United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
Washington, DC 20460
EPA745-R-98-014
December 1998
s&EPA Emergency Planning Community Right-To-
Know Act Section 313 Reporting Guidance
for Spray Application and Electrodeposition
of Organic Coatings
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TABLE OF CONTENTS
Page
ACKNOWLEDGMENT v
OVERVIEW vi
CHAPTER 1 - INTRODUCTION 1-1
1.0 PURPOSE 1-1
1.1 Background on EPCRA 1-2
CHAPTER 2 - REPORTING REQUIREMENTS 2-1
2.0 PURPOSE 2-1
2.1 Must You Report? 2-2
2.2 SIC Code Determination 2-4
2.3 Number of Employees 2-7
2.4 Manufacturing, Processing, and Otherwise Use of EPCRA Section
313 Chemicals or Chemical Categories 2-8
2.5 Activity Categories 2-11
2.6 How Do You Report? 2-14
2.7 Form R 2-14
2.8 Alternate Threshold and Form A 2-15
2.9 Trade Secrets 2-17
2.10 Recordkeeping 2-17
CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL CATEGORY
ACTIVITY THRESHOLD DETERMINATIONS 3-1
3.0 PURPOSE 3-1
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported), Processed, or
Otherwise Used 3-1
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for Each
EPCRA Section 313 Chemical and Chemical Category 3-7
3.2.1 Concentration Ranges for Threshold Determination 3-11
3.2.2 Evaluation of Exemptions 3-12
3.2.2.1 De Minimis Exemption 3-12
3.2.2.2 Article Exemption 3-15
3.2.2.3 Facility-Related Exemption 3-17
3.2.2.4 Activity-Related Exemptions 3-17
3.2.3 Additional Guidance on Threshold Calculations for
Certain Activities 3-19
3.2.3.1 Reuse Activities 3-19
3.2.3.2 Remediation Activities 3-20
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TABLE OF CONTENTS (Continued)
Page
3.2.3.3 Recycling Activities 3-21
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313 Chemical
and Chemical Category and Determine Which Ones Exceed an
Activity Threshold 3-21
CHAPTER 4 - ESTIMATING RELEASES AND
OTHER WASTE MANAGEMENT QUANTITIES 4-1
4.0 PURPOSE 4-1
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities 4-1
4.1.1 Step 1: Prepare a Process Flow Diagram 4-3
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical
Categories and Potential Sources of Chemical Release and
Other Waste Management Activities 4-3
4.1.3 Step 3: Identify Release and Other Waste Management Activity
Types 4-4
4.1.4 Step 4: Determine the Most Appropriate Method(s) and Calculate
the Estimates for Release and Other Waste Management Activity
Quantities 4-16
4.1.4.1 Monitoring Data or Direct Measurement (code ME-)18
4.1.4.2 Mass Balance (code C) 4-19
4.1.4.3 Emission Factors (code E) 4-21
4.1 A A Engineering Calculations (code O) 4-23
4.1.4.5 Estimating Release and Other Waste Management
Quantities 4-25
4.2 Process Descriptions (Chemical Activities) 4-30
4.2.1 Surface Preparation 4-32
4.2.1.1 Abrasive Cleaning 4-33
4.2.1.2 Cleaning/Degreasing 4-37
4.2.1.3 Rinsing 4-41
4.2.1.4 Phosphating 4-43
4.2.2 Spray Application 4-47
4.2.3 Electrodeposition 4-54
4.2.4 Flash-Off and Curing 4-60
Appendix A EPCRA SECTION 313 GUIDANCE RESOURCES
Appendix B BASIC CALCULATION TECHNIQUES
Appendix C LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR REPORTING
Appendix D EPCRA SECTION 313, GUIDANCE FOR REPORTING AQUEOUS
AMMONIA
INDEX
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LIST OF TABLES
Page
2-1 SIC Codes Covered by EPCRA Section 313 Reporting 2-4
2-2 SIC Codes for Facilities That May Include Organic Coating Operations 2-5
2-3 EPCRA Section 313 Chemicals and Chemical Categories Commonly Encountered
in Organic Coatings Operations 2-9
2-4 Activity Categories 2-12
3-1 Reporting Thresholds 3-7
3-2 Definitions and Examples of Manufacturing Subcategories 3-9
3-3 Definitions and Examples of Processing Subcategories 3-9
3-4 Definitions and Examples of Otherwise Use Subcategories 3-10
3-5 EPCRA Section 313 Reporting Threshold Worksheet 3-24
3-6 Sample EPCRA Section 313 Reporting Threshold Worksheet 3-25
4-1 Summary of Residue Quantities From Pilot-Scale Experimental Study 4-9
4-2 Potential Data Sources for Release and Other Waste Management
Calculations 4-18
4-3 Release and Other Waste Management Quantity Estimation Worksheet .... 4-26
4-4 Estimated Percentage of Overspray Resulting from Listed Spray Methods .. 4-50
4-5 Collection Efficiencies for Dry Particulate Collection Filters 4-52
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LIST OF FIGURES
Page
2-1 EPCRA Section 313 Reporting Decision Diagram 2-3
4-1 Releases and Other Waste Management Activity Calculation Approach 4-2
4-2 Possible Release and Other Waste Management Activity Types for EPCRA
Section 313 Chemicals and Chemical Categories 4-4
4-3 Overall Process Flow Diagram - Application of Organic Coatings 4-31
4-4 Process Flow Diagram - Abrasive Cleaning 4-34
4-5 Process Flow Diagram - Cleaning/Degreasing 4-37
4-6 Process Flow Diagram - Rinsing (counter-current) 4-41
4-7 Process Flow Diagram - Phosphating 4-44
4-8 Process Flow Diagram - Spray Application 4-48
4-9 Process Flow Diagram - Electrodeposition 4-56
4-10 Process Flow Diagram - Flash-Off and Curing 4-61
IV
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ACKNOWLEDGMENT
The U.S. EPA wishes to acknowledge the valuable contributions made by the staff and members
of the National Paint and Coatings Association (NPCA), the Association of International
Automobile Manufacturers, Inc. (AIAM), and the American Automobile Manufacturers
Association (AAMA). Without the insight provided by those in industry with actual experience in
fulfilling the reporting requirements of EPCRA Section 313 we would not have been able to
produce a document that we believe will be of great assistance to those who must prepare future
EPCRA Section 313 reports. Special thanks go to Mr. David Darling, Assistant Director,
Environmental Affairs, NPCA; Ms. Amy Lilly, Director, Manufacturing Operations, and Ms. Tara
Vizzi, Regulatory Environmental Engineer, Manufacturing Operations, AIAM; and Mr. Dave
Felinski, Manager of Occupational and Environmental Programs, AAMA for their hard work.
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OVERVIEW
This document supersedes the booklets entitled Title III Section 313 Release
Reporting Guidance, Estimating Chemical Releases from Electrodeposition of Organic Coatings
and Title III Section 313 Release Reporting Guidance, Estimating Chemical Releases from Spray
Application of Organic Coatings, both dated January 1988. It is intended to assist establishments
and facilities performing electrodeposition and spray application of organic coatings in complying
with the Emergency Planning and Community Right-To-Know Act (EPCRA) Section 313
reporting requirements, the preparation of Form R or the alternate certification statement, Form
A. The EPCRA Section 313 program is commonly referred to as the Toxic Chemical Release
Inventory (TRI).
The principal differences in the new document include:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
U.S. Environmental Protection Agency's (U.S. EPA's) interpretive
guidance on various issues specific to organic coating operations; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
documents.
This document is designed to be a supplement to the annual issue of the Toxic
Chemical Release Inventory Reporting Forms and Instructions, (TRI Forms and Instructions). It
is organized to provide a step-by-step guide to compliance with EPCRA Section 313, starting
with how to determine if your facility must report and ending with guidance for estimating
release and other waste management activity quantities.
The primary purposes for the application of organic coatings are protection and
decoration. The most widely used methods of organic coating application in the Standard
Industry Classification (SIC) Codes covered by EPCRA Section 313 are electrodeposition and
spray application. They are also the coating technologies with the potential for the largest release
and other waste management activity quantities. The application of an organic coating by either
method is essentially a three-step process:
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1. Surface preparation - cleaning and pre-treatment.
2. Application of the organic coating.
3. Flash-off and curing.
Steps 1 and 3 are similar, even identical, for both the application processes discussed in this
document. Likewise, many of the EPCRA Section 313 chemicals and chemical categories in the
application operations are similar, even identical. For these reasons, guidance for both coating
technologies has been combined in this document.
It is recognized that not all organic coating establishments will have all unit
operations described in this document. For example, original equipment manufacturers may not
have an abrasive cleaning step to remove old coatings. However, each of the unit operations
discussed are common operations found in organic coating establishments covered by EPCRA
Section 313 reporting requirements. You should select the operation, or combination of
operations, that most closely fits the activities at your establishment.
Chapter 1 introduces EPCRA Section 313 reporting and provides a brief
background on Section 313 of EPCRA.
Chapter 2 discusses reporting requirements and begins with how to determine
whether your facility must report. This determination is based on your answers to a series of four
questions:
• Is your facility's primary SIC Code on the EPCRA Section 313 list?
• Does your facility employ ten or more full-time employees or the
equivalent?
• Does your facility manufacture, process, or otherwise use any EPCRA
Section 313 chemicals or chemical categories?
• Does your facility exceed any of the activity thresholds for an EPCRA
Section 313 chemical or chemical category?
If the answer to ANY ONE of the first three questions is "No" you are not
required to submit an EPCRA Section 313 report. If you answer "Yes" to ALL four questions,
the next step is to determine what kind of report you must prepare, a Form R or the alternate
certification statement, Form A. Chapter 2 provides detailed information on the requirements for
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each kind of report. Chapter 2 concludes with a discussion on how to address trade secrets and
the records that should be kept to support your reporting.
Chapter 3 discusses how to calculate the activity thresholds (manufacture, process,
and otherwise use) for the EPCRA Section 313 chemicals or chemical categories. Information is
provided on how to determine which EPCRA Section 313 chemicals or chemical categories your
facility manufactures, processes, or otherwise uses and how to calculate the quantities of each.
Detailed information is also provided on the various exemptions:
• De minimis exemption;
• Article exemption;
• Facility-related exemption; and
• Activity-related exemptions.
Chapter 3 concludes with a discussion of how to determine which EPCRA Section 313 chemicals
or chemical categories exceed a reporting threshold.
Chapter 4 discusses how to estimate the release and other waste management
activity amounts for those EPCRA Section 313 chemicals and chemical categories for which you
must prepare a report. The first part of this chapter provides a step-by-step approach designed to
minimize the risk of overlooking an activity involving an EPCRA Section 313 chemical or
chemical category and any potential sources or types of release and other waste management
activities. This procedure consists of:
• Preparation of a detailed process flow diagram;
• Identification of EPCRA Section 313 chemicals and chemical categories
and potential sources of chemical release and other waste management
activities;
• Identification of the potential types of release and other waste management
activities from each source; and
• Determination of the most appropriate methods for estimating the
quantities of EPCRA Section 313 chemical and chemical category release
and other waste management activities.
The second part of Chapter 4 is organized by the three typical activities in organic
coating operations where EPCRA Section 313 chemicals and chemical categories are used:
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surface preparation, coating application (spray application or electrodeposition), and curing. The
commonly used EPCRA Section 313 chemicals and chemical categories, process descriptions,
release and other waste management activity estimates, example calculations, and common
problems are presented.
This document includes examples and common errors applicable to organic coating
operations. These examples are based on information identified during voluntary site surveys of
facilities that have filed EPCRA Section 313 reports in the past, discussion with representatives of
the National Paint and Coatings Association, the Association of International Automobile
Manufacturers, and the American Automobile Manufacturers Association, and on questions
received by the EPCRA Hotline.
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CHAPTER 1 - INTRODUCTION
1.0 PURPOSE
The purpose of this guidance manual is to assist facilities performing
electrodeposition or spray application of organic coatings in complying with the reporting
requirements of Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) and of Section 6607 of the Pollution Prevention Act of 1990 (PPA). This manual
explains the EPCRA Section 313 reporting requirements and discusses specific release and other
waste management activities encountered at many facilities that conduct these organic coating
operations. Spray application and electrodeposition are the most widely used and prevalent
coating techniques in the Standard Industry Classification (SIC) Codes covered by EPCRA
Section 313. They are also the coating technologies with the potential for the largest release and
other waste management activity quantities. Since each plant is unique, the recommendations
presented may have to be modified for your particular facility.
This manual is intended solely for guidance and does not alter any statutory or
regulatory requirements. The document should be used in conjunction with statutes and
regulations but does not supersede them. Accordingly, the reader should consult other applicable
documents (for example, the statute, the Code of Federal Regulations (CFR), relevant preamble
language, and the current Toxic Chemical Release Inventory Reporting Forms and Instructions
(TRI Forms and Instructions).
This document supersedes the 1988 documents entitled Title III Section 313
Release Reporting Guidance, Estimating Chemical Releases from Electrodeposition of Organic
Coatings and Title III Section 313 Release Reporting Guidance, Estimating Chemical Releases
from Spray Application of Organic Coatings. This new document includes:
More detailed examples;
New EPCRA Section 313 regulations and guidance developed since 1988;
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U.S. Environmental Protection Agency's (U.S. EPA's) interpretive
guidance on various issues specific to organic coating operations; and
EPCRA Section 313 issues regarding processes not discussed in the earlier
document.
It is intended to supplement the TRI Forms and Instructions document that is updated and
published annually by U.S. EPA. It is essential that you use the current version of the TRI Forms
and Instructions to determine if (and how) you should report. Changes or modifications to
EPCRA Section 313 reporting requirements are reflected in the annual TRI Forms and
Instructions and should be reviewed before compiling information for the report.
The objectives of this manual are to:
Reduce the level of effort expended by those facilities that prepare an
EPCRA Section 313 report; and
Increase the accuracy and completeness of the data being reported.
U.S. EPA cannot anticipate every potential issue or question that may apply to
your facility. Therefore, this manual attempts to address those issues most prevalent or common
for organic coating operations. Used in conjunction with the most current TRI Forms and
Instructions and Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (1999 version), facilities should be able to provide complete and accurate
information for EPCRA Section 313 reporting. Additional discussions on specific issues can be
found in U.S. EPA's current edition of EPCRA Section 313, Questions and Answers (the 1998
edition is EPA 745-B-98-004), which is available on the U.S. EPA's TRI website
(http://www.epa.gov/opptintr/tri) or by contacting the EPCRA Hotline at 1-800-424-9346 In
the Washington DC metropolitan area, call 703-412-9810.
1.1 Background on EPCRA
The following overview of EPCRA, specifically Section 313, and Section 6607 of
the PPA, will provide you with a basic understanding of the objectives and requirements of this
program, and will help you in completing your forms.
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One of the primary goals of EPCRA is to increase the public's knowledge of, and
access to, information on both the presence of toxic chemicals in their communities and on
releases into the environment and other waste management activities of those chemicals. EPCRA
Section 313 requires certain designated businesses (see SIC Code discussion, Chapter 2, Section
2.2) to submit annual reports (commonly referred to as Form R reports and Form A reports) on
the amounts of over 600 EPCRA Section 313 chemicals and chemical categories released and
otherwise managed as waste. Throughout this document, whenever EPCRA Section 313
chemicals are discussed, the discussion includes chemical categories, as appropriate. Chemicals
or chemical categories may be added or deleted from the list. Therefore, before completing your
annual report, be sure to check the most current list included with the TRI Forms and Instructions
when evaluating the chemicals and chemical categories in use at your facility. Copies of the
reporting package can be requested from the EPCRA Hotline, 1-800-424-9346.
All facilities meeting the EPCRA Section 313 reporting criteria must report the
annual releases and other waste management activity quantities (routine and accidental) of
EPCRA Section 313 chemicals and chemical categories to all environmental media. A separate
report is required for each EPCRA Section 313 chemical or chemical category that is
manufactured (including imported), processed, or otherwise used above the reporting threshold.
The reports are submitted to U.S. EPA and State or Tribal governments, on or before July 1, for
activities in the previous calendar year. The owner/operator of the facility on July 1 is primarily
responsible for the report, even if the owner/operator did not own the facility during the reporting
year. However, property owners with no business interest in the operation of the facility (for
example, owners of an industrial park) are exempt from reporting requirements.
EPCRA also mandates U.S. EPA to establish and maintain a publicly available
database system consisting of the information reported under Section 313 and under Section 6607
of the PPA. This database, known as the Toxic Chemical Release Inventory (TRI) database, can
be accessed through the following sources:
National Library of Medicine (NLM) TOXNET on-line system;
U.S. EPA Internet site, http://www.epa.gov/opptintr/tri;
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Envirofacts Warehouse Internet site, http://www.epa.gov/enviro/html/tris;
CD-ROM from the Government Printing Office;
Microfiche in public libraries; and
Magnetic tape and diskettes from the National Technical Information
Service.
Information identified by the submitter as trade secret in accordance with the
regulatory requirements is protected from public release. In addition to being a resource for the
public, TRI data are also used in the research and development of regulations related to EPCRA
Section 313 chemicals and chemical categories.
To reduce the reporting burden for small businesses, U.S. EPA established an
alternate activity threshold of one million pounds manufactured, processed, or otherwise used for
facilities with total annual reportable amounts of 500 pounds or less of the EPCRA Section 313
chemical or chemical category. Provided the facility does not exceed either the reportable amount
or the alternate threshold, the facility may file a certification form (Form A) rather than file a
Form R. By filing the Form A the facility certifies that they do not exceed the reportable amount
of 500 pounds or exceed the alternate threshold of one million pounds.
Note that the annual reportable amount includes the quantity of the EPCRA
Section 313 chemical or chemical category in all production-related waste management activities,
not just releases (see the discussion in Section 2.8 for more detail). Also note that either a Form
A or a Form R, but not both, must be submitted for each EPCRA Section 313 chemical or
chemical category above any reporting threshold, even if there are zero release and other waste
management activity quantities.
Violation of EPCRA Section 313 reporting provisions may result in federal civil
penalties of up to $27,500 per day for each violation (61 FR 69360). State enforcement
provisions may also be applicable depending on the state's EPCRA Section 313 reporting
regulations.
Members of the National Paint and Coatings Association, the Association of
International Automobile Manufacturers, and the American Automobile Manufacturers
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Association provided input on common problems, specific to organic coating operations,
encountered by those completing the EPCRA Section 313 reports. U.S. EPA has combined this
input with questions forwarded to the EPCRA Hotline and those identified during voluntary site
surveys of facilities that have filed EPCRA Section 313 reports in the past. Selected issues and
guidance addressing these common problems are presented throughout this document as
applicable.
The TRI Forms and Instructions also contains a discussion of common problems in
completing the EPCRA Section 313 reports. You are encouraged to read this discussion before
filling out the Form R (or Form A) for your facility.
If, after reading this manual, you still have questions about EPCRA Section 313
reporting, please contact the EPCRA Hotline at 1-800-424-9346. Assistance is also available
from the designated EPCRA Section 313 Coordinator in the U.S. EPA regional office and the
EPCRA contact in your state (see the TRI Forms and Instructions for a current list of these
contacts). Additional guidance is also available in the resources listed in Appendix A.
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CHAPTER 2 - REPORTING REQUIREMENTS
2.0 PURPOSE
The purpose of this chapter is to help you determine if you must prepare an
EPCRA Section 313 report(s) and, if so, what kind of a report(s) should be prepared (Form R or
the alternate certification statement, the Form A). This chapter presents the EPCRA Section 313
reporting requirements to help you determine if these requirements apply to your facility. It also
discusses the reporting of trade secrets and the records that must be kept.
To understand the following discussion you must first understand how EPCRA
defines a facility. The term "facility" is defined as, "all buildings, equipment, structures, and other
stationary items which are located on a single site or on contiguous or adjacent sites and which
are owned or operated by the same person (or by any person 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).
U.S. EPA recognizes that for business reasons it may be easier and more
appropriate for multiple establishments at one facility to report separately. However, the
combined quantities of EPCRA Section 313 chemicals and chemical categories manufactured,
processed, or otherwise used in all establishments in that facility must be considered for threshold
determinations. Also, the combined release and other waste management activity quantities
reported singly for each establishment must equal those for the facility as a whole.
Note that if a facility is comprised of more than one establishment, once an activity
threshold is met by the facility, providing the facility meets SIC Code and employee criteria,
release and other waste management activities from all establishments at the facility must be
reported. The preceding discussion is particularly applicable to organic coating operations since
they may be one of several industrial establishments using EPCRA Section 313 chemicals and
chemical categories at a large manufacturing facility.
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Example - Multiple Establishments
Your facility has several different establishments, all with SIC Codes covered under EPCRA Section 313. One
establishment used 7,000 pounds of toluene, an EPCRA Section 313 chemical, during the year to clean equipment.
Another establishment purchased and used 4,000 pounds of toluene during the year as a solvent to separate a
component from a mixture, with recovery of the toluene for reuse. Both activities constitute otherwise use of the
EPCRA Section 313 chemical (as presented in Section 2.5 and described in detail in Chapter 3) and the total for the
facility exceeded the 10,000-pound otherwise use threshold for the year. Thus, if your facility meets the employee
threshold, you must file one Form R for toluene from your facility, or two Form Rs, one from each establishment.
Please note that you may be eligible to file one Form A for the facility but you cannot file a separate Form A for each
establishment.
2.1 Must You Report?
How do you determine if your facility must prepare an EPCRA Section 313
report? Your answers to the following four questions will help you decide (illustrated by Figure
2-1):
1) Is the primary SIC Code for your facility included in the list covered by
EPCRA Section 313 reporting (see Section 2.2)?
2) Does your facility have 10 or more full-time employees or the equivalent
(see Section 2.3)?
3) Does your facility manufacture (which includes importation), process, or
otherwise use EPCRA Section 313 chemicals or chemical categories (see
Section 2.4)?
4) Does your facility exceed any applicable thresholds of EPCRA Section 313
chemicals or chemical categories (25,000 pounds per year for
manufacturing; 25,000 pounds per year for processing; or 10,000 pounds
per year for otherwise use - see Section 2.5)?
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Is Your Facility's Primary SIC Code Included
on the EPCRA Section 313 List?
(See Section 2.2)
NO
YES
Does Your Facility Have 10 or More Full-Time
Employees or the Equivalent?
(See Section 2.3)
NO
YES
Does Your Facility Manufacture, Process, or
Otherwise Use Any EPCRA Section 313
Chemicals or Chemical Categories?
(See Section 2.4)
NO
STOP
NO EPCRA
SECTION 313 REPORTS
REQUIRED FOR ANY
CHEMICALS OR
CHEMICAL CATEGORIES
YES
Does Your Facility Exceed Any of the Thresholds
for a Chemical or Chemical Category (after
excluding quantities that are exempt from
threshold calculations)
(See Section 2.5)
NO
AN EPCRA SECTION 313 REPORT
IS NOT REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY
YES
AN EPCRA SECTION 313 REPORT IS
REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
T
Is the Amount Manufactured, OR Processed, OR Otherwise Used less than or equal to 1,000,000
pounds AND is the Reportable Amount less than or equal to 500 Ib/yr
(See Section 2.8)
YES
NO
FORM A OR FORMR
IS REQUIRED FOR THIS CHEMICAL OR
CHEMICAL CATEGORY
FORM R IS REQUIRED FOR THIS
CHEMICAL OR CHEMICAL
CATEGORY (FORM A CANNOT BE
SUBMITTED)
Figure 2-1. EPCRA Section 313 Reporting Decision Diagram
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If you answered "No" to any of the first three questions, you are not required to
prepare any EPCRA Section 313 reports. If you answered "Yes" to ALL of the first three
questions, you must complete a threshold calculation for each EPCRA Section 313 chemical at
the facility, and submit an EPCRA Section 313 report for each chemical and chemical category
exceeding a threshold.
2.2
SIC Code Determination
Facilities with the SIC Codes presented in Table 2-1 are covered by the EPCRA
Section 313 reporting requirements.
Table 2-1
SIC Codes Covered by EPCRA Section 313 Reporting
SIC Codes
10
12
20 through 39
4911, 4931, and 4939
4953
5169
5171
7389
Industry
Metal Mining
Coal Mining
Manufacturing
Electric and Other Services and
Combination Utilities
Refuse Systems
Chemicals and Allied Products
Petroleum Bulk Stations and Terminals
Business Services
Qualifiers
Except SIC Codes 1011, 1081, and 1094
Except SIC Code 1241
None
Limited to facilities that combust coal
and/or oil for the purpose of generating
electricity for distribution in commerce
Limited to facilities regulated under
RCRA Subtitle C
None
None
Limited to facilities primarily engaged in
solvent recovery services on a contract or
fee basis
Table 2-2 presents a listing of each SIC Code for facilities typically engaged in the
application of organic coatings, with brief descriptions. The application of organic coatings by
electrodeposition or spray operations is commonly one of several unit operations conducted at a
facility as part of larger manufacturing operations. You should determine the SIC Code(s) for
your facility, based on the activities on site. For assistance in determining which SIC Code best
suits your facility refer to Standard Industrial Classification Manual, 1987 published by
Office of Management and Budget.
'the
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As an independent activity, the application of organic coatings would most likely
be included under SIC Code 347 - Coating, Engraving, and Allied Services (includes coloring and
finishing of metal and formed products, coating of metals with plastics and resins, and rust
preventive coatings). As an establishment at a manufacturing facility, organic coating applications
could be included in one of several SIC Codes.
Table 2-2
SIC Codes for Facilities That May Include
Organic Coating Operations
SIC Code
347
351
352
353
354
355
356
357
358
359
361
362
363
364
365
366
367
369
371
372
SIC Description
Coating, Engraving, and Allied Services
Engines and Turbines
Farm and Garden Machinery and Equipment
Construction, Mining, and Materials Handling Machinery and Equipment
Metalworking Machinery and Equipment
Special Industry Machinery, except Metalworking Machinery
General Industrial Machinery and Equipment
Computer and Office Equipment
Refrigeration and Service Industry Machinery
Miscellaneous Industrial and Commercial Machinery and Equipment
Electric Transmission and Distribution Equipment
Electrical Industrial Apparatus
Household Appliances
Electric Lighting and Wiring Equipment
Household Audio and Video Equipment, and Audio Recordings
Communications Equipment
Electronic Components and Accessories
Miscellaneous Electrical Machinery, Equipment, and Supplies
Motor Vehicles and Motor Vehicle Equipment
Aircraft and Parts
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Table 2-2 (Continued)
SIC Code
373
374
375
376
379
SIC Description
Ship and Boat Building and Repair
Railroad Equipment
Motorcycles, Bicycles, and Parts
Guided Missiles and Space Vehicles and Parts
Miscellaneous Transportation Equipment
Note that auxiliary facilities can assume the SIC Code of another covered
establishment if the primary function is to support the covered establishment's operations. For the
purpose of EPCRA Section 313, auxiliary facilities are defined as those that are primarily engaged
in performing support services for another covered establishment or multiple establishments of a
covered facility, and are in a different physical location from the primary facility. In addition,
auxiliary facilities perform an integral role in the primary facility's activities. In general, the
auxiliary facility's basic administrative services (e.g., paperwork, payroll, employment) are
performed by the primary facility. Therefore, if an auxiliary facility's primary function is to
support/service a facility with a covered SIC Code, the auxiliary facility is also covered by the
EPCRA Section 313 reporting requirements. However, if the SIC Code for the primary facility is
not covered by EPCRA Section 313, then neither the primary nor the auxiliary facility is required
to submit a report.
If your facility has more than one SIC Code (i.e., several establishments with
different SIC Codes are owned or operated by the same entity and are located at your facility),
you are subject to reporting requirements if:
All the establishments have SIC Codes covered by EPCRA Section 313;
OR
The total value of the products shipped or services provided at
establishments with covered SIC Codes is greater than 50% of the value of
the entire facility's products and services; OR
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Any one of the establishments with a covered SIC Code ships and/or
produces products or provides services whose value exceeds the value of
services provided, products produced and/or shipped by any other
establishment within the facility.
Example - Primary SIC Code
A facility has two establishments. The first, a general automotive repair service, is in SIC Code 7537. SIC Code
7537 is not a listed SIC Code. However, the second establishment, a metal products paint shop, is in SIC Code
3479, which is a listed SIC Code. The facility also determines the product is worth $500/unit as received from the
establishment in the non-listed SIC Code and the value of the product is $l,500/unit after processing by the
establishment in the listed SIC Code. The value added by the establishment in the listed SIC Code is more than 50%
of the product value; therefore, the primary SIC Code is 3479, a listed SIC Code. Thus, the establishment is covered
by EPCRA Section 313 reporting and the entire facility is subject to reporting.
A pilot plant within a covered SIC Code is considered a covered facility and is
subject to reporting, provided it meets the employee and activity criteria (note that pilot plants are
not eligible for the laboratory exemption, which is discussed in Chapter 3). Warehouses on the
same site as facilities in a covered SIC Code are also subject to reporting, but stand-alone
warehouses that are auxiliary facilities and that do not assume a covered SIC Code as their
primary SIC Code are not subject to reporting.
2.3 Number of Employees
If your facility meets SIC Code and activity threshold criteria, you are required to
prepare an EPCRA Section 313 report if your facility has 10 or more full-time employees or the
equivalent. A full-time employee equivalent is defined as a work year of 2,000 hours. If your
facility's employees aggregate 20,000 or more hours in a calendar year, you meet the 10 or more
employee criterion.
The following examples should be included in your employee calculations:
Owners;
Operations/manufacturing staff;
Clerical staff;
Temporary employees;
Sales personnel;
Truck drivers (employed by the facility);
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Other non-manufacturing or off-site facility employees directly supporting
the facility;
Paid vacation and sick leave; and
Contractor employees (maintenance, construction, etc. but excluding
contracted 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 - Employee Equivalent Calculation
Your facility has six full-time employees working 2,000 hours/year. You also employ two full-time sales people and
a delivery truck driver (employed by the facility) who are assigned to the plant, each working 2,000 hours/year but
predominantly on the road or from their homes. The wastewater treatment 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 (six plant personnel, two salespeople, and one
delivery truck driver) are:
(9 employees) x (2,000 hours/year) = 18,000 hours/year
• Hours for the wastewater treatment plant operator are:
(2 hours/day) x (5 days/week) x (52 weeks/year) = 520 hours/year; and
• Hours for the construction crew are:
(4 contractors) x (1,000 hours) = 4,000 hours/year.
Your facility has a total of 22,520 hours for the year, which is above the 20,000 hours/year threshold; therefore, you
meet the employee criterion.
2.4 Manufacturing. Processing, and Otherwise Use of EPCRA Section 313
Chemicals or Chemical Categories
If you are in a covered SIC Code and have 10 or more full-time employee
equivalents, you must determine which EPCRA Section 313 chemicals and chemical categories
are manufactured, processed, or otherwise used at your facility. You should prepare a list of all
chemicals and chemical categories used by all establishments at the facility, including the
chemicals and chemical categories found in mixtures and trade name products. This list should
then be compared to the CURRENT list of EPCRA Section 313 chemicals and chemical
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categories found in the TRI Forms and Instructions document for that reporting year (also
available from the EPCRA Hotline, 1-800-424-9346). Once you identify the EPCRA Section 313
chemicals and chemical categories at your facility, you must evaluate the activities involving each
chemical and chemical category and determine if any activity thresholds are met.
Note that chemicals and chemical categories are periodically added, delisted, or
modified. Therefore, it is imperative that you refer to the appropriate reporting year's list. Also,
note that a list of synonyms for EPCRA Section 313 chemicals and chemical categories can be
found in the U.S. EPA publication Common Synonyms for Chemicals Listed Under Section 313
of the Emergency Planning and Community Right-To-Know Act, (EPA 745-R-95-008). Table 2-
3 lists the EPCRA Section 313 chemicals and chemical categories most frequently reported for
organic coating operations. Some of the chemicals, e.g., xylene, toluene, methyl isobutyl ketone,
etc., are used in both surface preparation and coating operations. This list is not intended to be all
inclusive and should only be used as a guide.
Table 2-3
EPCRA Section 313 Chemicals and Chemical Categories Commonly
Encountered in Organic Coatings Operations
Process*
SP
WWT
SP
SP
SP
WWT
SP
SP&CA
SP
SP
SP
SP
SP
SP
Chemicals
Aluminum (fume or dust)
Ammonia (anhydrous and 1 0% of aqueous)
n-Butyl alcohol
Cadmium compounds
Certain glycol ethers
Chlorine
Chromium
Chromium compounds
Cobalt
Copper
Copper compounds
Cyanide compounds
Dichloromethane
Diisocyanates
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Table 2-3 (Continued)
Process*
SP
SP
SP
SP
SP
SP
SP&CA
SP
SP
SP
SP
SP&CA
SP
SP
SP
WWT
SP
SP
SP
SP
SP
SP&CA
SP
SP
SP
SP&CA
SP&CA
SP
SP
Chemicals
Dimethyl phthalate
Ethylbenzene
Ethylene glycol
Hydrochloric acid (acid aerosols)
Hydrogen fluoride
Lead
Lead compounds
Manganese
Manganese compounds
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Naphthalene
Nickel
Nickel compounds
Nitrate compounds (only in water and water dissociable)
Nitric acid
Phosphoric acid
Propylene
Sulfuric acid (acid aerosols)
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
1 ,2,4-Trimethylbenzene
m-Xylene
Xylene (mixed isomers)
Zinc (fume or dust)
Zinc compounds
SP = Surface Preparation
CA = Coating Application
WWT = Wastewater Treatment
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2.5 Activity Categories
EPCRA Section 313 defines three activity categories for the listed chemicals and
chemical categories: manufacturing (which includes importing), processing, and otherwise use.
The activity thresholds that have been in effect since reporting year 1989 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 or chemical category individually. The
quantity of chemicals or chemical categories stored on site or purchased is not relevant for
threshold determinations. Rather, the determination is based solely on the quantity actually
manufactured (including imported), processed, or otherwise used. Therefore, EPCRA Section
313 chemicals and chemical categories that are brought on site and stored, but are not
incorporated into a product for distribution or not otherwise used on site during the reporting
year, are not considered towards any activity thresholds.
Expanded definitions, with examples, of each of the three activities are found in
Chapter 3, Tables 3-2, 3-3, and 3-4. The terms are briefly defined in Table 2-4.
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Table 2-4
Activity Categories
Activity
Category
Definition
Threshold
(Ib/yr)
Manufacture
To produce, prepare, import, or compound an EPCRA Section 313 chemical or chemical
category. Manufacture also applies to an EPCRA Section 313 chemical or chemical
category that is produced coincidentally during the manufacture, processing, otherwise use,
or disposal of another chemical or mixture of chemicals as a byproduct, and an EPCRA
Section 313 chemical or chemical category that remains in that other chemical or mixture of
chemicals as an impurity during the manufacturing, processing, or otherwise use or disposal
of any other chemical substance or mixture. An example would be the production of
ammonia or nitrate compounds in a wastewater treatment system.
25,000
Process
To prepare an EPCRA Section 313 chemical or chemical category, or a mixture or trade
name product containing an EPCRA Section 313 chemical or chemical category, for
distribution in commerce (usually the intentional incorporation of an EPCRA Section 313
chemical or chemical category into a product). For example, the addition of EPCRA Section
313 listed pigments to paint should be reported if you exceeded the reporting threshold.
Processing includes the preparation for sale to your customers (and transferring between
facilities within your company) of a chemical or formulation that you manufacture. For
example, if you manufacture an EPCRA Section 313 chemical or chemical category or
product, package it, and then distribute it into commerce, this chemical has been
manufactured AND processed by your facility.
25,000
Otherwise
Use
Generally, use of an EPCRA Section 313 chemical or chemical category that does not fall
under the manufacture or process definitions is classified as otherwise use. An EPCRA
Section 313 chemical or chemical category that is otherwise used 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, toluene used as a carrier solvent for paint is classified as otherwise
used.
On May 1, 1997 U.S. EPA revised the interpretation of otherwise use. The following new
otherwise use definition becomes effective with the 1998 reporting year (62 FR 23834, May
1, 1997):
Otherwise use means "any use of a toxic chemical contained in a mixture or other
trade name product or waste, that is not covered by the terms manufacture or
process. Otherwise use of a toxic chemical does not include disposal, stabilization
(without subsequent distribution in commerce), or treatment for destruction unless:
1) The toxic chemical that was disposed, stabilized, or treated for destruction was
received from off site for the purposes of further waste management; OR
2) The toxic chemical that was disposed, stabilized, or treated for destruction was
manufactured as a result of waste management activities on materials received from
off site for the purposes of further waste management activities."
10,000
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COMMON ERROR - Coincidental Manufacture
The coincidental manufacture of an EPCRA Section 313 chemical or chemical category is frequently overlooked.
For example, in the phosphating process, during the coating reaction, crystalline structures of zinc and manganese
compounds are formed. The consumption of the free acids raises the pH and the metal (Zn and/or Mn) cations cannot
stay in solution. They deposit on the metal surface as crystalline zinc phosphate. The actual crystal structure is a
function of the process chemistry. A typical reaction is:
3Zn+2 + 2H2P04-' + 4H20 ->• Zn3(PO4)2 • 4H2O + 4H+1
In this example, zinc phosphate has been coincidentally manufactured and the quantity formed should be applied to
the manufacturing threshold determination for zinc compounds.
(Ref: Donofrio, J., "Zinc Phosphating"; Organic Finishing Guidebook and Directory, May 1996, pages 68-85).
Relabeling or redistribution of an EPCRA Section 313 chemical or chemical
category where no repackaging occurs does not constitute manufacturing, processing, or
otherwise use of that chemical. This type of activity should not be included in threshold
calculations.
Example - Relabeling
You buy a mixture in small containers that contains an EPCRA Section 313 chemical or chemical category. When it
arrives you put your own label on each container and put the containers in a larger box with several other items you
manufacture, and sell the larger box as a kit. The quantity of the EPCRA Section 313 chemical or chemical category
in the small containers should not be counted toward the processing (because you did not repackage the chemical) or
otherwise use thresholds, nor should it be counted toward the manufacturing activity threshold unless the small
containers were imported. However, you must consider other EPCRA Section 313 chemicals and chemical
categories that you manufactured in the kit toward manufacturing and processing threshold determinations.
Example - Treatment of Wastes from Off Site
A covered facility receives a waste containing 12,000 pounds of Chemical A, an EPCRA Section 313 chemical, from
off site. The facility treats the waste, destroying Chemical A and in the treatment process manufactures 10,500
pounds of Chemical B, another EPCRA Section 313 chemical. Chemical B is disposed on site.
Since the waste was received from off site for the purpose of waste management, the amount of Chemical A must be
included in the otherwise used threshold determination for Chemical A. The otherwise use threshold is 10,000
pounds and since the amount of Chemical A exceeds this threshold, all releases and other waste management
activities for Chemical A must be reported.
Chemical B was manufactured in the treatment of a waste received from off site. However, the facility disposed of
Chemical B on site and waste received from off site for treatment for destruction, disposal, or stabilization is
considered to be otherwise used and the amount of Chemical B must be considered in the otherwise used threshold
determination. Thus, the reporting threshold for Chemical B has also been exceeded and all releases and other waste
management activities for Chemical B must be reported.
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Also, note that the threshold determinations for the three activity categories
(manufacturing, processing, and otherwise use) are mutually exclusive. That is, you must conduct
a separate threshold determination for each activity category and if you exceed any threshold, all
release and other waste management activities of that EPCRA Section 313 chemical or chemical
category at the facility must be considered for reporting.
2.6 How Do You Report?
You must submit an EPCRA Section 313 report for each EPCRA Section 313
chemical or chemical category that exceeds a threshold for manufacturing, OR processing, OR
otherwise use (providing you meet the employee and SIC Code criteria). Provided you do not
exceed certain alternate activity thresholds and total annual reportable amounts, you may prepare
a Form A (See Section 2.8) rather than a Form R. The TRI Forms and Instructions contain
detailed directions for the preparation and submittal of EPCRA Section 313 reports for the
reporting year. The TRI Forms and Instructions are sent to all facilities that submitted EPCRA
Section 313 reports the preceding year. However, if you do not receive a courtesy copy, you may
request copies of the TRI Forms and Instructions from the EPCRA Hotline (1-800-424-9346).
2.7 FormR
Form R is the more detailed and more common EPCRA Section 313 report. If
you are submitting a Form R, it is essential that you use the TRI Forms and Instructions for the
appropriate reporting year. U.S. EPA encourages the electronic submittal of the Form R, via the
Automated Toxic Chemical Release Inventory Reporting Software (ATRS). Use of the ATRS
will save preparation time in data entry and photocopying and reduce errors via on-line validation
routines and use of pick lists. The ATRS can be found on the Internet at:
• http://www.epa.gov/opptintr/atrs
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The ATRS is available in both DOS and Windows versions. More information can be found in
the TRI Forms and Instructions and by calling the ATRS User Support Hotline at (703) 816-
4434.
The Form R consists of two parts:
Part I. Facility Identification Information. This part may be photocopied and re-
used for each Form R you submit, except for the signature, which must be original
for each submission.
Part II. Chemical Specific Information. You must complete this part separately for
each EPCRA Section 313 chemical or chemical category; it cannot be reused year
to year even if reporting has not changed.
Submission of incomplete EPCRA Section 313 reports may result in issuance of a
Notice of Technical Error (NOTE), Notice of Significant Error (NOSE), or Notice of Non-
compliance (NON). See the current TRI Forms and Instructions for more detailed information on
completing the Form R and submitting the EPCRA Section 313 report.
2.8 Alternate Threshold and Form A
U.S. EPA developed the Form A, also referred to as the "Certification Statement,"
to reduce the annual reporting burden for facilities with minimal amounts of EPCRA Section 313
chemicals or chemical categories released and otherwise managed as a waste. (59 FR 61488,
November 1994; applicable beginning reporting year 1994 and beyond). A facility must meet the
following two criteria to use a Form A:
First, the amount of the EPCRA Section 313 chemical or chemical
category manufactured, processed, OR otherwise used cannot exceed one
million pounds. It is important to note that the quantities for each activity
are mutually exclusive and must be evaluated independently. If the
quantity for any one of the activities exceeds 1,000,000 pounds a Form A
cannot be used.
Second, the total annual reportable amount of the EPCRA Section 313
chemical or chemical category cannot exceed 500 pounds per year. The
"reportable amount" is defined as the sum of the on-site amounts released
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(including disposal), treated, combusted for energy recovery, and recycled,
combined with the sum of the amounts transferred off site for recycling,
energy recovery, treatment, and/or release (including disposal). This total
corresponds to the total of data elements 8.1 through 8.7 on the 1997
version of the Form R.
Example - Form A Threshold
If the combined annual reportable amounts from all activities do not exceed 500 pounds, a facility that manufactures
900,000 pounds of an EPCRA Section 313 chemical or chemical category and processes 150,000 pounds of the
same chemical or chemical category is eligible to use the Form A because the facility did not exceed the one million
pounds for either activity, even though the total usage exceeds one million pounds.
The Form A Certification Statement must be submitted for each eligible EPCRA
Section 313 chemical or chemical category. The information on the Form A will be included in
the publicly accessible TRI database; however, these data are marked to indicate that they
represent certification statements rather than Form Rs. Note that separate establishments at a
facility cannot submit separate Form As for the same chemical or chemical category; rather, only
one Form A per EPCRA Section 313 chemical or chemical category can be submitted per facility.
Like the Form R, Form A includes facility identification information. However,
no release and other waste management quantity estimations to any media are provided. You
must simply certify that the total annual reportable amount did not exceed 500 pounds and that
amounts manufactured, processed, or otherwise used did not exceed one million pounds. Once
the facility has completed estimates to justify the submission of a Form A, there is a considerable
time savings in using the Form A, especially in subsequent years, providing activities involving the
chemical or chemical category did not change significantly. It is strongly recommended that you
document your initial rationale and refer to it every year, to verify that you have not modified a
part of the process that would invalidate the initial rationale supporting submission of Form A.
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2.9 Trade Secrets
If you submit trade secret information, you must prepare two versions of the
substantiation form as prescribed in 40 CFR Part 350 (see 53 FR 28801, July 29, 1988) as well as
two versions of the EPCRA Section 313 report. One set of reports should be "sanitized" (i.e., it
should provide a generic name for the EPCRA Section 313 chemical or chemical category
identity). This version will be made available to the public. The second version, the "unsanitized"
version, should provide the actual identity of the EPCRA Section 313 chemical or chemical
category and have the trade secret claim clearly marked in Part I, Section 2.1 of the Form R or
Form A. The trade secrets provision only applies to the EPCRA Section 313 chemical or
chemical category identity. All other parts of the Form R or Form A must be filled out
accordingly.
Individual states may have additional criteria for confidential business information
and the submittal of both sanitized and unsanitized reports for EPCRA Section 313 chemicals and
chemical categories. Facilities may jeopardize the trade secret status of an EPCRA Section 313
chemical or chemical category by submitting an unsanitized version to a state agency or tribal
government that does not require an unsanitized version.
More information on trade secret claims, including contacts for individual state's
submission requirements, can be found in the TRI Forms and Instructions.
2.10 Recordkeeping
Complete and accurate records are absolutely essential to meaningful compliance
with EPCRA Section 313 reporting requirements. Compiling and maintaining good records will
help you to reduce the effort and cost in preparing future reports, and to document how you
arrived at the reported data in the event of U.S. EPA compliance audits. U.S. EPA requires you
to maintain records substantiating each EPCRA Section 313 report submission for a minimum of
three years. Each facility must keep copies of every EPCRA Section 313 report along with all
supporting documents, calculations, work sheets, and other forms that you use to prepare the
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EPCRA Section 313 report. U.S. EPA may request this supporting documentation during a
regulatory audit.
Specifically, U.S. EPA requires the following records be maintained for a period of
three years from the date of the submission of a report (summarized from 40 CFR 372.10):
1) A copy of each EPCRA Section 313 report that is submitted.
2) All supporting materials and documentation used to make the compliance
determination that the facility or establishment is a covered facility.
3) Documentation supporting the report submitted, including:
• Claimed allowable exemptions,
• Threshold determinations,
• Calculations for each quantity reported as being released, either on
or off site, or otherwise managed as waste,
• Activity determinations, including dates of manufacturing,
processing, or use,
• The basis of all estimates,
• Receipts or manifests associated with transfers of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
4) For facilities submitting a Form A, all supporting materials used to make
the compliance determination the facility or establishment is eligible to
submit a Form A, including:
• Data supporting the determination the alternate threshold applies,
• Calculations of the annual reportable amounts,
• Receipts or manifests associated with the transfer of each EPCRA
Section 313 chemical or chemical category in waste to off-site
locations, and
• Waste treatment methods, treatment efficiencies, ranges of influent
concentrations to treatment, sequential nature of treatment steps,
and operating data to support efficiency claims.
Because EPCRA Section 313 reporting does not require additional testing or
monitoring you must determine the best readily available source of information for all estimates.
Some facilities may have detailed monitoring data and off-site transfer records that can be used
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for estimates while others may only have purchase and inventory records. Examples of records
that you should keep, if applicable, might include:
Each EPCRA Section 313 report submitted;
EPCRA Section 313 Reporting Threshold Worksheets (sample worksheets
can be found in Chapter 3 of this document as well as in the TRI Forms
and Instructions);
EPCRA Section 313 Reporting Release and Other Waste Management
Quantity Estimation Worksheets (sample worksheets can be found in
Chapter 4 of this document);
Engineering calculations and other notes;
Purchase records from suppliers;
Inventory data;
National Pollutant Discharge Elimination System (NPDES)/State Pollutant
Discharge Elimination System (SPDES) permits and monitoring reports;
EPCRA Section 312, Tier II reports;
Monitoring records;
Air permits;
• Flow measurement data;
• Resource Conservation Recovery Act (RCRA) hazardous waste
generator's reports;
• Pretreatment reports filed with local governments;
• Invoices from waste management firms;
• Manufacturer's estimates of treatment efficiencies;
• Comprehensive Environmental Response, Conservation, and Liability Act
of 1980 (CERCLA) Reportable Quantity (RQ) reports;
• RCRA manifests; and
• Process flow diagrams (including emissions, releases, and other waste
management activities).
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CHAPTER 3 - EPCRA SECTION 313 CHEMICAL OR CHEMICAL
CATEGORY ACTIVITY THRESHOLD DETERMINATIONS
3.0 PURPOSE
This chapter provides a step-by-step procedure for determining if any EPCRA
Section 313 chemicals or chemical categories exceed a reporting threshold. Threshold
determinations are essentially a three step process:
Step 1) Identify any EPCRA Section 313 chemicals and chemical categories
you manufacture/import, process, or otherwise use.
Step 2) Identify the activity category and any exempt activities for each
EPCRA Section 313 chemical or chemical category.
Step 3) Calculate the quantity of each EPCRA Section 313 chemical or
chemical category and determine which ones exceed an activity
threshold.
3.1 Step 1 - Identify Which EPCRA Section 313 Chemicals or Chemical
Categories are Manufactured (Including Imported). Processed, or Otherwise
Used
Compile lists of all chemicals, chemical categories, compounds, and mixtures at
your facility. For facilities with many different chemicals and mixtures it is often helpful to
prepare two lists: one with the pure (single ingredient) chemicals (including chemical
compounds) and one with the mixtures and trade name products. On the second list, under the
name of each mixture/trade name product, write the names of all chemicals in that product. Next,
compare the chemicals and chemical categories on both lists to the current EPCRA Section 313
chemicals and chemical categories list found in the TRI Forms and Instructions (remember that
chemicals and chemical categories may be periodically added and deleted and you should use the
current instructions). Highlight the EPCRA Section 313 chemicals and chemical categories that
are on your lists.
Review the lists to be sure each chemical and chemical category is shown by its
correct EPCRA Section 313 name. For example, a common EPCRA Section 313 chemical found
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in organic coating operations is toluene. Toluene (Chemical Abstracts Service (CAS) Registry
No. 108-88-3) has several synonyms including: methylbenzene; methylbenzol; phenylmethane; and
toluol. It must be reported on Form R (or Form A), Item 1.2, by its EPCRA Section 313
chemical name, toluene. Synonyms can be found in the U.S. EPA document Common Synonyms
for Chemicals Listed Under Section 313 of the Emergency Planning and Community Right-to-
Know Act (EPA 745-R-95-008).
The original list of chemicals and chemical categories subject to EPCRA Section
313 reporting was a combination of lists from New Jersey and Maryland. Refinements to the list
have been made and changes are anticipated to continue. The list can be modified by an U.S.
EPA initiative or industry or the public can petition U.S. EPA to modify the list. When evaluating
a chemical or chemical category for addition or deletion from the list, U.S. EPA must consider
potential acute and chronic human health effects and adverse environmental effects. U.S. EPA
reviews these petitions and initiates a rulemaking to add or delete the chemical or chemical
category from the list, or publishes an explanation why it denied the petition.
While you must consider every chemical on the EPCRA Section 313 chemical and
chemical category list, you should be aware of the chemicals and chemical categories typically
used in organic coating operations. As a guide, the most frequently reported EPCRA Section 313
chemicals and chemical categories for reporting year 1995 by organic coating operations, and the
processes they are typically used in, are listed in Table 2-3.
A computerized spreadsheet may be helpful in developing your facility's chemical
and chemical category list and performing threshold calculations. The spreadsheet could show the
chemical, chemical category or chemical mixture with corresponding component concentrations;
the yearly quantity manufactured, processed, or otherwise used; and the CAS Registry number.
The spreadsheet could also be designed to identify the total quantity by activity category (amounts
manufactured, processed, and otherwise used) for each EPCRA Section 313 chemical or chemical
category in every mixture, compound, and trade name product.
An initial investment of time will be required to develop this spreadsheet; however,
the time and effort saved in threshold calculations in subsequent years will be significant. Such a
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system will also reduce the potential of inadvertently overlooking EPCRA Section 313 chemicals
or chemical categories present in mixtures purchased from off-site sources.
To develop the chemical and chemical category list and the associated activity
categories you may want to consult the following:
Material Safety Data Sheets (MSDSs);
Facility purchasing records;
Inventory records;
Air and water discharge permits;
Individual manufacturing/operating functions; and
Receipts or manifests associated with the transfer of each EPCRA Section
313 chemical and chemical category in waste to off-site locations.
The following is suggested useful information needed to prepare your EPCRA
Section 313 reports and should be included for each chemical and chemical category on your
spreadsheet:
• The mixture name and associated EPCRA Section 313 chemical and
chemical category names;
• The associated CAS Registry numbers;
• The trade name for mixtures and compounds;
• The throughput quantities; and
• Whether the chemical or chemical category is manufactured, processed, or
otherwise used at the facility (be sure to include quantities that are
coincidentally manufactured and imported, as appropriate).
MSDSs are one of the best sources of information for the type and composition of
chemicals and chemical categories in mixtures, and for determining whether you have purchased
raw materials that contain EPCRA Section 313 chemicals and chemical categories. As of 1989,
chemical suppliers to facilities in SIC Major Group Codes 20 through 39 are required to notify
customers of any EPCRA Section 313 chemicals and chemical categories present in mixtures or
trade name products distributed to facilities. The notice must be provided to the receiving facility
and may be attached or incorporated into that product's MSDS. If no MSDS is required, the
notification must be in a letter that accompanies the first shipment of the product to your facility.
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This letter must contain the chemical name, CAS Registry number, and the weight or volume
percent (or a range) of the EPCRA Section 313 chemical or chemical category in mixtures or
trade name products. Beginning with the 1998 reporting year, seven additional industries will be
covered by most of the EPCRA Section 313 reporting requirements, but will not be required to
comply with most of the supplier notification regulations. These requirements can be found in the
May 1, 1997 Federal Register (62 FR23834). For more information on supplier notification, see
the current edition of EPCRA Section 313 Question and Answers (1998 edition is EPA 745-B-98-
004; see Appendix A, Directive #9) or Supplier Notification Requirements (EPA 560/4-91-006).
Carefully review the entire MSDS. Although new MSDSs must list whether
EPCRA Section 313 chemicals and chemical categories are present, the language and location of
this notification is not currently standardized. Depending on the supplier, this information could
be found in different sections of the MSDS. The most likely sections of an MSDS to provide
information on EPCRA Section 313 chemicals and chemical categories are:
• Physical properties/chemical composition section;
• Regulatory section;
• Hazardous components section;
• Labeling section; and
• Additional information section.
Also, many EPCRA Section 313 chemicals or chemical categories are present as
impurities in mixtures. These quantities must also be considered in threshold determinations
unless the concentration is below the de minimis value (see Section 3.2.2.1). In some cases, if the
EPCRA Section 313 chemical or chemical category is present below the de minimis
concentration, it may be exempt.
COMMON ERROR - Mixture Components
Facilities often overlook EPCRA Section 313 chemicals and chemical categories that are present in small quantities
of bulk solutions. For example, a common chemical used in organic coating applications is xylene. Xylene is often
purchased in large quantities for use as a solvent, among other things. Most facilities correctly report for xylene;
however, ethyl benzene is typically present at up to 15% in solutions of xylene commercially available. Many
facilities have historically overlooked the ethyl benzene in their bulk xylene purchases.
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Several chemicals on the EPCRA Section 313 chemical and chemical category list
include qualifiers related to use or form. Some chemicals are reportable ONLY if manufactured
by a specified process or classified in a specified activity category. For example, isopropyl alcohol
is only reportable if it is manufactured using the strong acid process and saccharin is reportable
only if it is manufactured. Some other chemicals are only reportable if present in certain forms.
For example, only yellow or white phosphorus is reportable, while black or red phosphorus is not.
The qualifiers, associated chemicals and chemical categories, and typical
applicability to organic coating operations 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
with "fume or dust." This definition excludes "wet" forms such as
solutions or slurries, but includes powder, particulate, or gaseous forms of
these metals. There is no particle size limitation for particulates. For
example, use of zinc metal as a paint component is not subject to reporting
unless the zinc is in the form of a fume or dust. However, even though
elemental zinc is reportable only in the fume or dust form, all forms of zinc
compounds are reportable. Note that the entire weight of all zinc
compounds should be included in the threshold determination for zinc
compounds, while only the metal portion of metal compounds is reported
in the release and other waste management amounts.
Manufacturing qualifiers - Two chemicals, saccharin and isopropyl
alcohol, contain qualifiers relating to manufacture. The qualifier for
saccharin means that only manufacturers of the chemical are subject to the
reporting requirement. The qualifier for isopropyl alcohol means that only
facilities that manufacture the chemical by the strong acid process are
required to report. Facilities that only process or otherwise use these
chemicals are not required to report. Thus, a facility that uses isopropyl
alcohol as a solvent in coatings does not need to include this quantity in
threshold determinations or release and other waste management
calculations.
Ammonia - (includes anhydrous ammonia and aqueous ammonia from
water dissociable ammonium salts and other sources) On June 26, 1995,
U.S. EPA qualified the listing for ammonia (CAS Registry No. 7664-41-7)
and deleted ammonium sulfate (solution) (CAS Registry No. 7783-20-2)
from the EPCRA Section 313 chemical list. Both the qualification and the
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deletion were effective as of reporting year 1994. The qualifier for
ammonia means that anhydrous forms of ammonia are 100% reportable
while only 10% of the total aqueous ammonia is reportable. Any
evaporation of ammonia from aqueous ammonia solutions is considered
anhydrous ammonia. This qualifier applies to both activity threshold
determinations and release and other waste management calculations. Note
that while ammonium sulfate is no longer an EPCRA Section 313 chemical,
10% of the aqueous ammonia formed from the dissociation of ammonium
sulfate (and all other ammonium salts) is reportable, and must be included
in both activity threshold determinations and release and other waste
management calculations. Additionally, any ammonium nitrate must also
be included in the threshold determination and the nitrate portion included
in the release and other waste management calculations, for the nitrate
compounds category. U.S. EPA has published guidance on reporting for
ammonia and ammonium salts in Emergency Planning and Community
Right-to-Know, EPCRA Section 313, Guidance for Reporting Aqueous
Ammonia, EPA 745-R-95-012 (see Appendix D).
Nitrate Compounds (water dissociable; reportable only in aqueous
solution) - A nitrate compound is covered by this listing only when in
water and if water dissociable. Although the complete weight of the nitrate
compound must be used for threshold determinations for the nitrate
compounds category, only the nitrate portion of the compound must be
considered for release and other waste management determinations. One
issue recently raised by industry is how to report nitrate compounds in
wastewater and sludge that is applied to farms as a nitrogen source (either
on site or off site). Although the plants and microorganisms ultimately
degrade these chemicals, U.S. EPA considers the wastewater and/or sludge
to be managed and should be reported as being disposed to land (either on
site or off site as appropriate). U.S. EPA has published guidance for these
chemicals in List of Toxic Chemicals Within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting, EPA 745-R-96-004
(see Appendix C).
Phosphorus (yellow or white) - Only manufacturing, processing, or
otherwise use of phosphorus in the yellow or white chemical forms require
reporting. Black and red phosphorus are not subject to EPCRA
Section 313 reporting.
Asbestos (friable) - Asbestos only needs to be considered when it is
handled in the friable form. Friable refers to the physical characteristics of
being able to crumble, pulverize, or reduce to a powder with hand
pressure.
Aluminum oxide (fibrous) - Beginning with reports for calendar year
1989, aluminum oxide is only subject to threshold determination and
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release and other waste management calculations when it is handled in
fibrous forms. U.S. EPA has characterized fibrous aluminum oxide for
purposes of EPCRA Section 313 reporting as a man-made fiber commonly
used in high-temperature insulation applications such as furnace linings,
filtration, gaskets, joints, and seals.
• Sulfuric acid (acid aerosols) - On June 26, 1995, U.S. EPA promulgated
a final rule delisting non-aerosol forms of sulfuric acid (CAS Registry No.
7664-93-9) from the EPCRA Section 313 toxic chemical list (effective for
the 1994 reporting year). Therefore, threshold determinations and release
and other waste management estimates now apply only to the aerosol
forms. Under EPCRA Section 313, the term aerosol covers any generation
of airborne acid (including mists, vapors, gas, or fog) without any particle
size limitation.
Hydrochloric acid (acid aerosols) - On July 25, 1996, US EPA
promulgated a final rule delisting non-aerosol forms of hydrochloric acid
(CAS Registry No. 7647-01-0) from the EPCRA Section 313 chemical list
(effective for the 1995 reporting year). Therefore, threshold
determinations and release and other waste management estimates now
apply only to the aerosol forms. Under EPCRA Section 313, the term
aerosol covers any generation of airborne acid (including mists, vapors,
gas, or fog) without any particle size limitation.
3.2 Step 2 - Identify the Activity Category and Any Exempt Activities for Each
EPCRA Section 313 Chemical and Chemical Category
The next step is to identify the activity category (or categories) and any exempt
activities for each EPCRA Section 313 chemical and chemical category on your list. Table 3-1
lists the reporting thresholds for each of these activity categories (Tables 3-2 through 3-4 provide
detailed definitions of subcategories for each activity category). Each threshold must be
individually calculated; they are mutually exclusive and are not additive.
Table 3-1
Reporting Thresholds
Activity Category
Manufacture (including import)
Process
Otherwise use
Threshold
25,000 pounds per year
25,000 pounds per year
10,000 pounds per year
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Example -Threshold Determination
If your facility manufactures 22,000 pounds of an EPCRA Section 313 chemical or chemical category and you also
otherwise use 8,000 pounds of the same chemical or chemical category, you have not exceeded either threshold, and
an EPCRA Section 313 report for that chemical or chemical category is not required. However, if your facility
manufactures 28,000 pounds per year of an EPCRA Section 313 chemical or chemical category and otherwise uses
8,000 pounds of the same chemical or chemical category, you have exceeded the manufacturing threshold and ALL
releases and other waste management quantities (except those specifically exempted) of that chemical or chemical
category must be reported on the Form R, including those from the otherwise used activity.
Example - Xylene Isomers
Organic coating operations use the EPCRA Section 313 chemical xylene with the mixed isomers, CAS Registry No.
1330-20-7, being the most frequently reported type. Xylene is listed on the EPCRA Section 313 chemicals and
chemical categories list in three isomeric forms and a mixture of these: ortho-, meta-, para-, and mixed. The mixed
isomers classification should be used when a mixture contains any combination of two or three of the isomers. The
threshold determination for xylene should be calculated for each isomeric form individually. For example, a covered
facility annually uses 8,000 pounds of para-xylene, 6,000 pounds of ortho-xylene, and 8,000 pounds of mixed
isomers as carrier solvents in three separate processing lines. All three activities of xylene are classified as otherwise
use as the carrier is intended to evaporate and not remain with the product. There are no other uses of any form of
xylene in the facility. The otherwise use activity threshold of 10,000 pounds/year has not been reached for any of the
xylenes and an EPCRA Section 313 report need not be prepared for xylene. However, should any two of the streams
mix, the facility will exceed the otherwise use threshold for mixed isomers and an EPCRA Section 313 report must
be prepared for the mixed isomer form of xylene.
COMMON ERROR - Threshold Determination for Recirculation
Facilities often incorrectly base threshold calculations on the amount of EPCRA Section 313 chemicals or chemical
categories in a recirculation system rather than the amount actually used in the reporting year. The amount of the
EPCRA Section 313 chemical or chemical category that is actually manufactured (including the quantity imported),
processed, or otherwise used, not the amount in storage or in the system, should be the amount applied to the
threshold determination. For example, a solvent containing an EPCRA Section 313 chemical or chemical category is
used, recirculated on site, and reused as a solvent. The amount of EPCRA Section 313 chemical or chemical
category recirculated in the on-site recycling process is not considered in the threshold determination because this is
considered a "direct reuse" and is not reportable. Only the amount of new chemical added to the system should be
included in the otherwise used threshold calculation. However, if you send a solvent containing an EPCRA Section
313 chemical or chemical category off site for distillation and subsequent recycling, it should be reported as a transfer
to an off-site location for recycling (Form R, Part II, Section 6.2 and 8.5) because the distillation is considered a
waste management activity. The amount of solvent returned to you and subsequently used in the same reporting year
must be included in the threshold determination. If the reporting threshold is exceeded, the total quantity recycled
should be reported in Section 8.4, i.e., the amount recycled must be reported in Section 8.4 each time it is recycled.
Each of the activity categories is divided into subcategories. As discussed in the
TRI Forms and Instructions, you are required to designate EACH category and subcategory that
applies to your facility. Detailed definitions, including descriptions of subcategories for each
activity and selected examples, are presented in Tables 3-2, 3-3, and 3-4.
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Table 3-2
Definitions and Examples of Manufacturing Subcategories
Manufacturing
Activity Subcategory
Definition
Examples in Organic
Coating Operations*
Produced or imported
for on-site
use/processing
A chemical or chemical category that is produced or
imported and then further processed or otherwise used at
the same facility.
Xylene, MEK, zinc
compounds, glycol ethers
Produced or imported
for sale/distribution
A chemical or chemical category that is produced or
imported specifically for sale or distribution outside the
manufacturing facility.
Zinc compounds, nickel
compounds
Produced as a byproduct
A chemical or chemical category that is produced
coincidentally during the production, processing, or
otherwise use of another chemical substance or a mixture
and is separated from that substance or mixture. EPCRA
Section 313 chemicals or chemical categories produced
and released as a result of waste treatment or disposal
are also considered byproducts.
Metal compounds in
phosphating process, xylene,
toluene, n-butyl alcohol
Produced as an impurity
A chemical or chemical category that is produced
coincidentally as a result of the manufacture, processing,
or otherwise use of another chemical and remains
primarily in the mixture or product with that other
chemical.
Xylene, MEK, zinc
compounds, glycol ethers
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Table 3-3
Definitions and Examples of Processing Subcategories
Processing Activity
Subcategory
Definition
Examples in Organic Coatings
Operations*
Reactant
A natural or synthetic chemical or chemical
category used in chemical reactions for the
manufacture of another chemical substance or
product. Examples include feedstocks, raw
materials, intermediates, and initiators.
Isocyanates, ethylene glycol,
ethylene oxide, vinyl chloride
Formulation component
A chemical or chemical category that is added to
a product or product mixture prior to further
distribution of the product and acts as a
performance enhancer during use of the product.
Examples include additives, dyes, reaction
diluents, initiators, solvents, inhibitors,
emulsifiers, surfactants, lubricants, flame
retardants, and rheological modifiers.
Toluene, xylene, butyl alcohol,
cyclohexane, cyclohexanol, ethylene
glycol, MTBE, N-methyl-2-
pyrolidone, benzoyl peroxide,
cresol, dibutyl phthalate, diethanol
amine, formaldehyde, phenol, 2-
mercaptobenzothiozole, thiourea,
dioxane, C.I. dyes, tributyltin
fluoride, tributyltin methacrylate,
pesticides
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Table 3-3 (Continued)
Processing Activity
Subcategory
Definition
Examples in Organic Coatings
Operations*
Article component
A chemical or chemical category that becomes an
integral component of an article distributed for
industrial, trade, or consumer use.
Xylene, zinc compounds, glycol
ethers, lead, copper, chromium,
nickel
Repackaging only
A chemical or chemical category that is processed
or prepared for distribution in commerce in a
different form, state, or quantity. May include, but
is not limited to, the transfer of material from a
bulk container, such as a tank truck, to smaller
containers such as cans or bottles.
Lead, copper
* More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
Table 3-4
Definitions and Examples of Otherwise Use Subcategories
Otherwise Use Activity
Subcategory
Definition
Examples in Organic Coatings
Operations*
Chemical processing aid
A chemical or chemical category that is
added to a reaction mixture to aid in the
manufacture or synthesis of another chemical
substance but is not intended to remain in or
become part of the product or product
mixture. Examples include process solvents,
catalysts, inhibitors, initiators, reaction
terminators, and solution buffers.
Xylene, MEK, zinc compounds,
glycol ethers, toluene, nitric acid, n-
butyl alcohol, MIBK, ethyl benzene,
naphthalene
Manufacturing aid
A chemical or chemical category that aids the
manufacturing process but does not become
part of the resulting product and is not added
to the reaction mixture during the
manufacture or synthesis of another chemical
substance. Examples include process
lubricants, metalworking fluids, coolants,
refrigerants, and hydraulic fluids.
Xylene, MEK, zinc compounds,
glycol ethers, toluene, n-butyl
alcohol, ethylbenzene, naphthalene
Ancillary or other use
A chemical or chemical category that is used
for purposes other than aiding chemical
processing or manufacturing. Examples
include cleaners, degreasers, lubricants, fuels
(including waste fuels), and chemicals used
for treating wastes.
Trichloroethylene,
tetrachloroethylene, diisocyanates,
chlorine, methanol
: More complete discussions of the industry-specific examples can be found in Chapter 4 of this guidance manual.
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Example - Chemical Processing Aid
A spray painting operation uses toluene as the carrier solvent. Ideally all the solvent would evaporate, however,
studies have shown 1% of the applied solvent remains on the workpiece. Since the function of the solvent is to
improve the application of the paint and is a non-incorporative activity, the entire amount of toluene is considered
otherwise used. If the solvent's function was such that it was intended to remain with the workpiece, it would be
considered processed, as is the case for pigments, binders, and other paint components intended to remain with the
workpiece.
3.2.1 Concentration Ranges for Threshold Determination
You are required to use the best, readily available information for all calculations
in EPCRA Section 313 reporting; however, the exact concentration of an EPCRA Section 313
chemical or chemical category in a mixture or trade name product may not be known. The
supplier or MSDS may only list ranges, or upper or lower bound concentrations. U.S. EPA has
developed guidance on how to use information in this situation for threshold determinations.
If the concentration is provided as a lower and upper bound or as a range,
you should use the mid-point in your calculations for the threshold
determination. For example, the MSDS for the trade name product states
methanol is present in a concentration of not less than 20% and not more
than 40%, or it may be stated as present at a concentration between 20 to
40%. You should use the mid-point value of 30% methanol in your
threshold calculations.
If only the lower bound concentration of the EPCRA Section 313 chemical
or chemical category is specified and the concentration of other
components are given, subtract the other component values from 100%.
The remainder should be considered the upper bound for the EPCRA
Section 313 chemical or chemical category and you should use the given
lower bound to calculate the mid-point as discussed above. For example,
the MSDS states that a solvent contains at least 50% methyl ethyl ketone
(MEK) and 20% non-hazardous surfactants. Subtracting the
non-hazardous contents from 100% leaves 80% as the upper bound for
MEK. The mid-point between upper (80%) and lower (50%) bounds is
65%, the value you should use in your threshold calculation.
If only the lower bound is specified and no information on other
components is given assume the upper bound is 100% and calculate the
mid-point as above.
If only the upper bound concentration is provided you must use this value
in your threshold calculation.
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Special guidance for concentration ranges that straddle the de minimis value is presented in
Section 3.2.2.1.
3.2.2 Evaluation of Exemptions
When determining thresholds, you can exclude quantities of any EPCRA Section
313 chemicals and chemical categories that are manufactured, processed, or otherwise used in
exempt activities. Exemptions are divided into four classes:
1. De minimis exemption;
2. Article exemption;
3. Facility-related exemption; and
4. Activity-related exemptions.
COMMON ERROR - Exempt Activities
If an EPCRA Section 313 chemical or chemical category is used in exempt activities, the quantity in these activities
does not need to be included in your threshold or release and other waste management calculations, even if the
chemical or chemical category is used in a reportable activity elsewhere in the facility.
3.2.2.1 De Minimis Exemption
If the amount of EPCRA Section 313 chemical(s) or chemical categories present in
a mixture or trade name product processed or otherwise used is below its de minimis
concentration level, that amount is considered to be exempt from threshold determinations and
release and other waste management calculations (note that this exemption does not apply to
manufacturing, except for importation or as an impurity as discussed below). The de minimis
concentration for EPCRA Section 313 chemicals and chemical categories is 1%, except for
Occupational Safety and Health Administration (OSHA)-defmed carcinogens, which have a 0.1%
de minimis concentration. Note that if a mixture contains more than one member of an EPCRA
Section 313 chemical category, the weight percent of all members must be summed. If the total
meets or exceeds the category's de minimis level, the de minimis exemption does not apply. U.S.
EPA has published several detailed questions and answers and a directive in the current edition of
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EPCRA Section 313 Questions and Answers (1998 edition is EPA 745-B-98-004; see Appendix
A, Directive #2) 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 chemical
category with the associated de minimis value.
Example - De Minimis
Your facility processes a mixture containing 1.1% phosphoric acid and 0.6% manganese. The de minimis exemption
would apply to manganese because the concentration is below 1%; however, it would not apply to phosphoric acid.
All of the phosphoric acid must be included in threshold determinations, and release and other waste management
calculations.
The de minimis exemption also applies to EPCRA Section 313 chemicals and
chemical categories that are coincidentally manufactured below the de minimis level as an
impurity in a mixture and subsequently distributed in commerce. In addition, the exemption
applies to EPCRA Section 313 chemicals and chemical categories below the de minimis
concentration in an imported mixture or trade name product.
For some mixtures the concentration of EPCRA Section 313 chemicals and
chemical categories may be available only as a range. U.S. EPA has developed guidance on how
to determine quantities applicable to threshold determinations, and release and other waste
management calculations when this range straddles the de minimis value. In general, only the
quantity of the processed or otherwise used EPCRA Section 313 chemical or chemical category
whose concentration exceeds the de minimis must be considered. Therefore, U.S. EPA allows
facilities to estimate the quantity below the de minimis and exclude it from further consideration.
The following examples illustrate this point.
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Examples - De Minimis Concentration Ranges
Example 1:
A facility processes 8,000,000 pounds of a mixture containing 0.25 to 1.25% manganese. Manganese is subject to a 1% de
minimis concentration exemption. The amount of mixture subject to reporting is the quantity containing manganese above the de
minimis concentration:
(8,000,000) x (1.25% - 0.99%) - (1.25% - 0.25%)
The average concentration of manganese that is not exempt (above the de minimis) is:
(1.25%+ 1.00%)-(2)
Therefore, the amount of manganese that is subject to threshold determination and release and other waste management estimates
is:
(8,000,000) x (1.25%-0.99%)
(1.25%-0.25%)
(l-25%+1.00%)] = 23,400 pounds
(2)
= 23,400 pounds manganese (which is below the processing threshold)
In this example, because the facility's information pertaining to manganese was available to two decimal places, 0.99 was used to
determine the amount below the de minimis concentrations. If the information was available to one decimal place, 0.9 should be
used, as in Example 2 below.
Example 2:
As in Example 1, manganese is present in a mixture, of which 8,000,000 pounds is processed. The MSDS states the mixture
contains 0.2% to 1.2% manganese. The amount of mixture subject to reporting (above de minimis) is:
(8,000,000) x (1.2% - 0.9%) - (1.2% - 0.2%)
The average concentration of manganese that is not exempt (above de minimis) is:
(1.2%+ 1.0%)-(2)
Therefore, the amount of manganese that is subject to threshold determinations and release and other waste management estimates
(8,000,000) x (1.2%-0.9%)
^-21 = 26,400 pounds
(2)
= 26,400 pounds manganese (which is above the processing threshold)
The exemption does not apply to EPCRA Section 313 chemicals and chemical
categories coincidentally manufactured as byproducts and separated from the product, nor does it
apply to EPCRA Section 313 chemicals and chemical categories coincidentally manufactured as a
result of waste management activities, from either on site or off site. (Under EPCRA Section
313, U.S. EPA does not consider waste to be a mixture.) For example, many facilities treat waste
solvents by incinerating them. If coal is used as the primary fuel source to incinerate these waste
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solvents, combustion can result in the coincidental manufacture of sulfuric and hydrochloric acid
aerosols and metal compounds. Since the de minimis exemption does not apply to the
coincidental manufacture of EPCRA Section 313 chemicals or chemical categories as a byproduct
or in a waste treatment process, the formation of these compounds must be considered for
threshold determinations, and release and other waste management calculations.
Once the de minimis level has been equaled or exceeded, the exemption no longer
applies to that process stream, even if the EPCRA Section 313 chemical or chemical category
later falls below the de minimis concentration. All release and other waste management activities
that occur after the de minimis concentration has been equaled or exceeded are subject to
reporting. The facility does not have to report release and other waste management activities that
took place before the de minimis concentration was equaled or exceeded.
3.2.2.2 Article Exemption
An article is defined as a manufactured item that:
• Is formed to a specific shape or design during manufacture;
• Has end-use functions dependent in whole or in part upon its shape or
design; and
• Does not release an EPCRA Section 313 chemical or chemical category
under normal conditions of processing or otherwise use of the item at the
facility.
If you receive a manufactured article from another facility and process or
otherwise use it without changing the shape or design, and your processing or otherwise use does
not result in the release of more than 0.5 pound of the EPCRA Section 313 chemical or chemical
category in a reporting year from all like articles, then the EPCRA Section 313 chemical or
chemical category in that article is exempt from threshold determinations and release and other
waste management reporting.
The shape and design can be changed somewhat during processing and otherwise
use as long as part of the item retains the original dimensions. That is, as a result of processing or
otherwise use, if an item retains its initial thickness or diameter, in whole or in part, then it still
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meets the article definition. If the item's original dimensional characteristics are totally altered
during processing or otherwise use, the item would not meet the definition. As an example, items
that do not meet the definition would be items that are cold extruded, such as lead ingots formed
into wire or rods. However, cutting a manufactured item into pieces that are recognizable as the
article would not change the exemption status as long as the diameter and the thickness of the
item remain unchanged. For instance, metal wire may be bent and sheet metal may be cut,
punched, stamped, or pressed without losing the article status as long as no change is made in the
diameter of the wire or tubing or the thickness of the sheet and no releases above 0.5 pound per
year occur.
Any processing or otherwise use of an article that results in a release above 0.5
pound per year for each EPCRA Section 313 chemical or chemical category for all like articles
negates the exemption. Cutting, grinding, melting, or other processing of a manufactured item
could result in a release of an EPCRA Section 313 chemical or chemical category during normal
conditions of use and, therefore, could negate the exemption as an article if the total exceeds 0.5
pound in a year. However, if all of the resulting waste is recycled or reused, either on site or off
site so the release and other waste management quantity of the EPCRA Section 313 chemical or
chemical category does not exceed 0.5 pound, then the article's exemption status is maintained.
Also, if the processing or otherwise use of similar manufactured items results in a total release and
other waste management quantity of less than or equal to 0.5 pound of any individual EPCRA
Section 313 chemical or chemical category to any environmental media in a calendar year, U.S.
EPA will allow this quantity to be rounded to zero and the manufactured items to maintain their
article exemption. The 0.5-pound limit does not apply to each individual article, but applies to the
sum of all release and other waste management activity quantities from processing or otherwise
use of like articles for each EPCRA Section 313 chemical or chemical category. The current
edition of EPCRA Section 313 Questions and Answers (1998 edition is EPA 745-B-98-004)
presents several specific question and answers/discussions pertaining to the article exemption.
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Example - Article Exemption
If an article, as part of a coating pre-treatment operation, is subjected to an etching process that removes a portion of
an EPCRA Section 313 metal from the surface that is not recycled or reused, this process would constitute a release
and negate the article exemption. For example, a copper plate is cleansed by dipping in a sulfuric acid solution.
Some of the copper reacts with the acid to form copper sulfate and the used cleaning solution is discharged to a
POTW. This process is considered a release of the copper and, if the release is greater than 0.5 pound per year, the
plate has lost its article exemption.
3.2.2.3 Facility-Related Exemption
EPCRA Section 313 chemicals and chemical categories that are manufactured,
processed, or otherwise used in laboratories are exempt from the threshold determination (and
subsequent release and other waste management calculations). This exemption includes EPCRA
Section 313 chemicals and chemical categories used in a laboratory under supervision of a
technically qualified individual. This exemption may be applicable in such circumstances such as
laboratory sampling and analysis, research and development, and quality assurance and quality
control activities. It does not include pilot plant scale or specialty chemical production. It also
does not include laboratory support activities. For example, chemicals used to maintain
laboratory equipment are not eligible for the laboratory exemption.
Example - Laboratory Exemption
A paint manufacturer at a separate research laboratory facility applies various formulations of organic coatings
containing EPCRA Section 313 chemicals and chemical categories to two cars per day for testing for an automobile
manufacturer. The testing is under the supervision of a "technically qualified individual" in the laboratory. The
EPCRA Section 313 chemicals and chemical categories used in this activity would be exempt from EPCRA Section
313 reporting and should not be included in any threshold determination or release and other waste management
calculations.
3.2.2.4 Activity-Related Exemptions
Some exemptions apply to the otherwise use of an EPCRA Section 313 chemical
and chemical category. The specific quantities of EPCRA Section 313 chemicals and chemical
categories used in these activities do not need to be included in a facility's threshold determination
(nor the associated release and other waste management calculations). The following activities
are considered exempt:
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EPCRA Section 313 chemicals and chemical categories used in routine
janitorial or facility grounds maintenance. Examples are bathroom
cleaners, fertilizers, and garden pesticides similar in type or concentration
found in consumer products. Materials used to clean process equipment do
not meet this exemption.
Personal use of items. Examples are foods, drugs, cosmetics, and other
personal items including those items within the facility such as in a facility
operated cafeteria, store, or infirmary. Office supplies such as correction
fluid are also exempt.
Example - Personal Use Exemption
Ammonia used to clean a cafeteria grill is exempt from threshold determinations and
release and other waste management calculations.
Structural components of the facility Exemptions apply to EPCRA
Section 313 chemicals and chemical categories present in materials used to
construct, repair, or maintain structural components of a facility. An
example common to all facilities would be the solvents and pigments used
to paint the buildings. Materials used to construct, repair, or maintain
process equipment are not exempt.
EPCRA Section 313 chemicals and chemical categories used with
facility motor vehicles. This exemption includes the use of EPCRA
Section 313 chemicals and chemical categories for the purpose of
maintaining motor vehicles operated by the facility. Common examples
include gasoline, radiator coolant, windshield wiper fluid, brake and
transmission fluid, oils and lubricants, cleaning solutions, and solvents in
paint used to touch up the vehicle. Motor vehicles include cars, trucks,
forklifts, locomotives, and aircraft. Note that this exemption applies to the
OTHERWISE USE of the EPCRA Section 313 chemical and chemical
category. The coincidental manufacture of EPCRA Section 313 chemicals
and chemical categories resulting from combustion of gasoline is not
exempt and should be considered as part of the manufacturing threshold.
Example - Motor Vehicle Exemption
Methanol is purchased for use as a processing aid and as a windshield washer anti-freeze
in company vehicles. The amount used for the latter purpose would be subtracted from the
facility total BEFORE the facility total is compared to the activity threshold. Even if the
facility still exceeds the otherwise use threshold, the amount in the anti-freeze is exempt
from release and other waste management reporting.
3-18
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This exemption does NOT apply to stationary equipment. The use of
lubricants and fuels for stationary process equipment (e.g., pumps and
compressors) and stationary energy sources (e.g., furnaces, boilers,
heaters), are NOT exempt.
Example - Process Equipment Chemical Use
Lubricants containing EPCRA Section 313 chemicals and chemical categories used on
facility vehicles, or on-site structural maintenance activities that are not integral to the
process, are exempt activities. However, lubricants used to maintain pumps and
compressors that aid facility process operations are not exempt and the amount of the
EPCRA Section 313 chemicals and chemical categories in the lubricant should be applied
to the otherwise use threshold.
EPCRA Section 313 chemicals and chemical categories in air or water
drawn from the environment or municipal sources. Included are
EPCRA Section 313 chemicals and chemical categories present in process
water and non-contact cooling water drawn from the environment or a
municipal source, or chemicals and chemical categories present in air used
either as compressed air or as an oxygen source for combustion.
Example - Chemicals in Process Water
A facility uses river water for one of its processes. This water contains approximately 100
pounds of an EPCRA Section 313 chemical or chemical category. The facility ultimately
returns the water that contains the entire 100 pounds of the EPCRA Section 313 chemical
or chemical category to the river. The EPCRA Section 313 chemical or chemical category
in the water can be considered exempt because the EPCRA Section 313 chemical or
chemical category was present as it was drawn from the environment. The facility does
not need to consider the EPCRA Section 313 chemical or chemical category drawn with
river water for threshold determinations or release and other waste management reporting.
3.2.3 Additional Guidance on Threshold Calculations for Certain Activities
This section covers three specific situations in which the threshold determination
may vary from normal facility operations: reuse, remediation, and recycling activities of EPCRA
Section 313 chemicals and chemical categories.
3.2.3.1
Reuse Activities
Threshold determinations of EPCRA Section 313 chemicals or chemical categories
that are reused at the facility are based only on the amount of the EPCRA Section 313 chemical
or chemical category that is added to the system during the year, not the total volume in the
3-19
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system. For example, a facility operates a refrigeration unit that contains 15,000 pounds of
anhydrous ammonia at the beginning of the year. The system is charged with 2,000 pounds of
anhydrous ammonia during the year. The facility has therefore otherwise used only 2,000 pounds
of the EPCRA Section 313 chemical or chemical category and is not required to report (unless the
facility has additional otherwise use activities of ammonia that, when taken together, exceed the
reporting threshold). If, however, the whole refrigeration unit was recharged with 15,000 pounds
of new or fresh anhydrous ammonia during the year, the facility would exceed the otherwise use
threshold, and be required to report.
3.2.3.2 Remediation Activities
EPCRA Section 313 chemicals and chemical categories undergoing remediation
(e.g., Superfund remediation) are not being manufactured, processed, or otherwise used.
Therefore, they are not included in the activity threshold determinations.
However, if you are conducting remediation of an EPCRA Section 313 chemical
or chemical category that is also being manufactured, processed, or otherwise used by the facility
above an activity threshold level, you must consider this activity for release and other waste
management calculations. You must report any release or other waste management quantities of
an EPCRA Section 313 chemical or chemical category due to remediation in Part II, Sections 5
through 8, accordingly, of the Form R. Those quantities would also be considered as part of the
amount for determining Form A eligibility. EPCRA Section 313 chemicals and chemical
categories used for remediation should be considered toward threshold determinations. If an
EPCRA Section 313 chemical or chemical category exceeds one of the reporting thresholds
elsewhere at the facility, all release and other waste management activity quantities of that
chemical or chemical category must be reported, including release and other waste management
activity quantities resulting from remediation.
Excavation of material already landfilled does not constitute a release or other
waste management activity for EPCRA Section 313 reporting purposes. Routine activities (e.g.,
dredging a lagoon), even if not performed every year, are not considered to be remedial actions
and are always subject to reporting.
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3.2.3.3 Recycling Activities
For on-site recycling and reuse systems, where the same EPCRA Section 313
chemical or chemical category is recycled and reused multiple times, the recycled quantity should
be counted only once for threshold calculations. (Please note that for reporting on-site waste
management activities [Section 8 of Form R] the quantity of the EPCRA Section 313 chemical or
chemical category should be counted every time it exits the recycling unit.) EPCRA Section 313
chemicals and chemical categories recycled off site and returned to the facility should be treated
as newly purchased materials for EPCRA Section 313 threshold determination.
3.3 Step 3 - Calculate the Quantity of Each EPCRA Section 313 Chemical and
Chemical Category and Determine Which Ones Exceed an Activity
Threshold
The final step is to determine the quantity and which EPCRA Section 313
chemicals and chemical categories exceed an activity threshold. At this point you should have:
1. Identified each EPCRA Section 313 chemical and chemical category at
your facility.
2. Determined the activity category for each EPCRA Section 313 chemical
and chemical category (manufactured, processed, or otherwise used).
Now, you must sum the usage for each EPCRA Section 313 chemical and
chemical category by activity category, subtract all exempt quantities, and compare the totals to
the applicable thresholds. Each EPCRA Section 313 chemical and chemical category exceeding
any one of the activity thresholds requires the submission of an EPCRA Section 313 report.
Provided you meet certain criteria you may prepare a Form A rather than a Form R (see Section
2.8).
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COMMON ERROR - Assuming a Threshold is Exceeded
U.S. EPA recently published a report, The 1994 and 1995 Toxic Release Inventory Data Quality Report, EPA 745-
R-98-002, with the results of over 100 site surveys to evaluate EPCRA Section 313 reporting quality. One of the
findings of this survey was that facilities that simply assumed that chemical activity thresholds were exceeded were
often in error. This resulted in many of these facilities filing EPCRA Section 313 reports when thresholds were
actually not exceeded. Unless the facility has strong grounds to support such an assumption, the time spent in
explicitly calculating the activity threshold is well spent.
COMMON ERROR - Zero Release and Other Waste Management Quantities
If you meet all reporting criteria and exceed any threshold for an EPCRA Section 313 chemical or chemical category,
you must file an EPCRA Section 313 report for that chemical or chemical category, even if you have zero release and
other waste management activity quantities. Exceeding the chemical activity threshold, not the quantity released or
otherwise managed as waste determines whether you must report. Note that if the release and other waste
management activity quantity is 500 pounds or less you may be eligible to use the alternate certification statement,
Form A, rather than a Form R (see Section 2-8).
To determine if an EPCRA Section 313 chemical or chemical category exceeds a
reporting threshold, you must calculate the annual activity amount of that chemical. Start with
the amount of chemical or chemical category at the facility as of January 1, add any amounts
brought on site during the year and the amount manufactured (including imported), and subtract
the amount left in the inventory on December 31. If necessary, adjust the total to account for
exempt activities (see Section 3.2.2 for a discussion of exemptions). You should then compare
the result to the appropriate threshold to determine if you are required to submit an EPCRA
Section 313 report for that chemical or chemical category. Keep in mind that the threshold
calculations are independent for each activity category: manufactured, processed, and otherwise
used. If more than one activity category applies, the amount associated with each category is
determined separately.
Table 3-5 presents a work sheet that may be helpful when conducting your
threshold determinations. Table 3-6 illustrates how the work sheet can be used for the following
example:
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Example - Threshold Worksheet
Assume your facility purchases two mixtures that contain xylene in the applicable reporting year. You purchased
25,000 pounds of Mixture A (which is 50% xylene according to the MSDS) and 110,000 pounds of Mixture B
(which contains 20% xylene). Further, you determine that you process the entire quantity of Mixture A, while you
process only half of Mixture B and otherwise use the other half. You do not qualify for any exempt activities.
In this example, you would have processed a total of 23,500 pounds of xylene (12,500 pounds from activities
associated with Mixture A and 11,000 pounds from activities associated with Mixture B). You would also have
otherwise used a total of 11,000 pounds (all from Mixture B). Therefore, you would not have exceeded the 25,000
pound threshold for processing; however, you would have exceeded the 10,000 pound threshold for otherwise use
and would be required to submit an EPCRA Section 313 report that includes releases and waste managed quantities
from all activities (including processing).
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Table 3-5. EPCRA Section 313 Reporting Threshold Worksheet
Facility Name:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
Date Worksheet Prepared:
Prepared By:
Amounts of chemical or chemical category manufactured,
Mixture Name or Other Identifier
1.
2.
3.
4.
Subtotal:
Information
Source
Drocessed, or otherwise used.
Total Weight
(Ib)
Percent
EPCRA
Section 3 13
Chemical or
Chemical
Category
by Weight
EPCRA
Section 3 13
Chemical or
Chemical
Category
Weight (Ib)
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
(A) Ib.
Processed
(B) Ib.
Otherwise Used
(C) Ib.
to
Exempt quantity of chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1.
2.
3.
4.
Subtotal:
Applicable Exemption (de
minimis, article, facility, activity)
Fraction or Percent Exempt
(if Applicable)
Amount of the EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(A,) Ib.
Processed
(B,) Ib.
Otherwise Used
(C,) Ib.
.Ib.
Amount subject to threshold: (A-Aj) Ib. (B-Bj)
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities: 25.000 Ib. 25.000 Ib. 10.000 Ib.
If any one of the thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
Ib.
-------
Table 3-6. Sample EPCRA Section 313 Reporting Threshold Worksheet
Facility Name: Coatings 'R Us. Inc.
EPCRA Section 313 Chemical or Chemical Category: Xvlene (mixed isomers)
CAS Registry Number: 1330-20-7
Reporting Year: 1997
Date Worksheet Prepared: May 1. 1998
Prepared By: A.B. Callowav
Amounts of chemical or chemical category manufactured, processed, or otherwise used.
Mixture Name or Other Identifier
1. Mixture A
2. Mixture B
3.
4.
Subtotal:
Information
Source
MSDS
MSDS
Total Weight
(Ib)
25,000
110,000
Percent
EPCRA
Section 3 13
Chemical or
Chemical
Category
by Weight
50%
20%
EPCRA
Section 3 13
Chemical or
Chemical
Category
Weight (Ib)
12,500
22,000
Amount of the EPCRA Section 313 Chemical or Chemical
Category by Activity (Ib):
Manufactured
—
—
(A) 0 Ib.
Processed
12,500
11,000
(B) 23,500 Ib.
Otherwise Used
—
11,000
(C) 11,000 Ib.
to
Exempt quantity of chemical or chemical category that should be excluded.
Mixture Name as Listed Above
1. Mixture A
2. Mixture B
3.
4.
Subtotal:
Applicable Exemption (de in inini is,
article, facility, activity)
none
none
Fraction or Percent Exempt (if
Applicable)
Amount of the EPCRA Section 313 Chemical or Chemical
Category Exempt from Above (Ib):
Manufactured
(Aj) 0 Ib.
Processed
(Bj) 0 Ib.
Otherwise Used
(Cj) 0 Ib.
Amount subject to threshold: (A-At) 0 Ib. (B-Bj) 23,500 Ib. (C-Cj) 11,000 Ib.
Compare to threshold for EPCRA Section 313 reporting. Activity threshold quantities: 25.000 Ib. 25.000 Ib. 10.000 Ib.
If any one of three thresholds is exceeded, reporting is required for all activities. [Do not submit this worksheet with Form R, retain it for your records.]
-------
CHAPTER 4 - ESTIMATING RELEASES AND
OTHER WASTE MANAGEMENT QUANTITIES
4.0 PURPOSE
This chapter is intended to guide the user in developing a systematic approach for
estimating quantities of EPCRA Section 313 chemicals and chemical categories released and
otherwise managed as waste from electrodeposition and spray application of organic coating
operations. Figure 4-1 diagrams a recommended approach for estimating quantities of reportable
EPCRA Section 313 chemicals or chemical categories.
This chapter also includes common EPCRA Section 313 reporting and compliance
issues as they apply to the electrodeposition and spray application of organic coatings. The
general discussion (Section 4.1) is followed by a presentation of specific examples and issues
(Section 4.2).
4.1 General Steps for Determining Release and Other Waste Management
Activity Quantities
Release and other waste management activity quantities can be determined by
completing the following four steps, described in detail in the following sections.
Step 1) Prepare a process flow diagram.
Step 2) Identify EPCRA Section 313 chemicals and chemical categories and
potential sources of chemical release and other waste management
activities.
Step 3) Identify release and other waste management activity types.
Step 4) Determine the most appropriate method(s) and calculate the
estimates for release and other waste management activity
quantities.
4-1
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STEP 1: Prepare Process
Flow Diagram
STEP 2: Identify EPCRA
Section 313 Chemicals
or Chemical Categories
STEP2: Identify Sources of Release
and Other Waste
Management Activities
Source 1
Source 2
STEPS: Define the
Operation
Source 3
STEPS: Identify Release and Other
Waste Management Activity
Types
i
r
i i rii
Fugitive
Air
Point
Air
Discharge
to
Waterbody
Underground
Injection
Land
On Site
POTW
Transfer
Off Site for
Recycling
Transfer
Off Site for
Energy Recovery
Transfer
Off Site for
Treatment
Transfer On-Site
Off Site for Waste
Disposal Treatment
On-Site On-Site
Energy Recycling
Recovery
1
STEP4: Review Available
Data & Choose
Estimation Method
Calculate Estimates for
Release and Other Waste
Management Activity
Quantities
Figure 4-1. Release and Other Waste Management Activity Calculation Approach
-------
For EPCRA Section 313 purposes, "sources" are defined as the streams or units
that generate the release and other waste management activity (such as process vents, container
residue, or spills) and "types" are defined as the environmental media corresponding to elements
in Sections 5 through 8 of the 1997 Form R (for example, releases to fugitive air, releases to stack
air, discharges to receiving streams or POTWs, or releases to land).
4.1.1 Step 1: Prepare a Process Flow Diagram
Preparing a process flow diagram will help you to identify potential sources and
types of EPCRA Section 313 chemicals and chemical categories released and otherwise managed
as waste at your facility. Depending on the complexity of your facility, you may want to diagram
individual processes or operations rather than the entire facility. The diagram should show how
materials flow through the processes and identify material input, generation, and output points.
Looking at each operation separately, you can determine where EPCRA Section 313 chemicals
and chemical categories are used and the medium to which they may be released or otherwise
managed as waste.
4.1.2 Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories
and Potential Sources of Chemical Release and Other Waste Management
Activities
Once a process flow diagram has been developed, you must determine the
potential sources and the EPCRA Section 313 chemicals and chemical categories that may be
released and otherwise managed as waste from each unit operation and process. Remember to
include upsets and routine maintenance activities. Potential sources include:
Accidental spills and • Process vents;
releases; • Pumps;
Clean up and housekeeping • Recycling and energy
practices; recovery byproducts;
Combustion byproducts; • Relief valves;
Container residues; • Stock pile losses;
Fittings; • Storage tanks;
Flanges; • Storm water runoff;
Process discharge stream; • Tower stacks;
4-3
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Transfer operations; • Volatilization from process or
Treatment sludge; treatment; and
• Waste treatment discharges.
Next, you must identify the EPCRA Section 313 chemicals and chemical
categories that may be released or otherwise managed as waste from each source. A thorough
knowledge of the facility operations and processes is required for this determination. You should
also consider whether any of the EPCRA Section 313 chemicals or chemical categories are
coincidentally manufactured at your facility. Table 2-3 identifies EPCRA Section 313 chemicals
and chemical categories typically used in the operations common to electrodeposition and spray
application of organic coatings. This table can be used as an aid in identifying which chemicals
and chemical categories are found in your process. The list may not include all the EPCRA
Section 313 chemicals and chemical categories your facility uses, and it may include many
chemicals and chemical categories that you do not use.
4.1.3 Step 3: Identify Release and Other Waste Management Activity Types
For each identified source of an EPCRA Section 313 chemical or chemical
category, you should examine all possible release and other waste management activity types.
Figure 4-2 schematically represents the possible release and other waste management activity
types as they correspond to individual data elements of the Form R. Remember to include both
routine operations and accidents when identifying types. This diagram along with the following
descriptions can be used as a checklist to make sure all possible types of release and other waste
management activities have been considered.
a. Fugitive or Non-Point Air Emissions (Part II, Section 5.1 of Form R) -
Includes all emissions to the air that are not released through stacks, vents,
ducts, pipes, or any confined air stream. Examples include:
• Equipment leaks from valves, pump seals, flanges, compressors,
sampling connections, open-ended lines, etc.;
• Releases from building ventilation systems, such as a roof fan in an
open room;
4-4
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Point Sources
Fugitive Emissions
EPCRA Section 313 Chemical
or Chemical Category
Operation
Transfer Off Site for Recycling
Transfer Off Site for Energy Recovery
Transfer Off Site for Treatment
Transfer Off Site for Disposal
On-Site Treatment
On-Site Energy Recovery
On-Site Recycling
Underground Injection
Receiving Stream
POTW
Land on site (landfill, land
treatment, surface impoundment)
Figure 4-2. Possible Release and Other Waste Management Activity Types
for EPCRA Section 313 Chemicals and Chemical Categories
• Evaporative losses from solvent cleaning tanks, surface
impoundments, and spills; and
• Emissions from any other fugitive or non-point source.
b. Stack or Point Air Emissions (Part II, Section 5.2 of Form R) -
Includes all emissions to the air that occur through stacks, vents, ducts,
pipes, or any confined air stream, including the emissions from storage
tanks and air pollution control equipment. Air emissions from paint booths
are often channeled through vapor recovery systems and/or air pollution
control devices. These are considered stack emissions. Note that
emissions released from general room air through a ventilation system are
not considered stack or point releases for the purpose of EPCRA Section
313 reporting unless they are channeled through an air pollution control
device. Instead, they are considered fugitive releases. However, you
should note that for certain state reporting requirements, not associated
with EPCRA Section 313 reporting, some state air quality agencies
consider ventilation systems to be a stack or point source.
4-5
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c. Discharges to Receiving Streams or Water Bodies (Part II, Section 5.3
of Form R) - Includes direct wastewater discharges to a receiving stream
or surface water body. Discharges usually occur under a NPDES or
SPDES permit.
d. Underground Injection On-Site to Class I Wells (Part II, Section 5.4.1
of Form R) and to Class II through V Wells (Part II, Section 5.4.2 of
Form R) - Includes releases into an underground well at the facility.
These wells may be monitored under an Underground Injection Control
(UIC) Program permit. RCRA Hazardous Waste Generator Reports may
be a good source of information for wastes injected into a Class I well.
Injection rate meters may provide information for all the well classes.
e. Disposal to Land On-Site (Part II, Section 5.5 of Form R) - Includes
all releases to land on site, both planned (i.e., disposal) and unplanned (i.e.,
accidental release or spill). The four predefined subcategories for reporting
quantities released to land within the boundaries of the facility are:
(1) Landfill - The landfill may be either a RCRA permitted (Part II,
Section 5.5.1 A) or a non-hazardous waste landfill (Part II, Section
5.5. IB). Both types are included if they are located on site. Leaks
from landfills in the years subsequent to the disposal of the EPCRA
Section 313 chemicals or chemical categories in the landfill do not
need to be reported as a release.
(2) Land treatment/application farming - Land treatment is a
disposal method in which a waste containing an EPCRA Section
313 chemical or chemical category is applied to or incorporated
into soil. Volatilization of an EPCRA Section 313 chemical or
chemical category due to the disposal operation must be included in
the total fugitive air releases and should be excluded from land
treatment/application farming to avoid double counting.
Sludge and/or aqueous solutions that contain biomass and other
organic materials are often collected and applied to farm land. This
procedure supplies a nitrogen source for plants and supplies
metabolites for microorganisms. U.S. EPA considers this operation
to be land treatment/farming if it occurs on site. If a facility sends
this material off site for the same purpose, it is considered to be a
"transfer to an off-site location, disposal" and should be reported
under Sections 6.2 and 8.1 of the Form R.
The ultimate disposition of the chemical or chemical category after
application to the land does not change the required reporting. For
example, even if the chemical or chemical category is eventually
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biodegraded by microorganisms or plants, it is not considered
recycled, reused, or treated.
(3) Surface impoundment - A surface impoundment is a natural
topographic depression, man-made excavation, or diked area
formed primarily of earthen materials that is designed to hold an
accumulation of wastes containing free liquids. Examples include:
holding, settling, storage, and elevation pits; ponds; and lagoons.
You do not have to report quantities of an EPCRA Section 313
chemical or chemical category that are released to a surface
impoundment as part of a wastewater treatment process in this
section. However, if the sludge from the surface impoundment
contains the EPCRA Section 313 chemical or chemical category,
then the EPCRA Section 313 chemicals or chemical categories in
the sludge must be estimated in this section unless the sludge is
removed and subject to another waste management activity.
(4) Other disposal - Releases to land that do not fit the categories of
landfills, land treatment, or surface impoundment are classified as
other disposal. This disposal may include any spills or leaks of the
EPCRA Section 313 chemical or chemical category to land.
f. Discharges to Publicly Owned Treatment Works (POTW) (Part II,
Section 6.1 of Form R) - Includes the amount of EPCRA Section 313
chemical or chemical category in water transferred to an off-site POTW.
Note that metals and metal compounds transferred to a POTW must also
be reported in Section 8.1.
g. Transfers to Other Off-Site Locations (Part II, Section 6.2 of Form R)
- Includes all off-site transfers containing the EPCRA Section 313 chemical
or chemical category for the purposes of disposal, treatment, energy
recovery, or recycling. Off-site transfer for disposal includes underground
injection, landfill/surface impoundment, other land disposal and transfer to
a waste broker for disposal. The amount transferred off site for disposal
must also be reported in Section 8.1.
Be sure to consider metals and metal compounds that are present in
pigments used in spray coating applications. Waste containing these
pigments may be present in spent filters or other waste generated from
spray booths.
Also reported in Section 6.2 would be any residual EPCRA Section 313
chemicals or chemical categories in "empty" containers transferred off site.
U.S. EPA expects that all containers (bags, totes, drums, tank trucks, etc.)
will have a small amount of residual solids and/or liquid. On-site cleaning
of containers must be considered for EPCRA Section 313 reporting.
If the cleaning occurs with a solvent (organic or aqueous), you
4-7
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disposition of the waste solvent as appropriate. If the containers are sent
off site for disposal or reclamation, you should report the EPCRA Section
313 chemical or chemical category in this section.
COMMON ERROR - Shipping Container Residue
Do not overlook residual chemicals or chemical categories in containers. U.S. EPA
recently published The 1994 and 1995 Toxic Release Inventory Data Quality Report,
EPA 745-R-98-002, presenting the results of over 100 site surveys to evaluate EPCRA
Section 313 reporting quality. This survey found the largest source of overlooked releases
and other waste management activities was from container residue. So-called "empty"
drums may contain an inch or more of liquid after draining and similarly "empty" bags
may contain residues of dust and powder. Even though each individual drum or bag may
only contain a small amount of an EPCRA Section 313 chemical or chemical category, for
facilities that receive hundreds or thousands of drums or bags each year the annual
cumulative amount of an EPCRA Section 313 chemical or chemical category can be
substantial. The quantities should typically be reported in Section 6.2.
Actual data and a knowledge of the unloading methods at your facility can
be used to estimate the quantity of residual chemicals or chemical
categories in containers. However, U.S. EPA has developed guidance to
assist facilities if no site-specific information is available. Table 4-1
provides results from experimentation on residue quantities left in drums
and tanks when emptied. These results are presented as the mass percent
of the vessel capacity, and are categorized based on unloading method,
vessel material, and bulk fluid material properties such as viscosity and
surface tension.
4-8
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Table 4-1
Summary of Residue Quantities From Pilot-Scale Experimental Studya'b
(weight percent of drum capacity)
Unloading
Method
Pumping
Pumping
Pouring
Pouring
Gravity
Drain
Gravity
Drain
Gravity
Drain
Vessel Type
Steel drum
Plastic drum
Bung-top steel
drum
Open-top steel
drum
Slope-bottom
steel tank
Dish-bottom
steel tank
Dish-bottom
glass-lined tank
Value
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Material
Kerosene0
1.93-3.08
2.48
1.69-4.08
2.61
0.244 - 0.472
0.404
0.032-0.080
0.054
0.020-0.039
0.033
0.031 -0.042
0.038
0.024 - 0.049
0.040
Water"
1.84-2.61
2.29
2.54-4.67
3.28
0.266-0.458
0.403
0.026-0.039
0.034
0.016-0.024
0.019
0.033-0.034
0.034
0.020 - 0.040
0.033
Motor Oil6
1.97-2.23
2.06
1.70-3.48
2.30
0.677-0.787
0.737
0.328-0.368
0.350
0.100-0.121
0.111
0.133-0.191
0.161
0.112-0.134
0.127
Surfactant
Solution'
3.06
3.06
Not
Available
0.485
0.485
0.089
0.089
0.048
0.048
0.058
0.058
0.040
0.040
Trom "Releases During Cleaning of Equipment." Prepared by PEI Associates, Inc., for the U.S. Environmental
Protection Agency, Office of Pesticides and Toxic Substances, Washington DC Contract No. 68-02-4248. June 30,
1986.
bThe values listed in this table should only be applied to similar vessel types, unloading methods, and bulk fluid
materials. At viscosities greater than 200 centipoise, the residue quantities can rise dramatically and the information on
this table is not applicable.
Tor kerosene, viscosity = 5 centipoise, surface tension = 29.3 dynes/cm2
dFor water, viscosity = 4 centipoise, surface tension = 77.3 dynes/cm2
Tor motor oil, viscosity = 97 centipoise, surface tension = 34.5 dynes/cm2
Tor surfactant solution viscosity = 3 centipoise, surface tension = 31.4 dynes/cm2
4-9
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The following example describes how the information in the table can be used to
estimate the quantity of an EPCRA Section 313 chemical or chemical category in
water that was used to clean drums on site.
Example - Container Residue
You have determined that a Form R for an EPCRA Section 313 chemical or chemical category must be submitted.
The facility purchases and uses one thousand 55-gallon steel drums that contain a 10% aqueous solution of the
chemical. Further, it is assumed that the physical properties of the solution are similar to water. The solution is
pumped from the drums directly into a mixing vessel and the "empty" drums are triple-rinsed with water. The rinse
water is indirectly discharged to a POTW and the cleaned drums are sent to a drum reclaimer.
From Table 4-1, the average drum residue quantity for this scenario is 2.29%. In this example, it can be assumed that
all of the residual solution in the drums was transferred to the rinse water. Therefore, the quantity of the EPCRA
Section 313 chemical or chemical category transferred to the drum reclaimer should be reported as "zero."
The annual quantity of residual solution that is transferred to the rinse water can be estimated by multiplying the mean
weight percent of residual solution remaining in a pumped steel drum by the total annual weight of solution in the
drums. If the density is not known, it may be appropriate to use the density of water (8.34 pounds per gallon):
(2.29%) x (55 gal/drum) x (1,000 drums) x (8.34 Ib/gal) = 10,504 pounds solution.
The concentration of the EPCRA Section 313 chemical or chemical category in the solution is only 10%.
(10,504 Ib solution) x (10%) = 1,050 pounds of the EPCRA Section 313 chemical or chemical
category.
Therefore, 1,050 pounds of the EPCRA Section 313 chemical or chemical category are transferred to the POTW.
h. On-Site Waste Treatment (Part II, Section 7A of Form R) - Includes all
on-site waste treatment of EPCRA Section 313 chemicals or chemical
categories. The information reported in Section 7A focuses on the
treatment of the entire waste stream, not the specific EPCRA Section 313
chemical or chemical category. The information includes type of waste
stream (gaseous, aqueous or non-aqueous liquid, or solid); treatment
methods or sequence; influent concentrations of the EPCRA Section 313
chemical or chemical category; treatment efficiency (combined removal and
destruction) of the entire method or sequence; and whether efficiency data
is based on actual operating data. Metals and metal portions of metal
compounds treated in a combustion process are not destroyed but should
still be reported as going through the treatment process, with a treatment
efficiency of zero. Note that only the metal portion of metal compounds
should be reported in the Form R. The following example illustrates how
Section 7A should be completed for on-site treatment of a wastewater
stream containing three EPCRA Section 313 chemicals or chemical
categories.
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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 chemicals have been exceeded and you are in the process of
completing separate Form Rs for each chemical.
Both wastewater streams are combined and sent to an on-site wastewater treatment system before being released to a
POTW. This system consists of an oil/water separator that removes 99% of chemical A; a neutralization tank in
which the pH is adjusted to 7.5, thereby destroying 100% of the mineral acid (chemical C); and a settling tank where
95% of the metal (chemical B) is removed from the water (and eventually land filled off site).
Section 7A should be completed slightly differently when you file the Form R for each of the chemicals or chemical
categories. The table accompanying this example shows how Section 7A should be completed for each chemical or
chemical category. First, on each Form R you should identify the type of waste stream in Section 7A. la as
wastewater (aqueous waste, code W). Next, on each Form R you should list the code for each of the treatment steps
that is applied to the entire waste stream, regardless of whether the operation affects the chemical or chemical
category for which you are completing the Form R (for instance, the first four blocks of Section 7A. Ib of all three
Form Rs should show: P19 (liquid phase separation), Cl 1 (neutralization), PI 1 (settling/clarification), and N/A (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 or chemical category specific. It applies to the entire waste stream being treated. Section 7 A. Ic of each
Form R should show the concentration of the specific chemical or chemical category in the influent to the first step of
the process (oil/water separation). For this example, assume chemicals or chemical categories A, B, and C are all
present at concentrations greater than 1%. Therefore, code "1" should be entered. Section 7A. Id is also chemical
specific. It applies to the efficiency of the entire system in destroying and/or removing the chemical or chemical
category for which you are preparing the Form R. You should enter 99% when filing for chemical A, 95% for
chemical B, and 100% for chemical C. Finally, you should report whether the influent concentration and efficiency
estimates are based on operating data for each chemical or chemical category, as appropriate.
Chemical A
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-1-
7A.ld
99 %
7A.le
Yes No
X
Chemical B
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-1-
7A.ld
95 %
7A.le
Yes No
X
Chemical C
7A.la
w
7A.lb
3. Pll
6.
1. P19 2. Cll
4. N/A 5.
7. 8.
7A.lc
-L~
7A.ld
100 %
[continued o
7A.le
Yes No
X
n next page]
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Note that the quantity removed and/or destroyed is not reported in Section 7 and that the efficiency reported in
Section 7A. 1 d refers to the amount of EPCRA Section 313 chemical or chemical category destroyed and/or removed
from the applicable waste stream. The amount actually destroyed should be reported in Section 8.6 (quantity treated
on site). For example, when completing the Form R for chemical B you should report "0" pounds in Section 8.6
because the metal has been removed from the wastewater stream, but not actually destroyed. The quantity of
chemical B that is ultimately land filled off site should be reported in Section 6.2 and 8.1. However, when
completing the Form R for chemical C you should report the entire quantity in Section 8.6 because raising the pH to
7.5 will completely destroy the mineral acid.
i. On-Site Energy Recovery (Part II, Section 7B of Form R) - Includes all
on-site energy recovery of reported EPCRA Section 313 chemicals and
chemical categories. U.S. EPA's view is that EPCRA Section 313
chemicals or chemical categories that do not contribute significant heat
energy during combustion processes should not be considered for energy
recovery. Therefore, only EPCRA Section 313 chemicals or chemical
categories with a significant heating value that are combusted in an energy
recovery unit, such as an industrial furnace, kiln, or boiler can be reported
for energy recovery. If an EPCRA Section 313 chemical or chemical
category is incinerated on site but does not significantly contribute energy
to the process, (e.g., chlorofluorocarbons (CFCs)) it must be considered
on-site waste treatment (see 4.1.3, h. above). Metals and metal portions of
metal compounds will never be combusted for energy recovery. Note that
only the metal portion of metal compounds should be reported in the Form
R.
j. On-Site Recycling (Part II, Section 7C of Form R) - Includes all on-site
recycling methods used on EPCRA Section 313 chemicals or chemical
categories.
k. Source Reduction and Recycling Activities (Part II, Section 8 of Form
R)1 - Provide information about source reduction and recycling activities
related to the EPCRA Section 313 chemical or chemical category for
which releases and other waste management activities are being reported.
Section 8 uses some data collected to complete Part II, Sections 5 through
7. For this reason, Section 8 should be completed last. The relationship
between Sections 5, 6, and 8.8 to Sections 8.1, 8.3, 8.5, and 8.7 are
provided in equation forms below.
(1) Quantity Released (Part II, Section 8.1 of Form R) - The
quantity reported in Section 8.1 is the quantity reported in all of
Section 5 plus the quantity of metals and metal compounds
reported as discharged off site to POTWs in Section 6.1 plus the
quantity reported as sent off site for disposal in Section 6.2 minus
'The Subsection 8.1 through 8.8 designations are for the 1997 Form R. Please refer to the current reporting year TRI
Forms and Instructions for any changes.
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the quantity reported in Section 8.8 that was released on site or sent
off site for disposal:
§8.1 = §5 + §6.1 (metals and metal compounds) + §6.2 (disposal
only) - §8.8 (on-site release or off-site disposal only)
(2) Quantity Used for Energy Recovery On-Site (Part II, Section
8.2 of Form R) - Estimate the quantity of the EPCRA Section 313
chemical or chemical category in wastes combusted for energy
recovery on site. This estimate should be the quantity of the
chemical or chemical category combusted in the process for which
codes were reported in Section 7B. Test data from trial burns or
other monitoring data may be used to estimate the quantity of the
EPCRA Section 313 chemical or chemical category combusted for
energy recovery purposes. If monitoring data are not available,
vendor specifications regarding combustion efficiency may be used
as they relate to the EPCRA Section 313 chemical or chemical
category. A quantity must be reported in Section 8.2 when a
method of on-site energy recovery is reported in Section 7B and
vice versa.
Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical or chemical category (1) must have a
significant heating value and (2) must be combusted in an energy
recovery unit, such as a waste heat boiler, an industrial furnace, or a
kiln. If an EPCRA Section 313 chemical or chemical category that
does not have a significant heating value (except metals and metal
compounds) is combusted for energy recovery on site, it must be
considered on-site waste treatment (see 4.1.3 .h). Metals and metal
compounds in a waste that are combusted on site will never be
combusted for energy recovery and are considered to be disposed.
Note that "NA" should be reported for EPCRA Section 313
chemicals or chemical categories that do not have a significant
heating value. This includes metals, metal portions of metal
compounds, halogens, hydrochlorofluorocarbons (HCFCs), and
CFCs.
(3) Quantity Used for Energy Recovery Off-Site (Part II, Section
8.3 of Form R) - The quantity reported in Section 8.3 is the
quantity reported in Section 6.2 for which energy recovery codes
are reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for energy recovery:
§8.3 = §6.2 (energy recovery) - §8.8 (off-site energy recovery)
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Two conditions need to be met to report the combustion of an
EPCRA Section 313 chemical or chemical category in waste as
energy recovery: the chemical or chemical category (1) must have a
significant heating value and (2) must be combusted in an energy
recovery unit, such as a waste heat boiler, an industrial furnace, or a
kiln. If an EPCRA Section 313 chemical or chemical category that
does not have a significant heating value (except metals and metal
compounds) is sent off site for energy recovery, it must be
considered off-site waste treatment (see 4.1.3.g). Metals and metal
compounds sent off site for combustion in energy recovery units
must be considered as sent off site for disposal because typically
they will ultimately be disposed. Metals and metal portions of
metal compounds will never be treated or combusted for energy
recovery. Note that only the metal portion of metal compounds
should be reported in the Form R. Also note that "NA" should be
reported for EPCRA Section 313 chemicals or chemical categories
that do not have a significant heating value. This includes metals,
metal portions of metal compounds, halogens, HCFCs, and CFCs.
(4) Quantity Recycled On-Site (Part II, Section 8.4 of Form R) -
Estimate the quantity of the EPCRA Section 313 chemical or
chemical category recycled in wastes on site. This estimate should
be the quantity of the chemical or chemical category recycled in the
process for which codes were reported in Section 7C. A quantity
should be reported in Section 8.4 when a method of on-site
recycling is reported in Section 7C and vice versa. To estimate this
quantity, you should determine if operating data exist that indicate a
recovery efficiency and use that efficiency value combined with
throughput data to calculate an estimate. If operating data are
unavailable, available vendor specifications may be appropriate.
(5) Quantity Recycled Off-Site (Part II, Section 8.5 of Form R) -
The quantity reported in Section 8.5 must be the same as the
quantity reported in Section 6.2 for which recycling codes are
reported. If a quantity is reported in Section 8.8, subtract any
associated off-site transfers for recycling:
§8.5 = §6.2 (recycling) - §8.8 (off-site recycling)
(6) Quantity Treated On-Site (Part II, Section 8.6 of Form R) -
Waste treatment in Section 8 is limited to the destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category in wastes. The quantities reported in Section 8.6
will be those that have undergone processes that are a subset of the
processes for which codes were reported in Section 7A, where
treatment includes physical removal from a waste stream. To
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estimate the quantity treated, you should determine if operating
data exist that indicate a treatment efficiency (e.g., destruction or
chemical conversion of the EPCRA Section 313 chemical or
chemical category) and use that efficiency value combined with
throughput data to calculate an estimate. Because metals cannot be
destroyed or chemically converted into something other than the
metal or metal compound, metals cannot be reported as treated in
Section 8.6. Note that conversion of a metal from one oxidation
state to another (e.g., Cr(VI) to Cr(III)) is not considered treatment
for Section 8.6. If operating data are unavailable, available vendor
specifications may be appropriate. Section 7A must be completed if
a quantity is entered in Section 8.6.
(7) Quantity Treated Off-Site (Part II, Section 8.7 of Form R) -
The quantity reported in Section 8.7 must be the same as the
quantity reported in Section 6.2 for which treatment codes are
reported plus quantities sent to a POTW as reported in Section 6.1
except for metals and metal compounds. If a quantity is reported in
Section 8.8, subtract any associated off-site transfers for treatment:
§8.7 = §6.1 (except metals and metal compounds) + §6.2
(treatment) - §8.8 (off-site treatment)
Because metals cannot be destroyed or chemically converted into
something other than the metal or metal compound, metals cannot
be reported as treated in Section 8.7. Quantities of metals reported
in Section 6.1 and 6.2 should be reported in Section 8.1 (Quantity
Released) unless the facility has knowledge that the metal is being
recovered.
(8) Quantity Released to the Environment as a Result of Remedial
Actions, Catastrophic Events, or One-Time Events Not
Associated with Production Processes (Part II, Section 8.8 of
Form R) - The purpose of this section is to separate quantities
recycled off site, used for energy recovery off site, treated off site,
or released (including disposed) that are associated with normal or
routine production from those quantities that are not. The quantity
reported in Section 8.8 is the quantity of the EPCRA Section 313
chemical or chemical category released directly into the
environment or sent off site for recycling, energy recovery,
treatment, or disposal during the reporting year due to any of the
following events:
• Remedial actions;
• Catastrophic events such as earthquakes, fires, or floods; or
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• 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 II, Sections 5 and 6 of Form R as
appropriate.
Spills that occur as a routine part of production operations and
could be reduced or eliminated by improved handling, loading, or
unloading procedures are included in the quantities reported in
Section 8.1 through 8.7 as appropriate. This includes small
drippings and spills that often occur during transfer operations and
loading/unloading operations associated with many painting
processes.
On-site releases and off-site transfers for further waste management
from remediation of an EPCRA Section 313 chemical or chemical
category or an unpreventable accident unrelated to production
(such as a hurricane) are reportable in Section 8.8.
On-site treatment, energy recovery, or recycling of EPCRA Section
313 chemicals or chemical categories in wastes generated as a
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 in Sections 8.1 through 8.7 of Form R.
COMMON ERROR - Double Counting
Release 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) and Calculate the
Estimates for Release and Other Waste Management Activity Quantities
After you have identified all of the potential sources for release and other waste
management activity types, you must estimate the quantities of each EPCRA Section 313
chemical and chemical category released and otherwise managed as waste. EPA has identified
4-16
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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 the U.S. EPA publication,
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
Forms (1999 edition). They are also briefly described below. A more detailed discussion
including examples of selected calculation techniques is presented in Appendix B. U.S. EPA does
not require you to conduct additional sampling or testing for EPCRA Section 313 reporting;
however, you are required to use the best, readily available information to determine the method
that will result in the most accurate estimate. For example, it may not be appropriate to use
emission factors or engineering calculations if more accurate data, such as stack testing results,
are available. You are required to identify the primary method used for each estimation.
Many potential sources of data exist for these (and other) methods of developing
estimates. Table 4-2 presents potential data sources and the estimation methodology in which they
are most likely to be used. Based on site-specific knowledge and potential data sources available,
you should be able to determine the best method for calculating each release and other waste
management activity quantity.
Once all potential release and other waste management activity sources, types, and
estimation methods have been determined, an estimate for each EPCRA Section 313 chemical and
chemical category can be developed corresponding to the elements on Form R.
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Table 4-2
Potential Data Sources for Release and Other Waste Management
Calculations
DATA SOURCES
Monitoring Data
• Air permits
• Continuous emission monitoring
• Effluent limitations
• Hazardous waste analysis
• Industrial hygiene monitoring data
• NPDES permits
• Outfall monitoring data
• pH for acids and bases
• POTW pretreatment standards
• RCRA permit
• Stack monitoring data
Emission Factors
AP-42 chemical specific emission factors
Facility or trade association derived chemical-
specific emission factors
Mass Balance
• Air emissions inventory
• Hazardous material inventory
• Hazardous waste manifests
• MSDSs
• Pollution prevention reports
• Spill event records
• Supply records
Engineering Calculations
• Facility non-chemical specific emission factors.
• Henry's Law
• Raoult's Law
• SOCMI* or trade association non-chemical specific
emission factors
• Solubilities
• Volatilization rates
* Synthetic Organic Chemicals Manufacturing Industry.
4.1.4.1
Monitoring Data or Direct Measurement (code M)
Using monitoring data or direct measurements is usually the best method for
developing chemical release and other waste management activity quantity estimates. Your
facility may be required to perform monitoring under provisions of the Clean Air Act (CAA),
Clean Water Act (CWA), RCRA, or other regulations. If so, data should be available for
developing estimates. Data may have also been collected for your facility through an occupational
health and safety assessment. If only a small amount of direct measurement data are available or
if you believe the monitoring data are not a representative, you must decide if another estimation
method would give a more accurate result.
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Example - Monitoring Data
Data from the on-site wastewater treatment facility indicate that the annual average concentration of copper in the
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 POTW. The amount of copper transferred off site to the POTW (for
Sections 6.1 and 8.1 of the Form R) is estimated as follows:
Amount of copper transferred
=(2 mg/L) x 1 1 x I * 1 x 1 L 1 x (! 50o ooo gal/yr)
& ' ( 1,000 mgj ( 453.59 g/ ( 0.2642 galj
= 25 Ib/yr
COMMON ERROR - Treatment Efficiencies
Vendor data on treatment efficiencies often represent ideal operating conditions. You should adjust such data to
account for downtime and process upsets during the year that would result in lower efficiencies. Remember that
efficiencies reported by vendors are often general and may not apply to specific chemicals. For example, an
incinerator or flare may be 99.99% efficient in destroying certain organic chemicals, but will have a 0% efficiency in
destroying metals.
4.1.4.2 Mass Balance (code C)
A mass balance involves determining the amount of an EPCRA Section 313
chemical or chemical category entering and leaving an operation. The mass balance is written as
follows:
Input + Generation = Output + Consumption
where:
Input refers to the materials (chemicals) entering an operation. For
example, chlorine added to process water as a disinfectant would be
considered an input to the water treatment operation.
Generation identifies those chemicals created during an operation
(manufactured, including coincidental manufacturing). For example, when
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nitrogen sources are used in biological wastewater treatment systems,
additional ammonia may be coincidentally manufactured.
Output means any avenue by which the chemical leaves the operation.
Output may include on-site releases and other on-site waste management
activities; transfers off site for recycling, energy recovery, treatment,
storage, or disposal; or the amount of chemical that leaves with the final
product. In a coating operation, for example, pigments in the paint may
leave the operation as part of the product (the coating), in wastewater
collected from overspray, and on paint spray booth filters sent for disposal.
Consumption refers to the amount of chemical converted to another
substance during the operation (i.e., reacted). For example, in the
phosphating process, accelerators may be added to enhance reaction speed,
eliminate hydrogen production, or sludge formation control. Several
materials can be used for this purpose, including nitrite or nitrate
compounds, which would be consumed in the process. Another illustration
of consumption can be found in the coating reaction of the phosphating
process. Here the phosphoric acid is consumed in a reaction with the metal
to form the crystalline metal phosphate, in this case the crystalline zinc
phosphate:
3Zn+2 + IFyO/ + 4H2O - Zn3 (PO4)2 • 4H2O + 4H+1
(Ref: Donofrio, J., "Zinc Phosphating"; Organic Finishing Guidebook and
Directory, May 1996, pages 68-85)
The mass balance technique may be applied toward manufactured, processed, or
otherwise used chemicals and chemical categories. It is typically most useful for otherwise used
chemicals or chemical categories that do not become part of the final product, such as catalysts.
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 - Mass Balance
A facility otherwise uses a volatile EPCRA Section 313 chemical as a refrigerant and adds 20,000 pounds to the
refrigeration system (to make up for system losses). The chemical is released to the air from relief vents, during
system filling operations and from leaks in valves and fittings. During system maintenance, the lines are bled directly
into water and the system is vented to the air. Monitoring data of the wastewater, including chemical concentrations
and wastewater throughput, indicate that 1,200 pounds of the chemical were discharged to the wastewater. The
remaining losses are assumed to be fugitive air releases and are estimated as follows:
Fugitive air releases of the EPCRA Section 313 chemical:
= Amount input (Ib/yr) - Amount released to wastewater (Ib/yr)
= 20,000 Ib/yr - 1,200 Ib/yr
= 18,800 Ib/yr
COMMON ERROR - Mass Balances for Otherwise Used Chemicals
Facilities often do not account for the entire quantity of EPCRA Section 313 chemicals or chemical categories that
are otherwise used. Many EPCRA Section 313 chemicals and chemical categories in electrodeposition and spray
application of organic coating operations are classified as otherwise used. Such chemicals and chemical categories
rarely leave the facility with the product. In these instances, all throughput may be lost during processing through on-
site releases to air, water, or land, or it may be shipped off site for further waste management activities. Thus, the
entire throughput is often reportable on Form R as releases and other waste management activities to various media.
Be sure to consider the entire throughput in these circumstances and partition it as appropriate. A mass balance may
be the best starting point to estimate the releases and other waste management quantities.
4.1.4.3 Emission Factors (code E)
An emission factor is a representative value that attempts to relate the quantity of a
chemical or chemical category released with an associated activity. These factors are usually
expressed as the weight of chemical or chemical category released divided by a unit weight,
volume, distance, or duration of the activity releasing the chemical (e.g., pounds of chemical
released per pounds of product produced). Emission factors, commonly used to estimate air
emissions, have been developed for many different industries and activities. You should carefully
evaluate the source of the emission factor and the conditions for its use to determine if it is
applicable to the situation at your facility.
The most widely known and used source for emission factors is U.S. EPA's
publication Compilation of Air Pollutant Emission Factors (AP-42). Volume I of AP-42
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information on over 200 stationary source categories, including process descriptions and potential
sources of air emissions from these processes. Methodologies for estimating the quantity of air
pollutant emissions from these sources are presented as Emission Factors. For EPCRA Section
313 purposes only CHEMICAL-SPECIFIC emission factors can be reported as Code "E" -
Emission Factor in Part II, Section 5, Column B, Basis for estimate, of the Form R. AP-42
contains emission factors for individual chemicals and for the chemical group Volatile Organic
Compounds (VOCs). The VOC emission factors are NOT chemical specific and when used must
be reported in Column B as Code "O" - Engineering Calculations. Each chapter in Volume I
covers a major industry or source category. Of special interest to organic coating operations
would be Chapter 4: Evaporation Loss Sources, in particular Sections 4.2, Surface Coating; and
4.6, Solvent Degreasing; Chapter 6: Organic Chemical Process Industry, in particular Sections
6.4, Paint and Varnish; and 6.18, Benzene, Toluene, and Xylenes; and Chapter 7: Liquid Storage
Tanks.
AP-42 can be accessed at the following Internet site:
• http://www.epa.gov/ttn/chief/ap42.html
In an effort to provide current emissions data in an easy-to-access format, U.S.
EPA has prepared a CD-ROM entitled Air CHIEF (Air ClearingHouse for Inventories and
Emission Factors). The Air CHIEF CD-ROM is updated annually and is available from the
Government Printing Office and can be ordered from their Web site. In addition to AP-42, the
Air CHIEF CD-ROM contains the Factor Information Retrieval (FIRE) data system, a database
management system containing U.S. EPA's recommended emission estimation factors for criteria
and hazardous air pollutants. The CD-ROM also contains installable copies of software programs
for air emission estimation models such as "TANKS" for VOC emission from storage tanks;
"WATERS" for air emissions from wastewater systems; and "CHEMDAT8" for VOC emissions
from Treatment, Storage, and Disposal Facility (TSDF) processes. Additional information on Air
CHIEF and the CD-ROM is available at:
• http://www.epa.gov/ttn/chief/airchief.html
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Your facility may have developed non-chemical-specific emission factors for
fugitive or stack emissions from paint booths based on stack tests for various air permits. Be sure
to consider these emission factors if appropriate. However, if such factors are used, they are
considered "engineering judgement" for the purposes of EPCRA Section 313 reporting.
Example - Emission Factors
Emission factors have been developed for air releases of fuel constituents and combustion products from boiler
operations. AP-42 lists a range of formaldehyde emission factors when No. 6 fuel oil is consumed:
0.024 to 0.061 Ib formaldehyde generated/103 gal No. 6 fuel oil fired.
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 lb/103 gal) x (1,000,000 gal) and (0.061 lb/103 gal) x (1,000,000 gal)
= 24 and 61 Ib of formaldehyde
NOTE: No. 6 fuel oil contains other EPCRA Section 313 chemicals and chemical categories and EPCRA Section
313 chemicals and chemical categories may also be coincidentally manufactured during combustion. All should be
considered for EPCRA Section 313 reporting.
4.1.4.4 Engineering Calculations (code O)
Engineering calculations are assumptions and/or judgments used to estimate
quantities of EPCRA Section 313 chemicals and chemical categories released or otherwise
managed as waste. The quantities are estimated by using physical and chemical properties and
relationships (e.g., ideal gas law, Raoult's law) or by modifying an emission factor to reflect the
chemical properties of the chemical in question. Engineering calculations rely on the process
parameters; you must have a thorough knowledge of your facility operations to complete these
calculations.
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Examples - Engineering Calculations
Example 1:
Stack monitoring data are available for xylene but you are required to report for toluene. Toluene is used in the same
application as xylene at your facility and the concentrations of the chemicals in the liquid feedstock are approximately
the same. You can estimate the emissions of toluene by adjusting the monitoring data of xylene by a ratio of the
vapor pressure for xylene to toluene. This example is an engineering calculation based on physical properties and
process operation information:
From facility stack monitoring data, an estimated 200 Ib of xylene are released as air emissions during the reporting
year. Toluene is also present in the air emissions, but not monitored. The stack operates at approximately 125°C.
Based on literature data, the vapor pressures at 125°C 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 Ib/yr toluene = 1.44 atm (vapor pressure of toluene')
200 Ib/yr xylene 0.93 atm (vapor pressure of xylene)
X Ib/yr toluene = (200 Ib/yr xylenel (1.44 atm toluene)
(0.93 atm xylene)
Completing the calculation, the facility determines that 310 Ibs of toluene were released as stack air emissions during
the reporting year.
Example 2:
A coating process uses 10,000 gallons per year of a paint that is 3% xylene by volume. All of the xylene in the paint
is assumed to evaporate during the coating operation. The coating process is equipped with a fume collection hood
that captures 80% of the paint vapors. The remaining 20% of the paint vapors are assumed to be released as fugitive
air emissions. The collection hood routes the paint vapors to an incinerator that is vented to the atmosphere and has a
destruction efficiency of 99% for xylene. The specific gravity of xylene is 0.86 and the density of water is 8.34 Ib/gal.
Fugitive air emissions and stack air emissions may be estimated as follows:
1. The total amount of xylene volatilized to air (assumed to be the total amount of xylene in
paint)
(10,000 gal/yr paint) x (3% xylene) x (0.86 xylene specific gravity) x (8.34
Ib/gal, density of water)
= 2,152 Ib/yr xylene evaporated from coating operations
2. The amount of xylene released as fugitive air emissions
(2,152 Ib/yr) x (20%)
430 Ib/yr
3. The amount of xylene released as stack air emissions
(2,152 Ib/yr) x (80% capture efficiency) x (100% - 99% incinerated)
17 Ib/yr
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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, Synthetic Organic Chemicals
Manufacturing Industry (SOCMI) emission factors, industry-determined emission factors for
processes or equipment, and site-specific emission factors also can be used, but must be classified
as "Engineering Calculations" for EPCRA Section 313 reporting.
4.1.4.5 Estimating Release and Other Waste Management Quantities
Once all sources, types, and appropriate estimation methodologies have been
identified, you can estimate the release and other waste management activity quantities for each
element of the Form R. The recommended approach is that you estimate amounts from all
sources at your facility to each type as identified by the elements of Form R. Table 4-3 presents a
work sheet that may be helpful in compiling this information.
If you prepare a Form R, you must also enter on-site treatment information in
Section 7 A, including the code for each treatment method used, the destruction and removal
efficiency for the EPCRA Section 313 chemical or chemical category in the treated waste stream,
and the concentration of the EPCRA Section 313 chemical or chemical category in the influent to
treatment. You should report treatment methods that do not actually destroy or remove the
chemical or chemical category by entering "zero (0)" for removal efficiency. Similarly, on-site
energy recovery methods and on-site recycling methods must be reported in Sections 7B and 7C,
respectively.
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Table 4-3
Facility Name:.
Release and Other
Waste Management Quantity Estimation Worksheet
Date Worksheet Prepared:
Prepared by:
EPCRA Section 313 Chemical or Chemical Category:
CAS Registry Number:
Reporting Year:
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1997 version)
FUGITIVE AIR
Equipment Leaks
Process Areas
Evaporative Losses, Spills, Surface Impoundments
Total =
5.1 and 8. lor 8.8
5.1 and 8.1 or 8.8
5.1 and 8. lor 8.8
5.1 and 8.1 or 8.8
STACK AIR
Process Vents
Storage Tanks
Control Device Stacks
Other
Total =
5. 2 and 8.1 or 8.8
5.2 and 8. lor 8.8
5. 2 and 8.1 or 8.8
5.2 and 8. lor 8.8
5. 2 and 8.1 or 8.8
RECEIVING STREAM/WATER BODY DISCHARGE
Stormwater Discharge
On-Site Treatment Plant Discharge
Total =
5. 3 and 8.1 or 8.8
5. 3 and 8. lor 8.8
5. 3 and 8.1 or 8.8
ON-SITE UNDERGROUND INJECTION
Underground Injection to Class I Wells
Underground Injection to Class II - V Wells
Total =
5. 4 and 8.1 or 8.8
5.4 and 8. lor 8.8
5. 4 and 8.1 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not associated
with production process.
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Table 4-3 (Continued)
ON SITE
Release or Other Waste Management Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1997 version)
ON-SITE LAND
RCRA Subtitle C Landfill
Other Landfill
Land Treatment/Application Farming
Surface Impoundment
Other Disposal
Total =
ON-SITE ENERGY RECOVERY
Industrial Kiln
Industrial Furnace
Industrial Boiler
Other Energy Recovery Methods
Total =
ON-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Acid Regeneration
Other Reuse or Recovery
Total =
ON-SITE TREATMENT
Air Emissions Treatment
Biological Treatment
Chemical Treatment
Incineration/Thermal Treatment
Physical Treatment
Solidification/Stabilization
Total =
5. 5 and 8. lor 8.8
5. 5 and 8.1 or 8.8
5. 5 and 8. 1,8.6, or 8.8
5. 5 and 8.1 or 8.8
5. 5 and 8. lor 8.8
5. 5 and 8.1 or 8.8
8.2
8.2
8.2
8.2
8.2
8.4
8.4
8.4
8.4
8.4
8.6
8.6
8.6
8.6
8.6
8.6
8.6
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not associated
with production process.
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Table 4-3 (Continued)
OFF SUE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1997 version)
Off-Site Location
(name)
OFF-SITE DISPOSAL
Solidification/Stabilization (metals and
metal compounds only)
Amount of metal and metal compounds to
POTW
Wastewater Treatment (excluding POTWs)
metals and metal compounds only
Underground Injection
Landfill/Surface Impoundment
Land Treatment
Other Land Disposal
Other Off -Site Management
Total =
6.2 and 8. lor 8.8
6.1 and 8. lor 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
6. 2 and 8.1 or 8.8
6.2 and 8. lor 8.8
6. 2 and 8.1 or 8.8
6.2 and 8. lor 8.8
6. 2 and 8.1 or 8.8
OTHER AMOUNTS SENT OFF SITE
Amounts sent for storage
Amounts sent for unknown waste
management practice
Total =
6. 2 and 8.1 or 8.8
6.2 and 8. lor 8.8
6.2 and 8. lor 8.8
OFF-SITE TREATMENT
Solidification/Stabilization
Incineration/Thermal Treatment
Incineration/Insignificant Fuel Value
Wastewater Treatment (to POTW excluding
metals and metal compounds)
Wastewater Treatment (excluding POTW
and metal and metal compounds)
Sent to Waste Treatment Broker
Total =
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.1 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
6.2 and 8.7 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not associated
with production process.
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Table 4-3 (Continued)
OFF SUE
Release or Other Waste Management
Activity Type
Amount
(Ib)
Basis of
Estimate
Form R Element*
(1997 version)
Off-Site Location
(name)
OFF-SITE ENERGY RECOVERY
Off- Site Energy Recovery
Sent to Energy Recovery Broker
Total =
6.2 and 8.3 or 8.8
6. 2 and 8.3 or 8.8
6.2 and 8.3 or 8.8
OFF-SITE RECYCLING
Solvents/Organics Recovery
Metals Recovery
Other Reuse or Recovery
Acid Regeneration
Sent to Recycling Waste Broker
Total =
6.2 and 8.5 or 8.8
6. 2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6. 2 and 8.5 or 8.8
6.2 and 8.5 or 8.8
6. 2 and 8.5 or 8.8
*Entries for Section 8.8 only if release is result of remedial action, catastrophic event, or one-time event not associated
with production process.
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4.2 Process Descriptions (Chemical Activities)
The primary purposes of the application of an organic coating to a workpiece are
protection and/or decoration. The composition of the coating may be simple (a single chemical);
however, it is almost always a complex formulation of a variety of materials, each having a
specific function. Organic coating formulations generally have three permanent components,
pigment, vehicle or binder, and additives, along with one temporary component, carrier fluid. The
carrier fluid evaporates after application to allow the permanent components to become
immobilized. EPCRA Section 313 chemicals or chemical categories may be found in any of the
components.
Spray application of organic coatings is used extensively in the automotive
industry for both original equipment manufacturing and refmishing. It is also widely used in the
furniture manufacturing industry, and in other industries requiring application of an organic
coating to a workpiece. In the spray application process, the coating material is atomized, and the
workpiece to be coated is exposed to the resulting spray.
Electrodeposition of organic coatings, or electrocoating, is used extensively in the
automotive industry and in the manufacture of appliances, heat exchangers, decorative items, and
heat sensitive components. Electrodeposition is the use of an electric current to apply a coating
to a metal part suspended in a dispersion of paint solids in water. The method has extremely high
transfer efficiencies, typically in the 95 to 99% range, and results in the application of uniform
coatings to even the most complex parts.
The application of organic coatings, by either spray or electrodeposition, is
essentially a three-step process (see Figure 4-3); detailed process flow diagrams are presented in
the subsequent discussion on each unit operation:
1. Surface preparation - cleaning and pre-treatment.
2. Application of the organic coating.
3. Flash-off and curing.
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Organic Coating Chemicals
and Chemical Categories
Air Emissions
Air Emissions
Workpiece
1
1
Cleaning
& Treatment
Chemicals
Surface
Prep
Spray Application
or
Electrodeposition
of
Organic Coatings
AI .
Wastewater
Slurry
Container Residues
Air Emissions
1 t
Wastewater
Slurry
Residues
Flash-Off
Zone
Curing
Zone
1
. Coated
Workpiece
Clean Out Wastes
from Oven and
Product Carrier
Figure 4-3. Overall Process Flow Diagram - Application of Organic Coatings
-------
Steps 1 and 3 for the spray application and electrodeposition of organic coatings processes are
similar and even identical in many instances. Both of the processes use many EPCRA Section 313
chemicals and chemical categories. Because of the many similarities, guidance for the two coating
technologies is combined in this document.
It is recognized that not all organic coating establishments will have all unit
operations described in this document. For example, original equipment manufacturers may not
have an abrasive cleaning step to remove old coatings. However, each of the unit operations
discussed are common operations found in organic coating establishments covered by EPCRA
Section 313 reporting requirements. You should select the operation, or combination of
operations, that most closely fits the activities at your establishment.
It is also recognized that flash-off and curing operations are physically separate
functions. However, for EPCRA Section 313 reporting purposes they are very similar and have
been combined in this document.
The following sections will discuss each of the steps in the application of organic
coatings and the estimation of release and other waste management activity quantities.
4.2.1 Surface Preparation
The condition of the workpiece and the desired purpose of the coating application
determine the type of surface preparation before the organic coating is applied. Surface
preparation may include as many as four steps:
1. Mechanical/abrasive cleaning.
2. Cleaning/degreasing.
3. Special treatments.
4. Rinsing (generally following every step).
The following sections discuss the most common operations involved in surface
preparation, and how to estimate release and other waste management activity quantities from
those operations. Your facility may not perform all of these processes.
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4.2.1.1 Abrasive Cleaning
If the workpiece has an existing coating (such as rust, mill scale, or old paint), it
usually requires mechanical or abrasive cleaning. In this cleaning process, abrasive particles are
projected onto the workpiece using compressed air as the source of power. Silica sand, plastic
beads, walnut shells, and metal pellets are typical abrasive materials. Most abrasives do not
contain any EPCRA Section 313 chemicals or chemical categories; however, metal pellets, mined
materials, and industrial slags are sometimes used as abrasives and may contain EPCRA Section
313 chemicals and chemical categories.
It should be noted that in the case of a coating being removed from a workpiece,
such as old paint, the removed coating is not being manufactured, processed, or otherwise used,
and any EPCRA Section 313 chemicals and chemical categories in the removed coating should
not be included in any activity threshold calculations. However, if an activity threshold for an
EPCRA Section 313 chemical or chemical category in the coating being stripped has been
exceeded by other activities elsewhere in the facility, any release and other waste management
activity amounts for the chemical or chemical category in the removed coating must be included in
the reported amount. It should also be noted that if the contaminated abrasive material is sent off
site for disposal, the receiving facility (if it meets the SIC Code and number of employees criteria)
must consider any EPCRA Section 313 chemicals and chemical categories in the waste in
otherwise use threshold determinations.
When evaluating items for the article exemption, the amount of any EPCRA
Section 313 chemicals and chemical categories removed from the workpiece itself must be
determined (e.g., chromium, manganese, nickel, or zinc (dust) from a steel workpiece). If this
results in a release exceeding 0.5 pound/year from all like articles, the article exemption for the
workpiece would be lost.
It is also important to note that any EPCRA Section 313 chemical or chemical
category in the abrasive material itself must be included in the otherwise use activity threshold. If
the activity threshold for such a chemical or chemical category is exceeded, the release and
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other waste management amounts from the disposal of the material, such as used shot and of the
breakdown dust from the use of the shot, must be reported.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-4.
Dust
Dirty Workpiece I
Abrasive
Cleaning
Abrasive Media
•j—*•
-> Cleaned Workpiece
Recycled Abrasive ,,
*• Contaminated Abrasive/Waste
Figure 4-4. Process Flow Diagram - Abrasive Cleaning
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The most common potential source of EPCRA Section 313 chemicals and
chemical categories from abrasive cleaning is the dust generated by the abrasive activity. If the
purpose of the cleaning process is to remove old paint, this dust may contain lead, chromium,
and/or zinc if the original paint was applied prior to 1980. Most, if not all, post-1980 paints do
not contain lead or chromium. Marine paints typically contain anti-fouling chemicals such as
tributyl tin, copper, and pesticides. If the surface being cleaned is composed of aluminum,
vanadium, or zinc, the creation of dust particles of these metals must be considered towards the
manufacturing threshold because dust forms of these three metals have been created
(manufactured) and they are separately listed as EPCRA Section 313 chemicals (see Fume and
Dust qualifier discussion in Section 3.1).
4-34
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EPCRA Section 313 chemicals and chemical categories could be released in the
form of fugitive dust from any leaks in the cleaning enclosure or as a stack release from an air
pollution control system, if present. Filters for the dust and the waste abrasive material may also
contain EPCRA Section 313 chemicals and chemical categories and their disposal should be
considered.
Step 3: Identify Releases and Other Waste Management Activity Types
The primary source of release is the cleaning unit itself. Release types include
fugitive emissions to the air from leaks and fittings in the cleaning enclosure and point source
emissions from air pollution control devices. Abrasive cleaning does not generally use volatile
chemicals or chemical categories; therefore, the primary air releases are expected to be in the form
of dust particulates. This dust may be collected in a baghouse or fabric filters. If so, the
disposition of EPCRA Section 313 chemicals and chemical categories in the dust should be
considered in your calculations (for example, the dust could be sent to landfills or other off-site
waste management activities). The dust may also be recycled. The waste abrasive material from
floor sweepings containing the dust can be land filled or otherwise disposed, on or off site. The
abrasive material can also be recycled, after removal and disposal of the dust component. Typical
release and other waste management activities and typical EPCRA Section 313 chemicals and
chemical categories are:
Typical Type of Release/Waste
Management Activity
Stack Air
Fugitive Air
Disposal to land or recycling
Typical EPCRA Section 313 Chemicals and
Chemical Categories
Lead, zinc dust, chromium, and nickel
Lead, zinc dust, chromium, and nickel
Lead, zinc dust, chromium, and nickel
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Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
If the dust and waste abrasive materials are managed as a hazardous waste,
analytical data should be available in hazardous waste manifests for estimating concentrations of
EPCRA Section 313 chemicals or chemical categories and the weight of waste disposed.
Additionally, efficiencies of treatment systems can be used to estimate stack and fugitive releases.
Example - Abrasive Surface Preparation
An earth-moving equipment manufacturer uses air blasting with a steel pellet abrasive to remove rust and old paint
from refurbished equipment before it is repainted. The removed material separates by particle size with 10%
dropping to the floor to be swept up, and 90% going to the bag filter dust collection system. According to the
manufacturer, the bag filters have a 95% capture efficiency. The dust collection bags are replaced when the pressure
drop across them reaches a designated amount. They are then removed from service and sent to an off-site landfill.
Over a period of time it has been determined the average dust collection bag has a net weight gain of 50 pounds at the
time when the pressure drop reaches the replacement level. The facility replaces the bags 25 times per year, with 5
bags replaced each time. Periodic chemical analysis of the captured dust has shown it contains 1.1% chromium.
Example 1: Off-Site Disposal of Collected Dust
Assuming the EPCRA Section 313 reporting threshold for chromium has been reached at the facility, the amount of
chromium in the bags as collected dust that is disposed off site can be calculated as follows.
Total weight of collected dust = (25 times/year) x (5 bags) x (50 Ib/bag)
= 6,250 Ib/year
Chromium content of collected dust = (1.1%) x (6,250) = 69 Ib/year.
This amount is only a portion of the chromium dust generated during the abrasive cleaning operation. Similar
calculations should be made for the amounts of chromium in the floor sweepings, stack releases, and the fugitive dust
releases.
Example 2: Stack Releases
Assuming 95% of the dust sent to the air pollution control device (APCD) is captured in the bag filters, the remaining
5% passes through the bags and is emitted as a stack release. The quantity can be estimated as follows:
Total weight of collected dust = 6,250 Ib/year (calculated above)
Total quantity of dust into APCD = (6,250 Ib/year) - (95%)
= 6,580 Ib/year
Dust escaping APCD (stack release) = (Total into APCD) - (Total Collected)
= 6,580 - 6,250 Ib/yr
= 330 Ib/yr
Chromium escaping as a stack release =(1.1%) x (330)
= 3.6 Ib/yr
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4.2.1.2 Cleaning /Degreasing
After abrasive cleaning, many facilities perform a cleaning/degreasing step. Note
that some facilities that perform abrasive cleaning often degrease the workpiece first to minimize
the contamination of the abrasive media. Cleaners generally fall into three chemical categories,
each of which may contain EPCRA Section 313 chemicals or chemical categories: organic
solvents, semiaqueous or emulsion cleaners, and aqueous-based products. Aqueous cleaning may
involve one or more of the following mechanisms: wetting, emulsification, neutralization,
solubilization, displacement, mechanical action, sequestration, and deflocculation.
Most work pieces are cleaned by immersing the object in a tank of degreasing
solution or spraying the piece with the degreasing solution. In some instances cleaning may
consist of wiping the work piece with a solution soaked rag. EPCRA Section 313 chemicals and
chemical categories contained in cleaning solutions should be considered otherwise used, and are
subject to the 10,000-pound reporting threshold.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-5.
Cleaning Evaporation
Solution Losses
1 I
Cleaned Workpiece
Workpiece to
be Cleaned
V
Cleaning/Degreasing
i
Vastewater
Slurry
Container
Residues
Figure 4-5. Process Flow Diagram - Cleaning/Degreasing
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Typical sources of EPCRA Section 313 chemical and chemical category releases
would be cleaning tank slurries, wastewater from spent cleaning solutions, evaporation of volatile
cleaning components, and container residues (from "empty" containers of the cleaning solution).
Other sources could be accidental spills and periodic dumping of entire tank contents.
Step 3: Identify Release and Other Waste Management Activity Types
Release and other waste management activity types from this process include
fugitive emissions from evaporation of volatile cleaning compounds; releases to land or off-site
transfer of the slurries for disposal; wastewater discharges (either direct or to a POTW); and
transfers of "empty" shipping containers to off-site locations. Typical release and other waste
management activities and the types of chemicals and chemical categories involved during the
cleaning/degreasing process are:
Typical Type of Release/Waste
Management Activity
Fugitive Air
Receiving stream or POTW
Disposal to land or recycling
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Glycol ethers, toluene, xylene, MEK, MIBK
Manganese, nickel, lead, zinc dust, and chromium
Manganese, nickel, lead, zinc dust, and chromium
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Fugitive emissions from evaporative losses can be estimated using engineering
calculations and mass balances based on purchasing records. Slurry disposal can be estimated
based on the waste manifests.
4-38
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Wastewater volumes are normally metered or may be estimated based on make-up
quantities required. Wastewater concentrations of EPCRA Section 313 chemicals or chemical
categories may already be monitored for compliance with discharge or pretreatment permit
requirements. Flow and concentration data can be used to determine the amount of the EPCRA
Section 313 chemical or chemical category managed in this fashion (see example (6) "NPDES
Data" in Appendix B). Treatment of the wastewater may result in the generation of a sludge.
Biodegradation of any organic chemicals in the sludge may occur. If the amount biodegraded is
known, it should be estimated and included in Part II, Section 8.6 (On-Site Treatment) of the
1997 Form R. To avoid double counting, it should be subtracted from the total amount sent into
the treatment system before the ultimate discharge is reported. The water soluble EPCRA
Section 313 chemicals or chemical categories discharged with the slurries can be estimated using
the water solubility of the chemical or chemical category and the water content of the slurry.
4-39
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Example - Cleaning/Degreasing (Estimating Fugitive Emissions)
For this cleaning process, assume you are using a 1,200-gallon tank with a surface area of 28 sq ft containing a
mixture of not less than 20% MEK, 30 to 40% toluene (by volume), from 5 to 15% proprietary chemicals (identified
by the supplier on the MSDS as not EPCRA Section 313 chemicals), and water. The mixture is purchased ready to
use in 55-gallon drums. The mixture in the tank is at room temperature (70 F) and is agitated with a sonic device.
The tank is equipped with a slot exhaust system as an engineering control to reduce operator exposure to solvent
vapors. Industrial hygiene evaluations have shown it to be 50% effective, i.e., it captures 50% of the volatilized
vapors. The remaining 50% escapes into the general room air. The captured 50% is routed to an air pollution
control device designed to remove 95% of the volatile organic compounds (VOCs) from the air stream.
The part to be cleaned is immersed in the tank for one to two minutes, removed from the liquid and allowed to drip
drain below the level of the slot exhaust system for about another minute above the tank. An average of 50 gallons
per week of the mixture are added to the tank to replace evaporative losses and drag-out. The slurry which builds up
in the tank, has been analyzed and found to contain an average of 2% nickel, 5% chromium, 0.05% lead, 1% zinc,
and 5% manganese on dry weight basis. An average of one 55-gallon drum of the slurry is collected and shipped off
site to a RCRA landfill every month. The slurry is 50% water and 50% solids.
The amount of toluene released as fugitive emissions from this operation can be estimated as follows:
The relevant data are the amount of toluene lost from the tank and the amount not captured by the industrial hygiene
control system. An average of 50 gallons per week of the mixture, containing 30 to 40% toluene by volume, is
consumed. Toluene is a very volatile chemical and it is assumed that all losses are in the vapor form.
Amount of toluene evaporated
= (50 gal/week) x (0.35; mid-point of toluene concentration) x (7.28 Ib/gal; density of toluene) x (52 weeks/year)
= 6,625 Ib/year
Amount of toluene not captured by slot exhaust ventilation and released as fugitive emissions
= (50%; capture efficiency) x (6,625 Ib/year)
= 3,3131b/year
This amount is the fugitive emissions of toluene; you must also determine fugitive emissions of MEK and point
source emissions of both toluene and MEK, as well as the amounts of EPCRA Section 313 chemicals and chemical
categories in the slurry and any container residues. In every case, you should determine whether the EPCRA Section
313 reporting threshold has been reached for the individual chemical or chemical category before undertaking any
release or other waste management quantity estimation calculations.
Quantities of EPCRA Section 313 chemicals or chemical categories in "empty"
container residues subject to waste management can be estimated using established residue factors
based on the method of cleaning or draining of the container (see Table 4-1 and the corresponding
container residue example).
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4.2.1.3
Rinsing
Normally, a rinse step follows every chemical pretreatment step and the
electrodeposition application step to remove any solution that does not adhere to a surface.
Rinsing can be performed in a single tank or as a multi-step, counter-current, or co-current flow
process. In some multiple tank rinse processes, the first tank contains tap water and subsequent
tanks contain deionized water. The spent rinsate may contain EPCRA Section 313 chemicals or
chemical categories which should be considered otherwise used and are subject to the 10,000-
pound reporting threshold.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-6.
Evaporative
Evaporative
Losses ,
Workpiece -
Wastewater
jporative Losses i
osses Rinse Water t Rinse Water
t
1st Rinse
Stage
I V
2nd Rinse
Stage
nes
Rinse V
1
3rd Rinse
Stage
• Workpiece
Slurry
Slurry
Workpiece Flow
Rinse Water Flow
Figure 4-6. Process Flow Diagram - Rinsing (counter-current)
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The rinsing process typically contains the same sources for release and other waste
management activities as the cleaning/degreasing operations, except for the container residues.
Potential losses are expected to have a much lower concentration of EPCRA Section 313
chemicals or chemical categories since they are diluted by the water in the rinse bath.
Step 3: Identify Release and Other Waste Management Activity Types
Release and other waste management activities from this process, of chemicals or
chemical categories carried over on the workpiece, include fugitive air from evaporation of
volatile cleaning compounds, releases to land or off-site transfer of the slurries, and wastewater
discharges (either direct or to a POTW). Typical release and other waste management activities
and the types of EPCRA Section 313 chemicals or chemical categories involved during the rinsing
process are:
Typical Type of Release/Waste
Management Activity
Fugitive Air
Receiving stream or POTW
Land or off-site disposal of slurries
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Xylene, MEK, MIBK, toluene, glycol ethers
Lead, manganese, zinc dust, nickel,
chromium, and glycol ethers
Lead, manganese, zinc dust, nickel,
chromium, and glycol ethers
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Evaporative losses can be estimated using engineering calculations and mass
balances based on purchasing records. Slurry disposal can be estimated based on waste manifests.
4-42
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Wastewater volumes are normally metered or may be estimated based on make-up
quantities required. Wastewater concentrations of EPCRA Section 313 chemicals and chemical
categories may already be monitored in compliance with discharge or pretreatment permit
requirements. Flow and concentration data can be used to determine the amount of the EPCRA
Section 313 chemical or chemical category managed in this fashion (see Appendix B). See Step 4
of Cleaning/Degreasing (paragraph 4.2.1.2) for discussion on sludge generation in wastewater
treatment.
Example - Rinsing (Estimating Aqueous Discharges)
In this example, the annual amount of manganese sent to an on-site wastewater treatment plant from a rinsing
operation is estimated.
An automobile manufacturer has a two-step counter-current flow water rinsing operation following the chromate
rinse in the phosphating process.
Deionized water flows continuously into the final rinse tank, with the overflow going to the first stage rinse tank. The
overflow from this tank is collected and sent to the facility wastewater treatment plant. It is monitored for flow rate,
pH, and concentrations of Ni, Cr, Zn, and Mn. Based on a year of monitoring data, the flow rate averages 15,000
gal/day, the pH ranges from 6.5 to 8.5, the Ni concentration averages 50 mg/L, Cr averages 25 mg/L, Zn averages
100 mg/L, and Mn averages 75 mg/L. The facility operates 350 days/year (the entire plant shuts down for two weeks
in July).
The amount of Mn sent to the treatment plant =
(15,000 gal/day) x (350 days/year) x (75 mg/L) x (3.78 L/gal) x (2.2 Ib/kg) x (10E-6 kg/mg)
= 3,275 Ib/year
Similar calculations must also be performed for the other EPCRA Section 313 chemicals and chemical categories
that have met a reporting threshold.
4.2.1.4 Phosphating
To promote better paint bonding, the cleaned workpiece may require some
pretreatment before the coating application. For steel-based work, a phosphate coating may be
applied to the workpiece prior to the organic coating to improve corrosion resistance and organic
coating adhesion. Phosphate coatings consist of crystalline salts of the metal being treated, e.g.,
iron, and/or crystalline salts of metals, e.g., manganese or zinc, which have been added to the
phosphating solution. When the metal workpiece comes in contact with the phosphating solution,
pickling occurs, which results in a reduction of acid concentration at the liquid-metal
4-43
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interface. At this point, iron is dissolved, hydrogen is evolved, and the phosphate coating is
deposited. Should the solution contain additional metals, such as manganese or zinc, phosphate
coatings of these ions are also deposited (Ref: Guss, B., "Iron Phosphating"; Metal Finishing:
Organic Finishing Guidebook and Directory Issue., 1996 Edition, page 63). A final rinse
containing chromates, such as a mixture of hexavalent and trivalent chromium, provides the
highest level of corrosion resistance (Ref: Gorecki, G., "Function of Final (Seal) Rinses in a
Phosphating Operation"; Metal Finishing: Organic Finishing Guidebook and Directory Issue,
1996 Edition, page 109).
All phosphate coatings are produced by the same chemical reaction: the acid bath,
containing the coating chemicals, reacts with the metal to be coated, and at the interface, a thin
film of solution is neutralized because of its attack on the metal. Iron phosphate coatings, the
most common in the industry, are usually derived from solutions that contain very little iron.
They are produced on ferrous metals through the combined use of acid phosphate salts, free
phosphoric acid, and accelerators. Many auto manufacturers use phosphate coatings containing
manganese, zinc, and nickel. EPCRA Section 313 chemicals or chemical categories used in
phosphate coating operations are considered processed and are therefore subject to the 25,000-
pound reporting threshold. Where manganese, nickel, or zinc coatings are applied to the
workpiece, the creation of compounds of these metals is considered coincidental manufacturing
and is subject to the 25,000-pound reporting threshold.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-7.
4-44
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Workpiece to
be Treated
Phospf
Acce
D
C
R
noric Acid
lerators
Evaporative
Losses
Phosphating
^
ont
esi
I
Slurry
r
ainer
dues
Waste
r
swater
Treated Workpiece
Figure 4-7. Process Flow Diagram - Phosphating
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The phosphate coating process may generate metal compounds in the coatings,
phosphating tank slurries, wastewater from used phosphating and chrome rinse solutions.
Potential sources of these and other EPCRA Section 313 chemicals and chemical categories are
evaporation of volatile components, container residues, and accidental spills and releases.
Step 3: Identify Release and Other Waste Management Activity Types
Types of release and other waste management activities may include fugitive air
emissions from evaporation of volatile compounds, releases to land from the slurries, wastewater
discharges (either direct or to a POTW), and transfers to off-site locations for management of
"empty" containers. Typical release and other waste management activities and the types of
EPCRA Section 313 chemicals and chemical categories involved during the phosphate coating
process are:
4-45
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Typical Type of Release/Waste
Management Activity
Fugitive Air
Receiving stream or POTW
Land or off-site disposal of slurries
Off-site management of container
residue (energy recovery, recycle,
treatment, or disposal as appropriate)
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Potentially could include some metals (Mn,
Zn dust, Ni)
Phosphoric acid, Cr, Mn, Ni, and metal
compounds
Phosphoric acid, Cr, Mn, Ni, and metal
compounds
Applicable chemicals purchased in
containers
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
The quantity of manganese, nickel, and/or zinc compounds manufactured in the
phosphating operation can be estimated based on the surface area being treated and the design
phosphate coating thickness. Keep in mind that it is the weight of the metal compound that must
be used to determine the activity threshold quantity, while it is only the weight of the parent metal
that is used in calculating release and other waste management activity amounts.
Due to similarities in this tank based operation to those of the rinsing step, release
and other waste management activity quantities related to evaporative losses and slurry and
wastewater generation can be evaluated as described in Step 4 of the Rinsing Operation
discussion, paragraph 4.2.1.3.
Quantities of EPCRA Section 313 chemicals or chemical categories in "empty"
container residues subject to waste management can be estimated using established residue factors
based on the method of cleaning or draining of the container (see Table 4-1 and the corresponding
container residue example).
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Example - Phosphating (Wastewater Discharges)
In this example, the amount of nickel discharged to a POT W is estimated.
An automobile manufacturer applies a phosphate coating by immersing the part in a solution containing nickel
phosphate.
The phosphate solution is continuously replenished through a pipe and spent solution is removed from an overflow
weir. The spent solution is neutralized to a pH between 6 and 9 and the Ni concentration is monitored (to comply
with a POTW pre-treatment permit) and known to average 500 mg/L. The wastewater volume averages 10,000
gallons per month. The amount of Ni to be reported as otherwise waste managed and discharged to the POTW from
this operation is:
(10,000 gal/month) x (12 months/year) x (3.78 L/gal) x (500 mg/L) x
(2.2 Ib/kg) x (10E-6 kg/mg)
= 500 Ib Ni
This quantity should be reported in Sections 6.1 and 8.1 of the Form R. Since the mineral acid is treated to a pH
between 6 and 9, the amount of phosphoric acid reported as discharged to a POTW (Section 6.1) should be zero.
A similar concentration and volume calculation can be performed for any discharges from the chromate final rinse, if
applicable.
4.2.2 Spray Application
Spray application of organic coatings is usually conducted in a mechanically
ventilated enclosure known as a spray booth. The primary purposes of the ventilation are the
protection of the worker from exposure to the chemicals in the paint and minimization of the air
emissions from the operation. The air movement also serves to speed the drying of the paint
through removal of the volatilized components. The two major types of spray booths are cross
draft and down draft. In the cross draft booth the air moves from behind the operator toward the
filter (dry or water curtain), parallel to the floor. In the down draft booth, the air moves from the
ceiling vertically downward toward the exhaust plenum in the floor. A combination, called the
semi-down draft, moves the air in a diagonal direction. Air movement can be from the ceiling in
the front of the booth toward the floor at the back. The air can also come from the center of the
ceiling and move toward exhaust plenums along the side walls of the booth. The choice of the
type of booth is generally driven by the type of workpieces to be painted.
The air flow is normally directed toward either a water curtain or a dry filter for
the removal of overspray paint particles and other paniculate contaminants. Overspray is the
amount of sprayed paint which does not adhere to the workpiece. It is discussed in more detail in
4-47
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Step 4 of this section. Volatile chemicals may be released as fugitive emissions into the general
workplace or captured and channeled through an air pollution control system as stack emissions.
Typically, all of the paint solvent (carrier fluid) in spray painting operations can be considered
potential emissions. The percentage of VOC emissions during the application/flash-off step
ranges from 70 to 90%, depending on the industry, with the remainder emitted in the curing stage
(Ref: Air & Waste Management Association, Air Pollution Engineering Manual, (AP-40), 1992,
page 365). As discussed earlier, while flash-off and curing are separate processes, they are
considered together in Section 4.2.4.
EPCRA Section 313 chemicals and chemical categories may be processed (e.g.,
paint pigments that remain on the workpiece) or otherwise used (e.g., carrier solvents that
evaporate) during spray application. They would therefore be subject to the 25,000-pound
processing activity threshold or the 10,000-pound otherwise use activity threshold, respectively.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-8.
Formulation Fugitive Air
and Solvents
From
Surface WorkPiece >
Preparation/
Special Treatment
Spray Booth
Water Curtain
(or Dry Filter)
Filtrate
Disposal
Slurry Pit
(if a water curtain is used)
-Stack Air
Coated
Workpiece
Air Pollution
Control Device
-To Curing
• Used Dry Filters (if applicable)
Water
-> Treatment or POTW
Figure 4-8. Process Flow Diagram - Spray Application
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Typical sources of EPCRA Section 313 chemicals and chemical categories would
include evaporation of volatile paint components, slurries and wastewater from water curtain
operation, chemicals captured in filters, and container residues. The cleaning of process
equipment may also generate waste solutions containing contaminated solvents and paint solids,
such as scrapings.
Step 3: Identify Release and Other Waste Management Activity Types
Typical types of EPCRA Section 313 chemical and chemical category release and
other waste management activities would include fugitive and/or stack air releases from the spray
operation. Water curtain wastewater could be treated on site or sent to a POTW. Water curtain
slurries, dry filter elements and container residues can be managed on site or sent off site. It
should be noted that the chemical systems are different for water-based versus solvent-based
points. Typical release and other waste management activities and the EPCRA Section 313
chemicals and chemical categories involved are:
Typical Type of Release/Waste
Management Activity
Fugitive Air
Stack Air
Receiving stream or POTW
Landfill or off-site disposal of slurries
and dry filters and solids from process
equipment cleaning
Off-site management of container
residue (energy recovery, recycle,
treatment, or disposal as appropriate)
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Methyl ethyl ketone, xylene, toluene
Methyl ethyl ketone, xylene, toluene
Zinc and chromium compounds
Zinc and chromium compounds
Applicable chemicals purchased in
containers
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Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Air releases can be estimated using control technology efficiencies, engineering
calculations, and published overspray efficiency values (see Example - Spray Application, page
4-53).
The percent overspray is the ratio of the coating solids not deposited to the coating
solids used. It is a function of the spraying method and the shape and complexity of the
workpiece surface. Table 4-4 presents typical overspray percentages for various spraying
methods and workpiece configurations.
Table 4-4
Estimated Percentage of Overspray Resulting from Listed Spray Methods
Spraying Method
Air Atomized
Airless
Electrostatic
• Disc
• Airless
• Air atomized
Estimated Percentage of Overspray
Flat Surfaces
50
20-25
5
20
25
Table Leg Surfaces
85
90
5-10
30
35
Bird Cage Surface
90
90
5-10
30
35
(Ref: Salman, David; Transfer Efficiency and Regulatory Guidance for Spray Coating Operations: presented at the
National Air Pollution Control Technology Advisory Committee. November 19-21,1991.
Several other factors also play a role in the transfer efficiency:
The skill, technique and fatigue level of the operator;
The wear level and maintenance history of the spray equipment;
The paint being sprayed and its amenability to spraying;
Operating parameters such as spray booth ventilation rate, spray gun to
workpiece distance, and the spacing of the parts on the conveyor (if used);
and
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• For automated spray applications, process control parameters such as
whether spray is continuous or shut off between parts, must also be
considered.
The data presented in Table 4-4 can be used in conjunction with engineering
judgment to estimate release and other waste management activity quantities from spray
application operations. The data in the table can be used as a reasonable starting point and be
modified based on operational experience at your facility.
Water releases can be estimated using monitoring data and water flow rates. This
information should be available whether the wastewater is discharged to an off-site treatment
facility or is treated in an on-site wastewater treatment plant. In most cases an off-site facility
receiving the wastewater will require monitoring data to determine treatment fees and/or to verify
permit compliance. Influent concentration data is typically available for operational control
monitoring of an on-site wastewater treatment system. If a water curtain is used in the spray
booth, the manufacturer's collection efficiency data can be used for particulate removal, if actual
operating performance data is not available. If neither is available, you can assume a 95%
particulate removal efficiency as water curtains generally achieve at least 95% control of
particulates. (Ref: Whitall, K.L., "Air Pollution Control in the Finishing Industry"; Metal
Finishing: Organic Finishing Guidebook and Directory Issue; 1996 Edition, p. 342-351.)
Quantities of EPCRA Section 313 chemicals and chemical categories in "empty"
containers subject to waste management, can be estimated using established container residue
factors based on the container construction and method of cleaning or draining (see Table 4-1 and
the corresponding container residue example).
EPCRA Section 313 chemicals and chemical categories in the sludge generated in
the treatment of wastewater from the water curtain can be estimated based on analytical data, if
available, or can be estimated as the difference between the solids in the overspray and the amount
carried over in the wastewater. Organic chemicals in the sludge may undergo biodegradation. If
applicable, this biodegraded quantity should be considered in the quantity treated on site and
should be subtracted from the total amount before the ultimate discharge is reported.
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Another potential source of solid waste containing EPCRA Section 313 chemicals
and chemical categories is spent filters from the spray booth itself and from the air pollution
control system. Collection efficiencies for several types of dry filters are shown in Table 4-5.
These values can be used in the absence of actual operating data from your facility.
Table 4-5
Collection Efficiencies for Dry Particulate Collection Filters
Description
Standard filter
High-capacity filter
High-efficiency filter
Efficiency (%)
High Solids Baking Enamel
Average Efficiency Range
96.5-97.5
94.0 - 96.0
98.5-99.5
Water-Borne Baking Enamel
Average Efficiency Range
93.0-94.0
91.5-92.5
97.0 - 98.0
(Ref: U.S. EPA, Pollution Prevention in the Paint and Coatings Industry, EPA 625-R-96-003, September 1996, Office
of Research and Development.)
Filters and the collected particulates may be discarded as solid wastes or the filters
may be washed and the particulates transferred to a water stream. Be sure to account for the
actual management of the EPCRA Section 313 chemicals and chemical categories in the correct
section of the Form R.
The cleaning of process equipment, including the interior surfaces of the paint
booth, can also generate solid wastes in the form of scrapings, coatings, etc. This can be
estimated by weighing the waste material and applying concentration factors from the paint
composition to determine the EPCRA Section 313 chemical and chemical category amounts.
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Example - Spray Application
This example focuses on estimating the release amounts of one volatile EPCRA Section 313 chemical, xylene, in the
solvent/carrier fluid in the spray application of a paint. Keep in mind the paint may contain several other volatile and
non-volatile EPCRA Section 313 chemicals and chemical categories in the pigment or other paint components.
These chemicals and chemical categories must also be considered in any threshold determinations and release and
other waste management quantity estimations.
A spray painting operation in a facility manufacturing large appliances, SIC Industry group 363, uses 500
gallons/week of a paint containing 70% o-xylene, by volume, as the carrier fluid. o-Xylene is volatile and is not
expected to remain with the workpiece. 100% of the paint solvent in a spray application operation can be considered
potential air emissions, with approximately 80% generated in the application/flash-off and 20% in the curing oven.
o-Xylene is essentially insoluble and the amount volatilized in the spray booth would be either removed by the booth
exhaust fan or become fugitive emissions from the booth into the general room air. In this example, the booth
manufacturer estimates the exhaust fan will capture 95% of the amount released in the booth. The booth exhaust is
routed to an air pollution control incineration device, which has a measured efficiency of 99% for VOC control.
Treated on Site
The following calculation estimates the amount of o-xylene (density = 7.36 Ib/gal) volatilized from this operation and
treated by the air pollution control incinerator (for reporting in Part II, Section 8.6 of the 1997 Form R, "Quantity
Treated On-Site"):
Quantity of o-xylene used = (500 gal/week) x (52 weeks/year) x (70%; o-xylene content) x
(7.36 Ib/gal; density of o-xylene)
= 134,000 Ib/year
Quantity of o-xylene treated by incinerator
= (134,000 Ib/year) x (80%; volatilized in application/flash-off) x (95%;
captured and sent to incinerator) x (99%; incinerator efficiency)
= 100,800 Ib
Stack Air Release
The quantity released from the air pollution control device (for reporting in Part II, Section 5.2 and included in Part
II, Section 8.1) can be calculated as follows:
Quantity of o-xylene used = 134,000 Ib/yr (calculated above)
Quantity of o-xylene emitted from incinerator
= (134,000 Ib/yr) x (80%; volatilized in application) x (95%; captured) x (1%;
not destroyed by incinerator)
= l,0201b
[continued on next page]
4-53
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Fugitive Release
The quantity released as fugitive air emission (for reporting in Part II, Section 5.1 and included in Part II, Section 8.1)
can be calculated as follows:
Total quantity of fugitive emissions
= (fugitive emission of o-xylene from application/flash off) + (fugitive emission
of o-xylene from curing)
Quantity of o-xylene fugitive emissions from application/flash off
= (134,000 Ib/yr) x (80%; volatilized in application ) x (5%; not captured by
exhaust fan)
= 5,360 Ib
Quantity of o-xylene fugitive emissions from curing
= (134,000 Ib/yr) x (20%; volatilized in cunng)
= 26,800 Ib
Total quantity of o-xylene fugitive emissions
= 5,360 Ib + 26,800 Ib
= 32,1601b
4.2.3 Electrodeposition
In the electrodeposition (EDP) process, the electrically charged (usually
negatively) workpiece is immersed into a dip tank where paint particles carrying the opposite
charge are attracted to the workpiece and form the desired coating. A typical EDP bath consists
of 80-90% deionized water and 10-20% paint components, resins, pigments, and small amounts
of solvents (Ref: Oravitz, J. J., "Electrocoating"; Metal Finishing: Organic Finishing Guidebook
and Directory Issue, May 1996, pages 203-207). The workpiece immersion time ranges from
seconds up to 3 minutes for large pieces. The intimate contact between workpiece and paint and
the recycling of paint particles from the rinse waters, result in very high transfer efficiencies of
coating solids to the workpiece. If actual data are not available, 95% efficiency can be assumed
(Ref: Air & Waste Management Association, Air Pollution Engineering Manual, (AP-40), 1992,
page 362).
The workpiece is removed from the bath and rinsed several times to remove excess
paint. The rinsate is returned to the bath to conserve undeposited paint. It is necessary to purge
the system of the excess water from the rinses. This is accomplished through the use of an
ultrafiltration system in which semipermeable membranes selectively allow low molecular weight
chemicals such as water, and dissolved substances such as solvents, solubilizers, and salts
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(impurities), to emerge from the system as the filtrate, while retaining the paint pigments and
additives. The retained pigments and additives are referred to as the reject stream and this is
returned to the EDP tank. Although each plant uses a unique rinse process, it is typical to use the
filtrate from the ultrafiltration system as one of the rinses. Sometimes it is used for the first rinse
after the part leaves the tank and the water and rinsed paint are returned to the EDP tank
immediately. Other arrangements may allow for the filtrate to run counter-current to the
emerging part allowing the final rinses to be performed by the most pure filtrate. A three-stage
rinse system recovers approximately 85% of the paint solids in the drag out (liquid which clings to
the workpiece but is not deposited electrically). (Ref: Brower, G.E.F., "Electrodeposition of
Organic Coatings"; Metal Finishing: Special Organic Finishing Guidebook and Industry Issue;
1993 Edition, pp. 112-118.) Because some chemical contaminants such as chloride ions,
phosphates, chromates and amine solubilizer, build up in the system, a portion, typically around
10%, of the ultrafiltrate is "bled" (diverted) to a waste stream.
In the EDP process EPCRA Section 313 chemicals and chemical categories may
be processed (e.g., paint pigments that remain on the workpiece) or otherwise used (e.g., solvents
that evaporate). These EPCRA Section 313 chemicals and chemical categories would therefore
be subject to the 25,000-pound processing activity threshold or the 10,000-pounds otherwise use
activity threshold, respectively.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-9.
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Fugitive Air
Formulations
From
Surface
Preparation/
Special Treatment
Workpiece
Make-up
Recycled Coating/Water Water
Electrodeposition
Dip Tank
Ultrafilter
Coated
Workpiece
Ultrafiltrate
*• Treatment or POTW
Figure 4-9. Process Flow Diagram - Electrodeposition
Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
Typical sources of EPCRA Section 313 chemicals and chemical categories would
include wastewater from ultrafiltration operation, evaporation of volatile paint components, and
container residues. The cleaning of process equipment may also generate contaminated solvents
and paint solids.
Step 3: Identify Release and Other Waste Management Activity Types
The primary release and other waste management activity types are wastewater
discharges, either direct to a receiving stream or indirect to a POTW. Note that EPCRA Section
313 chemicals and chemical categories sent to a POTW are considered to be treated off site,
except for metals which are not treated but are ultimately disposed. Thus, any EPCRA Section
313 metals sent to a POTW are considered to be released and should be reported in Sections 6.1
and 8.1. Other types of releases could include minimal fugitive air releases from evaporation of
volatile compounds. Other release and other waste management activities could also include
releases to land for the slurries and transfers to off-site locations from management of "empty"
shipping containers. Typical release and other waste management activities and the EPCRA
Section 313 chemicals and chemical categories involved are:
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Typical Type of Release/Waste
Management Activity
Fugitive Air
Off-site management of container
residue and slurries (energy recovery,
recycle, treatment, or disposal, as
appropriate)
Receiving stream or POTW
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Glycol ethers
Applicable chemicals purchased in
containers and zinc and chromium
compounds
Zinc and chromium compounds
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Air releases of EPCRA Section 313 chemicals and chemical categories from EDP
processes are expected to be very minimal. They can be estimated from purchasing records
combined with the use of engineering estimations based on volatility and surface area of the EDP
tank or a mass balance around the system.
EPCRA Section 313 chemicals and chemical categories in wastewater can be
estimated using monitoring data and water flow rates. This information should be available
whether the wastewater is discharged to an off-site treatment facility or is treated in an on-site
wastewater treatment plant. In most cases an off-site facility receiving the wastewater will require
monitoring data to determine treatment fees and/or to verify permit compliance. Influent
concentration data are typically available for operational control monitoring of an on-site
wastewater treatment system.
The wastewater from the ultrafiltration unit can be expected to contain the soluble
paint components and a certain amount of the insoluble components. For the water soluble
components you can use the solubility of the EPCRA Section 313 chemical or chemical category
multiplied by the amount of wastewater discharged to estimate the total chemical discharge (see
example (6) "NPDES Data" in Appendix B).
Quantities of EPCRA Section 313 chemicals and chemical categories in "empty"
containers subject to waste management, can be estimated using established container residue
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factors based on the container construction and method of cleaning or draining (see Table 4-1 and
the corresponding container residue example).
Example - Electrodeposition
Note that several EPCRA Section 313 chemicals and chemical categories may be involved in this EDP process.
Each must be accounted for and, if activity thresholds are exceeded the appropriate EPCRA Section 313 reports
prepared. This example focuses on the quantity of lead in the primer paint pigments sent off site for recycling. When
filing an EPCRA Section 313 report for metal compounds it is important to keep in mind that the weight of the metal
compound is used for the threshold determination while the weight of the parent metal is used in the release and other
waste management calculations.
The lead compounds in the paint pigment are processed and are subject to the 25,000 pound per year activity
threshold for reporting. An automobile assembly plant, SIC Code 3711, uses electrodeposition (EDP) to apply
primer coat to the auto frames. The facility uses 250,000 gallons of primer paint during the year. The pigment is
shipped to the facility in 55-gallon bung-top steel drums and has a viscosity and surface tension similar to motor oil.
According to the MSDS, the paint pigment contains 2.5% lead chromate (PbCrO4) and has a density of 9.25 Ib/gal.
The drum contents are poured into the EDP tank and the "empty" drums shipped off site to a drum recycler, where
the pigment residual is collected for recycle.
The frames undergo a surface preparation process consisting of alkaline cleaning, acid etching, and chrome-
phosphate conversion coating. An electric charge is applied to the frame. The frame is submerged in an EDP tank
followed by a three-stage countercurrent flow rinse process. The overflow from the first rinse tank is returned to the
EDP tank. The excess water in the EDP tank is purged by an ultrafiltration unit. The reject stream from the
ultrafilter is returned to the EDP tank. 90% of the filtrate from the ultrafilter is transferred to the first stage rinse tank,
and the remainder is discharged to a POTW. Analysis of the filtrate is conducted frequently and the amount of lead is
found to average 20 mg/L, and the amount of chromium averages 5 mg/L. The volume of wastewater sent to the on-
site treatment plant is 500,000 gallons per year.
The final step for the auto frame is curing in a heated curing oven. The entire system, from surface preparation
through curing, is totally enclosed to prevent dust from contaminating the process.
Threshold Determination
The activity threshold calculation is based on the weight of the metal compound.
(250,000 gal) x (9.25 Ib/gal) x (2.5% lead chromate)
= 57,8131bofPbCr04
This amount exceeds the processing activity threshold (25,000 pounds/year) for lead and chromium compounds and
an EPCRA Section 313 report must be prepared for both lead and chromium compounds.
Release and Other Waste Management Calculations
The release and other waste management calculations are based on the weight of the lead or chromium and not the
amount of the lead or chromium compound.
[continued on next page]
4-58
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Off-Site Recycling (Part II, Section 6.2 and Part II, Section 8.5 of the 1997 Form R)
The amount of lead in the "empty" drums sent to the off-site recycling facility can be estimated using Table 4-1. The
residue of a liquid with motor oil characteristics, in a bung-top steel drum, emptied by pouring, is an average of 0.737
percent.
Based on the molecular weight of lead and lead chromate, the mass of lead per pound of lead chromate is:
= (2071bmoleslead)
(323 Ib moles lead chromate)
= 0.64 Ib of lead/lb of lead chromate
Therefore, the quantity of lead sent to the off-site recycling facility as drum residual is:
= (250,000 gal) x (0.737% residual) x (9.25 Ib lead chromate/gal) x (0.64 Ib lead/lb lead
chromate)
= 11,000 Ib lead
Similarly, the amount of chromium sent to the off-site recycling facility is:
_ (52 poundmoles chromium)
(323 pound moles lead chromate)
= 0.16 Ib of chromium/lb of lead chromate
= (250,000 gal) x (0.737% residual) x (9.25 Ib lead chromate/gal) x (0.16 Ib chromium/lb lead
chromate)
= 2,800 Ib chromium
Discharge to a POTW (Part II, Section 6.1) and Quantity Released (Part II, Section 8.1 of the 1997 Form R)
Metals are not treated in a wastewater treatment system, but are ultimately disposed. Thus, any EPCRA Section 313
metals sent to a POTW must be reported as a release in Section 8.1 and a discharge in Section 6.1.
The amount of lead sent to the POTW =
(500,000gal/yr) x (3.78L/gal) x (20mg/L) x I Li—1 x I JJL
( l,000mgj ( 454g
= 83.41b/yr
The amount of chromium sent to the POTW =
(500,000gal/yr) x (3.78L/gal) x (5mg/L)
Is \ ( lib
1,000mg/ ( 454g/
= 20.8 Ib/yr
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4.2.4 Flash-Off and Curing
Flash-off and curing are typically two physically unique unit operations. However,
for the purposes of EPCRA Section 313 reporting they are very similar. The sources, types, and
release and other waste management activities are identical and these two operations are
combined in this document.
Drying and curing are the last steps in the effort to produce a final coating with
specific chemical and physical properties. A combination of time and temperature is used to drive
off solvents and set the coating. The curing stage in the electrodeposition coating process, where
the solvent is water, would not normally evolve any EPCRA Section 313 chemicals or chemical
categories.
Several options for the process are available. There are air-dry applications, low
temperature cures for woods, plastics and even electrocoated parts, and the more traditional
higher temperatures for solids and powders. The equipment to dry and/or cure the coating
includes infrared, radiant wall, and conventional and high-velocity convection ovens (Ref: Carl,
D., "Design and Operation of Conventional Dyeing and Curing Ovens"; Metal Finishing:
Organics Finishing Guidebook and Directory, May 1996, pages 308-312).
EPCRA Section 313 chemicals and chemical categories in the flash-off and curing
operations, carrier solvents that evaporate, are considered otherwise used. They would therefore
be subject to the 10,000-pound otherwise use threshold.
Step 1: Prepare Process Flow Diagram
A site-specific process flow diagram should be prepared to help identify all
potential sources and types of chemical and chemical category release and other waste
management activities. A typical flow diagram is presented in Figure 4-10.
4-60
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Step 2: Identify EPCRA Section 313 Chemicals and Chemical Categories and Potential
Sources of Chemical Release and Other Waste Management Activities
The evaporation of volatile paint components, predominantly solvents, is a typical
source of EPCRA Section 313 chemicals and chemical categories when spray application of the
organic coating has been used. The potential exists for creation of EPCRA Section 313 chemicals
or chemical categories if an incinerator is used as an air pollution control device for treatment of
these vapors.
Step 3: Identify Release and Other Waste Management Activity Types
The release and other waste management activity types of EPCRA Section 313
Fugitive Air
Coated ^
Workpiece
i
Air
1
L
Stack Air
1
Flash-Off
and Curing
^ Final
Workpiece
T
Heat
Figure 4-10. Process Flow Diagram - Flash-Off and Curing
chemicals and chemical categories from flash-off and curing operations are expected to be almost
exclusively stack and fugitive air emissions. The type of chemical present may depend on the type
of paint used in the coating process. Typical releases and the EPCRA Section 313 chemicals and
chemical categories associated with each are shown in the following table.
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Typical Type of Release
Fugitive Air
Stack Air
Typical EPCRA Section 313 Chemicals
and Chemical Categories
Methyl ethyl ketone, xylene, toluene
Methyl ethyl ketone, xylene, toluene - may
also include some coincidentally
manufactured EPCRA Section 313 chemicals
if an incinerator is used as control equipment
Step 4: Determine the Most Appropriate Method(s) and Calculate the Estimates for
Release and Other Waste Management Activity Quantities
Total air releases can be estimated using a mass balance approach, assuming that
100% of the carrier fluid/solvent entering the flash-off and curing systems will be released during
these two processes.
Once the total air release is determined, engineering judgement based on a
knowledge of your facility should be used to partition the release between fugitive and stack
emissions. Efficiencies of any vapor recovery systems and/or air pollution control devices should
be considered in your calculations for emissions and on-site treatment, as appropriate. Typical
efficiencies for control of bake oven emissions by a thermal incinerator is 96% and by a catalytic
incinerator, 90%, for surface coating operations other than the metal furniture industry. (Ref: Air
& Waste Management Association. Air Pollution Engineer ing Manual, (AP-40), 1992. Page
366.)
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APPENDIX A
EPCRA Section 313 Guidance Resources
-------
Appendix A
EPCRA SECTION 313 GUIDANCE RESOURCES
A.1 EPCRA Section 313 RELATED REFERENCES
40 CFR 372. Toxic Chemical Release Reporting: Community Right-to-Know: Final Rule
See 53 FR 4500, February 16, 1988.
Toxic Chemical Release Inventory Reporting Forms and Instructions for the Current Reporting
Year - See also Automated Toxic Chemical Release Inventory Reporting Software (ATRS) under
Section A.2, Internet Sites.
U.S. EPA publishes this document each year to provide current guidance for preparing the Form
R and Form A reports. This document contains the most up-to-date list of chemicals for which
reports are required. It includes a blank Form R and Form A and provides step-by-step
instructions for completing each report. It also has a list of U.S. EPA regional and state contacts
for EPCRA Section 313 reporting. The current version of this document should always be
consulted in preparing the EPCRA Section 313 report.
Common Synonyms for Chemicals Listed Under EPCRA Section 313 of the Emergency Planning
and Community Right-to-Know Act (EPA 745-R-95-008)
This glossary contains chemical names and their synonyms for substances covered by the
reporting requirements of EPCRA Section 313. The glossary was developed to aid in
determining whether a facility manufactures, processes, or uses a chemical subject to EPCRA
Section 313 reporting.
Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-
Know Act (EPCRA^ and Section 112frt of the Clean Air Act (as amended^ (EPA 740-R-95-001)
List of chemicals covered by EPCRA Sections 302 and 313, CERCLA Hazardous Substances,
and CAA 112(r). The list contains the chemical name, CAS Registry Number, and reporting
requirement(s) to which the chemical is subject.
The Emergency Planning and Community Right-to-Know Act: EPCRA Section 313 Release
Reporting Requirements. August 1995 (EPA 745/K-95-052)
This brochure alerts businesses to their reporting obligations under EPCRA Section 313 and
assists in determining whether their facility is required to report. The brochure contains U.S. EPA
Regional contacts, the list of EPCRA Section 313 toxic chemicals and a description of the
Standard Industrial Classification (SIC) codes subject to EPCRA Section 313.
EPCRA Section 313 Questions and Answers: 1998 Version. (EPA 745-B-97-004).
Executive Order 12856 - Federal Compliance with Right-to-Know Laws and Pollution Prevention
Requirements: Questions and Answers (EPA 745-R-95-011)
This document assists federal facilities in complying with Executive Order 12856. This
information has been compiled by U.S. EPA from questions received from federal facilities. This
document is intended for the exclusive use of federal facilities in complying with Sections 302,
A-l
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303, 304, 311, 312, and 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA) of 1986 and the Pollution Prevention Act of 1990, as directed by the Executive Order.
Supplier Notification Requirements (EPA 560/4-91-006)
This pamphlet assists chemical suppliers who may be subject to the supplier notification
requirements under EPCRA Section 313. The pamphlet explains the supplier notification
requirements, gives examples of situations which require notification, describes the trade secret
provision, and contains a sample notification.
Toxic Chemical Release Inventory - Data Quality Checks to Prevent Common Reporting Errors
on Form R/Form A (EPA 745-R-98-012)
This is a compilation of Notices of Data Change, Significant Error, Noncompliance, or Technical
Error. It provides a listing of common errors found on the Form R reports submitted to U.S.
EPA. It also provides a discussion of the types of errors which result in each of the above
Notices as well as a list of Notice of Technical Error codes and descriptions.
Trade Secrets Rule and Form
See 53 FR 28772, July 29, 1988. This rule implements the trade secrets provision of the EPCRA
(Section 322) and includes a copy of the trade secret substantiation form.
A.2 INFORMATION SOURCES
Most of the materials included as reference in this manual are available from the following
sources:
National Center for Environmental Publications and Information (NCEPI)
P.O. Box 42419
Cincinnati, OH 45242-2419
(800) 490-9198
Fax:(513)489-8695
Internet: http://www.epa.gov/ncepihom/index.html
Emergency Planning and Community Right-to-Know (EPCRA) Information Hotline
U.S. Environmental Protection Agency
(800) 424-9346 or (703) 412-9810 (for the Washington, D.C. metropolitan area)
TDD: (800)553-7672
Internet Sites
TRI homepage: http://www.epa.gov/opptintr/tri
This site contains information on the Toxic Release Inventory and provides links to
a variety of data and documents related to the TRI program.
Automated Toxic Chemical Release Inventory Reporting Software (ATRS):
http://www.epa.gov/opptintr/atrs
This site provides access to the automated EPCRA Section 313 reporting forms
for electronic submittal of required data to U.S. EPA.
A-2
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Air CHIEF CD-ROM
http://www.epa.gov/ttn/chief/airchief.html
This site provides information on the Air CHIEF CD-ROM, contents, ordering
information, system requirements, and sources for additional information.
Clearinghouse for Inventories and Emission Factors (CHIEF):
http://www. epa.gov/ttn/chief/
This site provides access to the latest information and tools for estimating
emissions of air pollutants and performing emission inventories.
Code of Federal Regulations, 40 CFR: http://www.epa.gov/epacfr40
This site was created by U.S. EPA to expand access to Title 40 - Environmental
Protections of the Code of Federal Regulations.
Compilation of Air Pollutant Emission Factors (AP-42):
http://www. epa.gov/ttn/chief/ap42etc. html
This site provides access to files containing guidance for estimating emissions from
specific sources and emission factors.
Federal Register Notice: http://www.epa.gov/EPA-TRI
This site provides access to all Federal Register notices related to the TRI program
from 1994 to current.
Material Safety Data Sheets (MSDSs):
http://msds.pdc. Cornell, edu/issearch/msdssrch. htm
A key word searchable database of 325,000 MSDSs.
TANKS: http://www. epa.gov/ttn/chief/tanks.html
This site contains information on TANKS, a DOS-based computer software
program that computes estimates of VOC emissions from fixed and floating-roof
storage tanks.
WATER8/CHEMDAT8: http://www.epa.gov/ttn/chief/software.htmMwater8
WATERS is an analytical model for estimating compound-specific air emissions
from wastewater collection and treatment systems. CHEMDAT8 is a Lotus 1-2-3
spreadsheet for estimating VOC emissions from TSDF processes.
A-3
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National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Call: (800) 553-6847; (703) 487-4650
Fax:(703) 321-8547
Publication Number PB97-502-587
E-mail: info@ntis.fedworld.gov
A.3 INDUSTRY-SPECIFIC TECHNICAL GUIDANCE DOCUMENTS
In 1988 and 1990, U.S. EPA developed a group of individual guidance documents for industries
or activities in industries who primarily manufacture, process, or otherwise use EPCRA
Section 313 chemicals. See list of industries/activities below. U.S. EPA is currently revising
some of these documents and preparing additional documents. The newer versions will be
available beginning in the Fall of 1998.
Guidance for Chemical Distribution Facilities (Version 1.0). October 7, 1997
Guidance for Coal Mining Facilities (Version 1.0). September 26, 1997
Guidance for Electricity Generating Facilities (Version 1.0). September 15, 1997
Guidance for Metal Mining Facilities (Version 1.0). October 6, 1997
Guidance for Petroleum Bulk Storage Facilities (Version 1.0). September 15, 1997
Guidance for RCRA Subtitle C TSD Facilities and Solvent Recovery Facilities (Version 1.0)
October 6, 1997
Coincidental Manufacture/By-products
Estimating Releases and Waste Treatment Efficiencies
Formulation of Aqueous Solutions
Food Processors
Leather Tanning and Finishing Processes
Metal Fabrication and Electroplating
Monofilament Fiber Manufacture
A-4
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Paper and Paperboard Production
Presswood & Laminated Wood Products Manufacturing
Printing Operations
Roller. Knife, and Gravure Coating Operations
Rubber and Plastics Manufacturing
Semiconductor Manufacture
Smelting Operations
Spray Application and Electrodeposition of Organic Coatings
Textile Dyeing
Welding Operations
Wood Preserving
U.S. EPA, Office of Compliance, published a series of documents in 1995 called Sector
Notebooks. These documents provide information of general interest regarding environmental
issues associated with specific industrial sectors. The Document Control Numbers (DCN) range
from EPA/310-R-95-001 through EPA/310-R-95-018.
A.4 CHEMICAL-SPECIFIC GUIDANCE DOCUMENTS
U.S. EPA has also developed a group of guidance documents specific to individual chemicals and
chemical categories. These are presented below.
Emergency Planning and Community Right-to-Know EPCRA Section 313: Guidance for
Reporting Aqueous Ammonia. July 1995 (EPA 745-R-95-012)
Emergency Planning and Community Right-to-Know EPCRA Section 313: List of Toxic
Chemicals within the Chlorophenols Category. November 1995 (EPA 745-B-95-004)
Estimating Releases for Mineral Acid Discharges Using pH Measurements. U.S. Environmental
Protection Agency. June 1991.
Guidance for Reporting Sulfuric Acid (acid aerosols including mists, vapors, gas, fog, and other
airborne forms of any particle size). November 1997 (EPA-745-R-97-007)
Toxic Release Inventory List of Toxic Chemicals within the Glycol Ethers Category and Guidance
for Reporting. May 1995 (EPA 745-R-95-006)
A-5
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Toxic Release Inventory List of Toxic Chemicals within the Nicotine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-004)
Toxic Release Inventory List of Toxic Chemicals within the Polychlorinated Alkanes Category
and Guidance for Reporting. February 1995 (EPA 745-R-95-001)
Toxic Release Inventory List of Toxic of Chemicals within the Polycyclic Aromatic Compounds
Category. February 1995 (EPA 745-R-95-003)
Toxic Release Inventory List of Toxic Chemicals within the Strychnine and Salts Category and
Guidance for Reporting. February 1995 (EPA 745-R-95-005)
Toxic Release Inventory List of Toxic of Chemicals within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting. May, 1996 (EPA 745-R-96-004)
Toxics Release Inventory - List of Toxic Chemicals Within Ethylenebisdithiocarbamic Acid
Category. November 1994, EPA 745-B-94-003.
Toxics Release Inventory - Copper Phthalocyanine Compounds Excluded for the Reporting
Requirements Under the Copper Compounds Category on the EPCRA Section 313 List. April
1995, EPA 745-R-95-007.
Toxics Release Inventory - List of Toxic Chemicals Within Warfarin Category. November 1994,
EPA 745-B-94-004.
A.5 OTHER USEFUL REFERENCES
Air & Waste Management Association. Air Pollution Engineering Manual. (AP-40). 1992. Van
Nostrand Reinhold, New York.
Burgess, W.A. Recognition of Health Hazards in Industry. Harvard School of Public Health.
Boston, Massachusetts, John-Wiley & Sons.
CRC Handbook of Chemistry and Physics. Latest Edition, Robert C. Weast, Editor, CRC Press,
Inc., Florida.
Locating and Estimating Air Emissions from Various Sources. Available from: National
Technical Information Services (NTIS), (703) 487-4650.
The Merck Index. Latest Edition, Merck & Co., Inc., New Jersey.
Organic Finishing Guidebook and Directory Issue. Latest Edition. Annual issue of Metal
Finishing magazine, Elsevier Science Inc., New York.
Perry, R.H. and C.H. Chilton, Chemical Engineer's Handbook. Latest Edition, McGraw-Hill Book
Company, New York.
A-6
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Salman, David, Transfer Efficiency and Regulatory Guidance for Spray Coating Operations.
Presented at the National Air Pollution Control Technology Advisory Committee. November 19-
21, 1991.
Sax, N.I. and R. J. Lewis, Sr., Hawley's Condensed Chemical Dictionary. Latest Edition, Van
Nostrand Reinhold Company, New York.
U.S. EPA. Pollution Prevention in the Paint and Coatings Industry. EPA 625-R-96-003.
September 1996. Office of Research and Development.
A-7
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APPENDIX B
Basic Calculation Techniques
-------
Appendix B
BASIC CALCULATION TECHNIQUES
This section will provide the basic techniques needed to use specific types of data or engineering
calculations. Examples are provided for:
(1) Stack monitoring data;
(2) Industrial hygiene data;
(3) Raoult's Law;
(4) Air emission factors;
(5) RCRA hazardous waste analysis data;
(6) NPDES monitoring data.
(1) Stack Monitoring Data
The following is an example of a release calculation using monitoring data.
Example: Stack monitoring data are available for a paint booth. The measured
average concentration of toluene is 0.1 ppmv (dry gas basis). The moisture
content in the stack is typically 10%, and stack conditions are maintained at 80°C
and atmospheric pressure. The stack gas velocity is 8 m/s. The diameter of the
stack is 0.3 m. Calculate the point air release of toluene.
Step 1. Calculate volumetric flow of stack gas stream.
Volumetric flow = (gas velocity) x [(TT) x (internal stack diameter)2/4)]
Volumetric flow = (8 m/s) x [(71) x (0.3 m)2/4] = 0.57 m3/s
Step 2. Correct for moisture content in stack gas stream.
Stack exhausts may contain large amounts of water vapor. The concentration of
the chemical in the exhaust is often presented on a dry basis. For an accurate
release rate, correct the vent gas flow rate for the moisture content by multiplying
by the term (1—fraction water vapor). The dry gas rate can then by multiplied by
the chemical concentration.
(Note: If the toluene concentration is on a wet gas basis, no correction is necessary
for moisture content.)
B-l
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Dry volumetric flow = (Volumetric flow) x (1-fraction water vapor)
Dry volumetric flow = (0.57m3/s) x (1-0.10) = 0.51 m3/s
Step 3. Convert ppmv to mg/m3.
• ppmv is defined as one part of a chemical in 106 parts of gas (1.0
m3/106m3).
• Use the molar volume of a gas, corrected for stack temperature and
pressure conditions, calculated by the ideal gas law (PV = nRT). Note that
the molar volume of an ideal gas at 0°C and 760 mmHg is 22.4L/mole.
• Molecular weight of toluene (MW) = 92.14 g/mole.
• R = the Ideal Gas Constant (0.082057 L - atm per mole-Kelvin)
To calculate the molar volume of stack gas, use the ideal gas equation.
A/T 1 1 V RT
Molar volume = — =
For the example, the stack conditions are 80°C (353 K) and atmospheric pressure
(1 atm).
Molar volume = 0.082057 L atm 1 x (353K)/(latm)
mole-KJ
= 29.0 L/mole
The conversion of ppmv to mg/m3 can now be calculated.
B-2
-------
—- = (concentration of chemical, ppmv) x x (MW)
m3 / ^ molar volume of gas)
Using the example, the concentration of toluene is calculated as follows:
0.1 m3"| ( mole \ ( 92.14 g^ ( L \ ( 1,000
I V I I V I O I v I I V I '
x i I x i ° I x i 1 x i ° |= 0.3 mg/m:
106 m3/ I 29.0 LI ( mole I 1Q"3 m3
Step 4. Calculate air releases.
Air releases are calculated as follows:
Air Release=(volumetric flow, m3/s) x (concentration, mg/m3) x (operating time, s/yr)
The paint booth is used 8 hours per day, 5 days per week, 52 weeks per year.
/-v +• +• (o hours \ [.days \ ( .~ weeks \ ~ non , ,
Operating time = 8 x 5—£_ x 52 = 2,080 hr/yr
^ day ) \ weekj ^ year )
A- r> i m«i 'i/\ mi i i\ L 3,600 s\ [ 2,080 hr\ [ Ib
Air Release = (0.51 mj/s) x (0.3 mg/irr) x I -i 1 x I -i 1 x '
hr / ^ yr ( 454 g/ ^ 1,000 mg
= 2.5 Ib/yr of toluene
It is important to note that this calculation assumes the measured emissions are
representative of actual emissions at all times; however, this is not always the case. Ideally, a
continuous emissions monitor provides the most representative data.
Also note that monitoring and stack data may have units that are different than
those used in the example. Modify conversion factors and constants to reflect your data when
calculating air releases.
(2) Industrial Hygiene Data
The following is an example of a release calculation using industrial hygiene data.
Example: Occupational industrial hygiene data shows that workers are exposed
to an average of 0.1 ppmv benzene (wet gas basis). The density of benzene vapor
B-3
-------
is 0.2 lb/ft3. The ventilation system exhausts 20,000 acfm of room air at 70°F.
The plant operates 24 hours per day, 330 days per year.
The benzene concentration is on a wet gas basis, therefore a moisture correction of
the ventilation flow rate is not necessary. The industrial hygiene data is collected
at the same ambient conditions as the ventilation system, therefore no adjustment
for temperature or pressure needs to be performed. A conservative estimation of
benzene fugitive releases could be calculated as follows:
Air Release = (ventilation flow rate, ft3/min) x (operating time, min/yr) x
(concentration of chemical, ppmv) x (vapor density of chemical, lb/ft3)
Benzene releases per year would be calculated as follows:
20,000 ft3} x ( 60 minutes^ x f 24 M x f 33° days\ x f °-1 ft3 benzene] x [ 0-2 l
minute j [ hour j I, day j [ year j [ 1Q6 ft3 air J { ft3
= 190 Ib/vr of benzene
(3) Raoult's Law
The following is an example of a release calculation using Raoult's Law. Raoult's
Law states that the partial pressure of a compound in the vapor phase over a solution may be
estimated by multiplying its mole fraction in the liquid solution by the vapor pressure of the pure
chemical.
PA ~ XALP° - XAjGPT
where:
P° = Vapor pressure of pure liquid chemical A;
XA L = Mole fraction of chemical A in solution;
XA,G = Mole fraction of chemical A in the gas phase;
PA = Partial pressure of chemical A in the gas phase; and
PT = Total pressure.
Example: A wash tank holds a solution containing 10% by weight of
o-xylene (A) and 90% by weight of toluene (B). The tank is vented to the atmosphere; the
process vent flow rate is estimated as 100 acfm (2.83m3/min) based on a minimum fresh air
ventilation rate. The molecular weight of o-xylene is 106.17 g/mole and toluene is 92.14 g/mole.
The vapor pressure of o-xylene is 10 mm of Hg (0.19 psia). The total pressure of the system is
B-4
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14.7 psia (atmospheric conditions). The process tank is in service 250 days/yr. Calculate the air
release of o-xylene.
Step 1: Calculate the mole fraction of o-xylene in the liquid solution.
X
wt fraction A
MWA
A'L wt fraction A wt fraction B
MW,
MW,
Where:
where:
MW
wt fraction
Mole fraction of chemical A in liquid solution;
Molecular weight of chemical, g/g-mole; and
Weight fraction of chemical in material.
X
•A,L
0.1
106.17
0.1 0.9
106.17 92.14
XA,L = 0.09
Step 2: Calculate the mole fraction of o-xylene in the gas phase.
X
A,G
X
X
p°
PT
•A,G
A,L
Mole fraction of chemical A in gas phase;
Mole fraction of chemical A in liquid solution;
Vapor pressure of pure liquid chemical, A, psia; and
Total pressure of system, psia.
XA.G = [°-09]
0.19 psia
14.7 psia
= 0.001
B-5
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Step 3: Calculate releases using Raoult's Law.
Emissions = (X, r) x (APR) x (t) x (MW.) x _L_
V A,G' V ! \ ! \ A' I My
where:
Emissions = Air release of pollutant A, g-A/yr;
XA G = Mole fraction of chemical A in gas phase;
APR = Air flow rate of room, m3/min;
t = Operating time of wash tank, min/yr;
MW = Molecular weight of chemical, g/g-mole; and
MV = Gas molar volume (22.4 L/mole at standard temperature
and pressure).
If conditions vary from standard temperature and pressure the gas molar volume
can be calculated using the ideal gas law and tank conditions as presented in
Example 1.
Emissions=(0.001)>
2.83 m3 250 day 24 hr 60 min mole 106.17g
x - L x - x - x - x - S.
mm } \ yr ) \ day ) \ hr / \ 22.4LJ (, mole / ( I(r3m3,
= 4.8 x 106g/yr
The emissions of o-xylene are calculated as shown below.
Emissions = (4.8 x io6 g/yr) x lb I = 10.570 Ib/vr of o-xvlene
I 454 gj
Air releases for toluene can be calculated in a similar manner.
(4) Air Emission Factor
The following is an example of a release calculation using air emission factors.
Example: An industrial boiler uses 300 gallons per hour of No. 2 fuel oil. The
boiler operates 2,000 hours per year. Calculate emissions of formaldehyde using
the AP-42 emission factors.
AE = (EF) x (AU)
B-6
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where:
AE = Annual emissions of pollutant, Ib/yr
EF = Emission factor of pollutant, lb/103 gallon of fuel. EF for
formaldehyde for an industrial boiler burning No. 2 fuel oil is 0.035
to 0.061 lb/103 gallons.
AU = Quantity of fuel used, gal/yr.
Using an emission factor of 0.061 pounds of formaldehyde per gallon of fuel, the
air releases are calculated as follows:
AT3 i 0.061 Ib [ 300 gall [ 2,000 hr| _, , ,, , ,. ,. , , , ,
AE = x S—\ x _j = 36.6 Ib/vr of formaldehyde
gai; ^ hr ) \ yr
(5) RCRA Waste Analysis
The following is an example of a calculation using RCRA waste analysis data.
Example: Spent paint wastes were disposed at an off-site waste treatment facility.
The quantity of paint waste shipped was five 55-gallon drums per year. Analysis
of the waste showed 5% cadmium by weight. Estimating the density of the paint
waste to be 9.5 Ib/gallon, the amount of cadmium to off-site disposal is calculated
as follows:
Amount of cadmium = (amount of paint waste disposed, gal/yr) x (concentration of cadmium, Ib/lb)
(density of paint waste, Ib/gal)
55 al 9.51b 51b Cd 101 ,,, , , .
= 131 lb/vr of cadmium
( drum } \ gal } ( lOOlb waste
(6) NPDES Data
The following is an example of a calculation using NPDES data.
NPDES permits require periodic monitoring of the effluent stream. In this
example, quarterly samples were taken to be analyzed for silver content. Each sample was an
hourly, flowrate-based composite taken for one day to be representative of the discharge for that
day. The total effluent volume for that day was also recorded. The following data were collected
on each sample day.
B-7
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Discharge Flow Rate
Quarter HO6 gal/day^ Total Silver ( ua/L)
1 0.5 10
2 0.6 10
3 0.4 6
4 0.2 <3
To calculate the amount of silver in pounds discharged on each sample day, the
concentration of silver in the discharge is multiplied by the discharge flow rate for that day, as
shown below for the first quarter sample.
Amount of silver = (daily flow rate) x (silver concentration)
lg x [ Hb] x ( 3.785L]
1454§/ ( §al j
0.5 x io6gal
day
= 0.04 Ib/day of silver
The amount of silver discharged during each of the other three monitoring events
was similarly determined to be:
0.05 Ib/day; 0.02 Ib/day, and 0.005 Ib/day.
For the last data point the concentration of silver was reported by the laboratory to
be less than the detection limit of 3 jig/L. For this calculation the detection limit was used to
calculate the daily discharge, a conservative assumption.
The average daily discharge was calculated to be:
( 0.04 +0.05 +0.02 +0.005}..,. nM^,A
Mb/day = 0.03 Ib/day
The plant operates 350 days/year (plant shuts down for two weeks in July).
The estimated annual discharge of silver is calculated as follows:
Annual discharge = (350 days/year) (0.03 Ib/day) = 10.5 Ib of silver/year
B-8
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Appendix C
LIST OF TOXIC CHEMICALS WITHIN THE WATER DISSOCIABLE
NITRATE COMPOUNDS CATEGORY AND GUIDANCE FOR
REPORTING
-------
United States
Environmental Protection
Agency
Office of Pollution Prevention and
Toxics
Washington, DC 20460
Revised May 1996
EPA 745-R-96-004
TOXICS RELEASE INVENTORY
List of Toxic Chemicals Within the Water Dissociable Nitrate
Compounds Category and Guidance for Reporting
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using
listed toxic chemicals to report their environmental releases of such chemicals annually.
Beginning with the 1991 reporting year, such facilities also must report pollution prevention and
recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42
U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals
that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section
313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth criteria
for these actions.
CONTENTS
Section 1. Introduction C-2
1.1 Who MustReport C-2
1.2 Thresholds C-2
1.3 Chemicals within the Water Dissociable Nitrate Compounds Category C-3
1.4 De Minimis Concentrations C-3
Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category C-4
2.1 Chemicals within the Water Dissociable Nitrate Compounds Category C-4
2.2 Determining Threshold and Release Quantities for Nitrate Compounds C-4
2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid C-5
2.3.1 Estimating Nitric Acid Releases C-6
2.3.2 Estimating Treatment Efficiencies for Nitric Acid
Neutralization C-8
2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid C-9
2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment .. C-10
Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category C-l 1
C-l
-------
Seciton 1. Introduction
On November 30, 1994 EPA added 286 chemicals and chemical categories, which
include 39 chemicals as part of two delineated categories, to the list of toxic chemicals subject to
reporting under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA), 42 U.S.C. 11001. These additions are described at 59 FR 61432, and are
effective January 1, 1995 for reports due July 1, 1996. Six chemical categories (nicotine and
salts, strychnine and salts, polycyclic aromatic compounds, water dissociable nitrate compounds,
diisocyanates, and poly chlorinated alkanes) are included in these additions. At the time of the
addition, EPA indicated that the Agency would develop, as appropriate, interpretations and
guidance that the Agency determines are necessary to facilitate accurate reporting for these
categories. This document constitutes such guidance for the water dissociable nitrate compounds
category.
Section 1.1 Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA Section
313, if it meets all three of the following criteria:
• It conducts manufacturing operations (is included in Standard Industrial
Classification (SIC) codes 20 through 39); and
• It has 10 or more full-time employees (or the equivalent 20,000 hours per
year); and
• It manufactures, imports, processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than the
"threshold" quantities specified below.
Section 1.2 Thresholds
Thresholds are specified amounts of toxic chemicals used during the calendar year
that trigger reporting requirements.
If a facility manufactures or imports any of the listed toxic chemicals, the
thresholds quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility processes any of the listed toxic chemicals, the threshold quantity will
be:
• 25,000 pounds per toxic chemical or category over the calendar year.
C-2
-------
If a facility otherwise uses any of the listed toxic chemicals (without
incorporating it into any product or producing it at the facility), the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
EPCRA Section 313 requires threshold determinations for chemical categories to
be based on the total of all chemicals in the category manufactured, processed or otherwise used.
For example, a facility that manufactures three members of a chemical category would count the
total amount of all three chemicals manufactured towards the manufacturing threshold for that
category. When filing reports for chemical categories, the releases are determined in the same
manner as the thresholds. One report is filed for the category and all releases are reported on this
form.
Section 1.3 Chemicals Within the Water Dissociable Nitrate Compounds Category
EPA is providing a list of CAS numbers and chemical names to aid the regulated
community in determining whether they need to report for the water dissociable nitrate
compounds category. The list includes individual chemicals within the water dissociable nitrate
compounds category. If a facility is manufacturing, processing, or otherwise using a chemical
which is on this list, they must report this chemical. However, this list is not exhaustive. If a
facility is manufacturing, processing, or otherwise using a water dissociable nitrate compound,
they must report the chemical, even if it does not appear on the list.
Section 1.4 De Minimis Concentrations
The water dissociable nitrate compounds category is subject to the one percent de
minimis concentration. Thus, mixtures that contain members of this category in excess of the de
minimis should be factored into threshold and release determinations.
C-3
-------
Section 2. Guidance for Reporting Chemicals within the Water Dissociable Nitrate
Compounds Category
Note: for the purposes of reporting under the nitrate compounds category, water
dissociable means that the nitrate ion dissociates from its counterion when in solution.
Section 2.1 Chemicals within the Water Dissociable Nitrate Compounds Category
Chemicals within the nitrate compounds category are only reportable when in
aqueous solution. All water dissociable nitrate compounds are included in the nitrate compounds
category, including ammonium nitrate. Specifically listed EPCRA Section 313 chemicals are not
included in threshold determinations for chemical categories such as the water dissociable nitrate
compounds category. Specifically listed toxic chemicals are subject to their own individual
threshold determinations. As of December 1, 1994, ammonium nitrate (solution) is not an
individually listed chemical on the EPCRA Section 313 list. However, ammonium nitrate is still
subject to reporting under the nitrate compounds category. In addition, the aqueous ammonia
from the dissociation of ammonium nitrate when in aqueous solution is subject to reporting under
the ammonia listing.
Section 2.2 Determining Threshold and Release Quantities for Nitrate Compounds
The total nitrate compound, including both the nitrate ion portion and the
counterion, is included in the nitrate compounds category. When determining threshold amounts,
the total weight of the nitrate compound is to be included in all calculations. However, only the
nitrate ion portion is to be included when determining the amount of the chemicals within the
nitrate compounds category that is released, transferred, or otherwise managed in wastes.
Example 1: In a calendar year, a facility processes 100,000 pounds of ammonium nitrate
(NH4NO3), in aqueous solution, which is released to wastewater streams then transferred to a
POTW. The quantity applied towards threshold calculations for the nitrate compounds
category is the total quantity of the nitrate compound or 100,000 pounds. Since this quantity
exceeds the 25,000 pound processing threshold, the facility is required to report for the nitrate
compounds category. Under the nitrate compounds category, only the weight of the nitrate ion
portion of ammonium nitrate is included in release transfer calculations. The molecular weight
of the ammonium nitrate is 80.04 and the weight of the nitrate ion portion is 62.01 or 77.47
percent of the molecular weight of ammonium nitrate. Therefore, the amount of nitrate ion
reported as transferred to the POTW is 77.47 percent of 100,000 pounds or 77,470 pounds
(reported as 77,000 pounds). The aqueous ammonia from ammonium nitrate is reportable
under the EPCRA Section 313 listing for ammonia. For determining thresholds and calculating
releases under the ammonia listing, see the separate directive, Guidance for Reporting Aqueous
Ammonia (EPA document #745-R-95-0003, July 1995).
C-4
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Example 2: In a calendar year, a facility manufactures as by-products 20,000 pounds of sodium
nitrate (NaNO3) and 10,000 pounds of calcium nitrate (Ca(NO3)2), both in aqueous solutions,
and releases these solutions to wastewater streams. The total quantity of nitrate compounds
manufactured by the facility is the sum of the two chemicals, or 30,000 pounds, which exceeds
the manufacturing threshold quantity of 25,000 pounds. The facility therefore is required to
report for the nitrate compounds category. By weight, the nitrate ion portion is 72.96 percent
of sodium nitrate and is 75.57 percent of calcium nitrate. Of the 20,000 pounds of the sodium
nitrate in solution, 72.96 percent or 14,592 pounds is nitrate ion, and similarly, of the 10,000
pounds of the calcium nitrate in solution, 75.57 percent or 7,557 pounds is nitrate ion. The
total nitrate ion in aqueous solution released by the facility is the sum of the nitrate ion in the
two solutions or 22,149 pounds (reported as 22,000 pounds).
Section 2.3 Reporting Nitrate Compounds Generated from the Partial or Complete
Neutralization of Nitric Acid
Nitric acid is an individually listed chemical on the original EPCRA Section 313 list
and is reported as a separate chemical if the manufacture, process, or otherwise use thresholds are
exceeded. The partial or complete neutralization of nitric acid results in the formation of nitrate
compounds which are reported as chemicals within the nitrate compounds category if their
manufacture, process, or otherwise use thresholds are exceeded.
Mineral acids such as nitric acid may be present in aqueous waste streams that are
sent to on-site neutralization or are discharged to a publicly owned treatment works (POTW) or
other off-site treatment facility. As stated in the Toxic Chemical Release Inventory Reporting
Form R and Instructions document (revised 1993 version, EPA 745-K-94-001), on-site acid
neutralization and its efficiency must be reported in Part II, section 7A of Form R (waste
treatment methods and efficiency section). For purposes of reporting on Form R, EPA considers
a waste mineral acid at a pH 6 or higher to be 100 percent neutralized (water discharges to
receiving streams or POTWs are reported as zero). The nitrate compounds produced from the
complete neutralization (pH 6.0 or above) of nitric acid are reportable under the nitrate
compounds category and should be included in all threshold and release calculations. Two Form
R reports would be required if the manufacture, process or otherwise use thresholds are exceeded
for nitric acid and for the nitrate compounds category.
If the nitric acid treatment efficiency is not equal to 100 percent (pH is less than 6),
the amount of the acid remaining in the waste stream which is released to the environment on-site
or off-site must be reported in Part II of Form R. The nitrate compounds produced from the
partial neutralization of nitric acid are reportable under the nitrate compounds category and
should be included in all threshold and release calculations. Two reports would again be required
if the manufacture, process or otherwise use thresholds are exceeded for nitric acid and for the
nitrate compounds category.
C-5
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Section 2.3.1 Estimating Nitric Acid Releases
The pH of the waste stream can be used to calculate the amount of nitric acid in
the stream and the efficiency of neutralization. The pH is a measure of the acidity or alkalinity of
a waste stream and can be obtained readily using a pH meter or pH sensitive paper. The pH scale
itself varies from 0 to 14.
The total nitric acid concentration (ionized and un-ionized) in pounds per gallon
can be calculated by using the pH value of the solution, the molecular weight and ionization
constant of the acid, and appropriate conversion factors. The total acid concentration for nitric
acid for different pH values is listed in Table 1. The calculation of mineral acid concentrations
and the derivation of Table 1 are discussed in a separate directive, Estimating Releases for
Mineral Acid Discharges Using pH Measurements, and an addendum to this directive.
The procedure outlined in this guidance document for calculating the quantity of
nitrate compounds formed from the complete or partial neutralization of nitric acid can be used if
nitric acid is the only mineral acid in a solution. In addition, the calculation of nitric acid releases
using only pH measurements is a rough estimate. The subsequent calculation of nitrate compound
releases is therefore also only a rough estimate. The estimates can be made for a waste stream
with a steady pH below 6 or for one whose pH temporarily drops to below pH 6. Facilities
should use their best engineering judgement and knowledge of the solution to evaluate how
reasonable the estimates are.
Example 3: In a calendar year, a facility transfers 1.0 million gallons of a solution containing
nitric acid (HNO3), at pH 4, to a POTW. Using Table 1 (next page), a pH of 4 corresponds to
a concentration of 0.0000520 Ibs HNO3/gallon of solution. The weight of HNO3 transferred
can be estimated using the equation:
Transfer of HNO3 = (Concentration of HNO3) x (effluent flow rate)
Substituting the example values into the above equation yields:
Transfer of HNO3 = 0.0000520 Ibs/gal HNO3 x 1,000,000 gal solution/year = 52 Ibs/year
Example 4: A facility had an episodic release of nitric acid (HNO3) in which the waste stream
was temporarily below pH 6. During the episode, the wastewater (pH 2.0) was discharged to a
river for 20 minutes at a rate of 100 gallons per minute. Using Table 1, a pH of 2.0 for HNO3
represents a concentration of 0.0052000 Ibs HNO3/gallon of solution. The amount of the
HNO3 released can be estimated using the following equation:
Release of HNO3 = (concentration of HNO3) x (effluent flow rate)
Substituting the example values in the above equation:
Release of HNO3 = 0.0052000 Ibs/gal x 100 gal/min x 20 min
= 10 Ibs
C-6
-------
Table C-l
Nitric Acid Concentration Versus pH
pH
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
2.2
2.4
2.6
2.8
Nitric Acid Concentration
(Ibs/gallon)
0.5200000
0.3300000
0.2100000
0.1300000
0.0830000
0.0520000
0.0330000
0.0210000
0.0130000
0.0083000
0.0052000
0.0033000
0.0021000
0.0013000
0.0008300
pH
3.0
3.2
3.4
3.6
3.8
4.0
4.2
4.4
4.6
4.8
5.0
5.2
5.4
5.6
5.8
6.0
Nitric Acid Concentration
(Ibs/gallon)
0.0005200
0.0003300
0.0002100
0.0001300
0.0000830
0.0000520
0.0000330
0.0000210
0.0000130
0.0000083
0.0000052
0.0000033
0.0000021
0.0000013
0.0000008
0.0000005
C-7
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Section 2.3.2 Estimating Treatment Efficiencies for Nitric Acid Neutralization
Nitric acid solutions that are neutralized to a pH of 6 or above have a treatment
efficiency of 100 percent. If nitric acid is neutralized to a pH less than 6, then the reportable
treatment efficiency is somewhere between 0 and 100 percent. It is possible to estimate the
neutralization treatment efficiency using nitric acid concentration values directly from Table 1 in
the equation given below. The concentrations correspond to the pH values before and after
treatment.
(I-E)
Treatment efficiency = x 100
where:
I = Acid concentration before treatment; and
E = Acid concentration after treatment.
Example 5: A nitric acid (HNO3) waste stream of pH 2.4 is neutralized to pH 4.6. Using
Table 1, the initial nitric acid concentration is 0.0021000 mol/liter and the final concentration is
0.0000130 mol/liter. Substituting these values into the equation for treatment efficiency:
(0.0021000-0.0000130)
Treatment Efficienc = - - x 100
=99.4 percent
For strong acids only (including nitric acid), the net difference in pH before and
after treatment can be used to estimate the treatment efficiency since pH is directly proportional
to the acid concentration. For example, a pH change of one unit results in a treatment efficiency
of 90 percent, whether the pH change is from pH 1 to pH 2 or from pH 4 to pH 5. Table 2
summarizes treatment efficiencies for various pH changes (the pH change is the difference
between the initial pH and the pH after neutralization). In the table, some pH changes result in
the same treatment efficiency values due to rounding to one decimal place.
-------
Table C-2
Nitric Acid Treatment Efficiencies for Various pH Changes
pH Unit Change
1.0
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
Treatment Efficiency
(%)
90.0
92.1
93.7
95.0
96.0
96.8
97.5
98.0
98.4
98.7
pH Unit Change
2.0
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
3.0
Treatment Efficiency
(%)
99.0
99.2
99.4
99.5
99.6
99.7
99.8
99.8
99.8
99.9
99.9
Example 6: If a nitric acid (HNO3) waste stream of pH 2 is treated to pH 4, the pH change is 2
| units. Using Table 2 above, the treatment efficiency is given as 99.0 percent. |
Section 2.3.3 Estimating Releases of Nitrate Compounds Generated from the
Neutralization of Nitric Acid
The nitrate compounds produced from the complete neutralization (pH 6.0 or
above) or partial neutralization (pH less than 6) or nitric acid are reportable under the nitrate
compounds category if the appropriate threshold is met and should be included in all threshold
and release calculations. In order to determine the quantity of a nitrate compound generated and
released, the quantity of nitric acid released must be known (or calculated from the equations used
in Examples 3 and 4 above) as well as the nitric acid treatment efficiency (calculated from the
equations used in Examples 5 and 6 above).
The neutralization of nitric acid will most likely result in the generation of
monovalent nitrate compounds (such as sodium nitrate and potassium nitrate). The quantity of
these compounds formed in kilomoles will be equal to the quantity of the nitric acid neutralized in
kilomoles. If divalent nitrate compounds are formed (such as calcium nitrate), the quantity of
these compounds formed in kilomoles will be equal to one-half the quantity of the nitric acid
neutralized in kilomoles. Similarly, if trivalent nitrate compounds are formed (such as iron (III)
nitrate), the quantity formed of these compounds in kilomoles will be equal to one-third the
quantity of the nitric acid neutralized in kilomoles. Note: to calculate the releases of nitrate
compounds generated from the neutralization of nitric acid, the molecular weight of the nitrate
C-9
-------
compound formed must be used. Molecular weights of some of the individual chemicals within
the water dissociable nitrate compounds category are given in Table 3.
Example 7: In a calendar year, a facility transfers 50,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid treatment efficiency is 95 percent, and the nitrate
compound formed as a result of the treatment is sodium nitrate (NaNO3). The quantity of nitric
acid transferred that is neutralized (generating sodium nitrate) is 95 percent of 50,000 pounds
or 47,500 pounds. The molecular weight of nitric acid is 63.01 kg/kmol, and the molecular
weight of sodium nitrate is 84.99 kg/kmol. The quantity of nitric acid neutralized is converted
first to kilograms then to kilomoles using the following equations:
Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)
Substituting the example values into the above equation yields:
Kilograms HNO3 neutralized = 47,500 Ibs x 0.4536 kg/lb = 21.546 kg
Kilomoles HNO3 neutralized = 21,546 kg + 63.01 kg/kmol = 341.9 kmol
The quantity of sodium nitrate generated in kilomoles is equal to the quantity of nitric acid
neutralized (341.9 kmol). The quantity of sodium nitrate generated in kilomoles is converted
first to kilograms then to pounds using the following equations:
Kilograms NaNO3 generated = (kmol NaNO3) x (MW of NaNO3 in kg/kmol)
Pounds NaNO3 generated = (kg NaNO3) x (2.205 Ibs/kg)
Substituting the values into the above equation yields:
Kilograms NaNO3 generated = 341.9 kmol x 84.99 kg/kmol = 29,058 kg
Pounds NaNO3 generated = 29,058 kg x 2.205 Ibs/kg = 64,073 pounds
(reported as 64,000 pounds)
The 64,000 pounds of sodium nitrate generated is the quantity used to determine whether
thresholds have been met or exceeded. The quantity of nitrate ion released is calculated as in
Example 1 above.
Section 2.4 Generation of Nitrate Compounds from Biological Wastewater Treatment
If a facility treats wastewater on-site biologically, using the activated sludge
process, for example, the facility may be generating nitrate compounds as by-products of this
biological process. The nitrate ion generated from this process will be associated with various
counter!ons (e.g., sodium ion, potassium ion). In the absence of information on the identity of the
counter!on, a facility should assume for the purposes of EPCRA Section 313 threshold
determinations that the counterion is sodium ion.
C-10
-------
Section 3. CAS Number List of Some of the Individual Chemicals within the Water
Dissociable Nitrate Compounds Category
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report for the water dissociable
nitrate compounds category. If a facility is manufacturing, processing, or otherwise using a
chemical which is listed below, they must report this chemical. However, this list is not
exhaustive. If a facility is manufacturing, processing, or otherwise using a water dissociable
nitrate compound, they must report this chemical, even if it does not appear on the following list.
Table C-3
Listing by CAS Number and Molecular Weight of Some of the Individual
Chemicals within the Water Dissociable Nitrate Compounds Category
Chemical Name
Aluminum nitrate, nonahydrate
Ammonium nitrate
Cerium (III) ammonium nitrate, tetrahydrate
Cerium (IV) ammonium nitrate
Barium nitrate
Beryllium nitrate, trihydrate
Cadmium nitrate
Cadmium nitrate, tetrahydrate
Calcium nitrate
Calcium nitrate, tetrahydrate
Cerium (III) nitrate, hexahydrate
Cesium nitrate
Chromium (III) nitrate, nonahydrate
Cobalt (II) nitrate, hexahydrate
Copper (II) nitrate, trihydrate
Copper (II) nitrate, hexahydrate
Dysprosium (III) nitrate, pentahydrate
Erbium (III) nitrate, pentahydrate
Gadolinium (III) nitrate, hexahydrate
Gallium nitrate, hydrate
Iron (III) nitrate, hexahydrate
Iron (III) nitrate, nonahydrate
Molecular Weight*
213.00
80.04
486.22
548.23
261.34
133.02
236.42
236.42
164.09
164.09
326.13
194.91
238.01
182.94
187.56
187.56
348.51
353.27
343.26
255.73
241.86
241.86
CAS Number
7784-27-2
6484-52-2
13083-04-0
10139-51-2
10022-31-8
7787-55-5
10325-94-7
10022-68-1
10124-37-5
13477-34-4
10294-41-4
7789-18-6
7789-02-8
10026-22-9
10031-43-3
13478-38-1
10031-49-9
10031-51-3
19598-90-4
69365-72-6
13476-08-9
7782-61-8
C-ll
-------
Table C-3 (Continued)
Chemical Name
Lanthanum (III) nitrate, hexahydrate
Lead (II) nitrate
Lithium nitrate
Lithium nitrate, trihydrate
Magnesium nitrate, dihydrate
Magnesium nitrate, hexahydrate
Manganese (II) nitrate, tetrahydrate
Neodymium (III) nitrate, hexahydrate
Nickel (II) nitrate, hexahydrate
Potassium nitrate
Rhodium (III) nitrate, dihydrate
Rubidium nitrate
Samarium (III) nitrate, hexahydrate
Scandium (III) nitrate
Scandium (III) nitrate, tetrahydrate
Silver nitrate
Sodium nitrate
Strontium nitrate
Strontium nitrate, tetrahydrate
Terbium (III) nitrate, hexahydrate
Thorium (IV) nitrate
Thorium (IV) nitrate, tetrahydrate
Yttrium (III) nitrate, hexahydrate
Yttrium (III) nitrate, tetrahydrate
Zinc nitrate, trihydrate
Zinc nitrate, hexahydrate
Zirconium (IV) nitrate, pentahydrate
Molecular Weight*
324.92
331.21
68.95
68.95
148.31
148.31
178.95
330.25
182.70
101.10
288.92
147.47
336.37
230.97
230.97
169.87
84.99
211.63
211.63
344.94
480.06
480.06
274.92
274.92
189.39
189.39
339.24
CAS Number
10277-43-7
10099-74-8
7790-69-4
13453-76-4
15750-45-5
13446-18-9
20694-39-7
16454-60-7
13478-00-7
7757-79-1
13465-43-5
13126-12-0
13759-83-6
13465-60-6
16999-44-3
7761-88-8
7631-99-4
10042-76-9
13470-05-8
13451-19-9
13823-29-5
13470-07-0
13494-98-9
13773-69-8
131446-84-9
10196-18-6
13986-27-1
*For hydrated compounds, e.g., aluminum nitrate, nonahydrate, the molecular weight excludes the weight of the hydrate portion. For
example, the same molecular weight is provided for aluminum nitrate, nonahydrate and aluminum nitrate.
C-12
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Appendix D
EPCRA SECTION 313, GUIDANCE FOR REPORTING
AQUEOUS AMMONIA
-------
United States Environmental
Protect! on_Agency
Office of Pollution Prevention
and Toxics
Washington, DC 20460
July 1995
EPA 745-R-95-012
EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW
EPCRA Section 313
Guidance for Reporting Aqueous Ammonia
EPCRA Section 313 of the Emergency Planning and Community Right-to-Know
Act of 1986 (EPCRA) requires certain facilities manufacturing, processing, or otherwise using
listed toxic chemicals to report their environmental releases of such chemicals annually.
Beginning with the 1991 reporting year, such facilities also must report pollution prevention and
recycling data for such chemicals, pursuant to section 6607 of the Pollution Prevention Act, 42
U.S.C. 13106. When enacted, EPCRA Section 313 established an initial list of toxic chemicals
that was comprised of more than 300 chemicals and 20 chemical categories. EPCRA Section
313(d) authorizes EPA to add chemicals to or delete chemicals from the list, and sets forth criteria
for these actions.
CONTENTS
Section 1. Introduction D-2
1.1 Who MustReport D-2
1.2 Thresholds D-2
1.3 Chemical Sources of Aqueous Ammonia D-3
1.4 De Minimis Concentrations D-3
Section 2. Guidance for Reporting Aqueous Ammonia D-4
2.1 Determining Threshold and Release Quantities for Ammonia D-4
2.2 Chemical Sources of Aqueous Ammonia D-5
2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous
Ammonia
in Water D-5
2.2.2 Reporting of Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate) D-6
2.2.3 Reporting of Aqueous Ammonia Generated from the
Dissociation of Ammonium Nitrate D-7
Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia . . . D-10
D-l
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Section 1. Introduction
On June 30, 1995 EPA finalized four actions in response to a petition received in
1989 to delete ammonium sulfate (solution) from the list of toxic chemicals subject to reporting
under EPCRA Section 313 of the Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA), 42 U.S.C. 11001. The four actions taken are summarized as follows: (1) deleted
ammonium sulfate (solution) from the EPCRA Section 313 list of toxic chemicals, (2) required
that threshold and release determinations for aqueous ammonia be based on 10 percent of the
total aqueous ammonia present in aqueous solutions of ammonia, (3) modified the ammonia
listing by adding the following qualifier: ammonia (includes anhydrous ammonia and aqueous
ammonia from water dissociable ammonium salts and other sources; 10 percent of total aqueous
ammonia is reportable under this listing), and (4) deleted ammonium nitrate (solution) as a
separately listed chemical on the EPCRA Section 313 list of toxic chemicals. All actions are
effective for the 1994 reporting year for reports due July 1, 1995, with the exception of the
deletion of ammonium nitrate (solution) as a separately listed chemical, which is effective for the
1995 reporting year for reports due July 1, 1996. At the time that these actions were finalized,
EPA indicated that the Agency would develop, as appropriate, interpretations and guidance that
the Agency determines are necessary to facilitate accurate reporting for aqueous ammonia. This
document constitutes such guidance for reporting under the ammonia listing.
Section 1.1 Who Must Report
A plant, factory, or other facility is subject to the provisions of EPCRA Section
313, if it meets all three of the following criteria:
• It conducts manufacturing operations (is included in Standard Industrial
Classification (SIC) codes 20 through 39); and
• It has 10 or more full-time employees (or the equivalent 20,000 hours per
year); and
• It manufactures, imports, processes, or otherwise uses any of the toxic
chemicals listed on the EPCRA Section 313 list in amounts greater than the
"threshold" quantities specified below.
Section 1.2 Thresholds
Thresholds are specified amounts of toxic chemicals used during the calendar year
that trigger reporting requirements.
If a facility manufactures or imports any of the listed toxic chemicals, the threshold
quantity will be:
• 25,000 pounds per toxic chemical or category over the calendar year.
D-2
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If a facility processes any of the listed toxic chemicals, the threshold quantity will
be:
• 25,000 pounds per toxic chemical or category over the calendar year.
If a facility otherwise uses any of the listed toxic chemicals (without incorporating
it into any product or producing it at the facility), the threshold quantity is:
• 10,000 pounds per toxic chemical or category over the calendar year.
Section 1.3 Chemical Sources of Aqueous Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia or
aqueous ammonia, they must report under the ammonia listing. EPA is providing a table of
Chemical Abstract Service (CAS) numbers and chemical names to aid the regulated community in
determining whether they need to report under the ammonia listing for aqueous ammonia. This
table includes a list of water dissociable ammonium salts which, when placed in water, are a
source of aqueous ammonia. The table contains only commonly used ammonium salts and
therefore is not exhaustive. If a facility manufactures, processes, or otherwise uses aqueous
ammonia, regardless of its source, it must report under the ammonia listing, even if the source of
the aqueous ammonia is not listed in the table provided in this document.
Section 1.4 De Minimis Concentrations
The ammonia listing is subject to the one percent de minimis concentration. Thus,
solutions containing aqueous ammonia at a concentration in excess of one percent of the 10
percent reportable under this listing should be factored into threshold and release determinations.
D-3
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Section 2. Guidance for Reporting Aqueous Ammonia
Note: for the purposes of reporting under the ammonia listing for aqueous
ammonia, water dissociable ammonium salts means that the ammonium ion dissociates from its
counterion when in solution.
Section 2.1 Determining Threshold and Release Quantities for Ammonia
If a facility manufactures, processes, or otherwise uses anhydrous ammonia., the
quantity applied towards threshold determinations for the ammonia listing is the total quantity of
the anhydrous ammonia manufactured, processed, or otherwise used. The quantity reported when
calculating the amount of ammonia that is released, transferred, or otherwise managed is the total
quantity of anhydrous ammonia released or transferred.
If the facility manufactures, processes, or otherwise uses anhydrous ammonia in
quantities that exceed the appropriate threshold and subsequently dissolves some or all of the
anhydrous ammonia in water, then the following applies: 1) threshold determinations are based
on 100 percent of the anhydrous ammonia (simply 10 percent of aqueous ammonia); 2) release,
transfer, and other waste management quantities for the aqueous ammonia are calculated as 10
percent of total ammonia; 3) release, transfer, and other waste management quantities for the
anhydrous ammonia are calculated as 100 percent of the anhydrous ammonia.
If a facility manufactures, processes, or otherwise uses aqueous ammonia, the
quantity applied toward threshold determinations for the ammonia listing is 10 percent of the total
quantity of the aqueous ammonia manufactured, processed, or otherwise used. The quantity
reported when calculating the amount of ammonia that is released, transferred, or otherwise
managed is 10 percent of the total quantity of aqueous ammonia released or transferred.
If a facility dissolves a water dissociable ammonium salt in water that facility has
manufactured aqueous ammonia and 10 percent of the total aqueous ammonia manufactured
from these salts is to be included in manufacturing threshold determinations under the ammonia
listing.
If aqueous ammonia from water dissociable ammonium salts is processed or
otherwise used, then 10 percent of the total aqueous ammonia is to be included in all processing
and otherwise use threshold determinations under the ammonia listing.
Example 1: In a calendar year, a facility places 25,000 Ibs of anhydrous ammonia in water for
processing and processes 25,000 Ibs of aqueous ammonia from an ammonium salt. The facility
must include all of the 25,000 Ibs of anhydrous ammonia in the determination of the processing
threshold, but only 10 percent (or 2,500 Ibs) of the aqueous ammonia from the ammonium salt
in the processing threshold determination.
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Total aqueous ammonia is the sum of the two forms of ammonia (un-ionized, NH3,
and ionized, NH4+) present in aqueous solutions. A precise calculation of the weight of total
aqueous ammonia would require determining the ratio of the two forms of ammonia present using
the pH and temperature of the solution. The weight of total aqueous ammonia can be more easily
calculated by assuming that aqueous ammonia is comprised entirely of the NH4+ form or the NH3
form. For the purpose of determining threshold and release quantities under EPCRA Section 313,
EPA recommends that total aqueous ammonia be calculated in terms of NH3 equivalents (i.e., for
determining weights, assume total ammonia is comprised entirely of the NH3 form). This method
is simpler than using pH and temperature data to determine the ratio of the two forms present and
is consistent with the presentation of total ammonia toxicity in a separate EPA document,
Ambient Water Quality Criteria for Ammonia (EPA document #440/5-85-001, January 1985).
Section 2.2 Chemical Sources of Aqueous Ammonia
Aqueous ammonia may be generated in solution from a variety of sources that
include the release of anhydrous ammonia to water and the dissociation of ammonium salts in
water. Water dissociable ammonium salts are not reportable in their entirety under the ammonia
listing; these salts are reportable to the extent that they dissociate in water, and only 10 percent of
the total aqueous ammonia that results when these salts dissociate is reportable. If these salts are
not placed in water, they are not reportable.
If these salts are purchased neat or as solids by a facility, then placed in water by
that facility, the facility is manufacturing aqueous ammonia.
Section 2.2.1 Reporting Aqueous Ammonia Generated from Anhydrous Ammonia in
Water
If the source of aqueous ammonia is anhydrous ammonia in water, total aqueous
ammonia (calculated in terms of NH3 equivalents) is equal to the quantity of anhydrous ammonia
manufactured, processed, or otherwise used. A hypothetical scenario demonstrating the
calculations involved in reporting aqueous ammonia generated from anhydrous ammonia in water
is given in Example 2.
Example 2: In a calendar year, a facility uses 30,000 pounds of anhydrous ammonia to
neutralize acids in a wastewater stream. The neutralized waste stream (containing aqueous
ammonia from dissociated ammonium salts) is then transferred to a POTW. The quantity to be
applied toward threshold determinations is the total quantity of anhydrous ammonia used in the
waste stream neutralization, or 30,000 pounds. The quantity of ammonia reported as
transferred is 10 percent of the total quantity of aqueous ammonia transferred, or 3,000
pounds.
Section 2.2.2 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Salts (Other Than Ammonium Nitrate)
If the source of aqueous ammonia is the dissociation of ammonium salts in water,
total aqueous ammonia (calculated in terms of NH3 equivalents) is calculated from the weight
D-5
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percent (wt%) of the NH3 equivalents of the ammonium salt. The NH3 equivalent wt% of an
ammonium salt is calculated using the following equation:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium salt) x 100
If the source of aqueous ammonia is a monovalent compound (such as ammonium chloride,
NH4C1, ammonium nitrate, NH4NO3, or ammonium bicarbonate (NH4HCO3), the NH3 equivalent
weight is equal to the MW of NH3 (17.03 kg/kmol). If divalent compounds are involved (such as
ammonium carbonate, (NH4)2CO3), then the NH3 equivalent weight is equal to the MW of NH3
multiplied by two. Similarly, if trivalent compound are involved, then the NH3 equivalent weight
is equal to the MW of NH3 multiplied by three.
Example 3:
The NH3 equivalent wt% of ammonium chloride is calculated as follows:
NH3 equivalent wt% = (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = (17.03)7(53.49) x 100
NH3 equivalent wt% = 31.84%
The NH3 equivalent wt% of ammonium carbonate is calculated as follows:
NH3 equivalent wt% = 2 x (NH3 equivalent weight)/(MW ammonium chloride) x 100
NH3 equivalent wt% = 2 x (17.03)7(96.09) x 100
NH3 equivalent wt% = 35.45%
To aid the regulated community in reporting under the ammonia listing for
aqueous ammonia, the table of chemical sources of aqueous ammonium provided in Section 3 of
this document includes, in addition to CAS number, chemical name, and molecular weight, the
NH3 equivalent wt% of the commonly used, water dissociable ammonium salts listed in this table.
Example 4: In a calendar year, a facility uses 100,000 pounds of ammonium chloride, NH4C1,
in aqueous solution which is released to wastewater streams, then transferred to a POTW. The
NH3 equivalent wt% of ammonium chloride is 31.84% (taken from Table 1 in Section 3 below
or calculated as in Example 3 above). The total quantity of aqueous ammonia present in
solution is 31.84% of the 100,000 pounds of ammonia chloride used, or 31,840 pounds. The
quantity applied towards threshold determinations for the ammonia listing is 10 percent of the
total quantity of aqueous ammonia present in solution, or 3,184 pounds. The quantity of
ammonia reported as released or transferred is 10 percent of the total quantity of aqueous
ammonia released or transferred, or 3,184 pounds.
D-6
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Example 5: In a calendar year, a facility uses 500,000 pounds of ammonium carbonate,
(NH4)2CO3, and 400,000 pounds of ammonium bicarbonate, NH4HCO3, in aqueous solution
which is released to wastewater streams, then transferred to a POTW. The NH3 equivalent
wt% of ammonium carbonate is 35.45%, and the NH3 equivalent wt% of ammonium
bicarbonate is 21.54% (taken from Table 1 in Section 3 below or calculated as in Example 3
above). The quantity of aqueous ammonia present in solution from ammonium carbonate is
35.45% of the 500,000 pounds of ammonia carbonate used, or 177,250 pounds. The quantity
of aqueous ammonia present in solution from ammonium bicarbonate is 21.54% of the 400,000
pounds of ammonia bicarbonate used or 86,160 pounds. The total quantity of aqueous
ammonia present in solution is 263,410 pounds. The quantity applied towards threshold
determinations for the ammonia listing is 10 percent of the total quantity of aqueous ammonia
present in solution, or 26,341 pounds. The quantity of ammonia reported as released or
transferred is 10 percent of the total quantity of aqueous ammonia released or transferred, or
26,341 pounds.
Section 2.2.3 Reporting Aqueous Ammonia Generated from the Dissociation of
Ammonium Nitrate
Some sources of aqueous ammonia may be reportable under other EPCRA Section
313 category listings. Ammonium nitrate (solution) is relevant to reporting under the ammonia
listing to the extent that 10 percent of the total aqueous ammonia that results when ammonium
nitrate dissociates is reported when determining thresholds and calculating releases. However,
under the nitrate compound category listing, ammonium nitrate (and other mixed salts containing
ammonium and nitrate) must be reported in its entirety. When reporting ammonium nitrate under
this category listing, the total nitrate compound, including both the nitrate ion portion and the
ammonium counterion, is included when determining threshold quantities. However, only the
nitrate ion portion is included when determining the amount of ammonium nitrate that is released,
transferred, or otherwise managed in wastes. The calculations involved in determining threshold
and release quantities for reporting under the nitrate compound category listing are described in a
separate directive, List of Toxic Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting (EPA document #745-R-95-002, February 1995). Note:
reporting ammonium nitrate under the ammonia listing and nitrate compounds category listing is
effective for the 1995 reporting year for reports due July 1, 1996.
D-7
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Example 6: In a calendar year, a facility uses 1,250,000 pounds of ammonium nitrate,
NH4NO3, in aqueous solution which is released to wastewater streams, then transferred to a
POTW. The NH3 equivalent wt% of ammonium nitrate is 21.28% (taken from Table 1 in
Section 3 below or calculated as in Example 3 above). The total quantity of aqueous ammonia
present in solution is 21.28% of the 1,250,000 pounds of ammonia chloride used, or 266,000
pounds. The quantity applied towards threshold determinations for the ammonia listing is 10
percent of the total quantity of aqueous ammonia present in solution, or 26,600 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 26,600 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February, 1995).
D-8
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Example 7: In a calendar year, a facility transfers 100,000 pounds of nitric acid (HNO3) to an
on-site treatment facility. The nitric acid is neutralized with anhydrous ammonia, and treatment
efficiency is 95 percent (the nitrate compound formed as a result of the treatment is ammonium
nitrate, NH4NO3). The neutralized waste stream (containing aqueous ammonia from
dissociated ammonium nitrate) is then transferred to a POTW. The quantity of nitric acid
neutralized is 95 percent of 100,000 pounds or 95,000 pounds. The quantity of nitric acid
neutralized is converted first to kilograms then to kilomoles using the following equations:
Kilograms HNO3 neutralized = (Ibs HNO3 neutralized) x (0.4536 kg/lb)
Kilomoles HNO3 neutralized = (kg HNO3) - (MW of HNO3 in kg/kmol)
Substituting the appropriate values into the above equations yields:
Kilograms HNO3 neutralized = 95,000 Ibs x 0.4536 kg/lb = 43,092 kg
Kilomoles HNO3 neutralized = 43,092 kg + 63.01 kg/kmol = 683.9 kmol
The quantity of anhydrous ammonia used in kilomoles in the acid neutralization and the
quantity of ammonium nitrate generated in kilomoles from the neutralization are equal to the
quantity of nitric acid neutralized (683.9 kmol). The quantity of anhydrous ammonia used in
kilograms and pounds in the acid neutralization is calculated as follows:
Kilograms NH3 used = (kmol NH3) x (MW of NH3 in kg/kmol)
Pounds NH3 used = (kg NH3) x (2.205 Ibs/kg)
Substituting the appropriate values into the above equation yields:
Kilograms NH3 used = (683.9 kmol) x (17.03 kg/kmol) = 11,647 kmol
Pounds NH3 used = (11,647 NH3) x (2,205 Ibs/kg) = 25,682 pounds
The quantity reported applied towards threshold determinations for the ammonia listing is the
total quantity of anhydrous ammonia used in the acid neutralization, or 25,682 pounds. The
quantity of ammonia reported as released or transferred is 10 percent of the total quantity of
aqueous ammonia released or transferred, or 2,568 pounds. For determining thresholds and
calculating releases under the nitrate compound category listing, see the separate directive, List
of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance
for Reporting (EPA document #745-R-95-002, February 1995).
D-9
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Section 3. CAS Number and List of Some Chemical Sources of Aqueous Ammonia
EPA is providing the following table of CAS numbers and chemical names to aid
the regulated community in determining whether they need to report under the ammonia listing
for aqueous ammonia. If a facility manufactures, processes, or otherwise uses, in aqueous
solution, a chemical which is listed below, they must report 10 percent of the total aqueous
ammonia that is the result of the dissociation of this chemical. However, this list is not
exhaustive. If a facility manufactures, processes, or otherwise uses, in aqueous solution, a water
dissociable ammonium compound, they must report 10 percent of the total aqueous ammonia that
is the result of the dissociation of the compound, even if the compound does not appear in the
following table.
Table D-l
Listing by CAS Number and Molecular Weight of
Some Chemical Sources of Aqueous Ammonia
Chemical Name
Ammonium acetate
Ammonium aluminum sulfate
(Ammonium aluminum disulfate)
Ammonium antimony fluoride
(Diammonium pentafluoroantimonate)
Ammonium arsenate
(Ammonium arsenate, hydrogen)
(Ammonium arsenate, dihydrogen)
Ammonium arsenate
(Diammonium arsenate)
(Diammonium arsenate, hydrogen)
(Diammonium arsenate, monohydrogen)
Ammonium arsenite
Ammonium azide
Ammonium benzenesulfonate
Ammonium benzoate
Ammonium bromate
Ammonium bromide
Ammonium cadmium chloride
(Ammonium cadmium trichloride)
Ammonium carbamate
Ammonium carbonate carbamate
Molecular
Weight*
77.08
237.14
252.82
158.97
176.00
124.96
60.06
175.20
139.15
145.94
97.94
236.81
78.07
157.13
NH3
Equivalent
Wt%
22.09
7.181
13.47
10.71
19.35
13.63
28.35
9.720
12.24
11.67
17.39
7.191
21.81
21.68
CAS Number
631-61-8
7784-25-0
32516-50-0
13462-93-6
7784-44-3
13462-94-7
12164-94-2
19402-64-3
1863-63-4
13843-59-9
12124-97-9
18532-52-0
1111-78-0
8000-73-5
D-10
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Table D-l (Continued)
Chemical Name
Ammonium carbonate
(Diammonium carbonate)
Ammonium carbonate, hydrogen
(Ammonium bicarbonate)
Ammonium cerium nitrate
(Ammonium hexanitratocerate)
(Ammonium hexanitratocerate (IV))
(Diammonium cerium hexanitrate)
Ammonium cerous nitrate
(Ammonium cerous nitrate, tetrahydrate)
Ammonium chlorate
Ammonium perchlorate
Ammonium chloride
Ammonium chromate
(Ammonium chromate (VI))
(Diammonium chromate)
Ammonium chromate
(Ammonium dichromate)
(Ammonium dichromate (VI))
(Ammonium bichromate)
(Diammonium dichromate)
Ammonium chromium sulfate
(Ammonium chromic sulfate)
Ammonium citrate
(Ammonium citrate, monohydrogen)
(Ammonium citrate, dibasic)
(Diammonium citrate)
(Diammonium citrate, hydrogen)
Ammonium citrate
(Ammonium citrate, tribasic)
(Triammonium citrate)
Ammonium cobalt sulfate
(Ammonium cobaltous sulfate)
Ammonium cupric chloride
(Ammonium chlorocuprate (II))
(Diammonium copper tetrachloride)
(Diammonium tetrachlorocuprate)
Ammonium cyanate
(Ammonium isocyanate)
Molecular
Weight*
96.09
79.06
548.23
486.22
101.49
117.49
53.49
152.07
252.06
265.17
226.19
243.22
289.14
241.43
60.06
NH3
Equivalent
Wt%
35.45
21.54
6.213
7.005
16.78
14.49
31.84
22.40
13.51
6.422
15.06
21.01
11.78
14.11
28.35
CAS Number
506-87-3
1066-33-7
16774-21-3
13083-04-0
10192-29-7
7790-98-9
12125-02-9
7788-98-9
7789-09-5
13548-43-1
3012-65-5
3458-72-8
13596-46-8
15610-76-1
22981-32-4
D-ll
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Table D-l (Continued)
Chemical Name
Ammonium cyanide
Ammonium cyanoaurate, monohydrate
(Ammonium tetracyanoaurate, monohydrate)
Ammonium cyanoaurate
(Ammonium dicyanoaurate)
Ammonium ferricyanide
(Ammonium hexacyanoferrate (III))
(Triammonium hexacyanoferrate)
Ammonium ferrocyanide
(Ammonium hexacyanoferrate (II))
(Tetraammonium ferrocyanide)
(Tetraammonium hexacyanoferrate)
Ammonium fluoride
Ammonium fluoride
(Ammonium difluoride)
(Ammonium bifluoride)
(Ammonium fluoride, hydrogen)
(Ammonium difluoride, hydrogen)
(Ammonium bifluoride, hydrogen)
Ammonium fluoroborate
(Ammonium tetrafluoroborate)
Ammonium fluorogermanate (IV)
(Ammonium hexafluorogermanate (IV))
(Diammonium hexafluorogermanate)
Ammonium fluorophosphate
(Ammonium hexafluorophosphate)
Ammonium fluorosulfate
(Ammonium fluorosulfonate)
Ammonium formate
Ammonium gallium sulfate
Ammonium hydroxide
Ammonium iodide
Ammonium iridium chloride
(Ammonium chloroiridate (III))
(Ammonium hexachloroiridate)
(Triammonium hexachloroiridate)
Ammonium iron sulfate
(Ammonium ferric sulfate)
(Ammonium iron disulfate)
Molecular
Weight*
44.06
319.07
267.04
266.07
284.11
37.04
57.04
104.84
222.66
163.00
117.10
63.06
282.90
35.05
144.94
459.05
269.02
NH3
Equivalent
Wt%
38.65
5.337
6.377
19.20
23.98
45.98
29.86
16.24
15.30
10.45
14.54
27.01
6.020
48.59
11.75
11.13
6.330
CAS Number
12211-52-8
14323-26-3
31096-40-9
14221-48-8
14481-29-9
12125-01-8
1341-49-7
13826-83-0
16962-47-3
16941-11-0
13446-08-7
540-69-2
15335-98-5
1336-21-6
12027-06-4
15752-05-3
10138-04-2
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Table D-l (Continued)
Chemical Name
Ammonium iron sulfate
(Ammonium ferrous sulfate)
(Diammonium iron disulfate)
(Diammonium ferrous disulfate)
Ammonium lactate
(Ammonium 2-hydroxypropionate)
Ammonium laurate
(Ammonium dodecanoate)
Ammonium magnesium sulfate
Ammonium malate
Ammonium malate, hydrogen
(Ammonium bimalate)
Ammonium molybdate
(Diammonium molybdate)
Ammonium molybdate
(Ammonium heptamolybdate)
(Ammonium molybdate, hydrate)
(Ammonium molybdate, tetrahydrate)
(Ammonium />aramolybdate, tetrahydrate)
Ammonium nickel chloride, hexahydrate
Ammonium nickel sulfate
(Ammonium nickel sulfate, hexahydrate)
(Ammonium nickel disulfate, hexahydrate)
(Diammonium nickel disulfate, hexahydrate)
Ammonium nitrate
Ammonium nitrate sulfate
Ammonium nitrite
Ammonium oleate
Ammonium oxalate
Ammonium palladium chloride
(Ammonium chloropalladate (II))
(Ammonium tetrachloropalladte (II))
(Diammonium tetrachloropalladate)
Ammonium phosphate
(Ammonium orthophosphate)
Molecular
Weight*
286.05
107.11
217.35
252.50
168.15
151.12
196.01
1,163.8
183.09
286.88
80.04
212.18
64.04
299.50
124.10
284.31
149.09
NH3
Equivalent
Wt%
11.91
15.90
7.835
13.49
20.26
11.27
17.38
8.780
9.301
11.87
21.28
24.08
26.59
5.686
27.45
11.98
34.27
CAS Number
10045-89-3
515-98-0
2437-23-2
14727-95-8
6283-27-8
5972-71-4
13106-76-8
12054-85-2
16122-03-5
7785-20-8
6484-52-2
12436-94-1
13446-48-5
544-60-5
1113-38-8
13820-40-1
10124-31-9
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Table D-l (Continued)
Chemical Name
Ammonium phosphate
(Ammonium biphosphate)
(Ammonium phosphate, hydrogen)
(Ammonium phosphate, dihydrogen)
(Ammonium orthophosphate, dihydrogen)
(Ammonium phosphate, monobasic)
Ammonium phosphate
(Ammonium phosphate, hydrogen)
(Ammonium orthophosphate, monohydrogen)
(Ammonium phosphate, dibasic)
(Ammonium orthophosphate, dibasic)
(Diammonium phosphate)
(Diammonium orthophosphate)
(Diammonium phosphate, hydrogen)
(Diammonium phosphate, monohydrogen)
(Diammonium orthophosphate, hydrogen)
Ammonium phosphinate
(Ammonium hypophosphite)
Ammonium phosphite
(Ammonium biphosphite)
(Ammonium phosphite, dihydrogen)
Ammonium picramate
Ammonium propionate
Ammonium rhodium chloride
(Ammonium chlororhodate (III))
(Ammonium hexachlororhodate (III))
(Triammonium rhodium hexachloride)
(Triammonium hexachlororhodate)
Ammonium salicylate
(Ammonium 2-hydroxybenzoate)
Ammonium selenide
Ammonium silicon fluoride
(Ammonium fluorosilicate)
(Ammonium hexafluorosilicate)
(Diammonium silicon hexafluoride)
(Diammonium fluorosilicate)
(Diammonium hexafluorosilicate)
Ammonium stearate
(Ammonium octadecanoate)
Ammonium succinate
(Diammonium succinate)
Molecular
Weight*
115.03
132.06
83.03
99.03
216.15
91.11
369.74
155.15
115.04
178.15
301.51
152.15
NH3
Equivalent
Wt%
14.80
25.79
20.51
17.20
7.879
18.69
13.82
10.98
29.61
19.12
5.648
22.39
CAS Number
7722-76-1
7783-28-0
7803-65-8
13446-12-3
1134-85-6
17496-08-1
15336-18-2
528-94-9
66455-76-3
16919-19-0
1002-89-7
2226-88-2
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Table D-l (Continued)
Chemical Name
Ammonium sulfamate
(Ammonium amidosulfate)
(Ammonium amidosulfonate)
Ammonium sulfate
(Diammonium sulfate)
Ammonium sulfate
(Ammonium bisulfate)
(Ammonium sulfate, hydrogen)
(Ammonium sulfate, monohydrogen)
Ammonium persutf ate
(Ammonium peroxy sulfate)
(Ammonium peroxy disulfate)
(Diammonium persulfate)
(Diammonium peroxy difulsite)
Ammonium sulfide
(Ammonium bisulfide)
(Ammonium sulfide, hydrogen)
Ammonium sulfide
(Ammonium monosulfide)
(Diammonium sulfide)
Ammonium sulfide
(Diammonium pentasulfide)
Ammonium sulfite, monohydrate
(Diammonium sulfite, monohydrate)
Ammonium sulfite
(Ammonium bisulfite)
(Ammonium sulfite, hydrogen)
Ammonium tetrachloroaurate (III), hydrate
Ammonium thiocarbamate
Ammonium thiocarbonate
(Diammonium trithiocarbonate)
Ammonium thiocyanate
(Ammonium isothiocyanate)
(Ammonium sulfocyanate)
(Ammonium rhodanate)
(Rhodanid)
Ammonium dithionate
Ammonium thiosulfate
(Ammonium hyposulfite)
(Diammonium thiosulfate)
Molecular
Weight*
114.12
132.13
115.10
228.19
51.11
68.14
196.39
116.13
99.10
356.82
94.13
144.27
76.12
196.19
148.20
NH3
Equivalent
Wt%
14.92
25.78
14.80
14.93
33.32
49.99
17.34
29.33
17.18
4.772
18.09
23.61
22.37
17.36
22.98
CAS Number
7773-06-0
7783-20-2
7803-63-6
7727-54-0
12124-99-1
12135-76-1
12135-77-2
7783-11-1
10192-30-0
13874-04-9
16687-42-6
13453-08-2
1762-95-4
60816-52-6
7783-18-8
D-15
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Chemical Name
Ammonium tin bromide
(Ammonium bromostannate (IV))
(Ammonium hexabromostannate (IV))
(Diammonium hexabromostannate)
Ammonium tin chloride
(Ammonium chlorostannate (IV))
(Ammonium hexachlorostannate (IV))
(Diammonium tin hexachloride)
(Diammonium hexachlorostannate)
Ammonium titanium fluoride
(Ammonium fluorotitanate (IV))
(Ammonium hexafluorotitanate (IV))
(Diammonium titanium hexafluoride)
(Diammonium hexafluorotitanate)
Ammonium titanium oxalate, monohydrate
(Diammonium dioxalatooxotitanate, monohydrate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Hexaammonium tungstate)
Ammonium tungstate
(Ammonium tungstate (VI))
(Ammonium />aratungstate)
(Decaammonium tungstate)
Ammonium valerate
(Ammonium pentoate)
Ammonium zinc chloride
(Ammonium chlorozincate)
(Ammonium tetrachlorozincate)
(Diammonium tetrachlorozincate)
Molecular
Weight*
634.19
367.48
197.95
276.00
1,779.2
3,058.6
119.16
243.27
NH3
Equivalent
Wt%
5.371
9.269
17.21
12.34
5.743
5.568
14.29
14.00
CAS Number
16925-34-1
16960-53-5
16962-40-6
10580-03-7
12028-06-7
11120-25-5
42739-38-8
14639-97-5
*For hydrated compounds, e.g., ammonium sulfite, monohydrate, the molecular weight excludes the weight of the hydrate portion.
D-16
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INDEX
The pages listed in bold text in the index correspond to the primary uses or definitions of the
associated term. Additionally, this index includes a list of primary purposes for examples and
common errors that are presented throughout the document.
Abrasive cleaning 4-33 to 4-37
Activity
Chemical use, subcategories 3-7 to 3-11
Exemption (see Exemptions)
Thresholds (see Threshold)
Air emissions
Fugitive 4-4, 4-21, 4-23 to 4-24, 4-35, 4-36, 4-38, 4-40, 4-42, 4-45, 4-48,
4-49, 4-54, 4-56, 4-62
Stack or point source 4-5, 4-23, 4-24, 4-35, 4-36, 4-48, 4-49, 4-53, 4-62
Article exemption (see Exemptions)
Automated toxic chemical release inventory software (ATRS) 2-14
Chemical-specific
Acid aerosols 3-6 to 3-7, 3-15
Ammonia 2-12, 3-5, 3-18 to 3-20, C-4, Appendix D
Metals/metal compounds 3-5, 3-15 to 3-17, 4-7, 4-10 to 4-15, 4-20,
4-33, 4-34, 4-43, 4-46, 4-56, 4-58, 4-60
Nitrate compounds 2-12, 3-6, 4-20, Appendix C
Zinc 2-13, 3-5, 4-20, 4-33, 4-34, 4-40, 4-43, 4-46
Cleaning/degreasing 4-37 to 4-39
Example, cleaning/degreasing 4-40
Combustion 3-15, 3-18, 3-19, 4-3, 4-10, 4-12 to 4-14, 4-23
For energy recovery off-site 4-13 to 4-14
For energy recovery on-site 4-12 to 4-13
For treatment off-site 4-15
For treatment on-site 4-10
Common errors
Assuming a threshold is exceeded 3-21
Coincidental manufacture 2-13
Double counting 4-16
Exempt activities 3-12
Mass balance 4-21
Mixture components 3-4
Shipping container residue 4-8
Threshold determination for recirculation 3-8
Treatment efficiencies 4-19
Zero release and other waste management quantities 3-22
Container residue 4-8 to 4-10, 4-45, 4-49, 4-56
Example, container residue 4-8 to 4-10
Curing 4-30, 4-32, 4-48, 4-53, 4-54, 4-58, 4-60 to 4-62
Index-i
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INDEX (Continued)
De minimis (see Exemptions)
Example, de minimis 3-13
Example, de minimis concentration ranges 3-14
Degreasing (see Cleaning)
Disposal 2-12, 2-13, 2-16, 3-9, 4-15, 4-20
Land, on-site 4-6 to 4-7
Land, off-site 4-7 to 4-8, 4-12 to 4-13, 4-33, 4-36, 4-38
Documentation (see Recordkeeping)
Double counting 4-6, 4-16, 4-39
Common error, double counting 4-16
Electrodeposition 1-1, 2-4, 4-1, 4-30, 4-41, 4-54 to 4-60
Emission factors 4-17, 4-18, 4-21 to 4-23, 4-25, B-6
Example, emission factors 4-23, B-6
Employee equivalent calculation 2-7 to 2-8
Example, calculating employees 2-8
Full-time employee 2-7, 2-8
Energy recovery (see Combustion for energy recovery)
Engineering calculation 4-17, 4-18, 4-22, 4-23 to 4-25, 4-38, 4-42, 4-50, B-l
Example, engineering calculations 4-24
EPCRA hotline 1-2, 1-3, 1-5, 2-9, 2-14
Establishment 2-1, 2-5 to 2-8
Example, multiple establishments 2-2
Example, primary SIC code 2-7
Examples
Abrasive surface preparation 4-36
Article exemption 3-17
Chemical processing aid 3-11
Chemicals in process water 3-19
Cleaning/degreasing (estimating fugitive emissions) 4-40
Container residue 4-8, 4-10
De minimis 3-13
De minimis concentration ranges 3-14
Electrodeposition 4-58
Emission factors 4-23, B-6
Employee equivalent calculation 2-8
Engineering calculation 4-24
Form A threshold 2-16
Fugitive releases 4-40
Laboratory exemption 3-17
Mass balance 4-21
Monitoring data 4-19, 4-24, 4-43
Motor vehicle exemption 3-18
Multiple establishments 2-2
On-site waste treatment 4-11
Index-ii
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INDEX (Continued)
Personal use exemption 3-18
Phosphating (wastewater discharge) 4-47
Primary SIC code 2-7
Process equipment chemical use 3-19
Relabeling 2-13
Rinsing (estimating fugitive emissions) 4-43
Spray application 4-53
Stack release 4-36, 4-53
Threshold determination 3-7
Threshold worksheet 3-23
Treatment of wastes from off site 2-13
Xylene isomers 3-8
Exempt activities 3-1, 3-7, 3-12, 3-19
Common error, exempt activities 3-12
Exemptions 3-12
Activity-related 3-17
Article 3-10, 3-15 to 3-17, 4-33
De minimis 3-12 to 3-15, C-3, D-3
Drawn from environment 3-19
Evaluation of 3-12
Facility-related 3-17
Grounds maintenance 3-18
Janitorial 3-18
Laboratory 2-7, 3-17
Motor vehicle 3-18
Personal use, example 3-18
Structural components 3-18
Facility
Auxiliary facility 2-6
Covered facility 2-6, 2-7, 2-18
Multi-establishment facilities (see Establishments)
Pilot plant 2-7, 3-17
Facility-related exemption (see Exemption)
Flash-off 4-30, 4-32, 4-48, 4-53, 4-60 to 4-62
Form A 1-4 to 1-5, 2-1, 2-2, 2-14 to 2-16, 2-18, 3-20
Example Form A threshold 2-16
Form R 1-3 to 1-5, 2-2, 2-14 to 2-15, 3-20, 4-7, 4-9 to 4-17, 4-19, 4-21, 4-22, 4-25,
4-26, 4-28, 4-39, 4-47, 4-52, 4-53, 4-58, 4-59
Impurity 2-12, 3-9, 3-12, 3-13
Laboratory exemption (see Exemption)
Manufacture/Manufacturing 2-8, 2-12, 3-5, 3-9
Byproduct 3-14, 3-15
Coincidental manufacture 2-13, 3-9, 3-13
Manufacturing subcategories 3-9
Index-iii
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INDEX (Continued)
Mass balance 4-17, 4-18, 4-19 to 4-21, 4-38, 4-42, 4-57, 4-62
Example, mass balance 4-21
Common error, otherwise used chemicals (see otherwise use) 4-21
Mechanical cleaning (see Abrasive cleaning)
Metal compound (see Chemical-specific)
Methods (see Reportable amount estimate methods)
Mixture 2-2, 2-8, 2-13, 3-1 to 3-4, 3-8 to 3-14, 3-23
Monitoring data 4-17 to 4-20, 4-51, 4-57, B-l
Example, monitoring data 4-19, 4-24, 4-43
Motor vehicle exemption (see Exemption)
MSDS 3-3, 3-11
Otherwise use 2-8, 2-12, 3-10
Common error, mass balance for otherwise used chemicals 4-21
Otherwise use subcategories 3-10
Owner/operator 1-3
Penalties 1-4
Phosphating 2-13, 3-9, 4-20, 4-43 to 4-47
Pilot plant (see Facility)
Point source (see Air emissions)
POTW 4-7, 4-10, 4-11, 4-15, 4-16, 4-18, 4-19, 4-38, 4-42,
4.45 to 4-47, 4-49, 4-56 to 4-59, 4-60
Process/processing 2-8, 2-12, 3-9
Process equipment 3-18, 3-19, 4-49, 4-52, 4-56
Example, process equipment chemical use 3-19
Process water 3-19, 4-19
Example, chemicals in process water 3-19
Processing subcategories 3-9
Recordkeeping 2-17 to 2-19
Recycling 3-8, 3-16, 3-17, 3-21, 4-35, 4-58
Off-site 4-14
On-site 4-14
Relabeling, example 2-13
Release Chapter 4
Accidental 4-15
Estimates (steps to calculate) 4-1, 4-16
Sources 4-3
Types 4-4
Remediation 3-20,4-16
Repackaging 2-13, 3-10
Reportable amount estimate methods 1-4, 2-15 to 2-16
Emission factors 4-21
Engineering calculations 4-23
Mass balance 4-19
Monitoring data/records 4-18
Index-iv
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INDEX (Continued)
Reporting criteria 2-1
Reuse 3-8,3-19
Rinsing 4-32, 4-41 to 4-43, 4-46
Sources 4-3
Spray application 1-1, 4-1, 4-30, 4-47 to 4-53
Standard Industrial Classification (SIC) 2-4 to 2-7
Primary SIC code 2-6, 2-7
Supplier notification 3-4
Surface preparation 2-9, 4-30, 4-32, 4-36, 4-58
Technically qualified individual 3-17
Threshold worksheet 3-23 to 3-25
Thresholds 3-7
Common error, threshold determination 3-8
Example, threshold determination 3-7
Threshold determination Chapter 3, 3-20
Threshold worksheet 3-24
Total annual reportable amount (see Reportable amount)
Trade secret 1-4, 2-17
Transfers 4-7, 4-13 to 4-16, 4-20
Treatment efficiency 4-10, 4-11, 4-19
Treatment for destruction
On-site 4-10 to 4-15
Off-site 4-15 to 4-16
TRI database 2-16
Types 4-4
Waste management Chapter 4
Waste treatment (see Treatment for destruction)
Common error, treatment efficiencies 4-19
Example, on-site waste treatment 4-11
Example, treatment of wastes from off site 2-13
Wastewater discharge 4-6, 4-38, 4-42, 4-45, 4-47, 4-56, B-7
Wastewater treatment 4-7, 4-11, 4-19 to 4-20, 4-43, 4-51, 4-57, 4-59
Index-v
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