Rocky Beem 2011 Smithfield Environmental Conference TRI Form R Reporting Rocky Beem 2011 Smithfield Environmental Conference

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

TRI Reporting Criteria

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

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

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

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

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

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)

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?

Chlorine Discussion NOT 313 Chemicals 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 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 !

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)

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).

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 8.1-8.7). It may be eligible for a Form A.

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.

Persistent Bioaccumulative Toxics (PBT)

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

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

EPA TRI Website http://www.epa.gov/tri/guide_docs/index.htm

Example FAQ - Closed-Loop Refrigeration