EPA
260­
B­
01­
015
September
2001
Office
of
Environmental
Information
Washington,
DC
20460
United
States
Environmental
Protection
Agency
Emergency
Planning
and
Community
Right­
To­
Know
Act
Section
313
Reporting
Guidance
for
the
Production
of
Pulp,
Paper
and
Paperboard
Industry
DISCLAIMER
This
guidance
is
intended
to
assist
industry
with
EPCRA
section313
reporting
for
the
pulp,
paper
and
paperboard
industry.
In
addition
to
providing
an
overview
of
aspects
of
the
statutory
and
regulatory
requirements
of
the
EPCRA
section
313
program,
this
document
also
provides
recommendations
and
emission
factors
to
assist
industry
with
EPCRA
reporting.
These
recommendations
do
not
supercede
any
statutory
or
regulatory
requirements,
are
subject
to
change,
and
are
not
independently
binding
on
either
EPA
or
covered
facilities.
Additionally,
if
a
conflict
exists
between
this
guidance
and
the
statutory
or
regulatory
requirements,
the
conflict
must
be
resolved
in
favor
of
the
statute
or
regulation.
Although
EPA
encourages
industry
to
consider
these
recommendations
and
emission
factors,
in
reviewing
this
document,
industry
should
be
aware
that
these
recommendations
and
emission
factors
were
developed
to
address
common
circumstances
at
typical
facilities.
The
circumstances
at
a
specific
facility
may
significantly
differ
from
those
contemplated
in
the
development
of
this
document.
Thus
individual
facilities
may
find
that
the
recommendations
and
emission
factors
provided
in
this
document
are
inapplicable
to
their
processes
or
circumstances,
and
that
alternative
approaches
or
information
are
more
accurate
and/
or
more
appropriate
for
meeting
the
statutory
and
regulatory
requirements
of
EPCRA
section
313.
Facilities
are
encouraged
to
contact
the
Agency
with
any
additional
or
clarifying
questions
about
the
recommendations
and
emission
factors
in
this
document,
or
if
the
facility
believes
that
EPA
has
incorrectly
characterized
a
particular
process
or
recommendation.

Additional
guidance
documents,
including
industry­
specific
and
chemical­
specific
guidance
documents,
are
available
at
the
EPA
TRI
website:
http://
www.
epa.
gov/
tri/.
iii
TABLE
OF
CONTENTS
Page
ACKNOWLEDGMENT
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vii
OVERVIEW
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viii
CHAPTER
1
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INTRODUCTION
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1­
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1.0
PURPOSE
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1­
1
1.1
Background
on
EPCRA
Section
313
and
PPA
Section
6607
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1­
2
CHAPTER
2
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REPORTING
REQUIREMENTS
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2­
1
2.0
PURPOSE
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2­
1
2.1
Must
You
Report?
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2­
2
2.2
SIC
Code
Determination
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2­
3
2.3
Number
of
Employees
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2­
6
2.4
Manufacturing,
Processing,
and
Otherwise
Use
of
EPCRA
Section
313
Chemicals
or
Chemical
Categories
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2­
8
2.5
Activity
Categories
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2­
11
2.6
Persistent,
Bioaccumulative,
and
Toxic
(
PBT)
Chemicals
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2­
15
2.7
How
Do
You
Report?
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2­
19
2.8
Form
R
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2­
20
2.9
Form
A
Certification
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2­
20
2.10
Trade
Secrets
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2­
22
2.11
Recordkeeping
and
Penalty
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2­
23
CHAPTER
3
­
EPCRA
SECTION
313
CHEMICAL
OR
CHEMICAL
CATEGORY
ACTIVITY
THRESHOLD
DETERMINATIONS
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3­
1
3.0
PURPOSE
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3­
1
3.1
Step
1
­
Identify
Which
EPCRA
Section
313
Chemicals
or
Chemical
Categories
are
Manufactured
(
Including
Imported),
Processed,
or
Otherwise
Used
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3­
1
Qualifiers
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3­
5
3.2
Step
2
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Identify
the
Activity
Category
and
Any
Exempt
Activities
for
Each
EPCRA
Section
313
Chemical
and
Chemical
Category
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3­
8
3.2.1
Concentration
Ranges
for
Threshold
Determination
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3­
13
3.2.2
Evaluation
of
Exemptions
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3­
14
3.2.2.1
De
Minimis
Exemption
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3­
15
3.2.2.2
Articles
Exemption
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3­
18
3.2.2.3
Facility­
Related
Exemption
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3­
20
Laboratory
Activity
Exemption
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3­
20
3.2.2.4
Activity­
Related
Exemptions
(
Otherwise
iv
Use
Exemptions)
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3­
20
3.2.3
Additional
Guidance
on
Threshold
Calculations
for
Certain
Activities
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3­
22
3.2.3.1
Reuse
Activities
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3­
22
3.2.3.2
Remediation
Activities
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3­
23
3.2.3.3
Recycling
Activities
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3­
24
3.3
Step
3
­
Calculate
the
Quantity
of
Each
EPCRA
Section
313
Chemical
and
Chemical
Category
and
Determine
Which
Ones
Exceed
an
Activity
Threshold
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3­
24
CHAPTER
4
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ESTIMATING
RELEASE
AND
OTHER
WASTE
MANAGEMENT
QUANTITIES
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4­
1
4.0
PURPOSE
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4­
1
4.1
General
Steps
for
Determining
Release
and
Other
Waste
Management
Activity
Quantities
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4­
1
4.1.1
Step
1:
Prepare
a
Process
Flow
Diagram
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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
.
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4­
3
4.1.3
Step
3:
Identify
Release
and
Other
Waste
Management
Activity
Types
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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
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4­
18
4.1.4.1
Monitoring
Data
or
Direct
Measurement
(
code
M)
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4­
19
4.1.4.2
Mass
Balance
(
code
C)
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4­
20
4.1.4.3
Emission
Factors
(
code
E)
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4­
22
4.1.4.4
Engineering
Calculations
(
code
O)
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4­
25
4.1.4.5
Estimating
Release
and
Other
Waste
Management
Quantities
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4­
27
4.2
Determination
of
Release
and
Other
Waste
Management
Activity
Quantities
from
Production
of
Pulp,
Paper,
and
Paperboard
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4­
32
4.2.1
Pulp
Production
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4­
39
4.2.2
Paper
and
Paperboard
Production
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4­
44
5.0
REFERENCES
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5­
1
INDEX
Appendix
A
EPCRA
SECTION
313
GUIDANCE
RESOURCES
Appendix
B
BASIC
CALCULATION
TECHNIQUES
Appendix
C
UNIT
CONVERSION
FACTORS
v
LIST
OF
TABLES
Page
2­
1
SIC
Codes
Covered
by
EPCRA
Section
313
Reporting
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2­
3
2­
2
EPCRA
Section
313
Chemicals
and
Chemical
Categories
Commonly
Reported
in
1997
for
Pulp
Mills,
Paper
Mills,
and
Paperboard
Mills
(
SIC
Codes
2611,
2621,
and
2631)
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2­
10
2­
3
Activity
Categories
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2­
13
2­
4
Reporting
Thresholds
for
EPCRA
Section
313
Listed
PBT
Chemicals
.
.
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2­
16
2­
5
Chemicals
Included
in
the
EPCRA
Section
313
Dioxin/
Dioxin­
Like
Compound
Category
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.
2­
17
2­
6
Chemicals
Included
in
the
EPCRA
Section
313
PAC
Category
.
.
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2­
18
3­
1
Reporting
Thresholds
.
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3­
8
3­
2
Description
of
Manufacturing
Subcategories
.
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3­
10
3­
3
Description
of
Processing
Subcategories
.
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3­
11
3­
4
Description
of
Otherwise
Use
Subcategories
.
.
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3­
12
3­
5
EPCRA
Section
313
Reporting
Threshold
Worksheet
.
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3­
27
3­
6
Sample
EPCRA
Section
313
Reporting
Threshold
Worksheet
.
.
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3­
28
4­
1
Summary
of
Residue
Quantities
From
Pilot­
Scale
Experimental
Study
a,
b
.
.
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.
.
4­
9
4­
2
Potential
Data
Sources
for
Release
and
Other
Waste
Management
Calculations
.
.
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4­
19
4­
3
Release
and
Other
Waste
Management
Quantity
Estimation
Worksheet
.
.
.
.
4­
28
4­
4
Pulp
Production
Process
and
Associated
EPCRA
Section
313
Chemicals
and
Chemical
Categories
.
.
.
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4­
36
vi
LIST
OF
FIGURES
Page
2­
1
EPCRA
Section
313
Reporting
Decision
Diagram
.
.
.
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2­
4
4­
1
Release
and
Other
Waste
Management
Activity
Calculation
Approach
.
.
.
.
.
.
4­
2
4­
2
Possible
Release
and
Other
Waste
Management
Types1
for
EPCRA
Section
313
Chemicals
and
Chemical
Categories
.
.
.
.
.
.
.
.
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.
4­
5
4­
3
Process
Flow
Diagram
­
Overall
Process
.
.
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4­
33
4­
4
Process
Flow
Diagram
­
Pulp
Production
.
.
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.
4­
40
4­
5
Process
Flow
Diagram
­
Production
of
Paper
and
Paperboard
.
.
.
.
.
.
.
.
.
.
.
.
4­
45
vii
ACKNOWLEDGMENT
The
U.
S.
EPA
wishes
to
acknowledge
the
valuable
contributions
made
by
the
staff
and
members
of
the
National
Council
of
the
Paper
Industry
for
Air
and
Streams
Improvement
(
NCASI).
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
Ms.
Susan
Crowley,
Manager,
Environmental
Affairs,

AFPA,
and
Mr.
John
Pinkerton,
Ph.
D.,
Vice
President,
Air
Quality,
NCASI.
viii
OVERVIEW
This
document
supersedes
the
booklet
entitled
Title
III
Section
313
Release
Reporting
Guidance,
Estimating
Chemical
Releases
from
Paper
and
Paperboard
Production
(
EPA­
560/
4­
88­
004k),
dated
February
1988.
It
is
intended
to
assist
establishments
and
facilities
in
the
production
of
pulp,
paper,
and
paperboard
industry
in
complying
with
the
Emergency
Planning
and
Community
Right­
To­
Know
Act
(
EPCRA)
Section
313
and
Pollution
Prevention
Act
(
PPA)
Section
6607
reporting
requirements,
including
the
preparation
of
Form
R
or
Form
A
certification
statement.
The
EPCRA
Section
313
program
is
commonly
referred
to
as
the
Toxics
Release
Inventory
(
TRI).

The
principal
differences
in
this
new
document
include:


More
detailed
examples;


New
EPCRA
Section
313
regulations
and
guidance
developed
since
1988;


PPA
Section
6607
reporting
requirements;


U.
S.
Environmental
Protection
Agency's
(
U.
S.
EPA's)
guidance
on
various
issues
specific
to
production
of
pulp,
paper,
and
paperboard;
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)

(
2000
version,
EPA­
745­
B­
01­
001).
It
is
organized
to
provide
a
step­
by­
step
guide
to
compliance
with
EPCRA
Section
313
and
PPA
Section
6607,
starting
with
how
to
determine
if
your
facility
must
report
and
ending
with
guidance
for
estimating
release
and
other
waste
management
activity
quantities.

It
is
recognized
that
not
all
pulp,
paper,
and
paperboard
production
establishments
will
have
all
unit
operations
described
in
this
document.
However,
each
of
the
unit
operations
discussed
are
common
operations
found
in
the
production
of
pulp,
paper,
and
paperboard
establishments
covered
by
EPCRA
Section
313
reporting
requirements.
To
use
this
guidance,
ix
select
the
operation,
or
combination
of
operations,
that
most
closely
fits
the
activities
at
your
establishment.

Chapter
1
introduces
EPCRA
Section
313
and
PPA
Section
6607
reporting
and
provides
a
brief
background
on
Section
313
of
EPCRA
and
Section
6607
of
PPA.

Chapter
2
discusses
reporting
requirements
and
begins
with
how
to
determine
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
for
any
toxic
chemicals.
If
you
answer
"
Yes"
to
the
first
three
questions
and
"
No"
to
the
forth,
you
are
not
required
to
submit
an
EPCRA
Section
313
report
for
that
chemical
or
chemical
category.
If
you
answer
"
Yes"
to
ALL
four
questions,

the
next
step
is
to
determine
what
kind
of
report
you
must
prepare,
a
Form
R
or
Form
A
certification
statement
(
40
CFR
§
372.22).
Chapter
2
provides
detailed
information
on
the
requirements
for
each
kind
of
report.
Chapter
2
concludes
with
a
discussion
on
how
to
address
trade
secrets
and
the
records
that
should
be
kept
to
support
your
reporting.

Chapter
3
discusses
ways
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:
x

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
ways
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
toxic
chemical
release
and
other
waste
management
activities;


Identification
of
the
potential
types
of
release
and
other
waste
management
activities
from
each
source;
and

Determination
of
the
most
appropriate
methods
for
estimating
the
quantities
of
EPCRA
Section
313
chemical
and
chemical
category
release
and
other
waste
management
activities.

The
second
part
of
Chapter
4
is
organized
by
the
typical
activities
in
pulp,
paper,

and
paperboard
production
operations
where
EPCRA
Section
313
chemicals
and
chemical
categories
are
used.
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
pulp,
paper,

and
paperboard
production
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
American
Forest
and
Paper
Association
and
the
National
xi
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
and
on
questions
received
by
the
EPCRA
Hotline.
1­
1
CHAPTER
1
­
INTRODUCTION
1.0
PURPOSE
The
purpose
of
this
guidance
manual
is
two­
fold.
The
primary
purpose
is
to
assist
pulp,
paper,
and
paperboard
production
facilities
in
complying
with
the
reporting
requirements
of
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
of
1986
(
EPCRA)

and
of
Section
6607
of
the
Pollution
Prevention
Act
of
1990
(
PPA).
This
manual
explains
the
EPCRA
Section
313
reporting
requirements
and
discusses
specific
release
and
other
waste
management
activities
encountered
at
many
facilities
that
conduct
pulp,
paper,
and
paperboard
production
operations.
Since
each
plant
is
unique,
the
recommendations
presented
may
have
to
be
modified
for
your
particular
facility.
The
secondary
purpose
is
to
provide
information
to
other
interested
parties
(
such
as
management,
legal
professionals,
inspectors,
consultants,
teachers,

students,
and
the
general
public)
about
the
processes
and
some
of
the
toxic
chemicals
used
in
this
industry.

This
manual
is
intended
solely
for
guidance
and
does
not
alter
any
statutory
or
regulatory
requirements.
The
document
should
be
used
in
conjunction
with
the
appropriate
statutes
and
regulations,
but
does
not
supersede
them.
Accordingly,
the
reader
should
consult
other
applicable
documents
(
for
example,
the
statute,
the
Code
of
Federal
Regulations
(
CFR),

relevant
preamble
language,
and
the
current
Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions
(
TRI
Forms
and
Instructions))
(
2000
version,
EPA­
745­
B­
01­
001).

This
document
supersedes
the
1988
document
entitled
Title
III
Section
313
Release
Reporting
Guidance,
Estimating
Chemical
Releases
from
Paper
and
Paperboard
Production
(
EPA­
560/
4­
88­
004k).
This
new
document
includes:


More
detailed
examples;


New
EPCRA
Section
313
regulations
and
guidance
developed
since
1988;


PPA
Section
6607
reporting
requirements;
1­
2

U.
S.
Environmental
Protection
Agency's
(
U.
S.
EPA's)
guidance
on
various
issues
specific
to
production
of
pulp,
paper,
and
paperboard;
and

EPCRA
Section
313
issues
regarding
processes
not
discussed
in
the
earlier
document.

This
document
supplements
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
the
production
of
pulp,
paper,
and
paperboard.
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
(
2002
version),
facilities
should
be
able
to
provide
complete
and
accurate
information
for
EPCRA
Section
313
reporting.
Additional
discussions
on
specific
issues
can
be
found
in
U.
S.
EPA's
current
edition
of
EPCRA
Section
313,
Questions
and
Answers
(
the
1998
edition
is
EPA
745­
B­
98­
004),
which
is
available
on
the
U.
S.
EPA's
TRI
website
(
http://
www.
epa.
gov/
tri)
or
by
contacting
the
EPCRA
Hotline
at
1­
800­
424­
9346.
In
the
Washington,
DC
metropolitan
area,
call
703­
412­
9810.

1.1
Background
on
EPCRA
Section
313
and
PPA
Section
6607
The
following
overview
of
EPCRA
Section
313
and
Section
6607
of
the
PPA,
will
provide
you
with
a
basic
understanding
of
the
objectives
and
requirements
of
this
program,
and
will
help
you
in
completing
your
forms.
1­
3
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
certification
statements)
on
over
600
EPCRA
Section
313
chemicals
and
chemical
categories
(
40
CFR
§
372.22).
Covered
facilities
report
the
amounts
released
or
otherwise
managed
as
waste
(
40
CFR
§
372.85).
However,
if
a
facility
meets
the
reporting
criteria
for
listed
toxic
chemicals,
the
facility
must
report
even
if
there
are
no
releases
or
other
waste
management
quantities
associated
with
these
chemicals
(
40
CFR
§
372.30(
a));
(
40
CFR
§
372.85(
b)(
15)).
Throughout
this
document,

whenever
EPCRA
Section
313
chemicals
are
discussed,
the
discussion
includes
toxic
chemical
categories,
as
appropriate.
Toxic
chemicals
or
chemical
categories
may
be
added
or
deleted
from
the
list
(
EPCRA
§
313
(
d)(
2)).
Therefore,
before
completing
your
annual
report,
be
sure
to
check
the
most
current
list
included
with
the
TRI
Forms
and
Instructions
when
evaluating
the
chemicals
and
chemical
categories
present
at
your
facility.
Copies
of
the
reporting
package
can
be
requested
from
the
EPCRA
Hotline,
1­
800­
424­
9346
or
accessed
through
TRI
web
site,
www.
epa.
gov/
tri/.

All
facilities
meeting
the
EPCRA
Section
313
reporting
criteria
must
report
the
annual
release
and
other
waste
management
activity
quantities
(
routine
and
accidental)
of
EPCRA
Section
313
chemicals
and
chemical
categories
to
all
environmental
media.
A
separate
report
is
required
for
each
EPCRA
Section
313
chemical
or
chemical
category
that
is
manufactured
(
including
imported),
processed,
or
otherwise
used
above
the
reporting
threshold
(
40
CFR
§
372.85).
The
reports
must
be
submitted
to
U.
S.
EPA
and
State
or
Tribal
governments,
on
or
before
July
1,
for
activities
in
the
previous
calendar
year
(
40
CFR
§
372.30(
d)).
On
July
1,
the
owner/
operator
of
the
facility
is
primarily
responsible
for
the
report,
even
if
the
owner/
operator
did
not
own
the
facility
during
the
reporting
year
(
40
CFR
§
372.5).
However,
property
owners
with
no
business
interest
in
the
operation
of
the
facility,
other
than
a
lessor
interest,
are
exempt
from
reporting
requirements
(
40
CFR
§
372.38(
e)).

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
1­
4
of
the
PPA.
This
database,
known
as
the
Toxics
Release
Inventory
(
TRI)
database,
can
be
accessed
through
the
following
sources:


U.
S.
EPA
Internet
site,
http://
www.
epa.
gov/
tri;


U.
S.
EPA
Internet
site,
http://
www.
epa.
gov/
triexplorer;


Envirofacts
Warehouse
Internet
site,
http://
www.
epa.
gov/
enviro;
and

Right­
to­
Know
network,
http://
www.
rtk.
net/
trisearch.
html.

However,
information
qualifying
as
a
trade
secret,
in
accordance
with
the
regulatory
requirements,
is
protected
from
public
release
(
40
CFR
§
350).
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.

Members
of
the
American
Forest
and
Paper
Association
and
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement
provided
input
on
common
problems,

specific
to
the
production
of
pulp,
paper,
and
paperboard,
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.
2­
1
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
under
common
control
with
such
person)
(
40
CFR
§
372.3).
A
facility
may
contain
more
than
one
establishment.
An
"
establishment"
is
defined
as,
"
an
economic
unit,
generally
at
a
single
physical
location,
where
business
is
conducted,
or
where
services
or
industrial
operations
are
performed"
(
40
CFR
§
372.3).

U.
S.
EPA
recognizes
that
for
business
reasons
it
may
be
easier
and
more
appropriate
for
establishments
at
one
facility
to
report
separately.
However,
the
combined
quantities
of
EPCRA
Section
313
chemicals
and
chemical
categories
manufactured,
processed,
or
otherwise
used
in
all
establishments
making
up
that
facility
must
be
considered
for
threshold
determinations
(
40
CFR
§
372.25(
c);
40
CFR
§
372.25(
d)).
Also,
the
combined
release
and
other
waste
management
activity
quantities
reported
singly
for
each
establishment
must
total
those
for
the
facility
as
a
whole.

Note
that
if
a
facility
is
comprised
of
more
than
one
establishment,
once
an
activity
threshold
is
met
by
the
facility,
providing
the
facility
meets
the
SIC
Code
and
employee
threshold
2­
2
criteria,
release
and
other
waste
management
activities
from
all
establishments
at
the
facility
must
be
reported
(
40
CFR
§
372.25(
c);
40
CFR
§
372.25(
d)).

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
the
release
and
other
waste
management
activities
of
toluene
from
your
facility,
or
two
Form
Rs,
one
from
each
establishment.
Please
note
that
you
may
be
eligible
to
file
one
Form
A
certification
for
the
facility
but
you
cannot
file
a
separate
Form
A
certification
statement
for
each
establishment.

2.1
Must
You
Report?

How
do
you
determine
if
your
facility
must
prepare
an
EPCRA
Section
313
report?
Your
answers
to
the
following
four
questions
will
help
you
decide
(
illustrated
by
Figure
2­
1):

1)
Is
the
primary
SIC
Code
for
your
facility
included
in
the
list
covered
by
EPCRA
Section
313
reporting
(
see
Section
2.2)?

2)
Does
your
facility
have
10
or
more
full­
time
employees
or
the
equivalent
(
see
Section
2.3)?

3)
Does
your
facility
manufacture
(
which
includes
importation),
process,
or
otherwise
use
EPCRA
Section
313
chemicals
or
chemical
categories
(
see
Section
2.4)?

4)
Does
your
facility
exceed
any
applicable
thresholds
of
EPCRA
Section
313
chemicals
or
chemical
categories
(
for
non­
PBT
chemicals:
25,000
pounds
per
year
for
manufacturing;
25,000
pounds
per
year
for
processing;
or
10,000
pounds
per
year
for
otherwise
use
­
see
Section
2.5;
For
PBT
chemicals
­
see
Section
2.6
for
applicable
thresholds)?

If
you
answered
"
No"
to
any
of
the
first
three
questions,
you
are
not
required
to
prepare
any
EPCRA
Section
313
reports.
If
you
answered
"
Yes"
to
ALL
of
the
first
three
questions,
you
must
complete
a
threshold
calculation
for
each
EPCRA
Section
313
chemical
at
2­
3
the
facility,
and
submit
an
EPCRA
Section
313
report
for
each
toxic
chemical
and
chemical
category
exceeding
the
applicable
threshold
(
40
CFR
§
372.22).

2.2
SIC
Code
Determination
Facilities
with
the
SIC
Codes
presented
in
Table
2­
1
are
covered
by
the
EPCRA
Section
313
reporting
requirements
(
40
CFR
§
372.22(
b)).

Table
2­
1
SIC
Codes
Covered
by
EPCRA
Section
313
Reporting
SIC
Codes
Industry
Qualifiers
10
Metal
Mining
Except
SIC
Codes
1011,
1081,
and
1094
12
Coal
Mining
Except
SIC
Code
1241
20
through
39
Manufacturing
None
4911,
4931,
and
4939
Electric
and
Other
Services
and
Combination
Utilities
Limited
to
facilities
that
combust
coal
and/
or
oil
for
the
purpose
of
generating
electricity
for
distribution
in
commerce
4953
Refuse
Systems
Limited
to
facilities
regulated
under
RCRA
Subtitle
C
5169
Chemicals
and
Allied
Products
None
5171
Petroleum
Bulk
Stations
and
Terminals
None
7389
Business
Services
Limited
to
facilities
primarily
engaged
in
solvent
recovery
services
on
a
contract
or
fee
basis
Pulp
mills,
paper
mills,
and
paperboard
mills
are
generally
covered
by
SIC
Codes
2611,
2621,
and
2631,
respectively.
You
should
determine
the
SIC
Code(
s)
for
your
facility,

based
on
the
activities
on
site.
For
assistance
in
determining
which
SIC
Code
best
suits
your
facility,
refer
to
Standard
Industrial
Classification
Manual,
1987
published
by
the
Office
of
Management
and
Budget
or
visit
the
U.
S.
Census
Bureau's
web
site
at
www.
census.
gov/
epcd/
www/
sic.
html.
2­
4
Figure
2­
1.
EPCRA
Section
313
Reporting
Decision
Diagram
2­
5
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
(
40
CFR
§
372.22).
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
(
53
FR
4503;
Standard
Industrial
Classification
Manual,
OMB,
1987).
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.
If
an
auxiliary
facility's
primary
function
is
to
support/
service
a
facility
with
a
covered
SIC
Code,
the
auxiliary
facility
assumes
the
covered
SIC
Code
as
its
primary
SIC
Code
and
must
consider
the
other
reporting
requirements
((
40
CFR,
§
372.22;
53
FR
4503)
40
CFR
Section
372.22)
to
determine
if
it
must
comply
with
the
EPCRA
Section
313
reporting
requirements.
However,
if
the
SIC
Code
for
the
primary
facility
is
not
covered
by
EPCRA
Section
313,
then
neither
the
primary
nor
the
auxiliary
facility
is
required
to
submit
a
report.

If
your
facility
has
more
than
one
SIC
Code
(
i.
e.,
several
establishments
with
different
SIC
Codes
are
owned
or
operated
by
the
same
entity
and
are
located
at
your
facility),

you
are
subject
to
reporting
requirements
if:


All
the
establishments
have
SIC
Codes
covered
by
EPCRA
Section
313;
OR

The
total
value
of
the
products
shipped
or
services
provided
at
establishments
with
covered
SIC
Codes
is
greater
than
50%
of
the
value
of
the
entire
facility's
products
and
services;
OR

Any
one
of
the
establishments
with
a
covered
SIC
Code
ships
and/
or
produces
products
or
provides
services
whose
value
exceeds
the
value
of
services
provided,
products
produced
and/
or
shipped
by
every
other
establishment
within
the
facility
(
40
CFR
§
372.22).
2­
6
Example
­
Primary
SIC
Code
A
facility
has
two
establishments.
The
first,
a
scrap
and
waste
materials
establishment,
is
in
SIC
Code
5093.
SIC
Code
5093
is
not
a
covered
SIC
Code.
However,
the
second
establishment,
a
paperboard
mill,
is
in
SIC
Code
2631,
which
is
a
covered
SIC
Code.
The
facility
also
determines
the
product
is
worth
$
50/
unit
as
received
from
the
establishment
in
the
non­
covered
SIC
Code
and
the
value
of
the
product
is
$
150/
unit
after
processing
by
the
establishment
in
the
covered
SIC
Code.
The
value
added
by
the
establishment
in
the
covered
SIC
Code
is
more
than
50%
of
the
product
value;
therefore,
the
primary
SIC
Code
is
2631,
a
covered
SIC
Code.
Thus,
the
establishment
is
covered
by
EPCRA
Section
313
reporting
and
the
entire
facility
(
i.
e.,
both
establishments)
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.
Likewise,
warehouses
that
qualify
as
auxiliary
facilities
of
covered
facilities
also
must
report,
provided
all
applicable
reporting
requirements
are
met
(
53
FR
4503).

While
you
are
currently
required
to
determine
your
facility's
reporting
eligibility
based
on
the
SIC
code
system
described
above,
it
is
important
to
be
aware
that
the
SIC
code
system
will
be
replaced
by
a
new
system
in
the
future.
On
April
9,
1997
(
62
FR
17287),
the
Office
of
Management
and
Budget
promulgated
the
North
American
Industrial
Classification
System
(
NAICS).
NAICS
is
a
new
economic
classification
system
that
replaces
the
SIC
code
system
as
a
means
of
classifying
economic
activities
for
economic
forecasting
and
statistical
purposes.
The
transition
to
the
new
NAICS
may
require
regulatory
actions.
As
a
result,
the
SIC
code
system
is
still
required
to
be
used
as
the
mechanism
to
determine
your
facility's
reporting
eligibility.
U.
S.
EPA
will
issue
notice
in
the
Federal
Register
to
inform
you
and
other
EPCRA
Section
313
facilities
of
its
plans
to
adopt
the
NAICS
and
how
facilities
should
make
their
NAICS
code
determination.

2.3
Number
of
Employees
If
your
facility
meets
SIC
Code
and
activity
threshold
criteria,
you
are
required
to
prepare
an
EPCRA
Section
313
report
if
your
facility
has
10
or
more
full­
time
employees
or
the
2­
7
equivalent
(
40
CFR
§
372.22(
a)).
A
full­
time
employee
equivalent
is
defined
as
a
work
year
of
2,000
hours.
If
your
facility's
employees
hours
total
20,000
or
more
hours
in
a
calendar
year,
you
meet
the
10
or
more
employee
threshold
criterion
(
40
CFR
§
372.3).

The
following
information
should
be
included
in
your
employee
calculations:


Owners;


Operations/
manufacturing
staff;


Clerical
staff;


Temporary
employees;


Sales
personnel;


Truck
drivers
(
employed
by
the
facility);


Other
non­
manufacturing
or
off­
site
facility
employees
directly
supporting
the
facility;


Paid
vacation
and
sick
leave;
and

Contractor
employees
(
maintenance,
construction,
etc.
but
excluding
contracted
truck
drivers
and
minor
intermittent
service
vendors
(
e.
g.,
trash
handlers)).

In
general,
if
an
individual
is
employed
or
hired
to
work
at
the
facility,
all
the
hours
worked
by
that
individual
(
including
paid
leave
and
overtime)
for
the
facility
should
be
counted
in
determining
if
the
20,000­
hour
criterion
has
been
met.

Example
­
Employee
Equivalent
Calculation
Your
facility
has
six
full­
time
employees
working
2,000
hours/
year.
You
also
employ
two
full­
time
sales
people
and
a
delivery
truck
driver
(
employed
by
the
facility)
who
are
assigned
to
the
plant,
each
working
2,000
hours/
year
but
predominantly
on
the
road
or
from
their
homes.
The
wastewater
treatment
system
(
on
site
and
owned
by
the
facility)
is
operated
by
a
contractor
who
spends
an
average
of
two
hours
per
day
and
five
days
per
week
at
the
plant.
Finally,
you
built
an
addition
to
the
plant
warehouse
during
the
year,
using
four
contractor
personnel
who
were
on
site
full
time
for
six
months
(
working
an
average
of
1,000
hours
each).
You
would
calculate
the
number
of
full­
time
employee
equivalents
as
follows:


Hours
for
your
nine
full­
time
employees
(
six
plant
personnel,
two
salespeople,
and
one
delivery
truck
driver)
are:
(
9
employees)
×
(
2,000
hours/
year)
=
18,000
hours/
year

Hours
for
the
wastewater
treatment
system
operator
are:
(
2
hours/
day)
×
(
5
days/
week)
×
(
52
weeks/
year)
=
520
hours/
year;
and

Hours
for
the
construction
crew
are:
(
4
contractors)
×
(
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
8
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,
determine
which
EPCRA
Section
313
chemicals
and
chemical
categories
are
manufactured,
processed,
or
otherwise
used
at
your
facility.
One
way
to
do
this
is
to
prepare
a
list
which
includes
all
toxic
chemicals
and
chemical
categories
found
in
mixtures
and
trade
name
products
at
all
establishments
at
the
facility.
This
list
should
then
be
compared
to
the
CURRENT
list
of
EPCRA
Section
313
chemicals
and
chemical
categories
found
in
the
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,
evaluate
the
activities
involving
each
toxic
chemical
and
chemical
category
and
determine
if
any
activity
thresholds
have
been
met.

The
original
list
of
toxic
chemicals
and
chemical
categories
subject
to
EPCRA
Section
313
reporting
was
a
combination
of
lists
from
New
Jersey
and
Maryland.
Refinements
to
the
list
have
been
made
and
changes
are
anticipated
to
continue.
The
list
can
be
modified
by
U.
S.

EPA
initiative,
or
industry
or
the
public
can
petition
U.
S.
EPA
to
modify
the
list
(
EPCRA
§
313
(
d)
+
(
e)).
When
evaluating
a
toxic
chemical
or
chemical
category
for
addition
or
deletion
from
the
list,
U.
S.
EPA
must
consider
the
toxic
chemical's
potential
acute
human
health
effects
and
chronic
human
health
effects
or
its
adverse
environmental
effects
(
EPCRA
§
313(
d)(
2)).
U.
S.

EPA
reviews
these
petitions
and
initiates
a
rulemaking
to
add
or
delete
the
toxic
chemical
or
chemical
category
from
the
list,
or
publishes
an
explanation
why
it
denied
the
petition
(
EPCRA
§
313(
e)(
1)).

Note
that
toxic
chemicals
and
chemical
categories
are
periodically
added,
delisted,

or
modified.
Therefore,
it
is
imperative
that
you
refer
to
the
appropriate
reporting
year's
list.

You
can
refer
to
the
U.
S.
EPA's
TRI
website,
http://
www.
epa.
gov/
tri,
for
updated
guidance.

Also,
note
that
a
list
of
synonyms
for
EPCRA
Section
313
chemicals
and
chemical
categories
can
be
found
in
the
U.
S.
EPA
publication
Common
Synonyms
for
Chemicals
Listed
Under
2­
9
Section
313
of
the
Emergency
Planning
and
Community
Right­
To­
Know
Act,
(
EPA
745­
R­
95­

008).
Table
2­
2
lists
the
EPCRA
Section
313
chemicals
and
chemical
categories
most
frequently
reported
for
paper
and
paperboard
production
facilities.
This
list
is
not
intended
to
be
all
inclusive
and
should
only
be
used
as
a
guide.
2­
10
Table
2­
2
EPCRA
Section
313
Chemicals
and
Chemical
Categories
Commonly
Reported*
in
1997
for
Pulp
Mills,
Paper
Mills,
and
Paperboard
Mills
(
SIC
Codes
2611,
2621,
and
2631)

EPCRA
Section
313
Chemical/
Chemical
Category
CAS
Registry
Number
Process/
Application
Acetaldehyde
75­
07­
0
Pulping,
bleaching,
and
chemical
recovery
operations
(
9)
Combustion
byproduct
Ammonia
7664­
41­
7
Sulfite
pulping
(
7,
9),
kraft
pulping,
black
liquor
pyrolysis,
smelt
recovery,
pH
adjustment,
wastewater
treatment
(
9)

Barium
Compounds
N040
Stock
preparation
(
7)

Biphenyl
92­
52­
4
Kraft
pulping
process
byproduct
Catechol
120­
80­
9
Kraft
pulping
process
byproduct
Certain
Glycol
Ethers
N230
Recovered
fiber
deinking
activities,
otherwise
used
Chlorine
7782­
50­
5
Bleaching,
water
&
wastewater
treatment
(
1,
9)
Manufacture
of
ClO2
(
9)

Chlorine
dioxide
10049­
04­
4
Bleaching
(
1,
7),
manufacture
Chloroform
67­
66­
3
Bleaching
(
1),
coincidental
manufacture
Chloromethane
74­
87­
3
Bleaching
(
1)
and
Kraft
recovery
furnace,
coincidental
manufacture
Chromium
compounds
N090
Equipment
maintenance;
manufactured/
processed
while
pretreating
pulp
with
chelating
agents
before
peroxide
bleaching
Catalytic
decomposition
agents;
combustion
byproduct
Copper
compounds
N100
Equipment
maintenance;
Cu(
NO3)
2
used
in
production
of
light­
sensitive
papers
Fungicides,
CuSO4
is
a
wood/
pulp
preservative,
combustion
byproduct
Cresol
(
mixed)
1319­
77­
3
Surfacant;
pulping
byproduct
Dazomet
533­
74­
4
Biocide
ingredient,
otherwise
used
Ethylene
glycol
107­
21­
1
Heat
transfer
fluid
and
antifreeze
(
otherwise
used),
specialty
paper
coating
Formaldehyde
50­
00­
0
Wet­
strength
additive(
2),
Kraft
pulping
process
byproduct,
combustion
byproduct
Formic
acid
64­
18­
6
Paper
dyeing/
finishing,
Kraft
pulping
process
byproduct
Hydrochloric
acid
(
acid
aerosol)
7647­
01­
0
Coal,
oil,
and
spent
pulping
liquor
combustion
byproduct
Hydrogen
fluoride
7664­
39­
3
Coal,
oil,
and
spent
pulping
liquor
combustion
byproduct
Table
2­
2
(
Continued)

EPCRA
Section
313
Chemical/
Chemical
Category
CAS
Registry
Number
Process/
Application
1These
activity
thresholds
are
for
non­
PBT
chemicals.
See
Section
2.6
for
the
activity
thresholds
applicable
to
PBT
chemicals.

2­
11
Manganese
compounds
N450
Manufactured/
processed
while
pretreating
pulp
with
chelating
agents
before
peroxide
bleaching
Paint
additive
(
pigments/
dyes),
catalytic
decomposition
agents,
combustion
byproduct
Methanol
67­
56­
1
Pulping,
chemical
recovery,
bleaching,
and
combustion
Printing
inks,
solvents,
antifreeze,
and
manufacture
of
ClO2
(
9),
byproduct
Methyl
ethyl
ketone
78­
93­
3
Pulping,
combustion,
and
chemical
recovery
(
9),
bleaching
(
1),
byproduct
Nickel
compounds
NN495
Manufactured/
processed
while
pretreating
pulp
with
chelating
agents
before
peroxide
bleaching
Nitrate
compounds
N511
Wastewater
treatment
system
byproduct
Nitric
acid
7697­
37­
2
Equipment
descaling,
otherwise
used
Phenol
108­
95­
2
Slimicide,
dye/
indicator,
solvent,
and
combustion
byproduct
Potassium
dimethyldithiocarbamate
128­
03­
0
Fungicide,
corrosion
inhibitor
Sulfuric
acid
(
acid
aerosol)
7664­
93­
9
Coal,
oil,
wood,
and
black
liquor
combustion
byproduct
(
9)

Toluene
108­
88­
3
Solvent
Vinyl
acetate
108­
05­
4
Paper
coating
additive
(
solvent)

Xylene
(
mixed
isomers)
1330­
20­
7
Paper
coating
additive
(
solvent)

Zinc
compounds
N982
Stock
preparation,
bleaching
(
7)

*
Reported
by
five
or
more
facilities
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.

For
non­
PBT
chemicals,
activity
thresholds
are
25,000
pounds
per
year
for
manufacturing,
25,000
pounds
per
year
for
processing,
and
10,000
pounds
per
year
for
otherwise
use1
(
40
CFR
§
372.25).
These
thresholds
apply
to
each
toxic
chemical
or
chemical
category
individually.
The
2­
12
quantity
of
toxic
chemicals
or
chemical
categories
stored
on
site
or
purchased
is
not
relevant
for
threshold
determinations.
Rather,
the
determination
is
based
solely
on
the
annual
quantity
actually
manufactured
(
including
imported),
processed,
or
otherwise
used.
Therefore,
EPCRA
Section
313
chemicals
and
chemical
categories
that
are
brought
on
site
and
stored,
and
are
neither
incorporated
into
a
product
for
distribution
in
commerce
nor
otherwise
used
on
site
during
the
reporting
year,
are
not
considered
towards
any
activity
threshold
(
EPCRA
§
313(
a)
&
(
b);

EPCRA
Section
313
Questions
and
Answers,
Revised
1998
Version,
Q&
A
87
(
1998)
(
EPA­
745­

B­
98­
004)).

Example
­
Activity
Determination
A
paperboard
manufacturer
buys
a
melamine
formaldehyde
resin,
dissolves
it
in
water
and
applies
it
to
paper
to
produce
a
polymer
coated
product.
The
resin
contains
a
small
amount
of
unreacted
formaldehyde
monomer
which
evaporates
during
the
coating
process.
Since
the
formaldehyde
(
CAS
Registry
No.
50­
00­
0)
is
not
incorporated
into
the
final
product
it
would
be
classified
as
otherwise
used
and
the
amount
used
should
be
included
in
calculations
to
determine
if
the
10,000­
pound/
year
otherwise
used
activity
threshold
has
been
reached.
If
the
formaldehyde
concentration
in
the
incoming
resin
mixture
is
below
the
0.1%
de
minimis
concentration
it
should
not
be
included
in
any
threshold
calculations.

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
3.
2­
13
Table
2­
3
Activity
Categories
Activity
Category
Definition
Threshold1
(
lb/
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
(
40
CFR
§
372.3).
An
example
of
coincidental
manufacturing
could
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
(
40
CFR
§
372.3).
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
(
40
CFR
§
372.3).
An
EPCRA
Section
313
chemical
or
chemical
category
that
is
otherwise
used
does
not
function
by
being
incorporated
into
a
product
that
is
distributed
in
commerce,
but
may
instead
be
used
as
a
manufacturing
or
processing
aid
(
e.
g.,
catalyst),
in
waste
processing,
or
as
a
fuel
(
including
waste
fuel).
For
example,
xylene
used
as
a
carrier
solvent
for
paint
is
classified
as
otherwise
used.

On
May
1,
1997
U.
S.
EPA
revised
the
interpretation
of
otherwise
use.
The
following
new
otherwise
use
definition
became
effective
with
the
1998
reporting
year
(
62
FR
23834,
May
1,
1997):

Otherwise
use
means
"
any
use
of
a
toxic
chemical,
including
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
1These
activity
thresholds
are
for
non­
PBT
chemicals.
See
Section
2.6
for
the
activity
thresholds
applicable
to
PBT
chemicals.
2­
14
COMMON
ERROR
­
Coincidental
Manufacture
The
coincidental
manufacture
of
an
EPCRA
Section
313
chemical
or
chemical
category,
outside
the
primary
product
process
line
but
in
direct
support
of
the
process,
is
frequently
overlooked.
For
example,
a
paperboard
manufacturer
(
SIC
Code
2631)
uses
steam
heated
rollers
in
the
dryer
process.
These
rollers
use
large
quantities
of
steam
which
is
generated
on
site
by
a
coal­
fired
steam
plant.
The
burning
of
coal
will
potentially
result
in
the
coincidental
manufacture
of
several
EPCRA
Section
313
chemicals
and
chemical
categories
including
the
aerosol
forms
of
sulfuric
and
hydrochloric
acid,
metal
compounds,
and
formaldehyde.
The
burning
of
waste
fuel
including,
but
not
limited
to,
wood
for
energy
recovery
may
result
in
coincidental
manufacture
of
metal
compounds.
The
amount
of
each
coincidentally
manufactured
EPCRA
Section
313
chemical
and
chemical
category
must
be
included
in
any
threshold
determinations
and,
if
a
threshold
is
exceeded,
any
subsequent
release
and
other
waste
management
activity
quantity
calculations.

Assuming
the
toxic
chemical
has
not
been
imported,
the
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
(
EPCRA
§
313(
a)
&
(
b);

40
CFR
§
372.3).
This
type
of
activity
should
not
be
included
in
threshold
determinations.

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
threshold
(
because
you
did
not
repackage
the
chemical)
or
the
otherwise
use
threshold,
nor
should
it
be
counted
toward
the
manufacturing
activity
threshold
unless
the
small
containers
were
imported.
However,
you
must
consider
other
EPCRA
Section
313
chemicals
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
use
threshold
determination
for
Chemical
A.
The
otherwise
use
threshold
is
10,000
pounds
and
since
the
amount
of
Chemical
A
exceeds
this
threshold,
all
release
and
other
waste
management
activities
for
Chemical
A
must
be
reported.

Chemical
B
was
manufactured
in
the
treatment
of
a
waste
received
from
off
site.
The
quantity
of
chemical
B
should
be
counted
towards
the
manufacturing
threshold.
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
(
40
CFR
§
372.3).
Therefore,
the
amount
of
Chemical
B
must
also
be
considered
in
the
otherwise
use
threshold
determination.
Thus,
the
reporting
threshold
for
Chemical
B
has
also
been
exceeded
and
all
release
and
other
waste
management
activities
for
Chemical
B
must
be
reported.
2­
15
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
(
40
CFR
§
372.25(
c)
&
(
d)).

2.6
Persistent,
Bioaccumulative,
and
Toxic
(
PBT)
Chemicals
U.
S.
EPA
promulgated
the
final
rule
for
Persistent,
Bioaccumulative,
and
Toxic
(
PBT)
chemicals
in
the
October
29,
1999
Federal
Register
(
64
FR
58666).
This
rule
applies
for
the
reporting
year
beginning
January
1,
2000
(
for
EPCRA
Section
313
reports
that
must
be
filed
by
July
1,
2001).

In
this
rule,
U.
S.
EPA
has
added
seven
chemicals
and
lowered
the
reporting
thresholds
for
18
chemicals
and
chemical
categories
that
meet
the
EPCRA
Section
313
criteria
for
persistence
and
bioaccumulation.
The
PBT
chemicals
and
their
thresholds
are
listed
in
Table
2­
4.
2­
16
Table
2­
4
Reporting
Thresholds
for
EPCRA
Section
313
Listed
PBT
Chemicals
Chemical
Name
or
Chemical
Category
CASRN
Section
313
Reporting
Threshold
(
in
pounds
unless
noted
other­
wise)

Aldrin
309­
00­
2
100
Benzo(
g,
h,
i)
perylene1
191­
24­
2
10
Chlordane
57­
74­
9
10
Dioxin
and
dioxin­
like
compounds
category1
(
manufacturing;
and
the
processing
or
otherwise
use
of
dioxin
and
dioxin­
like
compounds
if
the
dioxin
and
dioxin­
like
compounds
are
present
as
contaminants
in
a
chemical
and
if
they
were
created
during
the
manufacturing
of
that
chemical)
NA
0.1
grams
Heptachlor
76­
44­
8
10
Hexachlorobenzene
118­
74­
1
10
Isodrin
465­
73­
6
10
Methoxychlor
72­
43­
5
100
Octachlorostyrene1
29082­
74­
4
10
Pendimethalin
40487­
42­
1
100
Pentachlorobenzene1
608­
93­
5
10
Polycyclic
aromatic
compounds
category
NA
100
Polychlorinated
biphenyl
(
PCBs)
1336­
36­
3
10
Tetrabromobisphenol
A1
79­
94­
7
100
Toxaphene
8001­
35­
2
10
Trifluralin
1582­
09­
8
100
Mercury
7439­
97­
6
10
Mercury
compounds
NA
10
1
Chemical
or
chemical
category
added
to
the
EPCRA
Section
313
list
with
this
rulemaking.
Other
chemicals
and
chemical
categories
in
this
table
were
previously
reportable
for
EPCRA
Section
313;
however,
the
thresholds
have
now
been
lowered
as
indicated.

U.
S.
EPA
also
added
two
toxic
chemicals
to
the
polycyclic
aromatic
compounds
(
PACs)
category
that
is
listed
above:


Benzo(
j,
k)
fluorene
(
fluoranthene);
and

3­
methylchloanthrene.
2­
17
(
40
CFR
§
372.65(
c))
These
two
toxic
chemicals
are
not
to
be
reported
individually;
rather,
they
must
be
included
within
the
PACs
compound
category
(
40
CFR
§
372.25(
h)).

Tables
2­
5
and
2­
6
present
the
individual
chemicals
in
the
dioxin
and
dioxin­
like
compound
category
and
in
the
PAC
category,
respectively.

Table
2­
5
Chemicals
Included
in
the
EPCRA
Section
313
Dioxin/
Dioxin­
Like
Compound
Category
CASRN
Polychlorinated
dibenzo­
p­
dioxins
1,2,3,4,6,7,8­
heptachlorodibenzo­
p­
dioxin
35822­
46­
9
1,2,3,4,7,8­
hexachlorodibenzo­
p­
dioxin
39227­
28­
6
1,2,3,6,7,8­
hexachlorodibenzo­
p­
doixin
57653­
85­
7
1,2,3,7,8,9­
hexachlorodibenzo­
p­
dioxin
19408­
74­
3
1,2,3,4,6,7,8,9­
octachlorodibenzo­
p­
doixin
3268­
87­
9
1,2,3,7,8­
pentachlorodibenzo­
p­
dioxin
40321­
76­
4
2,3,7,8­
tetrachlorodibenzo­
p­
dioxin
1746­
01­
6
Polychlorinated
dibenzofurans
1,2,3,4,6,7,8­
heptachlorodibenzofuran
67562­
39­
4
1,2,3,4,7,8,9­
heptachlorodibenzofuran
55673­
89­
7
1,2,3,4,7,8­
hexachlorodibenzofuran
70648­
26­
9
1,2,3,6,7,8­
hexachlorodibenzofuran
57117­
44­
9
1,2,3,7,8,9­
hexachlorodibenzofuran
72918­
21­
9
2,3,4,6,7,8­
hexachlorodibenzofuran
60851­
34­
5
1,2,3,4,6,7,8,9­
octachlorodibenzofuran
39001­
02­
0
1,2,3,7,8­
pentachlorodibenzofuran
57117­
41­
6
2,3,4,7,8­
pentachlorodibenzofuran
57117­
31­
4
2,3,7,8­
tetrachlorodibenzofuran
51207­
31­
9
2­
18
Table
2­
6
Chemicals
Included
in
the
EPCRA
Section
313
PAC
Category
Chemical
Name
CAS
Number
Benz[
a]
anthracene
56­
55­
3
Benzo[
a]
phenanthrene
[
chrysene]
218­
01­
9
Benzo[
a]
pyrene
50­
32­
8
Benzo[
b]
fluoranthene
205­
99­
2
Benzo[
j]
fluoranthene
205­
82­
3
Benzo[
k]
fluoranthene
207­
08­
9
Benzo[
j,
k]
fluorene
[
fluoranthene]
1
206­
44­
0
Benzo[
rst]
pentaphene
189­
55­
9
Dibenz[
a,
h]
acridine
226­
36­
8
Dibenz[
a,
j]
acridine
224­
42­
0
Dibenzo[
a,
h]
anthracene
53­
70­
3
Dibenzo[
a,
e]
fluoranthene
5385­
75­
1
Dibenzo[
a,
e]
pyrene
192­
65­
4
Dibenzo[
a,
h]
pyrene
189­
64­
0
Dibenzo[
a,
l]
pyrene
191­
30­
0
7H­
Dibenzo[
c,
g]
carbazole
194­
59­
2
7,12­
Dimethyl­
benz[
a]
anthracene
57­
97­
6
Indeno[
1,2,3­
cd]
pyrene
193­
39­
5
3­
Methylchloroanthracene1
56­
49­
5
5­
Methylchrysene
3697­
24­
3
1­
Nitrpoyrene
5522­
43­
0
1
Chemical
or
chemical
category
added
to
the
EPCRA
Section
313
list
of
PACs
with
this
rulemaking.
Other
chemicals
and
chemical
categories
in
this
table
were
previously
reportable
for
EPCRA
Section
313
as
PACs.

U.
S.
EPA
finalized
two
thresholds
based
on
the
toxic
chemicals'
potential
to
persist
and
bioaccumulate
in
the
environment.
The
two
levels
include
setting
Section
313
manufacture,
process,
and
otherwise
use
thresholds
to
100
pounds
for
PBT
chemicals
and
to
10
pounds
for
that
subset
of
PBT
chemicals
that
are
highly
persistent
and
highly
bioaccumulative.

One
exception
is
the
dioxin
and
dioxin­
like
compounds
category.
U.
S.
EPA
set
the
threshold
for
the
dioxin
and
dioxin­
like
compound
category
at
0.1
gram.
2­
19
The
de
minimis
exemption
is
inapplicable
to
the
reporting
of
the
PBT
chemicals
(
40
CFR
§
372.38(
a)).
However,
this
action
does
not
affect
the
applicability
of
the
de
minimis
exemption
to
the
supplier
notification
requirements
(
40
CFR
§
372.45(
d)(
1)).
U.
S.
EPA
also
excluded
all
PBT
chemicals
from
eligibility
for
the
alternate
threshold
of
1
million
pounds
(
see
Section
2.9)
(
40
CFR
§
372.27(
e)
and
eliminated
range
reporting
of
PBT
chemicals
and
chemical
categories
for
on­
site
releases
and
transfers
off­
site
for
further
waste
management
(
40
CFR
§
372.85(
b)(
15)
&
(
16)).

Note
that
U.
S.
EPA
is
currently
developing
four
guidance
documents
for
PBT
chemicals
modified
in
the
PBT
rule:


Dioxins
and
dioxin­
like
compounds
(
EPA­
745­
B­
00­
021);


Polycyclic
aromatic
compounds
(
PACs)
category
(
EPA­
260­
B­
01­
003);


Mercury
and
mercury
compounds
(
EPA­
260­
B­
01­
004);
and

Pesticides
and
other
PBT
chemicals
(
EPA­
260­
B­
01­
005).

Please
refer
to
these
guidance
documents
as
appropriate
if
they
are
applicable
to
your
facility.

2.7
How
Do
You
Report?

You
must
submit
an
EPCRA
Section
313
report
for
each
EPCRA
Section
313
chemical
or
chemical
category
that
exceeds
a
threshold
for
manufacturing,
OR
processing,
OR
otherwise
use
(
providing
you
meet
the
employee
and
SIC
Code
criteria)
(
40
CFR
§
372.25).

Provided
you
do
not
exceed
certain
alternate
activity
thresholds
and
total
annual
reportable
amounts,
you
may
prepare
a
Form
A
certification
statement
(
See
Section
2.9)
rather
than
a
Form
R
for
non­
PBT
chemicals
(
40
CFR
§
372.27).
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
20
2.8
Form
R
Form
R
is
the
report
in
which
the
information
on
the
release
or
other
waste
management
activities
for
toxic
chemicals
required
by
EPCRA
Section
313
is
reported.
If
you
are
submitting
a
Form
R,
it
is
essential
that
you
use
the
TRI
Forms
and
Instructions
for
the
appropriate
reporting
year.
U.
S.
EPA
encourages
the
electronic
submittal
of
the
Form
R,
via
the
Automated
Toxic
Chemical
Release
Inventory
Reporting
Software
(
ATRS)
or
TRI
Made
Easy
(
TRI­
ME)
Software.
Use
of
the
ATRS
and
TRI­
ME
Software
will
save
preparation
time
in
data
entry
and
photocopying
and
reduce
errors
via
on­
line
validation
routines
and
use
of
pick
lists.
In
addition,
the
TRI­
ME
Software
will
guide
you
through
the
process
of
determining
your
reporting
requirements
and
assist
you
in
completing
Form
Rs.

The
Form
R
consists
of
two
parts:

Part
I,
Facility
Identification
Information.
This
part
may
be
photocopied
and
reused
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
Noncompliance
(
NON).
See
the
current
TRI
Forms
and
Instructions
for
more
detailed
information
on
completing
the
Form
R
and
submitting
the
EPCRA
Section
313
report.

2.9
Form
A
Certification
U.
S.
EPA
developed
the
Form
A,
also
referred
to
as
the
"
Certification
Statement,"

to
reduce
the
annual
reporting
burden
for
facilities
with
minimal
amounts
of
EPCRA
Section
313
chemicals
or
chemical
categories
released
and
otherwise
managed
as
waste
(
59
FR
61488,
2­
21
November
1994;
applicable
beginning
reporting
year
1994
and
beyond).
On
the
Form
A
certification,
you
certify
that
you
are
not
required
to
report
the
release
and
other
waste
management
information
required
by
EPCRA
Section
313
and
PPA
Section
6607.
A
facility
must
meet
the
following
two
criteria
to
use
a
Form
A:


First,
the
total
annual
reportable
amount
of
the
EPCRA
Section
313
chemical
or
chemical
category
cannot
exceed
500
pounds
per
year.
The
"
reportable
amount"
is
defined
as
the
sum
of
the
on­
site
amounts
released
(
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
2001
version
of
the
Form
R
(
40
CFR
§
372.27).


Second,
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
(
40
CFR
§
372.27).

Example
­
Form
A
Certification
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
certification
because
the
facility
did
not
exceed
the
one
million
pounds
for
either
activity,
even
though
the
total
usage
exceeds
1,000,000
pounds.

The
Form
A
Certification
Statement
must
be
submitted
for
each
eligible
EPCRA
Section
313
chemical
or
chemical
category
(
40
CFR
§
372.27).
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
(
40
CFR
§
372.27).

While
Form
A
certification
statement
requests
facility
identification
and
chemical
identification
information,
no
release
and
other
waste
management
quantity
estimations
to
any
2­
22
media
are
required.
You
simply
certify
that
the
total
annual
reportable
amount
did
not
exceed
500
pounds
and
that
amounts
manufactured,
processed,
or
otherwise
used
did
not
exceed
1,000,000
pounds.
Once
the
facility
has
completed
estimates
to
justify
the
submission
of
a
Form
A
certification,
there
is
a
considerable
time
savings
in
using
the
Form
A
certification,
especially
in
subsequent
years,
providing
activities
involving
the
toxic
chemical
or
chemical
category
did
not
change
significantly.
U.
S.
EPA
strongly
recommends
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
certification.

2.10
Trade
Secrets
If
you
submit
trade
secret
information,
you
must
prepare
two
versions
of
the
substantiation
form
as
prescribed
in
40
CFR
Part
350
(
see
53
FR
28801,
July
29,
1988)
as
well
as
two
versions
of
the
EPCRA
Section
313
report.
One
set
of
reports
should
be
"
sanitized"
(
i.
e.,
it
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
certification.
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
certification
must
be
filled
out
accordingly
(
40
CFR
§
350.3).

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
23
2.11
Recordkeeping
and
Penalty
Complete
and
accurate
records
are
absolutely
essential
to
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
(
40
CFR
§
372.10).
Each
facility
must
keep
copies
of
every
EPCRA
Section
313
report
along
with
all
supporting
documents,
calculations,
work
sheets,
and
other
forms
that
you
used
to
prepare
the
EPCRA
Section
313
report
(
40
CFR
§
372.10).
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,
which
may
include
some
or
all
of
the
following:


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.
2­
24
4)
For
facilities
submitting
a
Form
A
certification,
all
supporting
materials
used
to
make
the
compliance
determination
that
the
facility
or
establishment
is
eligible
to
submit
a
Form
A
certification,
which
may
include:


Data
supporting
the
determination
that
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.

EPCRA
Section
313
reporting
does
not
require
additional
testing
or
monitoring.

Rather,
in
order
to
report,
facilities
may
use
readily
available
data
collected
pursuant
to
other
provisions
of
the
law,
or
where
such
data
are
not
readily
available,
reasonable
estimates
of
the
amounts
involved
(
EPCRA
§
313(
g)(
2)).
Some
facilities
may
have
detailed
monitoring
data
and
off­
site
transfer
records
that
can
be
used
for
estimates
while
others
may
only
have
purchase
and
inventory
records.
Examples
of
records
that
you
could
use,
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;


Formulation
Sheets;


Purchase
records
from
suppliers;


Inventory
data;


Material
Safety
Data
Sheets
(
MSDS);


New
Source
Performance
Standards
(
NSPS);


National
Pollutant
Discharge
Elimination
System
(
NPDES)/
State
Pollutant
Discharge
Elimination
System
(
SPDES)
permits
and
monitoring
reports;


EPCRA
Section
312,
Tier
II
reports;


Monitoring
records;


Air
permits;


Clean
Air
Act
Title
V
Permit
Data;


Flow
measurement
data;
2­
25

Resource
Conservation
and
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).

Violation
of
EPCRA
Section
313
reporting
provisions
may
result
in
federal
civil
penalties
of
up
to
$
27,500
per
day
for
each
violation
(
40
CFR
§
372.18);(
40
CFR
§
19.4).
State
enforcement
provisions
may
also
be
applicable
depending
on
the
state's
EPCRA
Section
313
reporting
regulations.
3­
1
CHAPTER
3
­
EPCRA
SECTION
313
CHEMICAL
OR
CHEMICAL
CATEGORY
ACTIVITY
THRESHOLD
DETERMINATIONS
3.0
PURPOSE
This
chapter
provides
a
step­
by­
step
procedure
for
determining
if
any
EPCRA
Section
313
chemicals
or
chemical
categories
exceed
a
reporting
threshold.
Threshold
determinations
are
essentially
a
three
step
process:

Step
1)
Identify
any
EPCRA
Section
313
chemicals
and
chemical
categories
you
manufacture/
import,
process,
or
otherwise
use.

Step
2)
Identify
the
activity
category
and
any
exempt
activities
for
each
EPCRA
Section
313
chemical
or
chemical
category.

Step
3)
Calculate
the
quantity
of
each
EPCRA
Section
313
chemical
or
chemical
category
and
determine
which
ones
exceed
an
activity
threshold.

3.1
Step
1
­
Identify
Which
EPCRA
Section
313
Chemicals
or
Chemical
Categories
are
Manufactured
(
Including
Imported),
Processed,
or
Otherwise
Used
Compile
lists
of
all
chemicals
and
mixtures
at
your
facility.
For
facilities
with
many
different
chemicals
and
mixtures
it
is
often
helpful
to
prepare
two
lists:
one
with
the
pure
(
single
ingredient)
chemicals
(
including
chemical
compounds)
and
one
with
the
mixtures
and
trade
name
products.
On
the
second
list,
under
the
name
of
each
mixture/
trade
name
product,
write
the
names
of
all
chemicals
in
that
product.
Next,
compare
the
chemicals
and
chemical
categories
on
both
lists
to
the
current
EPCRA
Section
313
chemicals
and
chemical
categories
list
found
in
the
TRI
Forms
and
Instructions
(
remember
that
chemicals
and
chemical
categories
may
be
periodically
added
and
deleted
and
you
should
use
the
current
reporting
year's
instructions).

Highlight
the
EPCRA
Section
313
chemicals
and
chemical
categories
that
are
on
your
lists.
3­
2
Review
the
lists
to
be
sure
each
toxic
chemical
and
chemical
category
is
shown
by
its
correct
EPCRA
Section
313
name.
For
example,
a
common
EPCRA
Section
313
chemical
found
in
the
production
of
pulp,
paper,
and
paperboard
is
methanol.
Methanol
(
Chemical
Abstracts
Service
(
CAS)
Registry
No.
67­
56­
1)
has
several
synonyms
including:
carbinol;
methyl
alcohol;
methyl
hydroxide;
and
wood
alcohol.
It
should
be
reported
on
Form
R
(
or
Form
A
certification),
Item
1.2,
by
its
EPCRA
Section
313
chemical
name,
methanol
(
40
CFR
§
372.85(
b)(
10)).
Synonyms
can
be
found
in
the
U.
S.
EPA
document
Common
Synonyms
for
Chemicals
Listed
Under
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPA
745­
R­
95­
008).

While
you
must
consider
every
toxic
chemical
on
the
EPCRA
Section
313
chemical
and
chemical
category
list,
you
should
be
aware
of
the
toxic
chemicals
and
chemical
categories
typically
manufactured,
coincidentally
manufactured
as
byproducts,
or
otherwise
used
in
the
production
of
pulp,
paper,
and
paperboard
(
40
CFR
§
372.25(
h)).
As
a
guide,
the
most
frequently
reported
EPCRA
Section
313
chemicals
and
chemical
categories
for
reporting
year
1995
by
pulp,
paper,
and
paperboard
production
facilities,
and
the
processes
they
are
typically
used
in,
are
listed
in
Table
2­
2.

A
computerized
spreadsheet
may
be
helpful
in
developing
your
facility's
toxic
chemical
and
chemical
category
list
and
performing
threshold
calculations.
The
spreadsheet
could
show
the
toxic
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.
You
may
want
to
use
the
TRI­
ME
Software
as
one
easy
way
to
perform
chemical
threshold
determinations.

An
initial
investment
of
time
will
be
required
to
develop
this
spreadsheet;
however,

the
time
and
effort
saved
in
threshold
calculations
in
subsequent
years
will
be
significant.
Such
a
system
will
also
reduce
the
potential
of
inadvertently
overlooking
EPCRA
Section
313
chemicals
or
chemical
categories
present
in
mixtures
purchased
from
off­
site
sources.
3­
3
To
develop
the
toxic
chemical
and
chemical
category
list
and
the
associated
activity
categories
you
may
want
to
consult
the
following:


Material
Safety
Data
Sheets
(
MSDSs);


Facility
purchasing
records;


New
Source
Performance
Standards
(
NSPS);


Inventory
records;


Air
and
water
discharge
permits;


Individual
manufacturing/
operating
functions;
and

Receipts
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
toxic
chemical
and
chemical
category
on
your
spreadsheet:


The
mixture
name
and
associated
EPCRA
Section
313
chemical
and
chemical
category
names;


The
associated
Chemical
Abstract
Service
(
CAS)
Registry
numbers;


The
trade
name
for
mixtures
and
compounds;


The
throughput
quantities;
and

Whether
the
toxic
chemical
or
chemical
category
is
manufactured,
processed,
or
otherwise
used
at
the
facility
(
be
sure
to
include
quantities
that
are
coincidentally
manufactured
and
imported,
as
appropriate).

MSDSs
provide
important
information
for
the
type
and
composition
of
chemicals
and
chemical
categories
in
mixtures,
and
for
determining
whether
you
have
purchased
raw
materials
that
contain
EPCRA
Section
313
chemicals
and
chemical
categories.
As
of
1989,

chemical
suppliers
to
facilities
in
SIC
Major
Group
Codes
20
through
39
are
required
to
notify
manufacturing
customers
of
any
EPCRA
Section
313
chemicals
and
chemical
categories
present
above
the
applicable
de
minimis
concentrations
in
mixtures
or
trade
name
products
distributed
to
facilities
(
40
CFR
§
372.45(
a)).
The
notice
must
be
provided
to
the
receiving
facility
and
may
be
attached
or
incorporated
into
that
product's
MSDS
(
40
CFR
§
372.45(
c)(
5)).
If
no
MSDS
is
required,
the
notification
must
be
in
a
letter
that
accompanies
the
first
shipment
of
the
product
to
your
facility
each
year
(
40
CFR
§
372.45(
c)).
This
letter
must
contain
the
chemical
name,
CAS
3­
4
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
(
40
CFR
§
372.45(
b)).

Carefully
review
the
entire
MSDS.
Although
new
MSDSs
must
list
whether
EPCRA
Section
313
chemicals
and
chemical
categories
are
present
(
40
CFR
§
372.45(
b)),
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)
(
40
CFR
§
372.3);

(
40
CFR
§
372.38(
a)).

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
paper
and
paperboard
production
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
presence
of
ethyl
benzene
in
their
xylene
mixtures.

Qualifiers
Several
toxic
chemicals
on
the
EPCRA
Section
313
chemical
and
chemical
category
list
include
qualifiers
related
to
use
or
form.
Some
toxic
chemicals
are
reportable
ONLY
if
manufactured
by
a
specified
process
or
classified
in
a
specified
activity
category
(
40
CFR
§
3­
5
372.25(
f)).
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
(
40
CFR
§
372.65).

Some
other
toxic
chemicals
are
only
reportable
if
present
in
certain
forms
(
40
CFR
§
372.25(
g)).

For
example,
only
yellow
or
white
phosphorus
is
reportable,
while
black
or
red
phosphorus
is
not
reportable
(
40
CFR
§
372.65).

The
qualifiers
and
associated
toxic
chemicals
and
chemical
categories
listed
in
40
CFR
§
372.65
are
presented
below.
Please
make
special
note
of
the
discussion
pertaining
to
Vanadium
and
Vanadium
compounds
because
effective
as
of
December
31,
1999,
U.
S.
EPA
removed
the
`
fume
or
dust'
qualifier
for
vanadium
and
added
to
the
EPCRA
Section
313
list
all
forms
of
vanadium
and
vanadium
compounds,
with
the
exception
of
vanadium
when
contained
in
alloys.


Aluminum
oxide
(
fibrous)
­
Aluminum
oxide
is
only
subject
to
threshold
determination
and
release
and
other
waste
management
calculations
when
it
is
handled
in
fibrous
forms.
U.
S.
EPA
has
characterized
fibrous
aluminum
oxide
for
purposes
of
EPCRA
Section
313
reporting
as
a
manmade
fiber
commonly
used
in
high­
temperature
insulation
applications
such
as
furnace
linings,
filtration,
gaskets,
joints,
and
seals
(
55
FR
5221
(
February
14,
1990)).


Ammonia
(
includes
anhydrous
ammonia
and
aqueous
ammonia
from
water
dissociable
ammonium
salts
and
other
sources)
­
On
June
26,
1995,
U.
S.
EPA
qualified
the
listing
for
ammonia
(
CAS
Registry
No.
7664­
41­
7)
and
deleted
ammonium
sulfate
(
solution)
(
CAS
Registry
No.
7783­
20­
2)
from
the
EPCRA
Section
313
chemical
list.
Both
the
qualification
and
the
deletion
were
effective
as
of
reporting
year
1994.
The
qualifier
for
ammonia
means
that
anhydrous
forms
of
ammonia
are
100%
reportable
while
only
10%
of
the
total
aqueous
ammonia
is
reportable.
Any
evaporation
of
ammonia
from
aqueous
ammonia
solutions
is
considered
anhydrous
ammonia.
This
qualifier
applies
to
both
activity
threshold
determinations
and
release
and
other
waste
management
calculations.
Note
that
while
ammonium
sulfate
is
no
longer
an
EPCRA
Section
313
chemical,
10%
of
the
aqueous
ammonia
formed
from
the
dissociation
of
ammonium
sulfate
(
and
all
other
ammonium
salts)
is
reportable,
and
must
be
included
in
both
activity
threshold
determinations
and
release
and
other
waste
management
calculations.
Additionally,
any
ammonium
nitrate
must
also
be
included
in
the
threshold
determination
and
the
nitrate
portion
included
in
the
release
and
other
waste
management
calculations,
for
the
nitrate
3­
6
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.


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.


Fume
or
dust
­
Two
metals
(
aluminum
and
zinc)
are
qualified
with
"
fume
or
dust."
This
definition
excludes
"
wet"
forms
such
as
solutions
or
slurries,
but
includes
powder,
particulate,
or
gaseous
forms
of
these
metals.
There
is
no
particle
size
limitation
for
particulates.
For
example,
use
of
zinc
metal
as
a
paint
component
is
not
subject
to
reporting
unless
the
zinc
is
in
the
form
of
a
fume
or
dust.
However,
even
though
elemental
zinc
is
reportable
only
in
the
fume
or
dust
form,
all
forms
of
zinc
compounds
are
reportable.
Note
that
the
entire
weight
of
all
zinc
compounds
should
be
included
in
the
threshold
determination
for
zinc
compounds,
while
only
the
metal
portion
of
metal
compounds
is
reported
in
the
release
and
other
waste
management
amounts.
Prior
to
reporting
year
2000,
vanadium
was
also
qualified
with
"
fume
or
dust."
As
of
reporting
year
2000
this
qualifier
has
been
removed
for
vanadium
such
that
all
physical
forms
are
now
reportable.
Please
see
the
discussion
on
vanadium
and
vanadium
compounds
below,
if
applicable.


Hydrochloric
acid
(
acid
aerosols)
­
On
July
25,
1996,
U.
S.
EPA
promulgated
a
final
rule
delisting
non­
aerosol
forms
of
hydrochloric
acid
(
CAS
Registry
No.
7647­
01­
0)
from
the
EPCRA
Section
313
chemical
list
(
effective
for
the
1995
reporting
year).
Therefore,
threshold
determinations
and
release
and
other
waste
management
estimates
now
apply
only
to
the
aerosol
forms.
Under
EPCRA
Section
313,
the
term
aerosol
covers
any
generation
of
airborne
acid
(
including
mists,
vapors,
gas,
or
fog)
without
any
particle
size
limitation.
Therefore,
spraying
hydrochloric
acid
is
manufacturing
hydrochloric
acid
aerosol
for
TRI
reporting
purposes
and
you
should
include
this
quantity
in
the
manufacturing
threshold
determination.


Manufacturing
qualifiers
­
Two
chemicals,
saccharin
and
isopropyl
alcohol,
contain
qualifiers
relating
to
manufacture.
The
qualifier
for
saccharin
means
that
only
manufacturers
of
the
chemical
are
subject
to
the
reporting
requirement.
The
qualifier
for
isopropyl
alcohol
means
that
only
facilities
that
manufacture
the
chemical
by
the
strong
acid
process
are
required
to
report.
Facilities
that
only
process
or
otherwise
use
these
chemicals
are
not
required
to
report.
Thus,
a
facility
that
uses
isopropyl
alcohol
as
a
solvent
in
coatings
should
not
report
for
isopropyl
alcohol.
3­
7

Nitrate
Compounds
(
water
dissociable;
reportable
only
in
aqueous
solution)
­
A
nitrate
compound
is
covered
by
this
listing
only
when
in
water
and
if
water
dissociable.
Although
the
complete
weight
of
the
nitrate
compound
must
be
used
for
threshold
determinations
for
the
nitrate
compounds
category,
only
the
nitrate
portion
of
the
compound
must
be
considered
for
release
and
other
waste
management
calculations.
One
issue
recently
raised
by
industry
is
how
to
report
nitrate
compounds
in
wastewater
and
sludge
that
is
applied
to
farms
as
a
nitrogen
source
(
either
on
site
or
off
site).
Although
during
such
use
nitrate
compounds
may
be
taken
up
by
plants
and
cycled
back
into
the
ecosystem,
U.
S.
EPA
considers
that
the
nitrate
compounds
in
wastewater/
sludge
are
managed
as
waste.
In
this
scenario,
compounds
should
be
reported
as
being
disposed
to
land
(
either
on
site
or
off
site
as
appropriate).
U.
S.
EPA
has
published
guidance
for
these
chemicals
in
List
of
Toxic
Chemicals
Within
the
Water
Dissociable
Nitrate
Compounds
Category
and
Guidance
for
Reporting,
EPA
745­
R­
96­
004.


Phosphorus
(
yellow
or
white)
­
Only
manufacturing,
processing,
or
otherwise
use
of
phosphorus
in
the
yellow
or
white
chemical
forms
require
reporting.
Black
and
red
phosphorus
are
not
subject
to
EPCRA
Section
313
reporting.


Sulfuric
acid
(
acid
aerosols)
­
On
June
26,
1995,
U.
S.
EPA
promulgated
a
final
rule
delisting
non­
aerosol
forms
of
sulfuric
acid
(
CAS
Registry
No.
7664­
93­
9)
from
the
EPCRA
Section
313
toxic
chemical
list
(
effective
for
the
1994
reporting
year).
Therefore,
threshold
determinations
and
release
and
other
waste
management
estimates
now
apply
only
to
the
aerosol
forms.
Under
EPCRA
Section
313,
the
term
aerosol
covers
any
generation
of
airborne
acid
(
including
mists,
vapors,
gas,
or
fog)
without
any
particle
size
limitation.
Therefore,
spraying
sulfuric
acid
is
manufacturing
sulfuric
acid
aerosol
for
TRI
reporting
purposes
and
you
should
include
this
quantity
in
the
manufacturing
threshold
determination.
U.
S.
EPA
has
published
guidance
for
acid
aerosols
in
Guidance
for
Reporting
Sulfuric
Acid,
EPA
745­
R­
97­
007.


Vanadium
and
vanadium
compounds
­
Note
that
prior
to
reporting
year
2000,
the
fume
or
dust
qualifier
also
applied
to
vanadium.
As
of
December
31,
1999
(
effective
December
31,
1999
for
EPCRA
Section
313
reports
that
must
be
filed
by
July
1,
2001),
U.
S.
EPA
removed
this
qualifier
for
vanadium.
Effective
December
31,
1999,
U.
S.
EPA
removed
the
"
fume
or
dust"
qualifier
for
vanadium
and
added
to
the
EPCRA
Section
313
list
all
forms
of
vanadium
and
vanadium
compounds,
with
the
exception
of
vanadium
when
contained
in
alloys.
Therefore,
vanadium
that
is
present
in
fumes,
dusts,
or
any
other
physical
forms
of
alloys
should
not
be
considered
for
EPCRA
Section
313
reporting.
However,
if
vanadium
is
separated
from
the
alloy,
all
physical
forms
of
the
vanadium
are
considered
3­
8
to
be
manufactured
and
the
quantity
manufactured
should
be
applied
to
the
25,000­
pound
manufacturing
threshold.
If
the
vanadium
is
subsequently
processed
or
otherwise
used,
the
applicable
quantity
should
also
be
applied
to
the
processing
or
otherwise
use
threshold(
s).
If
an
acting
threshold
is
exceeded,
all
quantities
released
and
other
waste
management
quantities
must
be
reported
as
appropriate.

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
(
40
CFR
§
372.25);
they
are
mutually
exclusive
and
are
not
additive.

Table
3­
1
Reporting
Thresholds
Activity
Category
Threshold1
Manufacture
(
including
import)
25,000
pounds
per
year
Process
25,000
pounds
per
year
Otherwise
use
10,000
pounds
per
year
1These
reporting
thresholds
are
for
non­
PBT
chemicals.
See
Section
2.6
for
the
reporting
thresholds
applicable
to
PBT
chemicals.

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
release
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
use
activity.
3­
9
Example
­
Xylene
Isomers
Paper
and
paperboard
production
facilities
use
the
EPCRA
Section
313
chemical
xylene,
with
the
xylene
(
mixed
isomers),
CAS
Registry
No.
1330­
20­
7,
being
the
most
frequently
reported
type.
Ortho­,
meta­,
and
paraxylenes
are
listed
on
the
EPCRA
Section
313
chemicals
and
chemical
categories
list
in
addition
to
xylene
(
mixed
isomers).
The
mixed
isomers
classification
must
be
used
when
a
mixture
contains
any
combination
of
two
or
more
of
the
isomers.
The
threshold
determination
for
xylene
must
be
calculated
for
each
isomeric
form
individually
unless
the
xylenes
are
manufactured,
processed,
or
otherwise
used
as
a
mixture
of
xylene
isomers.
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
it
is
considered
a
"
direct
reuse"
and
is
not
reportable.
Only
the
amount
of
new
chemical
added
to
the
system
should
be
included
in
the
otherwise
used
threshold
calculation.
However,
if
you
send
a
solvent
containing
an
EPCRA
Section
313
chemical
or
chemical
category
off
site
for
distillation
and
subsequent
recycling,
it
should
be
reported
as
a
transfer
to
an
off­
site
location
for
recycling
(
Part
II,
Sections
6.2
and
8.5
of
the
2001
Form
R)
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
on
site
must
be
reported
in
Section
8.4
each
time
it
is
recycled.

Example
­
Chemical
Mixtures
A
manufacturer
of
resinous
impregnated
paper,
SIC
Code
2672,
purchases
a
mixture
of
natural
and
synthetic
resins
and
adds
chemicals
to
achieve
the
desired
properties.
Any
EPCRA
Section
313
chemicals
and
chemical
categories
in
the
purchased
resin
mixture
must
be
included
in
the
processing
threshold
determination,
providing
their
concentrations
are
above
the
de
minimis
concentration
limits.
The
amount
of
any
such
chemicals
can
be
estimated
by
multiplying
the
weight
percent
of
the
chemical
by
the
total
weight
of
the
mixture.
Likewise,
any
EPCRA
Section
313
chemicals
and
chemical
categories
added
on
site
must
be
included
in
the
processing
activity
threshold
determination.

Each
of
the
activity
categories
on
the
Form
R,
Part
II,
Section
3,
is
divided
into
subcategories.
As
discussed
in
the
TRI
Forms
and
Instructions,
you
are
required
to
designate
3­
10
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.

Table
3­
2
Description
of
Manufacturing
Subcategories
Manufacturing
Activity
Subcategory
Description
Examples
in
Pulp,
Paper,
and
Paperboard
Production*

Produced
or
imported
for
on­
site
use/
processing
A
toxic
chemical
or
chemical
category
that
is
produced
or
imported
and
then
further
processed
or
otherwise
used
at
the
same
facility.
Chlorine
dioxide
Produced
or
imported
for
sale/
distribution
A
toxic
chemical
or
chemical
category
that
is
produced
or
imported
specifically
for
sale
or
distribution
outside
the
manufacturing
facility.

Produced
as
a
byproduct
A
toxic
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.
Chloroform
produced
during
bleaching,
acetaldehyde
and
sulfuric
acid
(
aerosols)
produced
during
combustion,
biphenyl
produced
during
Kraft
pulping
Produced
as
an
impurity
A
toxic
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.
Chloromethane
produced
during
pulping
and
bleaching
*
More
complete
discussions
of
the
industry­
specific
examples
can
be
found
in
Chapter
4
of
this
guidance
manual.
3­
11
Table
3­
3
Description
of
Processing
Subcategories
Processing
Activity
Subcategory
Description
Examples
in
Pulp,
Paper,
and
Paperboard
Production*

Reactant
A
natural
or
synthetic
toxic
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.
Methanol
used
to
produce
chlorine
dioxide
Formulation
component
A
toxic
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.
Dyes:
cobalt
compounds,
C.
I.
acid
Green
3,
C.
I.
Direct
Blue
6
Flame
retardants:
antimony
compounds
Coatings:
zinc
compounds
Article
component
A
toxic
chemical
or
chemical
category
that
becomes
an
integral
component
of
an
article
distributed
for
industrial,
trade,
or
consumer
use.
Adhesives:
acrylamide,
ammonia
Repackaging
only
A
toxic
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.

*
More
complete
discussions
of
the
industry­
specific
examples
can
be
found
in
Chapter
4
of
this
guidance
manual.
3­
12
Table
3­
4
Description
of
Otherwise
Use
Subcategories
Otherwise
Use
Activity
Subcategory
Defscription
Examples
in
Pulp,
Paper,
and
Paperboard
Production*

Chemical
processing
aid
A
toxic
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.
Toluene
used
for
paper
coating
Manufacturing
aid
A
toxic
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.
Chlorine,
chlorine
dioxide
Ancillary
or
other
use
A
toxic
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.
Chlorine,
ammonia
used
in
wastewater
treatment
system
*
More
complete
discussions
of
the
industry­
specific
examples
can
be
found
in
Chapter
4
of
this
guidance
manual.

Example
­
Chemical
Processing
Aid
A
paperboard
coating
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
coating
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
coating
components
intended
to
remain
with
the
workpiece.
3­
13
3.2.1
Concentration
Ranges
for
Threshold
Determination
You
should
use
the
best,
readily
available
information
collected
pursuant
to
other
provisions
of
law
or
where
such
data
are
not
available,
reasonable
estimates
for
all
calculations
in
EPCRA
Section
313
reporting.
The
concentration
of
an
EPCRA
Section
313
chemical
or
chemical
category
in
a
mixture
or
trade
name
product
may
be
known
as
a
specific
concentration,

as
an
average,
as
a
range,
or
as
an
upper
or
lower
bound
concentration.
If
you
know
the
specific
concentration
of
an
EPCRA
Section
313
chemical
or
chemical
category
in
a
mixture
or
trade
name
product,
you
must
use
that
value
(
40
CFR
372.30
(
b)(
i)).
If
only
an
average
concentration
is
provided
(
e.
g.,
by
the
supplier),
you
can
use
that
value
in
the
threshold
determinations.
If
only
the
upper
bound
concentration
is
known,
you
must
use
this
value
in
the
threshold
determination
(
40
CFR
372.30(
b)(
3)(
ii)).
If
only
the
lower
bound
concentration
is
provided
or
the
concentration
is
given
as
a
range
or
an
upper
and
lower
bound
concentrations,
U.
S.
EPA
has
developed
the
following
guidance
on
the
use
of
this
type
of
information
in
threshold
determinations.


If
the
concentration
is
given
as
a
lower
and
upper
bound
or
as
a
range,
EPA
recommends
that
you
use
the
mid­
point
in
your
calculations
for
threshold
determinations.
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%.
EPA
recommends
you
use
the
mid­
point
value
of
30%
methanol
in
your
calculations
for
threshold
determinations.


If
only
the
lower
bound
concentration
is
given
and
the
concentration
of
other
components
are
given,
EPA
recommends
you
subtract
the
other
components
total
from
100%
to
calculate
the
upper
bound
concentration.
EPA
then
recommends
you
to
calculate
the
mid­
point
concentration
for
use
in
your
calculations.
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%,
EPA
recommends
you
use
the
value
in
your
calculations
for
threshold
determinations.


If
only
the
lower
bound
concentration
is
given
and
the
concentration
of
the
other
component(
s)
is
not
given,
EPA
recommends
that
you
assume
the
upper
bound
for
the
EPCRA
section
313
chemical
or
chemical
category
is
3­
14
100%
and
use
the
mid­
point.
Alternatively,
product
quality
requirements
or
information
available
from
the
most
similar
process
stream
may
be
used
to
determine
the
upper
bound
of
the
range.

Special
guidance
for
concentration
ranges
that
straddle
the
de
minimis
value
is
presented
in
Section
3.2.2.1.

Common
Error
­
Threshold
Determinations
Based
on
MSDS
Concentration
Data
During
the
site
surveys
conducted
to
determine
the
quality
of
the
EPCRA
Section
313
data
being
reported
it
was
noted
that
many
facilities
incorrectly
applied
concentration
information
provided
in
the
MSDSs.
The
most
frequent
error
was
the
use
of
the
upper
bound
of
a
concentration
range.
U.
S.
EPA
guidance
is
to
use
the
midpoint
of
the
concentration
range
in
any
calculations
to
estimate
activity
threshold
quantities.
Use
of
the
upper
bound
will
result
in
the
over
estimation
of
the
amount
manufactured,
processed
or
otherwise
used
and
may
result
in
the
unnecessary
filing
of
an
EPCRA
Section
313
report.
The
complete
results
of
the
site
survey
program
was
published
as
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002.

3.2.2
Evaluation
of
Exemptions
When
determining
thresholds,
you
can
exclude
quantities
of
any
EPCRA
Section
313
chemicals
and
chemical
categories
that
are
manufactured,
processed,
or
otherwise
used
in
exempt
activities.
Exemptions
are
divided
into
four
classes:

1.
De
minimis
exemption;
2.
Article
exemption;
3.
Facility­
related
exemption;
and
4.
Activity­
related
exemptions.

COMMON
ERROR
­
Exempt
Activities
If
an
EPCRA
Section
313
chemical
or
chemical
category
is
used
in
exempt
activities,
the
quantity
used
in
these
activities
does
not
need
to
be
included
in
your
threshold
determinations
or
release
and
other
waste
management
calculations,
even
if
the
chemical
or
chemical
category
is
used
in
a
reportable
activity
elsewhere
in
the
facility
(
40
CFR
§
372.38).
3­
15
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
(
40
CFR
§
372.38(
a)).
Note
that
this
exemption
does
not
apply
to
manufacturing,
except
for
importation
or
as
an
impurity
as
discussed
below.
Also
note
that
the
de
minimis
exemption
does
not
apply
to
the
manufacturing,
processing,

or
otherwise
use
of
the
PBT
chemicals
(
refer
to
Section
2.6)
(
40
CFR
§
372.38(
a)).
The
de
minimis
concentration
for
EPCRA
Section
313
chemicals
and
chemical
categories
is
1%,
except
for
Occupational
Safety
and
Health
Administration
(
OSHA)­
defined
carcinogens,
which
have
a
0.1%
de
minimis
concentration
(
40
CFR
§
372.38(
a)).
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
(
40
CFR
§
372.25(
h)).
If
the
total
meets
or
exceeds
the
category's
de
minimis
level,
the
de
minimis
exemption
does
not
apply.
U.
S.
EPA
has
published
several
detailed
questions
and
answers
and
a
directive
in
the
current
edition
of
EPCRA
Section
313
Questions
and
Answers
(
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.

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
in
the
process
stream.
3­
16
Example
­
De
Minimis
Your
facility
processes
a
mixture
containing
1.1%
nitric
acid
and
0.6%
manganese.
The
de
minimis
exemption
would
apply
to
manganese
because
the
concentration
is
below
1%,
which
is
the
de
minimis
level
for
manganese;
however,
it
would
not
apply
to
nitric
acid.
All
of
the
nitric
acid
must
be
included
in
threshold
determinations,
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
only
if
that
chemical
is
manufactured
as
an
impurity
in
a
mixture
(
53
FR
4504,
February
16,
1988)).
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
(
40
CFR
§
372.38(
a)).

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.
3­
17
(
8,000,000)
×
(
0.0125

0.0099)
(
0.0125

0.0025)
×
(
0.0125

0.01)
(
2)

23,400
pounds
(
8,000,000)
×
(
0.012

0.009)
(
0.012

0.002)
×
(
0.012

0.01)
(
2)

26,400
pounds
Examples
­
De
Minimis
Concentration
Ranges
Example
1:

A
facility
processes
8,000,000
pounds
of
a
mixture
containing
0.25
to
1.25%
naphthalene.
Naphthalene
is
subject
to
a
1%
de
minimis
concentration
exemption.
The
amount
of
mixture
subject
to
reporting
is
the
quantity
containing
naphthalene
above
the
de
minimis
concentration:

8,000,000
×
[(
0.0125
­
0.0099)
÷
(
0.0125
­
0.0025)]

The
average
concentration
of
naphthalene
that
is
not
exempt
(
above
the
de
minimis)
is:

(
0.0125
+
0.01)
÷
2
Therefore,
the
amount
of
naphthalene
that
is
subject
to
threshold
determination
and
release
and
other
waste
management
estimates
is:

=
23,400
pounds
naphthalene
(
which
is
below
the
processing
threshold)

In
this
example,
because
the
facility's
information
pertaining
to
naphthalene
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,
naphthalene
is
present
in
a
mixture,
of
which
8,000,000
pounds
is
processed.
The
MSDS
states
the
mixture
contains
0.2%
to
1.2%
naphthalene.
The
amount
of
mixture
subject
to
reporting
(
above
de
minimis)
is:

(
8,000,000)
×
(
0.012
­
0.009)
÷
(
0.012
­
0.002)

The
average
concentration
of
naphthalene
that
is
not
exempt
(
above
de
minimis)
is:

(
0.012
+
0.01)
÷
(
2)

Therefore,
the
amount
of
naphthalene
that
is
subject
to
threshold
determinations
and
release
and
other
waste
management
estimates
is:

=
26,400
pounds
naphthalene
(
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.)
(
see
53
FR
4501,
4504
(
February
16,
3­
18
1988);
62
FR
23,845­
46
(
May
1,
1997))
For
example,
many
facilities
treat
waste
solvents
by
incinerating
them.
If
coal
is
used
as
the
primary
fuel
source
to
incinerate
these
waste
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
(
40
CFR
§
372.3).

3.2.2.2
Articles
Exemption
An
article
is
defined
(
40
CFR
§
372.3)
as
a
manufactured
item
that:


Is
formed
to
a
specific
shape
or
design
during
manufacture;


Has
end­
use
functions
dependent
in
whole
or
in
part
upon
its
shape
or
design;
and

Does
not
release
an
EPCRA
Section
313
chemical
or
chemical
category
under
normal
conditions
of
processing
or
otherwise
use
of
the
item
at
the
facility.

If
you
receive
a
manufactured
article
from
another
facility
or
you
produce
the
article
in
your
facility
and
process
or
otherwise
use
it
without
changing
the
shape
or
design,
and
your
processing
or
otherwise
use
does
not
result
in
the
release
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
calculations
(
The
0.5
pound
limit
does
not
apply
to
each
individual
article,
but
applies
to
the
sum
of
all
releases
from
processing
or
use
of
all
like
articles)
(
40
CFR
§
372.38(
b)).
Section
313
chemicals
or
chemical
categories
used
to
produce
an
article,
however,
do
not
qualify
for
the
article
exemption.

The
shape
and
design
can
be
changed
somewhat
during
processing
and
otherwise
use
as
long
as
part
of
the
item
retains
the
original
dimensions.
That
is,
as
a
result
of
processing
or
otherwise
use,
if
an
item
retains
its
initial
thickness
or
diameter,
in
whole
or
in
part,
then
it
still
meets
the
article
definition.
If
the
item's
original
dimensional
characteristics
are
totally
altered
3­
19
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
(
53
FR
4507
(
February
16,
1988)).
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
from
all
like
articles.

Any
processing
or
otherwise
use
of
an
article
that
results
in
a
release
above
0.5
pound
per
year
for
each
EPCRA
Section
313
chemical
or
chemical
category
for
all
like
articles
negates
the
exemption
(
40
CFR
§
372.3,
372.38(
b)).
Cutting,
grinding,
melting,
or
other
activities
performed
on
a
manufactured
item
could
result
in
a
release
of
an
EPCRA
Section
313
chemical
or
chemical
category
during
normal
conditions
of
processing
or
otherwise
use
and,

therefore,
could
negate
the
article
exemption
if
the
total
annual
releases
from
all
like
articles
exceed
0.5
pound
in
a
calendar
year.
However,
if
all
of
the
resulting
waste
is
recycled
or
reused,

either
on
site
or
off
site,
so
that
the
release
quantity
of
the
EPCRA
Section
313
chemical
or
chemical
category
does
not
exceed
0.5
pound
for
the
calendar
year,
then
the
article's
exemption
status
may
be
maintained.
If
the
processing
or
otherwise
use
of
similar
manufactured
items
results
in
a
total
releases
of
less
than
or
equal
to
0.5
pound
of
any
individual
EPCRA
Section
313
chemical
or
chemical
category
to
any
environmental
media
in
a
calendar
year,
U.
S.
EPA
will
allow
this
quantity
to
be
rounded
to
zero
and
the
manufactured
items
maintain
their
article
status.
The
0.5­
pound
limit
does
not
apply
to
each
individual
article,
but
applies
to
the
sum
of
all
release
from
processing
or
otherwise
use
of
like
articles
for
each
EPCRA
Section
313
chemical
or
chemical
category.
The
current
edition
of
EPCRA
Section
313
Questions
and
Answers
(
1998
edition
is
EPA
745­
B­
98­
004)
presents
several
specific
question
and
answers/
discussions
pertaining
to
the
articles
exemption.
3­
20
Example
­
Articles
Exemption
If
an
article
is
subjected
to
a
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
if
the
total
release
from
all
like
articles
is
greater
than
0.5
lb
for
its
reporting
year.
For
example,
stainless
steel
pipes
containing
nickel
and
chromium
are
cut
and
installed
on
site.
Some
of
the
nickel
and
chromium
are
released
as
dust
from
the
cutting
operation.
The
dust
is
washed
away
during
area
cleaning
and
discharged
to
a
POTW.
This
process
is
considered
a
release
of
the
nickel
and
chromium
and,
if
the
release
from
all
like
articles
is
greater
than
0.5
pound
per
year
for
one
(
or
both)
toxic
chemicals,
the
pipe
has
lost
its
article
exemption.

3.2.2.3
Facility­
Related
Exemption
 
Laboratory
Activity
Exemption
EPCRA
Section
313
chemicals
and
chemical
categories
that
are
manufactured,

processed,
or
otherwise
used
in
laboratories
under
the
supervision
of
a
technically
qualified
individual
are
exempted
from
the
threshold
determination
(
and
subsequent
release
and
other
waste
management
calculations)
(
40
CFR
§
372.38(
d)).
This
exemption
may
be
applicable
in
circumstances
such
as
laboratory
sampling
and
analysis,
research
and
development,
and
quality
assurance
and
quality
control
activities.
It
does
not
include
pilot
plant
scale
or
specialty
chemical
production
(
40
CFR
§
372.38(
d)).
It
also
does
not
include
laboratory
support
activities.
For
example,
toxic
chemicals
used
to
maintain
laboratory
equipment
are
not
eligible
for
the
laboratory
exemption.

Example
­
Laboratory
Activity
Exemption
A
paperboard
manufacturer
at
a
separate
research
laboratory
facility
applies
various
formulations
of
polymer
coatings
containing
EPCRA
Section
313
chemicals
and
chemical
categories
to
product
samples
for
testing.
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
determinations
or
release
and
other
waste
management
calculations.

3.2.2.4
Activity­
Related
Exemptions
(
Otherwise
Use
Exemptions)

Some
exemptions
apply
to
the
otherwise
use
of
an
EPCRA
Section
313
chemical
and
chemical
category.
The
specific
quantities
of
EPCRA
Section
313
chemicals
and
chemical
categories
used
in
these
activities
do
not
need
to
be
included
in
facility
threshold
determinations
(
nor
the
associated
release
and
other
waste
management
calculations)
(
40
CFR
§
372.38(
c)).
The
following
otherwise
use
activities
are
considered
exempt:
3­
21

EPCRA
Section
313
chemicals
and
chemical
categories
used
in
routine
janitorial
or
facility
grounds
maintenance.
Examples
are
bathroom
cleaners,
fertilizers,
and
garden
pesticides
similar
in
type
or
concentration
to
consumer
products.
Materials
used
to
clean
process
equipment
do
not
meet
this
exemption.


Personal
use
of
items.
Examples
are
foods,
drugs,
cosmetics,
and
other
personal
items
including
those
items
within
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
Toluene
in
nail
polish
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
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
only
applies
to
the
OTHERWISE
USE
of
EPCRA
Section
313
chemicals
and
chemical
categories.
The
coincidental
manufacture
of
EPCRA
Section
313
chemicals
and
chemical
categories
resulting
from
combustion
of
gasoline
is
not
exempt
and
should
be
considered
toward
the
manufacturing
threshold.

Example
­
Motor
Vehicle
Exemption
Methanol
is
purchased
for
use
as
a
processing
aid
and
as
a
windshield
washer
antifreeze
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
calculations.

This
exemption
does
NOT
apply
to
stationary
equipment.
The
use
of
lubricants
and
fuels
for
stationary
process
equipment
(
e.
g.,
pumps
and
3­
22
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
certain
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
toxic
chemicals
and
chemical
categories
present
in
air
used
either
as
compressed
air
or
as
an
oxygen
source
for
combustion.

Example
­
Activity
Exemption
­
Toxic
Chemicals
in
Process
Water
Paper
manufacturing
facilities
use
large
amounts
of
process
water.
One
such
facility
draws
process
water
containing
1.0
part
per
billion
(
ppb)
of
lead
(
CAS
Registry
No.
7439­
92­
1)
from
a
river.
The
water
the
facility
returns
to
the
river
contains
0.5
ppb
lead.
Since
the
EPCRA
Section
313
chemical
is
contained
in
water
drawn
from
the
environment
(
or
a
municipal
source)
it
is
exempt
under
the
general
category
of
activity­
related
exemptions.
Thus,
the
facility
need
not
consider
the
lead
in
the
process
water
for
threshold
or
release
and/
or
other
waste
management
activity
calculations.

3.2.3
Additional
Guidance
on
Threshold
Calculations
for
Certain
Activities
This
section
covers
three
specific
situations
in
which
the
threshold
determination
may
vary
from
normal
facility
operations:
reuse,
remediation,
and
recycling
activities
of
EPCRA
Section
313
chemicals
and
chemical
categories.

3.2.3.1
Reuse
Activities
Threshold
determinations
of
EPCRA
Section
313
chemicals
or
chemical
categories
that
are
reused
at
the
facility
are
based
only
on
the
amount
of
the
EPCRA
Section
313
chemical
or
chemical
category
that
is
added
to
the
system
during
the
year,
not
the
total
volume
in
the
system.
For
example,
a
facility
operates
a
refrigeration
unit
that
contains
15,000
pounds
of
3­
23
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
(
40
CFR
§
372.25(
e)).

3.2.3.2
Remediation
Activities
EPCRA
Section
313
chemicals
and
chemical
categories
undergoing
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
2001
Form
R
(
40
CFR
§
372.85(
b)(
15)+(
16)).
Those
quantities
would
also
be
considered
as
part
of
the
amount
for
determining
Form
A
certification
eligibility.

EPCRA
Section
313
chemicals
and
chemical
categories
used
for
remediation
should
be
considered
toward
threshold
determinations
(
40
CFR
§
372.3).
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
(
40
CFR
§
372.85(
b)(
15)+(
16)).

Excavation
(
that
is
considered
part
of
the
remedial
action
)
of
material
already
landfilled
does
not
constitute
a
manufacturing,
processing,
or
otherwise
use
activity.
However,
3­
24
routine
activities
(
e.
g.,
dredging
a
lagoon),
even
if
not
performed
every
year,
are
not
considered
to
be
remedial
actions
and
may
be
subject
to
reporting.

3.2.3.3
Recycling
Activities
For
on­
site
recycling
and
reuse
systems,
where
the
same
EPCRA
Section
313
chemical
or
chemical
category
is
recycled
and
reused
multiple
times,
only
count
the
quantity
recycled
or
reused
once
(
at
the
time
it
is
introduced
into
the
system)
for
threshold
calculations
(
40
CFR
§
372.25(
e)).
(
Please
note
that
for
reporting
on­
site
waste
management
activities
the
quantity
of
the
EPCRA
Section
313
chemical
or
chemical
category
should
be
counted
every
time
it
exits
the
recycling
unit
in
Section
8
of
Form
R.)
EPCRA
Section
313
chemicals
and
chemical
categories
recycled
off
site
and
returned
to
the
facility
should
be
treated
as
newly
purchased
materials
for
purposes
of
EPCRA
Section
313
threshold
determinations.

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
sum
the
amount
for
each
EPCRA
Section
313
chemical
and
chemical
category
by
activity
category,
subtract
all
exempt
quantities,
and
compare
the
totals
to
the
applicable
thresholds.
Each
EPCRA
Section
313
chemical
and
chemical
category
exceeding
any
one
of
the
activity
thresholds
requires
the
submission
of
an
EPCRA
Section
313
report.
Provided
you
meet
certain
criteria
you
may
prepare
a
Form
A
certification
statement
rather
than
a
Form
R
(
see
Section
2.9).
3­
25
COMMON
ERROR
­
Assuming
a
Threshold
is
Exceeded
U.
S.
EPA
has
published
a
report,
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002,
with
the
site
survey
results
of
over
100
facilities
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
activity
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
report.
Note
that
if
the
release
and
other
waste
management
activity
quantity
is
500
pounds
or
less
for
each
chemical
or
chemical
category
you
may
be
eligible
to
use
the
alternate
certification
statement,
Form
A,
rather
than
a
Form
R
(
see
Section
2­
9).

COMMON
ERROR
­
Catastrophic
Events
It
is
worth
repeating
that
it
is
the
activity
threshold
amount
that
determines
whether
an
EPCRA
Section
313
report
must
be
filed.
Thus,
even
in
a
catastrophic
event
and
the
subsequent
release
and
other
waste
management
activities
of
the
residue,
an
EPCRA
Section
313
report
need
only
be
filed
if
the
activity
threshold
for
the
catastrophically
released
EPCRA
Section
313
chemical
or
chemical
category
has
been
exceeded.

To
determine
if
an
EPCRA
Section
313
chemical
or
chemical
category
exceeds
a
reporting
threshold,
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.
3­
26
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:

Example
­
Threshold
Worksheet
Assume
your
facility
purchases,
in
the
applicable
reporting
year,
two
mixtures
that
contain
xylene
(
mixed
isomers).
You
purchased
25,000
pounds
of
Mixture
A
(
which
is
50%
xylene,
by
weight,
according
to
the
MSDS)
and
110,000
pounds
of
Mixture
B
(
which
contains
20%
xylene,
by
weight).
Further,
you
determine
that
you
process
the
entire
quantity
of
Mixture
A,
while
you
process
only
half
of
Mixture
B
and
otherwise
use
the
other
half.
You
do
not
qualify
for
any
exempt
activities.

In
this
example,
you
would
have
processed
a
total
of
23,500
pounds
of
xylene
(
12,500
pounds
from
activities
associated
with
Mixture
A
and
11,000
pounds
from
activities
associated
with
Mixture
B).
You
would
also
have
otherwise
used
a
total
of
11,000
pounds
(
all
from
Mixture
B).
Therefore,
you
would
not
have
exceeded
the
25,000­
pound
threshold
for
processing;
however,
you
would
have
exceeded
the
10,000­
pound
threshold
for
otherwise
use
and
would
be
required
to
submit
an
EPCRA
Section
313
report
that
includes
releases
and
other
waste
management
quantities
from
all
activities
(
including
processing).
3­
27
Table
3­
5.
EPCRA
Section
313
Reporting
Threshold
Worksheet
Facility
Name:
Date
Worksheet
Prepared:
September
1,
2001_____________________

EPCRA
Section
313
Chemical
or
Chemical
Category:
Prepared
By:

_______________________________

CAS
Registry
Number:

Reporting
Year:

Amounts
of
chemical
or
chemical
category
manufactured,
processed,
or
otherwise
used.

Mixture
Name
or
Other
Identifier
Information
Source
Total
Weight
(
lb)
Percent
EPCRA
Section
313
Chemical
or
Chemical
Category
by
Weight
EPCRA
Section
313
Chemical
or
Chemical
Category
Weight
(
lb)
Amount
of
the
EPCRA
Section
313
Chemical
or
Chemical
Category
by
Activity
(
lb):

Manufactured
Processed
Otherwise
Used
1.
2.
3.
4.
Subtotal:
(
A)_________
lb.
(
B)_________
lb.
(
C)_________
lb.

Exempt
quantity
of
chemical
or
chemical
category
that
should
be
excluded.

Mixture
Name
as
Listed
Above
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
(
lb):

Manufactured
Processed
Otherwise
Used
1.
2.
3.
4.
Subtotal:
(
A1)_________
lb.
(
B1)_________
lb.
(
C1)_________
lb.

Amount
subject
to
threshold:
(
A­
A1)_____
lb.
(
B­
B1)_____
lb.
(
C­
C1)_____
lb.

Compare
to
threshold
for
EPCRA
Section
313
reporting.
Activity
threshold
quantities1:
25,000
lb.
25,000
lb.
10,000
lb.

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.]
1These
activity
thresholds
apply
to
non­
PBT
chemicals.
See
Section
2.6
for
activity
thresholds
applicable
to
PBT
chemicals.
Activity
threshold
for
dioxin
and
dioxin­
like
compounds
is
0.1
gram.
3­
29
Table
3­
6.
Sample
EPCRA
Section
313
Reporting
Threshold
Worksheet
Facility
Name:
Cartons
`
R
Us,
Inc.
Date
Worksheet
Prepared:
September
1,2001
EPCRA
Section
313
Chemical
or
Chemical
Category:
Xylene
(
mixed
isomers)
Prepared
By:
A.
B.
Calloway
CAS
Registry
Number:
1330­
20­
7
Reporting
Year:
2001
Amounts
of
chemical
or
chemical
category
manufactured,
processed,
or
otherwise
used.

Mixture
Name
or
Other
Identifier
Information
Source
Total
Weight
(
lb)
Percent
EPCRA
Section
313
Chemical
or
Chemical
Category
by
Weight
EPCRA
Section
313
Chemical
or
Chemical
Category
Weight
(
lb)
Amount
of
the
EPCRA
Section
313
Chemical
or
Chemical
Category
by
Activity
(
lb):

Manufactured
Processed
Otherwise
Used
1.
Mixture
A
MSDS
25,000
50%
12,500
­­­
12,500
­­­

2.
Mixture
B
MSDS
110,000
20%
22,000
­­­
11,000
11,000
3.
4.
Subtotal:
(
A)
0
lb.
(
B)
23,500
lb.
(
C)
11,000
lb.

Exempt
quantity
of
chemical
or
chemical
category
that
should
be
excluded.

Mixture
Name
as
Listed
Above
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
(
lb):

Manufactured
Processed
Otherwise
Used
1.
Mixture
A
none
2.
Mixture
B
none
3.
4.
Subtotal:
(
A1)
0
lb.
(
B1)
0
lb.
(
C1)
0
lb.

Amount
subject
to
threshold:
(
A­
A1)
0
lb.
(
B­
B1)
23,500
lb.
(
C­
C1)
11,000
lb.

Compare
to
threshold
for
EPCRA
Section
313
reporting.
Activity
threshold
quantities1:
25,000
lb.
25,000
lb.
10,000
lb.

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.]

1These
activity
thresholds
apply
to
non­
PBT
chemicals.
See
Section
2.6
for
activity
thresholds
applicable
to
PBT
chemicals.
Activity
threshold
for
dioxin
and
dioxin­
like
compounds
is
0.1
gram.
4­
1
CHAPTER
4
­
ESTIMATING
RELEASE
AND
OTHER
WASTE
MANAGEMENT
QUANTITIES
4.0
PURPOSE
This
chapter
is
intended
to
guide
the
user
in
developing
a
systematic
approach
for
estimating
release
and
other
waste
management
quantities
of
EPCRA
Section
313
chemicals
and
chemical
categories
released
and
otherwise
managed
as
waste
from
pulp
and
paper
production.

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
pulp,
paper,
and
paperboard
production
facilities.
The
general
discussion
(
Section
4.1)
is
followed
by
a
presentation
of
specific
examples
and
issues
(
Section
4.2).
The
basic
calculation
techniques
and
examples
provided
in
Appendix
B
may
be
used
to
estimate
the
release
and
other
waste
management
quantities
of
toxic
chemicals
and
chemical
categories.

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
2
Identify
EPCRA
Section
313
Chemicals
or
Chemical
Categories
Prepare
Process
Flow
Diagram
STEP
1:

STEP
2:

STEP
2:
STEP
3:

STEP
3:
STEP
4:

STEP
4:
Define
the
Operation
Review
Available
Data
&
Choose
Estimation
Method
Source
1
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
Off
Site
for
Disposal
On­
Site
Waste
Treatment
On­
Site
Energy
Recovery
On­
Site
Recycling
Source
3
Source
2
Identify
Sources
of
Release
and
Other
Waste
Management
Activities
Identify
Release
and
Other
Waste
Management
Activity
Types
Calculate
Estimates
for
Release
and
Other
Waste
Management
Activity
Quantities
Figure
4­
1.
Release
and
Other
Waste
Management
Activity
Calculation
Approach
4­
3
For
EPCRA
Section
313
reporting
purposes,
"
sources"
means
the
streams
or
units
that
generate
the
release
and
other
waste
management
activity
(
such
as
process
vents,
container
residue,
or
spills)
and
"
types"
means
the
environmental
media
corresponding
to
elements
in
Sections
5
through
8
of
the
2001
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,
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
releases;


Air
pollution
control
devices
(
e.
g.,
baghouses,
electrostatic
precipitators,
and
scrubbers;


Clean
up
and
housekeeping
practices;


Combustion
byproducts;


Container
residues;

Fittings;


Flanges;


Process
discharge
stream;


Process
vents;


Pumps;


Recycling
and
energy
recovery
byproducts;


Relief
valves;
4­
4

Stock
pile
losses;


Storage
tanks;


Storm
water
runoff;

Tower
stacks;


Transfer
operations;


Treatment
sludge;


Volatilization
from
process
or
treatment;
and

Waste
treatment
discharges.

Next,
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
(
40
CFR
§
372.3).
Table
2­
2
identifies
EPCRA
Section
313
chemicals
and
chemical
categories
typically
used
in
the
operations
common
to
the
production
of
pulp,
paper,
and
paperboard.
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,
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.
4­
5
Point
Sources
(
Part
II,
Sections
5.2
and
8.1)
Fugitive
Emissions
(
Part
II,
Sections
5.1
and
8.1)

Operation
Toxic
Chemical
In
On­
Site
Recycling
(
Part
II,
Sections
7C
and
8.4)
On­
Site
Energy
Recovery
(
Part
II,
Sections
7B
and
8.2)
On­
Site
Treatment
(
Part
II,
Sections
7A
and
8.6)
Transfer
Off
Site
for
Disposal
(
Part
II,
Sections
6.2
and
8.1)
Transfer
Off
Site
for
Treatment
(
Part
II,
Sections
6.2
and
8.7)
Transfer
Off
Site
for
Energy
Recovery
(
Part
II,
Sections
6.2
and
8.3)
Transfer
Off
Site
for
Recycling
(
Part
II,
Sections
6.2
and
8.5)

Receiving
Streams
(
Part
II,
Sections
5.3
and
8.1)
Underground
Injection
(
Part
II,
Sections
5.4
and
8.1)
POTW
(
Part
II,
Sections
6.1
and
8.1,
or
8.7)

Land
on
site
(
landfill,
land
treatment,
surface
impoundment)
(
Part
II,
Sections
5.5
and
8.1)

Figure
4­
2.
Possible
Release
and
Other
Waste
Management
Types1
for
EPCRA
Section
313
Chemicals
and
Chemical
Categories
1Sections
refer
to
2001
Form
R.
Quantities
released
to
the
environment
as
a
result
of
remedial
actions,
catastrophic
events,
or
one­
time
events
should
be
reported
in
Part
II,
Section
8
as
Subsection
8.8.

a.
Fugitive
or
Non­
Point
Air
Emissions
(
Part
II,
Section
5.1
of
Form
R)
­
Includes
all
emissions
to
the
air
that
are
not
released
through
stacks,
vents,
ducts,
pipes,
or
any
confined
air
stream.
Examples
include:


Equipment
leaks
from
valves,
pump
seals,
flanges,
compressors,
sampling
connections,
open­
ended
lines,
etc.;


Releases
from
building
ventilation
systems,
such
as
a
roof
fan
in
an
open
room;


Evaporative
losses
from
solvent
cleaning
tanks,
surface
impoundments,
and
spills;
and

Emissions
from
any
other
fugitive
or
non­
point
source.
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,
4­
6
pipes,
or
any
confined
air
stream,
including
the
emissions
from
storage
tanks
and
air
pollution
control
equipment.
Air
emissions
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,
certain
state
air
qality
reporting
requirements,
not
associated
with
EPCRA
Section
313
reporting,
consider
ventilation
systems
to
be
a
stack
or
point
source.

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
5.5.1A)
or
a
non­
hazardous
waste
landfill
(
Part
II,
Section
5.5.1B).
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
because
of
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
4­
7
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
biodegraded
by
microorganisms
or
plants,
it
is
not
considered
recycled,
reused,
or
treated.

(
3)
Surface
impoundment
­
A
surface
impoundment
is
a
natural
topographic
depression,
man­
made
excavation,
or
diked
area
formed
primarily
of
earthen
materials
that
is
designed
to
hold
an
accumulation
of
wastes
containing
free
liquids.
Examples
include:
holding,
settling,
storage,
and
elevation
pits;
ponds;
and
lagoons.
Quantities
of
the
toxic
chemical
released
to
surface
impoundments
that
are
used
merely
as
part
of
a
wastewater
treatment
process
generally
must
not
be
reported
in
this
section.
However,
if
the
sludge
from
the
surface
impoundment
contains
the
EPCRA
Section
313
chemical
or
chemical
category,
then
the
EPCRA
Section
313
chemicals
or
chemical
categories
in
the
sludge
should
be
reported
in
this
section
unless
the
sludge
is
removed
and
subjected
to
another
waste
management
activity.

(
4)
Other
disposal
­
Releases
to
land
that
do
not
fit
the
categories
of
landfills,
land
treatment,
or
surface
impoundment
are
classified
as
other
disposal.
This
disposal
may
include
any
spills
or
leaks
of
the
EPCRA
Section
313
chemical
or
chemical
category
to
land.

f.
Discharges
to
Publicly
Owned
Treatment
Works
(
POTW)
(
Part
II,
Section
6.1
of
Form
R)
­
Includes
the
amount
of
EPCRA
Section
313
chemical
or
chemical
category
in
water
transferred
to
an
off­
site
POTW.
Note
that
metals
and
metal
compounds
transferred
to
a
POTW
must
also
be
reported
in
Section
8.1
(
40
CFR
§
372.85(
b)(
16)(
i)).

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
(
40
CFR
§
372.85(
b)(
16)(
ii)).
4­
8
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
must
report
the
disposition
of
the
waste
solvent
as
appropriate.
If
the
containers
are
sent
off
site
for
disposal
or
reclamation,
you
should
report
the
EPCRA
Section
313
chemical
or
chemical
category
in
this
section
(
40
CFR
§
372.85(
b)(
16)(
ii)).

COMMON
ERROR
­
Shipping
Container
Residue
Do
not
overlook
residual
toxic
chemicals
or
chemical
categories
in
containers.
U.
S.
EPA
has
published
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002,
presenting
the
site
survey
results
of
over
100
facilities
to
evaluate
EPCRA
Section
313
reporting
quality.
This
survey
found
the
largest
source
of
overlooked
release
and
other
waste
management
activities
was
from
container
residue.
So­
called
"
empty"
drums
may
contain
an
inch
or
more
of
liquid
after
draining
and
similarly
"
empty"
bags
may
contain
residues
of
dust
and
powder.
Even
though
each
individual
drum
or
bag
may
only
contain
a
small
amount
of
an
EPCRA
Section
313
chemical
or
chemical
category,
for
facilities
that
receive
hundreds
or
thousands
of
drums
or
bags
each
year
the
annual
cumulative
amount
of
an
EPCRA
Section
313
chemical
or
chemical
category
can
be
substantial.
The
quantities
should
typically
be
reported
in
Section
6.2.
(
see
Table
4­
1
for
estimates
of
liquid
drum
residual
and
the
text
of
this
section
for
estimates
of
residual
from
solids).
Please
note
that
unlike
RCRA,
EPCRA
Section
313
does
not
define
what
constitutes
an
"
empty"
container.

Actual
data
and
a
knowledge
of
the
unloading
methods
at
your
facility
can
be
used
to
estimate
the
quantity
of
residual
EPCRA
Section
313
chemicals
or
chemical
categories
in
containers.
However,
U.
S.
EPA
has
developed
guidance
to
assist
facilities
if
no
site­
specific
information
is
available.
Table
4­
1
provides
results
from
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.
No
testing
was
conducted
for
residual
solids
in
this
study.
If
data
or
site­
specific
knowledge
is
available
to
estimate
the
quantity
of
solid
residual
in
containers,
it
should
be
considered.
If
no
data
are
available,
U.
S.
EPA
believes
an
estimate
of
1%
residual
solid
material
is
reasonable.
4­
9
Table
4­
1
Summary
of
Residue
Quantities
From
Pilot­
Scale
Experimental
Studya,
b
(
weight
percent
of
drum
capacity)

Unloading
Method
Vessel
Type
Value
Material
Kerosenec
Waterd
Motor
Oile
Surfactant
Solutionf
Pumping
Steel
drum
Range
Mean
1.93
­
3.08
2.48
1.84
­
2.61
2.29
1.97
­
2.23
2.06
3.06
3.06
Pumping
Plastic
drum
Range
Mean
1.69
­
4.08
2.61
2.54
­
4.67
3.28
1.70
­
3.48
2.30
Not
Available
Pouring
Bung­
top
steel
drum
Range
Mean
0.244
­
0.472
0.404
0.266
­
0.458
0.403
0.677
­
0.787
0.737
0.485
0.485
Pouring
Open­
top
steel
drum
Range
Mean
0.032
­
0.080
0.054
0.026
­
0.039
0.034
0.328
­
0.368
0.350
0.089
0.089
Gravity
Drain
Slope­
bottom
steel
tank
Range
Mean
0.020
­
0.039
0.033
0.016
­
0.024
0.019
0.100
­
0.121
0.111
0.048
0.048
Gravity
Drain
Dish­
bottom
steel
tank
Range
Mean
0.031
­
0.042
0.038
0.033
­
0.034
0.034
0.133
­
0.191
0.161
0.058
0.058
Gravity
Drain
Dish­
bottom
glass­
lined
tank
Range
Mean
0.024
­
0.049
0.040
0.020
­
0.040
0.033
0.112
­
0.134
0.127
0.040
0.040
aFrom
"
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.
cFor
kerosene,
viscosity
=
5
centipoise,
surface
tension
=
29.3
dynes/
cm2
dFor
water,
viscosity
=
4
centipoise,
surface
tension
=
77.3
dynes/
cm2
eFor
motor
oil,
viscosity
=
97
centipoise,
surface
tension
=
34.5
dynes/
cm2
fFor
surfactant
solution
viscosity
=
3
centipoise,
surface
tension
=
31.4
dynes/
cm2
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.
4­
10
Example
­
Container
Residue
You
have
determined
that
a
Form
R
for
an
EPCRA
Section
313
chemical
must
be
submitted.
The
facility
purchases
and
uses
one
thousand
55­
gallon
steel
drums
that
contain
a
10%
aqueous
solution
of
the
toxic
chemical.
Further,
it
is
assumed
that
the
physical
properties
of
the
solution
are
similar
to
water.
The
solution
is
pumped
from
the
drums
directly
into
a
mixing
vessel
and
the
"
empty"
drums
are
triple­
rinsed
with
water.
The
rinse
water
is
indirectly
discharged
to
a
POTW
and
the
cleaned
drums
are
sent
to
a
drum
reclaimer.

From
Table
4­
1,
the
average
drum
residue
quantity
for
this
scenario
is
2.29%.
In
this
example,
it
can
be
assumed
that
all
of
the
residual
solution
in
the
drums
was
transferred
to
the
rinse
water.
Therefore,
the
quantity
of
the
EPCRA
Section
313
chemical
transferred
to
the
drum
reclaimer
should
be
reported
as
"
zero."

The
annual
quantity
of
residual
solution
that
is
transferred
to
the
rinse
water
can
be
estimated
by
multiplying
the
mean
weight
percent
of
residual
solution
remaining
in
a
pumped
steel
drum
by
the
total
annual
weight
of
solution
in
the
drums.
If
the
density
is
not
known,
it
may
be
appropriate
to
use
the
density
of
water
(
8.34
pounds
per
gallon):

(
0.0229)
×
(
55
gal/
drum)
×
(
1,000
drums)
×
(
8.34
lb/
gal)
=
10,504
pounds
solution
The
concentration
of
the
EPCRA
Section
313
chemical
in
the
solution
is
only
10%.

(
10,504
lb
solution)
×
(
0.1)
=
1,050
pounds
of
the
EPCRA
Section
313
chemical
Therefore,
1,050
pounds
of
the
EPCRA
Section
313
chemical
are
transferred
to
the
POTW,
and
should
be
reported
in
Part
II,
Sections
6.1
and
8.7
of
the
2001
Form
R.
Because
they
cannot
be
destroyed,
metals
cannot
be
reported
as
being
treated,
and
metals
and
metal
portions
of
metal
compounds
should
be
reported
in
Part
II,
Section
6.1
and
8.1
of
the
2001
Form
R.

Common
Error
­
Reporting
Off­
Site
Recycling
To
report
an
EPCRA
Section
313
chemical
or
chemical
category
as
a
transfer
off
site
for
recycling,
the
reporting
facility
must
have
positive
knowledge
that
the
chemical
is
actually
being
recycled.
If
a
waste
stream
or
container
residue
is
sent
off
site
for
recycling
but
the
EPCRA
Section
313
chemical
or
chemical
category
is
not
recycled
the
reporting
facility
must
report
the
ultimate
disposal
of
the
EPCRA
Section
313
chemical
or
chemical
category.
If
the
disposal
method
is
unknown,
report
it
as
such
with
the
unknown
disposal
code
"
M99"
in
Section
6.2C
and
the
quantity
in
Section
8.1
of
the
2001
Form
R
(
40
CFR
§
372.85(
b)(
16)
&
(
17)).

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
are
based
on
actual
operating
data.
Metals
and
metal
portions
of
metal
compounds
treated
in
a
combustion
process
are
not
destroyed
but
should
still
be
reported
as
going
through
the
treatment
process,
with
a
treatment
efficiency
of
zero.
Note
that
only
the
metal
portion
of
metal
compounds
4­
11
should
be
reported
in
the
Form
R.
The
following
example
illustrates
how
Section
7A
could
be
completed
for
on­
site
treatment
of
a
wastewater
stream
containing
three
EPCRA
Section
313
chemicals
or
chemical
categories.

Example
­
On­
Site
Waste
Treatment
A
process
at
your
facility
generates
a
wastewater
stream
containing
an
EPCRA
Section
313
chemical
(
chemical
A).
A
second
process
generates
a
wastewater
stream
containing
two
EPCRA
Section
313
chemicals,
a
metal
(
chemical
B)
and
a
mineral
acid
(
chemical
C).
Thresholds
for
all
three
chemicals
have
been
exceeded
and
you
are
in
the
process
of
completing
separate
Form
Rs
for
each
chemical.

The
two
wastewater
streams
are
combined
and
sent
to
an
on­
site
wastewater
treatment
system
before
being
released
to
a
POTW.
This
system
consists
of
an
oil/
water
separator
that
removes
99%
of
chemical
A;
a
neutralization
tank
in
which
the
pH
is
adjusted
to
7.5,
thereby
destroying
100%
of
the
mineral
acid
(
chemical
C);
and
a
settling
tank
where
95%
of
the
metal
(
chemical
B)
is
removed
from
the
water
(
and
eventually
land
filled
off
site).

Section
7A
would
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
would
be
completed
for
each
chemical
or
chemical
category.
First,
on
each
Form
R
identify
the
type
of
waste
stream
in
Section
7A.
1a
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.
1b
of
all
three
Form
Rs
should
show:
P19
(
liquid
phase
separation),
C11
(
neutralization),
P11
(
settling/
clarification),
and
N/
A
(
to
signify
the
end
of
the
treatment
system).
Note
that
Section
7A.
1b
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
7A.
1c
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.
1d
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
(
40
CFR
§
372.85(
b)(
17)).

[
continued
on
next
page]
4­
12
Chemical
A
7A.
1a
7A.
1b
1.
P19
2.
C11
7A.
1c
7A.
1d
7A.
1e
W
3.
P11
4.
N/
A
5.
1
99
%
Yes
No
6.
7.
8.
X
Chemical
B
7A.
1a
7A.
1b
1.
P19
2.
C11
7A.
1c
7A.
1d
7A.
1e
W
3.
P11
4.
N/
A
5.
1
95
%
Yes
No
6.
7.
8.
X
Chemical
C
7A.
1a
7A.
1b
1.
P19
2.
C11
7A.
1c
7A.
1d
7A.
1e
W
3.
P11
4.
N/
A
5.
1
100
%
Yes
No
6.
7.
8.
X
Note
that
the
quantity
removed
and/
or
destroyed
is
not
reported
in
Section
7
and
that
the
efficiency
reported
in
Section
7A.
1d
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
would
be
reported
in
Section
8.6
(
quantity
treated
on
site).
For
example,
when
completing
the
Form
R
for
chemical
B
you
would
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
would
be
reported
in
Section
6.2
and
8.1.
However,
when
completing
the
Form
R
for
chemical
C
you
would
report
the
entire
quantity
in
Section
8.6
because
raising
the
pH
to
7.5
will
completely
destroy
the
mineral
acid.

Common
Error
­
Wastewater
Treatment
Chemicals
Many
facilities
operate
their
own
wastewater
treatment
plants
and
use
EPCRA
Section
313
chemicals
or
chemical
categories
in
the
treatment
process.
During
the
site
surveys
conducted
to
determine
the
quality
of
the
EPCRA
Section
313
data
being
reported
it
was
noted
that
some
facilities
incorrectly
reported
the
EPCRA
Section
313
chemicals
or
chemical
categories,
such
as
phosphoric
acid,
ammonia,
and
chlorine,
otherwise
used
in
the
treatment
of
the
wastewater
as
treated
on
site.
U.
S.
EPA's
current
interpretation
is
that
EPCRA
Section
313
chemicals
and
chemical
categories
used
for
treatment
cannot
be
considered
treated
themselves.

The
complete
results
of
the
site
survey
program
was
published
as
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002.

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
can
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)
(
see
PPA
§
6607;
63
FR
52,184).
Metals
and
metal
portions
of
metal
compounds
will
never
be
combusted
for
energy
recovery.
2The
Subsection
8.1
through
8.8
designations
are
for
the
2001
Form
R.
Please
refer
to
the
current
reporting
year
TRI
Forms
and
Instructions
for
any
changes.

4­
13
Common
Error
­
On­
Site
Energy
Recovery
vs.
On­
Site
Treatment
Several
facilities
visited
during
the
site
surveys
conducted
to
determine
the
quality
of
the
EPCRA
Section
313
data
being
reported
were
combusting
their
waste
stream,
containing
several
organic
EPCRA
Section
313
chemicals
or
chemical
categories,
in
on­
site
recovery
boilers.
Some
of
the
facilities
reported
this
as
on­
site
treatment
while
others
reported
it
as
on­
site
energy
recovery.
U.
S.
EPA's
current
guidance
is
that
if
the
chemicals
have
significant
heating
value,
they
should
be
reported
to
on­
site
energy
recovery.
The
complete
results
of
the
site
survey
program
was
published
as
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002.

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)
2
­
Provide
information
about
source
reduction
and
recycling
activities
related
to
the
EPCRA
Section
313
chemical
or
chemical
category
for
which
release
and
other
waste
management
activities
are
being
reported.
Section
8
uses
some
data
collected
to
complete
Part
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
quantity
reported
in
Section
8.8
that
was
released
on
site
or
sent
off
site
for
disposal:

§
8.1
=
§
5
+
§
6.1
(
metals
and
metal
compounds)
+
§
6.2
(
disposal)
­
§
8.8
(
on­
site
release
or
off­
site
disposal
only)

(
2)
Quantity
Used
for
Energy
Recovery
On­
Site
(
Part
II,
Section
8.2
of
Form
R)
­
Estimate
the
quantity
of
the
EPCRA
Section
313
chemical
or
chemical
category
in
wastes
combusted
for
energy
recovery
on
site.
This
estimate
should
be
the
quantity
of
the
toxic
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,
4­
14
vendor
specifications
regarding
combustion
efficiency
may
be
used
as
they
relate
to
the
EPCRA
Section
313
chemical
or
chemical
category.
There
should
be
quantities
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
toxic
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
(
63
FR
52,184).
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)

Two
conditions
need
to
be
met
to
report
the
combustion
of
an
EPCRA
Section
313
chemical
or
chemical
category
in
waste
as
energy
recovery:
the
chemical
or
chemical
category
(
1)
must
have
a
significant
heating
value
and
(
2)
must
be
combusted
in
an
energy
recovery
unit,
such
as
a
waste
heat
boiler,
an
industrial
furnace,
or
a
kiln.
If
an
EPCRA
Section
313
chemical
or
chemical
category
that
does
not
have
a
significant
heating
value
(
except
metals
and
metal
compounds)
is
sent
off
site
for
energy
recovery,
it
must
be
considered
off­
site
waste
treatment
(
see
4.1.3.
g).
However,
this
does
not
apply
to
metals
and
metal
compounds.
Metals
and
metal
compounds
sent
off
site
for
combustion
in
energy
recovery
units
must
be
considered
as
sent
off
site
for
disposal
because
typically
they
will
ultimately
be
disposed.
Metals
and
metal
portions
of
metal
compounds
will
never
be
treated
or
combusted
for
energy
recovery.
Note
that
only
the
metal
portion
of
metal
compounds
4­
15
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,
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.
If
the
facility
has
knowledge
regarding
metals
being
recovered,
this
quantity
would
be
reported
in
Section
8.5
(
PPA
§
6607).

§
8.5
=
§
6.2
(
recycling)
­
§
8.8
(
off­
site
recycling)

COMMON
ERROR
­
Direct
Reuse
vs.
Recycling
The
direct
reuse
of
an
EPCRA
Section
313
chemical
does
not
need
to
be
included
in
the
amount
reported
in
Part
II,
Section
8
of
Form
R.
However,
recycling
of
the
chemical
should
be
included
(
40
CFR
§
372.25(
e)).

(
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
estimate
the
quantity
treated,
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
4­
16
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
(
40
CFR
§
372.85(
b)(
17)).

(
7)
Quantity
Treated
Off­
Site
(
Part
II,
Section
8.7
of
Form
R)
­
The
quantity
reported
in
Section
8.7
would
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
because
of
any
of
the
following
events:


Remedial
actions;


Catastrophic
events
such
as
earthquakes,
fires,
or
floods;
or

One­
time
events
not
associated
with
normal
or
routine
production
processes.

The
quantity
reported
in
Section
8.8
should
not
be
included
with
quantities
reported
in
Part
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.
4­
17
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
"
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
release
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,
EPA
recommends
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.

Another
potential
double
counting
situation
was
noted
during
the
site
surveys
conducted
to
determine
the
quality
of
the
EPCRA
Section
313
data
being
reported.
See
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002.
This
error
typically
occurred
when
a
facility
had
a
very
accurate
way
to
estimate
some
release
and
other
waste
management
quantities
but
also
used
a
material
balance
to
estimate
other
quantities.
Sometimes
the
earlier
estimates
were
not
subtracted
from
the
later
estimates
thus
resulting
in
double
counting.

Common
Error
­
Source
Reduction
Credit
Some
facilities
surveyed
to
determine
the
quality
of
data
submitted
in
compliance
with
EPCRA
Section
313
were
not
reporting
source
reduction
correctly.
They
indicated
to
the
surveyors
they
only
take
credit
for
source
reduction
if
they
implement
a
procedure
specifically
for
the
purpose
of
reducing
releases.
For
example,
a
management
decision
to
implement
a
new
material
transfer
operation
was
made
to
reduce
costs
associated
with
the
old
procedure.
The
new
transfer
operation
coincidentally
also
reduced
the
release
amount
of
an
EPCRA
Section
313
chemical.
This
should
be
reported
as
a
source
reduction
in
Section
8.10
of
the
1998
Form
R.
The
complete
results
of
the
site
survey
program
was
published
as
The
1994
and
1995
Toxic
Release
Inventory
Data
Quality
Report,
EPA
745­
R­
98­
002.
4­
18
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,
estimate
the
quantities
of
each
EPCRA
Section
313
chemical
and
chemical
category
released
and
otherwise
managed
as
waste.
U.
S.
EPA
has
identified
four
basic
methods
that
may
be
used
to
develop
estimates
(
each
method
has
been
assigned
a
code
that
must
be
included
when
reporting).
The
methods
and
corresponding
codes
are:


Monitoring
Data
or
Direct
Measurement
(
M);


Mass
Balance
(
C);


Emission
Factors
(
E);
and,


Engineering
Calculations
(
O).

Descriptions
of
these
techniques
are
provided
in
the
U.
S.
EPA
publication,

Estimating
Releases
and
Waste
Treatment
Efficiencies
for
the
Toxic
Chemical
Release
Inventory
Forms
(
2002
edition).
They
are
also
briefly
described
below.
A
more
detailed
discussion
including
examples
of
selected
calculation
techniques
is
presented
in
Appendix
B.
EPCRA
does
not
require
you
to
conduct
additional
sampling
or
testing
for
EPCRA
Section
313
reporting.

Rather,
facilities
may
use
readily
available
data
collected
pursuant
to
other
provisions
of
law,
or
where
such
data
are
not
readily
available,
reasonable
estimates
of
the
amounts
involved
(
EPCRA
§
313(
g)(
2)).
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
(
40
CFR
§
372.85(
b)(
15)(
i)).

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.
4­
19
Once
all
potential
release
and
other
waste
management
activity
sources,
types,
and
estimation
methods
have
been
determined,
an
estimate
for
each
EPCRA
Section
313
chemical
and
chemical
category
can
be
developed
corresponding
to
the
elements
on
Form
R.

Table
4­
2
Potential
Data
Sources
for
Release
and
Other
Waste
Management
Calculations
DATA
SOURCES
Monitoring
Data
Mass
Balance

Air
permits

Continuous
emission
monitoring

Effluent
limitations

Hazardous
waste
analysis

Industrial
hygiene
monitoring
data

NPDES
permits

New
Source
Performance
Standards

Outfall
monitoring
data

pH
for
acids
and
bases

POTW
pretreatment
standards

RCRA
permit

Stack
monitoring
data

Title
V
Permit
data

Air
emissions
inventory

Hazardous
material
inventory

Hazardous
waste
manifests

MSDSs

Pollution
prevention
reports

Spill
event
records

Supply
and
purchasing
records
Emission
Factors
Engineering
Calculations

AP­
42
chemical
specific
emission
factors

Facility
or
trade
association
derived
chemicalspecific
emission
factors

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
4­
20

(
2
mg/
L)
×
g
1,000
mg
×
lb
453.59
g
×
L
0.2642
gal
×
1,500,000
gal/
yr
Input
+
Generation
=
Output
+
Consumption
developing
estimates.
Data
may
have
also
been
collected
for
your
facility
through
an
occupational
health
and
safety
assessment.
If
only
a
small
amount
of
direct
measurement
data
is
available
or
if
you
believe
the
monitoring
data
are
not
representative,
you
must
decide
if
another
estimation
method
would
give
a
more
accurate
result.

Example
­
Monitoring
Data
Data
from
the
on­
site
wastewater
treatment
facility
indicate
that
the
annual
average
concentration
of
copper
in
the
discharge
is
2
mg/
L.
The
wastewater
treatment
facility
processed
1.5
million
gallons
of
water.
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
=
25
lb/
yr
COMMON
ERROR
­
Treatment
Efficiencies
Vendor
data
on
treatment
efficiencies
often
represent
ideal
operating
conditions.
You
may
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:
4­
21
where:


Input
refers
to
the
materials
(
chemicals)
entering
an
operation.
For
example,
chlorine
added
to
process
water
as
a
disinfectant
would
be
considered
an
input
to
the
water
treatment
operation.


Generation
identifies
those
chemicals
created
during
an
operation
(
manufactured,
including
coincidental
manufacturing).
For
example,
when
nitrogen
sources
are
used
in
biological
wastewater
treatment
systems,
nitrate
compounds
may
be
coincidentally
manufactured.


Output
refers
to
the
materials
(
chemicals)
leaving
an
operation
by
various
avenues.
Output
(
avenues)
may
include
on­
site
release
and
other
on­
site
waste
management
activities;
transfers
off
site
for
recycling,
energy
recovery,
treatment,
storage,
or
disposal;
or
the
amount
of
chemical
that
leaves
with
the
final
product.
In
a
paperboard
coating
operation,
for
example,
pigments
in
the
paint
may
leave
the
facility
as
part
of
the
product
(
the
coating),
in
wastewater
collected
from
overspray,
and
as
fugitive
or
stack
air
emissions.


Consumption
refers
to
the
amount
of
chemical
converted
to
another
substance
during
the
operation
(
i.
e.,
reacted).

The
mass
balance
technique
may
be
applied
toward
manufactured,
processed,
or
otherwise
used
toxic
chemicals
and
chemical
categories.
It
is
typically
most
useful
for
otherwise
used
toxic
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.

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
paper
and
paperboard
production
are
classified
as
otherwise
used.
Such
chemicals
and
chemical
categories
may
or
may
not
leave
the
facility
with
the
product.
For
those
instances
where
the
EPCRA
Section
313
chemical
or
chemical
category
does
not
leave
the
facility
in
the
product,
all
throughput
may
be
lost
during
processing
through
on­
site
releases
to
air,
water,
or
land,
or
it
may
be
shipped
off
site
for
further
waste
management
activities.
Thus,
the
entire
throughput
is
often
reportable
on
Form
R
as
release
and
other
waste
management
activities
to
various
media.
Be
sure
to
consider
the
entire
throughput
in
these
circumstances
and
partition
it
as
appropriate.
A
mass
balance
may
be
the
best
starting
point
to
estimate
the
release
and
other
waste
management
quantities.
4­
22
Example
­
Using
a
Mass
Balance
and
Engineering
Assumption
to
Estimate
Releases
of
Ethylene
Glycol
via
Wastewater
A
papermaking
facility
used
12,200
pounds
of
an
EPCRA
Section
313
chemical
during
the
reporting
year
in
a
biocide
formulation
applied
on
the
wet
end
of
its
paper
machine.
To
estimate
releases
of
this
chemical,
it
can
be
assumed
that
the
chemical
does
not
become
part
of
the
paper
product,
because
its
miscibility
in
water
causes
it
to
be
removed
almost
completely
from
the
paper
web
during
the
forming
and
pressing
functions.
It
can
further
be
assumed
that
fugitive
air
emissions
are
unlikely
because
of
its
low
volatility
(
vapor
pressure
~
0.1
mmHg
at
20

C).

After
forming
and
pressing
functions
are
completed,
the
white
water
in
the
system
carries
the
chemical
through
a
saveall.
A
portion
of
the
filtered
white
water
is
discharged
as
wastewater,
and
the
rest
is
recirculated.
Assuming
that
none
is
retained
in
the
product
or
emitted
to
air,
on
a
mass
balance
basis,
all
of
the
chemical
used
in
this
facility
will
eventually
end
up
in
the
wastewater.
All
12,200
pounds
of
the
chemical
used
during
the
year
was
therefore
contained
in
this
facility's
wastewater.

If
the
facility
discharged
the
wastewater
to
a
POTW,
a
transfer
of
12,200
pounds
of
the
chemical
to
an
offsite
disposal
facility
would
be
reported.
If
the
wastewater
was
pretreated
before
discharge,
the
amount
of
chemical
removed
from
the
wastewater
during
the
pretreatment
process
would
be
subtracted
from
the
12,200
pounds.

The
amount
discharged
to
the
POTW
would
be
reported
in
Part
II,
Sections
6.1
and
8.1
(
metals
and
metal
compounds)
of
the
2001
Form
R.

4.1.4.3
Emission
Factors
(
code
E)

An
emission
factor
is
a
representative
value
that
attempts
to
relate
the
quantity
of
a
toxic
chemical
or
chemical
category
released
with
an
associated
activity.
These
factors
are
usually
expressed
as
the
weight
of
toxic
chemical
or
chemical
category
released
divided
by
a
unit
weight,
volume,
distance,
or
duration
of
the
activity
releasing
the
toxic
chemical
(
e.
g.,
pounds
of
chemical
released
per
pounds
of
product
produced).
Emission
factors,
commonly
used
to
estimate
air
emissions,
have
been
developed
for
many
different
industries
and
activities.
You
should
carefully
evaluate
the
source
of
the
emission
factor
and
the
conditions
for
its
use
to
determine
if
it
is
applicable
to
the
situation
at
your
facility.
If
there
are
more
than
one
EPA
published
emission
factors,
determine
which
is
the
most
appropriate
for
your
operations
and
document
your
rationale.

The
most
widely
known
and
used
source
for
emission
factors
is
U.
S.
EPA's
publication
Compilation
of
Air
Pollutant
Emission
Factors
(
AP­
42).
Volume
I
of
AP­
42
contains
information
on
over
200
stationary
source
categories,
including
process
descriptions
and
potential
4­
23
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
toxic
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
pulp,
paper,
and
paperboard
production
facilities
would
be
Chapter
1:
External
Combustion
Sources,
in
particular
Section
1.6
Wood
Waste
Combustion
in
Boilers;
Chapter
4:
Evaporation
Loss
Sources,
in
particular
Section
4.2.2.6
Paper
Coating;
Chapter
7:
Liquid
Storage
Tanks;
and
Chapter
10:

Wood
Products
Industry.
The
Table
of
Contents
for
Chapter
10
shows
four
sections
of
potential
interest
to
pulp,
paper,
and
paperboard
production
facilities:

Section
10.1,
Lumber,
Section
10.2,
Chemical
Wood
Pulping,
Section
10.3,
Pulp
Bleaching,
and
Section
10.4,
Papermaking.

Please
check
the
AP­
42
Internet
site
(
see
below)
for
the
latest
status
of
these
sections.

AP­
42
can
be
accessed
at
the
following
Internet
site:


http://
www.
epa.
gov/
ttn/
chief/
ap42.
html
Combustion
emission
factors
for
metal
compounds,
hydrochloric
acid,
and
hydrogen
flouride
are
included
in
U.
S.
EPA's
Guidance
for
Electricity
Generating
Facilities
(
EPA
745­
B­
00­
004).
This
document
can
be
accessed
at
http://
www.
epa.
gov/
tri.

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
4­
24
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;

"
WATER8"
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
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
calculations"
for
the
purposes
of
EPCRA
Section
313
reporting.

Example
­
Emission
Factors
Emission
factors
have
been
developed
for
air
releases
of
fuel
constituents
and
combustion
products
from
boiler
operations.
AP­
42
lists
a
following
emission
factor
for
formaldehyde
when
No.
6
fuel
oil
is
consumed
by
electricity
generating
facilities
(
EGFs):

0.033
lb
formaldehyde
generated/
103
gal
No.
6
fuel
oil
fired.

Assuming
a
facility
met
reporting
requirements
for
formaldehyde,
the
facility
operating
a
boiler
using
No.
6
fuel
oil
could
use
the
above
emission
factor
to
determine
the
amount
of
formaldehyde
generated
and
subsequently
released
to
the
air.
If
1,000,000
gallons
of
No.
6
fuel
oil
is
used
during
a
reporting
year,
the
amount
of
formaldehyde
generated
would
be:

(
0.033
lb/
103
gal)
×
(
1,000,000
gal)

=
33
lb
of
formaldehyde
generated
If
there
are
no
engineering
controls
or
air
pollution
control
devices
that
would
destroy
or
remove
the
formaldehyde,
this
quantity
would
be
reported
in
Part
II,
Sections
5.2
and
8.1
of
the
2001
Form
R.

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
25
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.

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
should
be
classified
as
"
Engineering
Calculations"
for
EPCRA
Section
313
reporting.
4­
26
Examples
­
Engineering
Calculations
Example
1:
A
papermaking
facility
discharged
an
average
of
200,000
gallons
of
treated
wastewater
per
day
to
a
nearby
river.
Zinc
oxide,
which
was
used
as
a
paper
filler,
was
added
to
the
refiner.
An
estimated
45
percent
(
or
90,000
gallons
per
day)
of
the
wastewater
from
the
entire
facility
was
generated
from
the
area
in
which
the
zinc
oxide
was
used.
Assuming
that
the
zinc
oxide
concentration
in
the
wastewater
is
equal
to
its
solubility
in
cold
water
(
0.00016
gram/
100
gram
H2O),
the
annual
quantity
of
zinc
in
the
raw
wastewater
from
the
facility,
which
operates
350
days
per
year,
can
be
calculated
as
follows.
(
Atomic
weight
of
Zn=
65.4;
molecular
weight
of
ZnO=
81.4)

(
0.00016
gram/
100
ml
H2O;
solubility
of
ZnO)
x
(
1
lb/
454
gram;
conversion
factor)
x
(
3,780
ml/
gal;
conversion
factor)
x
(
90,000
gal/
day;
wastewater
flow
rate)
x
(
65.4
lb
Zn/
81.4
lb
ZnO;
ratio
of
weight
of
Zn
to
weight
of
ZnO)
x
(
350
days/
year;
facility
operating
time)
=

=
322
pounds
of
zinc
per
year
The
preceding
calculations
were
used
to
estimate
the
quantity
of
zinc
in
the
raw
wastewater.
The
operators
of
this
facility
developed
a
treatment
factor
to
consider
the
treatment
before
discharge
for
various
toxic
compounds.
They
reviewed
the
literature
on
waste
treatment
in
papermaking
facilities
and
found
that,
for
the
treatment
system
at
their
facility,
80%
of
the
zinc
is
removed
from
the
facility
wastewater.
Because
zinc
cannot
be
destroyed
during
treatment,
the
amount
removed
was
actually
transferred
to
the
wastewater
sludge
which
is
disposed
in
a
RCRA
Subtitle
C
landfill
on
site.
The
remaining
20%
of
the
zinc
(
64
pounds)
passed
through
treatment
and
was
released
to
a
receiving
stream.
The
80%
(
258
pounds)
partitioned
to
the
wastewater
sludge
is
subsequently
landfilled
on
site.
The
64
pounds
in
the
on­
site
treatment
plant
effluent
would
be
reported
in
Part
II,
Sections
5.3
and
8.1
of
the
1998
Form
R.
The
258
pounds
landfilled
on
site
would
be
reported
in
Part
II,
Sections
5.5.1A
and
8.1
of
the
1998
Form
R.

Example
2:
Stack
monitoring
data
are
available
for
xylene
but
you
are
required
to
report
for
toluene.
Toluene
is
used
in
the
same
application
as
xylene
at
your
facility
and
the
concentrations
of
the
chemicals
in
the
liquid
feedstock
are
approximately
the
same.
You
can
estimate
the
emissions
of
toluene
by
adjusting
the
monitoring
data
of
xylene
by
a
ratio
of
the
vapor
pressure
for
xylene
to
toluene.
This
example
is
an
engineering
calculation
based
on
physical
properties
and
process
operation
information:

From
facility
stack
monitoring
data,
you
determine
that
an
estimated
200
lb
of
xylene
are
released
as
air
emissions
during
the
reporting
year.
Toluene
is
also
present
in
the
air
emissions,
but
not
monitored.
The
stack
operates
at
approximately
20
N
C.
Based
on
literature
data,
the
vapor
pressure
at
20
N
C
for
toluene
is
22
millimeters
of
mercury
(
mmHg)
and
for
xylene
is
6
mmHg.
Using
a
ratio
of
the
vapor
pressures,
the
amount
of
toluene
released
as
air
emissions
from
the
stack
can
be
calculated:

X
lb/
yr
toluene
=
22
mmHg
(
vapor
pressure
of
toluene)
200
lb/
yr
xylene
6
mmHg
(
vapor
pressure
of
xylene)

X
lb/
yr
toluene
=
(
200
lb/
yr
xylene)
(
22
mmHg
toluene)
(
6
mmHg
xylene)

Completing
the
calculation,
you
determine
that
730
lbs
of
toluene
were
released
as
stack
air
emissions
during
the
reporting
year.
This
would
be
reported
in
Part
II,
Sections
5.2
and
8.1
of
the
2001
Form
R.
4­
27
4.1.4.5
Estimating
Release
and
Other
Waste
Management
Quantities
Once
all
sources,
types,
and
appropriate
estimation
methodologies
have
been
identified,
you
can
estimate
the
release
and
other
waste
management
activity
quantities
of
EPCRA
Secion
313
chemicals
or
chemical
categories
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
7A,
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
(
40
CFR
§
372.85(
b)(
17)).
You
should
report
treatment
methods
that
do
not
actually
destroy
or
remove
the
toxic
chemical
or
chemical
category
by
entering
"
zero
(
0)"
for
removal
efficiency
(
53
FR
4517).
Similarly,
on­
site
energy
recovery
methods
and
on­
site
recycling
methods
must
be
reported
in
Sections
7B
and
7C,
respectively.
*
Entries
for
Section
8.8
only
if
release
is
result
of
remedial
action,
catastrophic
event,
or
one­
time
event
not
associated
with
production
process.

4­
28
Table
4­
3
Release
and
Other
Waste
Management
Quantity
Estimation
Worksheet
Facility
Name:
Date
Worksheet
Prepared:

EPCRA
Section
313
Chemical
or
Chemical
Category:
Prepared
by:

CAS
Registry
Number:

Reporting
Year:

ON
SITE
Release
or
Other
Waste
Management
Activity
Type
Amount
(
lb)
Basis
of
Estimate
Form
R
Element*
(
2001
version)

FUGITIVE
AIR
Equipment
Leaks
5.1
and
8.1
or
8.8
Process
Areas
5.1
and
8.1
or
8.8
Evaporative
Losses,
Spills,
Surface
Impoundments
5.1
and
8.1
or
8.8
Total
=
5.1
and
8.1
or
8.8
STACK
AIR
Process
Vents
5.2
and
8.1
or
8.8
Storage
Tanks
5.2
and
8.1
or
8.8
Control
Device
Stacks
5.2
and
8.1
or
8.8
Other
5.2
and
8.1
or
8.8
Total
=
5.2
and
8.1
or
8.8
RECEIVING
STREAM/
WATER
BODY
DISCHARGE
Stormwater
Discharge
5.3
and
8.1
or
8.8
On­
Site
Treatment
Plant
Discharge
5.3
and
8.1
or
8.8
Total
=
5.3
and
8.1
or
8.8
ON­
SITE
UNDERGROUND
INJECTION
Underground
Injection
to
Class
I
Wells
5.4
and
8.1
or
8.8
Underground
Injection
to
Class
II
­
V
Wells
5.4
and
8.1
or
8.8
Total
=
5.4
and
8.1
or
8.8
ON
SITE
Release
or
Other
Waste
Management
Activity
Type
Amount
(
lb)
Basis
of
Estimate
Form
R
Element*
(
2001
version)

*
Entries
for
Section
8.8
only
if
release
is
result
of
remedial
action,
catastrophic
event,
or
one­
time
event
not
associated
with
production
process.

4­
29
ON­
SITE
LAND
RCRA
Subtitle
C
Landfill
5.5
and
8.1
or
8.8
Other
Landfill
5.5
and
8.1
or
8.8
Land
Treatment/
Application
Farming
5.5
and
8.1,
or
8.8
Surface
Impoundment
5.5
and
8.1
or
8.8
Other
Disposal
5.5
and
8.1
or
8.8
Total
=
5.5
and
8.1
or
8.8
ON­
SITE
ENERGY
RECOVERY
Industrial
Kiln
8.2
Industrial
Furnace
8.2
Industrial
Boiler
8.2
Other
Energy
Recovery
Methods
8.2
Total
=
8.2
ON­
SITE
RECYCLING
Solvents/
Organics
Recovery
8.4
Metals
Recovery
8.4
Acid
Regeneration
8.4
Other
Reuse
or
Recovery
8.4
Total
=
8.4
ON­
SITE
TREATMENT
Air
Emissions
Treatment
8.6
Biological
Treatment
8.6
Chemical
Treatment
8.6
Incineration/
Thermal
Treatment
8.6
Physical
Treatment
8.6
Solidification/
Stabilization
8.6
Total
=
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.

4­
30
OFF
SITE
Release
or
Other
Waste
Management
Activity
Type
Amount
(
lb)
Basis
of
Estimate
Form
R
Element*
(
2001
version)
Off­
Site
Location
(
name)

OFF­
SITE
DISPOSAL
Solidification/
Stabilization
(
metals
and
metal
compounds
only)
6.2
and
8.1
or
8.8
Amount
of
metal
and
metal
compounds
to
POTW
6.1
and
8.1
or
8.8
Wastewater
Treatment
(
excluding
POTWs)
metals
and
metal
compounds
only
6.2
and
8.1
or
8.8
Underground
Injection
6.2
and
8.1
or
8.8
Landfill/
Surface
Impoundment
6.2
and
8.1
or
8.8
Land
Treatment
6.2
and
8.1
or
8.8
Other
Land
Disposal
6.2
and
8.1
or
8.8
Other
Off­
Site
Management
6.2
and
8.1
or
8.8
Total
=
6.2
and
8.1
or
8.8
OTHER
AMOUNTS
SENT
OFF
SITE
Amounts
sent
for
storage
6.2
and
8.1
or
8.8
Amounts
sent
for
unknown
waste
management
practice
6.2
and
8.1
or
8.8
Total
=
6.2
and
8.1
or
8.8
OFF­
SITE
TREATMENT
Solidification/
Stabilization
6.2
and
8.7
or
8.8
Incineration/
Thermal
Treatment
6.2
and
8.7
or
8.8
Incineration/
Insignificant
Fuel
Value
6.2
and
8.7
or
8.8
Wastewater
Treatment
(
to
POTW
excluding
metals
and
metal
compounds)
6.1
and
8.7
or
8.8
Wastewater
Treatment
(
excluding
POTW
and
metal
and
metal
compounds)
6.2
and
8.7
or
8.8
Sent
to
Waste
Treatment
Broker
6.2
and
8.7
or
8.8
Total
=
6.2
and
8.7
or
8.8
OFF
SITE
Release
or
Other
Waste
Management
Activity
Type
Amount
(
lb)
Basis
of
Estimate
Form
R
Element*
(
2001
version)
Off­
Site
Location
(
name)

4­
31
OFF­
SITE
ENERGY
RECOVERY
Off­
Site
Energy
Recovery
6.2
and
8.3
or
8.8
Sent
to
Energy
Recovery
Broker
6.2
and
8.3
or
8.8
Total
=
6.2
and
8.3
or
8.8
OFF­
SITE
RECYCLING
Solvents/
Organics
Recovery
6.2
and
8.5
or
8.8
Metals
Recovery
6.2
and
8.5
or
8.8
Other
Reuse
or
Recovery
6.2
and
8.5
or
8.8
Acid
Regeneration
6.2
and
8.5
or
8.8
Sent
to
Recycling
Waste
Broker
6.2
and
8.5
or
8.8
Total
=
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.
4­
32
4.2
Determination
of
Release
and
Other
Waste
Management
Activity
Quantities
from
Production
of
Pulp,
Paper,
and
Paperboard
Introduction
The
pulp
and
paper
industry
can
be
considered
as
being
composed
of
three
major
industrial
activities:


Production
of
pulp;


Production
of
paper
and
paperboard
from
the
pulp;
and

Manufacturing
(
converting)
the
paper
or
paperboard
stock
to
the
finished
product.

This
guidance
document
covers
the
EPCRA
Section
313
reporting
associated
with
the
production
of
pulp,
paper,
and
paperboard
stock,
i.
e.,
the
facilities
with
primary
SIC
codes
of
2611
­
Pulp
Mills;
2621­
Paper
Mills;
and
2631­
Paperboard
Mills.
See
Figure
4­
3
for
an
overall
process
flow
diagram.
The
manufacturing
process
for
paper
and
paperboard
is
identical.
The
difference
between
paper
and
paperboard
is
in
the
product
thickness,
with
products
of
thickness
greater
than
0.3
mm
generally
classified
as
paperboard,
and
those
less
than
0.3
mm
as
paper.
(
1)

There
are
approximately
555
pulp
and
paper
mills
in
the
United
States.
Of
these,

55
produce
only
pulp,
300
produce
only
paper
from
pulp,
and
200
produce
both
pulp
and
paper
in
the
same
facility.
(
1)

In
1997
the
EPCRA
Section
313
chemicals
and
chemical
categories
most
frequently
reported
by
facilities
in
SIC
Codes
2611,
2621
and
2631
were:
ammonia,
methanol,

chlorine,
hydrochloric
acid,
and
sulfuric
acid.
See
Table
2­
2
for
a
complete
list
of
the
EPCRA
Section
313
chemicals
and
chemical
categories
commonly
reported
by
these
facilities.
4­
33
4­
33
Figure
4­
3.
Process
Flow
Diagram
­
Overall
Process
4­
34
Typical
sources
of
release
and
other
waste
management
activities
in
pulp,
paper,

and
paperboard
production
facilities
that
may
potentially
contain
EPCRA
Section
313
chemicals
and
chemical
categories
are:
(
2)

Wastewater

Excess
white
water
from
savealls,
sealing
pits,
or
other
tank
overflows;


Rejects
from
stock­
cleaning
devices
(
centrifugal
cleaners,
screens,
and
junk
traps);


De­
inking
wastewater
from
centrifugal
cleaners,
washers,
deckers,
and
thickeners;


Bleaching
wastewater
generated
during
preparation
of
bleaching
chemicals
such
as
hypochlorite
and
chlorine
dioxide,
or
filtrates
coming
from
various
bleach
plant
washers;


Felt­
and
wire­
cleaning
waters;
and

Boiler
blowdown
and
other
miscellaneous
discharges.

Solid
Waste

Fibers,
fillers,
and
broke
from
the
paper
machine;


Coating
residue
and
broke
from
finishing
operations;


Cleaner
and
junker
rejects
from
wastepaper
processing;


Wastewater
treatment
sludge;


Container
residues;
and

Boiler
ash.

Air
Emissions

Fiber
furnish
preparation;


Pulping;


Bleach
plant;


Paper
dryers;


Paper
machine;


Coating
and
finishing
machines;


Mixing
vats;


Wastewater
treatment
volatilization;


Fuel
combustion;
and

Chemical
recovery.
4­
35
Release
and
other
waste
management
activity
types
for
EPCRA
Section
313
chemicals
and
chemical
categories
at
pulp,
paper,
and
paperboard
production
facilities
include:

fugitive
and
stack
air
emissions;
direct
and
in­
direct
wastewater
discharges;
and
land
or
off­
site
disposal
of
solid
wastes.

The
Pulp
Production
Process
Pulp
production
is
the
processing
of
fibrous
material
into
fibers
that
can
be
formed
into
a
sheet.
(
1)
See
Figure
4­
4
for
a
flow
diagram
of
the
pulp
production
process.
The
blend
of
fibrous
material
used
to
make
pulp
is
known
as
"
furnish".
Wood
is
by
far
the
most
common
furnish
material
for
pulp
and
paper
production,
it
accounts
for
approximately
95%
of
production.
(
1)
Pulp
production
also
includes
the
recovery
of
usable
fiber
from
recycled
paper
and
cotton
and
linen
rags.
(
4)
Of
special
note
in
the
use
of
recycled
paper
is
the
possibility
that
imported
waste
paper
may
contain
EPCRA
Section
313
chemicals
and
chemical
categories
as
ink
pigments,
coating
agents,
binders,
and
adhesives.
(
2)
There
are
three
basic
types
of
pulp
production
processes,
namely,
chemical,
mechanical,
and
semi­
chemical,
with
chemical
the
most
prevalent.
(
1)
EPCRA
Section
313
chemicals
and
chemical
categories
are
typically
found
in
the
pulping,
bleaching,
and
stock
preparation
steps
of
the
pulp
production
process.

The
pulp
production
process
and
the
typical
EPCRA
Section
313
chemicals
and
chemical
categories
associated
with
the
unit
operations
are
summarized
in
Table
4­
4.
(
1)
4­
36
Table
4­
4
Pulp
Production
Process
and
Associated
EPCRA
Section
313
Chemicals
and
Chemical
Categories
Process
Sequence
Description
EPCRA
Section
313
chemicals/
chemical
categories
Fiber
furnish
preparation
Debarking,
slashing,
chipping
of
wood
logs
and
screening
of
wood
chips/
secondary
fibers.

Pulping
Chemical
(
kraft,
sulfite,
and
soda),
mechanical,
semi­
chemical
breakdown
of
pulp
into
fibers
Acetaldehyde,
methyl
isobutyl
ketone,
chlorine,
chlorine
dioxide,
chloroform,
catechol.
Ammonia
(
anhydrous
and
10%
of
aqueous)
from
solution
of
ammonium
salts
[
Sulfite
process
uses
bisulfite
which
may
be
an
ionic
salt
of
Ca,
Mg,
Na,
or
NH3]
(
7)
Methanol,
methyl
ethyl
ketone
(
1)
Ref
#
1
also
mentions
terpenes,
alcohols,
and
phenols
as
categories
of
pollutant
outputs.
Need
more
specific
info
to
determine
if
these
groups
contain
EPCRA
Section
313
chemicals.

Pulp
processing
Removal
of
pulp
impurities,
cleaning
and
thickening
of
pulp
fiber
mixture
Same
as
pulping
Bleaching
Addition
of
chemicals
to
alter
pulp
to
increase
its
brightness.
A
sequential
operation
 
typically
alternating
acid
and
alkaline
bleaching
with
water
washing
steps
to
remove
bleaching
chemicals
and
dissolved
reaction
products
after
each
bleaching
step.
A
typical
process
would
be
acid
delignification
with
chlorine
dioxide,
water
wash,
alkaline
extraction
of
chlorinated
lignins
using
NaOH,
water
wash,
acid
bleaching
with
ClO2,
water
wash,
a
second
alkaline
extraction,
followed
by
water
wash,
and
another
ClO2
step.
(
7)
ClO2
is
manufactured
on­
site
due
to
its
instability
and
potential
for
explosiveness.
(
4)
Chlorine,
chlorine
dioxide,
sulfuric
acid
(
aerosols),
chloroform,
carbon
disulfide
(
1,7)

Stock
preparation
Mixing,
beating,
refining,
and
addition
of
wet
additives
to
add
strength,
gloss,
and
texture.
Barium
sulfate
(
barium
compounds),
zinc
sulfide
(
zinc
compounds)
(
7)

Chemical
Recovery
Used
chemicals
are
recovered
Acetaldehyde,
methyl
ethyl
ketone
4­
37
The
Paper
and
Paperboard
Production
Process
In
the
simplest
of
terms,
paper
is
produced
by
applying
the
pulp
as
a
watery
suspension
of
cellulose
fibers
to
a
screen
that
allows
the
water
to
drain
and
leaves
the
fibrous
particles
behind
in
a
sheet.
See
Figure
4­
5
for
a
flow
diagram
of
paper
and
paperboard
production.
A
variety
of
non­
fibrous
additives
are
used
in
the
paper
production
process
to
impart
desired
end
use
properties
to
the
paper
or
paperboard;
or
enhance
the
paper
production
processes.
(
3)
EPCRA
Section
313
chemicals
and
chemical
categories
are
most
often
found
in
these
non­
fibrous
additives
used
in
the
paper
production
process.

The
process
of
producing
paper
and
paperboard
is
broken
down
into
wet
end
operations,
in
which
formation
of
a
paper
sheet
from
wet
pulp
occurs;
and
dry
end
operations,
in
which
drying
of
the
paper
and
the
application
of
surface
treatment
is
performed.
The
wet
end
operations
can
be
further
broken
into
stock
preparation
and
sheet
formation.

The
wet
end
operations
for
paper
and
paperboard
production
begin
with
preparation
of
the
stock
to
achieve
the
optimal
fiber
properties
for
the
particular
product
being
manufactured.
This
stock
preparation
is
usually
a
combination
of
mechanical
treatment
and
the
addition
of
chemical
additives
to
the
virgin
pulp
and
wastepaper
pulp
(
which
may
be
used
as
is,
or
it
may
be
de­
inked
or
bleached).
Once
the
prepared
wet
pulp
is
refined,
cleaned
and
screened,
it
is
ready
for
paper
production.
The
most
common
paper
production
machine
is
the
Fourdrinier
machine
that
applies
the
fibers
in
the
wet
pulp
to
a
moving
wire
belt,
removes
the
water
by
the
use
of
gravity
or
suction,
and
presses
the
paper
sheet
with
rollers.
Because
of
its
high
fiber
content,

the
water
removed
in
this
process,
called
"
white
water",
is
recycled
back
into
the
process.

Once
the
paper
or
paperboard
has
been
formed
by
the
wet
end
process,
the
product
proceeds
through
the
dry
end
operations.
The
first
step
is
the
dryer
section,
typically
followed
by
various
additional
processing
steps
that
may
include
coating
and
sizing.
Additional
drying
steps
may
also
be
included.
After
a
final
pressing
called
calendering
to
reduce
thickness
and
smooth
the
surface,
the
dried
paper
is
wound
onto
a
reel.
The
final
steps
in
producing
paper
or
paperboard
are
the
finishing
operations,
which
include
weighing,
wrapping
and
labeling
the
4­
38
paper
rolls.
(
4)
The
individual
production
processes
that
typically
use
and/
or
generate
EPCRA
Section
313
chemicals
and
chemical
categories
are
de­
inking,
dyeing,
coating,
and
process
equipment
maintenance.

De­
inking
is
essentially
a
cleaning
process.
It
involves
the
removal
of
ink
and
other
extraneous
materials
(
contraries),
fillers,
and
fiber
fines
from
reclaimed
printed
papers
by
mechanical
disintegration
and
chemical
treatment,
with
subsequent
washing
or
flotation
separation.
(
3)
The
key
chemicals
used
for
de­
inking
are
surfactants.
(
4)
In
addition
to
the
EPCRA
Section
313
chemicals
and
chemical
categories
intentionally
applied
in
this
process,
the
reclaimed
paper
may
contain
EPCRA
Section
313
chemicals
and
chemical
categories
that
must
be
considered
and
included
in
the
threshold
determinations
and,
if
appropriate,
release
and
other
waste
management
calculations.

Paper
dyeing,
using
dyes
and
mineral
pigments,
is
used
to
achieve
the
desired
appearance
properties
of
the
end
product;
color,
opacity,
and
brightness.
(
3)
The
principal
water
soluble
dyes
are
known
as
acid,
basic,
or
direct
dyes.
(
4)
Acid
dyes
are
not
widely
used
by
the
paper
industry.
(
3)
Basic
dyes
are
important
for
coloring
paper,
combining
the
advantages
of
low
cost,
high
tinctorial
strength,
and
great
brilliance.
(
3)
Direct
dyes
have
a
high
affinity
for
cellulose
fibers,
partly
attributable
to
their
low
solubility,
and
are
the
most
common
dyes
used
in
the
paper
industry.
(
3)

Paper
is
coated
for
decorative
and
functional
purposes
with
waterborne,
organic
solvent­
borne,
and
solvent­
free
extruded
materials.
(
5)
Waterborne
coatings
generally
consist
of
the
application
of
an
aqueous
suspension
of
pigments
(
such
as
clay)
in
adhesives
(
such
as
starch)

to
achieve
desired
surface
properties.
(
6)
Organic
solvent­
borne
formulations
may
contain
one
or
more
EPCRA
Section
313
chemicals
and
chemical
categories.
Typical
EPCRA
Section
313
solvents
used
for
this
process
include
toluene,
xylene,
MEK,
and
methanol.
(
5)
However,
most
solvent­
borne
coating
is
done
by
paper
converting
companies
whose
SIC
Codes
are
not
covered
by
this
guidance
document.(
5)
Plastic
extrusion
coating
is
the
application
of
a
molten
plastic
sheet
(
usually
low
or
medium
density
polyethylene)
under
pressure
to
a
paper
substrate.
A
typical
end
product
for
this
process
is
the
coated
milk
carton.
(
5)
This
process
also
is
primarily
4­
39
performed
by
paper
converting
companies
and
thus
does
not
fall
within
the
purview
of
this
document.

Paper
and
paperboard
production
integrated
facilities
often
have
a
large
white
water
recycling
process,
as
well
as
energy
generation
and
waste
treatment
operations.
All
of
the
facility
operations
need
to
be
included
when
determining
the
release
and
other
waste
management
activity
quantities
for
EPCRA
Section
313
reporting
(
40
CFR
§
372.30).

The
sources,
types
and
quantity
estimation
of
the
release
and
other
waste
management
activities
for
the
EPCRA
Section
313
chemicals
for
the
production
of
pulp,
paper,

and
paperboard
will
now
be
discussed
in
detail.

4.2.1
Pulp
Production
The
pulp
production
process
begins
with
the
preparation
of
the
furnish,
usually
a
mechanical
activity.
The
pulping
itself
is
the
next
step.
This
is
typically
a
chemical,
mechanical,

or
combination
chemical
and
mechanical
activity,
with
the
objective
of
breaking
the
lignin
bonds
in
the
wood
structure
and
leaving
behind
the
cellulosic
fibers
used
to
make
paper.
After
some
additional
processing,
e.
g.,
screening,
thickening,
de­
knotting,
blending,
etc.,
the
pulp
may
be
bleached
to
achieve
a
desired
degree
of
whiteness.
The
final
step
in
the
pulp
production
process
is
the
stock
preparation,
typically
including
pulp
mixing
and
dispersion,
beating
and
refining
and
addition
of
wet
additives.
The
bleaching
step
is
typically
one
of
the
largest
operations
in
which
EPCRA
Section
313
chemicals
and
chemical
categories
are
manufactured,
coincidentally
manufactured,
and
otherwise
used.
In
the
kraft
pulping
process
the
black
liquor
that
is
produced
is
incinerated
in
recovery
furnaces
resulting
in
the
generation
of
sulfuric
acid
mist.
See
discussion
in
Section
3.1
under
Qualifiers.
4­
40
Step
1:
Prepare
Process
Flow
Diagram
A
site­
specific
process
flow
diagram
can
be
prepared
to
help
identify
all
potential
sources
and
types
of
EPCRA
Section
313
chemical
and
chemical
category
release
and
other
waste
management
activities.
A
typical
process
flow
diagram
for
pulp
production
is
presented
in
Figure
4­
4.

Figure
4­
4.
Process
Flow
Diagram
­
Pulp
Production
4­
41
Step
2:
Identify
Reportable
Toxic
Chemicals
and
Potential
Sources
of
Chemical
Release
and/
or
Other
Waste
Management
Activities
The
bleaching
step
in
the
production
of
pulp
may
be
a
source
of
several
EPCRA
Section
313
chemicals/
chemical
categories
with
chlorine
and
chlorine
dioxide
being
the
most
common.
Other
EPCRA
Section
313
chemicals/
chemical
categories
potentially
found
in
bleaching
are
sulfuric
acid
(
only
reportable
in
the
acid
aerosol
form,
see
discussion
in
Section
3.1),

peracetic
acid,
ozone,
zinc
compounds
(
e.
g.,
zinc
dithionite),
chloroform,
methyl
ethyl
ketone,

carbon
disulfide,
chloromethane,
trichloroethane,
2,4,5­
trichlorophenol,
2,4,6­
trichlorophenol,

and
pentachlorophenol.
Potential
EPCRA
Section
313
chemicals
and
chemical
categories
in
the
pulping
step
of
the
production
process
includes
acetaldehyde,
methyl
isobutyl
ketone,
methanol,

catechol,
and
methyl
ethyl
ketone.
For
sulfite
pulping,
in
which
the
bisulfite
may
be
an
ionic
salt
of
several
anions
including
the
ammonium
ion,
ammonia
may
be
formed.
Chemical
recovery
operations
may
be
performed
for
EPCRA
Section
313
chemicals
such
as
acetaldehyde
and
methyl
ethyl
ketone.

Potential
sources
of
EPCRA
Section
313
chemicals/
chemical
categories
are
process
wastewaters,
evaporation
of
volatile
compounds,
and
sludges
from
wastewater
treatment.

Step
3:
Identify
On­
Site
Releases,
Off­
Site
Transfers,
and/
or
On­
Site
Waste
Management
Activity
Types
Types
of
release
and
other
waste
management
activities
include
wastewater
discharges,
either
directly
to
a
receiving
stream
or
indirectly
to
a
POTW,
which
may
contain
ammonia,
chlorine,
chlorine
dioxide,
and
any
of
the
other
EPCRA
Section
313
chemicals/
chemical
categories
listed
above.
Also
included
are
fugitive
emissions
of
volatile
EPCRA
Section
313
chemicals/
chemical
categories
from
bleaching
and
chemical
recovery
processes
and
wastewater
treatment
activities.
Stack
emissions
from
kraft
recovery
furnaces
may
contain
sulfuric
acid
mist.

Another
type
of
release
or
other
waste
management
activity
from
pulp
production
operations
would
be
on­
site
or
off­
site
management
of
solid
residues
in
the
form
of
wastewater
treatment
sludges.
4­
42
Step
4:
Determine
the
Most
Appropriate
Method(
s)
to
Develop
and
Calculate
the
Estimates
for
Releases
and
Other
Waste
Management
Activity
Quantities
Example
 
Combustion
of
Black
Liquor
Solids
(
BLS)

Your
kraft
mill
produces
500
air­
dried
tons
of
unbleached
pulp
per
day
.
The
production
process
generates
3,200
pounds
of
black
liquor
solids
(
BLS)
per
ton.
The
BLS
burned
in
two
direct
contact
evaporator
(
DCE)
furnaces.
The
mill
operates
350
days
per
year.

It
can
be
assumed
all
the
emitted
sulfuric
acid
is
in
the
form
of
droplets.
The
total
amount
of
sulfuric
acid
emitted
from
the
furnace
stacks
is:

500
tons/
day
×
350
days/
yr
×
3,200
lb
BLS/
ton
×
8.4E­
03
lb
sulfuric
acid/
ton
BLS
(
sulfuric
acid
emission
factor
for
DCE
furnaces)
1
×
1
ton/
2,000
lb
(
conversion
factor)
=
2,352
lb/
yr
sulfuric
acid
emitted
This
must
be
reported
in
Part
II,
Sections
5.2
and
8.1
of
the
2001
Form
R.

1National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
Hand
book
of
Chemical
Specific
Information
for
SARA
313
Form
R
Reporting.
(
Note:
available
for
NCASI
members
only).
4­
43
Example
­
Release
Estimation
from
Bleaching
Operations
Your
pulp
mill
facility,
SIC
Code
2611,
performs
bleaching
of
1,000
tons
per
day
of
chemical
pulp
using
the
following
bleaching
sequence:


Delignification
with
chlorine
dioxide;


Solubilization
and
extraction
of
lignin
compounds
with
sodium
hydroxide,
hydrogen
peroxide,
and
oxygen;


Bleaching
with
chlorine
dioxide;


Additional
extraction
with
sodium
hydroxide;
and

Bleaching
with
chlorine
dioxide.

Each
of
the
above
steps
is
followed
by
a
washing
step.
To
reduce
fresh
water
usage
and
subsequent
treatment
and
discharge
of
large
volumes
of
wastewater
the
facility
practices
countercurrent
washing
with
separate
flow
streams
for
the
bleaching
and
extraction
steps
to
prevent
problems
with
foaming
and
precipitation
of
the
chlorolignin
materials.
The
vent
gases
from
the
bleach
plant
are
sent
to
a
chilled
water
and
caustic
scrubber.

The
facility
manufactures
15
tons
per
day
of
chlorine
dioxide
(
ClO2)
on
site
using
the
modified
Mathieson
process.
This
process
uses
sodium
chlorate,
sodium
chloride,
sulfuric
acid,
and
sulfur
dioxide
as
input
chemicals.
(
4)
This
process
produces
chlorine
(
Cl2)
as
an
impurity
at
the
rate
of
0.15
pound
Cl2
per
pound
of
ClO2.
(
9)
Vent
gases
from
the
ClO2
generator
are
sent
to
the
chilled
water
and
caustic
scrubber.
The
scrubber
has
an
efficiency
of
90%.
(
9)
Cl2
is
also
used
at
an
average
rate
of
100
pounds
per
day
in
the
disinfection
of
the
wastewater
effluent
from
the
treatment
plant
for
your
facility.
Cl2
used
for
this
purpose
is
brought
to
the
facility
as
a
gas
in
high­
pressure
cylinders.
The
wastewater
treatment
plant
treats
2,000,000
gallons
per
day
with
an
average
free
Cl2
residual
in
the
final
effluent
of
0.5
mg/
L.

Thus,
Cl2
is
both
manufactured
and
otherwise
used
at
your
facility.
You
must
perform
threshold
calculations
for
both
activities
(
40
CFR
§
372.25(
c)).
The
manufacturing
threshold
is
25,000
pounds
per
year
and
the
otherwise
use
activity
has
a
10,000
pounds
per
year
threshold.
Likewise,
threshold
determinations
should
be
performed
for
the
manufacturing
of
the
ClO2
chlorine
dioxide
as
well
as
for
the
otherwise
use
activity
in
the
bleaching
process.

Other
EPCRA
Section
313
chemicals
associated
with
the
bleaching
process
include
chloroform,
peracetic
acid,
methyl
ethyl
ketone,
carbon
disulfide,
chloromethane,
zinc
dithionite,
trichloroethane,
2,4,5­
trichlorophenol,
2,4,6­
trichloropenol,
and
pentachlorophenol.
To
illustrate
the
calculation
methods
we
will
show
the
estimation
calculations
for
Cl2.
Similar
calculations
must
be
performed
for
all
other
EPCRA
Section
313
chemicals
and
chemical
categories
that
exceed
the
appropriate
activity
use
thresholds
(
40
CFR
§
372.30(
a)).
Detailed
calculation
examples
for
other
chemicals
are
available
in
the
Handbook
of
Chemical
Specific
Information
for
SARA
313
Form
R
Reporting
published
by
the
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
(
9)

Threshold
Determination
for
Chlorine
Manufacturing:

(
15
ton/
day;
ClO2
generated)
×
(
2,000
lb/
ton)
×
(
365
days/
year)
×
(
0.15
lb
Cl2/
lb
ClO2;
Cl2
generation)
1
=
1,642,500
pounds
of
chlorine
per
year
Otherwise
use:

(
100
lb/
day;
Cl2
usage)
×
(
365
days/
year)
=
36,500
pounds
of
Cl2
per
year
Both
activity
thresholds
have
been
exceeded
and
EPCRA
Section
313
reports
must
be
prepared
for
both
4­
44
Release
Estimation
for
Chlorine
Fugitive
air:
The
amount
of
Cl2
released
from
leaks
in
valves
and
fittings
is
calculated
as
follows:

(
0.014
lb
Cl2/
ton
of
Cl2
used
at
the
facility;
fugitive
emission
factor)
1
x
(
1,679,000
lb
Cl2,
total
Cl2
manufactured
and
otherwise
used
at
facility)
×
(
1
ton/
2,000
lb)
=
11.75
pounds
of
Cl2
per
year
This
must
be
reported
in
Sections
5.1
and
8.1
of
the
2001
Form
R.

Stack
air:
Cl2
releases
from
the
scrubber
on
the
ClO2
generator
is
calculated
as
follows:

(
0.15
lb
Cl2/
lb
ClO2
generated;
emission
factor)
1
×
(
15
ton/
day;
ClO2
production)
×
(
2,000
lb/
ton)
×
365
days/
year)
×
(
1­
0.90;
scrubber
efficiency)
1
=
164,250
pounds
of
Cl2
per
year.

Cl2
releases
from
the
bleach
plant
is
calculated
as
follows:

(
1,000
tons
of
pulp/
day;
facility
production)
×
(
0.70
lb
Cl2/
ton
of
pulp;
emission
factor)
1
×
(
365
days/
year)
×
(
1­
0.90
scrubber
efficiency)
=
25,550
pounds
of
Cl2
per
year
Total
stack
air
emissions:
164,250
lb
+
25,550
lb
=
189,800
pounds
of
Cl2
per
year.

This
must
be
reported
in
Sections
5.2
and
8.1
of
the
2001
Form
R.

Wastewater:
The
free
available
Cl2
measured
in
the
wastewater
treatment
plant
effluent
is
composed
of
hydrochlorous
acid
and
hypochlorite
ion;
Cl2
disappears
almost
immediately
in
water
with
the
pH
values
normally
seen
in
wastewater.
(
8)
Thus,
no
Cl2
is
released
by
this
route.

1National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
Hand
book
of
Chemical
Specific
Information
for
SARA
313
Form
R
Reporting.
(
Note:
available
for
NCASI
members
only).

4.2.2
Paper
and
Paperboard
Production
Paper
and
paperboard
production
consists
of
"
wet
end"
operations
including
sheet
formation
and
pressing,
and
"
dry
end"
operations,
including
drying
calendering,
reeling,

winding,
and
application
of
surface
treatment.
(
7)

Step
1:
Prepare
Process
Flow
Diagram
A
site­
specific
process
flow
diagram
can
be
prepared
to
help
identify
all
potential
sources
and
types
of
EPCRA
Section
313
chemical
and
chemical
category
release
and
other
waste
4­
45
Figure
4­
5.
Process
Flow
Diagram
­
Production
of
Paper
and
Paperboard
management
activities.
A
typical
process
flow
diagram
for
paper
and
paperboard
production
is
presented
in
Figure
4­
5.

Step
2:
Identify
Reportable
Toxic
Chemicals
and
Potential
Sources
of
Chemical
Release
and/
or
Other
Waste
Management
Activities
The
potential
EPCRA
Section
313
chemicals
and
chemical
categories
encountered
in
paper
and
paperboard
production
include
formaldehyde
and
phenol
that
may
be
found
in
resins,
ammonia
that
may
be
added
as
a
coating
or
for
pH
adjustment,
hexane,
xylene,

and
toluene
from
cleaning
operations,
and
minute
quantities
of
unreacted
monomers
from
various
additives.
(
6)

Potential
sources
of
EPCRA
Section
313
chemicals/
chemical
categories
are
process
wastewaters,
evaporation
of
volatile
compounds,
and
sludges
from
wastewater
treatment.
4­
46
Step
3:
Identify
On­
Site
Releases,
Off­
Site
Transfers,
and/
or
On­
Site
Waste
Management
Activity
Types
Types
of
release
and
other
waste
management
activities
include
wastewater
discharges,
either
directly
to
a
receiving
stream
or
indirectly
to
a
POTW.
Also
included
are
fugitive
emissions
of
volatile
EPCRA
Section
313
chemicals/
chemical
categories
from
various
process
activities
and
wastewater
treatment
activities.
Another
type
of
release
or
other
waste
management
activity
from
paper
and
paperboard
production
would
be
on­
site
or
off­
site
management
of
solid
residues
in
the
form
of
container
residues
and
wastewater
treatment
sludges.
4­
47
Step
4:
Determine
the
Most
Appropriate
Method(
s)
to
Develop
and
Calculate
the
Estimates
for
Releases
and
Other
Waste
Management
Activity
Quantities
Example
 
Using
Mass
Balance
to
Estimate
the
Air
Releases
of
Formaldehyde
Your
paper
production
facility,
SIC
Code
2621,
uses
a
melamine­
formaldehyde
resin
as
the
wet­
strength
additive
in
the
wet
end
processing.
The
MSDS
provided
by
the
supplier
states
that
the
resin
contains
between
one
and
five
percent
free
formaldehyde
precursor.
During
the
reporting
year
your
facility
used
200
tons
of
the
melamineformaldehyde
resin.
The
formaldehyde
is
present
as
an
unreacted
component
of
the
resin
and
is
not
designed
to
be
a
part
of
the
product
being
distributed
in
commerce.
Thus,
it
is
a
non­
incorporative
activity
and
the
quantity
of
formaldehyde
used
as
described
above
is
considered
to
be
otherwise
used
and
the
EPCRA
Section
313
reporting
threshold
is
10,000
pounds
per
year
Threshold
Determination
Since
the
MSDS
provided
the
free
formaldehyde
concentration
as
a
range,
U.
S.
EPA
guidance
is
to
use
the
midpoint
of
the
range.
See
discussion
in
Section
3.2.1.

Quantity
of
formaldehyde
processed:

(
200
ton/
year;
quantity
of
resin
otherwise
used)
x
(
0.03;
mid­
point
of
formaldehyde
concentration
range)
x
(
2,000
lb/
ton;
conversion
factor)
=
12,000
pounds
per
year.

This
exceeds
the
otherwise
use
threshold
of
10,000
pounds
per
year
and
an
EPCRA
Section
313
report
should
be
filed.

Release
Estimation
Formaldehyde
is
both
volatile
and
highly
soluble
in
water.
In
the
wet
end
application
the
formaldehyde
is
partially
volatilized
during
the
paper
forming
and
drying
processes.
The
remainder
of
the
formaldehyde
is
dissolved
in
the
white
water.
Most
of
the
white
water
is
returned
to
the
process
with
the
rest
being
bled
off
and
discharged
to
the
facility
wastewater
treatment
system.
The
wastewater
treatment
system
consists
of
an
activated
sludge
secondary
treatment
facility
followed
by
a
series
of
aerated
facultative
stabilization/
polishing
ponds.
Total
system
retention
time
is
estimated
to
be
in
excess
of
90
days.

The
formaldehyde
volatilized
during
the
paper
making
process
is
removed
from
the
room
as
part
of
the
general
ventilation
and
is
vented
to
the
atmosphere
through
roof
vents
without
passing
through
any
air
pollution
control
devices.
Thus,
it
is
considered
a
fugitive
release.
The
quantity
volatilized
in
the
wastewater
treatment
system
is
also
considered
a
fugitive
release.
The
long
wastewater
treatment
system
retention
time
and
the
high
degree
of
aeration
assures
that
all
the
formaldehyde
will
be
volatilized
and
none
will
remain
dissolved
in
the
final
effluent.

All
the
formaldehyde
otherwise
used
by
the
facility,
12,000
pounds,
is
thus
considered
to
be
discharged
to
the
atmosphere
as
a
fugitive
release
and
must
be
reported
in
Sections
5.1
and
8.1
of
the
2001
Form
R.
5­
1
5.0
REFERENCES
1.
U.
S.
EPA.
Profile
of
the
Pulp
and
Paper
Industry.
EPA
310­
R­
95­
015,
Office
of
Compliance,
September
1995.

2.
U.
S.
EPA.
Title
III
Section
313
Release
Reporting
Guidance,
Estimating
Chemical
Releases
from
Paper
and
Paperboard
Production.
EPA
560/
4­
88­
004k,
Office
of
Pesticides
and
Toxic
Substances,
February
1988.

3.
Scott,
William,
E.
Principles
of
Wet
End
Chemistry.
TAPPI
Press,
Atlanta,
GA.
1996.

4.
Smook,
G.
A.
Handbook
for
Pulp
&
Paper
Technologists.
TAPPI,
Atlanta,
GA.
1989.

5.
U.
S.
EPA.
Compilation
of
Air
Pollutant
Emission
Factors
(
AP­
42).
Fifth
Edition.
Office
of
Air
Quality
Planning
and
Standards.

6.
Air
&
Waste
Management
Association.
Air
Pollution
Engineering
Manual
(
AP­
40).
1992.

7.
U.
S.
EPA.
Proposed
Technical
Development
Document
for
the
Pulp,
Paper,
and
Paperboard
Category
Effluent
Limitations
Guidelines,
Pretreatment
Standards,
and
New
Source
Performance
Standards.
Office
of
Science
and
Technology.
October
1993.

8.
Fair,
G.
M.,
J.
G.
Geyer,
D.
A.
Okun.
Water
and
Wastewater
Engineering.
Volume
2,
Page
31­
15.
John
Wiley
&
Sons,
Inc.
New
York.
1968.

9.
National
Council
of
the
Paper
Industry
for
Air
and
Stream
Improvement,
Inc.
Handbook
of
Chemical
Specific
Information
for
SARA
313
Form
R
Reporting.
(
Available
for
NCASI
members
only).
Index­
1
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.

Activity
Chemical
use,
subcategories
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
8
to
3­
13
Exemption
(
see
Exemptions)
Thresholds
(
see
Threshold)
Air
emissions
Fugitive
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
4,
4­
23,
4­
39,
4­
45,
4­
48,
4­
50,
4­
51
Stack
or
point
source
...........................................
4­
3,
4­
5,
4­
23,
4­
27,
4­
29,
4­
39,
4­
48
Article
exemption
(
see
Exemptions)
Automated
toxic
chemical
release
inventory
software
(
ATRS)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
20
Chemical­
specific
Acid
aerosols
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
6
to
3­
7,
3­
19
Ammonia
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
10,
2­
13,
3­
5,
3­
12,
3­
24,
4­
45
Metals/
metal
compounds
.
2­
10,
2­
13,
3­
5,
3­
12,
3­
19,
3­
24,
4­
4,
4­
7,
4­
11
to
4­
12,
4­
14
to
4­
17
Nitrate
compounds
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
11,
2­
13,
3­
5
to
3­
7
Combustion
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
12
to
4­
14,
4­
23,
4­
42
For
energy
recovery
on­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
13
For
energy
recovery
off­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
15
Common
errors
Assuming
a
threshold
is
exceeded
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
26
Catastrophic
Events
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
26
Coincidental
manufacture
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
14
Direct
Reuse
vs.
Recycling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
16
Double
counting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18
Exempt
activities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
15
Mass
balances
for
otherwise
used
chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
25
Mixture
components
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
4
On­
Site
Energy
Recovery
vs.
On­
site
Treatment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
14
On­
site
Recovery
vs.
On­
site
Treatment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
14
Reporting
off­
site
recycling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
11
Shipping
container
residue
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
8
Source
Reduction
Credit
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
19
Threshold
determinations
based
on
MSDS
concentration
data
.
.
.
.
.
.
.
.
.
.
.
3­
15
Threshold
determination
for
recirculation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
10
Treatment
efficiencies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
22
Wastewater
treatment
chemicals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
13
Zero
release
and
other
waste
management
quantities
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
26
Index­
2
De
minimis
(
see
Exemptions)
Example,
de
minimis
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
16
Example,
de
minimis
concentration
ranges
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
17
Disposal
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
2,
4­
6
to
4­
8
Land,
on­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
6
to
4­
7
Land,
off­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
7
to
4­
8
Documentation
(
see
Recordkeeping)
Double
counting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
17
Common
error,
double
counting
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
17
Emission
factors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18,
4­
19,
4­
23
to
4­
25,
B­
6
Example,
emission
factors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
25
Employee
equivalent
calculation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
6,
2­
8,
2­
19
Example,
calculating
employees
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
7
Full­
time
employee
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
6
Energy
recovery
(
see
Combustion
for
energy
recovery)
Engineering
calculation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
18
to
4­
19,
4­
25
to
4­
27
Example,
engineering
calculations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
26
EPCRA
hotline
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
2,
1­
3,
1­
5,
2­
8,
2­
19
Establishment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
1,
2­
2,
2­
5,
2­
6,
2­
8,
2­
21,
2­
23,
2­
24
Example,
multiple
establishments
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
2
Example,
primary
SIC
code
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
5
Examples
Activity
determination
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
12
Article
exemption
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
20
Bleaching
operations
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
43
Chemical
mixtures
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
9
Chemical
processing
aid
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
12
Combustion
of
black
liquor
solids
.
.
.
.
.
.
.
.
.
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4­
42
Container
residue
.
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4­
11
De
minimis
.
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.
3­
16
De
minimis
concentration
ranges
.
.
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.
3­
17
Emission
factors
.
.
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.
4­
22,
4­
25,
B­
6
Employee
equivalent
calculation
.
.
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2­
7
Engineering
calculation
.
.
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.
4­
22,
4­
26
Form
A
certification
threshold
.
.
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2­
21
Laboratory
exemption
.
.
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3­
20
Mass
balance
.
.
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4­
47
Monitoring
data
.
.
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4­
20
Motor
vehicle
exemption
.
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.
3­
22
Multiple
establishments
.
.
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.
2­
2
On­
site
waste
treatment
.
.
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4­
11
Personal
use
exemption
.
.
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.
3­
21
Primary
SIC
code
.
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.
2­
6
Process
equipment
chemical
use
.
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3­
22
Relabeling
.
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.
2­
14
Threshold
determination
.
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.
3­
8
Index­
3
Threshold
worksheet
.
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.
3­
26
Toxic
chemicals
in
process
water
.
.
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.
3­
22
Treatment
of
wastes
from
off
site
.
.
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.
2­
15
Using
a
mass
balance
and
engineering
assumption
.
.
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4­
22
Xylene
isomers
.
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3­
9
Exempt
activities
.
.
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.
3­
1,
3­
8,
3­
14
Common
error,
exempt
activities
.
.
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.
3­
14
Exemptions
.
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.
3­
14
Activity­
related
.
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.
3­
20
Article
.
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.
.
3­
18
to
3­
20
De
minimis
.
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.
3­
14
to
3­
18
Drawn
from
environment
.
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.
3­
21
Evaluation
of
.
.
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.
3­
14
Facility­
related
.
.
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.
3­
20
Grounds
maintenance
.
.
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.
3­
21
Janitorial
.
.
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.
3­
21
Laboratory
.
.
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.
3­
20
Motor
vehicle
.
.
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.
3­
21
Personal
use
.
.
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.
.
3­
21
Structural
components
.
.
.
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.
3­
21
Facility
.
.
.
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.
.
.
2­
1
to
2­
6
Auxiliary
facility
.
.
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.
2­
5
Covered
facility
.
.
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.
.
.
.
.
.
2­
4
to
2­
6
Multi­
establishment
facilities
(
see
Establishments)
Pilot
plant
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
2­
6
Facility­
related
exemption
(
see
Exemption)
Form
A
certification
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1­
2
to
1­
5,
3­
2,
2­
2,
2­
19,
2­
21,
2­
22,
2­
24,
3­
2
Example
Form
A
certification
threshold
.
.
.
.
.
.
.
.
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.
2­
21
Form
R
.
.
.
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.
.
.
.
.
.
.
.
2­
19
to
2­
20,
4­
28
to
4­
31
Impurity
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
2­
14,
3­
10,
3­
14
to
3­
16
Laboratory
exemption
(
see
Exemption)
Manufacture/
Manufacturing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
2­
11,
2­
12,
3­
6,
3­
8,
3­
10
Byproduct
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
2­
13,
3­
10
Coincidental
manufacture
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
2­
14
Subcategories
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
3­
10
Mass
balance
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
4­
19,
4­
20,
4­
22,
4­
47
Metal
compound
(
see
Chemical­
specific)
Methods
(
see
Reportable
amount
estimate
methods)
Monitoring
data
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
4­
18
to
4­
20
Motor
vehicle
exemption
(
see
Exemption)
MSDS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
2­
24,3­
3,
3­
4,
3­
13,
3­
14,
4­
19
Otherwise
use
.
.
.
.
.
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.
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.
2­
2,
2­
11,
2­
13,
3­
8,
3­
12,
3­
20,
3­
23
Subcategories
.
.
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.
3­
12
Owner/
operator
.
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.
.
1­
3
PBT
chemicals
.
.
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.
.
2­
2,
2­
16,
2­
18,
2­
19
Penalties
.
.
.
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.
.
.
.
1­
5
Index­
4
Pilot
plant
(
see
Facility)
Point
source
(
see
Air
emissions)
POTW.
.
.
.
.
.
.
.
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.
.
4­
7,
4­
13,
4­
19
Process/
processing
.
.
.
.
.
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.
.
.
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.
.
.
.
2­
11,
2­
13,
2­
15,
2­
21,3­
8,
3­
11
Subcategories
.
.
.
.
.
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.
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.
.
.
3­
11
Process
equipment
.
.
.
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.
.
3­
21,
3­
22
Qualifiers
.
.
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.
.
.
3­
4
to
3­
6,
4­
39
Recycling
.
.
.
.
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.
.
.
.
.
3­
24,
4­
7,
4­
13
to
4­
17
Off­
site
.
.
.
.
.
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.
.
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.
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.
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.
.
.
.
.
.
.
4­
7,
4­
10,
4­
15
On­
site
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
.
4­
13,
4­
15
Relabeling,
example
.
.
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.
2­
14
Release
.
.
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.
.
.
Chapter
4
Accidental
.
.
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.
.
.
4­
3,
4­
6
Estimates
(
steps
to
calculate)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
Chapter
4
Sources
.
.
.
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.
.
.
.
.
.
Chapter
4
Types
.
.
.
.
.
.
.
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.
.
.
.
.
.
Chapter
4
Remediation
.
.
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.
.
.
3­
23,
3­
24,
4­
17
Repackaging
.
.
.
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.
.
.
.
.
.
.
2­
14,
3­
11
Reportable
amount
estimation
methods
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
.
.
.
.
.
.
Chapter
4
Emission
factors
.
.
.
.
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.
.
.
.
4­
23
Engineering
calculations
.
.
.
.
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.
.
.
.
.
.
4­
25
Mass
balance
.
.
.
.
.
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.
.
.
.
.
.
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.
.
.
.
.
.
4­
21
Monitoring
data/
records
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
.
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.
.
.
.
.
.
.
4­
20
Reporting
criteria
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
1­
3,
2­
2
Reuse
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
3­
24,
4­
15
Sources
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
Chapter
4
Standard
Industrial
Classification
(
SIC)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
2­
3
to
2­
5
Primary
SIC
code
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
2­
6
Supplier
notification
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
2­
19
Technically
qualified
individual
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
.
.
.
.
.
.
.
3­
20
Threshold
worksheet
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2­
24,
3­
27,
3­
28
Thresholds
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
.
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.
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.
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.
.
.
.
.
.
.
.
.
.
Chapter
3
Common
error,
threshold
determination
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
10,
3­
15
Example,
threshold
determination
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
8
Threshold
determination
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Chapter
3
Threshold
worksheet
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
3­
27,
3­
28
Total
annual
reportable
amount
(
see
Reportable
amount)
Trade
secret
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
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.
.
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.
.
.
.
.
.
.
2­
22
Transfers
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
Chapter
4
Treatment
efficiency
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10,
4­
15
Treatment
for
destruction
On­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
4­
10,
4­
15
Off­
site
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4­
10,
4­
15
TRI
database
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
.
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.
.
.
.
.
.
.
2­
21
Types
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Chapter
4
Waste
management
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
Chapter
4
Appendix
A
TRI
GUIDANCE
RESOURCES
A­
1
Appendix
A
TRI
GUIDANCE
RESOURCES
A.
1
EPCRA
Section
313
RELATED
REFERENCES
40
CFR
372,
Toxic
Chemical
Release
Reporting;
Community
Right­
to­
Know;
Final
Rule
See
53
FR
4500,
February
16,
1988.

Toxic
Chemical
Release
Inventory
Reporting
Forms
and
Instructions
for
the
Current
Reporting
Year
­
See
also
Automated
Toxic
Chemical
Release
Inventory
Reporting
Software
(
ATRS)
under
Section
A.
2,
Internet
Sites.
U.
S.
EPA
publishes
this
document
each
year
to
provide
current
guidance
for
preparing
the
Form
R
reports
and
Form
A
certification
statements.
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
certification
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
112(
r)
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
98­
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
A­
2
document
is
intended
for
the
exclusive
use
of
federal
facilities
in
complying
with
Sections
302,
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
Certification
(
EPA
745­
R­
98­
012)
This
is
a
compilation
of
Notices
of
Data
Change,
Significant
Error,
Noncompliance,
or
Technical
Error.
It
provides
a
listing
of
common
errors
found
on
the
Form
R
reports
submitted
to
U.
S.
EPA.
It
also
provides
a
discussion
of
the
types
of
errors
which
result
in
each
of
the
above
Notices
as
well
as
a
list
of
Notice
of
Technical
Error
codes
and
descriptions.

Trade
Secrets
Rule
and
Form
See
53
FR
28772,
July
29,
1988.
This
rule
implements
the
trade
secrets
provision
of
the
EPCRA
(
Section
322)
and
includes
a
copy
of
the
trade
secret
substantiation
form.

A.
2
INFORMATION
SOURCES
Most
of
the
materials
included
as
reference
in
this
manual
are
available
from
the
following
sources:

National
Center
for
Environmental
Publications
and
Information
(
NCEPI)
P.
O.
Box
42419
Cincinnati,
OH
45242­
2419
(
800)
490­
9198
Fax:
(
513)
489­
8695
Internet:
http://
www.
epa.
gov/
ncepihom/
index.
html
Emergency
Planning
and
Community
Right­
to­
Know
(
EPCRA)
Information
Hotline
U.
S.
Environmental
Protection
Agency
(
800)
424­
9346
or
(
703)
412­
9810
(
for
the
Washington,
D.
C.
metropolitan
area)
TDD:
(
800)
553­
7672
Internet
Sites

TRI
homepage:
http://
www.
epa.
gov/
tri
This
site
contains
information
on
the
Toxic
Release
Inventory
and
provides
links
to
a
variety
of
data
and
documents
related
to
the
TRI
program.


Automated
Toxic
Chemical
Release
Inventory
Reporting
Software
(
ATRS):
http://
www.
epa.
gov/
atrs
A­
3
This
site
provides
access
to
the
automated
EPCRA
Section
313
reporting
forms
for
electronic
submittal
of
required
data
to
U.
S.
EPA.


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.
html#
water8
WATER8
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
4
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
2001.

Chemical
Distribution
Facilities,
January
1999
(
EPA
745­
B­
99­
005)

Coal
Mining
Facilities,
January
1999
(
EPA
745­
B­
99­
002)

Coincidental
Manufacture/
By­
Products
(
EPA
260­
B­
01­
012)

Electricity
Generating
Facilities,
January
1999
(
EPA
745­
B­
99­
003)

Estimating
Releases
and
Waste
Treatment
Efficiencies
(
EPA260­
F­
01­
004)

Federal
Facilities,
May
2000
(
EPA­
745­
R­
00­
003)

Food
Processors,
September
1998
(
EPA
745­
R­
98­
011)

Formulation
of
Aqueous
Solutions,
March
1988
(
EPA
560­
4­
88­
004F)

Foundry
Operations
(
EPA
260­
B­
01­
009)

Leather
Tanning
and
Finishing
Industry,
April
2000
(
EPA
745­
B­
00­
012)

Metal
Mining
Facilities,
January
1999
(
EPA
745­
B­
99­
001)

Metal
Working
and
Electroplating
Operations,
(
EPA
260­
B­
01­
010)

Monofilament
Fiber
Manufacture
(
EPA
260­
B­
01­
014)

Pulp,
Paper,
and
Paperboard
Production
(
EPA
260­
B­
01­
015)

Petroleum
Terminals
and
Bulk
Storage
Facilities,
January
1999
(
EPA
745­
B­
99­
006)

Presswood
&
Laminated
Wood
Products
Manufacturing
(
EPA
260­
B­
01­
013)

Printing,
Publishing
and
Packaging
Industry,
April
2000
(
EPA
745­
B­
00­
005)

RCRA
Subtitle
C
TSD
Facilities
and
Solvent
Recovery
Facilities,
January
1999
(
EPA
745­
B­
99­
004)

Rubber
and
Plastics
Manufacturing,
April
2000
(
EPA
745­
B­
00­
017)
A­
5
Semiconductor
Manufacture,
July
1999
(
EPA
745­
R­
99­
007)

Smelting
Operations
(
EPA
260­
B­
01­
011)

Spray
Application
and
Electrodeposition
of
Organic
Coatings,
December
1998
(
EPA
745­
B­
99­
014)

Textile
Processing
Industry,
April
200
(
EPA
745­
B­
00­
008)

Welding
Operations
(
EPA
260­
B­
01­
007)

Wood
Preserving
Operations
(
EPA
260­
B­
01­
008)

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,
December
2000
(
EPA
745­
R­
00­
005)

Emergency
Planning
and
Community
Right­
to­
Know
EPCRA
Section
313:
List
of
Toxic
Chemicals
within
the
Chlorophenols
Category,
June
1999
(
EPA
745­
B­
99­
013)

Emergency
Planning
and
Community
Right­
to­
Know
EPCRA
Section
313:
Guidance
for
Reporting
Toxic
Chemicals
within
Dioxin
and
Dioxin­
like
Compounds
Category,
December
2000
(
EPA
745­
B­
00­
021)

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),
March
1998
(
EPA­
745­
R­
97­
007)

Guidance
for
Reporting
Hydrochloric
Acid
(
acid
aerosols
including
mists,
vapors,
gas,
fog,
and
other
airborne
forms
of
any
particle
size),
December
1999
(
EPA­
745­
B­
99­
014)

Toxic
Release
Inventory
List
of
Toxic
Chemicals
within
the
Glycol
Ethers
Category
and
Guidance
for
Reporting,
December
2000
(
EPA
745­
R­
00­
004)
A­
6
Toxic
Release
Inventory:
List
of
Toxic
Chemicals
within
the
Nicotine
and
Salts
Category,
June
1999
(
EPA
745­
R­
99­
010)

Toxic
Release
Inventory:
List
of
Toxic
Chemicals
within
the
Polychlorinated
Alkanes
Category
and
Guidance
for
Reporting,
June
1999
(
EPA
745­
B­
99­
023)

Toxic
Release
Inventory:
List
of
Toxic
Chemicals
within
the
Strychnine
and
Salts
Category,
June
1999
(
EPA
745­
R­
99­
011)

Toxic
Release
Inventory
List
of
Toxic
of
Chemicals
within
the
Water
Dissociable
Nitrate
Compounds
Category
and
Guidance
for
Reporting,
December
2000
(
EPA
745­
R­
00­
006)

Toxics
Release
Inventory
­
List
of
Toxic
Chemicals
Within
Ethylenebisdithiocarbamic
Acid,
Salts
and
Esters
Category
and
List
of
Mixtures
that
Contain
the
Individually
Listed
Chemicals
Maneb,
Metiram,
Nabam
and
Zineb,
December
2000
(
EPA
745­
B­
00­
018)

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
Emergency
Planning
and
Community
Right­
to­
Know
EPCRA
Section
313:
Guidance
for
Reporting:
Mercury
and
Mercury
Compounds
Category,
June
2001
(
EPA
745­
B­
01­
00X)

Emergency
Planning
and
Community
Right­
to­
Know
EPCRA
Section
313:
Guidance
for
Reporting:
Pesticides
and
Other
Persistent
Bioaccumulative
Toxic
(
PBT)
Chemicals,
June
2001
(
EPA
745­
B­
01­
00X)

Emergency
Planning
and
Community
Right­
to­
Know
EPCRA
Section
313:
Guidance
for
Reporting:
Polycyclic
Aromatic
Compounds
Category,
June
2001
(
EPA
745­
B­
01­
00X)

Toxics
Release
Inventory
­
List
of
Toxic
Chemicals
Within
Warfarin
Category,
June
1999
(
EPA
745­
B­
99­
011)

A.
5
OTHER
USEFUL
REFERENCES
Burgess,
W.
A.
Recognition
of
Health
Hazards
in
Industry.
Harvard
School
of
Public
Health.
Boston,
Massachusetts,
John­
Wiley
&
Sons.

CRC
Handbook
of
Chemistry
and
Physics.
Latest
Edition,
Robert
C.
Weast,
Editor,
CRC
Press,
Inc.,
Florida.

Kirk
Othmer
­
Encyclopedia
of
Chemical
Technology.
Latest
Edition,
John
Wiley
&
Sons,
New
York.

Locating
and
Estimating
Air
Emissions
from
Various
Sources.
Available
from:
National
Technical
Information
Services
(
NTIS),
(
703)
487­
4650.
A­
7
The
Merck
Index.
Latest
Edition,
Merck
&
Co.,
Inc.,
New
Jersey.

Perry,
R.
H.
and
C.
H.
Chilton,
Chemical
Engineer's
Handbook.
Latest
Edition,
McGraw­
Hill
Book
Company,
New
York.

Sax,
N.
I.
and
R.
J.
Lewis,
Sr.,
Hawley's
Condensed
Chemical
Dictionary.
Latest
Edition,
Van
Nostrand
Reinhold
Company,
New
York.
Appendix
B
BASIC
CALCULATION
TECHNIQUES
B­
1
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
80oC
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)
×
[(
 )
×
(
internal
stack
diameter)
2/
4)]

Volumetric
flow
=
(
8.0
m/
s)
×
[(
 )
×
(
0.3
m)
2/
4]
=
0.6
m3/
s
Step
2.
Correct
for
moisture
content
in
stack
gas
stream.

Stack
exhausts
may
contain
large
amounts
of
water
vapor.
The
concentration
of
the
chemical
in
the
exhaust
is
often
presented
on
a
dry
basis.
For
an
accurate
release
rate,
correct
the
vent
gas
flow
rate
for
the
moisture
content
by
multiplying
by
the
term
(
1
­
fraction
water
vapor).
The
dry
gas
rate
can
then
by
multiplied
by
the
chemical
concentration.
B­
2
Molar
volume

V
n

RT
P
(
Note:
If
the
toluene
concentration
is
on
a
wet
gas
basis,
no
correction
is
necessary
for
moisture
content.)

Dry
volumetric
flow
=
(
Volumetric
flow)
×
(
1­
fraction
water
vapor)

Dry
volumetric
flow
=
(
0.6
m3/
s)
×
(
1­
0.10)
=
0.5
m3/
s
Step
3.
Convert
ppmv
to
mg/
m3.


ppmv
is
defined
as
one
part
of
a
chemical
in
106
parts
of
gas
(
1.0
m3/
106
m3).


Use
the
molar
volume
of
a
gas,
corrected
for
stack
temperature
and
pressure
conditions,
calculated
by
the
ideal
gas
law
(
PV
=
nRT).
Note
that
the
molar
volume
of
an
ideal
gas
at
237
K
and
1
atm
is
22.4
L/
mole.


Molecular
weight
of
toluene
(
MW)
=
92.14
g/
mole.


R
=
the
Ideal
Gas
Constant
(
0.082057
L
­
atm
per
mole­
Kelvin)

To
calculate
the
molar
volume
of
stack
gas,
use
the
ideal
gas
equation.

For
the
example,
the
stack
conditions
are
80o
C
(
353
K)
and
atmospheric
pressure
(
1
atm).

=
29.0
L/
mole
The
conversion
of
ppmv
to
mg/
m3
can
now
be
calculated.
B­
3

2.5
lb/
yr
of
toluene
Using
the
example,
the
concentration
of
toluene
is
calculated
as
follows:

Step
4.
Calculate
air
releases.

Air
releases
are
calculated
as
follows:

Air
Release=(
volumetric
flow,
m3/
s)
×
(
concentration,
mg/
m3)
×
(
operating
time,
s/
yr)

The
paint
booth
is
used
8
hours
per
day,
5
days
per
week,
52
weeks
per
year.

It
is
important
to
note
that
this
calculation
assumes
the
measured
emissions
are
representative
of
actual
emissions
at
all
times;
however,
this
is
not
always
the
case.
Ideally,
a
continuous
emissions
monitor
provides
the
most
representative
data.

Also
note
that
monitoring
and
stack
data
may
have
units
that
are
different
than
those
used
in
the
example.
Modify
conversion
factors
and
constants
to
reflect
your
data
when
calculating
air
releases.

(
2)
Industrial
Hygiene
Data
The
following
is
an
example
of
a
release
calculation
using
industrial
hygiene
data.

Example:
Occupational
industrial
hygiene
data
shows
that
workers
are
exposed
to
an
average
of
0.1
ppmv
benzene
(
wet
gas
basis).
The
density
of
benzene
vapor
is
0.2
lb/
ft3.
The
ventilation
system
exhausts
20,000
acfm
of
room
air
at
70

F.
The
plant
operates
24
hours
per
day,
330
days
per
year.

The
benzene
concentration
is
on
a
wet
gas
basis,
therefore
a
moisture
correction
of
the
ventilation
flow
rate
is
not
necessary.
The
industrial
hygiene
data
is
collected
at
the
same
ambient
conditions
as
the
ventilation
system,
therefore
no
B­
4

190
lb/
yr
of
benzene
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)
×
(
operating
time,
min/
yr)
×
(
concentration
of
chemical,
ppmv)
×
(
vapor
density
of
chemical,
lb/
ft3)

Benzene
releases
per
year
would
be
calculated
as
follows:

(
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.

P
A
=
X
A,
L
Po
=
X
A,
G
P
T
where:

P

=
Vapor
pressure
of
pure
liquid
chemical
A;
X
A,
L
=
Mole
fraction
of
chemical
A
in
solution;
X
A,
G
=
Mole
fraction
of
chemical
A
in
the
gas
phase;
P
A
=
Partial
pressure
of
chemical
A
in
the
gas
phase;
and
P
T
=
Total
pressure.

Example:
A
wash
tank
holds
a
solution
containing
10%
by
weight
of
o­
xylene
(
A)
and
90%
by
weight
of
toluene
(
B).
The
tank
is
vented
to
the
atmosphere;
the
process
vent
flow
rate
is
estimated
as
100
acfm
(
2.83m3/
min)
based
on
a
minimum
fresh
air
ventilation
rate.
The
molecular
weight
of
o­
xylene
is
106.17
g/
mole
and
toluene
is
92.14
g/
mole.
The
vapor
pressure
of
o­
xylene
is
10
mm
of
Hg
(
0.19
psia).
The
total
pressure
of
the
system
is
14.7
psia
(
atmospheric
conditions).
The
process
tank
is
in
service
250
days/
yr.
Calculate
the
air
release
of
o­
xylene.

Step
1:
Calculate
the
mole
fraction
of
o­
xylene
in
the
liquid
solution.
B­
5
X
A,
L

wt
fraction
A
MW
A
wt
fraction
A
MW
A

wt
fraction
B
MW
B
X
A,
L

0.1
106.17
0.1
106.17

0.9
92.14
X
A,
L

0.09
X
A,
G

X
A,
L
P

P
T
X
A,
G

[
0.09]
×
0.19
psia
14.7
psia

0.001
Where:

X
A,
L
=
Mole
fraction
of
chemical
A
in
liquid
solution;
MW
=
Molecular
weight
of
chemical,
g/
mole;
and
wt
fraction
=
Weight
fraction
of
chemical
in
material.

Step
2:
Calculate
the
mole
fraction
of
o­
xylene
in
the
gas
phase.

where:

X
A,
G
=
Mole
fraction
of
chemical
A
in
gas
phase;
X
A,
L
=
Mole
fraction
of
chemical
A
in
liquid
solution;
P

=
Vapor
pressure
of
pure
liquid
chemical
A,
psia;
and
P
T
=
Total
pressure
of
system,
psia.

Step
3:
Calculate
releases
using
Raoult's
Law.
B­
6
Emissions

(
X
A,
G)
×
(
AFR)
×
(
t)
×
(
MW
A)
×
1
MV
2.83m3
min
×
250
day
yr
×
24
hr
day
×
60
min
hr
×
mole
22.4L
×
106.17g
mole
×
L
10

3m3
Emissions

4.8
×
106
g/
yr
×
lb
454
g

10,570
lb/
yr
of
o

xylene
AE

(
EF)
×
(
AU)
×
(
OT)
where:

Emissions
=
Air
release
of
pollutant
A,
g­
A/
yr;
X
A,
G
=
Mole
fraction
of
chemical
A
in
gas
phase;
AFR
=
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)
×
=
4.8
×
106
g/
yr
The
emission
of
o­
xylene
is
calculated
as
shown
below.

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.
B­
7
AE

0.061
lb
103
gal
×
300
gal
hr
×
2,000
hr
yr

36.6
lb/
yr
of
formaldehyde
5
drums
yr
×
55
gal
drum
×
9.5
lb
gal
×
5lb
Cd
100lb
waste

131
lb/
yr
of
cadmium
where:

AE
=
Annual
emissions
of
pollutant,
lb/
yr
EF
=
Emission
factor
of
pollutant,
lb/
103
gallon
of
fuel.
EF
for
formaldehyde
for
an
industrial
boiler
burning
No.
2
fuel
oil
is
0.035
to
0.061
lb/
103
gallons.
AU
=
Quantity
of
fuel
used,
gal/
yr.
OT
=
Operating
time,
hr/
yr.

Using
an
emission
factor
of
0.061
pounds
of
formaldehyde
per
gallon
of
fuel,
the
air
releases
are
calculated
as
follows:

(
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
lb/
gallon,
the
amount
of
cadmium
to
off­
site
disposal
is
calculated
as
follows:

Amount
of
cadmium
=
(
amount
of
paint
waste
disposed,
gal/
yr)
×
(
concentration
of
cadmium,
lb/
lb)
×
(
density
of
paint
waste,
lb/
gal)

(
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,
flow
rate­
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
8
First
Quarter:
10
µ
g
L
×
1g
106
µ
g
×
1lb
454g
×
3.785L
gal
0.5
×
106
gal
day
0.04

0.05

0.02

0.005
4
lb/
day

0.03lb/
day
Yearly
Quarter
Sample
Number
Discharge
Flow
Rate
(
106
gal/
day)
Total
Silver
(
µ
g/
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)
×
(
silver
concentration)

=
0.04
lb/
day
of
silver
The
amount
of
silver
discharged
during
each
of
the
other
three
monitoring
events
was
similarly
determined
to
be:

0.05
lb/
day;
0.02
lb/
day,
and
0.005
lb/
day.

For
the
last
data
point
the
concentration
of
silver
was
reported
by
the
laboratory
to
be
less
than
the
detection
limit
of
3
µ
g/
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:

The
plant
operates
350
days/
year
(
plant
shuts
down
for
two
weeks
in
July).

The
estimated
annual
discharge
of
silver
is
calculated
as
follows:

Annual
discharge
=
(
350
day/
yr)
(
0.03
lb/
day)
=
10.5
lb
of
silver/
yr
Appendix
C
UNIT
CONVERSION
FACTORS
(
From
U.
S.
Coast
Guard
Commandant
Instruction
M.
16465.12A)
C­
1
CONVERSION
FACTORS
To
Convert
To
Multiply
By
Length
inches
inches
feet
feet
feet
feet
yards
yards
miles
(
U.
S.
statute)
miles
(
U.
S.
statute)
miles
(
U.
S.
statute)
miles
(
U.
S.
statute)
meters
meters
meters
nautical
miles
millimeters
feet
inches
meters
yards
miles
(
U.
S.
statute)
feet
miles
(
U.
S.
statute)
feet
yards
meters
nautical
miles
feet
yards
miles
(
U.
S.
statute)
miles
(
U.
S.
statute)
25.4
0.0833
12
0.3048
0.3333
0.0001894
3
0.0005682
5280
1760
1609
0.868
3.271
1.094
0.0006214
1.152
Area
square
inches
square
inches
square
feet
square
feet
square
meters
square
miles
square
yards
square
centimeters
square
feet
square
inches
square
meters
square
feet
square
yards
square
feet
6.452
0.006944
144
0.09290
10.76
3,097,600
9
Volume
cubic
inches
cubic
inches
cubic
feet
cubic
feet
cubic
feet
cubic
meters
liters
quarts
(
U.
S.
liquid)
U.
S.
gallons
U.
S.
gallons
U.
S.
gallons
barrels
(
petroleum)
Imperial
gallons
milliliters
cubic
centimeters
cubic
feet
cubic
inches
cubic
meters
U.
S.
gallons
cubic
feet
quarts
(
U.
S.
liquid)
liters
barrels
(
petroleum)
cubic
feet
Imperial
gallons
U.
S.
gallons
U.
S.
gallons
cubic
centimeters
16.39
0.0005787
1728
0.02832
7.481
35.31
1.057
0.9463
0.02381
0.1337
0.8327
42
1.201
1
CONVERSION
FACTORS
(
Continued)

To
Convert
To
Multiply
By
C­
2
Time
seconds
seconds
seconds
minutes
minutes
minutes
hours
hours
hours
minutes
hours
days
seconds
hours
days
seconds
minutes
days
0.01667
0.0002778
0.00001157
60
0.01667
0.0006944
3600
60
0.04167
Mass
or
Weight
pounds
pounds
pounds
pounds
tons
(
short)
tons
(
metric)
tons
(
long)
kilograms
tonnes
(
metric
tons)
kilograms
short
tons
long
tons
metric
tons
pounds
pounds
pounds
pounds
kilograms
0.4536
0.0005
0.000464
0.0004536
2000
2205
2240
2.205
1000
Energy
calories
calories
Btu
(
British
thermal
units)
Btu
joules
joules
Btu
joules
calories
joules
calories
Btu
0.003968
4.187
252.0
1055
0.2388
0.0009479
Velocity
feet
per
second
feet
per
second
feet
per
second
meters
per
second
meters
per
second
miles
per
hour
miles
per
hour
knots
knots
knots
pounds
per
cubic
foot
grams
per
cubic
centimeter
grams
er
cubic
centimeter
kilograms
per
cubic
meter
meters
per
second
miles
per
hour
knots
feet
per
second
miles
per
hour
meters
per
second
feet
per
second
meters
per
second
miles
per
hour
feet
per
second
grams
per
cubic
centimeter
pounds
per
cubic
foot
kilograms
per
cubic
meter
grams
per
cubic
centimeter
0.3048
0.6818
0.5921
3.281
2.237
0.4470
1.467
0.5148
1.151
1.689
0.01602
62.42
1000
0.001
CONVERSION
FACTORS
(
Continued)

To
Convert
To
Multiply
By
C­
3
Pressure
ponds
per
square
inch
(
absolute)
(
psia)
psia
psia
psia
pounds
per
square
inch
(
gauge)
(
psig)
millimeters
of
mercury
(
torr)
millimeters
of
mercury
(
torr)
inches
of
water
kilograms
per
square
centimeter
inches
of
water
kilograms
per
square
centimeter
atmospheres
kilograms
per
square
centimeter
atmospheres
bars
kilonewtons
per
square
meter
(
kN/
m2)
bars
kilonewtons
per
square
meter
(
kN/
m2)
bars
kilonewtons
per
square
meter
(
kN/
m2)
atmospheres
inches
of
water
millimeters
of
mercury
(
torr)
psia
psia
kN/
m2
psia
millimeters
of
mercury
(
torr)
kN/
m2
atmospheres
kN/
m2
psia
psia
kN/
m2
psia
atmospheres
atmospheres
kilograms
per
square
centimeter
6.895
0.0680
27.67
51.72
add
14.70
0.01934
0.1333
0.03614
735.6
0.2491
0.9678
101.3
14.22
14.70
100
0.1450
0.9869
0.009869
1.020
Viscosity
centipoises
pounds
per
foot
per
second
centipoises
centipoises
poises
grams
per
centimeter
per
second
Newton
seconds
per
square
meter
pounds
per
foot
per
second
centipoises
poises
Newton
seconds
per
square
meter
grams
per
centimeter
per
second
poises
centipoises
0.0006720
1488
0.01
0.001
1
1
1000
Thermal
Conductivity
Btu
per
hour
per
foot
per

F
Btu
per
hour
per
foot
per

F
watts
per
meter­
kelvin
kilocalories
per
hour
per
meter
per

C
kilocalories
per
hour
per
meter
per

C
watts
per
meter­
kelvin
kilocalories
per
hour
per
meter
per

C
Btu
per
hour
per
foot
per

F
watts
per
meter­
kelvin
Btu
per
hour
per
foot
per

F
1.731
1.488
0.5778
1.163
0.6720
Heat
Capacity
Btu
per
pound
per

F
Btu
per
pound
per

F
joules
per
kilogram­
kelvin
calories
per
gram
per

C
calories
per
gram
per

C
joules
per
kilogram­
kelvin
Btu
per
pound
per

F
Btu
per
pound
per

F
1
4187
0.0002388
1
CONVERSION
FACTORS
(
Continued)

To
Convert
To
Multiply
By
C­
4
Concentration
(
in
water
solution)

parts
per
million
(
ppm)
milligrams
per
liter
milligrams
per
cubic
meter
grams
per
cubic
centimeter
grams
per
cubic
centimeter
pounds
per
cubic
foot
milligrams
per
liter
ppm
grams
per
cubic
centimeter
milligrams
per
cubic
meter
pounds
per
cubic
foot
grams
per
cubic
centimeter
1
1
1
×
10­
9
1
×
109
62.42
0.01602
Temperature
degrees
Kelvin
(

K)
degrees
Rankine
(

R)
degrees
centigrade
(

C)
degrees
Fahrenheit
(

F)

degrees
centigrade
(

C)
degrees
Fahrenheit
(

F)
degrees
Rankine
(

R)
degrees
Kelvin
(

K)
degrees
Fahrenheit
(

F)
degrees
centigrade
(

C)

degrees
Kelvin
(

K)
degrees
Kelvin
(

K)
1.8
0.5556
first
multiply
by
1.8,
then
add
32
first
subtract
32,
then
multiply
by
0.5556
add
273.2
add
459.7
Flow
cubic
feet
per
second
U.
S.
gallons
per
minute
U.
S.
gallons
per
minute
cubic
feet
per
second
448.9
0.002228
Universal
Gas
Constant
(
R)

8.314
joules
per
gram
mole­
kelvin
1.987
calories
per
gram
mole­
kelvin
1.987
Btu
per
pound
mole
per

F
10.73
psia­
cubic
feet
per
pound
mole
per

F
82.057
atm­
cubic
centimeters
per
gram
mole­
kelvin
62.361
millimeters
mercury
liter
per
gram
mole­
kelvin
