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

 Facility Information  Emergency Contact  Reportable Chemicals  Quantity Stored  Chemical Hazards  Storage Locations (site map)  Liquid, Gas, Solid  EHS ?  CAS #  Submit MSDS’s

 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.

Lead Compounds 100 lbs Mercury Compounds 10 lbs Polycyclic aromatic compounds (PACs) 100 lbs

 AP-42  Stack Test  25,000 lb Threshold Unless PBT

 AP-42

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