oEPA
United States
Environmental Protection Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
February 2000
EPA 745-B-00-004
EPCRA Section 313
Industry Guidance
ELECTRICITY GENERATING 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 2-5
2.4 Number of Employees 2-8
2.5 Manufacturing, Processing, and Otherwise Use of EPCRA
Section 313 Chemicals 2-10
2.6 Activity Thresholds 2-10
2.7 How Do You Report? 2-12
2.8 Form R 2-13
2.9 Form A 2-13
2.10 Trade Secrets 2-15
2.11 Recordkeeping 2-15
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 3-45
3.2.2 Evaluation of Exemptions 3-47
3.2.2.1 Laboratory Activities Exemption 3-47
3.2.2.2 De minimis Exemption 3-47
3.2.2.3 Article Exemption 3-50
3.2.2.4 Exemptions That Apply to the Otherwise Use of EPCRA
Section 313 Chemicals 3-51
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3.2.3 Additional Guidance on Threshold Calculations for Certain Activities .... 3-53
3.2.3.1 On-site Reuse Activities 3-53
3.2.3.2 Remediation Activities 3-53
3.3 Step 3. Determine which EPCRA Section 313 chemicals
exceed a threshold 3-54
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) 4-18
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 n, 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
Electricity Generating Facilities 4-26
4.2.1 Fugitive Air Emissions, Section 5.1 ofFormR 4-28
4.2.2 Stack or Point Source Air Emissions, Section 5.2 ofFormR 4-33
4.2.3 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 4-39
4.2.4 Disposal to Land On-site, Section 5.5 of Form R 4-41
4.2.5 Transfers Off-site, Section 6.2 of Form R 4-44
4.2.6 On-site Waste Management Methods, Section 7A, 7B, and 7C of
Form R 4-45
4.2.7 Source Reduction and Recycling Activities, Section 8 of Form R 4-47
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4.2.8 Source Reduction Activities, Section 8.10 of Form R 4-47
Appendix A - TRI Guidance Resources A-1
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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 Electricity Generating Facilities, dated October
1997. It is intended to assist establishments and facilities designated by Standard Industrial
Classification (SIC) codes 4911 (limited to facilities that combust coal and/or oil for the purpose of
generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal and/or
oil for the purpose of generating electricity for distribution in commerce), and 4939 (limited to facilities
that combust coal and/or oil for the purpose of generating electricity for distribution in commerce) 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
electricity generating 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, use "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 electricity
generating 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
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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 electricity generating
facilities where EPCRA Section 313 chemicals are manufactured, processed, or otherwise used. A list
of EPCRA Section 313 chemicals likely to be managed by electricity generating 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 electricity generating
facilities may conduct, illustrating how these activities should be considered for EPCRA Section 313
reporting purposes. This chapter also notes areas where potential errors in reporting might be
encountered generally by electricity generating 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 members on the Electricity
Generating Committee (EGC) made up of staff from Allegheny Power, Duquesne Light Company,
FirstEnergy Corp., GPU Generation, PECO Energy Company, and PP&L, Inc., as well as the Edison
Electric Institute (EEI) whose industry insight and understanding of EPCRA Section 313 requirements
have greatly assisted in increasing the utility of this document. Special thanks go to Michelle Duncan of
EGC for coordinating their review.
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Chapter 1 - Introduction
1.0 PURPOSE
The purpose of this guidance document is to assist facilities in SIC codes 4911 (limited to
facilities that combust coal and/or oil for the purpose of generating electricity for distribution in
commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating
electricity for distribution in commerce), and 4939 (limited to facilities that combust coal and/or oil for
the purpose of generating electricity for distribution in commerce) in complying with the reporting
requirements of Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986
(EPCRA) and of Section 6607 of the Pollution Prevention Act of 1990 (PPA), commonly referred to
as the Toxic Release Inventory (TRI). On May 1, 1997, EPA promulgated a rule (62 FR 23834)
including electricity generating facilities, along with other industry groups, 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 Electricity Generating 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 electricity
generating facilities; and
Reduce the level of effort expended by those facilities that prepare an EPCRA Section
313 report.
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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 electricity
generating 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
complete and accurate information for EPCRA Section 313 reporting. Additional discussion
addressing specific issues can be found in the 1998 EPCRA Section 313 Questions and Answers
document. All of these documents are available on 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 Hotline TDD number is
1-800-553-7672, or in the Washington, DC metropolitan area, call 703-412-3323.
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 releases and 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
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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;
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 in the Washington, DC metropolitan area. The EPCRA Hotline TDD
number is 1-800-553-7672, or in the Washington, DC metropolitan area, 703-412-3323. Assistance
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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 with the necessary qualifiers 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). For
a facility to be made up of more than one establishment, in part requires that there are activities taking
place that are recognized as uniquely different at the facility. For example, at an electricity generating
facility there may also exist a large parts and maintenance shop which services haul trucks used to
transport ash to off-site locations along with other equipment. The haul truck maintenance shop is
uniquely different from the electricity generating portion of the facility and may be properly classified by
SIC code 7699 Miscellaneous repair shops and related services. The electricity generating portion of
the facility would obviously be the primary economic activity in this scenario; thus, the facility as a whole
would likely be classified as SIC code 4911 Electric services, that is made up of two establishments
SIC codes 4911 and 7699.
Conversely, in the case where an electricity generating facility has more than one type of
electricity generating unit, such as a coal fired unit located on the same property as a hydroelectric
generating unit, the facility would not be considered a multi-establishment facility because the two types
of units provide the same function (i.e., generating electricity) and are both classified as SIC code 4911.
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.
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Example - Multiple Establishments
Your facility is comprised of two different establishments with SIC codes covered by EPCRA Section 313, a power
plant and substation. The power plant used 8,000 pounds of an EPCRA Section 313 chemical for boiler cleaning
during the year. The substation used 3,000 pounds of the same chemical for equipment maintenance 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 a Form R 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.
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.
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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
4911, 4931, and 4939
4953
5169
5171
7389
Industry
Metal Mining
Coal Mining
Manufacturing
Electric and Other Services and
Combination Utilities
Refuse Systems
Chemicals and Allied Products
Petroleum Bulk Stations and Terminals
Business Services
Qualifiers
Except SIC codes 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 codes 4911, 4931, and 4939, that combust coal and/or oil for the purpose of
generating power for distribution in commerce must prepare Form R and/or Form A submissions if they
exceed the employee and chemical activity thresholds. There may be facilities within SIC codes 4911,
4931, and 4939 that will not have to report because they do not meet the "limiting" criteria. For
example, facilities that only combust natural gas are not subject
to EPCRA Section 313 reporting requirements. However, facilities in SIC codes 4911, 4931, or
4939 may combust coal or oil on-site for such limited uses as providing heat or electricity on-site, and
start-up activities provided such combustion of coal or oil is not for the purposes of generating power
for distribution in commerce, even if excess power is unavoidably generated during testing and
ultimately distributed in commerce. For example, existing regulations governing nuclear facilities, such
as those defined in 10 CFR §50 Appendix A, require nuclear reactors to maintain safety equipment to
ensure that certain protective measures are operable in the event that equipment may fail. These
regulations specify that an on-site backup power source must be provided in such a way as to be
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independent of normal system power in order for safety equipment to continue to function in the event
that the nuclear portion fails or malfunctions. This type of use of coal and/or oil is not sufficient to bring
a facility under the coverage of EPCRA Section 313. However, if a facility intentionally generates
excess power during testing operations for the purpose of distributing power in commerce, the facility
would be "covered."
Example - SIC Code
An electricity generating facility produces power using coal and/or oil. All of the power generated at the facility
is used to support a single facility within the same company that operates off-site from the electricity generating
facility. Is the electricity produced by the electricity generating facility considered to be distributed in
commerce for purposes of determining if the facility is "covered"?
Yes. The electricity generating facility is classified within the SIC codes of 4911, 4931, or 493 9 and combusts coal
and/or oil for purposes of generating power for distribution in commerce. Supplying electricity to a facility off-
site is considered generating power for distribution in commerce even if the facility is within the company. For
purposes of EPCRA Section 313 reporting, it does not matter that the sole user of the electricity produced by the
electricity generating facility is part of the same company.
If a facility within SIC codes 4911, 4931, or 4939 combusts any amount of coal and/or oil
during the year for purposes of generating power for distribution into commerce, and the facility meets
or exceeds the employee and chemical activity threshold, they must prepare a Form R or Form A.
Because SIC codes 4911, 4931, and 4939 include all types of electricity generating facilities and other
utilities, any generation of power for purposes of distribution into commerce using coal and/or oil will
subject the entire facility to TRI reporting, including combustion operations for on-site support and
testing purposes and non-coal and/or oil combustion operations. For instance, if your facility is
primarily a natural gas combustion facility but, because of fluctuations in natural gas supplies, was
required to supplement natural gas combustion with fuel oil combustion for several days during the
reporting year, the entire facility would meet the SIC code requirement. In this situation, the facility
would need to assess all activities, including the natural gas combustion operations, in conducting
threshold determinations and release and other waste management calculations. Even though your
primary power generation source may not be coal and/or oil, any use of coal and/or oil for purposes of
generating power for distribution into commerce, is sufficient for meeting the facility's SIC code
classification for EPCRA Section 313 purposes.
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Example - Coal/Oil
Electricity generating facilities in SIC codes 4911,4931, or 4939 may combust a number of fuels for the
purpose of generating power. For purposes of EPCRA Section 313:
• Kerosene and petroleum coke are considered oils. Facilities in SIC codes 4911, 4931, or 4939,
that combust kerosene and petroleum coke for the purpose of generating power for distribution
in commerce are subject to EPCRA Section 313.
• Non-hazardous oil-contaminated debris is not considered an oil. Facilities in SIC codes 4911,
4931, or 4939, that combust non-hazardous oil-contaminated debris, and do not combust coal or
oil, are not subject to EPCRA Section 313.
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
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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 electricity generating facility (SIC code 4911) must assume the SIC
code 4911 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 electricity generating 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 determination. Importantly,
even if a facility supports one of the covered facilities, it would STILL need to meet the SIC code
qualifier of combusting coal and/or oil for the purpose of generating power for distribution in commerce.
For example, an ash landfill which directly supports a non-contiguous or non-adjacent electricity
generating facility would be classified as an auxiliary facility and assume the SIC code of the electricity
generating facility, but the landfill would not be covered because no combustion of coal and/or oil for
purposes of generating electricity for distribution into commerce occurred at the landfill.
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
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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.
Example - Calculating Employees
Your facility has 7 full-time employees working 2,000 hours/year in the coal-fired power 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 on the road. Two part-time employees, based at the facility, work 1,000
hours/year each to maintain the off-site electricity distribution system. The wastewater treatment plant (on-site
and owned by the facility) is operated by a contractor who spends an average of two hours per day and five days
per week at the plant. Finally, you built an addition to the plant warehouse during the year, using four contractor
personnel who were on site full time for six months (working on average of 1,000 hours each). You would
calculate the number of full-time employee equivalents as follows:
• Hours for your nine full-time employees (seven 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 electricity distribution maintenance crew are:
2 employees x 1,000 hours/year = 2,000 hours; and
• Hours for the wastewater treatment plant operator are:
2 hours/day x 5 days/week x 52 weeks/year = 520 hours; and
• Hours for the construction crew are:
4 contractors x 1,000 hours = 4,000 hours.
This is a total of 24,520 hours for the year, which is above the 20,000 hours/year threshold; therefore, you meet
the employee criterion.
POSSIBLE ERROR - Off-site Maintenance Crew
Remember to include all employees based at your facility even if their primary activities are to maintain your
power distribution system, both on- and off-site.
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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
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 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 waste management calculations. Once you
identify the EPCRA Section 313 chemicals at your facility, you must evaluate the activities involving
each chemical 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
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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, Tables 3-3, 3-15, and 3-16. These terms are
briefly defined in Table 2-2, with a detailed discussion to follow.
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 wastes for energy recovery, treatment, or disposal are not
considered "distribution into commerce." For example, if you receive an EPCRA Section 313
chemical in waste from off-site and repackage the waste and send it to a landfill off-site, that activity
should not be included in threshold determinations.
Also, note that the threshold determinations for the three activities (manufacturing, processing,
and otherwise use) are mutually exclusive. That is, you must conduct a separate threshold
determination for each 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.
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
combustion of coal.
25,000
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Activity
Definition
Threshold
(Ibs/yr)
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 material 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, the components of fuel are classified
as otherwise used when the fuel is combusted on-site.
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 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
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
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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 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
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
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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.
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
A covered electricity generating facility manufactures 800,000 pounds of copper compounds from combustion of
coal, during the reporting year. Because the facility distributes all of its ash into commerce for direct reuse, the
total annual reportable amount of copper (the sum of Sections 8.1 through 8.7 of the Form R) is less than 500
pounds. Because the facility did not exceed the one million pound threshold for manufacturing, processing or
otherwise use and the facility's total reportable quantity of copper does not exceed 500 pounds, the facility has
the option of submitting either 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
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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
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;
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3) Documentation supporting the report that is submitted, including documentation
supporting:
• Threshold determinations;
Employee threshold determinations (including time sheets);
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
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 source of information 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;
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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, or other trade name
products, and wastes at your facility. Electricity generating facilities may find it helpful to create two
lists: one of purchased chemicals otherwise used at the facility or received from off-site for further waste
management, and one of chemicals manufactured during combustion. 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. Next,
compare the individual chemicals on both lists to the current EPCRA Section 313 chemical 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). Highlight 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 created during combustion at an electricity
generating facility is sulfuric acid (acid aerosols). Sulfuric acid (CAS No. 7664-93-9) has several
synonyms, including dihydrogen sulfate and sulphuric acid. It must be reported on Form R (or Form
A), Item 1.2, by its EPCRA Section 313 chemical name, sulfuric acid (acid aerosols). Synonyms can
be found in EPA's 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 EPCRA Section 313 chemical and chemical
category names and the corresponding CAS numbers and category codes.
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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 electricity generating
facilities. As a guide, certain chemicals that electricity generating facilities may manufacture during
combustion, process, and/or otherwise use are provided in Table 3-1. This is not a comprehensive list
of all chemicals that may be manufactured, processed, and/or otherwise used at electricity generating
facilities, but is merely a starting point for identifying chemicals for threshold determinations. Facilities
that distribute ash into commerce for direct reuse should also consider any chemicals in ash that are
above de minimis levels when making threshold determinations.
Information that is useful in performing threshold determinations and preparing your reports
includes the following:
Mixtures and other trade name products containing EPCRA Section 313 chemicals;
Associated CAS numbers;
• Throughput quantities; and
• Whether the chemical is manufactured, processed, or otherwise used at the facility (be
sure to include quantities that are coincidentally manufactured and imported, as
appropriate).
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 waste, 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.
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Table 3-1
Chemicals Commonly Manufactured, Processed, and Otherwise Used at
Electricity Generating Facilities
EPCRA Section 313
Chemicals that Electricity
Generating Facilities May
Manufacture During
Combustion
EPCRA Section 313
Chemicals that Electricity
Generating Facilities May
Process (in Ash for Direct
Reuse)
EPCRA Section 313 Chemicals
that Electricity Generating
Facilities May Otherwise Use
Antimony compounds
Arsenic compounds
Barium compounds
Cadmium compounds
Chromium compounds
Copper compounds
Formaldehyde
Hydrochloric acid (acid
aerosols)
Hydrogen fluoride
Lead compounds
Manganese compounds
Mercury/Mercury
compounds
Nickel compounds
Selenium compounds
Silver compounds
Sulfuric acid (acid aerosols)
Vanadium fume or dust
Zinc compounds
Antimony compounds
Arsenic compounds
Barium compounds
Cadmium compounds
Chromium compounds
Copper compounds
Lead compounds
Manganese compounds
Mercury
Nickel compounds
Selenium compounds
Silver compounds
Vanadium fume or dust
Zinc compounds
Ammonia
Bromine
Chlorine
Chlorine dioxide
Copper compounds
Ethylene glycol
Formic acid
Hydrazine
Hydrochloric acid (acid aerosols)
PAC compounds
Thiourea
1,2,4 Trimethylbenzene
Zinc compounds
Chemicals Manufactured During Combustion
Electricity generating facilities may manufacture several EPCRA Section 313 chemicals during
combustion. To identify the chemicals manufactured, you should use your best readily available
information. This information could include analytical data on fuel sources used and combustion
processes (e.g., fuel analyses, coal quality database, stack emission testing, combustion tests, etc.),
process knowledge, other facility derived data, information from industry associations and EPA
sources, and information on chemicals releases or other wastes leaving the facility. This chapter will
discuss many of the metals and metal compounds, acids, and organics that are likely to be
manufactured during combustion.
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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. Electricity
generating facilities may receive MSDSs for any mixture or other trade name product purchased for use
as fuel, equipment cleaning and maintenance, water treatment, 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, 1998 EPCRA Section 313 Question and Answers, Appendix A, Directive
9 (EPA-745-B-98-004) or Supplier Notification Requirements brochure, (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.
EPCRA Section 313 Chemical List
3-4
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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. 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 through 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. The Agency publishes its findings and any regulatory action through
the Federal Register.
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.
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.
3-5
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Example - Chemical Categories
Example 1 A facility otherwise uses 6,000 pounds of copper compound in equipment painting operation,
manufactures 20,000 pounds of copper oxide as a combustion by-product, and processes 18,000 pounds of
copper oxide in ash for reuse. All three compounds are members of the copper 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 copper 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
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.
The qualifiers associated with these chemicals which may be applicable to the electricity
generating industry 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, paniculate, 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
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).
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
3-6
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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 1998 EPCRA Section 313 Question
and Answers, - Appendix A, Directive 8. Additionally, ammonium nitrate in aqueous
solutions must be included in threshold determinations and release 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
3-7
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3.2
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 (acid aerosols) 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 (acid aerosols) 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).
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 activities (Tables 3-3, 3-14 and 3-15 provide
detailed definitions of subcategories for each 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.
3-i
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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.
COMMON ERROR - 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 that may be in storage, is the amount applied to the threshold
determination. For example, your electricity generating facility uses a recirculating cooling system containing
15,000 pounds of anhydrous ammonia. To replace fugitive releases and small losses that occur during use, you
add 5,000 pounds of anhydrous ammonia to the cooling system. In this example, only the 5,000 pounds that were
added to the system count toward the "otherwise use" threshold. Therefore, unless you "otherwise use" more
than 5,000 pounds elsewhere at the facility, the "otherwise use" threshold of 10,000 pounds has not been
exceeded and you would not have to report for ammonia.
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 electricity generating facilities may not intend to manufacture EPCRA Section 313
chemicals during operations, combustion of various fuels will produce certain EPCRA Section 313
chemicals that must be considered towards the manufacturing threshold. You will also 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. Most commonly, electricity generating facilities manufacture new metal compounds
(usually as a result of oxidation), acid aerosols, formaldehyde, and other organic compounds, or
convert metal compounds to the parent metal (e.g., mercury compounds in coal may reduce to
elemental mercury). The following discussion describes the various activities included under
manufacturing (see Table 3-3), and other manufacturing threshold issues that are relevant to electricity
generating facilities.
Table 3-3
Definitions and Examples of Manufactured Chemicals
3-9
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Manufacturing Activity
Subcategory
Imported for on-site
use/processing
Produced or imported for
sale/distribution
Produced as a by-product
Produced as an impurity
Examples
Fuels, maintenance chemicals, or limestone that may contain
EPCRA Section 313 chemicals imported into the customs
territory of the United States.
EPCRA Section 313 chemicals in fuel imported by a facility
and sent to other facilities, such as intra-company transfers.
Hydrogen fluoride, hydrochloric acid (acid aerosols) and/or
sulfuric acid (acid aerosols) formed during the combustion of
coal, oil, or other fuels.
The coincidental manufacturing of metal compounds during the
combustion of coal and oil.
May not occur in the electricity generating industry.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this
guidance manual.
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. The same is true if an elemental
metal is converted to a metal
compound, although this is not known to
be an issue in the combustion of coal,
oil, or other fuel types common to
electricity generating facilities. 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 remains 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
How Do I Calculate Amounts of Metal Compounds
Manufactured During Combustion?
In the absence of better facility-specific data, use Tables 3-4 and
3-5 to calculate amounts of metal compounds manufactured
during coal and oil 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.
5-10
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considered toward the manufacturing threshold.
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, oil, or other fuel. These
metals are likely to exist as metal compounds in the fuel. The best available information should be used
to estimate the approximate concentration of the metal in the fuel. If a facility has data regarding
chemical concentrations in the fuels used by the facility, and the facility believes that this is the best
readily available information, then the facility should use this information. If specific concentration data
of EPCRA Section 313 chemicals in fuel does not exist at your facility, there are several sources where
the facility can find this concentration data. Examples include specifications of product content and
concentrations from the supplier, as well as 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 data base on coal constituents.
As an alternative, if no other information is available, facilities can assume that most of these
metal compounds convert to the lowest weight metal oxide possible. You may use the default values
provided in Tables 3-4 and 3-5 provided in this chapter. Table 3-4 lists concentrations of EPCRA
Section 313 metals and organics typically found in crude oil and petroleum products otherwise used by
electricity generating facilities. Only the metals in Table 3-4 would be considered in manufacturing
threshold determinations. To support the facility's threshold calculations, the facility should document
the type of fuel it uses. Table 3-5 also uses the concentrations associated with coal type (by originating
state) to show the estimated 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 3-5 was derived from data in Appendix D of
the Study of Hazardous Air Pollutant Emissions From Utility Steam Generating Units).
Table 3-4
Estimated Concentration Values of EPCRA Section 313 Constituents
in Crude Oil and Petroleum Products (Weight Percent)
EPCRA Section
313 Chemical
Benzene
Biphenyl
Bromine
Chlorine
Cyclohexane
Ethylbenzene
n-Hexane
De Minimis
Level*
0.1
1.0
1.0
1.0
1.0
1.0
1.0
Crude Oil
0.446E
0.060E
N/A
N/A
0.700
0.346E
2.463R
Gasoline
(Various
Grades)
1.6081
0.010R
N/A
N/A
0.240
1.6051
1.0T
No.2 Fuel
Oil/ Diesel
Fuel
8.0E-04A
0.100
N/A
N/A
N/A
0.013A
1.0A
Jet Fuel
(JP-4)
1.0A
0.120E
N/A
N/A
1.240
0.50A
1.5T
Kerosene
0.004A
0.120R
N/A
N/A
N/A
0.127A
0.005 A
Lubri-
cating
Oil
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
Aviation
Gasoline
0.515R
N/A
N/A
N/A
N/A
0.432R
0.126R
5-11
-------
EPCRA Section
313 Chemical
MTBEb
Naphthalene
Phenanthrene
Phenol
PACs"
Styrene
Toluene
1,2,4-Tnmethyl-
benzene
Xylene
Antimony3
Arsenic3
Beryllium3
Cadmiunf
Chromium3
Cobalt3
Copper3
Lead Compounds
Manganese3
Mercury3
Nickel3
Selenium3
Silver-
Zinc Compounds
De Minimis
Level*
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'
0.1/1.0d
1.0
1.0
1.0 (organic)
0.1 (inorg.)
1.0
1.0
0.1
1.0
1.0
1.0
Crude Oil
N/A
0.219E
N/A
0.323
0.0004
N/A
0.8781
0.326
1.420E
l.OE-05
2.0E-05
2.0E-07
4.0E-07
4.0E-05
0.0003
4.0E-05
N/A
N/A
0.0006
0.0055
4.0E-05
N/A
N/A
Gasoline
(Various
Grades)
15.00
0.4441
N/A
0.055
N/A
N/A@
7.21211
2.5Qt
7.170*
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.2 Fuel
Oil/ Diesel
Fuel
N/A
0.550
0.125
0.064
N/A
0.03211
0.032A
l.Qt
0.290A
N/A
8.5E-°«
5.0E-°'
2 1 E"05
9.5 E-°5
N/A
5.6E-04
N/A
2.1E-05
4.0E-05
3.38E-04
N/A
N/A
N/A
Jet Fuel
(JP-4)
N/A
0.46811
N/A
N/A
N/A
N/A
3.20A
N/A
3.20A
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
Kerosene
N/A
07331
N/A
0.770
N/A
N/A
.13T
N/A
0.31 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
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
1.0
No. 6
Fuel Oil
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
3.5E-05
9.2E-07
2.6E-03
9.5E-06
2.0E-08
N/A
Aviation
Gasoline
N/A
0.10E
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
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.
5-12
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TThese 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 for Aviation Gasoline 100 (Exxon-MSDS).
t Concentrations updated with comments received from API.
1 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.
> -i o
5-1J
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Table 3-5
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 3 13 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 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
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 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
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
5-14
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Section 3 13 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
Arizona (Subbituminous)
Antimony /Sb 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmium/CdO
Chromium/CrO
Cobalt/CoO
Chlorine/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
5-15
-------
Section 3 13 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
Colorado (Subbituminous)
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
Iowa (Bituminous)
Antimony/SbO
0.35
1.03
0.84
0.08
4.1
1.6
118b
99b
3.5
32
0.14
7.9
0.89
2.3
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
5.50E-03
30
9.2
5.35
137.06
2.33
6.15
NA
NA
3.31
0.30
86
1.24
9.96
4.55
5-16
-------
Section 3 13 Metal/
Lowest Weight Metal
Oxide3 That May Be
Manufactured from the
Metal
Arsenic/As2O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO2
Metal Concentration in
Coal in Units of
Micrograms/Gram
12.0
1.88
14.0
12.10
10.00
1498.36
77.0
68.0
259.0
0.19
31.0
3.60
Pounds of Metal Oxide
Manufactured per Ton of
Coal Combusted
3.17E-02
1.05E-02
3.19E-02
3.17E-02
2.54E-02
NA
NA
1.47E-01
6.68E-01
3.95E-04
7.94E-02
1.02E-02
Approximate Million
Tons of Coal Needed To
Be Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
0.79
2.39
0.78
0.79
0.98
NA
NA
0.17
0.04
63.26
0.32
2.46
5-17
-------
Section 3 13 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 2O,
Arsenic/As.,0,
Beiyllium/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,
Beiyllium/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
5-18
-------
Section 3 13 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 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
0.85
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 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
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
5-19
-------
Section 3 13 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 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
0.82
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 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
0.81
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
5-20
-------
Section 3 13 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 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
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 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
0.69
7
0.52
0.08
3.1
1.5
80b
104b
o
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
5-21
-------
Section 3 13 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 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
0.92
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 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
0.69
7
0.52
0.08
3.1
1.5
80b
104b
o
5
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
5-22
-------
Section 3 13 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 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
0.58
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 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
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
3-1
-------
Section 3 13 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 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
0.81
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 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
0.69
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
5-24
-------
Section 3 13 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 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
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 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
0.82
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
5-25
-------
Section 3 13 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 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
0.23
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
Virginia (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
0.93
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
5-26
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Section 3 13 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 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
0.3
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 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
0.93
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
5-27
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Section 3 13 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 2O,
Arsenic/As2O,
Beryllium/BeO
Cadmmm/CdO
Chromium/CrO
Cobalt/CoO
Chlonne/Cl2O
Fluorine/F2O
Lead/PbO
Manganese/MnO
Mercury /Hg2O
Nickel/NiO
Selenium/SeO,
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
the 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 Electric
Utility Steam Generating Units - Final Report to Congress, February 1998\ this cleaning process
can affect the concentrations of some of the constituents in coal. In order to account for this, Table 3-6
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 3-6. Note, based on the analysis used to develop information
in Tables 3-5 and 3-6, it was identified that bituminous coal from Illinois and Colorado was not subject
to cleaning processes; therefore, the factors in Table 3-6 should not be used for bituminous coal from
these two states.
5-28
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Table 3-6
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
Example—Use of Coal Cleaning Factor
An electricity generating 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 Table 3-5 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.
5-29
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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
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 3-7 for purposes of threshold
determinations 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 3-7 and facilities are instructed to use their best
"readily available" information when developing these estimates. However, if the facility does not have
better information, then Table 3-7 should be considered.
Table 3-7
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 3-5
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 exists as a compound in coal. Current information
5-30
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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. Therefore, while divalent mercury will readily combine to form a compound, EPA is allowing
facilities to use the lower molecular weight of elemental mercury when making threshold determinations
{Study of Hazardous Air Pollutant Emissions from Electricity Generating Units - Final Report to
Congress, February 1998). 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 that 100% of the mercury portion of the
mercury compounds in the coal convert to elemental mercury. In this case, you must apply the weight
of the metal, rather 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 and Table 3-5.
Table 3-8 shows the estimated pounds of metal oxide manufactured per gallon of fuel oil No. 6
combusted and the estimated gallons of fuel oil No. 6 needed to be consumed to manufacture 25,000
pounds of the metal oxide. Table 3-9 shows the estimated pounds of metal oxide manufactured per
gallon of fuel oil No. 2 combusted and the estimated gallons of fuel oil No. 2 needed to be consumed to
manufacture 25,000 pounds of the metal oxide as a quick reference for facilities.
5-31
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Table 3-8
Concentrations of EPCRA Section 313 Metals and their Compounds
in No. 6 Fuel Oil and Pounds of Metal Oxide Manufactured
per Gallon of Fuel Oil Combusted
EPCRA Section 313
Metal/ Lowest
Weight Metal
Oxide* That May
Be Manufactured
from the Metal
Manganese/MnO
Nickel/NiO
Lead/PbO
Cadmium/CdO
Copper/Cu2O
Cobalt/CoO
Selenium/SeO2
Beryllium/BeO
Arsenic/As2O3
Antimony/Sb2O3
Mercury/Hg*
Chromium/CrO
Silver/Ag2O
Metal Concentration
in No. 6 Fuel Oil in
Units of
Micrograms/Gram
0.35
26.0
1.41
0.02
0.3
1.63
0.095
0.027
0.306
0.01
0.0092
0.31
0.0002
Pounds of Metal
Oxide Manufactured
per Gallon of Fuel
Oil No. 6 Combusted
3.6E-06
2.6E-04
1.2E-05
1.8E-07
2.7E-06
1.7E-05
1.1E-06
6.0E-07
3.2E-06
9.6E-08
7.4E-08*
3.2E-06
2.0E-09
Approximate
Gallons of Oil
Needed To Be
Consumed to
Manufacture 25,000
Lbs. of the Metal
Oxide
6.9E+09
9.5E+07
2.1E+09
1.4E+11
9.3E+09
1.5E+09
2.3E+10
4.2E+10
7.7E+09
2.6E+11
3.4E+11
7.7E+09
1.5E+13
* Mercury compounds in coal are likely to convert to elemental mercury during combustion. Value represents
pounds of elemental mercury manufactured per gallon of fuel oil No. 6 combusted.
Note: Values are calculated based on a density of 8 Ib/gal for Fuel Oil No. 6
5-32
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Table 3-9
Concentrations of EPCRA Section 313 Metals and their Compounds in No.
2 Fuel Oil and Pounds of Metal Oxide Manufactured per Gallon of Fuel Oil
Combusted
EPCRA Section 313
Metal/ Lowest Weight
Metal Oxide* That May
Be Manufactured from
the Metal
Copper/Cu2O
Nickel/NiO
Chromium/CrO
Mercury /Hg*
Manganese/MnO
Cadmium/CdO
Arsenic/As2O3
Beryllium/BeO
Metal Concentration in
No. 2 Fuel Oil in ppm
5.60
3.38
0.95
0.40
0.21
0.21
0.09
0.05
Pounds of Metal Oxide
Manufactured per Gallon
of Fuel Oil No. 2
Combusted
4.4E-05
3.0E-05
8.7E-06
2.8E-06
1.9E-06
1.7E-06
8.3E-07
9.7E-07
Approximate Gallons of
Fuel Oil Needed To Be
Consumed to
Manufacture 25,000 Lbs.
of the Metal Oxide
5.7E+08
8.3E-K)8
2.9E-K)9
8.9E+09
1.3E+10
1.5E+10
3.0E+10
2.6E+10
Mercury compounds in coal convert to elemental mercury during combustion. Value represents pounds of
elemental mercury manufactured per gallon of fuel oil No. 2 combusted.
Source: Economic Analysis of the Final Rule to Add Certain Industry Groups to EPCRA Section 313, Appendix E,
Table E
Manufacture of Acid Aerosols During Combustion . During combustion of fuel, facilities may
manufacture hydrochloric acid (HC1) (acid aerosols), hydrogen fluoride (HF), and sulfuric acid (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 3-10. 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 3-10. 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 3-10 are more appropriate than AP-42
factors, which are averages of factors for each type of coal.
> o O
5-33
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Example - Manufacture of Sulfuric Acid (Acid Aerosols)
An electricity generating facility combusts coal. As a result of the combustion operation, the 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) to form a sulfuric acid mist. For
purposes of EPCRA Section 313, must the facility report on the manufacture of sulfuric acid (acid aerosols)?
No. The sulfuric acid 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 a 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 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 (acid aerosols) from the facility.
For guidance on calculating the amount of sulfuric acid (acid aerosols) manufactured during
combustion, refer to: Emergency Planning and Community Right-to-Know Act—Section 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.
Calculating Thresholds for Hydrochloric Acid (Acid Aerosols) and Selenium
A facility in Wyoming combusts 1 million tons of subbituminous coal in the reporting year. What quantity of
selenium compounds and HC1 (acid aerosols) are manufactured?
Hydrochloric Acid (Acid Aerosols):
The HCl emission factor for subbituminous coal is 1.9 Ib/ton coal (see Table 3-10).
1.9 IbHCI/ton coalx 1,000,000 tons coal = 1,900,000pounds Hcl (acidaerosols)
Therefore, 1.9 million pounds of HCl 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 of selenium in Table 3-5, the concentration factor for selenium oxide (SeO^ is 1.44
xlO~3 Ib SeO^ton coal.
1.44x1 tt3 Ib SeO^ton coal x 1,000,000 tons of coal = 1,440 pounds ofSeO2 produced.
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.
5-34
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Manufacture of Formaldehyde During Combustion. Table 3-11 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 3-10
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
5-35
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Table 3-11
Emission Factors and Triggering Thresholds For
Formaldehyde Manufactured During Combustion
Fuel Source
Natural Gas
No. 2 Fuel Oil
No. 6 Fuel Oil
Coal
Emission Factor
(units of measure)
1.55e-01 lb/M-ft3
61 lb/Mgala
33 Ib/Mgal
2.4e-04 Ib/ton
Combusted to Manufacture 25,000 Ibs.
of Formaldehyde
161,290M-ft3
410Mgal
758 Mgal
104Mtons
Source:AP-42, External Combustion Sources, Tables 1.4-4, 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.
a. Emission factor is the upper range for No. 2 fuel oil combustion.
Manufacture During Flue Gas Desulfurization (FGDY Many electricity generating facilities use
various types of flue gas desulfurization (FGD) systems to remove sulfur dioxide from flue gas. In some
cases, the flue gas passes through a limestone slurry, where calcium from the limestone reacts with
sulfur dioxide in the flue gas. This produces various calcium compounds, and may result in the
coincidental manufacture of metal compounds. EPCRA Section 313 metal compounds may exist in
limestone as metal carbonates (e.g., cobalt carbonate) or as other metal compounds (e.g., silver
sulfide). As flue gas passes through the limestone slurry, metal compounds in limestone may convert to
other metal compounds, such as metal sulfites or sulfates. The amount of a compound within a EPCRA
Section 313 metal compound category produced as a result of chemical conversion must be applied to
the manufacturing threshold, even if the new metal compound is within the same compound category.
To determine the identity and amount of metal compounds manufactured during FGD, facilities
should use the best "readily available data". This may include analyses of limestone or lime solution,
process knowledge, data on sulfur content of coal, literature about reactions that take place in FGD
systems and information about the composition of FGD wastes and flue gas (see Chapter 4.2). In the
absence of better data, facilities can assume that all metal compounds in limestone will convert to either
metal sulfites or metal sulfates. The sulfate/sulfite ratio of FGD waste is chiefly determined by the sulfur
content of the coal burned and the use of forced sludge oxidation. Lower sulfur content in coal generally
produces a sludge high in sulfates, while coal with a higher sulfur content will be high in sulfites. Forced
oxidation converts sulfites in FGD sludge to sulfates, improving the disposal properties of the sludge. In
the absence of better data, facilities that combust low-sulfur western coal, or use a forced oxidation
step (regardless of sulfur content) should assume that metal compounds in limestone convert to metal
sulfates. Table 3-12 provides concentrations of metals in limestone, and shows the amount of metal
sulfate manufactured per pound of limestone used. Facilities that combust high-sulfur eastern coal and
5-36
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do not use a forced oxidation step should assume that metal compounds in limestone convert to metal
sulfites. Table 3-13 provides concentrations of metals in limestone, and shows the amount of metal
sulfite manufactured per pound of limestone used.
Table 3-12
EPCRA Section 313 Metal Constituents of Limestone and the Estimated
Pounds of Limestone Needed to Manufacture 25,000 Lbs. of Metal Sulfate
EPCRA Metal
Arsenic/As2(SO4)3
Barium/BaSO4
Cadmium/CdSO4
Chromium/CrSO4
Cobalt/CoSO4
Copper/Cu2SO4
Lead/PbSO4
Manganese/MnSO4
Mercury
Nickel/NiSO4
Selenium/Se(SO4)2
Silver/Ag2SO4
Zinc/ZnSO4
Concentration in
Limestone
(ppm)
2.5
2000
2
500
5
10
100
1100
1
20
.08
1
200
Pounds of Metal Sulfate per Ton
of Limestone Used (Western Coal,
or Any Coal with Forced Oxidation
Systems)
0.015
6.8
0.007
2.85
0.026
0.035
0.29
6.04
0.002
0.105
0.00055
0.003
0.99
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization by Electric Utilities,
Chemistry Report, OPPT, March 26, 1997.
5-37
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Table 3-13
EPCRA Section 313 Metal Constituents of Limestone and the Estimated
Pounds of Metal Sulfite Manufactured per Ton of Limestone Used
EPCRA Metal
Arsenic/As2(SO3)3
Barium/BaSO3
Cadmium/CdSO3
Chromium/CrSO3
Cobalt/CoSO3
Copper/Cu2SO3
Lead/PbSO3
Manganese/MnSO3
Mercury
Nickel/NiSO3
Selenium/Se(SO3)2
Silver/Ag2SO3
Zinc/ZnSO3
Concentration in Limestone
(ppm)
2.5
2000
2
500
5
10
100
1100
1
20
.08
1
200
Pounds of Metal Sulfite
Manufactured per Ton of
Limestone Used
(Eastern Coal)
0.013
6.3
0.007
2.5
0.024
0.033
0.28
5.4
0.002
0.094
0.00048
0.003
0.89
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization by Electric Utilities,
Chemistry Report, OPPT, March 26, 1997.
5-38
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Importing. The "manufacture" threshold includes importing an EPCRA Section 313 chemical if
the facility has causedthe 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 listed 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 waste or chemical broker), ordered the waste or 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 the 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.
Example - Importing that Qualifies as Manufacturing
Fuel oil containing EPCRA Section 313 chemicals above de minimis is produced in Mexico by an American
owned company and is sent to the U.S. When the facility operating within the U.S. receives the fuel oil, has it
manufactured the EPCRA Section 313 chemicals contained in the fuel oil?
Yes, if the receiving facility either has a contract or agreement in place to receive "imported" fuel oil and is
functioning as the importing facility. Amounts of EPCRA Section 313 chemicals received in the fuel oil must be
counted toward the "manufacturing" threshold.
Processing
Processing means preparing an EPCRA Section 313 chemical, or a mixture or other trade
name product containing an EPCRA Section 313 chemical, for distribution in commerce (usually
thought of as the intentional incorporation of an EPCRA Section 313 chemical into a product).
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. Distributed 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).
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
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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. Sending a commercial product fuel off site (for example, to a customer or distribution
center) is considered processing assuming that the facility sending the commercial fuel off-site has
blended and/or repackaged the fuel. 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 or other extraction of
contaminants; for example, ash sent off-site for concrete manufacturing. 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 3.2.2.2). EPCRA Section 313
chemicals in waste that are sent off-site for further waste management, e.g., disposal are not considered
to be reused.
A primary example of a processing activity that may take place at electricity generating facilities
is preparing for distribution of ash into commerce for direct reuse or recycling. Facilities that send ash
off-site for direct reuse must count amounts of EPCRA Section 313 chemicals in the ash toward their
processing thresholds. For example, some electricity generating facilities may sell ash to construction
companies for direct reuse in the manufacture of cement blocks. These electricity generating facilities
must apply the amounts of EPCRA Section 313 chemicals in the ash distributed into commerce
towards the processing threshold. As another example, some electricity generating facilities may send
ash off-site for vanadium recycling. Facilities must apply the amounts of EPCRA Section 313
chemicals in the ash toward the processing threshold.
Table 3-14 describes the subsections of processing for reporting purposes.
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Table 3-14
Definitions and Examples of Processed Chemicals
Processing Activity
Subcategory
As a reactant
As a formulation component
As an article component
Repackaging for distribution into
commerce
Examples
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
May not occur in the electricity generating industry.
Facilities may repackage fly ash resulting from combustion,
and distribute it into commerce for use in concrete
manufacturing.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
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 3-15).
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Table 3-15
Definitions and Examples of Otherwise Used Chemicals
Activity
Examples
As a chemical processing aid
May not occur in the electricity generating industry.
As a manufacturing aid
Metals used to maintain power lines within the facility.
Ancillary or other use
Combustion of coal or oil containing EPCRA Section 313
chemicals above the de minimis level.
Metals used to maintain/replace process equipment.
Ammonia used in water treatment.
Ethylene glycol sprayed on coal to prevent freezing.
Thiourea used as an inhibitor in cleaning solution for removal
of scale deposits and metals from tube walls.
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Combustion. All EPCRA Section 313 chemicals contained in fuels combusted for energy
production are considered otherwise used. However, this type of chemical use is eligible for the de
minimis exemption, and many of the EPCRA Section 313 chemicals contained in commonly used fuels
exist in below de minimis concentrations. As a result, 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 information indicating otherwise, 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. For example, No. 6 fuel oil may contain benzo(a)anthracene, a member of
the polycyclic aromatic compound chemical category, in concentrations above de minimis levels. EPA
has assembled information on EPCRA Section 313 chemicals in various fuel types from a number of
sources. This information is provided in Table 3-4. 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.
Other Activities. Otherwise use includes the use of EPCRA Section 313 chemicals in activities
such as cleaning, maintenance, and water purification. The use of an EPCRA Section 313 chemical to
treat another chemical constitutes otherwise use.
Other Examples of Chemicals that Electricity Generating Facilities "Otherwise-Use"
• Chemicals used to clean boilers, cooling towers, and other equipment;
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Chemicals in materials that are used to maintain process equipment (e.g., lubricants,
solvents, condenser tubes);
Chemicals used to treat boiler make-up water, or cooling tower water (e.g., chlorine,
chlorine dioxide, bromine);
Chemicals used to prevent corrosion, (e.g., ammonia, hydroquinone, and hydrazine);
Chemicals used to treat wastes, such as coagulants, or flocculants;
Chemicals in fuel used in any on-site equipment (other than motor vehicles eligible for
the motor vehicle maintenance exemption);
Chemicals in ash (or other wastes) that is received from off-site and disposed on-site.
Example - Ash Received from Off-Site
An electricity generating facility receives ash containing an EPCRA Section 313 chemical from other facilities
(e.g., remote peaker units). The electricity generating facility disposes this ash and ash generated from its own
operation, in its on-site landfill. The facility must consider the amount of the EPCRA Section 313 chemical in the
ash received from off-site and disposed on-site as "otherwise used." However, ash generated on-site and
disposed of on-site is not considered "otherwise used." If the facility exceeds an activity threshold for the
EPCRA Section 313 chemical, it must report on the Form R all amounts disposed, regardless of whether the facility
generated the ash on-site or received it from off-site. The EPCRA Section 313 chemicals in the ash are not eligible
for the de minimis exemption
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 quantities 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).
> A O
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Table 3-16
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 (c) 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 chlorofluorocarbons), 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.
Example - Otherwise Use
A facility captures leachate from a landfill, treats the leachate with an EPCRA Section 313 chemical, and then
uses 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.
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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 upon 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.
3.2.1 Concentration Ranges for Threshold Determination
You are required to use your best readily available information for estimating EPCRA Section
313 threshold determinations and release and other waste managed 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.
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• 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 information, be it process knowledge or other reasonable estimation techniques.
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 that are below the detection limit, you may 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. 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.
Example - Average Concentration
Is it appropriate for an electricity generating facility to develop an average concentration for an EPCRA Section
313 chemical contained in the different fuels used by the facility, and then use that average as a basis of
threshold determination? If so, does EPA have a recommended approach for developing such an average?
EPCRA allows facilities to use "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.
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3.2.2 Evaluation of Exemptions
EPCRA Section 313 provides facilities with certain exemptions:
Laboratory activities exemption;
• De minimis exemption;
• Article exemption;
• Exemptions that apply to the otherwise use of chemicals: routine janitorial/facility
grounds maintenance exemption; 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.
These exemptions are described in detail below.
3.2.2.1 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.
3.2.2.2 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
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
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mixtures or other trade name products is 1%, except for OSHA-defined 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,
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 1998 EPCRA Section
313 Questions and Answers 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 into 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 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 waste treatment or other management
activities, or to waste brought on site for waste management. Electricity generating facilities 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 (acid
aerosols), hydrochloric acid (acid aerosols), hydrofluoric acid, and certain metals and metal
compounds, as discussed earlier in this chapter.
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Example -Ash Distributed into Commerce
A covered facility combusts coal in a combustion unit. The coal contains a EPCRA Section 313 chemical below
de minimis amounts. During combustion, EPCRA Section 313 chemicals are manufactured. The 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 minimis 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 byproducts 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.
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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De Minimis Exemption Applies
A facility combusts coal and oil on-site to generate
power for distribution into commerce. The de minimis
exemption applies to the otherwise use threshold for
the EPCRA Section 313 chemicals in the fuel that
were otherwise used.
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.
A facility distributes ash (which meets industry
specifications) containing EPCRA Section 313
chemicals into commerce for use in the manufacture
of concrete. This activity constitutes a processing
activity, and the de minimis exemption applies to
amounts of EPCRA Section 313 chemicals in the ash
distributed into commerce, and to releases and other
waste management activities associated with this
processing activity.
De Minimis Exemption Does Not Apply
A facility combusts coal and oil on-site to generate
power for distribution into commerce. The de minimis
exemption does not apply to the manufacture of
EPCRA Section 313 chemicals (e.g., sulfuric acid
(acid aerosols), metal compounds, etc.) during
combustion. If the facility exceeds a threshold, they
must consider the amount of EPCRA Section 313
chemical coincidentally manufactured toward the
manufacturing threshold. They must also consider all
releases and other waste management quantities that
result from the manufacture of these compounds from
combustion.
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, it must report the
amount of EPCRA Section 313 chemical disposed on-
site, and any other releases and waste management
activities on the Form R.
EPCRA Section 313 chemicals in ash sent off-site for
use as roadfill, landfill, and in mining reclamation are
being managed as a waste; therefore they are not
eligible for the de minimis exemption.
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
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 or release and other waste management
estimates, activities that took place before the de minimis level was met or exceeded.
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3.2.2.3 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. As an example, items that do not
meet the definition would be items that are cold extruded, such as bar stock that is formed into wire.
However, stamping a manufactured item into pieces that are recognizable as the original articles would
not change the exemption status as long as the diameter and the thickness of the item remain
unchanged. For instance, metal wire may be bent and sheet metal may be cut, punched, stamped, or
pressed without losing the article status as long as no change is made in the diameter of the wire or
tubing or the thickness of the sheet and, more important, there are no releases of the EPCRA Section
313 chemical(s).
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
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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 1998 EPCRA Section 313 Questions and Answers
document presents several specific questions and answers/discussion pertaining to the article
exemption.
3.2.2.4 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 nor the associated release and other waste management calculations, provided
thresholds are met elsewhere. The following otherwise use activities are considered exempt (see most
current version of the TRI Forms and Instructions, and the 1998 EPCRA Section 313 Questions
and Answers document).
• 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.
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.
j-:
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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, and
locomotives. 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 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.
This amount is exempt under the motor vehicle exemption. The facility would not include the
amount of ethylene glycol in the windshield washer fluid or anti-freeze when making its
threshold determination or in its release and other waste management calculations.
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.
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.
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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 or
releases or 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.
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 undergoing remediation (e.g., Superfund) are not being
manufactured, processed, or otherwise used. Therefore, they are not included in the threshold
determinations.
If you, however, are conducting remediation for an EPCRA Section 313 chemical that is also
being manufactured, processed, or otherwise used by the facility above an activity threshold level, 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
5-55
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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;
2. Determined the activity threshold 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 activity, 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 Fuels
Electricity generating facilities typically do not manufacture chemicals or products intentionally.
However, these facilities may coincidentiy manufacture Section 313 chemicals during fuel combustion
and, a certain degree, in 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
common to electricity generating facilities, fuel combustion may result in the manufacture of metal
compounds (usually as a result of oxidation), or the conversion metal compounds to the parent metal
(e.g., mercury compounds in coal convert to elemental mercury). In addition, acid aerosols may be
manufactured as a result of the combustion of fuels 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
3-56
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combustion of fuels, you will need to determine the concentration of each metal present in the waste
being combusted. The best readily available information should be used to estimate the approximate
concentration of the metal(s) in the fuels used. From this information, you can estimate amounts of
metal or metal compounds and acid aerosols manufactured. If you have data regarding chemical
concentrations in the fuels combusted (e.g., supplier information and/or analytical data) and believe that
is the best readily available information, then you should use this information. If specific concentration
data of the metals in the fuels do not exist, you can assume that the metals will convert to the lowest
weight metal oxide possible. A more detailed discussion can be found in Chapter 3.2 of this
document. During combustion, other EPCRA Section 313 chemicals could be manufactured,
particularly acid aerosols. For instance, sulfuric acid (acid aerosols) could be produced depending on a
variety of factors such as sulfur content of the fuels. If you have specific data on the manufacture of
acid aerosols, then use it. If data are not available, EPA has published guidance on calculating the
amount of sulfuric acid (acid aerosols) manufactured during combustion; 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.
Calculating the Manufacturing Thresholds for Section 313 Chemicals in Wastes
In electricity generating facilities, some waste management activities may result in the
manufacture of EPCRA Section 313 chemicals. For instance, wastewater activities may result in the
generation of EPCRA Section 313 chemicals. To estimate the amount of EPCRA Section 313
chemicals manufactured during wastewater treatment, the Clean Water Act typically requires facilities
to monitor some EPCRA 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 nitrate compound
category is calculated by the total weight of the nitrate compound in aqueous solutions.
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Calculating the Otherwise Use and Processing Thresholds for Section 313 Chemicals in
Wastes
To determine if a chemical exceeds the processing and/or otherwise use threshold, you must
calculate the annual activity usage of that chemical. For 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 or recovery process, 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, particularly in terms of classifying the types of otherwise use activities the wastes may or may
not have undergone.
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. Jf 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 activity: manufactured,
processed, and otherwise used. Jf more than one activity threshold applies, the amount associated with
each threshold is determined separately.
Table 3-17 presents a worksheet that may be helpful when conducting your threshold
determinations and Table 3-18 illustrates an example of how the work sheet can be used for the
following example:
Example - Threshold Worksheet
Because your facility combusts coal to generate electricity for purposes of distribution into commerce, you are
required to consider the manufacture of EPCRA Section 313 chemicals as by-products of combustion. Using the
emission factor for hydrochloric acid (acid aerosols), 1.9 pounds/ton for your coal type, plus the amount of coal
combusted (1.0 million tons) for the reporting year, you calculate the amount of hydrochloric acid (acid aerosols)
produced to be 1.9 million pounds. Therefore, you would have exceeded the 25,000 pound threshold for
manufacture of hydrochloric acid (acid aerosols), and you would be required to submit a Form R. Because you
manufactured more than one million pounds of the EPCRA Section 313 chemical, you cannot file a Form A.
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Table 3-17 Section 313 Reporting Threshold Worksheet
Facility Name:
Toxic Chemical or Chemical Category:
CAS Number:
Reporting Year:
Amounts of the toxic chemical manufactured, processed, or otherwise used.
Date Worksheet Prepared:
Prepared By:
Mixture 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.
Exempt quantity of the toxic chemical that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility,
activity)
Fraction or Percent Exempt
(if Applicable)
Amount of the 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.
-AO Ibs. (B-BO Ibs. (C-Cj) Ibs.
25,000 Ibs 25,000 lb 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 3-18. Sample Section 313 Reporting Threshold Worksheet
Facility Name: ABC Electricity Generating Company
Toxic Chemical or Chemical Category: Hydrochloric Acid (acid aerosols)
CAS Number: 7647-01-0
Reporting Year: 1998
Amounts of the toxic chemical manufactured, processed, or otherwise used.
Date Worksheet Prepared: May 1. 1999
Prepared By:
Mixture Name or Other Identifier
1. Subbituminous Coal
2.
3.
4.
Subtotal:
Information
Source
Emission
Factor
Total Weight
(lb)
2 billion
Percent TRI
Chemical
by Weight
1.91b/toncoal
TRI Chemical
Weight
(in Ibs)
1,900,000
1,900,000
Amount of the Listed Toxic Chemical by Activity (in Ibs.):
Manufactured
1,900,000
—
(A) 1,900,000 Ibs.
Processed
—
—
(B) 0 Ibs.
Otherwise Used
—
—
(C) Olbs.
OJ
o
Exempt quantity of the toxic chemical that should be excluded.
Mixture Name as Listed Above
1. None
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
(AO 0 Ibs.
Processed
(BO 0 Ibs.
Otherwise Used
(CO 0 Ibs.
Amount subject to threshold:
Compare to threshold for Section 313 reporting.
(A-AO 1,900,000 Ibs. (B-BOO Ibs. (C-CO 0 Ibs.
25,000 Ibs. 25,000 Ibs. 10,000 Ibs.
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If any threshold is exceeded, reporting is required for all activities. Do not submit this worksheet with Form R, retain it for your records.
3-61
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Chapter 4 - Estimating Releases and Other Waste Management Quantities
4.0 PURPOSE
This chapter is intended to help you in developing a systematic approach for conducting release
and other waste management calculations specific to electricity generating facilities. 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 waste, by particular
waste management type (e.g., release to air, transfer off-site for waste management, etc.). To aid your
facility in making these calculations, 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 with examples of methods and tools
to use in calculating estimates of releases and other waste management activities specific to many
electricity generating operations.
4-1
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tatn
i
••iB^ Ui^^
FItfte Ml nuh^Uinfeqiniinl
Al Nr b
to
P01W Transfer ItonAr Transfer Transfer Qittite (Mlk
EKBIfRKIIW IHahlMt DktOHl TtNhMtt RfltWff
inahiint
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;
• Container residues;
• Recycling and energy recovery byproducts;
Accidental spills and releases;
Storm water runoff;
4-3
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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 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.
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.
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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:
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.
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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
4-6
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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 in evacuated areas 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
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 EPCRA Section 313 chemicals 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.
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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 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 7A. 1 d 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.
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Example - On-Site Waste Treatment (conf)
Chemical A
7 A. la
W
7A.lb | 1. P19 2. Cll
3. Pll 4. NA 5.
6. 7. 8.
7A.lc
1
7A.ld
99 %
7 Ale
Yes No
X
Chemical B
7 A. la
W
7A.lb 1. P19 2. Cll
3. Pll 4. NA 5.
6. 7. 8.
7A.lc
1
7A.ld
95 %
7 Ale
Yes No
X
Chemical C
7 A. la
W
7A.lb 1. P19 2. Cll
3. NA 4. 5.
7.
6.
8.
7A.lc
1
7A.ld
100 %
7 Ale
Yes No
X
Note that the quantity removed and/or destroyed is not reported in Section 7 and that the
efficiency reported in Section 7A. Id refers to the amount of EPCRA Section 313 chemical
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
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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
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 (c) a spent or contaminated "otherwise used" material; and
The subsection 8.1 through 8.8 designation are those for the 1997 Form R. Please refer to the current
reporting year's TRI Forms and Instructions for any changes.
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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
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 (c) 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
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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)
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(VI) 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
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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:
(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
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Electricity generating 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.
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 information or prepare reasonable estimates.
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For example, emission factors or engineering calculations may not be the best readily available
information 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 4-1 presents potential data sources and the estimation methodology in which they are most likely
to be used.
Table 4-1
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data (M)
Mass Balance (O
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
Supply records
Hazardous material inventory
Air emissions inventory
Pollution prevention reports
Hazardous waste manifests
Spill event records
Emission Factors (E)
AP-42 or other EPA emission factors
Published facility or trade association
chemical-specific emission factors
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)
• Process knowledge
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.
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4.1.4.1 Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for developing
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.
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 1997. 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 I yr
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
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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
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.
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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
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 boiler
operations. AP-42 lists a range of formaldehyde emission factors when No. 6 fuel oil is consumed:
0.024 to 0.061 Ibs formaldehyde generated/103 gallons No. 6 fuel oil fired.
A facility operating a boiler using No. 6 fuel oil could use the above emission factor to determine the amount of
formaldehyde generated and subsequently released to the air. If 1,000,000 gallons of No. 6 fuel oil is used during
a reporting year, the amount of formaldehyde generated would be between:
(0.024 lbs/103 gal) x (1,000,000 gallons) and (0.061 lbs/103 gal) x (1,000,000 gallons) = 24 and 61 Ibs of
formaldehyde
The mid-point of these two values, 42.5 pounds, should be use in developing release estimates assuming that a
threshold has been exceeded for formaldehyde.
NOTE: In addition to combustion by-products, there are other EPCRA Section 313 chemicals in No. 6 fuel oil 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
operations 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/yr 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/yr xylene) 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 4-2 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 4-2 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
Amount (Ibs)
Basis of
Estimate
Form R Element
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses (spills, surface
impoundments)
Total =
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)
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
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 =
5.3, (8.1 or 8. 8)
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II -V Wei
ON-SITE LAND
Landfill
Land Treatment/Application Farminj
Surface Impoundment
Other
Total =
ON-SITE ENERGY RECOVERY
ON-SITE RECYCLING
ON-SITE TREATMENT
s
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
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)
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Acid Regeneration
Transfer to Recycling Wast
Broker
6.2, (8. 5 or 8. 8)
6.2, (8. 5 or 8. 8)
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 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 2,000 pounds of an EPCRA Section 313 chemical in a mixture used for water treatment. This
is the first shipment received during the reporting year. Your facility uses all but 500 pounds of the
chemical. In July, your facility receives another shipment containing 2,500 pounds of the same
chemical, and you do not receive any other amounts of the chemical during the reporting year.
Provided this is your only use of the EPCRA Section 313 chemical, your maximum amount on-site is
3,000 pounds (range code 03).
Example - Maximum Amount On-Site for Landfills
How do facilities that operate landfills report 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. Facilities 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, Electricity generating facilities may only enter
"NA" in the production ratio or activity index data element if the EPCRA Section 313 chemical was not
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manufactured, processed, or otherwise used in the year prior to the reporting year for which a Form R
is being submitted.
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 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 EPCRA Section 313 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 of the amount of the cleaning solvent used between
the prior and current reporting years may seem logical but may not take into consideration potential
source reduction activities such as product reformulation. As a result, an activity index may be more
appropriate, such as the number of tank washouts conducted, which would be more accurate in
reflecting the potential source reduction activities that could be implemented for that chemical and/or
activity.
Example - Production Ratio
A facility uses coal as its fuel for its electricity generating combustion units and exceeds the manufacturing
threshold for several EPCRA Section 313 metal compounds. The facility produces 100 megawatt-hours of
electricity in the previous year. For the current reporting year, the facility produces 120 megawatt-hours of
electricity. As a result, the production ratio for these EPCRA Section 313 metals would be calculated by dividing
megawatt-hours produced from this year by megawatt-hours produced from last year.
120 megawatt - hours (current reporting year)
100 megawatt - hours (previous reporting year)
Production Ratio =1.20
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
activities do not include recycling, treating, using for energy recovery, or disposing of an EPCRA
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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 Electricity
Generating Facilities
This section discusses the most common releases and other waste management activities at
electricity generating 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 activities of any EPCRA Section
313 chemicals that exceed activity thresholds at the facility, including those associated with the
combustion of fuels other than coal or oil (e.g., natural gas). While this chapter is designed primarily for
electricity generating facilities that combust oil and/or coal for the purpose of generating power for
distribution in commerce, the release and other waste management reporting issues may be relevant to
all potentially reporting facilities. In particular, facilities that combust fuels, including coal or oil, will find
the estimation techniques discussed in this chapter (e.g., methods of calculating discharges to water)
useful.
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. Figure 4-3 illustrates common
operations and releases and other waste management outputs at electricity generating facilities. While
differing in some important respects, most conventional electricity generating facilities rely on the same
basic mechanism. Fuel is ignited and burned within a boiler chamber composed of thousands of feet of
water-filled tubes. The heat of combustion heats the water in the boiler tubes, creating high temperature
and high pressure steam The steam passes through turbines causing the turbine blades to rotate and a
shaft connected to the turbine blades drives electric generators, yielding electric power. In this fashion,
4-26
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the chemical energy of the fossil fuel is converted to heat energy through combustion, then to
mechanical energy in the turbines, and finally to electrical energy in the generators. Transmission lines,
substations, and switching stations channel generated electricity to various customers. While Figure 4-3
is not meant to represent all electricity generating facilities, it can be used as a starting point for creating
a facility-specific process flow diagram.
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ChMifcto
FODSIudp
Bectfely
C«olhgWitar
Blowdnvn
Figure 4-3 Process Flow Diagram at Electricity Generating Facilities
4.2.1 Fugitive Air Emissions, Section 5.1 of Form R.
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Fugitive air emissions can occur from a number of sources. The primary fugitive emissions
sources for EPCRA Section 313 chemicals at electricity generating facilities are likely to be:
• Storage and handling of the fuels containing EPCRA Section 313 chemicals above de
minimis levels;
Handling and storage of ash containing EPCRA Section 313 metal compounds
manufactured as by-products of fuel combustion; and
• Wastewater treatment and other sources, including cleaning operations and spills,
containing EPCRA Section 313 chemicals
Fuel. Fugitive emissions may occur
during storage and handling of fuels including
coal and oil. Concentrations of EPCRA
Section 313 chemicals in these fuels will greatly
affect the need to determine if fugitive emissions
will have to be calculated for handling activities
during use of fuels. For coal, the EPCRA
Section 313 chemicals are likely to be present in
concentrations below de minimis levels. During
the otherwise use of coal, EPCRA Section 313
chemicals below de minimis levels do not have
to be considered toward threshold
determinations and release or other waste
management calculations. (Note that any
coincidental manufacturing that occurs during
combustion must be considered because the de
minimis exemption does not apply to the
manufacture of a byproduct (see below)). Fuel
oils may have EPCRA Section 313 chemicals
above de minimis levels, and facilities should
consider fugitive emissions resulting from the
handling and storage of fuel oils, particularly
lighter oils. EPA's Protocol For Equipment Leak Emission Estimates (EPA-453/R-95-017)
presents a comprehensive discussion of how to estimate equipment leaks, such as those from valves,
seals, and connectors in fuel handling equipment. This document is available at
http://www.epa.gov/ttnchiel/fyi.html. Four approaches for estimating equipment leak emissions, in
order of increasing refinement, are presented:
• Average emission factor approach;
• Screening ranges approach;
EPA correlation approach; and
Unit-specific correlation approach.
4-29
Fugitive Emissions and the De minimis
Exemption
EPCRA Section 313 chemicals in fuel, along with other
mixtures or other trade name products, that are
processed or otherwise used are eligible for the de
minimis exemption.
Fugitive emissions of EPCRA Section 313 chemicals
below de minimis levels in ash being prepared for
distribution into commerce for direct reuse (i.e.,
processed) are exempt from threshold determinations
and release or other waste management calculations.
EPCRA Section 313 chemicals manufactured during
combustion that are subsequently managed in ash as a
waste (e.g., disposal) are not eligible for the de minimis
exemption. Facilities must consider fugitive emissions
of these chemicals, that occur during transportation,
handling, disposal, or other activities associated with
ash, regardless of concentration because the de
minimis exemption generally does not apply to the
manufacture of EPCRA Section 313 chemicals.
-------
In general, the more refined approaches require more data and provide more accurate emission
estimates for a process unit. Also, it is important to recognize in calculating estimates for these
sources, you may have already calculated these estimates as a result of separate requirements under the
Clean Air Act, particularly the Title V requirements.
In the average emission factor approach and the screening ranges approach, emission factors
are combined with equipment counts to estimate emissions. EPA has also developed emission factors
for the synthetic organic chemical manufacturing industry (SOCMI), refineries, oil and gas production
units, and petroleum marketing terminals. The SOCMI emission factors are presented in Table 4-3.
These average factors must be multiplied by the number of pieces of equipment being considered and
the length of time each piece of equipment is in service. The average emission factors vary depending
on the service category (e.g., gas, light liquid, or heavy liquid), and the total organic compound (TOC)
concentration of the stream. To estimate emissions with the EPA correlation approach, measured
concentrations (screening values) for all equipment are individually entered into general correlations
developed by the EPA. In the unit-specific correlation approach, screening and leak rate data are
measured for a select set of individual equipment components and used to develop unit-specific
correlations. Screening values for all components are then entered into these unit-specific correlations to
estimate emissions.
Table 4-3
SOCMI AVERAGE EMISSION FACTORS*
Equipment type
Valves
Pump sealsb
Compressor seals
Pressure relief valves
Connectors
Open-ended lines
Sampling connections
Service
Gas
Light liquid
Heavy liquid
Light liquid
Heavy liquid
Gas
Gas
All
All
All
Emission factors a (Ibs/hr/source)
0.0132
0.00888
0.00051
0.0439
0.0190
0.503
0.229
0.00403
0.0037
0.0331
*Protocolfor Equipment Leak Emission Estimates (EPA, EPA-453/R-95-017)
a These factors are for total organic compound emissions
b The light liquid pump seal factor can be used to estimate the leak rate from agitator seals
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The general equation for estimating TOC mass emissions from an equipment leak using average
emission factors is:
where:
ETQC = emission range of TOC from all equipment in the stream of a given equipment
type (Ib/hr)
FA = average emission factor for the equipment type (Ib/hr/source)
WFTOC = average weight fraction of TOC in the stream
N = number of pieces of equipment
And the equation for determining the emissions of a specific VOC in a mixture or other trade name
product from equipment is:
Ex = Eroc*(WP!/WPTOC)
where:
F^ = The mass emissions of organic chemical "x" (Ib/hr)
Epoc = The TOC mass emissions from the equipment (Ib/hr)
WPX = The concentration of organic chemical "x" in the equipment in weight percent
WPTOC = The TOC concentration in the equipment in weight percent.
Calculation of Equipment Leak Emissions
At an electricity generating facility, aviation gasoline passes through a system containing 100
connectors from storage to the combustion unit. The aviation gasoline contains 85 weight percent TOC.
The aviation gasoline is in contact with the connectors in the system for 8,000 hours during the year.
The weight percent of toluene in the waste is 5.6% based on the facility's data. The emissions of TOC
would be calculated as:
ETQ,-, = FA * WFTOC * N * (Number of hours in contact during the year)
= (0.00403 Ib/hr/connector) (0.85) (100) (8000 hrs/year)
= 2,740 Ib/year of TOC from connectors
The emissions of toluene from the connectors would be calculated as:
^ = Eroc*(WP,/WPTOC)
= 2,740Ib/year* (0.056/0.85)
= 181 Ib/y ear of toluene from connectors
This average emission factor approach is presented as an option for facilities with no data concerning
equipment leaks. As with all estimates derived for compliance with EPCRA Section 313, it is the
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facility's responsibility to choose the best method for estimating releases from equipment leaks.
Ash. Facilities may generate fugitive emissions during management of dry ash or dry FGD
waste. The fly ash handling operations in most electricity generating facilities consist of pneumatic
systems or enclosed and hooded systems, which are vented through control devices. Therefore, the
fugitive paniculate matter emissions from these systems are anticipated to be minimal. You should
review readily available data at your facility to identify what fugitive emissions may occur and to what
extent those emissions can be quantified. For example, you may have permit requirements in regards to
particulate matter emissions and, as part of these permits, may have facility-specific or other emission
factors for particulate matter released during ash management. Estimates for fugitive emissions may be
derived by combining these data with data on the measured or default concentrations of metal
concentrations in ash, along with annual throughput data. In particular, it may be useful to review your
permit applications, which may contain more detailed analyses of the potential for fugitive air emissions
related to ash management activities and, in some cases, may contain actual monitoring data or facility-
derived emission factors. Facilities that do not have such data may use other sources, including
engineering judgement to estimate fugitive emissions.
Wastewater Treatment. Fugitive air
emissions of volatile EPCRA Section 313
chemicals from wastewater treatment units
could be estimated using one of several
programs, such as CFLEMDAT8 and
WATERS. Volatile chemicals can evaporate
from solid waste and non-volatile chemicals
can be released to the air via particulate
emissions (e.g., ash). One tool that can be
used to estimate emissions in these situations is
CHEMDAT8 (See 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 for 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. ep a. go v/ttn/chief/software. html#water8.
Transfer and treatment operations will
result in fugitive air emissions, but waste
previously disposed of in landfills or surface
impoundments will also generate emissions. These emissions need to be considered in your release
calculations as well. These emissions will be dependent on the types and quantities of wastes placed in
the landfill or surface impoundments as well as the design and operating practices of the landfill.
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CHEMDAT8
Analytical models have been developed to estimate emissions of organic compounds via various pathways from
wastewater and waste management units. Some of these models have been assembled into a spreadsheet called
CHEMDAT8 for use on a PC. A user's guide for CHEMDAT8 is also available. Area emission sources for which
models are included in the spreadsheet are as follows: nonaerated impoundments, which include surface
impoundments and open top wastewater treatment tanks; aerated impoundments, which include aerated surface
impoundments and aerated WWT tanks; disposal impoundments, which include nonaerated disposal
impoundments; land treatment; and landfills. These models can be used to estimate the magnitude of site air
emissions for regulatory purposes. The CHEMDAT8 program and manual can be downloaded from the world
wide web at http://www.epa.gov/ttn/chief/software.html#water8.
Other Sources - Equipment. Storage. Spills. Leaks. Cleaning, etc. Fugitive air releases
of EPCRA Section 313 chemicals can occur from equipment in use, leaks in valves and fittings, losses
during cylinder changeovers, and periodic process-related cleaning operations. For small quantities of
EPCRA Section 313 chemicals otherwise used, engineering judgment can be used to estimate fugitive
releases (e.g., based on the volume of the connecting hose and the number of changeovers). If
significant quantities of chemicals are handled, fugitive releases can be estimated using the emission
factors discussed previously in regards to the use of fuels.
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.
4.2.2 Stack or Point Source Air Emissions, Section 5.2 of Form R.
Stack emissions of EPCRA Section 313 chemicals can occur from the combustion stack, storage
tanks, and plant maintenance activities. Each is discussed below.
Stack Emissions from Combustion. Amounts of EPCRA Section 313 chemicals not
captured 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
compounds in ash (e.g., barium compounds), and formaldehyde. As previously discussed in Chapter 3,
the amount of EPCRA Section 313 chemicals manufactured should be based on the best readily
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available data on constituents and associated concentrations of the coal, oil, 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 which should form the basis of estimating amounts
ultimately released as stack air emissions or otherwise managed as wastes.
Releases of EPCRA Section 313 chemicals to the stack air emission sources 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 a 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 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
calculating stack air 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 and oil. Table 4-4
presents AP-42 emission factors for metals
released during combustion of coal and fuel
oil No. 6. These factors are based on a
limited number of samples and may not
reflect more accurate information available
to the facility for the particular type of coal
combusted and pollution control devices
used. Table 4-5 presents emissions factors
for various organic compounds during
controlled coal combustion. Tables 4-6
and 4-7 show emission factors of metals
and organic compounds (respectively)
released during combustion of natural gas.
These tables are specific to
has emission factors which can be applied in
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.
Table 4-4
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EPCRA Section 313 Metal Emission Factors
for Combustion of Coal and Fuel Oil No. 6
CONTROLLED COAL COMBUSTION3
EPCRA
Section 313
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.
NO. 6 FUEL OIL COMBUSTION0
Average
Emission Factord
(lb/103 Gal)
5.25E-03
1.32E-03
2.57E-03
2.78E-05
3.98E-04
8.45E-04
2.48E-04
6.02E-03
1.76E-03
1.51E-03
3.00E-03
1.13E-04
8.45E-02
6.83E-04
Emission Factor
Rating
E
C
D
C
C
C
C
D
C
C
C
C
C
D
bEmission factor should be applied to coal feed, as
fired. To convert from Ib/ton to kg/Mg, multiply
by 0.5.
GData are for residual oil fired boilers, Source
Classification Codes (SCCs) 1-01-004-01/04.
dTo convert from lb/103 gal to kg/103 L, multiply
byO.12.
*N/A - data not available for this metal
Table 4-5
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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 Factor* (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.
Table 4-6
Emission Factors for EPCRA Section 313 Metals
from Natural Gas Combustiona
EPCRA Section 313 Metal
Arsenic
Barium
Chromium
Cobalt
Copper
Lead
Manganese
Nickel
Vanadium
Average Emission Factor b (Ib/million ft 3 )
2.30E-04
2.40E-03
1.10E-03
1.20E-04
2.51E-04
2.71E-04
3.81E-04
3.61E-03
3.21E-03
11 Data are for natural gas boilers controlled with overfire air and flue gas recirculation.
Source Classification Codes 1-01-006-04.
b Based on data from one source test. To convert from Ib/million ft3 to kg/million m3 ,multiply by 16.0.
Emission Factor Rating: E
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Table 4-7
Emission Factors for Speciated Organic Compounds
from Natural Gas Combustiona
Organic Compound
Formaldehyde
Naphthalene
Phenanthrene
Toluene
Average
Emission Factor (Ib/million ft 3 )
1.55E-01 "
2.40E-04 °
l.OOE-05 °
2.20E-03'
1 Data are based on boilers that were both controlled and uncontrolled for criteria pollutant emissions.
Source Classification Codes 1-01-006-01, 1-01-006-04. To convert from Ib/million ft3 to
kg/million m3 , multiply by 16.0.
b References 31-36.
c Reference 32. Based on data from one source test.
Emission Factor Rating is E for all chemicals except formaldehyde, which is C.
certain conditions (e.g., coal classification, boiler configuration). AP-42 emission factors for other
chemicals and fuels are also available. For example, there are AP-42 emission factors for organic
compounds released from the combustion of residual oils (which include No. 6 fuel oil) and distillate
fuels (which include No.2 fuel oil), and for various chemicals released during the combustion of liquefied
petroleum gas, wood waste, and waste. AP-42 can be found at
http://www.epa.gov/ttn/chief/ap42etc.html.
Combustion of coal may also result in emissions of sulfuric acid (acid aerosols), hydrochloric acid (acid
aerosols), and hydrogen fluoride (Fff). 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.
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Storage Tanks. Electricity generating
facilities should consider point source air
emissions from tanks that store materials
containing volatile chemicals, such as Fuel oil
No.2 and hydrazine. AP-42 provides detailed
information on the calculation of air emissions
during the storage and transfer of liquids. A
number 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 then 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 data base 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.
AP-42: Emission Factor Quality Ratings
Used in Tables 4-4 and 4-5
A Excellent. Factor is developed from A- and B-rated
source test data taken from many randomly chosen facili les
in the industry population. The source category populat on
is sufficiently specific to minimize variability.
B Above average. Factor is developed from A- or B-ratc
test data from a "reasonable number" of facilities. Altho igh
no specific bias is evident, it is not clear if the facilities
tested represent a random sample of the industry. As wi h
an A rating, the source category population is sufficientl
specific to minimize variability.
C Average. Factor is developed from A-, B-, and/or C-rt ted
test data from a "reasonable number" of facilities. Althoi gh
no specific bias is evident, it is not clear if the facilities
tested represent a random sample of the industry. As wi
the A rating, the source category population is sufficient
specific to minimize variability.
D Below average. Factor is developed from A-, B- andA r
C-rated test data from a small number of facilities, and th
may be reason to suspect that these facilities do not
represent a random sample of the industry. There also m;
be evidence of variability within the source population.
E Poor. Factor is developed from C- and D-rated test da
and there may be reason to suspect that the facilities tes
do not represent a random sample of the industry. There
also may be evidence of variability within the source
category population.
ed
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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's AP-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.
Plant Maintenance Facilities should not forget to consider stack or point source emissions
generated from periodic plant maintenance activities. For example, facilities that evaporate or incinerate
boiler cleaning wastes should examine EPCRA Section 313 chemicals generated from theses activities.
Facilities can use air permit applications and associated materials as well as process knowledge to
estimate emissions from evaporation or incineration of boiler wastes.
4.2.3 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. Facilities may discharge wastewater resulting from various on-site
operations. The two main sources of wastewater are ash transport water and cooling water. Facilities
may also discharge miscellaneous plant wastewater, water remaining after FGD sludge dewatering, and
wastewater from periodic boiler and equipment cleaning operations.
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 information in making these estimates as needed. See box for an
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example calculation.
Example Calculation of Yearly Wastewater
Discharge
A facility has monitoring data on discharges to water of xylene, a
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:
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.
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).
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:
(8.33 Ibs. + 0.332 lbs.)/2 days x 365 days/year = 1580.82 Ibs/yr
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.
4-41
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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 collect under the piles forming runoff. In addition to the chemicals
applied to the coal pile such as ethylene glycol, 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 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 electricity generating 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.
4.2.4 Disposal to Land On-site, Section 5.5 of Form R.
Facilities dispose of combustion wastes (e.g., ash), FGD wastes, and other wastes on site.
Accidental releases can also lead to EPCRA Section 313 chemicals being disposed to land on-site.
Each of these is discussed below.
Combustion Wastes. Some electricity generating facilities dispose of large amounts of ash
containing EPCRA Section 313 chemicals on-site. Most electricity generating facilities dispose of ash
at sites that are not contiguous or adjacent to the facility. Bottom or fly ash may be disposed in landfills,
surface impoundments, 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 is
disposed on-site, regardless of concentration, provided that thresholds have been exceeded for these
chemicals. Ash disposed in a landfill or otherwise applied to the land is considered a waste
management activity and must be reported.
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
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Table 4-8.
Table 4-8 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) Oil Ash (ppm)
10
168
9,360
10
5,820
932
1,082
1,940
4.2
2,939
14
9.9
537
1,796
1,072
10,000
1,000
11
4,390
130,000
100,000
1,170
1
180,000
500
10
460,000
100,000
Source: Inorganic and Organic Constituents in Fossil Fuel Combustion Residues, Volume 1,
Critical Review, Battelle, Pacific Northwest Laboratory forEPRI, EA5176, August 1987.
Flue Gas Desulfurization (FGD) Wastes. Wet FGD systems result in a waste slurry of
hydrated calcium sulfate and sulfite, and unreacted lime, which may be dewatered and/or stabilized with
fly ash and disposed in impoundments or landfills. Dry FGD systems spray an alkaline solution into the
flue gas to react with the sulfur oxides. The water from the solution evaporates into the flue gas, leaving
a dry powder, which is collected by a particulate collector such as a baghouse, and often disposed on-
site. Metal compounds coincidentally manufactured in FGD systems must be considered toward
threshold determinations and release and other waste management calculations, and are not subject to
the de minimis exemption.
Several data sources may be used to calculate the amount of EPCRA Section 313 chemicals in
FGD wastes. These sources include waste analyses, NPDES permits, and waste characterization
performed to meet state or other solid waste management requirements. The best "readily available"
data should be used to estimate concentrations of EPCRA Section 313 chemicals in FGD sludge solids
and liquors. In the absence of facility specific data, the values presented in Table 4-9 may be used to
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estimate concentrations of certain trace metals in FGD sludge solids and liquors. Only the weight of the
parent metal must be considered when reporting releases and other waste management activities of
EPCRA Section 313 metal compounds.
Table 4-9. Concentrations of Certain Trace Metals in FGD Sludge Solids and Liquors
Trace Element
Arsenic
Boron
Cadmium
Chromium
Copper
Mercury
Lead
Selenium
Sludge Solids
(ppm)
52.0
530.0
25.0
180.0
340.0
6.0
290.0
60.0
Sludge Liquors (ppm)
0.1
76.0
0.1
0.3
0.5
0.1
0.5
1.9
Source: The Release of Trace Metals From Limestone During Flue Gas Desulfurization
by Electric Utilities, p. 7.
Other Wastes. Electricity generating facilities may also dispose of other wastes such as
filtration and coagulation residues, demineralization regenerant products, brine from reverse osmosis,
slurries from polishers, blowdown from boilers and recirculating cooling water systems, cooling tower
sludges, solids from oil filtration and settled materials from coal pile runoff. To calculate quantities of
EPCRA Section 313 chemicals that may be present in these wastes, facilities can use waste analyses,
process knowledge, operating records, pollution prevention data, mass balance or other readily
available information sources.
Note that 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 a portion of that waste 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.
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Accidental Releases to Land. Leaks, spills, and drips from the loading and transfer of oil
and other materials received 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 of the EPCRA Section 313 chemical(s) 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 which was not cleaned up as a response to the accident. Equations found in
Section 6 ofEP'A:'s Estimating Releases
and Waste Treatment Efficiencies for
the Toxic Chemical Release Inventory
Form, provide guidance on calculating
releases from chemical spills or leaks,
including liquid discharges, fraction of
discharge flashed, vaporization, two-phase
discharges, and gas discharges.
4.2.5 Transfers Off-site, Section 6.2
of Form R.
Electricity generating facilities may
send wastes off-site for waste
management. Most commonly,
combustion wastes will be sent off-site for
disposal. For example, electricity
generating facilities may send EPCRA
Section 313 chemicals in ash off-site for
disposal in a landfill. Facilities must report
the quantities of EPCRA Section 313
chemicals in these wastes in Sections 6.2
and 8 of Form R. These amounts are
reportable whether they are sent to a
facility within the same company, or to a
different company. For example, if an
electricity generating facility sends ash to a
landfill owned by the same company that is
on non-contiguous, non-adjacent property
(i.e., a separate facility), then the electricity
generating facility must report those
amounts as transferred off-site if the
ultimate disposition in the reporting year is
for disposal.
Example - Seepage From a Landfill
If a facility in one of the new industries, which begins
reporting for activities conducted in 1998, has information
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
Section 313 chemical disposed.
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". These codes are considered disposal
codes for EPCRA Section 313 reporting purposes.
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EPCRA Section 313 chemicals in ash sent off-site for use in mining reclamation or to be used
as aggregate in road construction are also considered off-site transfers of wastes for disposal. These
uses of ash are not considered analogous to using a substitute material with a commercial value. You
must report amounts of EPCRA Section 313 chemicals in ash sent off-site for mining reclamation or for
use as road aggregate on the Form R. Because these chemicals are being managed as a waste by the
off-site location, the de minimis exemption does not apply.
The same methods discussed previously for estimating quantities disposed on-site can be used
to estimate amounts sent off-site for disposal. Wastes sent off-site that are regulated under RCRA
Subtitle C will also have waste analyses and waste profiles.
Electricity generating facilities may also distribute ash into commerce for use in the construction
industry, or for metals recovery. When ash is distributed in commerce to be directly used by an off-site
entity, the amounts of EPCRA Section 313 chemicals distributed in commerce are not reported on the
Form R. For example, an electricity generating facility that sells ash to a construction facility who
incorporates the ash directly into the manufacture of cement, does not report quantities of EPCRA
Section 313 chemicals in that ash on the Form R. However, EPCRA Section 313 chemicals sent off-
site in waste for recycling; for example, oil combustion ash sent off-site for vanadium recovery will
undergo a waste management activity and should be reported on the Form R as a transfer off-site for
recycling in Sections 6.2 and 8.5 of Form R. Facilities may use metal analyses of ash along with the
quantities of the ash sent off-site for disposal or recycling to calculate the pounds of the metal
transferred off-site.
Example - Storage of Ash on Land
Is ash placed on-site in a landfill waiting to be sold during construction season considered a release to land for
the reporting year prior to its transfer?
Material that is placed in a landfill on site during a reporting year does not have to be reported as a release to
land on-site if the landfill was only used for temporary storage. EPA will consider the landfill used for temporary
storage if the facility routinely made off-site transfers of material from the pile during that reporting year or the
facility had a contract in place before the end of the reporting year to transfer the material and transferred the
material containing EPCRA Section 313 chemicals off-site before that year's report was required or by July 1,
whichever comes first.
4.2.6 On-site Waste Management Methods, Section 7 A, 7B, and 7C of Form R.
On-site waste management at electricity generating facilities include treatment and energy
recovery. Recycling of wastes is not usually performed at electricity generating facilities.
On-site Treatment Methods. Section 7A of Form R. Electricity generating facilities may
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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 TRIForms and
Instructions document. The following are some examples of treatment methods that electricity
generating facilities may use:
lAsh or other solid wastes may pass through several steps, including filtration (P12), sludge dewatering
(P13), settling/clarification (PI 1), and thermal drying/dewatering (F83).
2Facilities commonly treat flue gas using scrubbers (A03), electrostatic precipitators (A05), and
baghouses (A06).
• Wastewater (such as coal pile runoff, boiler cleaning wastewater, etc.) may go through
several treatment steps, including neutralization (Cl 1), settling/clarification (PI 1),
filtration (P12), 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) plant maintenance wastes, such as
those from boiler cleaning.
For metal compounds, the calculation of the reportable concentration and waste treatment
efficiency must be based on the weight of the parent metal, not on the weight of the metal compounds.
Metals are not destroyed, only physically removed or chemically converted from one form into another.
The waste treatment efficiency reported must represent only physical removal of the parent metal from
the waste stream (except for incineration), not the percent chemical conversion of the metal compound.
If a listed waste treatment method converts but does not remove a metal (e.g., chromium reduction),
the method must be reported with a waste treatment efficiency of zero.
All data available at your facility must be used to calculate waste treatment efficiency and the
influent concentration of the EPCRA Section 313 chemical. If data are lacking, estimates can be made
using best engineering judgement or other methods.
On-site Energy Recovery Processes. Section 7B. Facilities should only report energy
recovery methods used on EPCRA Section 313 chemicals in wastes. Therefore, combustion of
commercially available fuels, such as coal or oil, is not considered energy recovery under EPCRA
Section 313 or the Pollution Prevention Act. Coal tar, a by-product of destructive distillation in the
production of coke, is not a waste and, therefore, its combustion is not reportable in Section 7B (or
Section 8) of Form R. As discussed in Chapter 4.1 of this document, facilities can only report energy
recovery of EPCRA Section 313 chemicals if they have a significant heating value and are burnt on-site
in a combustion unit that is integrated into an energy recovery system.
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4.2.7 Source Reduction and Recycling Activities, Section 8 of Form R.
In chapter 4.1.3, the general method for developing Section 8 quantities was discussed. Two
examples of how to calculate Section 8 quantities are presented below:
Table 4-10: Examples of Section 8 Reporting
Section
Section 8. 1, Quantity released
Section 8.2, Quantity used for
energy recovery on-site
Section 8.3, Quantity used for
energy recovery off-site
Section 8.4, Quantity recycled
on-site
Section 8.5, Quantity recycled
off- site
Section 8.6, Quantity treated on-site
Section 8.7, Quantity treated off-site
Metal Compounds
Fugitive and stack air emissions,
releases to water and POTW, and
off-site waste transfers for disposal
Not applicable to these metal
compounds that are products of
combustion
Not applicable to these metal
compounds that are products of
combustion
Not generally performed at EGFs
Off-site waste transfers with
recycling codes
Not possible to destroy metal
compound
Not possible to destroy metal
compound
Sulfuric Acid (Acid
Aerosols) and HC1 (Acid
Aerosols)
Fugitive and stack air emissions
(cannot release the aerosol in liquid
or solid form)
Not applicable to these acid
aerosols that are products of
combustion
Not applicable to these acid
aerosols that are products of
combustion
Not generally performed at EGFs
Not generally transferred off site in
aerosol form
Treated in scrubbers such as FGD
systems
Not generally transferred off site in
aerosol form
4.2.8 Source Reduction Activities, Section 8.10 of Form R.
Facilities have the opportunity to report source reduction actions initiated during the reporting year on
the Form R using codes listed in the Form R and Instructions. Some examples of source reduction
activities and suggested codes are given below.
• Reducing the frequency of boiler cleanings and, therefore, the amount of boiler cleaning
wastes by tracking process chemistry and monitoring boiler cleanliness to determine
more precisely the need for cleaning. (W13: Improved maintenance scheduling,
recordkeeping, or procedures)
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Reducing the frequency of boiler cleanings and the amount of boiler cleaning wastes by
applying a protective coating to the inside surfaces of boiler tubes to prevent
accumulation of scale on tube surfaces. (W52: Modified equipment, layout or piping)
Reducing the need for corrosion inhibitors in cooling towers by using inert construction
materials, such as polyethylene and stainless steel, rather than carbon steel. (W42:
Substituted raw materials, or W58: Other process modifications)
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)
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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-
KnowAct, 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
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
A-l
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A-2
-------
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
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
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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
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.
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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.
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.
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Order Number: 68-02-4248
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Air
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
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
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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
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
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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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