Rocky Beem
2011 Smithfield Environmental
Training Conference
Tier II Reporting
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40 CFR 370 EPCRA
Community Right-to-Know
For Emergency Response
Report Due March 1 (Tier II)
Above Thresholds for:
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TRI Reporting
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MSDS Required for Chemical
Stored On-Site
500 lbs for EHS
10,000 lbs all others
Report to LEPC, SEPC, Fire Dept.
40 CFR 372 EPCRA
Environmental Releases
Report Due July 1 (Form R or A)
Above Thresholds for:
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Listed 313 Chemicals (600+)
Manufactured - 25,000 lbs
Processed - 25,000 lbs
Otherwise Used - 10,000 lbs
Bioaccumlative Toxics - 0.1-100 lbs
Report to EPA and State
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Chemical Requiring MSDS
Stored On-Site at Any Time
Exceeds Threshold
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Calculate Mixture Quantity
10,000 lbs or 500 lbs/TPQ
Review MSDS’s, Inventories, Invoices
ALL Chemicals
Storage Locations & Volumes
10,000 lbs
Some Exclusions Apply
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Mixtures
Personal Items
Foods
Solid Form with No Exposure
Personal Use Items
Lab or Medical Uses
Agriculture Uses (e.g. fertilizer)
500 lbs or TPQ (EHS)
Aggregate lbs
Any Exclusions?
Articles / Food Additves
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Monthly Tour
Tank Storage Capacity
Contractor Usage
Fuels
Compressed Gases
De-icing Salt and Softeners
Hydraulic Fluid
Fire Suppressants
Lead-Acid Batteries
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18% Acid / 82% Lead
Sand-Blasting Grit
Truck Deliveries
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Facility Information
Emergency Contact
Reportable Chemicals
Quantity Stored
Chemical Hazards
Storage Locations (site
map)
Liquid, Gas, Solid
EHS ?
CAS #
Submit MSDS’s
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When
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Where
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Between January 1 and March 1 Annually
State Emergency Response Commission (SERC)
Local Emergency Planning Committee (LEPC)
Local Fire Department
How - State Specific
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Electronic Only (web) - IN, MD, MO, NC, OH, PA, VA, GA, IL
Paper Only - SD
Paper or Electronic - IA, KS, MN, NE, UT
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40 CFR 372
Understanding Activities and Thresholds
Exemptions
Form R versus Form A
Ammonia
Chlorine
Nitrates
Sodium Nitrite
Methanol
Combustion Manufactured 313’s
Wastewater Manufactured 313’s
Individual Lists
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Ammonia
Chlorine
Chlorine Dioxide
Sodium Nitrite
Methanol
PCBs
Asbestos
Chemical Categories
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Nitrate Compounds
Mercury Compounds
Lead Compounds
Polycyclic Aromatic Cpds
Special Concern List
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Persistant Bioaccumulative
Toxics (PBTs)
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Lower Thresholds
Long list
Activity Thresholds
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Manufactured 25,000 lbs
Processed 25,000 lbs
Otherwise Used 10,000 lbs
Separate Activity Thresholds
Persistant Bioaccumulative Toxics (PBTs)
16 Chemicals; 4 compounds (NO de mininis)
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100 lbs (e.g. PACs, lead, lead compounds)
10 lbs (“highly”) mercury, mercury cpds
0.1 lbs Dioxin-like
Activity
Manufactured
Processed
Otherwise Used
Threshold
25,000 lbs
25,000 lbs
10,000 lbs
Examples:
Produced
Compounded
Imported
ByproductCoincidentally
Manufactured
Prepare for
Distribution
Reactants
Formulations
-Ingredient
Process Aid
Treating Waste
Manufacturing
Aid
Sec 313
Made On-site
Sec 313
Already Exists
Sec 313
Already Exists
Exempt
N/A
Article
Personal Use
Environment
de minimis 1%
Structure
Vehicles
Laboratory
Janitorial
Activity
Threshold
Manufactured
Processed
Otherwise Used
25,000 lbs
25,000 lbs
10,000 lbs
ByproductCoincidentally
Manufactured
Examples: Wastewater Treatment:
Nitrate
Ammonia
Natural Gas Combustion:
Benzo (g,h,i) perylene
Mercury
Lead
Ingredient
Sodium
Nitrite
Process Aid
Treating Waste
Chlorine
Ammonia
Methanol
Activity
Threshold
Source
Total lbs
Manufactured
25,000 lbs
Processed
25,000 lbs
10,000 lbs
Refrigeration
Makeup
Wastewater Treatment
& Combustion Product
5,040 lbs
Otherwise Used
0 lbs
=300 MGD X 8.34 lb/gal X 2 mg/L
9,000 lbs
Annual Replacement
=200 mmft3 NG X 0.18 lb / mmft3
Threshold
Exceeded
NO
NO
NO
Activity
Threshold
Source
Total lbs
Manufactured
25,000 lbs
Processed
25,000 lbs
Wastewater Treatment
10,008 lbs**
0 lbs
=300 MGD X 8.34 lb/gal X 4 mg/L
Threshold
Exceeded
NO
Otherwise Used
10,000 lbs
Refrigeration
Makeup
37,000 lbs*
Annual Replacement
NO
YES
Form R Required: Report 47,008 lbs; check both manufactured and otherwise used.
*NOTE: If you release >36,000 lbs/yr (100 lbs/day), you will have to report a
continuous release !
**NOTE: The 1% de minimis exemption does not apply to manufactured
Section 313 chemicals (nitrate, ammonia, combustion products)
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Chlorine (Gas - Cl2)
Chlorine Dioxide (ClO2)
Sodium Hypochlorite (NaOCl)
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“Otherwise Used” 10,000 lbs
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NOT a Sec 313 Chemical
Same as “bleach”
Report Cl2 and ClO2
NaOCl Not reportable
Can Cl2 be manufactured from
sodium hypochlorite?
http://www.epa.gov/tri/guide_docs/pdf/1998/food.pdf
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IF the sum of Sections 8.1 through 8.7 is less than
500 lbs (should be), and the total used is less than
1,000,000 lbs, you can certify using Form A.
Source: EPA
On-site Drinking
Water
Chlorination
Employee Use
Personal Use
Exemption
Allocate Use
Process Use
Employee Use
City Water
Use
Process Use
“Otherwise Used”
“Environment”
Exemption
Activity
Threshold
Source
Total lbs
Manufactured
Processed
Otherwise Used
25,000 lbs
25,000 lbs
10,000 lbs
Wastewater Treatment
50,004 lbs*
0 lbs
0 lbs
NO
NO
=300 MGD X 8.34 lb/gal X 20 mg/L
Threshold
Exceeded
Yes
*The pounds of nitrate for threshold determinations must be based on the
weight of the nitrate compound NaNO3, not the ion NO3-. Releases are
reported using NO3-.
(“Toxic Release Inventory Lists of Chemicals within the Water Dissociable Nitrate Compounds
Category and Guidance for Reporting” (May 1996, EPA)
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Land application of wastewater sludge containing nitrate
and ammonia is regarded as “managed as waste” even
though it has nutrient value. - EPA
Report as being disposed to land (onsite or offsite).
Activity
Threshold
Manufactured
25,000 lbs
Processed
25,000 lbs
Otherwise Used
10,000 lbs
Processing Aid
Anoxic Basin
Food
Source
Total lbs
0 lbs
0 lbs
30,000 lbs
Threshold
Exceeded
NO
NO
Yes*
*Methanol may be completed consumed in the process resulting in zero
releases (Sections 8.1-8.7). It may be eligible for a Form A.
Activity
Threshold
Manufactured
25,000 lbs
Processed
25,000 lbs
Otherwise Used
10,000 lbs
Food
Ingredient
Source
Total lbs
0 lbs
Threshold
Exceeded
NO
*Primarily released to the wastewater.
65,000 lbs
Yes
0 lbs
NO
Lead Compounds 100 lbs Mercury Compounds 10 lbs
Polycyclic aromatic compounds (PACs) 100 lbs
AP-42
 Stack Test
 25,000 lb
Threshold
Unless PBT
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AP-42
Manufactured Lead = 0.0005 lb/106 ft3 X 700 mmft3 = 0.35 lbs Lead
Annual NG Used
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“EPCRA 313 Reporting Guidelines for Food
Processors”
EPA September 1998
http://www.epa.gov/tri/guide_docs/pdf/1998/food.pdf
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“List of Toxic Chemicals within the Water
Dissociable Nitrate Compounds Category and
Guidance for Reporting” May 1996, EPA
“Revised 1998 EPCRA 313 Questions and
Answers”
December 1998 EPA
http://www.epa.gov/tri/guide_docs/index.htm
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Combustion Manufactured 313’s
Wastewater Manufactured 313’s
Proper Activity Selection
Review significant Year to Year Changes
Start Early
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When
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What
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By July 1
Form R for Each 313 Chemical
Exceeding the Threshold
Form A if environmental releases
(Sec 8.1-8.7) are <500 lbs
How
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EPA Electronically TRI-MEweb