ESTIMATION OF PERSISTENT BIOACCUMULATIVE TOXIC CHEMICALS FOR THE TOXIC RELEASE INVENTORY

On October 29, 1999, the Environmental Protection Agency (EPA) promulgated a final rule to address Persistent Bioaccumulative Toxic (PBT) chemicals on the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 Toxic Release Inventory (TRI). EPA added seven chemicals and two chemical compound categories to the list of toxic chemicals subject to reporting under EPCRA section 313. EPA also lowered reporting thresholds and eliminated certain de minimis exemptions for 18 chemicals and chemical categories that meet the EPCRA 313 criteria for persistence and bio-accumulation.

The reporting thresholds for 17 of the 18 chemicals and chemical categories have been lowered from 10,000 or 25,000 pounds per year to 10 or 100 pounds per year depending on the particular chemical. The reporting threshold for the newly added dioxin category is 0.1 grams per year for 17 dioxin congeners on a total mass emission (TME₁₇) rather than a Toxic Equivalent (TEQ) basis. The 17 dioxin and dioxin-like compounds are the seven 2,3,7,8-substituted polychlorinated dibenzo-p-dioxin congeners and ten 2,3,7,8-substituted poly-chlorinated dibenzofuran congeners that have toxic equivalency factors (TEFs). The use of TME₁₇ instead of TEQ for the TRI reporting threshold is significant since many of the combustion related dioxin and furan congener profiles have high mass concentrations of hexa-, hepta- and octa-chlorinated dioxin and furan congeners which have low TEQs. Consequently, a facility combustion device could have a low dioxin TEQ concentration, but still be over the 0.1 gram per year TRI reporting threshold. A list of the new reporting thresholds for the 18 chemicals and chemical categories is shown in Table 1. The newly added chemicals and categories are also indicated in Table 1. The TRI reports for these 18 chemicals and chemical categories for the 2000 reporting year are due on July 1, 2001.

Section 313 of EPCRA requires that facilities submit a TRI Form R for any chemical or chemical category included on the 40 CFR 372.65 list that they manufacture, process, or otherwise use in quantities greater than the respective threshold amount for that chemical or chemical category. Estimates of releases to different environmental media, annual source reduction and recycling quantities, and other information for each applicable chemical or chemical category must be included on each Form R. Facilities are not required to conduct sampling and analysis in determining threshold or estimating releases, but may instead base these determinations on engineering judgment. If however, the facility has previously obtained valid analytical data, this data must be used for the threshold and release determinations.

The EPA will be coming out with a TRI-PBT Guidance Document for estimating D/F emissions in about mid-March, 2000. This Guidance Document will use an emission factor approach for different types of incinerators and air pollution control equipment. The emission factors will probably be in nanograms (ng) of a specific congener per kilogram (kg) of waste fed to the incinerator or other combustion device. To estimate grams per year of the 17 dioxin congeners, there will be 17 emission factors. Focus expects that these emission factors will be conservative and typically result in high end D/F estimates.

The most likely sources of D/F manufacture are the combustion devices being used at the facility, such as hazardous waste inciner-ators, solid waste incinerators, BIFs, fossil-fired boilers and process heaters. If the facility is over the 0.1 D/F gram per year threshold for manufacture, process or otherwise use, each facility combustion device will need to have a D/F emission estimate done as part of the TRI reporting estimate. Focus Environmental has all ready doneperformed preliminary D/F emissions estimates for two combustion devices at a Fortune 500 manufacturing company in support of their year 2000 TRI reporting. and can use the same D/F emission estimating methodology can be applied at other facilities with combustion devices. same estimation procedures to estimate D/F emissions at your facility. A preliminary estimate of D/F emissions from facility combustion devices could be important information for a facility’s environmental manager to know.