1. Rocky Beem 2011 Smithfield Environmental Conference
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:
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

7. 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:
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
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

9. Threshold Determination - Ammonia
Activity
Threshold
Source
Total lbs
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 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 - Cl2) Chlorine Dioxide (ClO2)
Sodium Hypochlorite (NaOCl)
NOT a Sec 313 Chemical
Same as “bleach”
“Otherwise Used”
Can Cl2 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 Employee Use Water Chlorination
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
NOTE: Likely no “chlorine” in the water !

15. Nitrate Compounds Activity Threshold Source Total lbs 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)

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. Processing Aid Anoxic Basin Food
Methanol
Activity
Threshold
Source
Total lbs
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 ). It may be eligible for a Form A.

18. Sodium Nitrite Activity Threshold Source Total lbs 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.

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/106 ft3 X 700 mmft3 = 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