Presentation on theme: "Rocky Beem 2011 Smithfield Environmental Training Conference."— Presentation transcript:
Rocky Beem 2011 Smithfield Environmental Training Conference
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 lbs Report to EPA and State
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) Any Exclusions? Personal Items Articles / Food Additves Storage Locations & Volumes 10,000 lbs500 lbs or TPQ (EHS) Review MSDS’s, Inventories, Invoices ALL ChemicalsMixtures Aggregate lbs
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
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
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 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
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 Separate Activity Thresholds
Activity Threshold Examples: ManufacturedProcessed Otherwise Used Exempt 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
Activity Threshold Examples: ManufacturedProcessed Otherwise Used 25,000 lbs 10,000 lbs Byproduct- Coincidentally Manufactured Ingredient Process Aid Treating Waste Wastewater Treatment: Nitrate Ammonia Natural Gas Combustion: Benzo (g,h,i) perylene Mercury Lead Sodium Nitrite Chlorine Ammonia Methanol
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
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 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 (Gas - Cl 2 ) Chlorine Dioxide (ClO 2 ) Sodium Hypochlorite (NaOCl) NOT a Sec 313 Chemical Same as “bleach” “Otherwise Used” 10,000 lbs Report Cl 2 and ClO 2 NaOCl Not reportable Can Cl 2 be manufactured from sodium hypochlorite?
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 City Water Use Employee Use Process Use Allocate Use Personal Use Exemption “Otherwise Used” Employee Use Process Use “Environment” Exemption
Activity Threshold Source Total lbs Threshold Exceeded Manufactured ProcessedOtherwise 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)
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 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.
Activity Threshold Source Total lbs Threshold Exceeded ManufacturedProcessed Otherwise Used 25,000 lbs 10,000 lbs 65,000 lbs0 lbs NO Yes Food Ingredient 0 lbs *Primarily released to the wastewater.
Manufactured Lead = lb/10 6 ft 3 X 700 mmft 3 = 0.35 lbs Lead Annual NG Used
“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
Combustion Manufactured 313’s Wastewater Manufactured 313’s Proper Activity Selection Review significant Year to Year Changes Start Early
When By July 1 What Form R for Each 313 Chemical Exceeding the Threshold Form A if environmental releases (Sec ) are <500 lbs How EPA Electronically TRI-MEweb