Industry Questions & Answers for Reporting
Dioxin and Dioxin-Like Compounds Under EPCRA § 313
The Chlorine Chemistry Division of the American Chemistry
Council prepared this document to briefly answer a number
of common questions on Toxics Release Inventory (TRI) reporting
requirements for dioxin and dioxin-like compounds. For
more detailed information, see EPAs Guidance for
Reporting Toxic Chemicals within the Dioxin and Dioxin-like
Compounds Category (December 2000). EPAs reporting
guidance is available on the Agencys website at http://www.epa.gov/tri/TRIdioxinguidance.pdf.
What is the reporting threshold for the dioxin and dioxin-like
The reporting threshold for the dioxin category is 0.1
gram total mass of all 7 dioxin and 10 furan congeners
in the dioxin and dioxin-like compounds category.
What level of reporting precision is required?
Once the threshold is met, facilities should report emissions
at the level of precision supported by the underlying data
and the estimation techniques on which the estimate is based.
However, the smallest quantity that should be reported on
Form R is 0.0001 gram (100 microgram). If the amount
is 0.00005 microgram or less, zero can be entered. If
the amount is between 0.00005 and 0.0001 gram, then you can
enter either 0.0001 gram or the actual number.
How will dioxin data be reported?
EPA will require reporting of the total mass of all 17 dioxin
and furan congeners. Data will not be reported on a
Toxic Equivalent (TEQ) basis.
If you have information on the distribution of the congeners
for your facility, you must report:
- either the distribution that best represents the distribution
of the total quantity of dioxin and dioxin-like compounds
released to all media from the facility;
- or its one best media-specific distribution.
To report this distribution, you will provide a percentage
for each of the 17 compounds.
Do the de minimis exemption, Form A reporting,
and range reporting apply to the dioxin and dioxin like compounds
No. The de minimis exemption will not be applicable
to the dioxins category or to other PBTs, except for purposes
of the supplier notification requirement. EPA has also
excluded PBTs from the "TRI Alternate Threshold for Facilities
with Low Annual Reportable Amounts." Therefore submitting
a Form A rather than a Form R is not an option for these chemicals.
In addition, no ranges can be used for reporting PBTs.
What activities are covered by the qualifier for the dioxin
and dioxin-like compounds category?
The final rule has the following activity qualifier for the
- Manufacturing; and the processing or otherwise use
of dioxin and dioxin-like compounds if the dioxin and dioxin-like
compounds are present as contaminants in a chemical and
if they were created during the manufacturing of that chemical.
All dioxin and dioxin-like compounds manufactured by your
facility must be applied towards the 0.1 gram manufacturing
threshold and included in release and other waste management
calculations. "Manufacture" includes coincidental
production during any process, as well as importation.
Under the activity qualifier, a facility must account for
dioxins present as contaminants in a chemical that is processed
or otherwise used, but only if the dioxins were created during
the manufacturing of that chemical.
What reporting requirements will be passed on to downstream
If your customers are covered under EPCRA § 313, they may
have to account for dioxins present as contaminants in your
products. According to EPAs reporting guidance,
if you make chemical A and incidentally manufacture dioxins
as contaminants in that chemical, then customers that process
or otherwise use chemical A would have to include these dioxins
in their threshold determinations as well as in release and
other waste management calculations. However, if a customer
then uses chemical A to make chemical B and chemical B contains
dioxins merely because they were in chemical A, a facility
using or processing chemical B would not have to report the
dioxins in chemical B.
What chemicals are identified in the guidance as potentially
containing by-product dioxins?
EPAs reporting guidance identifies several chemicals
as having the potential to contain dioxins created as byproducts
during the manufacturing process for those chemicals.
The list includes ethylene dichloride manufactured by oxychlorination.
In response to public comments, EPA removed vinyl chloride
and PVC from the original draft list.
Chlorine and sodium hydroxide are not listed.
Nevertheless, reporting requirements apply to dioxin created
during the manufacturing process of any chemical, whether
listed in the guidance or not.
How will facilities estimate releases?
EPA describes 3 different approaches for estimating releases:
- Facility-specific actual monitoring data,
- Facility-specific emission factors (based on specific
monitoring data from a similar facility)
- EPAs default emission factors for those industrial
sectors listed in the guidance.
In general, EPA considers these three approaches to be hierarchical.
However, the facility operator is encouraged to exercise "best
engineering judgment" when selecting the appropriate approach.
When documenting the annual releases and other waste management
quantities, EPA recommends that you indicate which approach
was used in deriving the estimate.
What emission factors are provided?
EPAs reporting guidance provides facility-specific
emission factors for a number of source categories.
Of particular interest to the chlorine industry are emission
factors for 1) hazardous waste combustion facilities
and 2) commercial boilers and industrial furnaces that burn
hazardous waste as an auxiliary fuel. The guidance does not
provide emission factors for chlor-alkali manufacture or other
chlorine industry processes.
How should facilities treat "non-detects" of dioxins?
According to EPAs reporting guidance, monitoring data
and emission factors determined for your facility should be
reported "in a manner consistent with the methods and procedures
that EPA has developed for determining if these compounds
are present in various industrial processes." If the
method treats non-detects as zero (e.g., Method 1613, Method
23), then they should be reported as zero. However,
if a facility has better information than is provided by these
methods, that information should be used.
EPAs reporting guidance states that if the method being
used by a facility to detect dioxins is not an EPA approved
method and the detection level being used is not as sensitive
as those approved for use under EPA methods, then the facility
must use "reasonable judgment" as to the presence
and amount of a listed toxic chemical, based on the best readily
available information. If the reportable toxic chemical
is known to be present, a concentration equivalent to half
the detection limit should be used.