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TRI Form R Reporting Rocky Beem 2011 Smithfield Environmental Conference.

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Presentation on theme: "TRI Form R Reporting Rocky Beem 2011 Smithfield Environmental Conference."— Presentation transcript:

1 TRI Form R Reporting Rocky Beem 2011 Smithfield Environmental Conference

2 Smithfield-Specific Reporting 40 CFR 372 Understanding Activities and Thresholds Exemptions Form R versus Form A Smithfield Form R Chemicals Ammonia Chlorine Nitrates Sodium Nitrite Methanol Combustion Manufactured 313’s

3 TRI Reporting Criteria

4 Potential Section 313 Chemicals Individual Lists Ammonia Chlorine Chlorine Dioxide Sodium Nitrite Methanol PCBs Asbestos Chemical Categories Nitrates Compounds Mercury Compounds Lead Compounds Polycyclic Aromatic Cpds Special Concern List Persistant Bioaccumulative Toxics (PBTs) Lower Thresholds Long list

5 Chemical Thresholds Activity 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

6 Applicable Activities – Sec 313 Activity Threshold Examples : ManufacturedProcessedOtherwise UsedExempt 25,000 lbs 10,000 lbsN/A Produced Compounded Imported Byproduct- Coincidentally 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 Article Personal Use Environment de minimis 1% Structure Vehicles Laboratory Janitorial

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

8 Threshold Determination - Ammonia Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessedOtherwise Used 25,000 lbs 10,000 lbs Refrigeration Makeup Wastewater Treatment & Combustion Product 5,040 lbs0 lbs9,000 lbs =300 MGD X 8.34 lb/gal X 2 mg/LAnnual Replacement NO =200 mmft 3 NG X 0.18 lb / mmft 3

9 Threshold Determination - Ammonia Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessedOtherwise Used 25,000 lbs 10,000 lbs Refrigeration Makeup Wastewater Treatment 10,008 lbs**0 lbs37,000 lbs* =300 MGD X 8.34 lb/gal X 4 mg/LAnnual Replacement NOYESNO Form R Required: Report 47,008 lbs; check both produced and otherwise used. *NOTE: If you release >36,500 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)

10 Chlorine Discussion Chlorine (Gas - Cl 2 ) Chlorine Dioxide (ClO 2 ) Sodium Hypochlorite (NaOCl) NOT a Sec 313 Chemical Same as “bleach” “Otherwise Used” Can Cl 2 be manufactured from sodium hypochlorite?

11 Chlorine Discussion NOT 313 Chemicals

12 Chlorine Discussion

13 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

14 Chlorine – Exemptions On-site Drinking Water Chlorination City Water Use Employee Use Process Use Allocate Use Personal Use Exemption “Otherwise Used” Employee Use Process Use “Environment” Exemption NOTE: Likely no “chlorine” in the water !

15 Nitrate Compounds Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessedOtherwise Used 25,000 lbs 10,000 lbs Wastewater Treatment 50,004 lbs*0 lbs =300 MGD X 8.34 lb/gal X 20 mg/L YesNO *The pounds of nitrate for threshold determinations must be based on the weight of the nitrate compound NaNO 3, not the ion NO 3 -. Releases are reported using NO 3 -. (“Toxic Release Inventory Lists of Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance for Reporting” (May 1996, EPA)

16 Nitrate Compounds - Sludge Land application of wastewater sludge containing nitrate and ammonia is regarded as managed as waste even though it has nutrient value. Report as being disposed to land (onsite or offsite).

17 Methanol Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessedOtherwise Used 25,000 lbs 10,000 lbs 0 lbs30,000 lbs NO Yes*NO Processing Aid Anoxic Basin Food 0 lbs *Methanol may be completed consumed in the process resulting in zero releases (Sections ). It may be eligible for a Form A.

18 Sodium Nitrite Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessedOtherwise Used 25,000 lbs 10,000 lbs 65,000 lbs0 lbs NO Yes Food Ingredient 0 lbs *Primarily released to the wastewater.

19 Persistent Bioaccumulative Toxics (PBT)

20 Combustion Manufactured 313’s AP-42 NG 25,000 lb Threshold (Unless PBT) PACs

21 Combustion Manufactured 313’s AP-42

22 Combustion Manufactured 313’s Manufactured Lead = lb/10 6 ft 3 X 700 mmft 3 = 0.35 lbs Lead Annual NG Used

23 References “EPCRA 313 Reporting Guidelines for Food Processors” EPA September “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

24 EPA TRI Website

25 Example FAQ - Closed-Loop Refrigeration


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