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OASBO K-22 -

SECTION 313 REPORTING: ISSUE PAPER

Clarification and Guidance i for the

Metal Fabrication Industry

1 I GEpA. From Tha

Small Business I Ombudsman I

SMALL BUSINESS HOTLlNl lWO1368-5688

...

office of Toxic Substances U.S. Environmental Protection Agency

January 1990

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TABLE OF CONTENTS

I . Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

I1 . Standard Industrial Classification (SIC) Codes Applicable to . < Metal Fabrication . . . . . . . . . . . . . . . . . . . . . . . . . 3

I11 . Clarification of Section 313 Policy Issues o f Interest to the Metal Fabrication Industry . . . . . . . . . . . . . . . . . . 5

Compounds ,and Mixtures . . . . . . . . . . . . . . . . . . . . . . 5 Special Qualifier: "Fume or Dust" . . . . . . . . . . . . . . . . 6 Chemical Categories . . . . . . . . . . . . . . . . . . . . . . . . 7 De Minimis Exemption . . . . . . . . . . . . . . . . . . . . . . . 9 Article Exemption . . . . . . . . . . . . . . . . . . . . . . . . . 10 Reus and Recycle Exceptions . . . . . . . . . . . . . . . . . . . 11 Estimating Emissions from Metal Welding and Oxygen Cutting Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Estimating Emissions from Solvent Degreaaing Operations . . . . . . 17 Estimating Emissions from Chromium Electroplating Operations . . . 21

IV . Select Questions and Answers on Issues Faced by the Metal Fabrication Industry . . . . . . . . . . . . . . . . . . . . . . . 24

Determining Whether or Not to Report: Facility . . . . . . . . . . 24 Mixtures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 Supplier Notification . . . . . . . . . . . . . . . . . . . . . . . 26

27 Exemptlanr . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Relouem of the Chemical . . . . . . . . . . . . . . . . . . . . . 31

Determining Whether or Not to Report: Listed Chemicals . . . . . . 24

Activities and Uses of the Chemical a t the Facility . . . . . . . .

V . Bibliography of Reference Sources . . . . . . . . . . . . . . . . . 32

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I. INTRODUCTION

This Issue Paper has been prepared to assist establishments in the metal fabricating industry to comply with the reporting requirements of section 313 of the Emergency Planning and Community Right-to-Know Act (Title I11 of the Superfund Amendments and Reauthorization Act of 1986, Public Law 99-499). Under section 313, facilities that meet all three of the following criteria are required to report releases to the air, water, and land as well as transfers of wastes containing any listed toxic chemical to off-site locations:

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0 The facility is included in Standard Industrial

The facility has 10 or more full-time employees;

Classification (SIC) codes 20 through 39 (thus including all metal fabricating establishments grouped under SIC cod. 34); and

The facility manufactured (defined to include imported), processed, or otherwise used in the course of a calendar year any listed chemical in quantities greater than the s e t threshold. listed toxic chemical or chemical category are 25,000 pounds.

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The thresholds for manufacturing or processing a

The otherwise use threshold is 10,000 pounds.

This document includes a clarification of threshold determinations and reporting requirements for metal fabricators which describes, in detail, the more complex issues involved in section 313 reporting. have been selected from the €PA document, Toxic Chepfcal Re- In ventory Ouestions and &lsweu (EPA 56&/4-90-003), t o address reporting issuer and problems typically encountered by metal fabricators. Finally, this document contains a list of reference materials and documents that may be of use in obtaining emission factors and other information to develop release estimates.

Questions and answers

The following statemonto represent clarifications of threshold determination8 and roportfng requirements associated with processing and use of covered toxic choricals by matal fabricators (for a more thorough explanation of theso clarifications, see Section 111 of this document):

0 m k l alloy8 are solid mixtures. Any alloy containing a l is ted toxic chemical above the de minimis concentration must be evaluated for threshold determinations and release calculations.

0 notal warticlern are exempt from threshold determinations if, during normal processing or otherwise use activities, no toxic chemical is released. Neither the disposal of solid wastes th8t are recognizable as the processed article nor the recycle of wastes constitute releases that would negate the article status of the metal item.

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o Welding metal par t s ( e . g . . welding of s t e e l plates) requires the f a c i l i t y t o determine whether releases occur from the metal items being joined, as w e l l as the toxic chemical components of the welding rods. no releases occur from the joined metal par t s themselves, then only the toxic chemical(s) contained in the welding rods a re subject to threshold and release determinations.

I f

Fume or dust is the qualifier for three l i s t e d toxic chemicals (aluminum, vanadium, and zinc) . Threshold determiMtions a re based on the amount of the chemical manufactured, processed, or otherwise used only as a fume o r dust. Zinc compounds, d i s t i nc t from zinc (fume o r dus t ) , a re reportable as members of the zinc compound category. Zinc compounds released i n .4

par t icu la te form are not considared zinc (fume o r dust) .

While the information contained in t h i s document is tha most up-to-date guidance available from EPA, no new policy information is contained here tha t is not represented i n other EPA documents.

If you have spec i f ic circumstances or situations for which you need additional EPA guidance, contact your Regional ooctfon 313 coordinator o r call the Emergency Planning and Community Right-to-Know Information Hotline a t 1- 800-535-0202, or i n Washington, D . C . and Alaska 202-479-2449.

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11. STWARD INDUSTRUL CLASSIFICATION (SIC) CODES OF "L FABRICATION

In general, metal fabricators are classified in the Standard Industrial Classification (SIC) codes of Major Group 34, which includes "Fabricated Metal Products, Except Machinery and Transportation Equipment." listing of SIC codes within this group is provided on the next few pages.

The complete

Multiple SIC codes may apply to facilities which perform several types of manufacturing operations. of establishments, consult the Standard Ind ustrial Classificati on Man ual , (PB 87-100012) published by the Executive Office of Management and Budget. manual is available for purchase from: National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703-487-4650).

For further information about the classification

The

Major Group 31. Fabricated Metal Products, Except Machinery and Transportation Equipment

This major group includes establishments engaged in fabricating ferrous and nonferrous metal products, such as metal cans, tlnwara, handtools, cutlery, general hardware, nonelectric heating apparatw, fabricated structural metal products, metal forgings, metal stampings, ordnance (except vehicles and guided missiles), and a variety of metal and wire products, not elsewhere classified.

[Note that: Certain important segments of the metal fabricating industries are classified in other major groups of the SIC code system. include: machinery in Major Groups 35 and 36; transportation equipment, including tanka, in Major Group 37; professioml scientific and controlling instnunenti, watcher, and clocks in Major Group 38; and jewelry and silverware in Major Group 39. nonferrous metals and their alloys are classified in U j o r Group 33.1

These

Establishments primarily engaged in producing ferrous and _<

341 METAL CANS AND SHIPPING CONTAINERS

3411 Metal Cans 3412 Metal Shipping Barrels, Drums, Kegs, and Pails '

3421 Cutlery 3423 Hurd and Edge Tools, Except Machine Tools and Hardware 3425 Saw Blades and Handsaws 3429 Hardware, Not Elsewhere Classified

343 HEATING EQUIPMENT, EXCEPT ELECTRIC AND UARW AIR; AND PLUHBINC FIXTURES

3431 Enameled Iron and Metal Sanitary Ware 3432 3433 Heating Equipment, Except Electric and Warm Air Furnaces

Plumbing Fixture Fittings and Trim

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344 FABRICATED STRUCTURAL METAL PRODUCTS

3441 Fabricated Structural Metal 3412 Mota1 Doors, Sash, Frames, Molding, and Trim 3443 3444 Sheet Metal Work 3446 3448 3449 Miscellaneous Structural Metal Work

Fabricated Plate Work (Boiler Shops)

Architectural and Ornamental Metal Work Prefabricated Metal Buildings and Components

345 SCREW MACHINE PRODUCTS, AND BOLTS, NUTS, SCREWS, RIVETS, AND WASHERS

.- 3451 Screw Machine Products 3452 Bolts, Nuts, Screws, Rivets, and Washers

346 METAL FORGINGS AND STAMPINGS

3462 Iron and Steel Forgings 3463 Nonferrous Forgings 3465 Automotive Stampings 3466 Crowns and Closures 3469 Metal Stampings, Not Elsewhere Classified

347 COATING, ENCRAVING, AND ALLIED SERVICES

3471 Electroplating, Plating, Polishing, Anodizing, and Coloring 3479 Coating, Engraving, and Allied Semices, Not Elsewhere Classified

348 OaNANCE AND ACCESSORIES ,- EXCEPT VEHICLES AND GUIDED MISSILES

3482 Small Arms Ammunition 3483 Ammunition, Except for Small Arms 3484 Small Arms 3489 Ordnance and Accessories, Not Elsewhero Classified

349 MISCELUSXOUS FABRICATED METAL PRODUCTS

3491 3492 3493 3494 3495 3496 3497 3490 3499

Inchstrial Valves Fluid Power Valves and Hose Fittings Steel Springs, Except Wire Valves and Pipe Fittings, Not Elsewhere Classified Wire Springs Miscellaneous Fabricated Wire Products Hetal Foil and Leaf Fabricated Pipe and Pipe Fittings Fabricated Metal Products, Not: Elsewhero Classified

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111. CLARIFICATION OF SECTION 313 POLICY ISSUES OF INTEREST TO THE HETAL FABRICATION INDUSTRY

This section of the issue paper provides in-depth descriptions of some of the more complex issues involved in section 313 reporting for the metal fabrication industry.

For some issues, such as de minimis and article exemptions, multiple factors become involved in determining threshold and release information. These issues have generated many inquiries and requests for clarification from facilities, particularly metal fabricators. understand these complex issues, comprehensive written interpretations are provided.

To help facilities better

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comms AND "S

A "compound" is any combination of two or more chemicals that is the result (in whole or in part) of a chemical reaction. In the formation of a compound, the reactant chemicals loose their individual chemical identities.

A "mixture" is any combination of two or more chemicals, if the combination is m, in whole or in part, the result of a chemical reaction. In a mixture, the individual components retain their fdentities. Mixtures includd any combination of a chemical and associated impurities.

Metal 8110p aro so l id mlxturer because tho individual motals in the alloy retain their chemic81 identity. toxic chemical at or above the da minimis concentration is subject to threshold determinations. Release of the mixture is considered a release of the toxic chemical(s) contained in the mixture. The quantity of metal released can be 08tl~tod based on the percent by weight of each toxic chemical in tha nixturo.

Any ouch mixture containing a listed

3 . b. C w r e d for Sect- 313 R e n o r t u

Threshold and release determinations for section 313 reporting must include the amount of the listed toxic chemical present above the de minimis concentration in all mixtures processed o r otheratis8 used by tho facility unless othewise exempted. at or above the de minimis concentration, only the amount of tho toxic chemical, and not the mixture itself, is subject to threshold and release determinations,

If a listed toxic chemical is present in a mixture

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The distinction between a compound and mixture is important because it affects tho w u n t of the metal which is considered in making threshold determinations and release CalCUhtiOnS. alloy ( i . e . , solid mixture), only the weight of the listed metal is subject to threshold determinations and release calculations. present in the fonn of a listed metal compound (e.g., zinc oxide), the entire weight of the metal compound is subject to threshold determinations for the applicable metal compound category ( e . g . , zinc compounds), however, release determinations would be calculated for the parent metal only (e.g., pounds of zinc).

If a listed metal is present in an

If a listed metal is

4. NOtificAtiOn and Concentr ation Ranger PfavLde InforrP.tion f 0.r;

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bRQz€ iu

The section 313 supplier notification requirements are designed to provide chemical users with information on the identities and concentrations of listed toxic chemicals present in the mixtures that thay use. There can still be situations, however, when a facility may not have this information for a mixtura. but no concentration information is provided by tho supplior, then the facility does not have to consider the chemical present in tho mixture for purposes of threshold and release detenninations. Howevor, if a facility owner/operator only knows the lower bound concontration o f a toxic chemical present in a mixture, the owner/operator should base tho throshold determination on that lover bound concentration number. I f only a range of concentrations is available for a toxic chemical proront in a mixture, the owner/operator should use an average of the low and high concentrations numbers for threshold determinations.

If a facility knows that a mixture contains a toxic chemical,

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SPECXU Q U U B I t B : wF"HE OR DUST"

Three listed toxic chemicals (aluminum, vanadium, and zinc) have the qualifier, "fume or dust". When these chemicals are manufactured, prbceosed, or otherwise used, including as part of an alloy, a different approach is used to make threshold &terminations. Only the amount of theso chooicals that are manufactured, procoraed, or otherwise used as a fum or dust is subject to threshold &tominatioru. Manufacturing, processing, or otherwise using these chemicals in any other form is not reportable under section 313. compounds, dimtinct from zinc (fume or dust), are reportable as members of the zinc c o m category. In most cases, only the generation of a fume or dust (i.e., "facturin8) would be a reportable activity, because there are fev processing or otherwise use activities that utilize those chemicals in a fume or dust form.

Zinc

To make threshold determinations for theso chemicals, the mount of fume or dust generated for each chemical, including chemicals contained in an alloy mixture, are totalled. Because the chemical is being manufactured into a dust or fume, the manufacturing threshold o f 25,000 pounds is applied and the de minimis exemption does not apply.

I ' For example, a f a c i l i t y manufactures metal posts and uses over 150,000

pounds of sol id aluminum slabs Over the reporting year. of the alurninun s labs into posts, 11,000 pounds of fumes and dust are generated from the cut t ing, grinding, and polishing of the aluminum which is e i ther released a s fugitive emissions o r is disposed i n an o f f - s i t e landf i l l . For threshold determinations, only the 11,000 pounds of aluminum generated in the form of fume and dust would be applied to the 25 ,000 pound manufacturing threshold. no t exceeded and a Fom R is not required for t h i s toxic chemical.

During the processing

Therefore, the threshold for aluminum i n a fume o r dust form is

CHEMICAL CATEGORIES

1. a L i s ted Chaacal Catenom ara tad for Thr esholQ . c,

Toxic chemical categories l i s t e d under section 313 require a different approach when making threshold and release determinations. t ha t is included i n a l i s t e d metal compound category, the t o t a l weight of that chemical compound, not j u s t the parent metal, is used in making threshold determinations., A f a c i l i t y w i l l need t o calculate the t o t a l weight of all compounds tha t are in the category, sup the amounts involved throughout the f a c i l i t y in each threshold ac t iv i ty , and compare the to t a l s t o the applicable thresholds.

For a chemical

For example, 30,000 pounds of nickel chloride are used i n a plating bath during the reporting year. is incorporated on s t e e l p la tes , while the chlorida remains i n the plating bath. f a c i l i t y io processing nickel chloride, which fs a metal compound within the nickel compound category. The t o t a l w e i g h t of the nickel chloride processed during the reporting year is considered f o r thrashold &terminations. Therefore, the f a c i l i t y mus tmbo i t a Form R for the nickel compound category and must report a l l releases from nickel compounds in terms of the parent metal, nickel.

The nickel, which is 40 percent of the compound,

Even though only the nickel i o incorporated on the steel plates , the

A compound i n a l i s t a d chemical category which is present in a mixture below the de minimis concentration, based OIL tho t o t a l weight of the coatpound in the mixtura, is exompt from threshold and reloase calculations under section 313. Again, a l l individual members of a chemical category must be to t a l l ed to dotemino if the chemical category has m e t o r exceeded the de minimis concontration i n a mixture.

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The section 313 l i s t contains some l i s t e d substances tha t are also members of a l i s t e d chemical category. specif ical ly l i s t e d toxic chemical are calculated separately from the threshold determinations for the chemical category. Brown 95 (CAS number 16071-86-61, a copper-based pigment, which is specif ical ly l i s t e d on the section 313 l i s t , is also a member of the copper compound category. threshold determination for C . I . Direct Brown 95 and a separate threshold determination fo r a l l other copper compounds tha t meet the c r i t e r i a for that metal compound category which are not specif ical ly l i s t e d under section 313.

Threshold determinations for a

For example, C . I . Direct

Because it i s specif ical ly l i s t e d , a f a c i l i t y must make a

./ Threshold determinations are calculated separately fo r a specifically

l i s t e d metal and compounds that a re members of the associated metal compound category. the Listed metal) t o form 15,000 pounds of lead oxido (manufacturing the l isted compound category). these cheaic8ls and these a c t i v i t i e s , and, therefore, the 25,000 pound thresholds f o r processing or manufacturing would not bo exceedod for e i ther the lead or the lead compounds.

For example, a f a c i l i t y converts 12,000 pounds of lead (processing

Separate threshold &termination8 are made for

3 . u l a t r R a l ( ~ o r Urod on Parant &$a1 ?or b t a l C m Cat-

Once a reporting threshold is met f o r a metal compound catagory, releases of compounds are calculated based on the pound. of tho p u e n t mota1 released, ra ther than the t o t a l weight of the compound. EPA adopted this approach because it is d i f f i c u l t t o calculate releases of potent ia l ly numorous compounds w-in a motal compound category, and because there are often methods and data fo r monitorir?g the parent motal but not the compound(s).

4. tlorul Form B -Ion f o r PCfant Matal U i a t L L g Metal C o w C a t e m

If both the parent mota1 and the PSSOCiated mom1 compound category exceed their rerpoctlva thr08hOlds, one sect ion 313 reporting Form R may be f i l e d , which cuvors all releases of the parent natal from activities involving both tho parant -tal and the metal compound catagory. This approach of reporting r o l w o a on a single Form R may be easiar fo r f a c i l i t i a s whore operatiom irnolvo conversions between the l i s t e d notal and meaberr of a l i s t e d motal compound category. pounds of lead and othervise uses 13,000 pounds of lead oxide, tha f a c i l i t y could submit one Form R fo r lead and lead compounds. f a c i l i t y would report on a l l a c t i v i t i e s involving lead and lead compounds and a l l releases of the parent metal, lead. This option, preferred by EPA, is available to f a c i l i t i e s , although separate reports may be f i l e d if desired.

For example, i f a f a c i l i t y processor 30,000

On t h i s Form R, the

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DE 24INmIS EXEMPTION

The de ninlmis exemption allows facilities to discount certain mini" concentrations of listed toxic chemicals in mixtures they process or otherwise use in threshold and release determinations for section 313 reporting. This de minimis level is 0.1 percent by weight for OSHA defined carcinogens and 1 percent by weight for a l l other section 313 listed toxic chemicals. minimis levels for chemical categories apply to the total concentration of all chemicals in the category within a mixture, not the concentration of each individual category member within the mixture.

De

or Use of a Mixture .r

1.

If a listed toxic chemical is present in a mixture at a concentration below the de minimis level, this amount of the toxic chemical is not subject to threshold determination, release reporting, or supplier notification requirements.

For processes where the chemical concentration fluenutas above and below the de minimis level, the de minimis exemption applies to tha process stages where the de minimis level is not exceeded. This application is further described in the general section of the Toxic Chemical Rel8~re Inventory Reporting Form R and Instructions document (EPA 560/4-90-007).

2 .

The de minimis exemption doer not apply to manufacture of a toxic chemical. One exception applies to the toxic chemical which is created (manufactured) as an impurity and remains in tha product distributed in commerce at below the de minimh levels; tha amount remaining in the product is exempt from threshold determinations. separated from the product (e .g . , ends up in a wutestrem) is subject to threshold and release determinations regardless of the concentration in the wastestream.

However, any amount that is

Example of Coincidental Manufacture as a Wart. Byproduct:

A n811 amount of aluminum fumes is manufactured as a reaction byproduct during an arc welding process. collactod u a waate and disposed on site. is a listad toxic chemical under section 313. The amount of aluminum fumes generated and removed as waste must be included in threshold and release determinations, even i f the aluminum fumes were present below the de minimis level in the process stream where it was manufactured or in the wastestream to which it was separated.

The aluminum fumes are Aluminum (fume or dust)

The de minimis exemption also does not apply to situations where the manufactured chemical is released or transferred t o waste s t r e w and thereby diluted to below the de minimis level.

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If the toxic chemical in a product (mixture or trade name product) is present belov the de minimis level for that toxic chemical, supplier notification is not required for that chemical in the mixture.

Listed toxic chemicals contained in articles that are processed or otherwise used are exempt from threshold determinations. article is not exempt. must meet all of the following three criteria in the section 31-2 article definition; that is, the €tam must be one:

Manufacturing an For a material to be exempt as an article, an item

i) Which is formed to a specific shape or design during manuf acture ;

ii) Which has end use functions dependent in whole or in part Upon its shape or design during end us.; urd

iii) Which doer not release a toxic chemical undar the normal conditiona of processing or otherwiso us0 of tho item at tho facility.

If, as a result of processing or otherwiso w e , an item retaina its ' initial thicknesr or dl-tor, in wholo or in part, then it moots tho first

part of the definition. totally altered during procossing o r otherwise use, @IO itom would not meet the first paft of tho definition. An exanplo of items that do not meet the dofinitson would bo item whic_h-are cold extrudod, such as lead ingots formed into wire or rods.

If the item's basic dimensional characteristics are

However, cutting a manufactured item into piecos which are recognizable as the article &os not chmgo the original exemption as long as tho diameter and the thickness of tho item remain the samo and no releaso of the toxic chemical occurs. For exmple, metal wire may bo bent or cut into smaller pieces and shoot mota1 may bo cut, punched, r t q o d , or ptesred without losing the articla s t a t u AS long as there is no chango in tha diamater of the wire or the thlchwsm of tho shoot metal.

An important upoct of the article exemption is tho criteria for what constitutos 8 roleaso of a toxic chemical. article that results in ganrration of a waste containing tho chemic81 is considered a releaso which negates the exemption. Cutting, grinding, melting, or other processing of a manufactured item could result in a release of a toxic chemical during normal conditions of use and, therefore, negate the item's exemption as an article.

Any procossing or us0 of an

A facility which recoives an article for further processing that incorporates a toxic chemical into the article m ~ y retain the exemption f o r the article. However, the toxic chemical incorpor8ted into the article will not be exempt. For example, a facility chat receiver steel bolts (articles)

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and plates them with chromium (processing). an article, hovever, the use of chromium does not meet the definition of an article and, therefore, is subject to threshold and release determinations.

The bolts retain the exemption as

HowevOr, there are two circumstances for which releases may not negate the exemption of the item as an article:

e If the resulting waste containing a listed toxic chemical is 100 percent recycled or reused, on-site or off-site, then the article exempt status is maintained. For section 313 purposes, wastes containing toxic chemicals are not reportable on Form R if the toxic chemical(s) in the waste is reused or recycled, on-site or off-site.

e 'If the processing or othewisa use of all similar m26nufacturad items results in a total release of less than 0.5 pound of a toxic chemical to any environmental media in a calendar year, EPA will allow this release quantity to ba roundad to zero and the manufactured item remain exempt as artlclos. Facilities should round off and report all estimates to the nearest whole numbor. The 0.5 pound limit doer not apply to each individual article, but applies to tha sup of all releasor of a toxic chemical from the processing or othorviro -0 of all like articles.

BEUSE m RECYCLE PC12PTIO108

Reuse or recycling of a listed toxic chemical can impact threshold determinatioru, articlo exemption statu, reporting of off -site transfers, and supplia notification. A -

Qucmtltios of a toxic chemical that aro prosent in an on-sit. recycle/rousa oparatim at the beginning of tho reporting year aro not counted toward a thro.hold &trrminatioh for that reporting year. This exemption prevents tho facility from counting the samo amount of a toxic chemical every time it cyclu throyh tho on-site operation. However, tho amount of a toxic chemical that is novly 8dded to a process system during tho reporting year is counted in tho threshold datermination.

For example, a facility purchases 21,600 pounds of copper sheets for its decorative mail box manufacturing operation. As part of this operation, all the coppor sheotr are cut, grinded and polished, negating the copper sheets' exemption as an article. In addition, the facility procosses 500 pounds of copper ingots into wire which the facility sells to an eloctronics firm. Hovever, this 500 pounds of copper ingots was obtained by on-sit. reuse of scrap copper genorated in the form of shavings and dust from the decorative mail box manufacturing operation. The scrap copper was molted and reformed

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into ingots and the facility cold extruded the ingots into the copper wire. Despite tho reuse of the copper, only 24,600 pounds of copper would be applied to the procraring threshold determination. exceed tho processing threshold for copper.

Therefore, the facility does not

A 2. e e 0 d

An important aspect of the article exemption is the criteria for what constitutes a release of a toxic chemical. Any processing or otherwise use of an article that results in generation of a waste containing the toxic chemical can be considered a release which negates the article exemption. Cutting, grinding, melting, or other processing or use of a manufactured item could result i n a release of a toxic chemical during normal conditions of use, and therefore, could negate the exemption as an article. However,.lf the resulting waste containing a listed toxic chemical is 100 percent recycled or reused, on-site or off-site, then the article status is maintained and no section 313 reporting would be required for that toxic chemical. containing toxic chemicals are not reportable under section 313 if the toxic chemical contained in the waste is reused or recycled, on-sit. or off-site.

Wastes

If a toxic chemical is sent off-site for purpose8 of reus. or recycling, the location and amount of the chemical do not have to be reported on Form R as an off-site transfer. EPA requires the idontification of all other toxic chemicals in wastes which are transferred off-site for final disposal. Off- site reus. or recycling activities, however, are more closely related to facility products distributed in commerce.

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4. far WotigiElfian hpoIies t o C h a u l r Sent Off-Sit. f.or Reuse OK hxs.aut

while the off -s f to location to which a toxic chomical is sent for reuse or recycling does not havo to be reported on Form B, supplier notification is still requirod to ba provided to the off-site location, if the location is a manufacturing facility i n SIC codes 20-39 or a facility that distributes to facilities la SIC cod.. 20-39.

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ESTRUTINC mSSfONS FROM METAL WELDING AND OFICE8 CDTTXNG OPERATIONS

Metal fabrication facilities that conduct welding operations vi11 need to estimate emissions that occur from these operations. determination, the facility uses the total weight of the metal being processed not just the immediate area being cut. determine if emissions are occurring from tho metals being welded, in addition to emissions from the welding rods used in the welding process. Releases of listed toxic chemicals and chemical categories must be estimated f o r welding operations both to develop fugitive air release data and t o identify whether the releases from the base material exceed 0.5 poundr per year and therefore negate the article status of the material walded.

When making a threshold

First, the facility will need to

The materials contained in the welding rod or electrode will make up much of the release from welding activities. cutting of metals will produce emissions primarily from tho baa& material ( i . e . , the material being welded). estimates is, therafore, strongly dependent on the type of operation performed.

Howover, oxyacetylene and oxynethane

The method for dovoloping emission

b t a l Weldirrp Re-

The amount ‘of each section 313 listed metals roleasod from welding rods may be estimated as followm:

re lruo nuber of niat 02 the rad that U i S S i a E fmtoi comveraim faator of l i a t d - roda u a d I i r conatmod or d o p o r i t d x x ( I t o n 1 mota1 d u r i q y e u (-1 ( Lba of ) zoo0 lbr

Emission factors for section 313 listed motals applicablo t o several (Lb./7.U) ( rod./7eu: ) rod ua.d toor motorial dmpositd

types and classes of electrodes are provided in the tablor that follow. These data represent averago fume generation rater and percent mota1 in the fume taken from Tables 2.2 and 2.18 from W B E m r i r o a (see biblioghphy) . d -

If the electrodes your facility uses are not listod, you may use emission factors for a similar electrode and adjust tho calculated roleam values based on the composition of tho eloctrodes you use.

Electrode composition information for dovelopnent of welding release estimates cub often ba obtained from Material Safety Data Sheet8, manufacturor’8 rp~cif~cations, and American Welding Society (AWS) Electrode Specificationm. composition of tho veld deposit is provided for many covered or flux cored electrodes:

Flux composition is often considored propriotary so only the

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Shielded Metal Arc Covered Electrodes (5/32”) Carbon and Lov Alloy Steal

Electrode class

E6010 E6013 E7018 E7024 E8018 C3

El e c t 1: ode class E316-15 E316-16 E410- 16 ENi-CI mi-cu2

Amrage fume % 313 metal lbs 313 metal released per

35.9 3.2 2.3 20. 4.9 2.0 21.1 4.1 1.8 10.0 6.2 1.2 16.9 7.2 1.2

Shielded nota l Arc Covered Elactrodor (5/32”) Stainless Steel and High Ul07

./

Average fume % 313 metal lbs 313 metal released per generation S t-d

9.6 7 . 7 1.1 5.8 1.5 0.2 1.1 1.2 9.2 8.8 1.5 6.5 1.6 0.3

12.9 5.2 cO.1 1.3 <0.02 12.9 0.3 6.9 < O . l 0.1 1.8 ~ 0 . 0 2 10.1 2.1 4.2 6.2 0.4 0.8 1.2

0.8 0.1 1.1 Inconel 625 9.2 4.6 0.7 5.9 Haynes C-276 14.2 0.3 1.1 2.5 0.1 0.3 0.7 Hahes 25

Electrode class E70T-1 E70T-4 E70T - 5

Electrode class E316LT- 3

8.9 4.6 1.8 6.9 0.8 0.3 1.2

Flux Cored El8Ctrod.S (3/32*) Carbon and Iar All- Stool

qverage fume % 313 metal l b s 313 meal released per generation in &mas tn m e w w d

U t e - alkn+ 1-1 1-1 12.1 9.2 2.2 13.3 3.9 <O.Ol 0.8 21.0 11.1 4.7

F l u x Cored Eloctrodr8 (3/32’) Stainless Stool

% 313 metal lbs 313 metal released per in t-d

Amrage fuma gonoration

9.6 7.3 1.1 12.5 1.4 0.2 2.4

* g/kg - grams of fume per kilogram of t o t a l deposited metal.

- 1 5 -

Cas Metal Arc Solid Electrodes ( 0 . 0 4 5 " ) Carbon Steel

Average fume % 313 metal

class E70S - 3 5.1 E70S - 5 4.0 5.8

0.1 1.8 0.5 0.1

Car Metal Arc Solid Electrodes (0.045n) (0.035" for Haper C-276) Stainless Steel and High Alloy

Average fume % 313 metal lbs 313 metal released per a1 &Dosited

ERNicu- 7 2.0 1.1 22.1 44.4 ~0.01 0.04 0 . 9 1.8 Inconel 625 0.9 27.2 0.7 15.4 0.5 0.01 0.3 Haynes 25 1.4 15.4 7.1 14.9 0.4 0 . 2 0.4 1.2 Haynes C-276 7.0 1 . 0 32.5 0 . 1 4 . 6 8 . 2

i Cas Mota1 Arc Solid Elactrodor (3/64")

Aluminum

Averago fume generrtlon % altuninun lbr alumimm released per Electrode

class EX4043 L

9.9 72.3 38.0 54.9 ' ER5356

5 Car notal Arc Solid Elactrodor (Q.045n) - - Coppor

Average fume Electrode generation % copper lbr coppar released per

ERCU - U t e . nflrn * kuas.a -

4 .9 6 6 . 0 6 . 5 8.1 70 .5 11.4 -A2

* g/kg - grama of fume per kilogram of total deposited metal.

-16-

-n C ut- Releases

The following release rates are based on information contained i n Fumes

calculated based on the percent metal i n the fume and a fume generation rate of 2.1 grama par meter for oxyacetylene cut t ing and 0.037 grams per inch for oxymethane cutt ing. section 313 chemical present i n the metal. presented below.

W En vironment, (see bibliography). The valuer shown are

Releases are affected by the percent o f the l i s t ed The values for carbon s t ee l are

Release rates for oxyacetylene cut t ing were found t o increase and decrease proportionally with changing p la te thickness (e.g., cutting a 2 inch plate would r e su l t In mica the release ra te shown i n the table below). of release for oxymethana cut t ing a m independent and not affected by plate thickness. .4

Rates

Listed Sect ion

2 l u a a . L

Ba Mn C r N i A 1 v cu Zn co - .

Percent Fetal

. i R u m 0.01 0.3 0 . 2 0.05 0 .02

co. 01 0.1 co.1

* 0.02

Oxyacetylene Cutting of Carbon Steel

lbs 313 matal emitted per million f e e t of

alate (1" thick)

0.14 4.2 2.8 0.7 0.3

<O .14 1.4

4 . 4 0.3

Oxymethrne Cutting of Carbon Steel

lb r 313 metal emitted par million fee t of

n l a t e (1" thick)

0.1 2.9 2.0 0 . 5 0 .2 co.1 1.0 4.0

0 . 2

Total annual releaser of each of the l i s t a d saction 313 chemicals i n the plate would be found by multiplying tha emission factor by the total amount of cut plate (in million feet/year).

I ' - 1 7 -

ESTIXATINC EnISSIONS FOR SOLVENT DEGREASINC OPERATIONS

Many facilities use organic solvants to remove grease, oil, loose metal In the process of chips, and dirt from metal Products, equipment, and tools.

degreasing, organic solvents may be intermixed with air, heated to boiling, or agitated which will cause the solvent to volatilize. used in degreasing are listed under section 313 (e.g., methyl chloride, perchloroethylene, trichloroethylene, methyl chlorofom, trichlorotrifluoroethane). containing a toxic chemical must estimate emissions if the reporting threshold for otherwise use (10,000 pounds per calendar year) has been exceeded for that chemical.

Many organic solvents

Facilities that use an organic solvent degreaser

Emission estimates may be calculated from the following information:

e Emission factors to translate activity informrtion.into fugitive emission estimates;

e Facility activity rate or volume information (e.g., amount of product produced, fuel used); and

e Efficiency information on emission control devicas to allow estinktion of net releases to the air after emissions pass through control devices.

The basic fugitive emission estimation formula is:

E - R x EF x (1 - C / l O O ) , where E is the emission estimate for the source, R is the facility activity rat. or volume, EF is the emission factor, and C is the control devices efficiency . The talqle on the following pages has beon excerpted from TQFic &

ons -torr - A C o u t i o n For Selected Air Toxic Comnoundg &3 S o u (EPA-450/2-88-006a), and contains information on the following section 313 substances: trichlorotrifluoroethane, trichloroethylene, methyl chloride, perchloroethylene, and methyl chloroform. For each type of degreasing operation, the table provides a brief description of the specific solvent degreasing procesr and the relevant Standard Industrial Code (SIC Code) if available, the emission source and appropriato Sourco Category Code (SCC) , the chomical NP. and CAS number of the emitted pollutant, the estimated omismion factor, and relevant notes. These emission factors should only be u.6 if no sito-specific or otherwise more accurate data is available to the facflfty.

Pollutant emission factors are provided in terms of mass of pollutant per mass of product produced, generally kilogram per kilogram (kg/kg), and were derived from a variety of methods, such as source tests, theoretical calculations, or a combination of the two; so that there is considerable variation in the quality of the emission factors presented. These estimates are further clarified by tho identification of emission reduction techniques or controls in place within the degreasing operation used t o develop these emission factors. assumed pollution reduction techniques.

The notes column provides details on methodology and

-18-

Dearaas I cia oper at I ons usln& r*:

Cold cloonora

Cold claurara

40100204 btbylono

4010'0104 W.tbylono

obloc id.

oblorid.

40100224 W.thyl.ao

40100224 btbyluro

cblorido

oblorido

40100302 Wthylona cblor ido

7530 Corburato~ cloubor~ 40100302 Motbylono

7530 Cukuator c l o m u r 40100302 MothyL.ao

chLorido

ohlorid.

b R vapor 40100203 Porobloro- d y r o u u s ot.hyLao

doorouua .*Lam U R Vapor 40100203 Porchloro-

Convayor1a.d vapor 40100223 PotcbLoro- d y r o u o r otrlylrru

CMv0yorix.d vapor 40100223 Parohloro- d y r o u o r otbyla.

Cold clo.aoro 40100304 Porcbloro- 0thyl.a.

Cold cloonora 40100304 Pecchloro- athylona

75092

' 75092

*

75092

75092

75092

75092

75092

7 5092

127184

127184

117184

127184

127184

127 184

0.94 k& a i t . / k & frosb (vlr&la) IC u a d

0.87 ks u l t . / k s frosh (vir&ln) tC usod

0.93 kg/k& of fresh (vir&in) PCE uood

0.89 k&/k& of froah (virsio) DCE u0.d

0.91 kr/k& of fronh (viri ln) DCE uaod

0.78 kr/k& of fresh (virgln) PCE uaod

0.74 k~/L;8 of freah (v lr6ln) PCE usod

I

Uncontrollod, coculdors rOcYCl0, ~ U r 1 . 1 balonce

Controlld by rofrl&orsted froaboord cb8llOr, conmldero rOcyG~0. matorial balance

Uncontrollod, conaldora racyclo. u t o r i a l balance

Controlld by carbon odsorbor or rofri&orated frooboord chlllor. considers rocyclo. material baloncn

Uncontrollad. conalders rocyclo. based on aaterial balonco

Controlled = 0.7 freeboard r a t l o + dralnaao rack w i t h 15 second draln tho. conaidor. rocycla. raterial balonco

Uncontrolled. cons 1 ders rocycla. u t a r l a l balanco

Controllad by wator cover, CC~nDidOts rocycle, m a t e r i a l bolanco

Uncontrolled, bared on

Controllod by rofrlserated frooboard chlllor, based 0 1 1 matorial balonco

Uncontrolled, basad on lo rial balonco

Controllod by carbon odaorboc or rofrl&orated frooboord chlllar, baaed on amtorial bolonca

Uncontrolled, booed on utorlsl balonce

Controllod by 0 . 7 f r r n l o a r d ratlan uul dralna&e rack wlth 15 sacond draln t l n ~ a , basod on matarla1 balnrica

- 0 t O r l d balonca

. -19-

Do~rooaln8 oporatlona uairy TCE

Do8rooalry oporationa uairy TCE

O p a top vopor 40100205 Trichloro- 79016 0.93 k&/k& fraah Uncontrollod, basod 011

w o u o r a 0thyl.n. (vlrsin) ICE uaod aotorlal balulco

opa U P vapor 4ora02os tr ichloro- ' 79016 0.89 L&/k& fraah Contro1l.d by b v o OK below -0.80CB 0Lbyl.o. (vlr&ln) ICE u8.d frooxin8 rafrl&oratod

c frooboard cblllor, bared 011

matorla1 bolmco

79016 0.96 k&/k8 froah Uncontrollod. baaod on

79016 0.91 kg/k& fraah Controllod by carbon

(v1r.h) ICE uaod matorla1 ba1.n~.

(virain) ICE usod oba0rb.r or refrl&oroted frooboord chlllor, basad on motorial b0lMCa

79016 0.84 La/&& froah Uncontrollad. baaed on (vlr6ia) TCE uaod motorial balonco

79016 0.82 ka/k& froah Controlled by 0.7 freeboard ratio urd drelnara rack wlth 1s aocond droln L l u . based on motor101 bALMC0

(virain) ICE uaod

123911 0.03 &/ton mothy1 8oa.d on 3 prcont ual&ht In chlorofoa mothy1 chloroform

715% 0.86 kg/k& (froah) Unoontrol1od. conaldora vireln aolvont uoad rocyclo. boaod on u t o r i a l

bblancm

40100225 Trlchloro- othylono

.tbyl.l1. 40100225 Trlchloro-

+0100306 Trlcbloro- .thylono

0thyl.n. 40100306 Trlchloro-

Do&rooairy oporotlona w i n 6 W E

Do&raaain& oporotlona uatn8 ICE

Cold cloanora

Cold claonora

Do&roaain& oporatlona urlry mothy1 cblorofoa

Cold ohanor nothyl ahlorofom

Cold olouur 71556 0.84 ka/kg (froah) Controllod by 0 .7 froaboard vlrllo aolvont uaod ratio t drolnuo rock w l t h

15 roc& drain tho . conoldor8 rocyclo. boaad on u t o r l a l balonco

40100202 Mothy1 cblorofooa

71556 0.93 k8/ks (fraah) vlrala aolvont uaod

Uncontrolled, considers rocyclo, baaod on u t o r l a l balmco

Controllod by rafrl&orrted frooboerd chillor. conaldrrs rocyclo. bomed on rateclal balonco

Uncontrollad. consldors rocycla. based on m t e r l r l balance

Controlled by carbon adsorber or refrlaersted fraoboerd chlllor. co~isId*rs rocyc 10, matar lo1 ba 1 aiic(1

71556 0.89 k&/ka i (fresh) vlr8ln aolvont uaod

40100202 Mothy1 ablorolom

Dyroaaiw opratlona rully wthy l chlorofoa

Convoyor Ls.6 vapor da8roaa.r

40100222 k t h y l chloroform

71556 0.96 k&/k& (trash) virain aolvont uaad

Do#raoal~ oparationa u a i q w t b y l chloroform

Do8rooain& oporatlona ualry mothy1 cblorofom

Convoyorlrod vopor do&rooaor

40100222 &thy1 chloroform

71556 0 .91 k&/k& (Prarh) vlrain solvent uaed

* -20-

mu c1a.a.r

Convoyorlsod vapor 40100298 da&rooaora

Coavoy0rir.d vapor 40100298 dyrmuor

Irichlorotri- 761131 f LUOKWthMS

761131 Iricblorotri- f l W C O O t h M 0

Irichlorotri - 761131 f luoroothura

Trichlorotri- 761131 Iluoro.~.

trichlorotrl- 761131 f 1uoro.tb.a.

Trisblorotrl- 761131 f 1~roatb.a.

0.86 k&/kg frarh (viriin) molvo uaod

Uncootrolld, conaidorr racycla, bud on material balmco

Controllad - 0.7 Lraoboard ratio + drola.&o rack ulth 15 a~cond drain tho , conoldora rocycla. material b d M C 0

Uncontrollad, considers rocyclo, baaod on motorial balance

Controllod by refrlaorated frooboard chlllor, con6ldars rocycla. barad on raterlal balonco

Uncontrollod. conaidorti rocycla, boaod on material b d M C 0

Controlled by carbon adaorbor or rofrl&oratod fraoboard chlllor, contildvrs rocycla, u t o r l a l brh8Co

i

- 21- 1

ChropiUp electroplating and anodizing operations range in size from small

These operations can also be separated into captive shops that are part

shops, with one or two tanks that are operated only a few hours per week, to large shops with several tanks that are operated 24 hours a day, 7 days a week. of a larger manufacturing operation, or job shops that perform these services for many different clients.

Electroplating consists of the immersion of the base item into a plating solution, and the passing of a direct current through the solution, causing a metal to deposit out of the solution and onto the item. of electroplating: hard, in which a relatively thick layer of chromium is deposited directly on the base metal (usually steel) for use in engine components, marine hardware, plastic molds, zinc die castings, industrial rolls, and hydraulic cylinders and rods: and decorative, in which the base material is plated with a layer of nickel prior t o tho addition of a relatively thin layer of chromium, for use in automotivo trim, metal furniture, bicycles, hand tools, and plumbing fixtures.

There are two types

./

Chromic acqd anodizing consists of the immersion of tho bas0 metal, usually aluminum, in a chromic acid solution and the application of electricity to produce a film of chromium deposit on tho bas. metal, for w o in aircraft parts and architectural stnactures that are subjoct to high stress and corrosion.

Emissions of chromic acid mist occur dua to the inafficiency of the hexavalent chromium plating process. electric current applied t o the solution is actually used in tha deposition of the chromium on tho item. consumed in the evolution of hydrogen gas, with tho resultant liberation of gas bubbles,*which burst at the surface of the plating solution, forming a fina mi>t of chromic acid dropl-ets.

Only about ten t o twonty percent of the

The vast majority of the electric current is

The table on tho following pages has been excerpted from S o w a s of (S- (EPA-450/2-89-

0 0 2 ) . and presents uncontrolled emission dat8 for twelve chromium plating operations - - ten hard (Plants A - J) and two dacoratlvo (Plants K and L). Process parametors (chromic acid concentration and temperature of the plating baths) vero mnitorod, and appeared to be represontative of typical operation values for convantiom1 chromium plating operations. should o n l y b e wod if no site specific or otherwise more accurate data is availablo to th. facility.

Theso emission factors

Based on this test data, an uncontrolled emission factor of 10 milligrams of hexavalent chromium per ampere-hour (mg/Ah) (0.15 grain por ampere-hour [gr/Ah]) is considorad to ba representative of uncontrolled emissions from a hard chromium electroplating operation. A n uncontrolled hexavalent emission factor of 2 m g / A h (0.03 gr/Ah) is considered t o bo representative of uncontrolled emission8 from a decorative chromium electroplating oporation. (A more conservative estimate was selected for this emission factor duo t o the limited data available).

-22-

UNCO#TILOLLED EnISSIOl DATA FOE TOTAL AND HEXAVALE#T C U O M I U n FROM CHROUIUX PLATING OPXMTIOUS'

. Actual Gas w s s Coditi 0-

Total Tank 4 Flow Rate, Mass Emission B - L l Process Cr*' Emission

Hours (ft3/min) Total Cr C C * ~ Rate, mg/A*h (gr/A*h) No. of Surface Area, Ampere- ,,3/mIn

Plant Tanko m2 ( f t2) - Plant Ab*32 1

Plant Bc033 2

Plant cd* '' 4

Plant DC " 1

Plant E' " 1

Plant fl*'7 1

Plant Go 30 1

Plant HC* 39 1

Plant I i S 4 ' 2

14,000

I 14,400

20,000

19,800

11.700

12,200

8,900

3,440

8,530

0.029 (0.064)

0.008 (0.018)

0

0.076 (0.167)

0

0

0

0.009 (0.019)

0.100 (0.221)

0.026 (0.057)

0.015 (0.033)

0.039 (0 .08s )

0.076 (0.168)

0.031 (0.069)

0.083 (0.183)

0.024 i 1 (0.053)

6

6

0 .090 (0.199)

4.0 (0.06)

3.2 ( 0 . 0 5 )

4.6 (0.07)

9.1 (0.14)

6.3 (0.10)

16.3 (0.25)

6.5 (0.10)

3.6 (0.06)h

2 2 . 5 (0.35)

(continued)

' -23-

Process Conditions ' Actual Gas Total Tank , . Flow Rate, Mass Emission

Pate. krr/h (lb/h) Process Crt6 Emission Hours (ft3/min) Total Cr Cr+b Rate, mg/A*h (gr/Aoh)

No. of Surface Area, hpere- #-in

Plant Tanlrr m2 (ft') .0

Plant Jc 3 6.6 (71)

8 , 790 512 c 0.044 0.046 (18 , 100) (0.097) (0.102)

35.5 (0.24)

0 683 0.066 2.0 (0.03) P1 an t KC " 1 22.6 97 , 000 (24,100) (0.145) I (240)

e 70 0.004 1.3 (0.02) Plant L" 1 2.9 6,500

Average 1.6 (0.02) (30.8) (2,470) (0.008)

All tests were performed by EPA except for the Plant H test which was performed b the Naval Energy and Environmental Support Activity, Port Hueneme, California. Ampere-hour and mass emission rate values are based on an average of four test runs.

O Ampere-hour and mass emission rate values are based on an average of three test runs. Ampere-hour and mass emission rate values are based on an average of six test runs. Total chromium emissions were not determined. Ampere-hour and mass emission rate values are based on an average of five test runs. Hexavalent chromium emissions were not reported. Not included in average value because data are based on total chromium. Ampere-hour and mass emission rate values are based on an average of 11 test ruvs.

Chromic Acid Anodizing Operations

An uncontrolled emission factor of 0.0006 kilogram of hexavalent chromium per hour per square foot of tank surface (0.00012 pound per hour per square foot of tank surface area) is appropriate to characterize emissions frolrl

chromic acid anodizing.

Source: Locating and Estimating Air Emissions from Sources of Chromium (Supplement). August 1989.

EPA 450/2-89-002.

-24-

IV. SELECT QUESTIONS AND ANSWERS ON PROBLEXS FACED BY THE =TU, FABRICATION ImusTRY

(Noto: The numbers next to the questions re fer t o the i r location i n ~-

the EPA document Tgxic Chemical Release Inventorv Ouestions and BpSwers: 1990 U D ~ (EPA 5 6 0 / 4 - 9 0 - 0 0 3 ) . ]

DETWINING WHETHE3 OR NOT TO REPORT: FACILITY

4 5 . joined during a welding or soldering job i n throshold dotemination?

Must a f a c i l i t y include welding rods, solders, and the motals being

Yes, however, if no releases occur from the joined metal par t s themselves they may be considered articles and only the welding rods or solder-must be assessed for threshold purposes.

49 . imports 7,000 pounds of chomical X during 1989, is it requirod t o report fo r chomical X?

For 1989, the f a c i l i t y would have to report chonical X becawo it would have exceeded the manufacture threshold of 25,000 pounds (19,000 (“ fac tur ing) + 7,000 (importing) - 26,000) . manufacturing and therefore the amounts must be addod togethor ‘for threshold determinations.

If a f a c i l i t y be nu factures 19,000 pounds, processor 18,000 pounds, and

1

Note tha t importing is tho equivalent of

53. f a c i l i t y a t a soparato location tbt doos mot81 pl&ting (gonorally SIC 3471 -- Plating o f Motals and Formed Products). Would tha plat ing f a c i l i t y bo exempt?

According to the SIC code manual, t h i s plat ing f a c i l i t y would not be “auxiliary“ but would bo considered a separate operating establishment conducting a manufacturing ac t iv i ty . It would, therefor., need t o make the employee and ac t iv i ty threrhold determinationa and report , i f appropriate, because it f a l l s betwoon SIC codes 20-39.

A n airplan. ongino rapir shop (gonorally SIC 7699) oms aa * a u r i l i a q n

. d

DE- OR IQO? TO REPORT: L I S m CElr;McALs

57. chomicalr. CAS number.

Wo tu0 8 chuical r t t h li CAS numb8r not on tho l i s t of soctioa 313 toxic Thore &?a similar chemicals ou the list, but none with tho ram0 Eor can I bo sur0 I don‘t have t o roportt

As a general ru lo , tho f a c i l i t y should focus on tho availablo CAS number of chemicals present a t the f a c i l i t y and compare thon t o tho CAS number l i s t i n g of reportable sectionr 313 chemicals. mixture, such as naphtha, has a specif ic CAS numbers i t s e l f , but may also be composed of l i s t e d soction 313 chemicals. a l l available information a t the f a c i l i t y , not just tho CAS number, when attempting t o ident i fy reportable chemicals i n materials. Also, cer tain specif ic chemicals (o.g. , copper chloride) may not appoar i n tho CAS number l ist but a re reportable under a compound category l i s t i n g (e.g. , copper compounds).

Be aware, however, t ha t a complex

Therefor., tho f a c i l i t y should use

- 2 5 -

59. are listed under saction 313 with the qualifier "fume or dust." processing operation subject to reporting?

A facility processes aluminum, vanadiu. and zinc. These thteo chemicals Is this

If the processing of these substances generated (i.e., manufactured) any fume or dust during its operation or if the three substances were processed or otherwise used, at any time, as a fume or dust in the operation, the processing would constitute a reportable use of a listed section 313 toxic chemical. The manufacturing, processing, or otherwise use of these substances in fume or dust form would be subject to threshold determinations.

60. CAS numbers (e.g., nickel compounds), how is the CAS number of the item described?

If an item on the section 313 list incorporates chemicals vith multiple

., Do not enter a CAS number in such cases. Instead, enter NA in the space for the CAS number in Part 111, Section 1.2 of Form R. The individual chemical members of a listed category are not required to be, and should not be, identified in the report.

61. compounds, soon thoro vhich b o o not been as~ociatod rith adverse health effects?

Do the chorical categories such as nickel compounds include all

What is tho authority for this decirion?

The saction 313 list established by Congressional legislation included categories. example, regardless of whether specific toxicological problem have been identified for a specific compound in the category,

EPA interprets these listings to mean a l l compounds of nickel for

77. heat seal it in to a glass bulb. 313 reporting?

I use copper wire in on0 of my products. I cut it and bend it and then How do I considor the copper wire for section

d -

First, the wire would ramin an articlo if no releaser of copper (e.g., dusts) occur during manufacture of the glass bulbs. If the wire is not an article, then for an element such as copper, both copper metal and copper compounds are subject to section 313 reporting. First dotermine the form of copper in the wire. If it is pura copper wire, the entire weight of the wire must be used. If it is an alloy, the weight percent times the wire weight must be used. If there are coppor coapounds, the entire weight of each copper compound must be used for tbrerhold determination.

81. which includos 26 percent frea nickal and nickel containrd in compounds. Should the threshold datamination be based on tho 61 percent total nickel?

For rrctioa 313 reporting, a catalyrt contains 61 percent total nickel,

The 61 percent total nickel cannot be usad in tha threshold determinations. Nickel compounds are a listad category, therefor. tho full weight of nickel compounds must be used in the threshold determination for nickal compounds. separate threshold determination is required for the free nickel since nickel is a separately listed chemical under section 313.

A

- 2 6 -

8 5 . (NiC1). COmerCe. the chloride renuins in the plating bath (othervise used). chloride is reportable under the nickel compound category of section 313, which threshold applies for this situation?

A product io immersed into a plating bath containing n i c k e l chloride This is done to bond nickel to the product prior to distribution in Nickel is incorporated into the final product (processed) vhareas

Since nickel

The threshold determination is made based on the total amount of nickel chloride processed and the report will be filed for nickel compounds.

91. chemical in a mixture, are they required to use the upper bound concentration to determine threshold as stated in the February 16, 1988 F e d e m Ranis tes? Use of the average or midpoint of the range w i l l &wid ovorest&aating emissions. If a metal mixture contains a range of 1 to LO petcmt of three metals together, how can this information be used to dotermino threrholds?

If a facility only know8 the range of concentration of 8 section 313

The final rule does not discuss ranges, it only says that the upper bound should be used "if the person knows only the upper bound concentration". range is available, using the midpoht or average valuo is reasonable. the combination df three chemicals, the facFlLty should split tha range among the three chemicals based on the knowledge th8t they have, so the total equals 10 percent. They do not have to assume 10 percent "ti" for each chemical.

If a For

SUPPLIER NOTIFICATIOS . 94. Is a facility subject to supplier notitiertion roquireuntr if it

distributer products cont8ining more than tho de minimis 1.9.1 of listed metal compound?

3

Yes, ifeyou distribute these products to other manufacturers or processors, and you are in SIC Coder 20-39, you are subject to the supplier notification requirements. notification.

Articles and consumer products are exempt from supplier

9 5 . customer is in SIC coda 20 through 39 and b s mora than 10 employees?

Do supplier notiffcation requirements apply only to situation where the

A coapany is responsible for providing supplier notification to a covered facility within SIC codas 20-39 and with 10 or more employees, and to customers who in turn may sell or distribute to a "covered facility." customer may bo 8 wholesale distributor who is not in SIC codes 20 - 39 but sells to other manufacturing facilities.

Such a

110. report8ble section 313 chomic8l category, hor should that bo addressed on the supplier notification? Is it acceptable to provlda the percmt o f the parent metal?

If a m k t u r a cant8lns 8 chemical compound that is a member of a

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59. A f a c i l i t y processes alumh.m, vanadium, and zinc. are l i s t a d under section 313 with the qua l i f ie r "fume or dust." processing operation subject t o reporting?

These threa chamicals Is t h i s

If the processing of these substances generated ( i . e . , manufactured) any fume or dust during its operation or if the three substances were processed o r otherwise used, a t any time, as a fume or dus t i n the operation, the processing would consti tute a reportable use of a l i s t e d section 313 toxic chemical. The manufacturing, processing, o r otherwise use of these substances i n fume or dust form would be subject t o threshold determinations.

60. CAS numbors (e .g . , nickol compounds), how is the CAS numbor of the item dascrlbed?

If an itam on tho srct ion 313 l i s t incorporates chemicals with multiple

Do not enter a CAS number i n such cases. the CAS number i n Part 111, Section 1.2 of Form R. members of a l i s t e d category a re not required to be, and should not be, ident i f ied i n the report.

Instead, enter NA i;l'the space for The individual chemical

61. compounds, even thoro which b v o not been aS80~ht.d with advorso health effocts? What is tho authority fo r t h i s dociriant

Do tho Che8iCal catagoria8 such a8 nick01 compounds includo a11

The section 313 l ist established by Congressional leg is la t ion included categories. example, regardless of whether specif ic toxicological problems have been ident i f ied fo r a specif ic compound in the category.

EPA interprets these l i s t i ngs to mean a11 compounds of nickel for

77. heat s ea l it in to a glass bulb.

I us. coppor riro in on0 of nry products. I cut it and bond it and thon How do I coaridor tho coppor uiro fo r soctlon 313 r o p r t i n g t d

F i r s t , the wire would remain an a r t i c l e if no teleasos of coppor (e .g . , dusts) occur during manufacture of the glass bulbs. If tho wire is not an a r t i c l e , then fo r an element such as copper, both copper metal and copper compounds are subject t o section 313 reporting. F i r s t detonnina the form of copper i n the wire. If it is pur. coppor wire, the en t i re woight of tho w i r e must be used. If it is an alloy, tho woight percent times the wire weight must be used. I f there aro coppot compounds, the en t i re weight of each coppor compound must be used f o r throrhold d a t e r a i u t i o n .

81. which inclodor 26 porcent fro0 nick01 8nd nick01 containod in compounds. Should tho threshold d o t o r a i u t i o n be basod on the 6 1 percant t o t a l nickel?

For roctian 313 reporting, a catalyst contains 61 parcont t o t a l nickal,

The 61 percent t o t a l nickel cannot be used i n tho threshold determinations. Nickel compounds a re a l isted category, therefore the full woight of nickel compounds must be used in tho threshold determination f o r nickol compounds. separate threshold dotemination is required for the f ree nickel since nickel is a soparately l i s t o d chemical under section 313.

A

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8 5 . (NiCl). CoPIIperce. the chloride remains in the plating bath (othervise used). chloride is reportable under the nickel compound category of section 313, vhich threshold applies for this sitution?

A product is immersed into a Plating bath containing nickel chloride This is done to bond nickel to the product prior to distribution in

Nickel is incorporated into the final product (processed) vhcreas Since nickel

The threshold determination is made based on the total aaiount of nickel chloride processed and the report will be filed for nickel compounds.

91. If a facility only knwr the range of concentration of a section 313 chemical in a mixture, ara they required to use the upper bound concentration to determine threshold as stated in the Febnury 16, 1988 Federal Renis tax? Use of the average or midpoint of the rang. will avoid ooerert&mating emissions. If a metal mixture contains a range of 1 to 10 percent o f three metals together, how can this information be u m d to determine threrholds?

The final rule does not discuss ranges, it only says that the upper bound should be used "if the person knows only the upper bound concentration". range is available, using the midpoint or average value is reasonable. the combination bf threo chemicals, the facility should split the range among the three chemicals based on the knowledge that they havo, so the total equals LO percent. They do not havo to assume 10 percent nuximum for each chemical.

If a For

SUPPLIER NOTIFICATIOW * 94. Is a facllit~ subject to supplier notification requirements if it

distributes products containing more than the da minimis leva1 o f a listed metal compound?

Yes, if-you distribute these products to other manufacturers or processors, and you are in SIC Codas 20-39, you are subject to the supplier notification requirements. notification.

-I

Articles and consumer products are exempt from supplier

9 5 . customar is in SIC code 20 through 39 and ha8 more than 10 employoer?

Do auppliar notification requirements apply only to a situation where the

A company ir rasponribla for providing supplier notification to a covered facility within SIC coder 20-39 and with 10 or more employees, and to customers who in turn may sel l or distribute to a wcovered facility." customer may ba a arhOhS810 distributor who is not Ln SIC coder 20 - 39 but sells to other manufacturing facilities.

Such a

110. reportable section 313 chemical category, how should that bo addressed on the suppllor notification? Is it acceptable to provide the porcent of the parent matal?

If a mixture contains a chemical compound that is a mombor of a

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If a mixture contains a chemical compound (i.e., 12% zinc oxide) that is a member of a reportable chemical category (i.e., zinc compounds), the supplier is required to notify his customers that the mixture contains a zinc compound at 12% by weight. metal (zinc) doer not fulfill the requirement, but may be done to aid receiving facilities in estimating releases. weight percent of the entire compound for threshold determinations.

Supplying only the weight percent of the parent

The customer must be told the

ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITP

125. A process at a facility draws Steel rod8 into a smaller diameter. Is this manufacture, process, or otherriso us01 How do I report?

This activity is considered processing because the toxic chemical remains incorporated in the final product distributed in commerce. amount of each chemical in the rods processed toward the applicable activity threshold if the toxic chemical is present abovo the de minimis level.

OriZy apply the

128. block form to mako a mold which st8ys on sit.. and dust aro A hyproduct.

Vo havo purcharod in excos8 of 100,000 pound8 of aluminum material in Whon makin8 tho mold, funor

Do wo report aluminum ar tho choaical?

Aluminum appears on the list of chemicals as “aluminum (fume or dust)“. must determino if you manufacture, process, or use aluminum fume or dust. In this case, you are not processing or using, but do Rumnufacturea aluminum fume or dust coincidentally as a byproduct of making molds. report for aluminum (fume or dust) if you exceed the 25,000 pound manufacturing threshold for the reporting year.

You

Thorefore, you must

129. die to‘fonn parts.

A facslity molt8 alumhum ingots, rerhapor thor, and injects them into a Door tho -25,000 pound8 procorring throrhold apply to the

“t of molton procorsod?

For calendar year 1989, tho 25,000 pound8 threshold applies to the amount of aluminum fume or dust generated at the facility, not the aluminum in molten (liquid) or solid form. Thorefore, the facility must determine whether they produce more than 25,000 pounds of aluminum fume or dust air emissions in their processing oporation.

130. produce8 lrad-coat8ining w8ste (from gasolino load dOporit8). m~nufacturrr, procosror, or othenriso u8.r of lobd conpornrdrt

A r-acmror of auto engines cleans tho ongin. parts and thoreby Aro they a

The facility neither manufactures, processes, nor othewiso uses lead. Lead is not incorporated into products for distribution nor is it a manufacturing aid or a processing aid as those terms aro defined. Lead in the waste would not be included for threshold determination.

132. If percent stay.8 vith product, is t h i s processing or w o ? not necersaril~ intondod to stay vith the product.

If 8 solvont is urod in a process and 85 porcont evaporator but Tho 1S percent vas

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In this case, the entire quantity of the solvent should be considered "othewiso wed" and subject to the 10,000 pound threshold. was intendad to remain in the product, this would be processing.

If the solvent

133. solder?

Is soldering light bulbs using lead solder considered processing of the

Yes, it incorporates the solder into a product for distribution in commerce.

134. electroplating oporations. compounds, and how do thoy dotormino vhether tho7 moot tho threrhold and which

An eloctroplating facility USIS motal cyanido compounds in their Are they processing or using thoro cyanid.

throshold applies? .,

The parent metal from the metal cyanide compound is plated onto a substrate electrochemically, leaving the cyanide as waste product. "processed', while the cyanide is "otherwise used". reportable under section 313 as both cyanid. compounds and motal cyanides. Seloct the threshold based on the action that involver tho portion of the compound that identifies tho category (i.e., cyanid. for cyanid. compounds). The total weight of the compound counts for both tho mota1 cyanidor threshold and the cyanide compound threshold.

The parent metal is Metal cyanide8 aro

138. acid to plat. chromo onto fabricated mot~l. in tho bath and somo chromo is doporitod onto tho fabricatod moul part. umrtilired compounds aro soat to tho facility's vasto treataont process, vhoro horrvalent chromiun is reducod to trivalent chromitn. compouhd8 cqunted for soctian 313 throshold detrrminrtiont

A facility u8.s A chromo modo in an oloctroplatiq bath o f rttlfuric cbromfum compounds aro gonorated

Tho

Hw art. thoro r o b e d

d

The threshold dotormination for chromium compounds is buod upon the amount of chromium compounds generated in the plating bath. transformations of hexavalent to trivalent chromlup compounds as a result of waste treatment does not affect the threshold dotermination. To do so would involve double counting.

Any subsequent

139. not zinc capoond. a t , a11 of .bich i8 c8ptur.d and sent off-ritr for rocyclo. C.rr tho company c h i n ut -ion bocatuo tho shoot metal roluins an articlo, or m t it do a throshold dotrr"tioa bacauso it ha8 coincidontall7 nunrf~cturod zinc (fuma or dust)?

A c- procossos a galvmized shoot mota1 containin# olemontal zinc, vhon tho sheet mot~l is prOCO88Od it gaaorator zinc

Though the sheet motal remains an articlo during tha procorring of the sheet metal, zinc (furno or dust), a listed chemical, is manufactured. This release negates the article exemption. apply to cases of manufacture. determination based upon the quantity of zinc dust gonerated. Tho amount sent off-site for recycle is not reportable, being tho equivalent of a product sold in comerce.

The recpclo/rowo exemption does not The company would havo to d o A threshold

Any amount not recycled would also bo a rrportable rolearo.

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141. part of an article. volatfle chemicals from the painting operation - - are they "otherwise used," thus subject to the 10,000 pound threshold?

Paint containing listed chemicals is applied to a product and becomes Doer the 25,000 pound threshold apply? What about the

Yes to both questions. This is a case in which listed chemicals in the same mixture may have different uses and, therefore, different thresholds. n e listed chemicals that are incorporated as part of the coating are "processed," whereas the volatile solvents in the paint are "otherwise used" because they are not intended to be incorporated into the article.

152. ma int enanc e inc luded?

Hor is routine maintenance defined in the exemption list? Is equipment

Equipment maintenance such as the use of oil or grease is not cxempt. The routine maintenance exemption is intended to cover janitorial or other custodial or plant grounds maintenance activities using such substances as bathroom cleaners, or fertilizers and pesticides u r d to maintain lawns, in the same form and concentration commonly distributed to consumers. of equipment is exempt because the paint becomes part of the structure of the facility. i

Painting

EXEl4PTIONS

154. The wstntctural componentn exemption from section 313 reporting covers tho saull amounts of abradod/corroded motals from pipos and other facility equipment. regularly suffers abrasion, such as grinding rho018 .nd motalrorkiq tools? What critoria can a facility use to dacide which piocos of equip~.pf are structural components and which are not?

I Would tho structural caapon.nt eroqtion apply to equipnone vhich

\

Thi section 313 structural componentr exemption would not apply to grinding wheels and matal working tools. down and to be replaced because of the M & O of their use. component exemption applies to passive structures and equipment such as pipes. The abrasion/corrosion includes normal or natural degradation. such as occurs in pipes, but not activo &gradation, such as occurs in a grinding wheel.

These item are intendad to wear Tho structural

155 . equipmont i a u u p t because tho pafat is intondod to bocomo part of tho structure. materials are fntondod to becomo part of tho facility?

A factlit7 usas walding rods to ~ i n t a i n its equipment. The painting o f

Aro roldfng rods used to maintain equipment exoapt becauro tho

Welding rods w e d to repair and maintain equipment would bo exempt from reporting under section 313 because they are becoming a fixed part of the structure of the facility. In this way, they are slmilar to paint, and unlike some replaceable maintenance materials Like oil or greasa. *facility* includes all buildings, equipment, structures and othor stationary items located on a single site, or on contiguous or adjacont sites.

Tho term

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114. the m u m and mini" concentr8tions l i s t ed on the HSDS range above and below tho do ninlmis concentration levels, how can the f a c i l i t y determine qurmtities f o r section 313 compliance?

A f a c i l i t y uses a chemical mixture that contains a toxic chemical. If

The amount of the chemical i n the mixture that is present above the de minimis level and therefore counts toward the threshold, can be assumed t o be proportional t o the r a t io of the above-de minimis concentration range t o the overall concentration range. t ha t is not exempt is the average of the de minimis level and the maximum concentration.

The concentration of the chemical in the mixture

178. A f a c i l i t y Cut8 metal sheet8 containing nickel, releasing fumer. then fur ther grindr the metal t o i t s fin81 shape, producing grlndlngs. the shaets t o r e t a in the i r a r t i c l e S t 8 t u 8 , relaares must be l e s r than 0.5 pound/year t o any modi.. of the s a o typo of item being ptocesred or used Ln tho smo uay or t o releases from a l l manner8 of processing o r use of tho samo typo of itam?

It For

Doer t h i s cut-off value apply to a ~ r e g a t e releaser

The 0 . 5 pound/yeaz release cut-off valuo applies t o aggregato releases

Tho various shapes result ing from

from the samo type of i t e m being processed or used in all manners a t tha f a c i l i t y . chemical from both steps of the process. the cut t ing a re "the same type of item" as the i n i t i a l sheet. releases from grinding should be added to those from cutting.

This yalue applies t o the total aggregate reloasas of tho toxic

Thus any

180. wire r t i l l aa a r t i c l e ?

We taka coppor wire, cut it, and wind it arouad amallor spools. Ir the

If there is no release of a toxic chemical during n o m 1 procosring of the copper-wire, then tho wire remains an a r t i c lo .

> . d -

181. I rUn 8 met81 fabricat ion f a c i l i t y , S f C cod. 34.

sheet8 8 r t i C l O 8 ? sheet8 and send tho rhrriqr o f f - s i t e fo r r m o , caa I

If the shavings tha t a re formed during the cut t ing a re

If I cut tho metal con8idet tho metal

the sole releases, and i f all the shavings aro sont o f f - s i t e fo r reuso, &d the thickness of the metal shoot doas not chuyg. during processing, then the metal sheets are s t i l l considered a r t fc loa md uo exempt.

182. thus erupt from section 313 reporting? p a r t 8 t ha t h vholo os in part r e t a in tho bar ic dSmensiaru1 character is t ic of tho bar stock. specif ic shapo and dimension of the bar stock.

Is brr rtock that is urod t o nuke precir ian "d par t s an a r t i c l r and Tho b8r rtock is processed t o produce

Tho production of the par t itrelf is drpondont upon the

Bar stock io an a r t i c l e i f i ts basic dlmonsional charactar is t ics are maintained in whole or in p a r t i n the finished product and zero releases occurring during processing. If the end product is totally di f fe ren t i n diameter o r thickness, then the bar stock would not be an article.

I ' -31-

183. or rod aa an a r t i c lo?

Can f a c i l i t i e s which extrude copper bars or rods into v i ta t rea t the bar

No, an a r t i c l ~ has end use functions dependent i n whole o r in part upon its shape or design during end use. The end use function is dependent upon the copper being i n the shape of the wire, so the copper bar cannot be considered an a r t i c l e . you are processing the chemicals; the a r t i c l e exemption no longer applies.

If you are changing the shape o r form of an item substantially,

RELEASES OF TEE CHEMICAL

192. r e su l t from grinding or d r i l l i n g of motal items considered Nreleases o f toxic chemicalsN? ./

Is tho disposal of wastes such as dusts, shavingr, or turnings that

Yes, such releases of %on-recognizable" sol id wastes such as dusts, shavings, o r turnings are considered releases of toxic chericala.

197. A f a c i l i t y discharges w8Sta COnt8ining l i s tod section 313 metals t o an on-sit. cooling pond. water is thon dr8in.d fTOm tha cooling pond, having tho h o a q motal sludgo. Tho sludgo i a thon drodged and Sent off-sit . t o a rocyclor. Elor should th i s bo reportod?

Tho IPOt.18 accumulate and so t t l o ovor t h o , and tho

The ultimate disposal of l i s t e d chemicals from tho facility during the reporting year must bo reported. "released to land." Chemicals sent t o a rocoiving atroam whon eh. waste water is drained are areleased to water." recycle of the chemical a r e not reported as a re1eaa.o or t r u u f o r ; others sent o f f - s i t e not for recycle a re reported as a "transfer off-sit.."

Chemicals remaining in tho sediments are

Matorials dredgod and sont o f f - s i t e for

d .

201.

room and a closod ovon room vontod by UI w o n stack. Is tho vont to tho outsido of tho build- w a r tho p8inting roo8 8 aro108soa from building vent i la t ion s y s t o 1 ~ ~ fugitivo emission?

Our f8cil i ty pints mot81 cablnotr and tho paint solvents contain a l i s t e d toric ch.pic.1. Tho S7St.m C O I U i 8 t 8 Of 8 clo8.d vontod p8inting

No, fugitivcr rolouos 8ro emissions tha t are not in a confined directional a i r flow. Sinem your building vent system over the painting room is a confined a i r stream., lt cua bs combined with the oven stack as a stack o r point emission in P u t 111, Section 5 . 2 of Form R.

. ?

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v. BIBLIOG~APHY OF REFERENCE SOURCES t

Fumes and G m e s in the Weld- En vir onment, , 1979, American Welding Society, P.O. Box 351040, Miami, FL for non-members).

I

33135, phone (305) 443-9353 ($48 for members: $ 6 4

H C-a For a R e c w n d e d Standard: WelQine-8rPliao. and Thermal Cutting, April 1988, National Institute for Occupational Safety and Health, 1-800-356-4674, no charge.

Releases and Waste Treatment E u c i e s for Toxic Chemical BeLease In ventow Fol~p (EPA 560/4-88-002). Suggested methods on the development of release estimates and warte treatment efficiency calculations required on Form R. Available from: Superintendent of Documents, Government Printing Office, Washington, DC 20402-9325, (202) 783-3238, Stock Number: 055-000-00270-3, $11.00.

Co=LLarion of Bir P o U j , t l Fac wrs. Volylps 1. S- Po-

Documents, Government Printing Office, Wa.hfngton, DC 20402-9325, (202) 783- 3238, Stock Number: 055-000-00251-7, $20.00.

EdifiLsn (AP-421. Available from: Superintendent of

, August 1989, (EPA 450/2-89-002). Available from: National Technical Information Senrice (NTIS), 5285 Port Royal Road, Springfield, Virginia 22161, (703) 487-4650, Stock Numbor: PB 90-103243, $15.95.

aro available from NTIS or tho Government Printing Offico. industry-specific information concoming chemic818 in vartev8t.r.

Thoro documents contain

NTIS w Coil Coatin& \.ph (EPA440/1-82-073) PB83-205542

E l e c t r o W n - - (EPA 440/1-79-003) PB80-196488

Metal. -*

Coil C o a k u P- If - Can-. (EPA 440/1-83-071) PB84-198647

e -

(EPA 440/1-74-003A) P8-238834/F (EPA 440/1-83-091) PB84-115989 (EPA 440/1-84-074) P884-192459

A complate l i a t of tho industries is available from: Documents Cavumont Printing Office, Warhington, D . C . 20402, (202) 783- 3238. available foz rrviow and inspection at the EPA Regional Offico Libraries.

Superintendent of

All Dovmlopmont Documents for Effluent Limitation Guidaliner are

Factors 0 0 CO- To- corn- . (EPA 450/2-88-006a) October 1988. Available from: National Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, Virginia 22161, (703) 487-4650, Stock Number: PB 89-135644.

EPA has published a group individual guidance documents that targat activities industries who primarily process or otherwise use listed toxic chemicals. The following are relevant to the metal fabrication industry and are available for no charge from: Section 313 Document Distribution Center, P . O . Box 12505, Cincinnati, OH 45212.

, For More Information

Emergency Planning (800) 535-0202 and Community or Rlgh t- tO-KnOW (202) 479-2449

' Hotline (in Washington. D.C. and Alaska)

Small Burlnclr , (800) 368-5888 Ombudsman or -- Hotline (703) 557- 1938

(in Washington. D.C. and Virginia)

The EPA brochure. Tltle 111 Section 313 Release Reporting Requlrements (EPA 560/4- 90-002) presents an wervlew of the new law. It identifies the types of facilities that come under the provtsions of Section 313. the threshold chemical volumes that trigger re- porUng requirements. and what must be reported. I t also contains a complete listing of the chemicals and chemical categorlcs subject to Section 313 reportlng. The EPA publlcatlon. Estimating Release and Waste- 'TYeatment Emciencies for the T w c Chemlcal Release Inventory Form (EPA 560/4-88-0021. presents more detailed information on gen- eral release estimation technlques than is included in this document.