The Toxic Release Inventory (TRI) Jim Walsh Georgia Tech Economic Development Institute 404.210.5550...
-
Upload
candace-douglas -
Category
Documents
-
view
217 -
download
0
Transcript of The Toxic Release Inventory (TRI) Jim Walsh Georgia Tech Economic Development Institute 404.210.5550...
The Toxic Release Inventory(TRI)
Jim WalshGeorgia Tech Economic Development
Institute404.210.5550
November 2001
Presentation Outline
What is the TRI? Who must file reports for the TRI? Form R vs Form A Common TRI Reportables Estimating Releases Filing & Fees TRI Enforcement What’s New for 2001
The Bhopal Incident
December 3, 1984 pesticide plant (Sevin) massive release of
methyl isocyanate 3,800+ dead and
11,000 disabled worst industrial accident
in historyUnion Carbide India Limited
Bhopal
What is the TRI? provides public with information on routine &
accidental releases of certain toxic chemicals began in 1986 as Superfund re-authorization Congress prompted to act by Bhopal tragedy Section 313 of the Emergency Planning and
Community Right to Know Act (EPCRA)– a.k.a. Section 313 of Title III – Community Right
to Know, of the Superfund Amendments and Reauthorization Act (SARA Title III)
Who Must File TRI Reports?
Facility must meet three criteria in order to be required to submit reports:
• have 10 or more employees(part-time included at 2000 hours/employee)
• be included under SIC codes 20xx through 39xx(all Federal facilities are also included)
• manufacture, process, or otherwise use any listed toxic chemical in quantities greater than the established thresholds for a given year
The EPCRA Chemicals
EHSs(356)
Section 313TRI Chemicals
(App. 630)*CERCLA
Hazardous Substances(739)
228
792159
* Excluded Chemical Categoriesand chemicals subjective toAdministrative Stay
EPCRA Chemicals
The “Title III List of Lists” is the key to EPCRA and is available from:
– http://www.epa.gov/ceppo/pubs/title3.pdf
– EPA hotline at 1-800-535-0202 (hotline is operated by contractor; provides
“shield” from EPA inquiries)
Notable Chemical Exemptions
Certain common industrial chemicals are
presently exempt from TRI reporting: acetone sodium hydroxide ammonium sulfate sulfuric and hydrochloric acids (non-aerosol) isopropyl alcohol (unless from strong acid
manufacturing facility)
TRI Reporting Thresholds
The reporting threshold is tripped if your facility:
manufactures or processes….. more than 25,000 lbs of certain chemicals or compounds
OR
otherwise uses….. more than 10,000 lbs of certain chemicals or compounds
Determining Applicability
Is your facility SIC 20xx-39xx or aFederal facility?
Do you have 10 or morefull-time employees?
Do you manufacture, process,or otherwise use any listedchemical or chemical category?
Do you trip the thresholds?
Does Form R Section 8.1-8.7exceed 500 lbs?
Submit Form R
No report this year
No report this year
Do you manufacture, processor otherwise use more than1,000,000 lbs
Submit Form A
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No
Yes No
Form R vs Form A analogous to IRS Form 1040 vs Form 1040EZ
Form R must be used if the total amount in Sections 8.1 thru 8.7 exceeds 500 lbs
Form A can be used if the total amount in Sections 8.1 thru 8.7 is less than 500 lbs– unless more than one million lbs is manufactured,
processed, or otherwise used– PAC, PBT, mercury and mercury compounds
Form A Exclusion
Less than 500 lbs reported in Sections:8.1 – Quantity Released
8.2 – On- Site Energy Recovery
8.3 – Off-Site Energy Recovery
8.4 – On-Site Recycling
8.5 – Off-Site Recycling
8.6 – Treated On-Site
8.7 – Treated Off-Site
Manufacture
EPCRA defines “manufacture” as: to produce chemicals for
– sale– distribution– on-site use
coincidentally manufacture as a byproduct or impurity– deminimis exemption does not apply
or import
Process
EPCRA defines “process” as: distributed in commerce
– stays or is intended to stay with product used as a reactant used as a formulation component incorporated as an article component repackaged created as an impurity
Otherwise Use
EPCRA defines “otherwise use” as: does not stay with product used in chemical processing
– solvents used as a manufacturing aid
– refrigerant ancillary
– waste water treatment chemicals
Reporting ExemptionsFacility-Related Exemptions Laboratory
– manufactured, processed, or otherwise used in laboratory activities by technically qualified persons
Property Owner– own real estate with covered facility
Use-Related Exemptions used as a structural component of the facility used in janitorial or grounds maintenance work personal use by employees or other persons maintenance of facility motor vehicles contained in intake water or air
The Article Exemption Quantities of listed toxics contained in an article do
not have to be factored into threshold or release determinations:
an article is formed to a specific shape has an end-use dependent on shape does not release a TRI chemical or chemical
category under normal processing– less than 0.5 lbs of release per year
original shape still definable ingot melting, wire drawing, welding rods and wire,
and solder are NOT exempt
Machining of Articles
drilling, cutting, or other machining probably negates the article exemption
Releases via Machining
Many common engineering materials contain TRI reportables. For instance, stainless steels usually contain the following TRI chemicals:– manganese (Mn)– chromium (Cr)– nickel (Ni)– lead (Pb)– others MAY be deminimis exempt
Estimating Releases Estimating Releases and Waste Treatment
Efficiencies for the Toxic Chemical Release Inventory Form– EPA 560/4-88-002, Call NTIS at 703-605-6000
– Has SOCMI Factors, Cost $54.50, PB88210380
Compilation of Air Pollutant Emission Factors AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources– http://www.epa.gov/ttn/chief/ap42.html
Common Reportables:Painting Operations many solvents used in
painting, such as toluene, xylene, and methyl ethyl ketone are TRI reportables as otherwise used
solid paint that remains on product is processed
what you use is often what you lose
Painting Process Often Complex
SurfacePrep
Spray Applicationor
Electrodepostionof
Organic CoatingsCoated
Workpiece
Flash-OffZone
CuringZone
Organic Coating Chemicals and Chemical Compounds
Air EmissionsAir EmissionsAir Emissions
Workpiece
Cleaningand TreatmentChemicals
WastewaterSlurry
Container Residues
Wastewater
Slurry
Container Residues
Clean OutWastes fromOven and ProductCarrier
Painting Factors to Consider
surface preparation can result in substantial solvent and/or particulate releases (abrasive blasting)
transfer efficiency of different types of spray guns has tremendous impact on amount of overspray (conventional vs HVLP vs electrostatic)
booth filter efficiency plays a lesser role residue quantities in drums for different chemicals
and removal methods
Estimating Releases from Abrasive Surface Preparation Bag House Performance
– 95% efficient, 25 replacements/year, 5 bags/replacement, 50 lb weight gain/bag, dust 1.1% chromium, bags to landfill
Off-Site Disposal– 25 x 5 x 50 x 1.1% = 69 lbs
Air Emissions– 25 x 5 x 50 x (.05/.95) x 1.1% = 3.6 lbs
Common Reportables:Ammonia Refrigeration Systems
Anhydrous ammonia is otherwise used in a refrigeration system
If more than 10,000 lbs is added, TRI report must be filed– new system can trip
the threshold
Common Reportables:Chlorine for Water Treatment
chlorine is otherwise used in water and wastewater treatment
if more than 10,000 lbs is used, TRI report must be filed
chlorine in water is NOT released
only fugitive air emissions are reported
Common Reportables:Aqueous Ammonia & Nitrates Nitrate compounds and
aqueous ammonia are coincidentally manufactured as wastewater byproducts– threshold is 25,000 lbs
– concentrations are less than 10,000 mg/l
– deminimis exemption does not apply when manufactured as byproduct
Nitrification/Denitrification
Total Organic Nitrogen (TON) = TKN –NH3-N
Total Kjeldahl Nitrogen (TKN)
Anaerobic Treatment Ammonia Nitrogen (NH3-N)
Aerobic Treatment Nitrite Nitrogen (N02-N)
Oxidizing
Nitrate Nitrogen (NO3-N)
Anoxic Treatment (Shut Off Aerators)
Nitrogen (N2) Facultative Bacteria strip O from NO3
Common Reportables:Aqueous Ammonia aqueous ammonia is manufactured as a
byproduct by biological wastewater treatment systems which convert protein (TON) into ammonia nitrogen (NH3-N)
the highest concentration is immediately after an anaerobic treatment system
the data from laboratory analysis is reported as N and must be multiplied by 1.2
10% of the aqueous ammonia is used for threshold and release calculations
Common Reportables:Nitrate Compounds nitrate compounds are manufactured as a
byproduct by aerobic wastewater treatment systems which oxidize nitrogen compounds
deminimis does not apply the threshold is computed by assuming the
nitrate compound is NaNO3
if nitrate nitrogen (N03-N) is reported as N, the amount must be multiplied by 6.1
the release is only the amount of NO3 in the final effluent
Common Reportables:Mineral Acids and Bases no release if pH is 6 to 9 100% wastewater treatment efficiency typical chemicals excluded
– sulfuric acid– phosphoric acid
typical chemicals NOT excluded– acetic acid
Aerosol forms Sulfuric Acid
threshold– 25,000 lbs– manufactured as a by-product by
combustion of fuel oil and coal– deminimis does not apply– although natural gas contains trace
amounts of sulfur, it is not likely that an aerosol form of sulfuric acid will be manufactured
Mercury & Mercury Compounds
threshold is 10 lbs deminimis exemption does not apply Form A cannot be used fluorescent light tubes
– generally qualify for article exemption– can be crushed when no longer in use
Polycyclic Aromatic Compounds (PACs) 21 chemicals in PAC category
– benzo(a)anthracene– benzo(a)pyrene– dibenzo(a,l)pyrene
threshold is 100 lbs for all chemicals in PAC category
deminimis does not apply Form A cannot be used
Persistent Bioaccumulative Toxic (PBT) Chemicals chemical
– aldrin– methoxychlor– chlorodane– benzo(g,h,i) perylene– polychlorinated biphenyls
(PCBs)» Transformers may be
article exempt
– dioxin and dioxin Like Compounds – 17 total
deminimis does not apply Form A cannot be used
threshold– 100 lbs– 100– 10– 10– 10
– 0.1 gram
Combustion System Releases
PBTs– benzo(g,h,I)perylene– PCBs (used oil)– dioxin
PACs Mercury lead sulfuric acid other TRI chemicals
– otherwise used are subject to deminimis
– manufactured are not subject to deminimis
Natural Gas Thresholds
manufacture– benzo(g,h,i)perylene – 8.33 trillion SCF– PACs – 115.1 trillion SCF– benzene – 11.9 trillion SCF– formaldehyde – 333.33 trillion SCF– naphthalene – 40.98 trillion SCF
otherwise use– vanadium – 4.35 trillion SCF
No. 2 Fuel Oil Thresholds
manufacture– dioxin – 8.3 million gal– sulfuric acid – 20.4 million gal– mercury compounds – 3.6 million gal
otherwise use– PACs – 1.4 million gal– benzo(g,h,I)perylene – 28.6 million gal– vanadium – 952.4 million gal– mercury – 3.6 million gal
No. 6 Fuel Oil Thresholds manufacture
– PAC – 6.1 billion gal– benzo(g,h,I)perylene – 4.4 billion gal (two different factors)– dioxin – 8.3 million gal– sulfuric acid (5% sulfur) – 5.1 million gal– mercury compounds – 135.1 million gal– formaldehyde – 0.8 million gal
otherwise use– PAC – 5,079 gal– benzo(g,h,I)perylene – 47,170 gal– Vanadium – 17.1 million gal– mercury – 135.9 million gal
Coal Thresholds
manufacture– zinc compounds – 1,801 tons– all others greater than 19 thousand tons
otherwise use– zinc – 893 tons– all others greater than 20 thousand tons
How to File Form R/A must be sent to both EPA and state
environmental agency electronic filing is strongly encouraged;
Georgia EPD prefers this format ATRS 2000 software available free from:
http://www.epa.gov/tri/atrs/ reports are due July 1 for previous calendar
year, along with applicable fees
TRI Reporting Fees
less than 500 lbs of release $0 500-1,000 lbs of release $500 1,000-10,000 lbs of release $1,000 more than 10,000 lbs of release
$1,500 fees are for any one report due July 1
Filing for Previous Years if facility determines it should have been submitting
Form R or A in past years– submitting data for past 5 years is recommended– EPCRA provides for enforcement 5 years into past– EPA Region IV known to enforce 3 years back
penalties or fines vary per situation:– unofficial policy is to not levy fines as long as facility has
submitted reports voluntarily– fines are likely if EPA finds the discrepancy– $50,000 per chemical per year is typical (get legal help!)– fine reductions up to 90% are possible via Supplemental
Environmental Project (SEP) …. this is not an EMS!
Information Sources The TRI section of the U.S. EPA website
(http://www.epa.gov/tri) is a treasure trove of information on EPCRA and TRI:– general information– FAQs and guidance documents– reporting forms and instructions– TRI Explorer software for accessing TRI data (It is a good idea to review your posted facility data for
errors; transcription errors abound)http://www.epa.gov/enviro/index_java.htmlhttp://www.epa.gov/enviro/index_java.html
TRI Enforcement
a.k.a. “Beware of Your Grandparents” EPA/AARP agreement several enforcement actions in Georgia $50,000 fine per chemical per year typical
proposed penalty legal help may be necessary
New for 2001
transportation SICs may be added lead (Pb) threshold lowered to 100 lbs
for reporting year 2001– Exception for stainless, brass, and bronze– Lead acid batteries qualify for article
exemption coal ash used in cement is “processed”