base any average concentration level are "readily available". In any event, a facility should
carefully document its decision making. For example, if a facility decides to use average concentration levels, it
should document why the raw data from which the averages are based are not "readily available", how it arrived
at any average concentration level used, and why the average concentration level is a "reasonable estimate"of
the amount of the EPCRA Section 313 chemical in the waste stream. EPA does not have a recommended
approach for determining average concentration levels.
3.2.2 Evaluation of Exemptions
EPCRA Section 313 provides facilities with certain exemptions:
Coal Extraction Activities Exemption;
Laboratory Activities Exemption;
De minimis exemption;
Exemptions that apply to the otherwise use of chemicals: routine janitorial/facility
grounds maintenance; personal use exemption; structural component exemption; motor
vehicle maintenance exemption; exemption for air or water drawn from the environment
or municipal sources for certain uses.
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3.2.2.1 Coal Extraction Activities Exemption
EPA specifically exempted coal extraction activities from threshold determinations and release
and other waste management calculations. As stated in (62 FR 23892), if an EPCRA Section 313
chemical is manufactured, processed, or otherwise used in extraction by facilities in SIC code 12, a
person is not required to consider the quantity of the toxic chemical so manufactured, processed, or
otherwise used when determining whether an applicable threshold has been met under §372.25 or
§372.27, or determining the amounts to be reported under §372.30. EPA defines coal extraction, for
purposes of determining which activities are eligible for the "extraction exemption" to mean the physical
removal or exposure of ore, coal, minerals, waste rock, or overburden prior to beneficiation, and to
encompass all extraction-related activities prior to beneficiation. EPA defines beneficiation as the
preparation of ores to regulate size (including crushing and grinding) of the product, to remove
unwanted constituents, or to improve the quality, purity, or grade of a desired product.
In terms of identifying which coal mining activities are considered part of the coal extraction
activities exemption under 40 CFR 372, EPA has made the following determinations:
Coal Extraction Activities Exemption
Applies
Any use of explosives to remove ore is exempt from
threshold determinations and release and other waste
management reporting.
Land disposal of materials including overburden, waste
rock, ore, and oily water from underground coal
extraction activities are considered part of extraction
activities and therefore exempt from threshold and
release and other waste management calculations.
Reclamation activities occurring simultaneously with
coal extraction activities (e.g., cast blasting).
Use of EPCRA Section 313 chemicals for extraction-
related maintenance of equipment.
Coal Extraction Activities Exemption Does
Not Apply
Crushing and screening of coal is not considered part
of extraction and amounts of EPCRA Section 313
chemicals involved in these activities must be
considered toward threshold determinations and
release and other waste management calculations.
Otherwise use of ash, waste rock, or fertilizer for
reclamation purposes are not considered part of
extraction; non-exempt amounts of Section 313
chemicals contained in these materials must be
considered toward threshold determinations and
release and other waste management calculations (see
Chapter 3.2 - Reclamation).
EPCRA Section 313 chemicals received in ash from off-
site (e.g., from an electricity generating facility) and
used as back-fill or structural support underground,
must be considered toward the otherwise use
threshold.
EPCRA Section 313 chemicals used to maintain belt
lines and other stationary equipment used to transport
coal to processing plants following extraction.
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Example - Coal Extraction Activities Exemption
EPA provided a reporting exemption for coal extraction activities (62 FR 23833). Can a coal mining
facility assume that all activities prior to beneficiation, or in other words all activities that take place
before the coal enters a processing plant, are exempt under the extraction exemption?
No. EPA has specifically exempted only coal extraction activities from EPCRA Section 313 reporting.
EPA defines coal extraction, for purposes of determining which activities are eligible for the
"extraction exemption" to mean the physical removal or exposure of ore, coal, minerals, waste rock,
or overburden prior to beneficiation, and to encompass all extraction-related activities prior to
beneficiation. EPA defines beneficiation as the preparation of ores to regulate size (including
crushing and grinding) of the product, to remove unwanted constituents, or to improve the quality,
purity, or grade of a desired product. Based on these definitions, certain non-extraction activities
such as crushing, grinding, or screening may occur before coal enters a processing plant which are
not exempt under the extraction exemption.
3.2.2.2 Laboratory Activities Exemption
This exemption includes EPCRA Section 313 chemicals that are manufactured, processed, or
otherwise used in a laboratory under the supervision of a technically qualified individual. This
exemption may be applicable in such circumstances 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. It also does not include laboratory support activities. For example,
chemicals used to maintain laboratory equipment are not eligible for the laboratory activities exemption.
Example - Laboratory Activities Exemption
If a facility takes a sample from its process stream to be tested in a laboratory for quality control purposes, are
releases of an EPCRA Section 313 chemical from the testing of the sample in the laboratory exempt under the
laboratory activities exemption?
Yes, provided that the laboratory at the covered facility is under the direct supervision of a technically qualified
individual as provided in 40 CFR 372.38(d). The laboratory exemption applies to the "manufacture," "process," or
"otherwise use" of EPCRA Section 313 chemicals and any associated release and other waste management
amounts that take place in a qualifying laboratory.
3.2.2.3 De Minimis Exemption
If the amount of EPCRA Section 313 chemical(s) present in a mixture or other 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
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impurity as discussed below.) Because wastes are not considered mixtures or other trade name
products, the de minimis exemption cannot apply to wastes. The de minimis concentration for
mixtures or other trade name products is 1%, except for OSHA-defmed carcinogens, which have a
0.1% de minimis concentration. If a mixture or other trade name product contains more than one
member of a compound 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.
Information may only be available that lists the concentration of chemicals in mixtures as a range. EPA
has developed guidance on how to determine quantities that are applicable to threshold determinations
and release and other waste management calculations when this range straddles the de minimis value.
EPA has published several detailed questions and answers and a directive in the EPCRA Section 313
Q&A Document that may be helpful if you have additional concerns about the de minimis exemption.
The TRI Forms and Instructions list each EPCRA Section 313 chemical and compound category with
the associated de minimis value.
The de minimis exemption also applies in limited circumstances to the manufacture of EPCRA
Section 313 chemicals. In the specific case where EPCRA Section 313 chemicals are coincidentally
manufactured in a product and remain in the product as an impurity which is then subsequently
distributed in commerce, amounts of EPCRA Section 313 chemicals are eligible for the de minimis
exemption. The de minimis exemption also applies to EPCRA Section 313 chemicals below the de
minimis concentration in an imported mixture or other trade name product.
The de minimis exemption, however, does not apply to EPCRA Section 313 chemicals that
are coincidentally manufactured as byproducts that are separated from the product; nor does it apply to
chemicals that are coincidentally manufactured as a result of treatment or other waste management
activities, or to waste brought on site for waste management. Coal mining facilities which combust fuel
for thermal drying must consider amounts of EPCRA Section 313 chemicals manufactured during
combustion. Combustion may result in the coincidental manufacture of such EPCRA Section 313
chemicals as sulfuric acid aerosols, hydrochloric acid aerosols, hydrofluoric acid, and certain metals and
metal compounds, as discussed earlier in this chapter.
Since the de minimis exemption does not apply to the coincidental manufacture of chemicals as
byproducts, the formation of these compounds in any concentration must be considered for threshold
determinations and release and other waste management calculations. The de minimis exemption
applies to materials otherwise used or processed, such as ash distributed into commerce for direct
reuse.
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Example -Ash Distributed into Commerce
An EPCRA Section 313 covered facility combusts coal in a combustion unit. The coal contains an EPCRA Section
313 chemical below de minimis amounts. An ash containing the EPCRA Section 313 chemical is generated from
the combustion of the coal. The ash which meets industry specification, is then sold to another facility for use in
the manufacture of concrete. If the EPCRA Section 313 chemicals in the ash are below the appropriate de minimii
concentration, are they eligible for the de minimis exemption?
The EPCRA Section 313 chemicals in the coal being combusted should be considered towards the facility's
otherwise use threshold and this activity is eligible for the de minimis exemption. The EPCRA Section 313
chemicals that are manufactured as a result of the combustion process are by products and therefore not eligible
for the de minimis exemption when determining whether the manufacturing threshold has been exceeded. The
EPCRA Section 313 chemicals in the ash that is sold are considered processed. After combustion, when the
facility is preparing the EPCRA Section 313 chemicals in ash for distribution in commerce, they are eligible for the
de minimis exemption.
De Minimis Exemption Applies
A facility distributes coal containing EPCRA Section
313 chemicals into commerce. This activity constitutes
a processing activity, and the de minimis exemption
applies to amounts of EPCRA Section 313 chemicals in
the coal distributed into commerce and to releases and
other waste management activities associated with this
processing activity.
A facility combusts coal on-site for thermal drying. The
de minimis exemption applies to the EPCRA Section
313 chemicals that were otherwise used in the fuel.
A facility otherwise uses EPCRA Section 313 chemicals
on-site to maintain and clean equipment. The de
minimis exemption applies to threshold determinations
and release and other waste management activities for
those chemicals otherwise used.
De Minimis Exemption Does Not Apply
Waste materials used to build up to grade during
reclamation.
A facility receives ash from off-site containing EPCRA
Section 313 chemicals for disposal. Because the facility
receives the waste ash from off-site for purposes of
further waste management, the de minimis exemption
does not apply, and the facility must consider the
amount of the EPCRA Section 313 chemical towards its
"otherwise use" threshold. If the facility exceeds the
threshold for an EPCRA Section 313 chemical, they
must report the amount of EPCRA Section 313 chemical
disposed on-site and any other releases and waste
management activities on the Form R.
A facility combusts coal for thermal drying. The de
minimis exemption does not apply to the manufacture of
EPCRA Section 313 chemicals (e.g., sulfuric acid, metal
compounds, etc.) during combustion. If the facility
exceeds a threshold for any EPCRA Section 313
chemical, they must consider the amount of the EPCRA
Section 313 chemical toward their release and other
waste management calculations.
Coal mines are likely to receive all of the ash they use for reclamation or otherwise use activities
from off-site. It is expected that the electricity generating facility from which the coal mining facility
receives their ash has determined the quantities of metals present in their ash. Additionally, coal mining
facilities maintain contractual agreements with the electricity generating facilities to whom they supply
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coal which stipulate that the ash will be returned to the coal mine. These contracts may contain
concentration data for metals and metal compounds contained in the ash and can be used in
combination with the total ash received to calculate the quantities of metals and metal compounds
otherwise used. If the coal mining facility does not have access to this type of data, it may use the
default values presented in Table 3-13 presented below.
Table 3-13
Total Constituent Concentrations of Elements in Coal and
Coal Combustion Residuals
Element Concentrations in Different Materials (ppm)
Element (units)
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
Coal
14
106
250
6.5
610
185
218
181
1.6
104
8
8
1,281
5,600
Fly Ash
131
6,300
13,800
130
900
2,200
2,120
3,000
12
4,300
134
36
1,180
3,500
Bottom Ash
10
168
9,360
10
5,820
932
1,082
1,940
4.2
2,939
14
9.9
537
1,796
Source: Adapted from Electric Power Research Institute (EPRI). Inorganic and Organic Constituents in Fossil
Fuel Combustion Residues, Volume 1. 1987; and Economic Analysis of the Final Rule to Add Certain Industry
Groups to EPCRA Section 313, April 1997, Appendix D, Table D-2.
Note: If specific concentration data of Section 313 chemicals in the coal and coal combustion residues are not
available, your facility may use the default values provided in this table to estimate concentration values of
constituents.
Once the de minimis level has been met or exceeded, the exemption no longer applies to that
process stream, even if the concentration of the EPCRA Section 313 chemical in a mixture or other
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trade name product later drops below the de minimis level. All releases and other waste management
activities are subject to reporting after the de minimis concentration has been equaled or exceeded,
provided an activity threshold has been exceeded.
Example - De Minimis
A facility receives a mixture with an EPCRA Section 313 chemical in a concentration below the de minimis
concentration. During processing, the concentration of the EPCRA Section 313 chemical exceeds its de minimis
level. This facility must consider amounts toward threshold determination and releases and other waste
management activities that take place after the point in the process where the de minimis level is met or exceeded.
The facility does not have to consider toward threshold determinations and release and other waste management
estimates, activities that took place before the de minimis level was met or exceeded.
3.2.2.4 Article Exemption
An article is defined as a manufactured item if each of the three criteria below applies:
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 under normal conditions of
processing or otherwise use of the item at the facility.
If you receive a manufactured item from another facility and process or otherwise use the item
without changing the shape or design, and your processing or otherwise use results in the release of 0.5
pound or less of the EPCRA Section 313 chemical in a reporting year from all like articles, then the
EPCRA Section 313 chemical in that item is exempt from threshold determinations and release and
other waste management reporting. The article exemption does not apply to the manufacturing of items
at your facility.
The shape and design of a manufactured item can change somewhat during processing and
otherwise use activities 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 definition of article. If the item's basic dimensional characteristics are totally altered
during processing or otherwise use, the item would not meet the definition, even if there were no
releases of an EPCRA 313 chemical from these manufactured items. An example of an article that coal
mines may encounter is the transfer or selling of used equipment, such as dump trucks. These materials
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may be considered articles and would not be required for threshold determination and release and other
waste management calculations.
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 for all like articles will negate the article exemption. Cutting,
grinding, melting, or other processing of a manufactured item could result in a release of an EPCRA
Section 313 chemical during normal conditions of use and, therefore, could negate the exemption as an
article if the total release exceeds 0.5 pound in a year. However, if all of the resulting waste is recycled
or reused, either on site or off site such that the release and other waste management of the EPCRA
Section 313 chemical in all like articles does not exceed 0.5 pound, then the article exemption status is
maintained. Also, if the processing or otherwise use of similar manufactured items results in a total
release and other waste management of less than or equal to 0.5 pound of any individual EPCRA
Section 313 chemical in a calendar year, EPA will allow this quantity to be rounded to zero and the
manufactured items to maintain their article exemption. The 0.5 pound limit does not apply to each
individual article; instead, it applies to the sum of releases and other waste management activities
(except recycling) from processing or otherwise use of all like articles for each EPCRA Section 313
chemical contained in these articles.
For additional information, refer to the EPCRA Section 313 Q&A document presents several
specific questions and answers/discussion pertaining to the article exemption.
3.2.2.5 Exemptions that Apply to the Otherwise Use of EPCRA Section 313 Chemicals
Some exemptions are limited to the "otherwise use" of an EPCRA Section 313 chemical.
EPCRA Section 313 chemicals used in these activities do not need to be included in a facility's
threshold determinations and release and other waste management calculations, provided thresholds are
met elsewhere. The following otherwise use activities are considered exempt (see most current
versions of the TRI Forms and Instructions and EPCRA Section 313 Question and Answers
documents):
EPCRA Section 313 chemicals used in routine janitorial or facility grounds
maintenance. Examples are bathroom cleaners and fertilizers and garden pesticides in
similar type or concentration distributed in consumer products. Materials used to clean
process-related equipment do not qualify for this exemption.
EPCRA Section 313 chemicals for personal use. Examples are foods, drugs,
cosmetics, and other personal items including those items used in cafeterias and
infirmaries.
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Example - Personal Use Exemption
Ammonia used to clean a cafeteria grill is exempt from threshold determinations and release and
other waste management calculations. Chlorine added to the water supply system to prepare
potable water for consumption at the facility is also exempt under the personal use exemption.
EPCRA Section 313 chemicals in structural components of the facility. This
exemption applies to EPCRA Section 313 chemicals present in materials used to
construct, repair, or maintain non-process related structural components of a facility.
An example common to all facilities would be the solvents and pigments used to paint
the administrative office buildings. Materials used to construct, repair, or maintain
process-related equipment (e.g., storage tanks, reactors, and piping) are not exempt.
EPCRA Section 313 chemicals used to maintain facility motor vehicles. This
exemption includes the use of EPCRA Section 313 chemicals for the purpose of
maintaining motor vehicles operated by the facility. Common examples include EPCRA
Section 313 chemicals in gasoline, radiator coolant, windshield wiper fluid, brake and
transmission fluid, oils and lubricants, batteries, cleaning solutions, and solvents in paint
used to touch up the vehicle. Motor vehicles include cars, trucks, forklifts, locomotives,
and aircraft. The use of EPCRA Section 313 chemicals to maintain belt lines and other
non-motor vehicles is not eligible for this exemption. Note that this exemption applies
only to the OTHERWISE USE of the chemical only. The coincidental manufacture of
EPCRA Section 313 chemicals resulting from combustion of gasoline is not considered
part of the exemption and any amounts of EPCRA Section 313 chemicals
coincidentally manufactured should be considered as part of the manufacturing
threshold.
Example - Motor Vehicle Exemption
A facility purchases ethylene glycol, and uses it on-site to prevent coal from freezing. The
facility must include the amount of ethylene glycol used on the coal for threshold
determinations and release and other waste management calculations. The facility also uses
ethylene glycol in antifreeze and in windshield washer fluid in vehicles operated by the facility.
These amounts are eligible for the motor vehicle exemption. The facility would not be required
to include the amount of ethylene glycol in the windshield washer fluid or anti-freeze used for
motor vehicles when making its threshold determination or in its release and other waste
management calculations.
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This exemption does NOT apply to stationary 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 - Use of Lubricants
Lubricants containing EPCRA Section 313 chemicals 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, which aid in facility process-
related operations, are not exempt and the amount of the chemical in that lubricant should be
applied to the otherwise use threshold.
Example - Motor Vehicle Exemption
Are EPCRA Section 313 chemicals used to maintain fleets of large earth-moving vehicles i
mining facilities exempt from threshold determinations and release or other waste
management reporting?
Yes. EPCRA Section 313 chemicals used to maintain motor vehicles owned and operated
by the facility are eligible for the motor vehicle exemption.
EPCRA Section 313 chemicals in certain air and water drawn from the
environment or municipal sources. Included are EPCRA Section 313 chemicals
present in process water and non-contact cooling water drawn from the environment or
a municipal source, or chemicals present in compressed air or air used in combustion.
Example - Chemicals in Process Water
A facility uses river water for non-contact cooling purposes. The river water contains 100
pounds of an EPCRA Section 313 chemical. Amounts of the EPCRA Section 313 chemicals
contained in the river water do not have to be considered for threshold determinations and
release and other waste management calculations because the EPCRA Section 313 chemicals
was present as it was drawn from the environment.
3.2.3 Additional Guidance on Threshold Calculations for Certain Activities
This section covers two specific situations in which the threshold determination may vary from
normal facility operations: reuse and remediation activities of EPCRA Section 313 chemicals.
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3.2.3.1 On-site Reuse Activities
Threshold determinations of EPCRA Section 313 chemicals that are reused at the facility are
based only on the amount of the EPCRA Section 313 chemical that is added during the year, and not
the total volume in the system or the amounts reused.
Example - Reuse Activities
A facility operates a heat transfer unit that contains 15,000 pounds of ethylene glycol at the beginning of the year
that was in use in prior years. The system is charged with 2,000 pounds of ethylene glycol during the reporting
year. The facility has therefore "otherwise used" only 2,000 pounds of the covered EPCRA Section 313 chemical
within that particular reporting year. A facility reporting for the first time would consider only the amount of
EPCRA Section 313 chemical that is added during its first reporting year towards its "otherwise use" threshold for
that year. If, however, the entire heat transfer unit was recharged with 15,000 pounds of ethylene glycol during
the year, the facility would consider the 15,000 pounds toward its otherwise use threshold and, exceeding the
otherwise use threshold, be required to report.
3.2.3.2 Remediation Activities
EPCRA Section 313 chemicals that are being managed at a remediation site (e.g., Superfund)
are not considered manufactured, processed, or otherwise used, and therefore, these amounts are not
included in the threshold determinations. However, if during remediation activities, an EPCRA Section
313 chemical is manufactured, then these amounts would have to be considered toward the
manufacturing threshold. Additionally, if you, are conducting remediation for an EPCRA Section 313
chemical for which you have exceeded a threshold elsewhere at the facility, you must consider this
activity in your release and other waste management calculations. In that case, you must report any
release and other waste management of an EPCRA Section 313 chemical due to remediation in Part n,
Sections 5 through 8, accordingly, of the Form R. Those quantities, however, would not be considered
as part of the reportable amount for determining Form A eligibility because they are not considered part
of normal production related activities.
3.3 Step 3: Determine which EPCRA Section 313 chemicals exceed a threshold
The final step is to determine which chemicals exceed a threshold. At this point you should
have:
1. Determined each EPCRA Section 313 chemical at your facility;
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2. Determined the threshold activity for each EPCRA Section 313 chemical
(manufactured, processed, or otherwise used) and calculated the quantity for each activity.
Now, you must sum the usage for each chemical by category, subtract all exempt quantities,
and compare the totals to the applicable thresholds. Each EPCRA Section 313 chemical exceeding
any one of the activity thresholds requires the submission of a Form R. Provided you meet certain
criteria you may be eligible to file a Form A rather than a Form R.
POSSIBLE ERROR - What if Your Facility Has No Releases and Other
Waste Management Quantities of EPCRA Section 313 Chemicals?
If you meet all reporting criteria and exceed any threshold for an EPCRA Section 313 chemical, you must file a
Form R or Form A for that chemical, even if you have zero releases and no other waste management activities.
Exceeding the chemical activity threshold, not the quantity released and otherwise managed as waste, determines
whether you must report. Note that if the total annual reportable amount is 500 pounds or less, and you do not
exceed one million pounds manufactured, processed, or otherwise used for that chemical, then you are eligible to
submit a Form A rather than a Form R for that chemical (see Chapter 2.9).
Calculating the Manufacturing Threshold for Section 313 Chemicals in Wastes
Coal mining facilities typically do not manufacture chemicals or products intentionally.
However, these facilities may coincidently manufacture Section 313 chemicals during incineration,
wastewater treatment, and other waste management operations. You will also need to consider
whether EPCRA Section 313 chemicals are produced coincidentally, even if the chemical exists for
only a short period of time, and later is destroyed by air control equipment. Most commonly,
incineration may result in the manufacture of metal compounds (usually as a result of oxidation), acid
aerosols, and other organic compounds, or convert metal compounds to the parent metal (e.g., mercury
compounds in coal convert to elemental mercury). The following discussion describes how to calculate
the manufacturing threshold for these situations.
To calculate the amount of EPCRA Section 313 metal compounds manufactured during
combustion of wastes, you will need to determine the concentration of each metal present in the waste
being combusted. The best "readily available data" should be used to estimate the approximate
concentration of the metal(s) in the waste. If you have data regarding chemical concentrations in the
wastes (e.g., analytical data) and believe that is the best "readily available data", then you should use
this information. If specific concentration data of the metals in the waste do not exist, you can assume
that the metals will convert to the lowest weight metal oxide possible.
During combustion, other EPCRA Section 313 chemicals could be manufactured, particularly
acid aerosols. For instance, sulfuric acid aerosols could be produced depending on a variety of factors
such as sulfur content of the waste. If you have specific data on the manufacture of acid aerosols, then
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use it. If data are not available, EPA has published guidance on calculating the amount of sulfuric acid
aerosols manufactured during combustion, which could be applied to the combustion of wastes;
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size), EPA, March 1998, available on EPA's TRI website at
http://www.epa.gov/tri.
To estimate the amount of EPCRA Section 313 chemicals manufactured during wastewater
treatment, the Clean Water Act typically requires facilities to monitor some Section 313 chemicals. In
particular, the facility's wastewater permit application may have more detailed, chemical-specific
monitoring data. However, it is important to note how the chemical is monitored in relation to the
EPCRA Section 313 chemical being evaluated. For example, wastewater permits may require
monitoring for the nitrate ion, but the nitrogen compound category is calculated by the total weight of
the nitrate compound.
Calculating the Otherwise Use and Processing Thresholds for Section 313 Chemicals
in Wastes
To determine if a chemical exceeds the processing or otherwise use threshold, you must
calculate the annual activity for that chemical. For EPCRA Section 313 chemicals in wastes, start with
the amount of chemical in stored waste as of January 1, add the amount of the chemical in waste both
received from off-site and generated on-site and any amounts that are manufactured during the
treatment during that year, and subtract the amount remaining in storage on December 31. The waste
manifests received from your customers will be an invaluable source for determining the quantities of
different types of wastes managed by your facility, particularly in terms of classifying how various types
and quantities undergo a treatment step or are disposed by your facility, for example, when determining
if the otherwise use threshold has been exceeded.
Calculating Thresholds for Section 313 Chemicals in Purchases
For purchased chemicals, start with the amount of chemical at the facility as of January 1, add
any purchases during the year and the amount manufactured (including imported), and subtract the
amount remaining in the inventory on December 31. If necessary, adjust the total to account for
exempt activities (see Chapter 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.
Keep in mind that the threshold calculations are independent for each threshold activity:
manufactured, processed, and otherwise used. If more than one threshold activity applies, the amount
associated with each activity is determined separately.
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Table 3-14 presents a worksheet that may be helpful when conducting your threshold
determinations and Table 3-15 illustrates an example of how the work sheet can be used for the
following example:
Example - Threshold Worksheet
Your facility uses a total of 13,000 pounds of ethylene glycol in the current reporting year. 8,000 pounds of the
ethylene gly col is used to prevent freezing of coal during storage on-site. The remaining 5,000 pounds of
ethy lene gly col is used as antifreeze in maintenance trucks operated by the facility. Because the amount of
ethylene gly col used as antifreeze for trucks is eligible for the motor vehicle exemption, your facility has otherwise
used only 8,000 pounds of ethylene gly col. Therefore, you have not exceeded the 10,000 pound threshold for
otherwise use and you are not required to submit a Form R or Form A.
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Table 3-14 Section 313 Reporting Threshold Worksheet
Facility Name:
Toxic Chemical or Chemical Category:
CAS Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of the toxic chemical manufactured, processed, or otherwise used.
Mixture Name, Waste Name, or
Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source
Total Weight
(lb)
Percent TRI
Chemical
by Weight
TRI Chemical
Weight
(in Ibs)
Amount of the Listed Toxic Chemical by Activity (in Ibs.):
Manufactured
(A) Ibs.
Processed
(B) Ibs.
Otherwise Used
(C) Ibs.
OJ
o
Exempt quantity of the toxic chemical that should be excluded.
Mixture Name or Waste 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 Toxic Chemical Exempt from Above (in
Ibs.):
Manufactured
(A,) Ibs.
Processed
BO Ibs
Otherwise Used
(CO Ibs,
Amount subject to threshold:
Compare to threshold for Section 313 reporting.
25.000 Ibs.
Ibs:(B-Bj) Ibs. (C-Cj) Ibs.
25.000 Ibs. 10.000 Ibs.
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R, retain it for your records.
-------
Table 3-15. Sample Section 313 Reporting Threshold Worksheet
Facility Name: U.S.A. Mining
Toxic Chemical or Chemical Category Ethvlene Glvcol
CAS Number: 107-21-1 7
Reporting Year: 1998
Date Worksheet Prepared: May 1. 1999
Prepared By:
Amounts of the toxic chemical manufactured, processed, or otherwise used.
Mixture Name, Waste Name, or
Other Identifier
1. Ethylene Glycol
2.
3.
4.
Subtotal:
Information
Source
Inventory
Records
Total Weight
(lb)
13,000
Percent TRI
Chemical
by Weight
100%
TRI Chemical
Weight
(in Ibs)
13,000
13,000
Amount of the Listed Toxic Chemical by Activity (in Ibs.):
Manufactured
(A) 0 Ibs.
Processed
(B) 0 Ibs.
Otherwise Used
13,000
©13,000 Ibs.
Exempt quantity of the toxic chemical that should be excluded.
Mixture Name or Waste Name
as Listed Above
1. Ethylene glycol used in trucks
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility,
activity)
Motor Vehicle
Fraction or Percent Exempt
(if Applicable)
38
Amount of the Toxic Chemical Exempt from Above (in
Ibs.):
Manufactured
(AO 0 Ibs.
Processed
(BO 0 Ibs.
Otherwise Used
5,000
(CO 5,000 Ibs.
Amount subject to threshold:
Compare to threshold for Section 313 reporting.
(A-AOOlbs.
25,000 Ibs.
(6-6023,500 Ibs.
25,000 Ibs.
(C-CO 8,000 Ibs.
10,000 Ibs.
-------
If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R, retain it for your records.
3-62
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Chapter 4 - Estimating Releases and Other Waste Management Quantities
4.0 PURPOSE
Once you have determined which EPCRA Section 313 chemicals have exceeded thresholds at
your facility, as described in Chapter 3, you must then estimate amounts of these chemicals in wastes by
particular waste management type (e.g., release to air, transfer off-site, etc.). To aid in making these
calculations, this chapter is intended to help you in developing a systematic approach for conducting
releases and other waste management calculations specific to coal mining facilities. This chapter has
been divided into two parts. The first part provides a general approach to identifying sources of
potential releases and other waste management activities, collecting data, and determining the most
appropriate method(s) to develop estimates. Chapter 4.1 also provides insights into the requirements,
recommended approaches, and other nuances associated with developing comprehensive and accurate
estimates for reportable EPCRA Section 313 chemicals. To illustrate this approach, a diagram of a
recommended steps for estimating quantities of reportable EPCRA Section 313 chemicals released or
otherwise managed as wastes is provided in Figure 4-1.
Chapter 4.2 of this chapter provides a focused discussion, along with examples, of methods
and tools to use in calculating estimates of releases and other waste management activities specific to
many coal mining facilities. In particular, section 4.2 provides specific examples and issues pertaining to
common chemical use categories in the coal mining industry (Section 4.2). These chemical use
categories are:
Extraction
Transportation, size regulation, and screening/classifying
Coal cleaning, including froth flotation
Coal drying (combustion)
Storage
Reclamation and ash management
Facility and vehicle maintenance.
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Figure 4-1 Release and Other Waste Management Calculation Approach
-------
4.1 General Steps for Determining Releases and Other Waste Management Activities
You can develop release and other waste management estimates by completing these four basic
steps. See Figure 4-1 for illustration of this four-step process.
Step 1) Identify potential sources of chemicals released or otherwise managed
as waste.
Step 2) Prepare a process flow diagram.
Step 3) Identify on-site releases, off-site transfers, and other on-site waste
management activity types.
Step 4) Determine the most appropriate method(s) to develop the estimates for
releases and other waste management activity quantities and calculate
the estimates.
These steps are described in detail in the following sections.
4.1.1 Step 1. Identify Potential Sources of Chemical Release and Other Waste
Management Activities
The first step in release calculations is to identify all areas at your facility that could potentially
release reportable Section 313 chemicals. Consider all potential sources at which reportable EPCRA
Section 313 chemicals may be released and otherwise managed from each unit operation and process.
Remember to include upsets and routine maintenance activities. Potential sources include the following:
Relief valves;
Pumps;
Stacks;
Volatilization from process or treatment;
Fittings;
Transfer operations;
Flanges;
Storage tanks;
Stock pile losses;
Waste treatment discharges;
Process discharge stream;
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Container residues;
Recycling and energy recovery byproducts;
Accidental spills and releases;
Storm water runoff;
Clean up and housekeeping practices;
Treatment sludge; and
Combustion byproducts.
Next, you must identify the reportable EPCRA Section 313 chemicals that are released and
otherwise managed from each source. A thorough knowledge of the facility's operations and
processes will be required to make an accurate determination of which chemicals are involved,
including those EPCRA Section 313 chemicals that are coincidentally manufactured during these
processes.
4.1.2 Step 2. Prepare a Process Flow Diagram
Preparing a process flow diagram will help you calculate your releases by illustrating the life-
cycle of the reportable EPCRA Section 313 chemical(s), as well as help you identify any sources of
chemicals that are released and otherwise managed as waste at your facility that you might have missed
in step 1. Depending on the complexity of your facility, you may want to diagram individual processes
or operations rather than the entire facility. The diagram should illustrate how materials flow through the
processes and identify material input, generation, and output points. By reviewing each operation
separately, you can determine where EPCRA Section 313 chemicals are manufactured, processed, or
otherwise used and the medium to which they will be released on-site, transferred off-site for further
waste management, or otherwise managed as wastes on-site.
4.1.3 Step 3. Identify On-Site Releases, Off-Site Transfers and On-Site Waste
Management Activity Types
For each identified source of an EPCRA Section 313 chemical, you must examine all possible
releases and other waste management activities. Figure 4-2 is a schematic of releases and other waste
management activities as they correspond to individual data elements on the Form R. Remember to
include both routine operations and accidents when identifying types of chemical management activities.
This diagram, along with the following descriptions, can be used as a checklist to make sure all possible
types of releases and other waste management activities have been considered.
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EPCRA Section 313
Chemical In
Point Sources
Fugitive Emissions
A
Operation
(EPCRA Section 313
Chemicals Manufactured
On-Site)
Underground Injection
on-site
Receiving Streams
POTWs
Transfer Off-Site
Recycling
Energy Recovery
Treatment
Disposal
Product Containing
EPCRA Section 313
Chemical
(Not Reported on Form R)
Treatment
On-site Management
Energy Recovery
Recycling
Land on-site (landfill, land
treatment, surface impoundment,
other disposal)
Figure 4-2. Possible Release and Other Waste Management Types
for EPCRA Section 313 Chemicals
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a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) - 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 sources.
b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) - All emissions to
the air which occur through stacks, vents, ducts, pipes, or any confined air stream,
including storage tank emissions and emissions from air pollution control equipment.
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. You should note that some state air quality agencies
consider ventilation systems without an attached pollution control device to be a stack
or point source, and other agencies consider releases from storage tanks to be fugitive
emissions.
c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3 of Form
R) - Direct wastewater discharges to a receiving stream or surface water body.
Discharges usually occur under a National Pollutant Discharge Elimination System
(NPDES) permit.
d. Underground Injection On site to Class I Wells (Part n, Section 5.4.1 of
Form R) and to Class II through V Wells (Part II, Section 5.4.2 of Form R)
Disposal 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 combined with waste profiles may provide the
necessary information for all classes of wells.
e. Releases to Land On Site (Part II, Section 5.5 of Form R) - 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:
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e(l). Landfill - The landfill may be either a RCRA permitted or a non-hazardous
waste landfill. Both types are included if they are located on site.
e(2). Land treatment/application farming - Land treatment is a disposal method in
which a waste containing an EPCRA Section 313 chemical is applied to or
incorporated into soil. Volatilization of an EPCRA Section 313 chemical due
to the disposal operation must be included in the total fugitive air releases
and/or should be excluded from land treatment/application farming to accurately
represent the disposition of the EPCRA Section 313 chemical and 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. 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 Part II,
Sections 6.2 and 8.1 of the Form R.
The ultimate disposition of the chemical after application to the land does not
change the required reporting. For example, even if the chemical is eventually
biodegraded by microorganisms or plants, it is not considered recycled, reused,
or treated.
e(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. Ash disposed of in excavated area would also be reported here.
You do not have to report quantities of an EPCRA Section 313 chemical that
are released to a surface impoundment as part of a wastewater treatment
operation in this section. However, if the sludge from the surface impoundment
contains the EPCRA Section 313 chemical, then the EPCRA Section 313
chemical in the sludge must be estimated in this section unless the sludge is
removed and subjected to another waste management activity. In that case, it
should be reported for that activity, as appropriate.
e(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
4-7
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category also includes any spills or leaks of the EPCRA Section 313 chemical
to land.
f. Transfers Off Site to a Publicly Owned Treatment Works (POTW) (Part H,
Section 6.1 of Form R) The amount of EPCRA Section 313 chemical in water
transferred to an off site POTW.
g. Transfers to Other Off-Site Locations (Part H, Section 6.2 of Form R) All
amounts of the EPCRA Section 313 chemical transferred off-site for the purposes of
waste treatment, disposal, recycling, or energy recovery. Be sure to include quantities
of the EPCRA Section 313 chemical in non-hazardous wastes (such as sanitary waste
and facility trash) transferred off-site and metals in waste transferred off site for
recycling.
Any residual chemicals in "empty" containers transferred off-site would also be
reported in Section 6.2. 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 in this section..
h. On-Site Waste Treatment (Part II, Section 7A of Form R) All on-site waste
treatment of reported EPCRA Section 313 chemicals. The information reported in
Section 7A focuses on the treatment of the waste stream. 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;
treatment efficiency of each method or sequence; and whether efficiency data are based
on actual operating data. Metals or metal compounds in waste subjected to a
combustion process are not destroyed but should still be reported as going through the
treatment process, with a treatment efficiency of zero.
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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 EPCRA Section 313 chemicals have been exceeded and you are in the
process of completing separate Form Rs for each chemical.
All 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 which
removes 99% of chemical A; a neutralization tank where 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 landfilled off site).
Section 7A should be completed slightly differently for each chemical for which a Form R
must be filed. The table accompanying this example shows how Section 7A should be
completed for each chemical. 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 are applied to the entire waste stream,
regardless of whether the operation affects the chemical for which you are completing the
Form R (for instance, the first four blocks of Section 7A. Ib of all three Form Rs should show:
P19 (liquid phase separation), C11 (neutralization), P11 (settling/clarification), and NA (to
signify the end of the treatment system). Note that Section 7A. Ib is the only section of the
Form R that is not chemical specific. It applies to the entire waste stream being treated.
Section 7A. Ic of each Form R should show the concentration of the specific chemical in the
influent to the first step of the process (oil/water separation). For this example, assume
chemicals A, B, and C are all present at concentrations greater than 1%. Therefore, code "1"
should be entered. Section 7 A. Id is also chemical specific. It applies to the efficiency of the
entire system in destroying and/or removing the chemical for the Form R you are currently
completing. 99% should be entered 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, as appropriate.
Chemical A
7 A. la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. NA 5.
7. 8.
7A.lc
!
7A.ld
99 %
7 Ale
Yes No
X
Chemical B
7 A. la
W
7A.lb
3. Pll
6.
1. P19 2. Cll
4. NA 5.
7. 8.
7A.lc
!
7A.ld
95 %
7 Ale
Yes No
X
Example - On-Site Waste Treatment (cont.)
Chemical C
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7A.la
W
7A.lb 1. P19 2. Cll
_ _
3. NA 4. 5.
6. 7. 8.
7A.lc
1
7A.ld
100
%
7A.le
Yes N
0
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
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.
I. On-Site Energy Recovery (Part II, Section 7B of Form R) All on-site energy
recovery of reported EPCRA Section 313 chemicals must be reported. EPA's view is
that chemicals that do not contribute significant heat energy during combustion
processes should not be considered for energy recovery. Therefore, only chemicals
with a significant heating value (e.g., heating value high enough to sustain combustion)
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 is
incinerated on-site but does not significantly contribute energy to the process (e.g.,
chlorofluorocarbons), it must be considered on-site waste treatment (see Chapter
4.1.3, h. above). Metal and metal compounds in a waste that is combusted cannot be
considered combusted for energy recovery because metals do not have any heat value.
j. On-Site Recycling (Part n, Section 7C of Form R) All on-site recycling methods
used on EPCRA Section 313 chemicals must be reported.
k. Source Reduction and Recycling Activities (Part II, Section 8 of Form R)2
Provide information about source reduction and recycling activities related to the
EPCRA Section 313 chemical for which releases 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
2The subsection 8. 1 through 8.8 designation are those for the 1 997 Form R. Please refer to the
current reporting year's TRI Forms and Instructions for any changes.
4-10
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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.
k(l). 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 transferred off-site for disposal:
Section 8.1 = Section 5 + Section 6.1 (metals and metal compounds) +
Section 6.2 (disposal) - Section 8.8 (release or off-site disposal only)
k(2). Quantity Used for Energy Recovery On-Site (Part II, Section 8.2 of
Form R) - Estimate a quantity of the EPCRA Section 313 chemical in wastes
combusted for energy recovery on-site. This estimate should be the quantity of
the chemical combusted in the process for which codes were reported in
Section 7B (unless the 7B code is related to a Section 8.8 activity). Test data
from trial burns or other monitoring data may be used to estimate the quantity of
the EPCRA Section 313 chemical combusted for energy recovery purposes. If
monitoring data are not available, vendor specifications regarding combustion
efficiency may be used as they relate to the reportable EPCRA Section 313
chemical. A quantity should be reported in Section 8.2 when a method is
reported in Section 7B (unless the 7B code is related to a Section 8.8 activity).
Combustion for energy recovery is interpreted by EPA to include the
combustion of an EPCRA Section 313 chemical that is (1) (a) a RCRA
hazardous waste or waste fuel, (b) a constituent of a RCRA hazardous waste
or waste fuel, or © a spent or contaminated "otherwise used" material; and that
(2) has a significant heating value and is combusted in an energy or materials
recovery device. Energy or materials recovery devices are boilers and
industrial furnaces as defined in 40 CFR 372.3 (see 62 FR 23891, May 1,
1997). If a reported EPCRA Section 313 chemical is incinerated but does not
contribute energy to the process (e.g., metal, metal compounds, and
chlorofluorocarbons), it must be considered treatment for destruction. In
determining whether an EPCRA Section 313 listed chemical is combusted for
energy recovery, the facility should consider the heating value of the EPCRA
Section 313 chemical and not of the chemical stream. Note that "NA" should
be reported for EPCRA Section 313 chemicals which are halogens, CFCs,
halons, and metals.
k(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
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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:
Section 8.3 = Section 6.2 (energy recovery) - Section 8.8 (off-site energy
recovery)
Combustion for energy recovery is interpreted by EPA to include the
combustion of an EPCRA Section 313 chemical that is (1) (a) a RCRA
hazardous waste or waste fuel, (b) a constituent of a RCRA hazardous waste
or waste fuel, or © a spent or contaminated "otherwise used" material; and that
(2) has a significant heating value and is combusted in an energy or materials
recovery device. Energy or materials recovery devices are boilers and
industrial furnaces as defined in 40 CFR 372.3 (see 62 FR 23891, May 1,
1997). If a reported EPCRA Section 313 chemical is incinerated but does not
contribute energy to the process (e.g., metal, metal compounds, and
chlorofluorocarbons), it must be considered treatment for destruction. In
determining whether an EPCRA Section 313 listed chemical is combusted for
energy recovery, the facility should consider the heating value of the EPCRA
Section 313 chemical and not of the chemical stream. Note that "NA" should
be reported for EPCRA Section 313 chemicals which are halogens, CFCs,
halons, and metals.
k(4). Quantity Recycled On-Site (Part II, Section 8.4 of Form R) - Estimate a
quantity of the EPCRA Section 313 chemical recycled in wastes on-site. This
estimate should be the quantity of the chemical recycled in the operation for
which codes were reported in Section 7C (unless the 7C code is related to a
Section 8.8 activity). A quantity should be reported in Section 8.4 when a
method of on-site recycling is reported in Section 7C (unless the 7C code is
related to a Section 8.8 activity). To estimate this quantity, you should
determine if operating data exist which indicate a recovery efficiency and use
that efficiency value combined with throughput data to calculate an estimate. If
operating data are unavailable, use available vendor specifications.
k(5). Quantity Recycled Off-Site (Part H, Section 8.5 of Form R) - The
quantity reported in Section 8.5 will generally 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:
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
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k(6). Quantity Treated On-Site (Part H, 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 in wastes. The quantities reported in Section
8.6 will be those treated in a subset of the operations for which codes were
reported in Section 7 A, where treatment can include physical removal of the
EPCRA Section 313 chemical(s) from a waste stream. To estimate the
quantity, you should determine if operating data exist which indicate a treatment
(e.g., destruction or chemical conversion of EPCRA Section 313 chemical)
efficiency 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 Sections 8.6 or 8.7. Note that conversion of a
metal from one oxidation state to another (e.g., Cr(VT) to Cr(in) is not
considered treatment in Section 8.6. If operating data are unavailable, use
available vendor specifications. Section 7A must be completed if a quantity is
entered into Section 8.6.
k(7). Quantity Treated Off-Site (Part II, Section 8.7 of Form R) - This quantity
reported in Section 8.7 must be the same as the quantity reported in Section
6.2 for which treatment codes are reported and quantities sent to a POTW as
reported in Section 6.1 except for metal and metal compounds. If a quantity is
reported in Section 8.8, subtract any associated off-site transfers for treatment:
Section 8.7 = Section 6.1 (except metals and metal compounds) + Section 6.2
(treatment) - Section 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 Sections 8.6 or 8.7. Quantities of metals reported in Section 6.1 and 6.2 as
being treated should be reported in Section 8.1 (Quantity Released) unless the
facility has knowledge that the metal is being recovered.
k(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, used for energy recovery, treated,
or released (including disposal) that are associated with normal or routine
production from those that are not. The quantity reported in Section 8.8 is the
quantity of the EPCRA Section 313 chemical 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:
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(1) Remedial actions;
(2) Catastrophic events such as earthquakes, fires, or floods; or
(3) 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 II, Sections 8.1 through 8.7 of Form R, but should be included
in Part n, Sections 5 and 6 of Form R as appropriate. The on-site waste
management activities should also be reported in Section 7.
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 Sections 8.1 through 8.7 as
appropriate. On-site releases and off-site transfers for further waste
management resulting from remediation of an EPCRA Section 313 chemical 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 in wastes generated as a result of remedial actions, catastrophic
events, or one-time events not associated with production processes are not
reported in Part II, Section 8.8 nor Sections 8.1 through 8.7 of Form R.
k(9) Prior Year Estimates (for Part II, Sections 8.1 - 8.7 of Form R) In
several instances, the Form R prompts the facility for information from prior
reporting years. In Section 8, Source Reduction and Recycling Activities,
Column A of Sections 8.1-8.7 requests release and other waste management
information from the prior reporting year. Because 1998 is the first year that
coal mining facilities were required to collect data for EPCRA Section 313
reporting, you may enter "NA" in column A for Form Rs for RY 1998 only. In
Section 8.9, you are required to provide a production ratio or activity index to
reflect either the ratio of current year's production to prior year's production or
an index of the current year's activity to prior year's activity with respect to the
reportable EPCRA Section 313 chemical. Because you were not required to
collect data prior to 1998, recently added facilities as a result of the industry
expansion rulemaking may also enter "NA" in Section 8.9 for Form Rs for RY
1998 only.
4-14
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POSSIBLE ERROR - Double Counting
Releases and other waste management activities should not be inadvertently "double counted."
A single wastewater discharge should not be listed as both a release to water (on site) and a
discharge to POTW (off site). Similarly, a release to land should not be listed as both a release
to land (on site) and a transfer to an off-site landfill. 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) to Develop the Estimates for
Releases and Other Waste Management Activity Quantities and Calculate the
Estimates
After you have identified all of the potential sources for release and other waste management
activity types, you must next estimate the quantities of each reportable chemical released and otherwise
managed as waste. EPA has identified four basic methods that may be used to develop estimates (each
estimate has been assigned a code that must be identified 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 Estimating Releases and Waste Treatment
Efficiencies for the Toxic Chemical Release Inventory Form. They are also briefly described
below. EPA does not require you to conduct additional sampling or testing for Section 313 reporting;
however, you are required to use the best "readily available data" or prepare "reasonable estimates".
For example, emission factors or engineering calculations may not be the best "readily available data"
when other data, such as stack testing, are available. For each reported amount, you are required to
identify only the primary method used for each estimate.
Based on site-specific knowledge and potential data sources available, you should be able to
determine the best method for calculating quantities for each release and other waste management
activity. 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.
4-15
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Table 4-2
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data (M)
Stack monitoring data
Outfall monitoring data
Air permits
Industrial hygiene monitoring data
NPDES permits
POTW pretreatment standards
Effluent limitations
RCRA permit
Hazardous waste analysis
pH for acids
Continuous emission monitoring
Emission Factors (E)
AP-42 or other EPA emission factors
Published facility or trade association chemical-
specific emission factors
Mass Balance (O
Supply records
Hazardous material inventory
Air emissions inventory
Pollution prevention reports
Hazardous waste manifests
Spill event records
Engineering Calculations (O)
Volatilization rates
Raoult'sLaw
Henry's Law
Solubilities
Non-published emission factors
Facility or trade association non chemical specific
emission factors (e.g., SOCMI factors)
Once estimation methods have been determined for all potential sources, releases and other
waste management activities, an estimate for each reportable EPCRA Section 313 chemical can be
developed corresponding to the data elements on Form R.
4.1.4.1
Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for developing
estimates for chemical releases and other waste management activity quantities estimates. Your facility
may be required to perform monitoring under provisions of the Clean Air Act (CAA), Clean Water Act
(CWA), Resource Conservation and Recovery Act (RCRA), or other regulations. If so, these 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 are available or if you believe the monitoring data are not representative, you must determine if
another estimation method would give a more accurate result.
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Example - Monitoring Data
Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in the
POT W discharge is 2 mg/L . The wastewater treatment facility processed 1 . 5 million gallons of water in 1 998. The
treated wastewater is discharged to an off-site POT W. The amount of copper transferred off site to the POTW
(for Part II, Section 6. 1 of the Form R) is estimated as follows:
Amount of copper transferred
= 25lbs lyr
POSSIBLE ERROR - Treatment Efficiencies
Vendor data on treatment efficiencies often represent ideal operating conditions. Thus, you should adjust such
data to account for downtime and process upsets during the actual reporting year that would result in lower
efficiencies. Remember that efficiencies reported by vendors are often general and may not apply to specific
chemicals or uses of the equipment. For example, an incinerator or flare may be 99.99% efficient in combusting
organic chemicals, but will have a zero percent efficiency in combusting metals.
4.1.4.2 Mass Balance (code C)
A mass balance involves determining the amount of an EPCRA Section 313 chemical 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 that are created during an operation
(manufactured, including coincidental manufacturing). For example, additional
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ammonia, sodium nitrite, or nitrate compounds may be coincidentally manufactured in
biological wastewater treatment systems.
Output means any avenue by which the EPCRA Section 313 chemical leaves the
operation. Output may include on-site releases and other on-site waste management
activities; transfers for treatment, disposal, energy recovery, or recycling; or the amount
of chemical that leaves with the final product. In a solvent recovery operation, for
example, the recovered solvent product and wastes generated from the process are
outputs.
Consumption refers to the amount of chemical that is converted to another substance
during the operation (i.e., reacted). For example, phosphoric acid would be consumed
by neutralization during wastewater treatment.
The mass balance technique may be used for manufactured, processed, or otherwise used
chemicals. It is typically useful for chemicals that are "otherwise used" and do not become part of the
final product, such as catalysts, solvents, acids, and bases. For large inputs and outputs, 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 estimates.
Example - Estimating Releases to Air Using Mass Balance
A facility uses an EPCRA Section 313 chemical as a refrigerant in condensers to control air emissions and adds
20,000 pounds to the refrigeration system in 1998 (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 in 1998. 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 (Ibs/yr) - Amount released to wastewater (Ibs/yr)
= 20,000 Ibs/yr - 1,200 Ibs/yr
= 18,800 Ibs/yr
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POSSIBLE ERROR - Mass Balances for Otherwise Used Chemicals
If you are performing mass balance to estimate the quantity for a particular data element, make sure you include all
inputs and outputs as precisely as possible. If, for example, you identify all inputs properly, but you fail to
include all outputs, your estimate could be inaccurately inflated. Furthermore, if all inputs and outputs are
identified, but are not precise, the estimate of the release in question could also be inaccurate.
4.1.4.3 Emissions Factors (code E)
An emission factor is a representative value that attempts to relate the quantity of a chemical
released with an associated activity. These factors are usually expressed as the weight of chemical
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.
Many emission factors are available in EPA's Compilation of Air Pollutant Emission
Factors (AP-42). The use of AP-42 emission factors is appropriate in developing estimates for
emissions from boilers and process heaters. Equations are presented in AP-42 to calculate chemical
specific emission factors for liquid material loading/unloading of transportation vehicles and storage
tanks. AP-42 can be accessed at EPA's Technology Transfer Network (TTN) website:
http://www.epa.gov/ttn/chief/ap42.html.
It should be noted that, for purposes of EPCRA Section 313 reporting, the only estimates that
can be reported as "emission factors (code E)" are published chemical-specific emission factors.
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Example - Emission Factors
Emission factors have been developed for air releases of fuel constituents and combustion products from thermal
drying operations. This document (Table 3-8) lists an emission factor for formaldehyde manufactured during
combustion:
0.00024 Ibs formaldehyde generated/ ton coal combusted
A facility operating a boiler using coal for thermal drying could use the above emission factor to determine the
amount of formaldehyde generated and subsequently released to the air (assuming no formaldehyde is removed
prior to release). If 1,000,000 tons of coal are used during a reporting year, the amount of formaldehyde generated
and released would be:
(0.00024 Ibs/ton) x (1,000,000 tons) = 240 Ibs of formaldehyde
NOTE: In addition to these combustion by-products, there are other EPCRA Section 313 chemicals in coal that
should be considered for EPCRA Section 313 reporting.
4.1.4.4 Engineering Calculations (code O)
Engineering calculations are assumptions and/or judgements used to estimate quantities of
EPCRA Section 313 chemicals released or otherwise managed. 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 EPCRA Section 313 chemical in question.
Engineering calculations rely on the process parameters; you must have a thorough knowledge of the
processes at your facility to complete these calculations.
Engineering calculations can also include computer models. Several computer models are
available for estimating emissions from landfills, wastewater treatment, water treatment, and other
processes.
Non-chemical-specific emission factors (e.g., SOCMI emission factors) and non-published
emission factors also can be used as discussed in Section 4.1.4.3, but must be classified as "engineering
calculations" for EPCRA Section 313 reporting.
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Example - Engineering Calculations
Stack monitoring data are available for xylene but you have exceeded a threshold for toluene and must determine
amount released or otherwise managed. Toluene is used in the same application as xylene at your facility. 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, an estimated 200 Ibs. of xylene is released as air emissions during the
reporting year. Toluene is also present in the air emissions, but not monitored. The stack operates at
approximately 125NC. Based on literature data, the vapor pressures at 125NC for toluene is 1.44 atmospheres and
for xylene is 0.93 atmospheres. Using a ratio of the vapor pressures, the amount of toluene released as air
emissions from the stack can be calculated:
X Ibs/vr toluene = 1.44 atm (vapor pressure of toluene)
200 Ibs/yr xylene 0.93 atm (vapor pressure of xylene)
X Ibs/yr toluene = (200 Ibs/vr xvlene) x (1.44 atm toluene)
(0.93 atm xylene)
Completing the calculation, the facility determines that 310 pounds of toluene were released as stack air emissions
during the reporting year.
4.1.4.5 Estimating Releases 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 for each data element of the
Form R. The recommended approach is that you estimate the amounts released from all sources at
your facility by the data element on the form R (i.e., first estimate all fugitive emissions for a Section 313
chemical (Part n, Section 5.1), then estimate all stack air releases for a Section 313 chemical (Part II,
Section 5.2), etc.). Table 4-3 presents a work sheet that may be helpful in compiling this information.
If you submit a Form R, you must also enter on-site waste treatment information in Section 7 A,
including the code for each treatment method used, the treatment efficiency for the chemical in the
treated waste stream, and the concentration of the chemical in the influent sent to treatment. You
should report treatment methods that do not actually destroy or remove the chemical by entering "0" for
removal efficiency. Similarly, on-site energy recovery methods and on-site recycling methods must be
reported in Section 7B and 7C, respectively.
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Table 4-3
Release and Other Waste Management
Quantity Estimation Worksheet
Facility Name:
Toxic Chemical or Chemical Category:
CAS Number:
Reporting Year:
Date Worksheet Prepared:
Prepared by:
ON-SITE
Release or Other Waste Management
Activity Type
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses (spills, surface
impoundments)
Total =
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
Amount (Ibs)
Basis of
Estimate
Form R Element
5.1, (8.1 or 8. 8)
5.1, (8.1 or 8. 8)
5.1, (8.1 or 8. 8)
5.1, (8.1 or 8. 8)
5.2, (8.1 or 8. 8)
5.2, (8.1 or 8. 8)
5.2, (8.1 or 8. 8)
5.2, (8.1 or 8. 8)
5.2, (8.1 or 8. 8)
RECEIVING STREAM/WATER BODY DISCHARGE
Stormwater Discharge
On-Site Treatment Plant Discharge
Total =
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II -V Wei
ON-SITE LAND
Landfill
Land Treatment/Application Farming
Surface Impoundment
Other
Total =
ON-SITE ENERGY RECOVERY
ON-SITE RECYCLING
ON-SITE TREATMENT
s
5.3, (8.1 or 8. 8)
5.4, (8.1 or 8.8)
5.4, (8.1 or 8. 8)
5.5, (8.1 or 8. 8)
5.5,(8.1,8.6, or
8.8)
5.5,(8.1 or 8. 8)
5.5,(8.1 or 8. 8)
8.2
8.4
8.6
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OFF-SITE
Release or Other Waste
Management
Activity Type
Amount (Ibs)
Basis of
Estimate
Form R Data
Element
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
OTHER AMOUNTS SENT OFF-SITE
Amounts sent for storage
Amounts sent for unknown
waste management practice
6.2, (8.1 or 8. 8)
6.1, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
6.2, (8. lor 8. 8)
OFF-SITE TREATMENT
Solidification/Stabilization
Incineration/Thermal
Treatment
Incineration/Insignificant
Fuel Value
Wastewater Treatment (to
POTW excluding metals anc
metal compounds)
Wastewater Treatment
(Excluding POTW and meta
and metal compounds)
Transfer to Waste Treatmer
Broker
6.2,(8.7or8.8)
6.2, (8. 7 or 8. 8)
6.2, (8. 7 or 8. 8)
6.1, (8. 7 or 8. 8)
6.2, (8. 7 or 8. 8)
6.2, (8. 7 or 8. 8)
OFF-SITE ENERGY RECOVERY
Off-site Energy Recovery
Transfer to Energy Recover
Broker
OFF-SITE RECYCLING
Solvents/Organics Recover
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
6.2, (8. 3 or 8. 8)
6.2, (8. 3 or 8. 8)
6.2, (8. 5 or 8. 8)
6.2, (8. 5 or 8. 8)
6.2, (8. 5 or 8. 8)
6.2, (8. 5 or 8. 8)
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Transfer to Recycling Wast
Broker
6.2, (8. 5 or 8. 8)
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4.1.5 OTHER FORM R ELEMENTS
4.1.5.1 Maximum Amount On-Site (Part II, Section 4.1 of Form R)
In this section of the Form R, you are required to report the code that indicates the maximum
quantity of the EPCRA Section 313 chemical present at your facility at any time during the reporting
year. This estimate includes any amount of the chemical on-site in storage, in process vessels, in
treatment units, and in shipping containers. This calculation includes quantities of the EPCRA Section
313 chemical present in purchased chemicals and in wastes. When performing the calculation, use only
the total amount of the chemical present at your site at any one time. For example, in March your
facility receives a froth flotation mixture that contains 2,000 pounds of an EPCRA Section 313
chemical. By July, your facility uses 1,500 pounds of the chemical while the 500 pounds remain on-
site. In July your facility receives another shipment containing 2,500 pounds of the same chemical. If
you have no other sources of the EPCRA Section 313 chemical on-site, your maximum amount
estimation is equal to 3,000 pounds for the reporting year (range code 03). These codes are provided
in the TRI Forms and Instructions document.
Example - Maximum Amount On-Site for Landfills
How do coal mines that operate backfill operations using ash report the maximum amount of a chemical on-site?
Does this data element take into account amounts of a chemical that have been disposed of in prior years.
No. Coal mines do not have to count amounts of the EPCRA Section 313 chemical that it disposed of on-site in
previous years. Wastes that are released to such management units as surface impoundments and landfills
should be counted for the purposes of data element 4.1, Part II, of the Form R during the reporting year that they
are disposed.
4.1.5.2 Production Ratio or Activity Index (Part II, Section 8.9 of Form R)
For this data element, you are required to provide a ratio of reporting year production to prior
year production or provide an "activity index" based on a variable other than production that is the
primary influence on the quantity of the reported EPCRA Section 313 chemical recycled, used for
energy recovery, treated, or disposed. The ratio or index must be reported to the nearest tenths or
hundredth place (e.g., one or two digits to the right of the decimal point). Because the facilities added
by the facility expansion rulemaking were not required to collect data until RY 1998, these facilities may
enter "NA" in this data element regardless of whether the chemical existed at your facility in the
previous year (i.e., RY 1997). In future years, however, coal mining facilities may only enter "NA" in
the production ratio or activity index data element if the EPCRA Section 313 chemical was not
manufactured, processed, or otherwise used in the year prior to the reporting year for which a Form R
is being submitted.
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You may choose either the production ratio or activity index depending on the chemical and
how the chemical is used at your facility. The major factor in selecting whether to use a production
ratio or activity index is typically a measure of which threshold activity applies. Typically, production
ratio would apply to EPCRA Section 313 chemicals manufactured and processed by a facility, while
otherwise use activities would be best measured using an activity index. A key consideration in
developing a methodology for determining a production ratio/activity index is that you should choose a
methodology that will be least likely to be affected by potential source reduction activities. In most
cases, the production ratio or activity index should be based on some variable of production or activity
rather than on toxic chemical or material usage.
For example, suppose you use an EPCRA Section 313 chemical as a cleaning solvent to
perform tank washouts. Using a production ratio based on the amount of the product produced in the
tanks between the prior and current reporting years may seem logical but may not take into
consideration potential source reduction activities. As a result, an activity index may be more
appropriate. In this instance, an activity index based on the number of tank washouts conducted would
be more accurate in reflecting the potential source reduction activities that could be implemented for
that chemical and/or activity. For example, a source reduction activity might include the facility deciding
to modify the production process such that they would need to clean the process equipment less often
and, therefore, use less cleaning solvent. The use of an activity index based on the number of
equipment washings would better reflect the factors that influence the amount of solvent managed as a
waste than would a production ratio based on the amount of product used in the washings.
Example - Production Ratio
A coal mine facility applies ethylene glycol to their coal on-site to prevent freezing for on-site storage. The
facility estimates that it shipped 120,000 tons of coal in the previous year during winter months in which an anti-
freezing agent was typically applied and 150,000 tons for the current year. As a result, the production ratio for
this EPCRA Section 313 chemical can be calculated by dividing the tons of coal shipped during winter months
this year by tons of coal shipped during winter months last year.
150,000 tons (current reporting year)
120,000 tons (previous reporting year)
Production Ratio =1.25
4.1.5.3 Source Reduction (Part II, Sections 8.10 and 8.11 of Form R)
The final two sections of the Form R are used for reporting any source reduction activities
conducted at the facility. Section 8.10 asks whether there has been any source reduction at the facility
during the current reporting year. If so, TRI Forms and Instructions provides a list of three-digit
codes that the facility must choose from to describe these source reduction activities. Source reduction
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activities do not include recycling, treating, using for energy recovery, or disposing of an EPCRA
Section 313 chemical. Report in this section only the source reduction activities implemented to reduce
or eliminate the quantities reported in Section 8.1 through 8.7.
Under Section 8.11, check "yes" if you would like to attach any optional information on source
reduction, recycling, or pollution control activities for the EPCRA Section 313 chemical at your facility.
This information can be reported for the current reporting year, or for prior year activities. The Agency
asks that you limit this information to one page that summarizes the source reduction, recycling, or
pollution control activities implemented by your facility.
4.2 Calculating Release and Other Waste Management Estimates at Coal Mines
This section discusses the most common releases and other waste management activities at coal
mining facilities, and gives guidance for estimating these quantities. The discussion is organized by
release or other waste management type, as follows:
Fugitive Air Emissions
Stack or Point Source Air Emissions
Water Discharges
Releases to Land
On-site Waste Management
Transfers Off-site
Pollution Prevention Data
Facilities must report all releases and other waste management quantities of any EPCRA
Section 313 chemicals that exceed activity thresholds at the facility. As mentioned earlier in Chapter 4,
process flow diagrams are a very useful way for facilities to identify all sources of releases and other
waste management activities. Figures 4-3 and 4-4 present generic process flow diagrams for the
beneficiation of coarse and intermediate grade coal and fine grade coal and illustrate common
operations and release and other waste management outputs.
4.2.1 Coal Mining Overview
Extraction. Coal extraction involves accessing and removing ore deposits from below the
surface. Raw coal is generally obtained by surface, strip, or underground mining. During surface or
strip mining, the overburden is removed to expose the coal deposits while underground mining involves
creating a series of shafts and corridors to access the coal seam. EPA provided coal mining operations
with an extraction exemption because coal extraction activities do not typically involve the presence or
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use of listed toxic chemicals in reportable concentration and very little additional information would be
made available from their inclusion. As a result, the management of materials involved in coal extraction
are exempt from threshold determinations and release and other waste management activities. For
example, blasting agents used to break up the overburden and coal during the extraction process would
be eligible for the extraction exemption, as would EPCRA Section 313 chemicals used to maintain drag
lines, drills, electric shovels, and trucks during extraction. For example, materials that are removed
during extraction (e.g., overburden) are exempt from threshold determinations and release and other
waste management calculations. Overburden that is removed and placed in a pile that is subsequently
disposed of as fill material is exempt from reporting because its disposal is exempt under the extraction
exemption.
As a point of clarification, some very similar materials may be involved in more than one
activity. As a result, materials that may be exempt when associated with one activity may not be when
used or otherwise managed during another. One example of this are belt lines that may be used to
transport coal from underground mines. Chemicals used to maintain these belt lines during extraction
are considered eligible for the extraction exemption. Belt lines may also be used after a crushing or
sizing activity, which is not considered part of extraction; therefore, chemicals used to maintain belt lines
not associated with extraction must be considered toward threshold determinations and release and
other waste management calculations.
Transportation. Although coal beneficiation plants are generally at or near coal mines, the
coal still must be transported from the mine to the plant either by truck, rail, or conveyer system (belt
lines) depending on distance and terrain. In addition, clean coal must be transported from the site after
beneficiation.
Coal Preparation Coal preparation includes all the methods utilized to upgrade or clean the
raw coal in order to improve the energy value and to remove non-coal impurities. The first step of coal
preparation is often size reduction. This is often followed by screening/ classification, coal/impurity
removal (cleaning), and drying. Activities are different depending on the coal particle sizes and not all
plants conduct all activities. Some plants may only size and classify the coal while others may
undertake all four stages.
The run-of-mine coal must be crushed, ground and/or broken in order to prepare the coal for
the washing process. Size reduction allows the plant to handle the coal more easily while at the same
time helps to remove impurities by breaking the coal down into smaller pieces. This process is
performed using large machines, such as rotary brakers and rollers and can be conducted either in the
open or in enclosed structures. All crushing is considered beneficiation under EPCRA Section 313,
regardless of where it occurs. While some size reduction activities occur inside mines during extraction,
these activities are still considered part of the beneficiation process and are not eligible for the coal
extraction activities exemption under EPCRA Section 313 reporting.
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Following size reduction, the raw coal is screened or classified. Screening is performed to
match size specifications of cleaning equipment and also to meet market demand. Generally the coal is
divided into three groups; coarse (>10 mm), intermediate (0.6-10 mm) and fine (<0.6 mm). Some
plants, however, make only coarse and fine grade distinctions, or none at all.
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Ffgue 4-i Cod Preparation Flowsheet for Coarse ft lntmned.tfrGrafcCod
4-30
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Figure 44 Coal Preparation Flow shoot for Fho-Grado Coal
4-31
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Classification mechanisms used include screening through a mesh of perforated plates or metal
wires/rods of fixed aperture. These activities can be carried out in open or enclosed structures and
either wet or dry. The coal is now ready to be cleaned in house or transported to another facility.
Coal Cleaning. At this stage, the coal is cleaned and impurities, such as sulfur and ash-forming
elements, must be removed. The sulfur content in the run-of-mine coal can be in three forms: pyritic
sulfur, sulfates, and organic sulfur. In the U.S., the total sulfur in coal is generally high but varies from 1-
4 percent, with Eastern (Appalachian) coal having a higher percentage of sulfur than Western coal.
There are two types of coal washing performed on intermediate and coarse coal: gravity
concentration and dense medium separation. Some media used may contain EPCRA Section 313
chemicals that must be considered toward the facility's otherwise use threshold. These methods rely on
differences in specific gravities between the coal and the refuse minerals.
Gravity concentration methods used to clean coal include jigs, cyclones, shaking tables, and
Reichert cones. A significant portion of coal preparation plants use jigs to separate coal from non-coal
material. The majority of jigs process wet coal, but some pneumatic jigs are used. Like jigs, the
shaking tables, cyclones, and Reichert cones rely on water flow and motion of the equipment to
separate more dense impurities from the lighter coal.
Another commonly used method is dense medium separation. This process usually occurs in a
large, open tank, and pulverized magnetite in water is the preferred medium in industrial coal separation.
The density of the medium is adjusted to lie between the dense inorganic matter and the less dense
organic, combustible fraction of coal. As a result, the inorganic material sinks to the bottom of the tank
and the organic coal floats to the top of the tank where it is skimmed from the tank.
Fine coal cleaning involves chemical conditioning of the coal followed by flotation to recover
clean coal. These steps remove the inorganics.
Depending on the characteristics of the coal, some mines may perform fine coal conditioning
using lime, sodium carbonate, sodium hydroxide, or sulfuric acid. Conditioning is used to adjust pH, so
as to facilitate the flotation process.
Froth flotation is a widely used method of flotation in coal preparation facilities and may contain
EPCRA Section 313 chemicals above de minimis levels. Flotation typically will be conducted using
air, water, coal slurry, and flotation agents (e.g., collectors, activators, depressants, dispersants, or
flocculents) specially selected to recover the desired fine coal. Collectors (promoters), such as fuel oil
and kerosene, cause adherence between the fine coal particles and the air bubbles. Depressants,
including amyl xanthate, are used to depress or cause the inorganic impurities to sink to the bottom of
the tank. Activators promote flotation in the presence of collecting agents. Pine oil is a common frother
that stabilizes air bubbles by reducing surface tension, thus allowing froth formation. During froth
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flotation, the coal-water slurry is passed through a series of "rougher" and "cleaner" cells that are
sparged with air from below. Particles in this slurry are preferentially wetted by various agents causing
the hydrophobic coal particles to adhere to the surfaces of air bubbles. As the air bubbles rise to the
surface, the coal slimes are transported to the surface and are removed by skimming with a mechanical
scraper, removing much of the flotation agent.
Coal Drying. The purpose of drying is to remove excess moisture and prepare the cleaned
coal for shipment. All cleaning operations utilizing water require some type of mechanical or thermal
drying.
Coarser coal is predominantly dried using mechanical methods including drying screens, and
centrifuge drying. Generally, no EPCRA Section 313 chemicals are added during coarse coal drying.
Several techniques are available to accomplish fine coal drying such as vacuum filtration and
thermal drying. Vacuum filtration is used for drying the cleaned fines and of the tailings. Tailings drying
is preceded by thickening (as discussed earlier). Flocculents are frequently used as filter aids, but they
are not likely to contain EPCRA Section 313 chemicals above de minimis levels.
At this stage, the fine coal has been cleaned using froth flotation and perhaps dried using
vacuum filtration. Due to the large surface area of the small particles, further drying is needed. Thermal
drying is especially successful at drying fine particles. Generally, coal preparation plants reserve
thermal drying as the final step for drying fine coal. This process involves combusting a portion of coal
in furnaces to sufficiently dry the wet coal to marketable levels. If thermal drying is used, elaborate ash
collection is required and the facility must be aware of all the wastes generated (see Chapter 3 for
EPCRA Section 313 chemical manufacturing during coal combustion). Figure 4-5 presents a process
flow diagram for thermal drying using a coal-fired furnace. Usually, the more coarse coal does not
undergo as extensive drying process as the fines. More advanced techniques, including thermal drying,
must be used with fines because they possess a greater surface area to volume ratio then more coarse
coal.
Extracted coal often will be stored in large coal piles. This storage will occur throughout the
coal beneficiation operation as the coal is processed prior to distribution into commerce. Depending
on regional weather conditions, ethylene glycol may be sprayed on coal to prevent freezing during
storage and transit within the facility and to the customer off-site.
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Air
Scrubber
LEGEND
Point-source
->Wastewater
Fly Ash
Collection
(Cyclone)
Fly Ash
A
(Fire Side)
Bo ler
(Coal
Drying)
Coal Run-off
Oil Filtrate
Bottom Ash
Boiler Slag
-*Wet Coal
_^ Coal
Product
Boiler Slowdown
Waste
Figure 4-5 Furnace Used for Thermal Dewatering
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Coal is generally expected to contain EPCRA Section 313 chemicals in concentrations below
current de minimis levels and, therefore, these chemicals are likely to be exempt from release and other
waste management calculations. While the EPCRA Section 313 chemicals present in the coal are
generally below de minimis and, therefore, likely to be exempt from processing activities, many of the
chemicals used to prepare the coal for distribution into commerce and to maintain the facility's
operations will exceed the applicable activity thresholds and require calculation of releases and other
waste management activities.
4.2.2 Fugitive Air Emissions, Section 5.1 of Form R
Fugitive air emissions can occur from a number of sources. The primary air emissions sources
for EPCRA Section 313 chemicals at coal mining facilities are discussed in the paragraphs below.
Fugitive air emissions that take place during extraction are eligible for the coal mining extraction
exemption, and these amounts do not have to be considered toward threshold determinations and
release and other waste management calculations. When dry mining processes are involved, fugitive
particulate matter may be appreciable during crushing and sizing activities, as well as transportation,
from stock piles, and conveyor pour-offs. However, many facilities reduce the potential for fugitive
emissions by using a wet process or by enclosing the process area and circulating the air through fabric
filters.
As previously mentioned, coal is generally expected to contain EPCRA Section 313 chemicals
in concentrations below de minimis levels. Therefore, these chemicals are likely to be exempt from
threshold determinations and release and other waste management calculations.
If coal is transported by belt lines, the amount of EPCRA Section 313 chemicals released from
materials used to maintain this belt must be reported on the Form R. Depending on the volatility of the
chemical, it may volatilize to air and be reported as fugitive air emissions in Section 5.1 of the Form R.
Depending on regional weather conditions, ethylene glycol may be sprayed on coal to prevent
freezing in transport and storage. Fugitive air emissions from the application of these chemicals are
possible due to overspray or volatilization. Based on the quantity of chemical used and given the low
volatility of ethylene glycol, fugitive air emissions are expected to be low. Based on the quantity applied
during the reporting year, an estimate could be derived using best engineering judgement.
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Flotation could generate fugitive
air emissions of the various flotation agents
along with releases to wastewater. Air
emissions of volatile EPCRA Section 313
chemicals from wastewater treatment units
could be estimated using one of several
programs. One program is WATERS
(described in the box). Other programs
are available commercially.
WATERS
A computer program, WATERS, is available for estimating
the fate of organic compounds in various wastewater
treatment units, including collection systems, aerated basins,
and other units. WATERS is written to run under DOS
without the need to purchase other programs. WATERS
contains useful features such as the ability to link treatment
units to form a treatment system, the ability to recycle among
units, and the ability to generate and save site-specific
compound properties. The WATERS program and users
manual can be downloaded from the world wide web at
http://www.epa. gov/ttn/chief/software.html#water8.
Releases From Transportation Vehicles
A facility is responsible for reporting releases and other waste management activities for an EPCRA Section 313
chemical that occur during loading or unloading of a transportation vehicle provided an activity threshold has
been exceeded for that chemical. Releases of an EPCRA Section 313 chemical from a transportation vehicle that
occur while the material is still under "active shipping papers" is considered to be in transportation and is not
subject to EPCRA Section 313 requirements (EPCRA Section 327). For example, a facility shipping ash containing
nickel oxide for direct reuse off site is not responsible for reporting releases once the shipping papers have been
signed. The facility is responsible for reporting releases of EPCRA Section 313 chemicals, including those that
occur during storage of the chemicals in the transportation vehicle while the vehicle is on property owned or
operated by the facility, up until the point that the shipping papers have been signed.
4.2.3 Stack or Point Source Air Emissions, Section 5.2 of Form R
Stack emissions occur primarily from the coal drying combustion stack sources, if applicable,
and storage tanks. Each is discussed below.
Stack Emissions from Combustion. Amounts of EPCRA Section 313 chemicals not caught in
particulate control devices or in flue gas desulfurization (FGD) systems exit as stack emissions. Some
EPCRA Section 313 chemicals manufactured during fuel combustion include hydrogen fluoride,
hydrochloric acid (acid aerosols), sulfuric acid (acid aerosols), numerous metal compound categories
(e.g., selenium compounds), and formaldehyde. As previously discussed in Chapter 3, the amount of
EPCRA Section 313 chemicals manufactured should be based on the best "readily available data" on
constituents and associated concentrations of the coal or other fuel sources. Using specific data on the
fuels combusted will be extremely useful in identifying the type and quantity of EPCRA Section 313
chemicals manufactured and ultimately released as stack emissions or otherwise managed as wastes.
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Releases of EPCRA Section 313 chemicals to the air may be calculated using a number of
methods. It is the responsibility of each facility to determine the best data to use. The best data source
would be facility-specific monitoring data if enough data were available to sufficiently characterize the
emissions on an EPCRA Section 313 chemical-specific basis. Unfortunately, these types of data are
rarely available. One of the best practical alternatives is emission factors for the particular type of fuel
that is being combusted. This document presents many of these emission factors as default values to
consider if no other data exist or are "readily available". Other sources, such as the Electrical Power
Research Institute's (EPRI) PISCES database, provide emission factors and models to calculate air
emissions, including stack emissions.
When other data are not available,
EPA has emission factors which can be
applied in calculating stack emission
estimates. EPA's Compilation of Air
Pollutant Emission Factors (AP-42)
provides emission factors for many
chemicals resulting from various
combustion fuel sources, including coal.
Table 4-4 presents AP-42 emission factors
for metals released during combustion of
coal. Table 4-5 presents emissions factors
for various organic compounds during
controlled coal combustion. These tables
are specific to certain conditions (e.g., coal
classification, boiler configuration).
Combustion of coal may also result
in emissions of sulfuric acid (acid aerosol),
hydrochloric acid (acid aerosol), and hydrogen fluoride (HF). The quantities of these chemicals must
be applied to the manufacturing
threshold (as discussed in Section 3 of this document). To estimate stack air emissions of these acids
when no better data are available, assume the amount released is the amount manufactured minus
amounts removed by air control devices. Efficiency estimates for air pollution control devices can be
obtained from monitoring data, vendor specifications, and air permit applications. Note that chlorine
(7782-50-5) and fluorine (7782-41-4) may also be formed. Facilities must use their best available
information to estimate these quantities.
Use of AP-42 Emission Factors
The general equation for emission estimation is:
E = AxEFx(l-ER/100)
where:
E = emissions,
A = activity rate,
EF = emission factor, and
ER = overall emission reduction
efficiency, %.
ER is further defined as the product of the control device
destruction or removal efficiency and the capture
efficiency of the control system. When estimating
emissions for a long time period (e.g., one year), both the
device and the capture efficiency terms should account
for upset periods as well as routine operations. Note that
some emission factors already incorporate a removal
efficiency term.
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Table 4-4
EPCRA Section 313 Metal Emission Factors for Combustion of Coal
CONTROLLED COAL COMBUSTION3
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Chromium (VI)
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Emission Factor
(lb/ton)b
1.8E-05
4.1E-04
N/A*
2.1E-05
5.1E-05
2.6E-04
7.9E-05
l.OE-04
N/A*
4.2E-04
4.9E-04
8.3E-05
2.8E-04
1.3E-03
Emission Factor Rating
A
A
N/A*
A
A
A
D
A
N/A*
A
A
A
A
A
Source: AP-42 Chapter 1, External Combustion Sources.
'The emission factors were developed from emissions data at eleven facilities firing
bituminous coal, fifteen facilities firing subbituminous coal, and from two facilities
firing lignite. The factors apply to boilers utilizing either venturi scrubbers, spray
dryer absorbers, or wet limestone scrubbers with an electrostatic precipitator (ESP)
or Fabric Filter (FF). In addition, the factors apply to boilers using only an ESP,
FF, or venturi scrubber. SCCs = pulverized coal-fired, dry bottom boilers,
1-01-002-02/22, 1-02-002-02/22, 1-03-002-06/22; pulverized coal, dry bottom,
tangentially-fired boilers, 1-01-002-12/26, 1-02-002-12/26, 1-03-002-16/26;
cyclone boilers, 1-01-002-03/23, 1-02-002-03/23, 1-03-002-03/23; and,
atmospheric fluidized bed combustors, circulating bed, 1-01-002-18/38,
1-02-002-18, and 1-03-002-18.
*N/A - data not available for this metal
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Table 4-5
Emission Factors for Organic EPCRA Section 313 Chemicals
from Controlled Coal Combustion
Pollutant15
Acetaldehyde
Acetophenone
Acrolein
Benzene
Benzyl chloride
Bromoform
Carbon disulfide
2-Chloroacetophenone
Chlorobenzene
Chloroform
Cumene
2,4-Dinitrotoluene
Dimethyl sulfate
Ethyl benzene
Formaldehyde
Hexane
Methyl ethyl ketone
Methyl hydrazine
Methyl methacrylate
Methylene chloride
Phenol
Propionaldehyde
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Styrene
Emission Factoi* (Ib/ton)
5.7E-04
1.5E-05
2.9E-04
1.3E-03
7.0E-04
3.9E-05
1.3E-04
7.0E-06
2.2E-05
5.9E-05
5.3E-06
2.8E-07
4.8E-05
9.4E-05
2.4E-04
6.7E-05
3.9E-04
1.7E-04
2.0E-05
2.9E-04
1.6E-05
3.8E-04
4.3E-05
2.4E-04
2.0E-05
2.5E-05
Emission
Factor Rating
C
D
D
A
D
E
D
E
D
D
E
D
E
D
A
D
D
E
E
D
D
D
D
A
E
D
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Pollutant15
Xylenes
Vinyl acetate
Emission Factor* (Ib/ton)
3.7E-05
7.6E-06
Emission
Factor Rating
C
E
1 Source: AP-42 Chapter 1, External Combustion Sources. Factors were developed from emissions data from ten sites firing
bituminous coal, eight sites firing subbituminous coal, and from one site firing lignite. The emission factors are applicable to boilers
using both wet limestone scrubbers or spray dryers and an electrostatic precipitator (ESP) or fabric filter (FF). In addition, the factors
apply to boilers utilizing only an ESP or FF. SCCs = pulverized coal-fired, dry bottom boilers, 1-01-002-02/22, 1-02-002-02/22,
1-03-002-06/22; pulverized coal, dry bottom, tangentially-fired boilers, 1-01-002-12/26, 1-02-002-12/26, 1-03-002-16/26; cyclone
boilers, 1-01-002-03/23, 1-02-002-03/23, 1-03-002-03/23; and, atmospheric fluidized bed combustors, circulating bed,
1-01-002-18/38, 1-02-002-18, and 1-03-002-18.
bPollutants sampled for but not detected in any sampling run include: Carbon tetrachloride- 2 sites; 1,3-Dichloropropylene- 2 sites;
N-nitrosodimethylamine- 2 sites; Ethylidene dichloride- 2 sites; Hexachlorobutadiene- 1 site; Hexachloroethane- 1 site; Propylene
dichloride- 2 sites; 1,1,2,2-Tetrachloroethane- 2 sites; 1,1,2-Trichloroethane- 2 sites; Vinyl chloride- 2 sites; and,
Hexachlorobenzene- 2 sites.
'Emission factor should be applied to coal feed, as fired. To convert from Ib/ton to kg/Mg, multiply by 0.5.
AP-42: Emission Factor Quality Ratings for Tables 4-4 and 4-5
A Excellent. Factor is developed from A- and B-rated source test data taken from many randomly chosen facilities i i the
industry population. The source category population is sufficiently specific to minimize variability.
B Above average. Factor is developed from A- or B-rated test data from a "reasonable number" of facilities. Althoi
specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with an A
the source category population is sufficiently specific to minimize variability.
C Average. Factor is developed from A-, B-, and/or C-rated test data from a "reasonable number" of facilities. Althi
specific bias is evident, it is not clear if the facilities tested represent a random sample of the industry. As with the P
the source category population is sufficiently specific to minimize variability.
D Below average. Factor is developed from A-, B- and/or C-rated test data from a small number of facilities, and the
be reason to suspect that these facilities
variability within the source population.
E Poor. Factor is developed from C- an<
not represent a random sample of the ind
population.
Storage Tanks. Coal
mining facilities should consider
point source air emissions from
tanks that store materials
containing volatile chemicals, such
as flotation and conditioning
agents. AP-42 provides detailed
information on the calculation of
air emissions during the storage
and transfer of liquids. A number
TANKS3
The TANKS3 program is designed to estimate emissions of organic
chemicals from several types of storage tanks. The calculations are
performed according to EPA'sAP-42, Chapter 7. After the user
provides specific information concerning a storage tank and its liquid
contents, the system produces a report which estimates the chemical
emissions for the tank on an annual or partial year basis. The user
can also determine individual component losses by using one of the
specification options available in the program.
The TANKS3 program relies on a chemical database of over 100
organic liquids and a meteorological database which includes over
250 cities in the United States; users may add new chemicals and
cities to these databases by providing specific information through
system utilities. On-line help provides documentation and user
assistance for each screen of the program. The TANKS3 program and
manual can be downloaded from the world wide web at
http://www.epa.gov/ttn/chief/tanks.html.
ghno
rating,
ugh no
rating,
emay
ice of
ed do
4-40
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of equations used to calculate air emissions from storage tanks can be found in AP-42, Chapter 7.
Total emissions from storage tanks are equal to the sum of the standing storage loss and working loss.
Variables such as tank design, liquid temperature, and wind velocity are taken into account when
determining standing storage loss and working loss. The emission equations for fixed-roof tanks in AP-
42 were developed for vertical tanks; however, the equations can also be used for horizontal tanks by
modifying the tank parameters as specified in AP-42. Many of these equations have been incorporated
into computer models such as TANKS3 (See box on TANKS3 for more information).
Once the total volatile organic compound (VOC) loss is calculated, you can determine the
emission rate of each constituent in the vapor. In general, the emission rate for individual components
can be estimated by multiplying the weight fraction of the constituent in the vapor by the amount of total
VOC loss. The weight fraction of the constituent in the vapor can be calculated using the mole fraction
and the vapor pressure of the constituent (equations found in AP-42). The weight percent can also be
obtained from the SPECIATE database. The SPECIATE database contains organic compound and
particulate matter speciation profiles for more than 300 source types. The profiles attempt to break
down the total VOC or particulate emissions from a particular source into the individual compounds.
The SPECIATE database can be downloaded from the world wide web at
http://www.epa.gov/ttn/chief/software.htmWspeciate.
4.2.4 Discharges to Receiving Streams or Water Bodies, Section 5.3 of Form R; and
Discharges to Publicly Owned Treatment Works (POTWs), Section 6.1 of Form R
Wastewaters discharged include process wastewater, coal pile run-off, and storm water. Each
is discussed below.
Process Wastewater. Process wastewater are generated at several operations at coal mines
including the following:
Froth flotation results in wastewater streams containing coal and flotation agents. This
could generate fugitive air emissions of the various flotation agents along with releases
to wastewater.
Coal is often conveyed and managed in a wet state; dewatering the coal will result in
wastewater that contains metal compounds and possibly other EPCRA Section 313
chemicals that were used in preparing the coal for distribution into commerce.
Coal washing and rinsing generates wastewater that may contain manufactured metal
compounds.
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Flocculents used as filter aids during vacuum filtration that contain EPCRA Section 313
chemicals are reportable when released
in wastewater to a receiving stream or
POTW provided thresholds have been
excluded.
Example Calculation of Yearly Wastewater
Discharge
A facility has monitoring data on discharges to water of xylene,
a listed EPCRA Section 313 chemical, and a Form R report is
required. In this example, monitoring data on this chemical are
only available for two days in the year. The daily quantities of
pounds of xylene released for those two dates would then be
divided by the number of sample dates to determine the daily
average for the whole reporting year, which would be used to
estimate the annual discharge of xylene in wastewater:
A facility that discharges or has
the potential to discharge water
containing regulated wastes must
operate under the terms of Federal,
State, and/or local permits, such as a
NPDES direct discharge permit, or a
POTW indirect discharge agreement.
The permit(s) or agreement usually
require measurements of the water
volume and monitoring of some
generalized wastewater parameters
including concentrations of various
constituents. In some cases, the
constituent analyses required for permit
compliance includes EPCRA Section
313 chemicals. In other cases, facilities
may have conducted more detailed analysis of specific constituents in its wastewaters as part of its
NPDES or POTW discharge applications. In these instances, releases can be calculated by multiplying
the volume of wastewater released by the concentration of the chemical released. Otherwise, the
facility should use their best "readily available data" in making these estimates as needed. See text box
for an example calculation.
Date
3/1
9/8
Concentration
(mg/1)
1.0
0.2
Flow
(MGD)
1.0
0.2
Daily
Discharge
8.33 Ibs.
0.332 Ibs.
Annual Calculation:
Based on the concentration and wastewater flow data available, an estimate of discharges to
water can be calculated. Facilities should calculate the daily average discharges of a reportable
EPCRA Section 313 chemical in pounds and should use those estimates to determine the annual
discharge in pounds per year. Using the daily concentration data available for the reportable chemical
combined with the wastewater flow data for each of the sampling dates, calculate an estimate of pounds
per day for each sampling date. After the calculations are made for each monitoring point (e.g., daily,
monthly), the pounds discharged are averaged to determine an average daily discharge amount, which
would be multiplied by the number of days discharges were possible (e.g., 365 days a year).
If no chemical-specific monitoring data exist, process knowledge (or in some cases, mass
balance) may be used to develop an estimate.
4-42
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Discharges of listed acids may be reported as zero if all discharges have been neutralized to pH
6 or above. If wastewater containing a listed acid is discharged below pH 6, then releases of the acid
must be calculated and reported except for hydrochloric and sulfuric acid, which are only reportable in
the aerosol form. For more information on calculating such discharges of acids, see EPA's Estimating
Releases of Mineral Acid Discharges Using pH Measurements (EPA 745/F-97-003, June 1991).
Reminder: Reporting of Aqueous Ammonia
Facilities may use ammonia or ammoniated cleaners during boiler cleaning. When reporting releases and
other waste management activities of ammonia, remember to report only 10 percent of the total amount of
ammonia if released or managed in aqueous form.
No releases to water of chlorine are typically expected. Chlorine reacts very quickly with
water to form HOC1, Cl", and FT. Although this is an equilibrium reaction, at a pH above 4 the
equilibrium shifts almost completely toward formation of these products. Therefore, essentially zero
releases of chlorine to water are expected to occur under normal circumstances.
Coal Pile Runoff. As discussed in Chapter 3, coal stored in exposed piles may be subject to
rainfall, snowfall, spraying for dust control or to prevent freezing, which may create acidic leachate that
flows in underground streams or that collect under the piles, forming runoff. The dissolution of the metal
compounds typically found in coal may lead to the manufacture of metal compounds. As a result, on-
site storage of coal may result in coal pile run-off containing reportable EPCRA Section 313 chemicals.
If you believe that conditions exist at your facility that generate and/or release EPCRA Section 313
chemicals from coal piles, then you should include this as a source of making threshold determinations
and release and other waste management calculations. In doing so you may apply data used for
threshold determinations. If you believe that these releases result in releases to surface water, you may
combine these data with data on the estimated quantity of runoff to derive an estimate of EPCRA
Section 313 chemicals released.
Storm Water Runoff. Storm water runoff at coal mining facilities may contain EPCRA
Section 313 chemicals washed from outdoor materials such as coal or other raw materials, waste, and
land features. You must report the amount of non-exempt EPCRA Section 313 chemicals in storm
water runoff (including unchanneled runoff). If you do not have periodic measurements of storm water
releases, but have chemical-specific monitoring data on the reportable EPCRA Section 313 chemicals,
you should use these data to calculate the quantity discharged and the percent contribution from storm
water to the overall water discharge estimate. See the current TRI Forms and Instructions document
for guidance on calculating storm water runoff.
4-43
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4.2.5 Disposal to Land On-site, Section 5.5 of Form R
Coal mines dispose of reclamation wastes, tailings, combustion wastes, and other wastes.
Accidental releases can also lead to Section 313 chemicals being disposed of to land on-site. Each of
these are discussed below.
Reclamation Wastes. The use of various materials for mine reclamation constitutes an
otherwise use activity as outlined in Chapter 3 of this document. The direct application of these
materials in the mine or on the land constitutes a release to land and may require reporting in Section
5.5 of the Form R. The disposal of overburden displaced to gain access to coal on-site, while possibly
aiding in the backfilling or reclamation of a completed area, is considered covered by the coal
extraction activities exemption, and the amount of any EPCRA Section 313 chemicals that may be
present in the overburden is exempt from threshold determinations and release and other waste
management calculations. However, ash either generated on-site or received from off-site for
reclamation purposes is not eligible for the coal extraction activities exemption and must be considered
toward the facility's release to land calculations. Additionally, quantities of EPCRA Section 313
chemicals in ash received from off-site for reclamation must also be considered toward the facility's
otherwise use threshold because it is considered a waste received from off-site for the purposes of
waste management. EPCRA Section 313 chemicals in wastes that are otherwise used must be
considered towards threshold and release and other waste management calculations regardless of their
concentrations (i.e., they are not eligible for the de minimis exemption).
Tailings. After the flotation, tailings (in a wastewater slurry) may be sent directly to a tailings
impoundment or to a thickener. To accelerate settling and agglomeration, the thickening process may
use chemicals in addition to those used for froth flotation. Releases of thickening agents must also be
reported on the Form R once the otherwise use threshold has been exceeded or another threshold has
been exceeded elsewhere for that chemical. Some of these chemicals may be disposed with the
tailings. After thickening, the tailings are then generally sent to a tailings impoundment.
Combustion Wastes. Many coal mines dispose of coal ash containing EPCRA Section 313
chemicals on-site. Bottom or fly ash may be disposed in on-site landfills, surface impoundments, ash
ponds, or other waste management units. Some facilities may also dispose boiler slag (bottom ash
particles in a molten state) containing EPCRA Section 313 chemicals.
Facilities must report all non-exempt releases of EPCRA Section 313 chemicals in ash that are
disposed on-site, regardless of their concentration, provided thresholds have been exceeded for these
chemicals.
4-44
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Facility specific information, such as waste analyses and process knowledge, can be used to
estimate amounts of EPCRA Section 313 chemicals in combustion wastes. In the absence of data
determined to be better, facilities can use default values for concentrations of metals in ash, presented in
Table 4-6.
Table 4-6
Total Constituent Concentrations of Elements in Combustion
Residuals
Element
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
Fly Ash (ppm)
131
6,300
13,800
130
900
2,200
2,120
3,000
12
4,300
134
36
1,180
3,500
Bottom Ash (ppm)
10
168
9,360
10
5,820
932
1,082
1,940
4.2
2,939
14
9.9
537
1,796
Source: Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume 1, Critical Review,
Battelle, Pacific Northwest Laboratory forEPRI, EA5176, August 1987.
Other Wastes. Coal mines may also dispose of other wastes such as filtration and coagulation
residues, settled materials, and ethylene glycol from coal pile runoff. To calculate quantities of EPCRA
Section 313 chemicals in these wastes, facilities can use waste analyses, process knowledge, operating
records, pollution prevention data, mass balance, or other sources provided it is determined to be the
facility's best "readily available data".
4-45
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You must report the ultimate known disposition of an EPCRA Section 313 chemical in the
reporting year. In other words, you may need to consider any cross-media transfers that may result
from land disposal. If a waste has been disposed in a land disposal unit, but a portion of that waste
volatilizes into the air or discharges to a surface water, the ultimate disposition of the reportable
EPCRA Section 313 chemical during the reporting year must be reported for the year in which the
waste was disposed. Therefore, only the quantity that remains in a surface impoundment, ash pond, or
other land disposal unit must be reported as a release to land, while the amount that is released to
another media must be reported as released to that media.
Accidental Releases to Land.
Leaks, spills, and drips from the loading
and transfer of materials or wastes at the
facility should be considered and reported
in your release estimates. Data
concerning specific incidents (such as
notification reports or incident logs)
should be used to estimate releases. In
calculating quantities related to accidental
releases, you are required to report the
ultimate disposition in the reporting year
that the EPCRA Section 313 chemical(s)
are released. For instance, releases to
land (e.g., Other Disposal, Section 5.5.4
of Form R), would only include the
quantity of spilled material that was not
cleaned up as a response to the accident.
Equations found in Section 6 of EPA's
Estimating Releases and Waste
Treatment Efficiencies for the Toxic
Chemical Release Inventory Form,
provide guidance on calculating releases from chemical spills or leaks for determining how to partition
amounts for different reporting elements, including liquid discharges, fraction of discharge flashed,
vaporization, two-phase discharges, and gas discharges.
4.2.6 Transfers Off-site, Section 6.2 of Form R.
Example - Seepage From a Landfill
If a facility in one of the new industries, which begins
reporting for activities conducted in 1998, has informatioi
on the amount of seepage from a landfill in 1998, do they
report this amount as a release to land, since they were
not required to report the initial disposal to land in the
previous year?
No, facilities are required to report only the amounts
which are disposed during the year in which they are
disposed, provided certain thresholds have been meet
and the facility does not conduct any further activities
involving amounts previously disposed. Amounts
which move within the same media, such as seepage
from a landfill to surrounding soils do not have to be
included in release estimates in subsequent years. EPA
requires reporting of the amount of EPCRA Section 313
chemical placed in an on-site landfill during the year. It
is not necessary to estimate migration from the landfill in
subsequent years, provided the facility does not
conduct activities that further involve the EPCRA
4-46
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Coal mines do not generally send large
amounts of waste off site. Two types of waste that
could be sent off site and are discussed below.
Hazardous Wastes While most wastes from
coal mining operations will be disposed of on-site,
some facilities may generate hazardous wastes, which
must be sent off site for further waste management. The
quantity of the waste can be obtained from manifests
and the composition can be obtained from analyses,
waste profiles, or process knowledge.
Waste Management Codes for
Metals
Metals and metal compounds in wastewater
sent off-site for treatment should be reported
using code M62 - "Wastewater Treatment
(Excluding POTW) - Metals and Metal
Compounds Only". Similarly, metals in solids
sent off-site for solidification or stabilization
should be reported using code M41 -
"Solidification/Stabilization - Metals and
Metal Compounds Only".
Scrap Metal. In crushing operations, a mine
may use high alloy metals in their brakers or rollers. Due to the nature of the process, some parts of
this machinery which are in contact with the coal will frequently break off or wear out. When this
occurs, scrap metal is generated. If a threshold has been exceed for the elemental metal contained in the
metal alloys otherwise used in its process activities, then the quantities of scrap metals generated and
sent off-site will need to be reported in Section 6.2 of Form R. If the scrap metals are sent off-site for
recycling, bills of lading will be useful in determining the total weight shipped off-site.
SCRAP METAL
If a covered facility sends metal scraps containing chemicals off-site to be remelted and
subsequently reused, does it report the amount of EPCRA Section 313 chemical in the metal
as recycled off-site?
Assuming no contaminants are removed during the melting process, the chromium in the
metal scraps is not actually being recovered, but merely melted and reused. Therefore, the
amount of EPCRA Section 313 chemical in the metal scraps would not be reportable in Part II,
Sections 6.2 or 8 of the Form R. However, because the facility is repackaging and
distributing the EPCRA Section 313 chemicals in commerce, it should consider these
amounts of the EPCRA Section 313 chemical towards the facility' s processing threshold. If
the covered facility exceeds a chemical activity threshold, it is required to submit a Form R or
4.2.7 On-site Waste Management Methods, Section 7A, 7B, and 7C of Form R
On-site waste management at coal mines may include waste treatment. Recycling of wastes and
energy recovery from wastes is usually not performed at coal mines.
4-47
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On-site Treatment Methods, Section 7A of Form R
Coal mines may treat wastes on-site using various methods. When completing a Form R for a
chemical, you must report all treatment methods performed on the waste containing that chemical,
regardless of its efficiency. For each treatment method, report the applicable code, given in the TRI
Forms and Instructions document. The following are some examples of treatment methods that coal
mines may use:
Tailing or other solid wastes may pass through several steps, including filtration
(PI2), sludge dewatering (PI3), settling/clarification (PI 1), and thermal
drying/dewatering (F83).
Wastewater (such as coal pile runoff) may go through several treatment steps,
including neutralization (Cll), settling/clarification (Pll), filtration (PI2),
chemical precipitation - lime or sodium hydroxide (C01), sludge dewatering -
non-thermal (P13), or other physical treatment (e.g., evaporation) (P99).
Some facilities incinerate (F99 and other F codes) wastes as part of the coal
drying process.
4.2.8 Source Reduction and Recycling Activities, Section 8
In Chapter 4.1.3, the general method for developing Section 8 quantities was discussed in
Chapter 4.1.3. Two examples of how to calculate Section 8 quantities are presented below in Table 4-
7:
Table 4-7
Example of Section 8 Reporting
Section
Metal Compounds
Ammonia
Section 8.1, Quantity released
Fugitive and stack air
emissions, releases to water
and POTW, and off-site waste
transfers for disposal
100% of fugitive and stack air
emissions and 10% of the
quantity released to water or
land in aqueous form
Section 8.2, Quantity used for
energy recovery on-site
Not applicable to these metal
compounds that are products
of combustion
Not generally performed at
coal mines
4-48
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Section 8.3, Quantity used for
energy recovery off-site
Not applicable to these metal
compounds that are products
of combustion
Not generally transferred off
site in wastes
Section 8.4, Quantity recycled
on-site
Water decanted from tailings
ponds are returned to the
process may contain metal
compounds
Not generally performed at
coal mines
Section 8.5, Quantity recycled
off-site
Metal compounds not generally
transferred off site in wastes
from coal mines (elemental
metals are separately listed)
Not generally transferred off
site in wastes
Section 8.6, Quantity treated
on-site
Not possible to destroy metal
compound
Report quantity in waste that is
neutralized (do not include the
quantity used to neutralize)
Section 8.7, Quantity treated
off-site
Not possible to destroy metal
compound
Not generally transferred off
site in wastes
4.2.9 Source Reduction Activities, Section 8.10
Facilities have the opportunity to report source reduction actions initiated during the reporting
year on the Form R, using codes listed in the TRI Forms and Instructions document. An example of a
source reduction activity and a suggested code is given below.
Spraying coal piles with an anionic detergent to reduce bacterial oxidation of sulfide
minerals, lowering the acidity of the pile, and decreasing the amount of EPCRA Section
313 chemicals in coal pile runoff. (W49: Other raw material modifications)
4-49
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APPENDIX A
REPORTING GUIDANCE DOCUMENTS
General Guidance
Air/SuperfundNational Technology Guidance Study Series, no date.
Internet Availability: None
Hardcopy Availability: NTIS
Order Number: PB96-162-490
Chemicals in Your Community: A Guide to the Emergency Planning and Community Right-To-
Know Act, 1993.
Internet Availability: http://www.epa.gov/swercepp/gen-pubs.html
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-550-K-93-003
Common Synonyms for Chemicals Listed Under Section 313 of the Emergency Planning and
Community Right-To-Know Act, March 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-008
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-
Know Act and Section 112(r) of the Clean Air Act, as amended (Title III List of Lists), November
1998.
Internet Availability: http://www.epa.gov/swercepp/gen-pubs.html
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-550-B-98-017
The Emergency Planning and Community Right-to-Know Act: Section 313 Release Reporting
Requirements, December 1997 (brochure).
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-K-97-002
A-l
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A-2
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EPCRA Section 313 Questions & Answers, Revised 1998 Version, December 1998.
Internet Availability: http://www.epa.gov/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-B-99-004
Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements: Questions and Answers.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-011
Interpretations of Waste Management Activities: Recycling, Combustion for Energy Recovery,
Treatment for Destruction, Waste Stabilization and Release, April 1997.
Internet Availability: None
Hardcopy Availability: EPCRA Hotline
Order Number: No order number
Standard Industrial Classification Manual, 1987.
Internet Availability: None (see http://www.epa.gov/tdbnrmrl/help/l_help7.htm for codes)
Hardcopy Availability: NTIS
Order Number: PB-87-100-012
Supplier Notification Requirements
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-560-4-91-006
Toxic Chemical Release Inventory Reporting Forms and Instructions (TRI Forms and Reporting
Requirements), March 23, 1998
Internet Availability: http://www.epa.gov/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-K-98-001
A-3
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Toxic Chemical Release Reporting; Community Right-to-Know; Final Rule, February 16, 1988
(53 FR 4500).
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: None
Trade Secrets Rule and Form, July 29, 1988 (53 FR 28772).
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: None
Waste Analysis at Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes; A
Guidance Manual., April 26, 1994.
Internet Availability: http://es.epa.gov/oeca/ore/red/wap330.pdf
Hardcopy Availability: NTIS
Order Number: PB94-963-603
Chemical-Specific Guidance
Emergency Planning and Community Right-to-Know Section 313: Guidance for Reporting
Aqueous Ammonia, July 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-012
Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals
Within the Chlorophenols Category, November 1994.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-B-95-004
Emergency Planning and Community Right-to-Know Section 313: List of Toxic Chemicals,
September 1996.
Internet Availability: None
A-4
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Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-B-96-002
Guidance for Reporting Sulfuric Acid Aerosols (acid aerosols, including mists, vapors, gas, fog,
and other airborne forms of any particle size), March 1998 Revision
Internet Availability: http://www.epa.gov/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-97-007
List of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and
Guidance for Reporting, May 1996.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-96-004
Toxics Release Inventory: List of Toxic Chemicals Within the Glycol Ethers Category and
Guidance for Reporting, May 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-006
Toxics Release Inventory: List of Toxic Chemicals Within the Nicotine and Salts Category and
Guidance for Reporting, February 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-004
Toxics Release Inventory: List of Toxic Chemicals Within the Polychlorinatd Alkanes Category
and Guidance for Reporting, February 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-001
Toxics Release Inventory: List of Toxic Chemicals Within the Poly cyclic Aromatics Compounds
Category, February 1995.
A-5
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Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-003
Toxics Release Inventory: List of Toxic Chemicals Within the Strychnine and Salts Category and
Guidance for Reporting., February 1995.
Internet Availability: None
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-95-005
Release Estimation Guidance
General
Data Quality Checks to Prevent Common Reporting Errors on Form R/Form A, August 1998.
Internet Availability: http://www.epa.gov/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-745-R-98-012
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
Form, December 1987.
Internet Availability: http://www.epa.gov/tri
Hardcopy Availability: NCEPI or EPCRA Hotline
Order Number: EPA-560-4-88-002
Releases During Cleaning of Equipment, June 30, 1986.
Internet Availability: None
Hardcopy Availability: Prepared by PEI Associates, Inc. for the U.S. Environmental Protection
Agency, Office of Prevention, Pesticides & Toxic Substances, Washington, DC, Contract Bo.
Order Number: 68-02-4248
Air
Chemdat 8/Water 8: Air Emission Models for Waste and Wastewater (for Microcomputers), 1994
A-6
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Internet Availability: http://www.epa.gov/ttn/chief/software.html#water8
Hardcopy Availability: NTIS
Order Number: PB95-503595
A-7
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Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources,
5th Edition (AP-42).
Internet Availability: http://www.epa.gov/ttn/chief/ap42.html
Hardcopy Availability: NCEPI
Order Number: EPA-450-AP-425ED
Protocol for Equipment Leak Emission Estimates, 1987.
Internet Availability: http://www.epa.gov/ttnchiel/fyi.html
Hardcopy Availability: NCEPI
Order Number: EPA-423-R-95-017
Tanks 3: Tanks: Storage Tank Emission Estimation Software, Version 3.0 (for Microcomputers),
March 1996
Internet Availability: http://www.epa.gov/ttn/chief/tanks.html
Hardcopy Availability: NTIS
Order Number: PB97-500-755
Water
Chemdat 8/Water 8: Air Emission Models for Waste and Wastewater (for Microcomputers), 1994
Internet Availability: http://www.epa.gov/ttn/chief/software.html#water8
Hardcopy Availability: NTIS
Order Number: PB95-503595
Information and Document Distribution Centers
Enviro$en$e Information Network
BBS modem: (703) 908-2092
User Support: (703) 908-2007
Internet Home Page: http://es.epa/gov/index.html
A-8
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National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OH 45242
(800)490-9198
(513) 489-8695 (fax)
Internet Home Page: http://www.epa.gov/ncepihom/index.html
National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22151
(800)553-6847
(703) 605-6900 (fax)
Internet Home Page: http://www.ntis.gov
OPPT Pollution Prevention (P2)
Internet Home Page: http://www.epa.gov/opptintr/p2home/index.html
Pollution Prevention Information Clearinghouse (PPIC)
Mail Code 3404
401 M Street, SW
Washington, DC
(202)260-1023
(202) 260-0178 (fax)
RCRA, Superfund & EPCRA Hotline
(800) 424-9346 (outside the Washington, DC Area)
(703) 412-9810 (inside the Washington, DC Area)
TDD: (800) 553-7672 (outside the Washington, DC Area)
(703) 412-3323 (inside the Washington, DC Area)
RTK-Net
1742 Connecticut Avenue, NW
Washington, DC 20009-1146
(202) 797-7200
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Internet Home Page: http://www.rtknet.org
Technology Transfer Network (TTN)
(919) 541-5384 (Help Desk)
Internet Home Page: http://www.epa.gov/ttn
EPA Toxic Release Inventory General Information and Guidance
Internet Home Page: http://www.epa.gov/tri
U.S. Government Printing Office (GPO)
(202)512-1800
(202) 512-2250 (fax)
Internet Availability: http://www.gpo.gov
*For the latest list of industry-specific and other technical guidance documents, please refer to the latest
version of the Toxic Chemical Release Inventory Reporting Forms and Instructions, Appendix H.
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