I am the facility engineer for a manufacturing plant that uses fuel oil to operate our boilers. Recently, our fuel oil supplier informed us that we may have to report some chemicals in the fuel oil on this year's Form R report. I have never heard of this before. Do you know if there is really something to this? J.G.
Surprisingly, you may have to report some chemicals that are contained in the fuel oil or formed when the fuel oil is burned in your boilers. Beginning with the reporting year of 2000, EPA expanded and/or added additional chemicals or chemical classes to the SARA 313 toxic chemical release reporting list, including mercury and mercury compounds, persistent bioaccumulative toxic (PBT) chemicals and polycyclic aromatic compounds (PAC). Furthermore, EPA eliminated the de minimis exemption; this means that facilities are required to include all amounts of these chemicals in threshold determinations and release calculations regardless of concentration. Also, the reporting threshold amount can be as low as 10 lb/yr. The above chemicals are known to be contained in or formed during combustion of many hydrocarbon based fuels; however, those fuels that have the greatest likelihood to cause reporting are coal and fuel oils.
According to EPA guidance documents, a facility "processes" the chemical if it is contained in the fuel since it will be changed during combustion. If one of the PBT or PAC chemicals is formed during combustion, EPA considers this "manufacturing" of the compound as a byproduct.
With the reporting deadline of July 1, 2001, for the year 2000, I strongly recommend that you either engage a professional who is familiar with this issue or obtain the guidance documents from EPA. EPA has three draft documents that are available: mercury and mercury compounds; pesticides and other persistent bioaccumulative toxic (PBT) chemicals; and polycyclic aromatic compounds. These are available on the Internet at www.epa.gov/tri/guidance.htm or at 800-424-9346.
While discussing SARA 313 reporting, this is a good time to remind those that use nitric acid not to forget to evaluate the "manufacture" of nitrate compounds in your wastewater treatment system. Despite some evidence to the contrary, EPA still assumes that all of the nitric acid neutralized with sodium hydroxide is converted into sodium nitrate at the rate of 1 lb nitric acid forms 1.35 lb of sodium nitrate. Therefore, to exceed the 25,000 lb/yr "manufacturing" reporting threshold, more than 18,518 lb of nitric acid would need to be treated. Again, EPA has a guidance document on nitrate compounds.