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Tier II and TRI Reporting

Tier II and TRI Reporting. Rocky Beem 2011 Smithfield Environmental Training Conference. Comparison of Requirements. Tier II Reporting. TRI Reporting. 40 CFR 372 EPCRA Environmental Releases Report Due July 1 (Form R or A) Above Thresholds for: Listed 313 Chemicals (600+)

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Tier II and TRI Reporting

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  1. Tier II and TRI Reporting Rocky Beem 2011 Smithfield Environmental Training Conference

  2. Comparison of Requirements Tier II Reporting TRI Reporting 40 CFR 372 EPCRA Environmental Releases Report Due July 1 (Form R or A) Above Thresholds for: 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 • 40 CFR 370 EPCRA • Community Right-to-Know • For Emergency Response • Report Due March 1 (Tier II) • Above Thresholds for: • MSDS Required for Chemical • Stored On-Site • 500 lbs for EHS • 10,000 lbs all others • Report to LEPC, SEPC, Fire Dept.

  3. Tier II - What is Reported? • Chemical Requiring MSDS • Stored On-Site at Any Time • Exceeds Threshold • Calculate Mixture Quantity • 10,000 lbs or 500 lbs/TPQ • Some Exclusions Apply • Foods • Solid Form with No Exposure • Personal Use Items • Lab or Medical Uses • Agriculture Uses (e.g. fertilizer) Aggregate lbs

  4. Chemical Inventory • Monthly Tour • Tank Storage Capacity • Contractor Usage • Fuels • Compressed Gases • De-icing Salt and Softeners • Hydraulic Fluid • Fire Suppressants • Lead-Acid Batteries • 18% Acid / 82% Lead • Sand-Blasting Grit • Truck Deliveries All Chemicals Max on Any Day Temporary Storage On Site at any time

  5. Example Spreadsheet

  6. EPA “List of Lists”

  7. Annual Report • Facility Information • Emergency Contact • Reportable Chemicals • Quantity Stored • Chemical Hazards • Storage Locations (site map) • Liquid, Gas, Solid • EHS ? • CAS # • Submit MSDS’s

  8. Tier II Submittal • When • Between January 1 and March 1 Annually • Where • State Emergency Response Commission (SERC) • Local Emergency Planning Committee (LEPC) • Local Fire Department • How - State Specific • Electronic Only (web) - IN, MD, MO, NC, OH, PA, VA, GA, IL • Paper Only - SD • Paper or Electronic - IA, KS, MN, NE, UT

  9. TRI Reporting • 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

  10. TRI Reporting Criteria

  11. Potential Section 313 Chemicals Individual Lists • Ammonia • Chlorine • Chlorine Dioxide • Sodium Nitrite • Methanol • PCBs • Asbestos Chemical Categories • Nitrate Compounds • Mercury Compounds • Lead Compounds • Polycyclic Aromatic Cpds Special Concern List • PersistantBioaccumulative Toxics (PBTs) • Lower Thresholds • Long list

  12. Chemical Thresholds Activity Thresholds Manufactured 25,000 lbs Processed 25,000 lbs Otherwise Used 10,000 lbs PersistantBioaccumulative Toxics (PBTs) 16 Chemicals; 4 compounds (NO de mininis) 100 lbs (e.g. PACs, lead, lead compounds) 10 lbs (“highly”) mercury, mercury cpds 0.1 lbs Dioxin-like Separate Activity Thresholds

  13. Applicable Activities – Sec 313 Activity Threshold Examples: Manufactured Processed Otherwise Used Exempt 25,000 lbs 25,000 lbs 10,000 lbs N/A Process Aid Treating Waste Manufacturing Aid Article Personal Use Environment de minimis 1% Structure Vehicles Laboratory Janitorial Produced Compounded Imported Byproduct- Coincidentally Manufactured Prepare for Distribution Reactants Formulations -Ingredient Sec 313 Made On-site Sec 313 Already Exists Sec 313 Already Exists

  14. Applicable Activities Activity Threshold Examples: Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Process Aid Treating Waste Byproduct- Coincidentally Manufactured Ingredient Wastewater Treatment: Nitrate Ammonia Natural Gas Combustion: Benzo (g,h,i) perylene Mercury Lead Sodium Nitrite Chlorine Ammonia Methanol

  15. Threshold Determination - Ammonia Activity Threshold Source Total lbs Threshold Exceeded Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Refrigeration Makeup Wastewater Treatment & Combustion Product 5,040 lbs 0 lbs 9,000 lbs =300 MGD X 8.34 lb/gal X 2 mg/L Annual Replacement =200 mmft3 NG X 0.18 lb / mmft3 NO NO NO

  16. Threshold Determination - Ammonia Activity Threshold Source Total lbs Threshold Exceeded Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Refrigeration Makeup Wastewater Treatment 10,008 lbs** 0 lbs 37,000 lbs* =300 MGD X 8.34 lb/gal X 4 mg/L Annual Replacement NO 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)

  17. Chlorine Discussion • Chlorine (Gas - Cl2) • Chlorine Dioxide (ClO2) • Sodium Hypochlorite (NaOCl) • NOT a Sec 313 Chemical • Same as “bleach” • “Otherwise Used” 10,000 lbs • Report Cl2 and ClO2 • NaOCl Not reportable • Can Cl2 be manufactured from sodium hypochlorite?

  18. Chlorine Discussion http://www.epa.gov/tri/guide_docs/pdf/1998/food.pdf

  19. Chlorine Discussion

  20. Chlorine – Optional Form A • 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

  21. Chlorine – Exemptions Personal Use Exemption On-site Drinking Water Chlorination Employee Use Allocate Use Process Use “Otherwise Used” Employee Use City Water Use “Environment” Exemption Process Use

  22. Nitrate Compounds Activity Threshold Source Total lbs Threshold Exceeded Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Wastewater Treatment 50,004 lbs* 0 lbs 0 lbs =300 MGD X 8.34 lb/gal X 20 mg/L Yes NO NO *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)

  23. Nitrate Compounds - Sludge • 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).

  24. Methanol Activity Threshold Source Total lbs Threshold Exceeded Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Processing Aid Anoxic Basin Food 0 lbs 0 lbs 30,000 lbs NO Yes* NO *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.

  25. Sodium Nitrite Activity Threshold Source Total lbs Threshold Exceeded Manufactured Processed Otherwise Used 25,000 lbs 25,000 lbs 10,000 lbs Food Ingredient 0 lbs 65,000 lbs 0 lbs NO Yes NO *Primarily released to the wastewater.

  26. Example FAQ - Closed-Loop Refrigeration

  27. Persistent Bioaccumulative Toxics Lead Compounds 100 lbs Mercury Compounds 10 lbs Polycyclic aromatic compounds (PACs) 100 lbs

  28. Combustion Manufactured 313’s • AP-42 • Stack Test • 25,000 lb Threshold Unless PBT

  29. Combustion Manufactured 313’s • AP-42

  30. Combustion Manufactured 313’s Manufactured Lead = 0.0005 lb/106 ft3 X 700 mmft3 = 0.35 lbs Lead Annual NG Used

  31. References • “EPCRA 313 Reporting Guidelines for Food Processors” EPA September 1998 http://www.epa.gov/tri/guide_docs/pdf/1998/food.pdf • “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

  32. http://www.epa.gov/tri/guide_docs/index.htm

  33. Don’t Forget ! • Combustion Manufactured 313’s • Wastewater Manufactured 313’s • Proper Activity Selection • Review significant Year to Year Changes • Start Early

  34. Annual Reporting • When • By July 1 • What • Form R for Each 313 Chemical Exceeding the Threshold • Form A if environmental releases (Sec 8.1-8.7) are <500 lbs • How • EPA Electronically TRI-MEweb

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