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Book Review: Guidance for Reporting Persistent, Bioaccumulative, Toxic (PBT) Chemicals from Aluminum Operations
12-27-02
Publisher: The Aluminum Association
The first edition of Guidance for Reporting Persistent, Bioaccumulative, Toxic (PBT) Chemicals from Aluminum Operations was issued in March 2001 by The Aluminum Association PBT Work Group. This document is provided to serve as guidance for aluminum producing facilities to estimate releases to the environment for PBT chemicals for purposes of Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 Toxics Release Inventory (TRI) reporting. The Environmental Protection Agency (EPA) promulgated the final rule for Toxics Release Inventory reporting of Persistent, Bioaccumulative, Toxic compounds on October 29, 1999. The Aluminum Association PBT Work Group, consisting of representative of Member companies, Association staff, and expert consultants, produced this guidance document in order to aid facilities managers in estimating releases of PBT chemicals for reporting under TRI.
This 129-page document begins with an introductory chapter providing an updated list of PBT chemicals and their reporting thresholds and reporting requirements, with specific attention to changes. The PBT rule includes reporting for three chemical compound categories: Dioxin and dioxin-like compounds (D/F); mercury compounds; and polycyclic aromatic compounds (PACs). In addition, polychlorinated biphenyls (PCBs) are listed. This introductory section also provides general reporting guidance, specifically the EPA hierarchy of approaches for estimating annual releases of PBT chemicals.
Specific release factors for the PBT chemicals that have been developed are then discussed in the next four chapters of the report, organized by the types of aluminum operations. In each case, the Work Group assessed the EPA PBT reporting requirements using a combination of extensive operational experience supported by an extensive search and review of literature sources. The Primary Aluminum Reporting Guidance notes that the PBT chemicals that may be manufactured, processed, or otherwise used at primary aluminum operations includes PACs, generally found in the coal tar pitch used to make carbon anodes and mercury, which is sometimes found in very low quantities in alumina. The secondary aluminum operations addressed include aluminum scrap shredding, scrap drying/delacquering/decoating, thermal chip drying, furnace operations such as melting, holding, refining, fluxing, and alloying, in-line fluxing, and dross cooling.
The result of the Work Group's assessment in this area is that PBT chemicals including dioxin and furans, mercury, PCBs, octachlorostyrene, and hexachlorobenzene may be released from secondary operations. Regarding alumina refining, specifically the Bayer Process, the main PBT chemical involved is mercury, which may be present in bauxite at concentrations up to 400 ppb, depending on the physical location from which the bauxite was mined. Finally, regarding fabricating facilities hat are involved in the extrusion, rolling, and shaping of aluminum, the Work Group's assessment as that these facilities are not likely to be impacted by the new reporting requirements for PBT chemicals. In all cases, the guidance document notes that The Aluminum Association has made every effort to provide information that best represents operations in general. However, each facility is responsible for determining what constitutes its best readily available information and to use that information in reporting. Chapter VI provides greater detail on the methodology used in the literature search and resulting key peer-reviewed articles used as background for the report.
A series of five Appendices provides additional information on secondary aluminum emission profiles and factor summaries for dioxin and furan compounds as well as mercury compounds, guidelines for threshold determination, Form R completion, and sampling and analysis for dioxin and dioxin-like compounds, and emission factors for natural gas combustion.
This publication is available from the Aluminum Association on CD-ROM. In addition to the PBT Guidance Document itself in PDF format, three key EPA documents are included as supporting files entitled "Guidance for Reporting Toxic Chemicals within the Dioxin and Dioxin-like Compounds Category", "EPCRA Section 313 Questions and Answers, Revised 1998 Version", and "Toxic Chemical Release Inventory Reporting Forms and Instructions".
Article provided courtesy of The Aluminum Association - www.aluminum.org
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