Trihydro presented Benzene TSCA Chemical Data Report - preparing for 2016 Reporting

1. 3/9/2016 Page 1TSCA CDR - Preparing for 2016 Reporting
TSCA Chemical Data Report
Rebecca Bradley
Project Manager
Trihydro Corporation
Preparing for 2016 Reporting

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Presentation Outline
• TSCA background and regulation
• CDR background and updates
• Determining how and what to
report
• Best practices for CDR
• Industry specific best practices
and examples
• Tips and tricks for 2016

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TSCA Background
• Toxic Substances Control Act (TSCA) created in the late 1970s
• Listed toxic chemicals in commerce
• Primary Objective
• Reduce the risk of chemical exposure to the environment or human health via controls
at:
• Manufacturing
• Distribution
• Use
• Disposal
• Authority given to EPA to regulate potentially dangerous chemicals not already
covered under existing regulations

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TSCA Regulatory Sections
Regulations at 40 CFR Subchapter R (Parts 700-799)
• Principal sections of TSCA:
• Section 4 – Testing of Chemical Substances
• Section 5 – Manufacturing and Processing Notices
• Section 6 – Regulation of Hazardous Chemical
Substances and Mixtures
• Section 8 – Reporting and Recordkeeping

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CDR
Chemical Data Reporting (CDR)
• CDR Objective –
• Collect exposure-related information on chemical
substances and make it available to the EPA and
general public.
• Screen, identify, and prioritize potentially harmful
chemicals
• Most comprehensive data set on chemical
substances and their proposed uses

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CDR Background
• Required every 4 years
• 2016 Submission Period: June 1, 2016 – September 30, 2016
• 2016 Reporting Period: January 1, 2012 – December 31, 2015
• Many changes to this report
• Inventory Update Reporting (IUR) rule implemented in 1986
• IUR changed to CDR in 2012 reports
• Form U
• Parts I, II, and III

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TSCA Definition of Chemical Substance
Any organic or inorganic substance of particular molecular identity,
including any combination of such substances occurring in whole or in
part as a result of a chemical reaction or occurring in nature, and
chemical element or uncombined radical.

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Relevant CDR Changes
Reporting Year 2006 2012 2016
Production Volume Reporting
Threshold (lbs)
100,000 25,000 25,000*
Production Volume Reporting
Threshold for Partial Exemption (lbs)
300,000 100,000 25,000*
Principal Reporting Year 2006 2011 Not Applicable
* Potentially harmful chemicals subject to TSCA regulatory or consent agreement status have a lower threshold of 2,500 lbs.

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Example – Is This Reportable?
Site X produces “Chemical A” during the reporting period. “Chemical
A” has a reportable quantity of 25,000+ lbs. The “Chemical A”
production volumes were:
2012 – 28,000 lbs
2013 – 26,000 lbs
2014 – 25,000 lbs
2015 – 24,000 lbs
YES!!

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Example – Is This Reportable?
Site X produces and distributes benzene off site during the reporting
period (2012-2015). The benzene production volumes were:
2012 – 23,000 lbs
2013 – 25,000 lbs
2014 – 27,000 lbs
2015 – 29,000 lbs
YES!!

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How much is 25,000 lbs?
• 12.5 tons of Asphalt
• ~5.7 LT or ~35.7 bbl of Sulfur
• ~6100 gals or ~140 bbl of Propane
• ~3700 gals or ~90 bbl of Kerosene
𝑀𝑀 = 𝑉𝑉 𝑥𝑥 𝜌𝜌

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Getting Started – Subject to CDR?
A. Is your chemical
substance manufactured for
commercial purposes?
B. Is your chemical substance
on the TSCA Inventory?
C. Is your chemical
substance potentially
exempt from reporting?
D. Is your chemical
substance ineligible for an
exemption due to its TSCA
regulatory or consent
agreement status?
YES
NO
NO
YES
YES
YES
NO
NO
You are manufacturing a CDR reportable Chemical.

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Exempt Substances
• Certain forms of natural gas
• Natural gas
• Condensates
• Gasoline natural
• Raw liquid mix
• Naturally occurring substances
• Crude oil
• Water
• Natural and manufactured
• Byproducts
• No separate commercial intent
• Impurities
• Fuel Gas/ Off Gas
• Non-isolated intermediates
• Polymers and microorganisms

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Byproducts Examples
If a chemical byproduct is disposed of as a waste only or combusted as
fuel, is it exempt from the CDR?
100,000 lbs of sulfur from a sulfur recovery unit (considered a
byproduct) is generated – 40,000 lbs is sold to a fertilizer plant, and the
other 60,000 lbs is land-filled; is it exempt from the CDR?
YES!!
The 40,000 lbs sold is
REPORTABLE.

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Getting Started – Required to Report?
E. Did you manufacture
(including import) 25,000 lb
or more of the chemical
substance at a single site?
F. Do you qualify for a small
manufacturer exemption?
H. Do you qualify for
any other reporting
exemptions?
G. Did you
manufacture a
chemical substance
subject to reporting
due to its TSCA
regulatory status?
YES
NO
You must Report.
YES
NO
NO
NO
YES
YES

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Exemptions from Reporting
• Small manufacturer
• Annual sales (w/parent company) less than $4 million
• Annual sales (w/parent company) less than $40 million AND annual production
volume of the chemical substance is less than 100,000 lbs
• Research and development substances
• Chemical substance imported as part of an “article”
• Metal, plastic, wire, carpet, plywood, etc.

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Production Threshold Examples
Site A imports and manufactures Chemical X in the following annual
amounts:
22,000 lbs manufactured
4,000 lbs imported
Is Chemical X reportable?
Site B manufactured 30,000 lbs of Chemical Y in 2015. They directly
exported 25,000 lbs and sold the remaining 5,000 lbs in the US. Is
Chemical Y reportable?
YES!!
YES!!

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Getting Started – Reportable Information
I. Did you manufacture
(including import) 25,000 lb
or more of the chemical
substance at a single site?
J. Is your chemical substance
subject to full reporting due
to is TSCA regulatory or
consent agreement status?
L. Is your chemical substance
listed as a chemical for which
there is low current interest
in the CDR processing and
use information?
K. Is your chemical
substance listed as a
petroleum process
stream?
YES
NO
COMPLETE PARTS I, II, & III OF FORM U.
NO
NO
YES
YES
YES
NO

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Exemptions from Part III Reporting
• Listed petroleum process streams
• 40 CFR 711.6(b) Table 1
• Don’t include streams sold separately in their “pure” state
• Butane, propane, ethane, benzene, toluene, sulfur, etc.
• Listed as chemical with low current interest
• 40 CFR 711.6(b) Table 2
• Hydrogen
• CO2

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Partially Exempt from Reporting?
In 2015 Site A manufactures and distributes 120,000 lbs of Diesel Fuel.
Is the substance partially exempt from reporting?
Yes – many different forms of diesel
are on the exemption Table 1.
In 2015 Site B manufactures and distributes 50,000 lbs of Toluene. Is
the substance partially exempt from reporting?
No – The Toluene is sold in it’s “pure”
state, and above the threshold.

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Getting Started – Best Practices
• Block Flow Diagrams (BFD)
• 2006 and 2012 reports
• Identify new units or products since 2012 report
• Best sources for information
• Accounting reports: annual breakdowns of
substances manufactured/imported
• Charge and yield, process inventory, receipts &
shipments, etc.

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Refineries and TSCA CDR
• Most substances are exempt from Part III
Reporting
• Refinery fuel gas and off-gases are fully
exempt from reporting
• Breakup substances unit by unit
• Substances shipped off-site not in Exemption
Table 1 are Part III reportable
• “Pure” form substances

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Refinery Example
Which of the following substances would be reportable in the 2016
CDR?
Heavy Straight Run 70,000 lbs
FCC Gasoline/Naphtha 50,000 lbs
Fuel Gas 110,000 lbs
Butane (shipped off-site) 25,000 lbs
Coke (shipped off-site) 100,000 lbs
Vacuum Gas Oil 15,000 lbs
Hydrogen (shipped off-site) 35,000 lbs
Sulfur (shipped off-site) 50,000 lbs
Which would be Part III reportable?

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Importers and TSCA CDR
• Importer is entity that is directly responsible for importing the substance
• Typically finished gasolines and diesels
• No generic “finished gasoline” in TSCA Inventory
• Mixture of chemical substances
• Breakdown into the individual components
• Work with best data available
• Speciation's/lab analyses
• Sulfur and benzene reports
• SDS (formerly MSDS)

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Importer Example
You import 16,000 bbl (~4,000,000 lbs) Regular Gasoline and 3,000 bbl
(~700,000 lbs) Premium Gasoline in a single year. It is determined that
the annual average concentration (by weight) of Benzene in the
Regular Gasoline is 0.55% and 0.57% in Premium Gasoline. Do you
have to report Benzene in the CDR?
Benzene in Regular Gasoline: 4,000,000 𝑙𝑙𝑙𝑙𝑙𝑙 𝑥𝑥
0.55
100
= 22,000 𝑙𝑙𝑙𝑙𝑙𝑙
Benzene in Premium Gasoline: 700,000 𝑙𝑙𝑙𝑙𝑙𝑙 𝑥𝑥
0.57
100
= 3,990 𝑙𝑙𝑙𝑙𝑙𝑙
Total Imported Benzene: 22,000 𝑙𝑙𝑙𝑙𝑙𝑙 + 3,990 𝑙𝑙𝑙𝑙𝑙𝑙 = 𝟐𝟐𝟐𝟐, 𝟗𝟗𝟗𝟗𝟗𝟗 𝒍𝒍 𝒍𝒍𝒍𝒍

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Upstream Oil and Gas and TSCA CDR
• Most products fully exempt
• Crude oils
• Natural gases
• Condensates
• Water
• If you do sell anything after any processing (aside from 3 phase
separation), it could be reportable
• Methane, ethane, propane, and butane

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Evaluating Naturally Occurring Exemption
• Chemical substances that are removed/isolated from nature by physical or
natural means are typically considered Naturally Occurring.
• Using water to extract a chemical substance from a naturally occurring
substance is considered a natural means of removal.
• Using any other solvent is not considered a natural means of removal and
would result in the extracted substance potentially reportable.

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Chemical Processors and TSCA CDR
• Vary greatly
• Petrochemical
• Ethanol plants
• Inventory reports
• Substance by substance
determination

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Tips and Tricks
• CDX
• Verify accounts are current
• Plenty of time data entry
• Hotline can be very useful
• Verify accuracy of substance list and
documentation
• Annual variations impacting
substance list
• Check imports/exports
• Check storage tank contents
• Verify CBI status
• Annually Update CDR

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Becca Bradley
Environmental Engineer
Bbradley@trihydro.com