rocky beem 2011 smithfield environmental training conference
TRANSCRIPT
Tier II and TRI Reporting
Rocky Beem2011 Smithfield Environmental
Training Conference
Comparison of Requirements
Tier II Reporting 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.
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
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
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
Example Spreadsheet
EPA “List of Lists”
Annual Report Facility Information Emergency Contact Reportable Chemicals Quantity Stored Chemical Hazards Storage Locations (site
map) Liquid, Gas, Solid EHS ? CAS # Submit MSDS’s
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
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
TRI Reporting Criteria
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 Persistant Bioaccumulative
Toxics (PBTs) Lower Thresholds Long list
Chemical ThresholdsActivity Thresholds Manufactured 25,000 lbs Processed 25,000 lbs Otherwise Used 10,000 lbs
Persistant Bioaccumulative 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
Applicable Activities – Sec 313
Activity
Threshold
Examples:
Manufactured Processed Otherwise Used Exempt
25,000 lbs 25,000 lbs 10,000 lbs N/A
ProducedCompoundedImportedByproduct-CoincidentallyManufactured
Prepare for DistributionReactantsFormulations-Ingredient
Process AidTreating WasteManufacturing Aid
Sec 313Made On-site
Sec 313 Already Exists
Sec 313 Already Exists
ArticlePersonal UseEnvironmentde minimis 1%StructureVehiclesLaboratoryJanitorial
Applicable Activities Activity
Threshold
Examples:
Manufactured Processed Otherwise Used
25,000 lbs 25,000 lbs 10,000 lbs
Byproduct-CoincidentallyManufactured
Ingredient Process AidTreating Waste
Wastewater Treatment: Nitrate AmmoniaNatural Gas Combustion: Benzo (g,h,i) perylene Mercury Lead
Sodium Nitrite
ChlorineAmmoniaMethanol
Threshold Determination - Ammonia
Activity
Threshold
Source
Total lbs
ThresholdExceeded
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
NO NONO
=200 mmft3 NG X 0.18 lb / mmft3
Threshold Determination - Ammonia
Activity
Threshold
Source
Total lbs
ThresholdExceeded
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 YESNO
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)
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?
Chlorine Discussion
http://www.epa.gov/tri/guide_docs/pdf/1998/food.pdf
Chlorine Discussion
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
Chlorine – Exemptions
On-site DrinkingWater
Chlorination
City WaterUse
Employee Use
Process Use
Allocate Use
Personal UseExemption
“Otherwise Used”
Employee Use
Process Use
“Environment”Exemption
Nitrate Compounds Activity
Threshold
Source
Total lbs
ThresholdExceeded
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 NONO
*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)
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).
Methanol Activity
Threshold
Source
Total lbs
ThresholdExceeded
Manufactured Processed Otherwise Used
25,000 lbs 25,000 lbs 10,000 lbs
0 lbs 30,000 lbs
NO Yes*NO
Processing Aid Anoxic Basin
Food
0 lbs
*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.
Sodium Nitrite Activity
Threshold
Source
Total lbs
ThresholdExceeded
Manufactured Processed Otherwise Used
25,000 lbs 25,000 lbs 10,000 lbs
65,000 lbs 0 lbs
NO NOYes
FoodIngredient
0 lbs
*Primarily released to the wastewater.
Example FAQ - Closed-Loop Refrigeration
Persistent Bioaccumulative Toxics
Lead Compounds 100 lbs Mercury Compounds 10 lbsPolycyclic aromatic compounds (PACs) 100 lbs
Combustion Manufactured 313’s AP-42 Stack Test 25,000 lbThresholdUnless PBT
Combustion Manufactured 313’s
AP-42
Combustion Manufactured 313’s
Manufactured Lead = 0.0005 lb/106 ft3 X 700 mmft3 = 0.35 lbs Lead
Annual NG Used
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
Don’t Forget !
Combustion Manufactured 313’s Wastewater Manufactured 313’s Proper Activity Selection Review significant Year to Year Changes Start Early
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